BNUMBER:  B-275439.3
DATE:  March 31, 1997
TITLE:  ACS Systems & Engineering, Inc.

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Matter of:ACS Systems & Engineering, Inc.

File:     B-275439.3

Date:March 31, 1997

L. Allan Parrott, Jr., Esq., Patrick H. O'Donnell, Esq., and Terence 
Murphy, Esq., Kaufman & Canoles, for the protester.
John W. Fowler, Jr., Esq., Blank, Rome, Comisky & McCauley, for 
Peirce-Phelps, Inc., an intervenor.
Kathryn E. Simmons, Department of Defense, for the agency.
Tania L. Calhoun, Esq., and Christine S. Melody, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Where contracting agency evaluated best and final offers (BAFO) based 
upon changed requirements which were not communicated to offerors 
until after award, contracting agency properly proposed to correct 
this error by issuing an amendment to clarify its revised 
requirements; allowing the submission of revised BAFOs based upon 
those requirements; and evaluating the revised BAFOs for purposes of 
award.

DECISION

ACS Systems & Engineering, Inc. protests the corrective action 
proposed by the Department of Defense's Television-Audio Support 
Activity (T-ASA) in connection with the firm's prior protest of the 
award of a contract to Peirce-Phelps, Inc. under request for proposals 
(RFP) No. TASA12-95-R-0025, issued to obtain shipboard audio 
entertainment systems (SAES) on behalf of the Naval Media Center 
(NMC).  ACS contends that the proposed corrective action is 
unreasonable and unlawful.

We deny the protest.

The solicitation, issued July 20, 1995, anticipated the award of a 
fixed-price requirements contract for SAES units consisting of 
state-of-the-art, commercial-off-the-shelf components.  Each SAES unit 
will broadcast through a ship's intercom system from such sources as 
compact discs, audio cassettes, commercial FM signals, and the Armed 
Forces Satellite Transmitted Radio Service audio signal.  The contract 
will run for 1 base year, with up to 4 option years.  

To satisfy the base year requirements, offerors were to supply up to 
13 SAES units under the third line item.  This line item also included 
two sub-line items, one for a 1-year SAES warranty and the other for a 
2-year SAES warranty.  In this regard, section C.3.10 of the RFP 
required that a manufacturer's standard warranty cover the equipment 
and services to be provided.  If this warranty did not extend for a 
total of 1 year, offerors were to provide the price of doing so; 
offerors were also to provide the price associated with extending this 
warranty for a total of 2 years.  In addition, the solicitation 
contained two separate line items for SAES spare parts kits--one for 
onboard use and one for depot-level use.  Offerors were advised that 
these line items were to be priced as options.  The remaining line 
items concerned such things as data, engineering services and support, 
technical manuals, and training.[1]

Award would be made to the offeror submitting the "best overall 
proposal," considering merit and price.  The solicitation included the 
standard clause, "Evaluation of Options," set forth at Federal 
Acquisition Regulation (FAR)  sec.  52.217-5, which informed offerors that 
offers would be evaluated by adding the total price for all options to 
the total price for the basic requirement unless, in accordance with 
FAR  sec.  17.206(b), it was determined not to be in the government's best 
interests to do so.[2]  

T-ASA's technical evaluation team (TET) evaluated the eight proposals 
it received and conducted discussions with all offerors.  The 
evaluation of discussion responses resulted in a competitive range of 
three:  ACS's proposal; Peirce-Phelps's proposal for a basic system; 
and Peirce-Phelps's proposal for an enhanced system.  Best and final 
offers (BAFO) were requested and submitted by March 11, 1996.  
However, on March 21, a firm whose proposal was excluded from the 
competitive range filed a protest in this Office, and the final 
evaluation of BAFOs was suspended until after our July decision 
denying the protest was issued.  Techniarts Eng'g, B-271509,
July 1, 1996, 96-2 CPD  para.  1.  

Given the passage of time since the solicitation's issuance, the TET 
postponed its final evaluation until after the NMC had reviewed each 
line item in light of the agency's current situation and requirements.  
NMC listed the line items in terms of their priority, placing primary 
emphasis on the production units and associated nonrecurring items.  
The three items lowest on the priority list were the 2-year warranty 
and the two types of spare parts kits.    

In view of the NMC's priorities, the TET's final evaluation did not 
consider the proposed prices of the 2-year warranty or spare parts 
kits.  The TET concluded that Peirce-Phelps's proposal for an enhanced 
system represented the best value to the government and the 
contracting officer, acting as the source selection official, agreed.  
After its September 27 briefing, T-ASA's Board of Awards discussed the 
fact that the prices of the 2-year warranty and spare parts kits were 
not evaluated and concluded that such action was proper in view of the 
language in FAR  sec.  17.206(b).  Award was made to Peirce-Phelps on 
September 30.  

After its debriefing, ACS filed a protest in this Office challenging 
T-ASA's conduct of the evaluation.  The agency subsequently conceded 
that it had improperly failed to evaluate all line item prices.  The 
agency proposed to take corrective action by amending the solicitation 
to delete the unevaluated line items and allowing the submission of 
second BAFOs from the offerors in the competitive range.  We dismissed 
the protest as academic on December 23, and the present protest 
followed.

Contracting officials in negotiated procurements have broad discretion 
to take corrective action where the agency determines that such action 
is necessary to ensure fair and impartial competition.  Computing 
Devices Int'l, B-258554.3, Oct. 25, 1994, 94-2 CPD  para.  162.  It is 
fundamental that offerors must be advised of a procuring agency's 
actual minimum requirements and the basis upon which their proposals 
will be evaluated.  Unisys Corp., 67 Comp. Gen. 512 (1988), 88-2 CPD  para.  
35; Occu-Health, Inc., B-270228.3, Apr. 3, 1996, 96-1 CPD  para.  196; Lobar 
Inc., 
B-247843.3, Aug. 31, 1992, 92-2 CPD  para.  139.  When an agency changes its 
requirements, either before or after receipt of proposals, it must 
issue a written amendment to notify all offerors of the changed 
requirements and allow competing firms an opportunity to respond to 
them.  FAR  sec.  15.606(a) (FAC 90-31); Ogden Gov't Servs.--Protest and 
Request for Modification of Remedy; Tate Facilities Servs., 
Inc.--Protest, B-253350.3 et al., Apr. 4, 1994, 94-1 CPD  para.  226; Budney 
Indus., 
B-252361, June 10, 1993, 93-1 CPD  para.  450; Universal Technologies, Inc., 
B-241157, Jan. 18, 1991, 91-1 CPD  para.  63. 

ACS contends that the Navy does require the items proposed for 
deletion and should simply reevaluate the BAFOs which have already 
been submitted in accordance with the evaluation scheme.  Our review 
of the record affords us no basis to find the agency's proposed 
corrective action unreasonable.

NMC states that the spare parts kits were included in the solicitation 
to provide a potentially more convenient method of procuring items 
since, at the time the acquisition was planned, the agency was faced 
with drastically diminishing manning levels and increased workloads, 
but steady funding levels.  Thus, for example, if the agency's 
storekeepers were swamped with ordering parts for other systems, the 
inclusion of these line items would allow them to buy kits of spare 
parts instead of many parts individually.  However, NMC reports that 
the drastic manning reductions have not continued, the workload has 
eased, and funding has been reduced.[3]  As a result, NMC no longer 
needs the convenient option of these line items--the agency employs a 
staff of 10 at its supply depot and one of their primary functions is 
to procure parts for shipboard broadcasting systems.  Similarly, while 
the 2-year extended warranty was a potential convenience for Navy 
repair personnel given the once-current manning, workload, and funding 
considerations, these considerations no longer exist.  NMC has six 
fleet maintenance facilities located around the world staffed with 
technicians qualified to work on all NMC shipboard systems, as well as 
repair personnel at its supply depot, and these repair personnel 
successfully maintain numerous pieces of equipment without any 
warranty protection.  

ACS asserts that the NMC must still buy spare parts and has no other 
contract vehicle for purchasing them.  However, NMC states that it has 
no intention of fielding units without having spare parts available, 
but prefers the flexibility of purchasing the components for these 
commercial-off-the-shelf items individually, rather than in kits, 
through its supply depot.  As for ACS's assertion that the 2-year 
warranty is in the Navy's best interest, the question here is not 
whether the solicitation reflects the Navy's ultimate "wish list," but 
whether it reflects the Navy's minimum needs.  Finally, ACS's point 
that the Navy has not "ruled out" the need for these items overlooks 
the NMC's statements that these items are "clearly not required" and 
"will not be procured."  Under the circumstances, we have no basis to 
question NMC's determination that its requirements no longer include 
the items at issue here.  As a result, the agency properly determined 
to amend the RFP to reflect its actual requirements and to allow the 
submission of second BAFOs based upon those requirements.  Lobar Inc., 
supra.

ACS also complains that the proposed corrective action amounts to an 
improper auction because Peirce-Phelps's prices have been exposed, or 
"technical leveling and/or technical transfusion."[4]  Where the 
reopening of negotiations is properly required, as here, the prior 
disclosure of an offeror's pricing does not preclude reopening 
negotiations because the possibility that a contract may not be 
awarded based on true competition on an equal basis has a more harmful 
effect on the integrity of the competitive system than the otherwise 
improper disclosure of proprietary information.  The Faxon Co., 67 
Comp. Gen. 39 (1987), 87-2 CPD  para.  425; Lobar Inc., supra.  Accordingly, 
the agency's proposed corrective action here is entirely proper.

ACS finally asserts that the proposed corrective action is designed to 
"steer" the award to Peirce-Phelps.  When a protester contends that 
contracting officials are motivated by bias or bad faith, it must 
provide convincing proof, since contracting officials are presumed to 
act in good faith.  Protective Group, Inc./Protective Materials Co. 
Div., B-236975, Jan. 11, 1990, 90-1 CPD  para.  45.  ACS merely notes the 
error that led to this proposed corrective action, reiterates its 
complaint concerning improper technical transfusion or an auction, and 
concludes, with no further proof, that the agency's proposed 
corrective action is an attempt to "steer" the award to Peirce-Phelps.  
In light of the rationale for the agency's actions, which we have 
found reasonable, we find that ACS's unsupported allegations do not 
constitute the proof required.  Id. 

The protest is denied.

Comptroller General
of the United States

1. The contents of the option year requirements were essentially 
identical to those of the base year requirements.

2. FAR  sec.  17.206(b) states, in part, that:

            "The contracting officer need not evaluate offers for any 
            option quantities when it is determined that evaluation 
            would not be in the best interests of the [g]overnment and 
            this determination is approved at a level above the 
            contracting officer. . . . "

3. ACS's argument that manning reductions will continue are not 
particularized to the personnel functions at issue here and provide us 
no basis to discount NMC's statements in this regard.

4. The basis for this position is the protester's apparent contention 
that reopening negotiations will give Peirce-Phelps an opportunity to 
correct what ACS calls its "flawed technical approach," i.e., 
allotting a major portion of its proposed price to the warranty and 
spare parts kits.  Although ACS supports its argument by citing to the 
regulation relating to technical transfusion (FAR  sec.  15.610(e)(1)), 
that provision clearly has no application to ACS's contention; at 
best, ACS's argument can be interpreted as an allegation of technical 
leveling, a charge unsupported by the record.