BNUMBER:  B-260983.3
DATE:  October 13, 1995
TITLE:  Safeguard Maintenance Corporation

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DOCUMENT FOR PUBLIC RELEASE
A protected decision was issued on the date below and was subject to a 
GAO Protective Order.  This version has been redacted or approved by 
the parties involved for public release.
Matter of:Safeguard Maintenance Corporation

File:     B-260983.3

Date:October 13, 1995

Thomas J. Madden, Esq., Fernand A. Lavallee, Esq., and Carla Draluck 
Craft, Esq., Venable, Baetjer, Howard & Civiletti, L.L.P., for the 
protester.
Donald M. Suica, Esq., Duane M. Zezula, Esq., and Corlyss Drinkard, 
Esq., Department of the Treasury, for the agency.
Charles W. Morrow, Esq., and James A. Spangenberg, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Protest that proposal was improperly excluded from the competitive 
range is sustained where the procuring agency misevaluated the 
proposal in three significant respects and the record indicates that 
under a proper evaluation the proposal may have received a higher 
technical score than at least one higher-priced competitive range 
proposal.

DECISION

Safeguard Maintenance Corporation protests the exclusion of its 
proposal from the competitive range under request for proposals (RFP) 
No. IRS-94-0005, a total small business set-aside, issued by the 
Department of the Treasury, Internal Revenue Service (IRS), for 
janitorial services.

We sustain the protest.

The IRS issued the RFP on April 21, 1994, to procure janitorial, lawn 
and grounds maintenance, trash removal, snow removal, and related 
services at the Martinsburg Computing Center (MCC), Martinsburg, West 
Virginia, for a base period with 4 option years.  The RFP solicited 
technical proposals and line item prices for fixed price and 
indefinite quantity work at the MCC main computing center and an MCC 
annex that was under construction.[1]  The RFP contained detailed 
cleaning and quality requirements, including frequency of cleaning.  
Among the services described in section J of the RFP was "utility 
work," which required the contractor to provide hours on a daily 
basis, beyond those required to perform the basic contract work, to 
cover other work that may be ordered by the contracting officer's 
technical representative (COTR).

Award under the RFP was to be made to the technically acceptable, 
responsible offeror whose proposal was most advantageous to the 
government, price and other factors considered.  Technical 
considerations were said to be more important than cost.  There were 
three technical factors described in the RFP, under each of which 
various subfactors were described.  The specific weights of the 
factors and subfactors, expressed as a percentage on a 100-percent 
scale, were disclosed.  The technical factors and their respective 
weights were "Management Capabilities"--40 percent, "Operating 
Plan"--25 percent, and "Experience"--35 percent.  Among the subfactors 
of the management capabilities factor were "Organizational Plan"--10 
percent, "Staffing"--10 percent, and "Training Programs"--4 percent.  
Among the Subfactors of the operating plan factor was "Timeliness"--4 
percent.  The two subfactors of the experience factor were "Prime 
Contractor's Project Experience"--25 percent and "Contract 
Personnel"--10 percent.

On June 24, the IRS received 14 proposals in response to the RFP, 
including Safeguard's.  The proposals were evaluated by a two-member 
technical evaluation panel (TEP) that used an adjectival and weighted 
numerical rating system to determine each proposal's technical 
score.[2]  The initial TEP evaluation identified eight technically 
"acceptable" proposals with point scores ranging from 48.70 to 88.60 
points; Safeguard's proposal received a score of 51.20 points.  The 
IRS rejected the remaining proposals.  Without conducting discussions, 
the TEP then reevaluated the eight proposals and awarded revised 
scores ranging from 39.40 to 89.35 points; Safeguard's proposal 
received a score of 49.60 points.

Based upon there revised evaluation, the IRS established a competitive 
range consisting of the three highest-ranked offers rated as follows:

OfferorPrice             Points

Miracle Services, Inc.[DELETED]89.4

Potomac Valley Custodial Services[DELETED]79.6

Spotless Janitorial Services[DELETED]70.1

The IRS eliminated from the competitive range Safeguard's lower-rated 
proposal priced at [DELETED].  The TEP summarized Safeguard's proposal 
deficiencies as follows:

     Safeguard's proposal reflects a lack of experience in ADP 
     [automatic data processing] facilities similar to the size and 
     complexity of MCC.  Additionally, Safeguard's proposal did not 
     meet the SOW [statement of work] requirements in the subfactors 
     of Organizational Plan, Staffing and Training under the 
     Management Capabilities criterion."

Discussions were conducted with the competitive range offerors, and 
best and final offers (BAFO) were received by March 13, 1995.  Because 
the IRS determined that none of the BAFOs met all of the 
requirements,[3] the IRS conducted a second round of discussions and 
received revised BAFOs by March 15.  Under the final evaluation, 
Potomac Valley's BAFO, priced at [DELETED] was the highest rated with 
a score of 83.8 points.[4]  Spotless' BAFO, priced at [DELETED], 
received a score of 78.3 points.  Miracle's revised BAFO was rejected 
as unacceptable for failing to propose sufficient hours.  Award was 
made to Potomac Valley on March 29.

Safeguard then protested the evaluation and exclusion of its proposal 
from the competitive range.[5]  The TEP Chairman, after reviewing the 
protest, reevaluated Safeguard's proposal and lowered its score from 
49.6 points to 32.6 points; in this reevaluation the Chairman 
basically lowered Safeguard's score to zero for the training, 
timeliness, and prime contractor's project experience subfactors.[6]

Safeguard contends that its proposal was unreasonably evaluated and 
unequally evaluated as compared to the evaluation of the other 
proposals.  The specific subfactors that Safeguard asserts were 
misevaluated were organizational plan, staffing, training, timeliness, 
and prime contractor's project experience.  Safeguard argues that but 
for the agency's improper evaluation its proposal would have scored 
comparably with the competitive range proposals and would have been 
included in the competitive range.

In reviewing an agency's decision to exclude a proposal from the 
competitive range, we look first to the agency's evaluation of 
proposals to determine whether the evaluation had a reasonable basis.  
Intown Properties, Inc., B-249036.3, Jan. 15, 1993, 93-1 CPD  para.  45.  
Although we will not independently determine the merits of a proposal, 
in reviewing an agency's evaluation, we examine the record to ensure 
that the evaluation was reasonable and consistent with the evaluation 
criteria.  A.G. Personnel Leasing, Inc., B-238289, Apr. 24, 1990, 90-1 
CPD  para.  416.  Such judgments
by their nature are often subjective; nonetheless, the exercise of 
these judgments in the evaluation of proposals must be reasonable and 
must bear a rational relationship to the announced criteria upon which 
competing offerors are to be selected.  NITCO, B-246185, Feb. 21, 
1992, 92-1 CPD  para.  212.

Based upon our review, we find that the IRS unreasonably evaluated 
Safeguard's proposal under the organizational plan, staffing, and 
prime contractor's project experience subfactors and unreasonably 
reevaluated Safeguard's proposal under the training and timeliness 
subfactors, such that the record does not support the eIimination of 
Safeguard's proposal from the competitive range.[7]

With regard to the organizational plan subfactor, the IRS awarded 
Safeguard's proposal zero out of a possible 10 points.  The basis for 
this evaluation, as documented in the contemporaneous evaluation 
sheets, was that Safeguard's proposal assertedly did not provide for 
an on-site project manager, which the IRS alleges was required by the 
RFP.

Under the organizational plan subfactor, the RFP required the 
following information:

     "[p]rovide a plan depicting the structure of the corporation; the 
     local office and the authority and responsibilities of the 
     on-site management to solve problems, assign work, hire 
     personnel; and the abilities and skills available for local 
     performance.  Also important in this plan is the apparent intent 
     and ability of the corporate headquarters to support the 
     custodial operations at the [MCC]."

In addition, section G.1.3 of the RFP stated that the contractor shall 
provide a "Project Manager" with the authority to make any no-cost 
contract technical hiring and dismissal decisions, or special 
arrangements regarding the contract.  The RFP further stated that the 
project manager shall be responsible for the overall management and 
coordination of the contract, shall act as the central point of 
contact for the government, and shall have full authority to act for 
the contractor in the performance of the required services.[8]   
Section H.19 advised that the project manager was required to possess 
recent experience in the management of custodial
operations of the approximate size and complexity of the IRS 
buildings.

Safeguard's proposal contained an organizational chart[9] and 
narrative describing the structure of its corporation and 
organization.  The proposal described its local office as well as the 
authority and responsibilities of on-site management to solve 
problems, assign work, and hire personnel.  It further described the 
skills available for local performance as well as its ability to 
support the MCC operation.  Safeguard proposed a project manager,[10] 
who was to be located off-site and who was to assist in the on-site 
management, which was to be led by a specifically identified on-site 
supervisor.[11]  Safeguard assigned the contract functions that the 
RFP reserved to the project manager under G.1.3 to the on-site 
supervisor, including no-cost hire and fire decisions.  As indicated 
in Safeguard's proposal, the on-site supervisor was to report directly 
to the project manager and the project manager was "to assist the 
on-site supervisor in the daily routine of job performance and project 
personnel management," but the right to hire or fire the on-site 
supervisor was reserved to the company president.

We find, however, no requirement in the RFP for the project manager to 
be located on-site; neither do we find any suggestion of a preference 
for an on-site project manager.[12]  Moreover, the IRS has not pointed 
to any provision in the RFP precluding the delegation of these project 
manager duties, or otherwise explained why Safeguard's proposal did 
not meet the substance of the IRS' requirements, given that Safeguard 
proposed an on-site management figure with the same authority 
reflected in G.1.3 and experience required by H.19.[13]

While the IRS may have considered an on-site project manager to be 
more desirable and might have properly lowered Safeguard's score in 
light of this concern, since the RFP did not require an on-site 
project manager and since Safeguard met the requirement to have an 
on-site management official with the appropriate authority and 
experience, we find that the IRS had no reasonable basis for scoring 
Safeguard's proposal with zero points for this subfactor.  See 
Gardiner, Kamya & Assocs., B-258915.2, Apr. 12, 1995, 95-1 CPD  para.  193; 
J.M. Cashman, Inc., B-233773, Apr. 14, 1989, 89-1 CPD  para.  380.

Based upon its post-protest reevaluation, the IRS nevertheless argues 
that the zero score is justified because the organizational chart and 
narrative allegedly are ambiguous in that the relationships between 
the corporate president, project manager, and on-site supervisor 
assertedly cannot be clearly discerned from the submitted material.  
As indicated by our foregoing discussion, we find no real ambiguity in 
Safeguard's proposal.  For example, while IRS makes much of the 
alleged confusion attendant with the use of the terms on-site program 
manager and program manager in Safeguard's proposal in addition to 
on-site supervisor and project manager, we note that the term on-site 
program manager only appears in a part of the organizational plan with 
a heading that is clearly marked "[r]esponsibility for work 
performance - on-site supervisor," so it is obvious that this term is 
synonymous with on-site supervisor.  Further, the proposal clearly 
reflects that its reference to program manager is synonymous with 
Safeguard's proposed project manager, since within its corporate 
structure this is identified as being the same individual--the TEP 
Chairman concedes that Safeguard inserted the name of its 
program/project manager in the space in the RFP provided for 
identifying a project manager, Hearing Transcript (Tr.) at 16--so 
there should have been no reasonable basis for confusion.  Also, IRS' 
argument that Safeguard's narrative, which indicates that the on-site 
supervisor reports directly to the program manager, may conflict with 
the organizational chart, which assertedly could be read as indicating 
that the on-site supervisor reports to the president, is belied by any 
reasonable reading of Safeguard's proposal, which clearly shows the 
respective roles and responsibilities of these individuals.

In sum, the IRS had no reasonable basis to award Safeguard's proposal 
zero points for the organizational plan subfactor.  See Gardiner, 
Kamya & Assocs., supra; J.M. Cashman, Inc., supra.  While the IRS may 
have had a reasonable basis to award less than a perfect score for 
this subfactor, we find, based on our review of Safeguard's 
organizational plan and IRS' evaluation of the competitive range 
proposals, that Safeguard's proposal could have received as many as 8 
points under a proper evaluation for this subfactor.

Under the staffing subfactor, Safeguard also received zero of the 10 
possible points. As indicated by the contemporaneous documentation, 
the IRS determined that Safeguard's proposal failed to provide 
sufficient explanation and assurance of the availability, on a timely 
basis, of personnel of the right skill mix and levels of competence to 
assure contract performance[14] for two reasons:  (1) the project
manager was not located on-site[15] and (2) Safeguard's proposal 
failed to propose 34 utility hours per week for both the MCC main 
building and annex, which the IRS asserts was required by the RFP.

First, as discussed above, there was no requirement that the program 
manager be located on-site and the record indicates that this 
individual can respond to IRS within the 4 hours required by the RFP.  
Thus, this reason does not provide a basis for a zero rating under the 
staffing subfactor.  Id.

With respect to utility work, section J of the RFP required the 
contractor to provide daily "utility work" at the discretion of the 
COTR; the contractor is required to make available the "indicated 
[utility] man hours," which are stated to be 6 hours per day Monday 
through Friday and 2 hours per day on Saturday and Sunday.[16]  The 
utility hours "may be for any location or type of work specified 
within the scope of [the] contract" and would be used to "service high 
public use areas, high complaint, special cleaning requirements, or in 
assisting in the loading, unloading, and/or distribution of supplies, 
carpets, furniture or other items."

The IRS argues that the RFP required 34 weekly utility hours per 
building, primarily relying on the language in section B that required 
separate pricing for the main MCC building and the annex.[17]  See Tr. 
at 86-88.  The IRS contends that because offerors were required to 
provide the services contained in section J at both buildings and 
section J required 34 utility hours, the RFP required 34 utility hours 
per building.

However, as indicated above, under section J, the designated 34 
utility hours may be used for "any location." The RFP did not 
explicitly state that 34 utility hours would be required per building.  
Accordingly, we find that the RFP's requirement for such hours is 
ambiguous at best.[18]  In addition, none of the competitive range 
offerors proposed more than a total of 34 utility hours in their 
initial offers.  While one of these offerors (the awardee) also 
received a zero score under this subfactor apparently for this reason, 
the record shows that the other two competitive range offerors 
received perfect or near perfect scores under this factor, even though 
their proposals did not evidence 34 utility hours per building.[19]   
Under these circumstances, the IRS appears to have had no reasonable 
basis for downgrading Safeguard's proposal for its asserted failure to 
propose adequate utility hours. J.M. Cashman, Inc., supra.

In defending the protest and in the reevaluation, the IRS reports that 
Safeguard's zero rating was justified because the proposal failed to 
provide sufficient explanation and assurance of the personnel of the 
right skill mix and levels of competence and experience.  These post 
hoc reasons are not supported by the record.

Specifically, while the IRS argues that Safeguard's organizational 
plan contained contradictions that would result in no enforceable 
commitment from Safeguard to provide any management figures-which, as 
discussed above, IRS claims are unknown--our review, as explained 
above, confirms that Safeguard's proposal clearly described its 
management structure, and we note that the same management  figures 
are reiterated in the section of Safeguard's proposal describing its 
staffing. Thus, contrary to the IRS' assertions, Safeguard's 
management was clearly discussed in an unambiguous way and the 
management figures are identifiable.[20]

The record actually suggests that Safeguard's proposal provided all 
requested information and should have received a high rating for the 
staffing subfactor. Safeguard proposed to staff the contract with 14 
employees, one of whom was the program/project manager on Safeguard's 
current staff, and the rest of whom were from the incumbent's staff, 
including Safeguard's proposed on-site supervisor who, as previously 
noted, served as the project manager under the incumbent contract See 
Tr. at 28.  Safeguard provided the resumes and employment applications 
of these individuals, which indicated immediate availability at the 
start of the contract.[21]  In addition, the proposal contained 
Safeguard's detailed manpower estimates, which exceeded the 
government's, and its labor hour staffing plans for the buildings.

Although the IRS argues that the lack of actual commitment from any 
incumbent employees was critical in now determining that Safeguard did 
not provide adequate assurance of the availability of personnel, the 
RFP did not require offerors to provide any evidence of employment 
commitments.  The non-incumbent competitive range offerors, whose 
proposals received perfect or near perfect ratings for this subfactor, 
also proposed to hire the employees of the incumbent, but did not 
provide any more evidence of commitments from these individuals than 
did Safeguard; to the contrary, the record shows that Safeguard's 
proffered evidence of the availability of personnel was on a par with, 
and in one case more extensive than, that reflected in the competitive 
range proposals.

In light of the above, we find that the IRS' zero rating of 
Safeguard's proposal under the staffing subfactor was unjustified, and 
that Safeguard may have been entitled to as much as a perfect score 
for this subfactor, particularly given the information reflected in 
its proposal as compared to that reflected in higher-rated competitive 
range proposals.

With regard to the prime contractor's project experience subfactor, 
the IRS awarded Safeguard 13.75 out of 25 points.  In the post-protest 
reevaluation, the IRS changed this score to zero.  The sole reason 
that IRS downgraded Safeguard's proposal under this subfactor in the 
initial evaluation was that it contained no evidence that the listed 
projects involved janitorial experience at ADP centers.  See Tr. at 
67-68, 77-78, 129.

Under this subfactor, the RFP advised offerors to "[l]ist at least 
three projects of similar size and complexity to the subject project," 
to "[b]e certain to emphasize experience in custodial operations in 
ADP centers, and that "[g]reater experience would receive greater 
emphasis."  The RFP also cautioned that the proposal may be ranked 
lower if the customer point of contact--who can verify the quality of 
contract performance--cannot he reached by the government because of 
misinformation provided in the proposal.

Safeguard's proposal listed 28 custodial projects in response to this 
subfactor, but did not specifically mention that any of the projects 
involved an ADP center. The protester argues that the fact that the 28 
projects involved custodial experience should have been discerned from 
the prefatory language introducing the projects; and indeed the 
record, as developed during this protest, reflects that all of the 
listed 28 projects did involve ADP centers.  See Tr. at 132, 134-136, 
141-149.  Since an offeror has the burden of submitting an adequately 
written proposal, an agency may downgrade a proposal for lack of 
detail pertaining to the requirements of an RFP, or consider a more 
detailed proposal superior, if the proposal fails to include requested 
information.  Formal Management Sys., Inc., B-259824, May 3, 1995, 
95-1 CPD  para.  227; SBS Technical Servs., B-259934, Apr. 19, 1995, 95-1 
CPD  para.  205.  Thus, in light of the specific direction to emphasize ADP 
centers, Safeguard ran the risk of being downgraded by failing to 
clearly do so.[22]  See Baker Support Servs., Inc., B-257054.2, Jan. 
20, 1995, 95-1 CPD  para.  29.

Nevertheless, the TEP Chairman testified that during the evaluation he 
specifically noticed that the IRS headquarters complex was among the 
projects listed by Safeguard and acknowledged that he was personally 
aware that this building possessed significant ADP space that was 
maintained by Safeguard.  Tr. at 131-132, 135-136.  He also testified 
that he believed that he is specifically precluded from taking into 
account this personal knowledge in an evaluation.  Tr. at 145.  
However, an agency may properly use information known by its own 
evaluators, as with any other references, to aid in the evaluation of 
proposals, including evaluating offeror experience, and may not simply 
ignore personally known information about an offeror's prior 
experience merely because it was not mentioned in the proposal.  See 
G. Marine Diesel; Phillyship, B-232619; B-232619.2, Jan. 27, 1989, 
89-1 CPD  para.  90; Inlingua Schools of Languages, B-229784, Apr. 5, 1988, 
88-1 CPD  para.  340.  Thus, the TEP Chairman's personal knowledge that the 
IRS headquarters complex listed in Safeguard's proposal contained ADP 
space, for which Safeguard provided custodial services, was 
appropriate for consideration during the initial evaluation.  Since 
the RFP only required 3 projects to be listed (Safeguard listed 28 
projects), and the IRS was aware that Safeguard had at least one 
project with directly relevant experience, it would seem that 
Safeguard would be entitled to as many as 4 more points than the 13.75 
points awarded under the initial evaluation.[23]  In this regard, our 
review reveals that Spotless listed only two projects involving ADP 
centers in its proposal and was only downgraded by 4 points for this 
reason.

As noted above, the post-protest reevaluation of the TEP Chairman also 
resulted in a lowering of Safeguard's score for the training subfactor 
from 1.6 of 4 possible 
points to zero points, and for the timeliness subfactor from 1.8 of 4 
possible points to zero points.  While we cannot say IRS' initial 
scores for these subfactors were unreasonable, we find no support for 
the reevaluation resulting in zero scores for these subfactors.

With regard to the training subfactor, Safeguard's proposal described 
training programs applicable both to supervisory and other personnel 
"to improve, enhance, and ensure [that they] are able to perform the 
[contract] tasks."  IRS' primary complaint about Safeguard's training 
proposal was that it contained no believable "commitment" to provide 
the training described, which IRS described as confusing. Our review 
indicates that Safeguard's proposal addressed the training 
requirements as indicated in the RFP, and while we cannot find, on 
this record, that the initial score for this subfactor was 
unwarranted, there is no support for a zero rating, since Safeguard's 
proposal described a training program that, if implemented, was 
apparently acceptable.  J.M. Cashman, Inc., supra.

With regard to the timeliness subfactor, section C.3 of the RFP 
required all service calls to "be addressed within 5 minutes in an 
emergency and within 15 minutes for routine service requests."  The 
initial low rating under this subfactor and the zero rating on 
reevaluation were based on a statement in Safeguard's proposal that 
responses to service calls would be made within 1 hour.  Tr. 169-170.  
However, the proposal also contained repeated specific promises that 
Safeguard would comply with the required 5- and 15-minute response 
times.  Tr. at 170-172.  While we cannot say Safeguard's initial 
rating was not warranted, we do not find the assignment of zero points 
in the post-protest reevaluation was justified; we note that this type 
of problem is easily resolvable during discussions.  See Caldwell 
Consulting Assocs., B-242767; B-242767.2, June 5, 1991, 91-1 CPD  para.  
530.

In conclusion, our review indicates that Safeguard's proposal was 
misevaluated in three significant respects,[24] and that had the 
proposal been properly evaluated the proposal may well have received a 
higher technical score than did the lowest-rated but more costly offer 
that was included in the competitive range, with the result that 
Safeguard's proposal would have been included in the competitive 
range.

We recommend that the IRS reevaluate proposals consistent with this 
decision and establish a new competitive range as appropriate, and 
proceed with meaningful discussions, receipt of BAFOs, and a new 
selection decision.  If Potomac Valley is then determined to be not 
entitled to the award, Potomac Valley's contract should be terminated 
and award made to the offeror found to be cost advantageous under the 
RFP evaluation criteria.  Alternatively, if it is no longer feasible, 
in light of the time that has elapsed since the award was made, to 
reopen the competition, the IRS, rather than exercise the options in 
the contract, should conduct a new procurement.  Safeguard is also 
entitled to recover its costs of filing and pursuing the protest, 
including reasonable attorneys' fees, 4 C.F.R  sec.  21.6(d) (1995), and 
since the basic contract period has been performed for which Safeguard 
did not have fair opportunity to compete, its proposal preparation 
costs.  4 C.F.R. 21.6(d) (2); see Pacific Util. Equip. Co., B-259942, 
May 16, 1995, 95-2 CPD  para.  114.  The protester should submit its 
certified claim for costs directly to the agency within 60 days of 
receipt of this decision.  4 C.F.R.  sec.  21.6(f)(1).

The protest is sustained.

Comptroller General
of the United States

1. Although the RFP work statement described the services to be 
performed at the annex as optional services, the contract 
automatically required these services to be performed upon completion 
and occupancy of the annex.

2. The TEP assigned raw point scores under each subfactor based upon a 
decimal point scale from 0.0 to 1.0, which were equated with 
adjectival ratings.  A numerical rating from .8 to 1.0 represented an 
"exceptional" rating, from .5 to .7 an "acceptable" rating, from .1 to 
.4 a "marginal" rating, and 0 an "unacceptable" rating.  Each 
proposal's point scores were calculated by multiplying each 
subfactor's percentage weight by the decimal point score awarded by 
the TEP for that subfactor and adding the weighted scores to arrive at 
a total score.

3. As discussed in detail below, none of the competitive range 
proposals met IRS' requirement that the contractor provide 34 utility 
hours per building.

4. Potomac Valley was the incumbent contractor for these services.

5. On April 5, the IRS notified this Office of its determination to 
override the stay and proceed with performance under the contract 
based upon urgent and compelling circumstances.  See 4 C.F.R.  sec.  
21.4(b) (1995).

6. None of the other proposals was reevaluated.

7. As discussed further below, we find the TEP Chairman's post-protest 
reevaluation was generally unreasonable.  While we consider the 
record, including statements and arguments made in response to a 
protest, in determining whether an agency's selection decision is 
supportable, we accord greater weight to contemporaneous source 
selection materials than to documents which were prepared in response 
to protest contentions.  Alliant Techsvstems, Inc; Olin Corp., 
B-2602l5.4; B-260215.5, Aug. 4, 1995, 95-2 CPD  para.  79.  This 
reevaluation is particularly questionable since none of the other 
proposals was reevaluated.

8. The RFP further stated that the project manager or designated 
representative must respond within 4 hours after being notified of the 
existence of a problem.

9. The chart is a line chart that depicts the president at the head 
with a vertical line drawn below to the center of the next level that 
reflects two individuals labeled program managers on a horizontal line 
opposite from each other.  Two diagonal lines, which connect with the 
center line leading to the president, are drawn below this level, one 
going to the on-site supervisor at MCC and the other going to another 
Safeguard program manager.

10. Safeguard identified this individual by name in the space provided 
in G.1.3 for designating the project manager, and this individual was 
the designated program manager appearing on the level of Safeguard's 
organizational chart below the president with a diagonal line drawn 
between the program manager and the proposed on-site supervisor at MCC 
on the level below on the organizational chart.

11. Safeguard proposed the incumbent contractor's project manager to 
be its on-site supervisor.

12. The protester persuasively argues that the RFP requirements 
reasonably can be interpreted to permit an off-site project manager 
because, under G.1.3, the project manager is only responsible for the 
overall management and coordination of the contract and is permitted 
to act through a designated representative, and because the RFP 
contains a 4-hour limit for the project manager to respond to the 
agency.

13. Save for the express titles, our review reveals that the structure 
of Safeguard's organization was consistent with those offers in the 
competitive range, in that an on-site management figure was proposed 
to carry out the day-to-day activities
contained in sections G.1.3 and H.19 of the RFP, who was in turn to be 
supervised by an off-site manager.  While the IRS contends that 
Safeguard's proposal's restriction of its project manager's ability to 
fire the on-site supervisor, by reserving this authority in the 
president, and the assignment of the project manager's duties to the 
on-site supervisor, contravenes the terms of G.1.3, we are not 
persuaded that Safeguard's proposed structure radically departed from 
the intent of that provision.

14. The staffing subfactor required offerors' proposals to contain 
this information.

15. The IRS determined that Safeguard's designated program manager may 
not be available on a timely basis because the individual also was 
listed in its organizational plan as a program manager on another 
project.

16. This totals 34 hours per week.

17. Under the line item entitled "Fixed Price Work" for both the main 
building and the annex the RFP stated as follows:

             "BASIC SERVICES: Contractor shall provide the janitorial 
             and related services as described in Sections C, G, H, & 
             J."

18. The TEP Chairman testified that historically the IRS had used only 
30 percent of the required 34 utility hours and that all utility hours 
are generally not used, Tr. at 93, so it may be reasonable to conclude 
that the RFP actually intended that the 34 utility hours was to cover 
both buildings.

19. Moreover, the record shows that the agency made award to Potomac 
Valley, even though its BAFO still only specified 34 utility hours for 
the main building, despite several rounds of discussions where this 
was a subject.  Although the IRS now argues that the awardee met the 
requirement because it agreed to additional utility hours at the 
awardee's expense, the fact remains that the awardee's staffing charts 
only actually proposed a total of 34 utility hours, as was the case 
with Safeguard's proposal.  Tr. at 100-104.

20. While the IRS cited the inability to identify management figures 
and the prospect that Safeguard's project manager might have 
conflicting responsibilities, we note that Spotless's proposal was 
rated highly for staffing, ever though it proposed an interim project 
manager, who also had other responsibilities, to serve for only the 
first 6 months of the contract with the actual project manager to be a 
"promising local West Virginian" to be identified after start of the 
contract.  Tr. at l60-162.

21. Safeguard represented that it had permission to use the resumes 
and also furnished a separate letter from the incumbent's project 
manager granting Safeguard permission to use this individual's resume 
for the on-site supervisor position.

22. The competitive range proposals stressed ADP center custodial 
experience in most of the projects listed.

23. We find no support in the record for IRS' reevaluation resulting 
in a zero score for this subfactor.  IRS' newly advanced reasons that 
it could only contact two of the listed points of contact after this 
protest was filed and that Safeguard's description of each custodial 
services project was identical do not justify a zero rating.  J.M. 
Cashman, Inc., supra.

24. We also note that the IRS evaluated Safeguard's proposal with a 
lower score for the contract personnel subfactor of the experience 
factor than the competitive range proposals.  This score seems 
questionable, inasmuch as Safeguard proposed the incumbent work force 
and the incumbent protect manager to be the on-site supervisor.