Protests Against Improper Evaluation

In reviewing protests against allegedly improper evaluations, the GAO will examine the record to determine whether the agency’s determination was reasonable and consistent with the evaluation criteria listed in the solicitation, Matter of: Commandeer Constr. Co. LLC, B-405771, 2011 CPD ¶ 287 (Comp. Gen. Dec. 29, 2011); Hattal & Assocs., B-243357, B-243357.2, 91-2 CPD ¶ 90 (Comp. Gen. July 25, 1991), and an agency must document its judgments in sufficient detail to show that they are not arbitrary. Matter of: Gov’t Acquisitions, Inc., B-401048, 2009 CPD ¶ 137 (Comp. Gen. May 4, 2009); U.S. Defense Sys., Inc., B-245563, 92-1 CPD ¶ 89 (Comp. Gen. Jan. 17, 1992). The amount and detail of documentation necessary to demonstrate that an agency’s judgments were reasoned and rational will vary from procurement to procurement, and there is no absolute requirement that evaluation records must include narrative explanations for every score assigned. Matter of: Gov’t Acquisitions, Inc., B-401048, 2009 CPD ¶ 137 (Comp. Gen. May 4, 2009) (citing Champion-Alliance, Inc., B-249504, Dec. 1, 1992, 92-2 CPD ¶ 386 at 6-7 (contemporaneous summary evaluation narrative and post-protest amplification sufficient documentation)).

Updated: August 3, 2018