An agency’s cost realism evaluation was improper because the agency “mechanically” compared an offeror’s proposed staffing to an undisclosed government estimate.
In a recent bid protest decision, the GAO held that it was improper for the agency to apply its own estimates for labor hours and costs without considering the protester’s unique technical approach.
The GAO’s decision in CFS-KBR Marianas Support Services, LLC; Fluor Federal Solutions LLC, B-410586 et al. (Jan. 2, 2015) involved a Navy procurement for base operations support services. The solicitation contemplated the award of a cost-reimbursement contract, which was to be awarded on a “best value” basis. Among the evaluation factors, the Navy was to consider offerors’ proposed staffing and resources.
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