United States Government Accountability Office

Washington, DC 20548

Comptroller General

of the United States

Decision

Matter of: SENTEL Corporation

File: B-407060; B-407060.2

Date: October 26, 2012

John E. Jensen, Esq., Daniel S. Herzfeld, Esq., and Clare M. Cavaliero, Esq., 

Pillsbury Winthrop Shaw Pittman LLP, for the protester.

Ronald S. Perlman, Esq., and Alexander B. Ginsberg, Esq., Holland & Knight LLP, 

for National Technology Associates, Inc., the intervenor.

Maj. K. L. Grace Moseley and Capt. Tyler L. Davidson, Department of the Army, for 

the agency.

Linda C. Glass, Esq., and Guy R. Pietrovito, Esq., Office of the General Counsel, 

GAO, participated in the preparation of the decision.

DIGEST

1. Protest challenging an agency’s evaluation and selection decision is denied 

where the record demonstrates that the evaluation and selection decision were 

reasonable and consistent with the solicitation’s evaluation criteria. 

2. Protest that agency failed to conduct meaningful discussions is denied where the 

aspect of the protester’s quotation that was not discussed was not a deficiency or 

weakness, but reflected an approach that did not receive the maximum rating 

available.

DECISION

SENTEL Corporation, of Alexandria, Virginia, protests the issuance of a task order to 

National Technology Associates, Inc. (NTA), of Alexandria, Virginia, under request 

for quotations (RFQ) No. W91WAW-12-R-0060, issued by the Department of the 

Army for logistics contractor support services. The protester objects to the agency’s 

evaluation, discussions, and selection decision.

We deny the protest.

DOCUMENT FOR PUBLIC RELEASE

The decision issued on the date below was subject to 

a GAO Protective Order. This redacted version has 

been approved for public release.
Page 2 B-407060; B-407060.2 

BACKGROUND

The agency issued the RFQ via the General Services Administration (GSA) eBuy 

system on April 30, 2012, under Federal Acquisition Regulation (FAR) Subpart 8.4, 

to vendors holding GSA Logistics Worldwide Schedule 874V contracts. The RFQ 

provided for the issuance of a task order to provide logistics contractor support 

services for Department of the Navy air fleet readiness centers in California, 

Maryland and Virginia for a base year and 2 option years. Vendors were informed 

that the successful vendor would be selected on a best value basis, considering the 

following factors listed in descending order of importance: technical approach, 

personnel, past performance and price. RFP at 57. The technical approach factor 

was stated to be significantly more important than the personnel factor, which was 

slightly more important than the past performance factor. Id. All non-price factors 

combined were stated to be significantly more important than price. Id. 

With respect to the technical approach evaluation factor, vendors were instructed to 

demonstrate their understanding of the Performance Work Statement (PWS) work. 

Id. at 55. With respect to the past performance factor, vendors were required to 

provide not more than three relevant contracts performed within the last three years, 

and to explain how their experience was relevant to the analytical, technical, and 

administrative support work indentified in the PWS. Id. at 55-56. In this regard, the 

RFQ defined a relevant contract to be contracts with federal, state or local 

government entities or commercial entities that were similar in scope and complexity 

to the PWS requirements.1

 Id. at 56. 

The agency received five quotations, including SENTEL’s and NTA’s. The 

quotations were evaluated under the technical approach and personnel factors by

the agency’s source selection evaluation board (SSEB) and contracting officer, who 

was the source selection authority for this procurement. The contracting officer 

evaluated the quotations under the past performance factor. Contracting Officer’s 

Statement at 5-6. 

Discussions were conducted with all five vendors. SENTEL was asked to clarify its 

quotation with respect to its personnel and past performance references, see AR, 

Tab 24, Request for Clarifications, at 1, and advised of several evaluated 

weaknesses concerning specific PWS requirements. AR, Tab 29, Request for 

Clarifications and Final Revision, at 1-2. For example, SENTEL was advised that it 

failed to address the requirement or mention a process for generating estimates for 

special project workload. Id.

 1 The RFQ also stated that the scope of a contract related to the range of products 

and services provided and its dollar value. RFP at 56.

 SENTEL was also advised that its failure to mention 

the requirement to coordinate with supply technicians and the warehouse manager 
Page 3 B-407060; B-407060.2 

to reorder any items determined to be lost in shipment within 24 hours of the 

discovery was a significant weakness. Id.

NTA’s and SENTEL’s revised quotations were evaluated as follows:2

NTA SENTEL

Technical Approach Good Acceptable

Personnel Good Good

Past Performance Satisfactory Confidence Substantial Confidence

Contract #1 Somewhat Relevant Very Relevant

Contract #2 Somewhat Relevant Very Relevant

Contract #3 Somewhat Relevant Not Relevant

Price $12.8 million $12.6 million

Agency Report (AR), Tab 15, Source Selection Decision, at 10.

NTA’s good rating under the technical approach factor reflected the SSEB’s 

judgment that NTA’s quotation satisfied requirements and indicated a thorough 

approach and understanding. Id. at 11. NTA’s quotation was evaluated as having 

the following seven strengths (and no weaknesses): the use of an executive white 

paper to clearly demonstrate that the offeror understood the concept behind the 

requirements to proactively track and manage funding lines; quad charts to provide 

actionable data to decision makers; maintaining a list of obsolete parts to facilitate 

finding new sources for diminishing manufacturing sources and material shortages; 

creating an inaccurate tech data log book to exchange information with 

organizations responsible for technical publication revisions; shelf-life training; and 

periodic training of warehouse personnel. Id. The agency also found that NTA’s 

draft transition plan exceeded the PWS requirements by including several critical 

elements which would be of value to the government, such as, a sharepoint site to 

facilitate communication during the transition and identifying areas for improved 

efficiencies and notifying the government before implementation. Id.

 2 Quotations were evaluated under the technical approach and personnel factors as 

outstanding, good, acceptable, marginal or unacceptable. RFQ at 59. An 

acceptable rating reflected a proposal that met the requirements, indicated an 

adequate approach and understanding of the requirements, and had strengths and 

weaknesses that were offsetting or would have little or no impact on contract 

performance. Id. at 59. Past performance was evaluated as substantial confidence, 

satisfactory confidence, limited confidence, no confidence, and unknown confidence. 

Id. A satisfactory confidence rating reflected that the agency had a reasonable 

expectation that the vendor would successfully perform the required effort. Id.
Page 4 B-407060; B-407060.2 

NTA’s satisfactory confidence rating reflected the contracting officer’s assessment 

that NTA had provided three references that were somewhat relevant to the RFQ 

work. AR, Tab 14, Past Performance Assessment, at 2-4. The contracting officer 

evaluated NTA’s past performance as satisfactory confidence based upon an 

interview with one reference’s contracting officer’s representative (COR) and 

information in the Past Performance Information Retrieval System (PPIRS) for 

another reference. NTA’s third reference was a recently awarded contract, for which 

there was no past performance assessment available.3 Id. at 3.

SENTEL’s acceptable rating under the technical approach factor reflected the 

SSEB’s judgment that SENTEL’s quotation demonstrated its ability to satisfy the 

requirements and indicated an adequate approach and understanding. Id. at 12. 

SENTEL’s quotation was evaluated as having the following three strengths (and no 

weaknesses): organizational work structure; management structure including 

detailing the role and responsibilities of the teams; and risk mitigation strategy in the 

draft transition plan. Id.

SENTEL’s substantial confidence rating under the past performance factor reflected 

the contracting officer’s finding that two of the protester’s references were very 

relevant and SENTEL had satisfactory to very good performance for these 

references. AR, Tab 14, Past Performance Assessment, at 9-10. The contracting 

officer found SENTEL’s third reference to be not relevant. Id. at 10.

The contracting officer concluded that NTA’s quotation reflected the best value to the 

agency. Specifically, the contracting officer found that NTA’s thorough 

understanding of the requirement, acceptable mix of personnel, and satisfactory past 

performance confidence rating showed a “great likelihood of successful 

performance.” AR, Tab 15, Source Selection Decision, at 16. In this regard, she 

found that NTA’s quotation was superior to SENTEL’s under the technical approach 

factor, noting that NTA’s evaluated strengths under this factor outweighed SENTEL’s 

strengths. Id. at 17. She also found that, although both vendors’ quotations were 

rated good under the personnel factor, NTA’s quotation was in fact superior to 

SENTEL’s because NTA would provide two additional logisticians. Id. In assessing 

the overall merit of the firms’ quotations, the contracting officer concluded that NTA’s 

superiority under the technical approach and personnel factors outweighed 

SENTEL’s higher rating under the past performance factor and lower price. Id.

 3 Although the contracting officer stated in her source selection decision that she 

obtained past performance information from PPIRS for two of NTA’s references, the 

past performance assessment indicated that there was information in PPIRS with 

respect to only one of NTA’s references. Compare AR, Tab 14, Past Performance 

Assessment, at 3-4, with AR, Tab 15, Source Selection Decision, at 14.

at 

17. 
Page 5 B-407060; B-407060.2 

The task order was issued to NTA, and this protest followed a debriefing.

DISCUSSION

Technical Approach Factor

SENTEL objects to the acceptable rating assigned to its quotation under the 

technical approach factor, arguing that its quotation should have received a good 

rating under this factor, given its three evaluated strengths and lack of weaknesses.4 

Protest at 8.

In reviewing an agency’s evaluation in an FSS competitive acquisition, we will not 

reevaluate quotations, but will examine the record to ensure that the agency’s 

evaluation was reasonable and consistent with the terms of the solicitation. 

Beckman Coulter, Inc., B-405452, Nov. 4, 2011, 2011 CPD ¶ 231 at 5; Maybank 

Indus., LLC, B-403327, B-403327.2, Oct. 21, 2010, 2010 CPD ¶ 249 at 5. The 

essence of an agency’s evaluation is reflected in the evaluation record itself, not the 

adjectival ratings. Stateside Assocs., Inc., B-400670.2, B-400670.3, May 28, 2009, 

2009 CPD ¶ 120 at 8. It is well established that ratings, be they numerical, 

adjectival, or color, are merely guides for intelligent decision making in the 

procurement process. Burchick Constr. Co., B-400342.3, April 20, 2009, 2009 CPD 

¶ 102 at 4-5. There is no legal requirement that an agency must award the highest 

possible rating, or the maximum point score, under an evaluation factor simply 

because the proposal or quotation contains strengths and/or is not evaluated as 

having any weaknesses. See Applied Tech. Sys., Inc., B-404267, B-404267.2, 

Jan. 25, 2011, 2011 CPD ¶ 36 at 9.

Here, the agency gave ample consideration to the qualitative differences in NTA’s 

and SENTEL’s quotations. The record shows that the SSEB and contracting officer 

recognized SENTEL’s evaluated strengths and lack of weaknesses under the 

technical approach factor, but concluded that SENTEL’s quotation only 

demonstrated an adequate approach and understanding of the requirements. See

 4 SENTEL also complains that the SSEB initially identified a fourth strength involving 

the protester’s quality management plan that was not included as a strength in the 

final SSEB evaluation report. Supplemental Protest at 13. The agency explains that 

after several rounds of discussions, it no longer considered the protester’s quality 

management plan to be a strength. SSEB Chairman Statement at 2. Although 

SENTEL disagrees with this evaluation judgment, it has not shown it to be 

unreasonable.

AR, Tab 15, Source Selection Decision, at 12; Tab 13, Technical Approach 

Consensus Evaluation, at 1. In this regard, the SSEB recognized that SENTEL’s 
Page 6 B-407060; B-407060.2 

quotation exceeded expectations with respect to certain PWS areas but also noted 

that its quotation demonstrated a lack of understanding of the basic requirements in 

other areas. AR, Tab 13, Technical Approach Consensus Evaluation, at 1. 

Moreover, the SSEB and contracting officer noted that none of SENTEL’s evaluated 

strengths involved the core areas of the PWS, whereas six of NTA’s seven 

evaluated strengths did involve core areas. See Contracting Officer’s Statement 

at 6; SSEB Chairman Statement at 4. Based upon this evaluation, the agency 

concluded that SENTEL’s quotation merited an acceptable, and not good, rating 

under the technical approach factor. 

Although the protester disagrees with the agency’s judgment in this regard, this does 

not show that the agency acted unreasonably. We have found that where, as here, 

an agency reasonably considers the underlying bases for its ratings, including the 

advantages and disadvantages associated with the specific content of competing 

offers or quotations, in a manner that is fair and consistent with the terms of the 

solicitation, the protester’s disagreement over the adjectival or color ratings is 

essentially inconsequential in that it does not affect the reasonableness of the 

judgments made in the source selection decision. See Sherrick Aerospace, 

B-310359.2, Jan. 10, 2008, 2008 CPD ¶ 17 at 6. 

Past Performance Factor

The protester complains that the agency unreasonably found NTA’s past 

performance merited satisfactory confidence where the agency determined that 

NTA’s experience was only somewhat relevant. Protest at 16. The protester 

contends that NTA’s past performance should have been evaluated as limited 

confidence. Id. The protester also complains that the Army unreasonably 

considered information provided by a COR concerning NTA’s past performance, 

arguing that the COR was not authorized to provide the information. Supp. Protest 

at 9.

Where a solicitation contemplates the evaluation of vendors’ past performance, the 

agency has the discretion to determine the scope of the performance history to be 

considered, provided all quotations are evaluated on the same basis and the 

evaluation is consistent with the terms of the solicitation. Weidlinger Assocs., Inc., 

B-299433, B-299433.2, May 7, 2007, 2007 CPD ¶ 91 at 8. Regarding the relative 

merits of vendors’ past performance information, this matter is generally within the 

broad discretion of the contracting agency, and our Office will not substitute our 

judgment for that of the agency. See e.g., Clean Harbors Envtl. Servs., Inc., 

B-296176.2, Dec. 9, 2005, 2005 CPD ¶ 222 at 3. A protester’s mere disagreement 

with the agency’s judgment does not establish that an evaluation was improper. Id.

First, we find no merit to SENTEL’s complaint that the Army unreasonably 

considered information provided by a COR for one of NTA’s references. An agency 

is generally not precluded from considering any relevant past performance 
Page 7 B-407060; B-407060.2 

information, regardless of its source. See e.g., NVT Techs., Inc., B-297524, 

B-297524.2, Feb. 2, 2006, 2006 CPD ¶ 36 at 5. In this regard, SENTEL does not 

argue that the COR for this reference did not have sufficient basis of knowledge to 

render an informed opinion regarding NTA’s performance. Rather, SENTEL 

appears to mistakenly believe that the agency may only consider the opinion of a 

contracting officer.

We also find no merit to SENTEL’s objection that the Army could not have found 

NTA’s experience somewhat relevant because the value of these projects was 

significantly below the task order value here. The RFQ defined somewhat relevant 

to be where the present or past performance effort involved some of the scope and 

magnitude of the effort and complexities of the work solicited here. RFQ at 59. The 

Army found that, although NTA’s references were not of the value of the task order, 

they nevertheless reflected some of the scope, magnitude, and complexity of the 

task order work. See AR, Tab 14, Past Performance Assessment, at 2-4. Although 

SENTEL disagrees with the agency’s judgment in this regard, it has not shown it to 

be unreasonable.

Discussions

The protester also complains that the Army’s discussions with SENTEL were not 

meaningful. Specifically, SENTEL contends that the Army found a significant 

weakness in its quotation under the technical approach factor, because SENTEL 

had not provided descriptions of processes the firm would use to perform certain 

PWS requirements. The protester states that the Army did not disclose this concern 

in its discussions with SENTEL. Supp. Protest at 7; Protester’s Comments at 17.

When an agency engages in discussions with a vendor, the discussions must be 

"meaningful," that is, sufficiently detailed to lead the vendor into the areas of its 

quotation requiring amplification or revision. AINS, Inc., B-400760.4, B-400760.5, 

Jan. 19, 2010, 2010 CPD ¶ 32 at 5. To satisfy this obligation to conduct meaningful 

discussions, an agency must lead firms into the areas of their proposals or 

quotations that reflect deficiencies or significant weaknesses; that is, an agency 

must identify aspects of the firm’s proposal or quotation that, unless further 

addressed, would prevent the firm from having a reasonable chance for award. 

Northrop Grumman Info. Tech., Inc., B-290080 et al., June 10, 2002, 2002 CPD 

¶ 136 at 6. An agency is not required to conduct all-encompassing discussions or to 

discuss every element of a proposal or quotation receiving less than the maximum 

rating. American Ordnance, LLC, B-292847 et al., Dec. 5, 2003, 2004 CPD ¶ 3 at 4-

5; Information Sys. Tech. Corp., B-289313, Feb. 5, 2002, 2002 CPD ¶ 36 at 5.

Here, the record shows that, contrary to the protester’s arguments, the Army found 

no weaknesses in SENTEL’s final revised quotation under the technical approach 

factor. See AR, Tab 2, Source Selection Decision, at 11. Rather than being a 

deficiency or significant weakness, the Army’s “concern” with SENTEL’s failure to 
Page 8 B-407060; B-407060.2 

provide a detailed description of some of its processes to perform PWS work 

reflected the agency’s weighing of the firm’s evaluated strengths and comparing the 

merits of SENTEL’s approach to that of NTA’s. See Supp. AR at 16-17. We find 

that the Army’s discussions with SENTEL were meaningful and that the Army was 

not required to discuss this concern with the firm.

Source Selection Decision

SENTEL raises numerous challenges to the Army’s source selection decision. In 

addition to arguing that its quotation should have been selected based upon its lower 

price, SENTEL complains that the selection decision contains errors and does not 

sufficiently document the basis for the contracting officer’s judgment.5

Where, as here, a procurement conducted pursuant to FAR subpart 8.4 provides for 

award on a “best value” basis, it is the function of the source selection authority to 

perform a price/technical tradeoff, that is, to determine whether a quotation's 

technical superiority is worth its higher price. InnovaTech, Inc., B-402415, Apr. 8,

2010, 2010 CPD ¶ 94 at 6; The MIL Corp., B-297508, B-297508.2, Jan. 26, 2006, 

2006 CPD ¶ 34 at 13. While we are mindful that, under simplified acquisition 

procedures, limited documentation of the source selection is permissible, the agency 

must at least provide a sufficient record to show that the source selection was 

reasonable. FAR § 8.405-2(e) (minimum documentation requirements include 

documenting the rationale for any tradeoffs when establishing a BPA or placing an 

order); e-LYNXX Corp., B-292761, Dec. 3, 2003, 2003 CPD ¶ 219 at 8 (even for 

procurements conducted under simplified acquisition procedures, an agency must 

have a sufficient record to allow for a meaningful review). 

As an initial matter we disagree with the protester that the agency’s source selection 

decision in this FSS procurement is inadequately documented. In her decision, the 

contracting officer describes the SSEB’s evaluation of each vendor’s quotation under 

each factor, detailing the evaluation ratings and describing the evaluated strengths 

and weaknesses supporting the respective ratings. The contracting officer also 

 5 In its supplemental protest, SENTEL complained that the agency failed to inform it 

of a significant weakness under the technical approach factor, citing the agency’s 

legal memorandum that described SENTEL’s failure to fully describe its process for 

performing the PWS as a significant weakness. See Supp. Protest at 8. The Army 

contends that SENTEL has misread the agency’s legal memorandum and states that 

it found no weaknesses or significant weaknesses in SENTEL’s quotation under the 

technical approach factor. See Supp. AR at 16-17. Our review confirms the Army’s 

position; the contemporaneous record shows that the agency found no weaknesses 

or significant weaknesses in SENTEL’s quotation under this factor. See AR, Tab 15, 

Source Selection Decision, at 11.
Page 9 B-407060; B-407060.2 

details the basis for her conclusion that the technical merit of NTA’s higher-priced 

quotation outweighed SENTEL’s better past performance rating and lower price.

We also do not agree with SENTEL that two “alleged” factual errors in the selection 

decision call into question the reasonableness of the contracting officer’s best value 

judgment. Specifically, SENTEL complains that, although the SSEB found the firm’s 

draft transition plan to be a strength, the contracting officer stated in her selection 

decision that SENTEL’s draft transition plan satisfied the PWS requirements “with no 

weaknesses or strengths.” AR, Tab 2, Source Selection Decision, at 12. The record 

shows, however, that the contracting officer specifically recognized that SENTEL’s 

risk mitigation strategy in its draft transition plan had been evaluated as a strength, 

but also recognized that the transition plan would only be in effect for a short period 

of time and would have little impact on performance. See AR, Tab 15, Source 

Selection Decision, at 12; see also Contracting Officer’s Statement at 6.6

SENTEL also complains that the contracting officer in weighing NTA’s past 

performance erroneously stated that she received past performance information 

from PPIRS for two of NTA’s references, when in fact she obtained PPIRS 

information for only one reference. Protester’s Comments at 7. The contracting 

officer acknowledges that this statement in the selection decision is in error. See

Supp. Contracting Officer’s Statement at 8. Nevertheless, this minor misstatement 

does not call into question the contracting officer’s judgment regarding the NTA’s 

past performance or with respect to her cost/technical tradeoff. As noted above, the 

contracting officer performed the past performance assessments and obtained 

adequate information supporting her evaluation. Although she may have misstated 

the source for NTA’s past performance information with respect to one reference, 

SENTEL has not shown any basis to question the information received with respect 

to that reference.

Finally, we find no merit to SENTEL’s disagreement with the contracting officer’s 

judgment that NTA’s higher-priced quotation reflected the best value to the agency. 

Source selection officials have considerable discretion in making cost/technical 

tradeoff decisions. Their judgments in these tradeoffs are by their nature subjective; 

 6 Although SENTEL contends that we should give little weight to the agency’s posthoc explanation of the “errors” in the contracting officer’s selection decision, citing 

Boeing Sikorsky Aircraft Support, B-277263.2, B-277263.3, Sept. 29, 1997, 97-2 

CPD ¶ 91 at 15, we will consider post-protest explanations that, as here, provide a 

detailed rationale for contemporaneous conclusions, and simply fill in previously 

unrecorded details. In reviewing such explanations, we consider whether the 

explanations are credible and consistent with the contemporaneous record. NWT, 

Inc.; PharmChem Labs., Inc., B-280988, B-280988.2, Dec. 17, 1998, 98-2 CPD 

¶ 158 at 16.
Page 10 B-407060; B-407060.2 

nevertheless, the exercise of these judgments must be reasonable and must bear a 

rational relationship to the announced criteria upon which competing offers are to be

selected. An agency may select the higher-rated, higher-priced quotation as 

reflecting the best value to the agency where that decision is consistent with the 

evaluation criteria and the agency reasonably determines that the technical 

superiority of the higher-priced quotation outweighs the price difference. 

InnovaTech, Inc., supra. SENTEL has not shown the contracting officer’s judgment 

here to be unreasonable or inconsistent with the solicitation’s criteria.

The protest is denied.

Lynn H. Gibson

General Counsel