BNUMBER:  B-274744
DATE:  December 26, 1996
TITLE:  Centra Technology, Inc.

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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:Centra Technology, Inc.

File:     B-274744

Date:December 26, 1996

Thomas L. Patten, Esq., and Vivian C. Strache, Esq., Latham & Watkins, 
for the protester.
Paul F. Khoury, Esq., and Mark H. Neblett, Esq., Wiley, Rein & 
Fielding, an intervenor.
Bernard J. Roan, Esq., and Donna J. Bartoe, Esq., National Aeronautics 
and Space Administration, for the agency.
Sylvia Schatz, Esq., and John M. Melody, Esq., Office of the General 
Counsel, GAO, participated in the preparation of the decision.

DIGEST

1.  Protest that evaluation failed to take into account experience of 
protester's proposed subcontractor is denied where record shows this 
experience was considered, but was rated as only "fair," compared to 
the awardee's rating of "excellent," since protester and its proposed 
subcontractors had limited experience compared to the incumbent 
awardee.

2.  Protester's proposed travel costs properly were adjusted upward 
based on the costs under the incumbent contract, where protester's 
proposal failed to provide the basis of  the estimates for its 
proposed travel costs, as required by the solicitation, and the 
incumbent contract was based on the same performance approach as 
protester proposed. 

DECISION

Centra Technology, Inc. (CTI), a wholly owned subsidiary of Defense 
Group, Inc. (DGI), protests the award of a contract to TechTrans 
International, Inc. (TTI) under request for proposals (RFP) No. 
9-BP2-H50-6-01P, issued by the National Aeronautics and Space 
Administration (NASA) for Russian language and logistics services for 
the Johnson Space Center, Houston, Texas.  CTI challenges the 
evaluation of its proposal and argues that the award was improper due 
to an improper conflict of interest.

We deny the protest.

The RFP contemplated the award of a cost-plus-fixed-fee contract on a 
best value basis for translation, interpretation, language training, 
and logistics services at various sites in the United States and 
Russia.  The solicitation set forth the following three equally 
weighted factors:  (1) mission suitability; (2) cost; and (3) relevant 
experience and past performance.  Under the mission suitability 
factor,  proposals were to receive both a numerical and an adjectival 
(excellent, very good, good, fair, or poor) rating, which then was 
subject to adjustment based on a cost realism analysis.  In this 
regard, proposed costs were to be evaluated to establish probable 
cost, which would not be scored. 

Six proposals were received.  CTI's and TTI's proposals (the only ones 
relevant here) were scored as follows:

FACTOR               CTI                  TTI

Mission Suitability
(1,000 available points)453/fair          636[1]/good

Relevant Experience/
Past Performance     fair                 excellent

Probable Cost        $42,456,000          $41,602,000
The source selection official (SSO) determined that TTI's proposal was 
the best value to the government based on its highest technical 
ratings and lowest  probable cost and thus made award to TTI without 
discussions. 

RELEVANT EXPERIENCE/PAST PERFORMANCE

CTI asserts that the agency admitted during the debriefing following 
the award that it had not considered any of the relevant experience of 
its proposed subcontractor, Universal Technical Translation, Inc. 
(UTT), which allegedly had 18 years of Russian language translation 
and interpretation experience on multi-million dollar contracts 
(including subcontract experience on TTI's incumbent contract).  Since 
this allegedly is more experience than TTI has, CTI maintains that its 
proposal's rating of fair in this area was erroneous in light of TTI's 
excellent rating.

In reviewing an evaluation, we will not reevaluate technical 
proposals; rather, we will examine the agency's evaluation to ensure 
that it was reasonable.  Comarco, Inc., B-249697.2, Jan. 26, 1993, 
93-1 CPD  para.  65.

Notwithstanding the agency's alleged statements at the debriefing, the 
record shows that the SSEB did in fact consider UTT's experience (as 
well as that of EAI Corporation, another proposed subcontractor and 
CTI's parent company, DGI[2]).  It rated CTI's proposal as only fair 
for two principal reasons:  most of the personnel involved in DGI's 
and EAI's prior contracts were scientists who primarily performed 
research and development tasks on aeronautics rather than Russian 
language interpretation and translation services, as required here; 
and, although the SSEB determined that UTT had significant translation 
experience, it also found that the firm had limited interpretation and 
training experience, and no logistics experience, two elements of the 
work under the RFP.  In contrast, the SSEB determined that, while 
TTI's experience was limited to its incumbent NASA contract, that 
experience extended into all areas of the RFP, and TTI's performance 
was superior.  Specifically, TTI provided (1) translators who handled 
large volumes of materials, often under very short deadlines, while 
maintaining high quality and completing the translations on or ahead 
of schedule; (2) a large number of interpreters who handled an 
increasing volume of interpretations in all areas of medicine, 
engineering, and other sciences at numerous teleconferences and 
meetings were available on short notice (as little as a few minutes); 
(3) all logistics support at different locations in Russia; and (4) 
Russian language training classes on a continual basis.  We find 
nothing erroneous in the agency's findings or unreasonable in its 
conclusion that the differences in the offerors' experience/past 
performance warranted rating TTI's proposal superior to CTI's in this 
area.

COST 

CTI argues that the agency improperly adjusted its proposed travel 
costs upward (by $3,933,000) based on the travel costs experienced 
under TTI's incumbent contract; CTI maintains that, in doing so, the 
agency ignored its unique staffing approach of employing Russian-based 
translators and interpreters, which would reduce travel costs.

When an agency evaluates proposals for the award of a 
cost-reimbursement contract, a cost realism analysis must be performed 
to determine the extent to which an offeror's proposed costs represent 
what the contract should cost, assuming reasonable economy and 
efficiency.  Federal Acquisition Regulation (FAR)  sec.  15.605(c) (FAC 
90-31); Sabre Sys., Inc., B-255311, Feb. 22, 1994, 94-1 CPD  para.  129.  
Because the contracting agency is in the best position to make this 
cost realism determination, our review of an agency's realism 
determination is limited to considering whether it was reasonable.  
Titan Corp., B-260557.2, July 18, 1995, 95-2 CPD  para.  89.

The RFP required offerors to identify travel and subsistence costs by 
contract period and to provide the basis of the estimate for their 
proposed travel costs.  Notwithstanding this requirement, CTI's cost 
proposal was devoid of any explanation as to the assumptions 
underlying CTI's proposed travel costs.  The agency found, for 
example, that while CTI's spreadsheets calculated the total price per 
employee of a trip to Moscow--by multiplying the total amount for 
airfare, subsistence, car rental, and miscellaneous expenses by the 
number of days per trip, and then indicated the total number of trips 
and personnel needed for each trip--the proposal did not explain how 
CTI calculated the total number of proposed trips, the length of each 
trip, and the number of personnel required for each trip.  Due to the 
lack of such information, the SSEB looked to TTI's current contract 
for guidance as to probable travel costs.  This comparison was 
appropriate, the agency determined, since CTI's proposed 
approach--i.e., using foreign local translators and interpreters--was 
similar to TTI's.  Based on this comparison, the agency increased 
CTI's travel costs from $1.167 million to $5.1 million.  

The cost adjustment was reasonable.  Given the absence of required 
explanatory information from CTI's proposal--CTI does not explain why 
it did not provide the assumptions on which its travel costs were 
based--it was reasonable for the agency to evaluate CTI's probable 
costs by reference to the costs under a similar approach.  Although 
CTI asserts that its staffing approach is unique, the agency 
specifically determined that it was similar to the approach under 
TTI's current contract--TTI's proposal stated that its ". . . multiple 
sources of interpreters and translators throughout the U.S. and in 
Moscow has allowed us to reduce travel and subsistence costs by using 
local support . . ."--and CTI does not refute this determination.

CONFLICT OF INTEREST

CTI maintains that the director of the Johnson Space Center, who 
appointed the deputy director of the Center as the SSO, had a close 
personal relationship with the president of TTI.  CTI argues that 
since the SSO was in a subordinate position to the director, the 
personal relationship between the director and the president of TTI 
improperly influenced the SSO's source selection decision in favor of 
TTI.  

Where a protester alleges bias or conflict of interest on the part of 
a procurement official, the question is whether the official exerted 
improper influence in the procurement on behalf of the awardee or 
against the protester.  E.J. Richardson Assocs., Inc., B-250951, Mar. 
1, 1993, 93-1 CPD  para.  185.

There is no evidence of improper influence here.  Although the 
director appointed the deputy director as the SSO prior to the SSO's 
selection of the SSEB members, the record shows that the director was 
not involved in the evaluation of proposals, the source selection 
process or any other matters related to the procurement.  Nor is there 
any evidence that the director had any contact with the SSO or the 
SSEB during the course of the procurement, or that the SSO was in any 
way influenced by the director's personal relationship with TTI's 
president.  We note, furthermore,  that we have found no merit to 
CTI's allegations that its proposal was improperly evaluated relative 
to TTI's.  There thus is no basis for finding an improper conflict of 
interest.[3]

The protest is denied.

 Comptroller General
 of the United States

1. The source selection evaluation board (SSEB) deducted (under the 
                                          mission suitability factor) 
                                          100 points from TTI's 
                                          original rating of 736 
                                          points and 150 points from 
                                          CTI's original rating of 603 
                                          points, after taking cost 
                                          realism into account.

2. The agency evaluated the experience of DGI because CTI was a 
newly-formed company and had no past performance references.

3. CTI also argues that the director failed to effectively recuse 
himself from participating in the procurement, since he did not 
execute a written recusal.  While FAR  sec.  3.104-6(d) requires 
procurement officials who wish to discuss future employment or 
business opportunities with a competing contractor during the conduct 
of a procurement to provide a written proposal of disqualification 
from further participation in the procurement which relates to that 
competing contractor, there is no similar requirement for a written 
recusal under the circumstances here.  Since the record shows that the 
director, in fact, did not participate in the procurement, the absence 
of a written recusal would constitute a mere formality that would not 
affect the propriety of the award.