In a recent decision, the GAO played seventh-grade English teacher, reminding offerors to use their own words to get full proposal-writing credit.
In the case of Res Rei Development, Inc., B-410466.7 (Oct. 16, 2015), the agency found a proposal unacceptable because, in its view, the offeror had simply restated the terms of the solicitation. The GAO agreed with the agency’s decision, writing that a proposal that merely restates the requirements of the solicitation without adding detail and insight into how the offeror would manage and execute the contract can be found unacceptable.
The Res Rei Development protest arose out of a United States Special Operations Command (“SOCOM”) solicitation for support services such as acquisition, budget planning, business process re-engineering, and program planning services. Res Rei Development, Inc. was one of several offerors submitting proposals.
In its review of initial proposals, SOCOM assigned Res Rei an “unacceptable” score for its task order management plan. Explaining its evaluation under this subfactor, SOCOM wrote: “The business process as depicted in [Res Rei’s] proposal is a direct restatement of the government’s [Statement of Work] requirement and the offeror failed to provide details and insight into ‘how’ their technical approach will effectively manage and execute” the required work. SOCOM excluded Res Rei from the competitive range, in part because of Res Rei’s “unacceptable” task order management plan.
Res Rei filed a GAO bid protest challenging its exclusion from the competitive range. Res Rei argued, in part, that it should not have received an unacceptable score for its task order management plan.
The GAO disagreed. Comparing Res Rei’s proposal to the solicitation’s SOW, the GAO found “substantial similarity” between the two. GAO wrote that Res Rei’s approach to the task order management plan consisted of “largely restating the SOW requirements . . ..” The GAO continued:
Given Res Rei’s response to the SORDAC support task order management plan requirements, consisting largely of a generic management approach and a restatement of the SORDAC SOW requirements . . . we find reasonable both the agency’s assessment that Res Rei failed to demonstrate a task order technical approach to execute all of the requirements of the SORDAC SOW and its consequent assignment of an unacceptable rating in this area.
The GAO denied Res Rei’s protest.
The Res Rei decision is a good reminder that an acceptable technical response may require more than merely restating the requirements of the solicitation. When it comes to proposal-writing, contractors should rely on the axiom of those seventh -grade English teachers: use your own words.