Protests & Claims Brief
Agency Unreasonably Used Fixed-Price Labor Rates to Conduct Price Realism Analysis for Cost Reimbursement Contract; GAO B-413386.2, CALNET Inc.
Protest challenging agency’s cost realism evaluation is sustained, where the agency used labor rate data from fixed-price contracts to evaluate rates proposed for a cost-reimbursement contract, though the fixed-price rates had never been evaluated for realism and the rates were proposed for geographic areas with lower cost labor markets; and protest that agency unreasonably found several proposals equivalent is sustained where, although the agency’s evaluators identified detailed strengths and weaknesses in each proposal, and also ranked the proposals based on these non-cost findings, the agency’s source selection decision relied entirely on the adjectival ratings assigned to the proposals in making a finding of equivalence.
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