BNUMBER:  B-276860 
DATE:  July 28, 1997
TITLE: Food Services of America, B-276860, July 28, 1997
**********************************************************************

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:Food Services of America

File:     B-276860

Date:July 28, 1997

Martin P. Willard, Esq., and Richard W. Oehler, Esq., Perkins Coie, 
for the protester.
Lynne E. Georges, Esq., Defense Logistics Agency, for the agency.
Susan McAuliffe, Esq., and Michael R. Golden, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

1.  Protest that solicitation's relevant experience/past performance 
requirement is a definitive responsibility criterion is denied where 
the requirement was an evaluation factor, not a definitive 
responsibility criterion.

2.  Protest that contracting agency's evaluation of awardee's proposal 
improperly considered the experience and past performance of the 
awardee's proposed subcontractors is denied where, given the proposed 
relationship of the firms, the strength of the experience cited, and 
the terms of the solicitation (which did not expressly prohibit 
consideration of the experience), there is no basis to conclude that 
the agency acted unreasonably in giving awardee credit for the 
combined experience.

DECISION

Food Services of America (FSA) protests the award of a contract to 
Sunshine Dairy Inc. under request for proposals (RFP) No. 
SPO300-96-R-M068, issued by the Defense Logistics Agency (DLA), 
Defense Personnel Support Center, Philadelphia, Pennsylvania, for the 
acquisition of full line food distribution services for various 
delivery sites at five installations in the Spokane, Washington area.  
The protester contends that the awardee failed to meet a mandatory 
definitive responsibility criterion of the RFP and that the agency 
improperly evaluated the awardee's proposal.[1]

We deny the protest.

The RFP, issued on July 23, 1996, contemplated the award of an 
indefinite quantity contract to the offeror determined to have 
submitted the conforming offer most advantageous to the government.  
The RFP provided that in evaluating offers for award, technical 
quality was significantly more important than price.  The RFP listed, 
in descending order of importance, the following six technical 
evaluation factors for award (with all subfactors being of equal 
importance):  distribution/
delivery system/location/site visits (for which the RFP provided five 
subfactors, including product sourcing); corporate experience (which 
included two subfactors--past performance/experience and 
organizational support); quality program; socioeconomic 
considerations; procurement/pricing plan; and DLA Mentoring Business 
Agreements (MBA) program (however, since no offeror provided an MBA 
plan, this factor was not applied in the evaluation for award).  The 
RFP advised offerors that each technical proposal "must demonstrate 
the offeror's ability to meet the government's requirements as set 
forth in this solicitation."  Regarding the technical evaluation 
factor for corporate experience, the RFP provided:

     The Government will assess the offeror's performance record, as a 
     regular dealer/prime vendor, in providing full line food service 
     with similar food dollar/volume as required on this solicitation.  
     This assessment will be applied to any entity performing on this 
     contract, although experience provided that does not directly 
     pertain to the offeror will not receive as much consideration.

The RFP's proposal submission instructions were tailored to each of 
the evaluation criteria listed in the solicitation and, basically 
mirroring the solicitation terms for evaluation of corporate 
experience, provided:

     Offeror must show evidence of experience in providing full line 
     food service as a prime vendor/regular dealer for customers with 
     similar food dollar/volume requirements as those of this 
     solicitation. . . .  The offeror must also show that they and 
     their parent corporation, partners, subcontractors, and the like 
     who would be performing on the proposed contract have experience 
     in handling the proposed number of customers upon which 
     submitting a proposal. . . .  Experience information provided 
     that does not directly pertain to the commercial entity 
     represented in this proposal will not receive as much 
     consideration.

Proposals were received from three offerors--including FSA and 
Sunshine--and discussions were conducted.  Best and final offers were 
received and evaluated.  Sunshine's proposal offered both Sunshine's 
substantial vendor/dealer experience (in the dairy product market and 
as a retail grocer) and that of two proposed subcontractors, SuperValu 
Inc., a large national grocery provider, and Hathaway Meats Inc., a 
local meat distributor--both with extensive food service experience in 
the Spokane area.  The proposal explained how the joint experience of 
the firms would benefit the agency and meet the corporate requirements 
of the RFP.  The agency, in its evaluation of Sunshine's proposal, 
noted that Sunshine did not present evidence of its own full line food 
service experience, but concluded that together the proposed team 
possessed an acceptable level of corporate experience, as required by 
the RFP.

All three offerors' proposals were rated as acceptable overall; of the 
three proposals, Sunshine's was considered to be the highest rated 
technically.  The third offeror submitted the lowest evaluated price 
[deleted].[2]  FSA's proposal offered the highest cost [deleted].  In 
comparison to the awardee's proposal, the FSA proposal received the 
following [deleted] ratings:  [deleted] under the evaluation factor 
for distribution/delivery/location/site visits (compared to the 
Sunshine proposal's rating of [deleted]); [deleted] under the 
evaluation factor for quality program (compared to the Sunshine 
proposal's rating of [deleted]); and [deleted] under the evaluation 
factor for procurement/pricing plan/rebates/discounts (compared to the 
Sunshine proposal's rating of [deleted]).  The agency determined that 
the technically superior Sunshine proposal (at $2,365,241.18) 
represented the overall best value to the government and awarded a 
contract to Sunshine on April 7.  Subsequent to a debriefing held with 
the firm, FSA filed this protest.

FSA first protests that the above-quoted RFP proposal submission 
instruction for each offeror to show evidence of experience in 
providing full line food service as a prime vendor/regular dealer is a 
mandatory definitive responsibility criterion which Sunshine cannot 
meet since Sunshine is primarily a dairy product vendor and has not 
performed full line food services, and that the firm was therefore 
ineligible for award.  However, where, as here, responsibility-type 
factors such as experience are set forth as evaluation criteria in a 
negotiated procurement and are to be used by technical evaluators to 
make a comparative evaluation of the technical merits of each offer, 
we do not regard them as definitive responsibility criteria.  
Commercial Bldg. Serv., Inc., B-237865.2, B-237865.3, May 16, 1990, 
90-1 CPD  para.  473 at 5.[3]  In
such cases, as with any other evaluation factor, an agency's 
assessment and scoring of experience must be reasonable and in accord 
with the RFP's evaluation scheme.  Id.; Supreme Automation Corp.; Clay 
Bernard Sys. Int'l, B-224158, B-224158.2, 
Jan. 23, 1987, 87-1 CPD  para.  83 at 8.

The protester also contends that the RFP mandated that the offeror 
itself (i.e., Sunshine) must show full line food service experience, 
without consideration of any proposed subcontractor's experience, 
because the proposal submission requirement references the term 
"offeror" regarding the need for a showing of full line food service 
experience.  We do not read the RFP as restrictively as the protester, 
however, since the experience of a proposed subcontractor properly may 
be considered in determining whether an offeror meets an experience 
requirement in the solicitation where it is not expressly prohibited 
by the RFP.[4]  AeroVironment, Inc., B-233712, Apr. 3, 1989, 89-1 CPD  para.  
343 at 4.  Here, despite the language cited by the protester, the RFP 
in no way expressly prohibited consideration of proposed 
subcontractors' experience in the evaluation of proposals.  In fact, 
as quoted above, the RFP advised offerors that such experience may be 
considered, but that it will be given less weight in the evaluation 
than would be given to demonstrated experience attained by the 
commercial entity offeror itself.

FSA also states that it was improper for the agency to consider 
Sunshine's proposed subcontractors' experience without a firm 
commitment from those entities.  Offerors need not possess written 
subcontracting agreements for subcontractors identified in their 
proposals prior to an agency's evaluation of the proposals.  
Commercial Bldg. Serv., Inc., supra, at 6; National Biomedical 
Research Found., 
B-208214, Sept. 23, 1983, 83-2 CPD  para.  363 at 9.  Here, the Sunshine 
proposal described both firms as proposed subcontractors of Sunshine 
and stated that Sunshine had discussed with each firm (and obtained 
agreement from each firm regarding) its supplier role in performing 
the contract, appropriate contact persons were provided for each 
proposed subcontractor, the firms are represented in the offeror's 
proposed organizational structure, and business information about 
these firms was included in the proposal.  In our view, although the 
agency initially questioned the awardee about the terms of the 
relationship among the proposed firms, given the substantial role of 
these firms in the proposal, the proposal's showing of informed, 
substantial involvement by these subcontractors in Sunshine's proposed 
performance of the contract (confirmed through the agency's site 
visits), and the subcontractors' substantial food distribution service 
experience, it was reasonable for the agency to consider their 
experience as submitted.

FSA next contends that, even if the agency could consider the Sunshine 
team's combined experience under the RFP's terms, the evaluation was 
improper because the agency failed to give less weight to experience 
not attained by the offeror (Sunshine) itself, as required by the 
RFP's evaluation scheme.  The agency evaluated the Sunshine proposal 
as acceptable for corporate experience (with ratings of acceptable for 
both subfactors, past performance/experience and organizational 
support).  The evaluation record does not show whether Sunshine's 
proposal was specifically downgraded or given less weight for its 
offer of the combined experience of the firm and its subcontractors to 
show full line food service capabilities.  However, as explained 
below, in evaluating full line food service capability, even giving 
less weight to the Sunshine suppliers' substantial experience, the 
rating of acceptable for the overall corporate experience factor is 
otherwise reasonable and supported by the record.

First, the past performance/experience subfactor in fact included 
three distinct areas of evaluation:  assessing the offeror's 
experience in providing a full line food service as a prime 
vendor/regular dealer; the offeror's previous efforts toward prompt 
resolution of discrepancies and customer complaints; and certain 
experience/past performance data (such as years as a prime 
vendor/regular dealer, annual sales, number of customers, fill rates 
and number of items delivered).  The record shows that for the last 
two of these areas, as stated in the RFP and evaluation plan, the 
evaluation was to be focused more generally on prime vendor/regular 
dealer experience (since the evaluation plan did not expressly require 
full line food service experience under the latter two areas, as was 
specifically required to be considered under the first of the three 
past performance/experience subfactor evaluation areas).  In this 
regard, Sunshine's own substantial experience as a large volume 
regular vendor/dealer of dairy products and as a retail grocer (in 
conjunction with its subcontractors' substantial qualifications in 
these areas), is directly relevant and, we believe, otherwise supports 
the acceptable rating received for the past performance/experience 
subfactor.

Second, even assuming that the agency improperly failed to downgrade 
Sunshine's proposal under the subfactor for past 
performance/experience, the record shows that any such downgrade would 
have had no (or only a minor) effect on the proposal's overall 
corporate experience factor rating, given the strong organizational 
support presentation of the Sunshine proposal, whose evaluation under 
the other equally weighted subfactor of the corporate experience 
factor has not been challenged.  Thus, the awardee's proposal would 
still reasonably support the overall rating of acceptable under the 
corporate experience factor.  In sum, given the strength of the 
experience of each firm represented in the Sunshine proposal, which 
combined reasonably conveys full line food service capabilities, we 
find no basis in the record for concluding that the agency acted other 
than properly in crediting Sunshine's proposal with the experience of 
SuperValu and Hathaway, or for concluding that the combined past 
performance/experience and the strong organizational support shown in 
the proposal warranted a rating of acceptable under the overall 
corporate experience evaluation factor.[5]  See Commercial Bldg. 
Serv., Inc., supra, at 5.

The protest is denied.

Comptroller General
of the United States

1. FSA also alleges that the agency's issuance of amendment No. 3, 
which eliminated various required food items from the solicitation, 
was an improper relaxation of solicitation requirements for Sunshine.  
FSA contends that the issuance of the amendment after the receipt of 
Sunshine's initial proposal (which failed to comply with some of those 
food item requirements) was improper and unfairly benefitted 
Sunshine's proposal's subsequent evaluation rating.  The record shows, 
however, that these products were reasonably and legitimately 
eliminated from the RFP for all offerors.  The elimination was 
justified, as the agency explains, since it involved either 
military-unique (Navy) items not required by any user serviced under 
the contract or the users' identification of approved alternate 
products, which alternates included items proposed by the protester 
and the other offerors in their initial proposals.  Accordingly, the 
record shows that the issuance of the amendment was a proper action by 
the agency to better define its actual needs and thus provides no 
basis to challenge the award.

2. Since the third offeror's proposal is not relevant to FSA's protest 
contentions, it is not discussed further in this decision.

3. In order to be a definitive responsibility criterion (a specific 
and objective standard, qualitative or quantitative, that is 
established by a contracting agency in a solicitation to measure an 
offeror's ability to perform a contract), the solicitation provision 
must reasonably inform offerors that they must demonstrate compliance 
with the standard as a precondition to receiving award.  AT&T Corp., 
B-260447.4, Mar. 4, 1996, 96-1 CPD  para.  200 at 5.  The RFP did not do so 
here.

4. Further, contrary to the protester's contention, a subcontractor's 
experience may be considered, unless expressly prohibited, even where 
the nature of the experience required is that of a prime contractor.  
See, e.g., Tutor-Saliba Corp., Perini Corp., Buckley & Co., Inc., and 
O&G Indus., Inc., A Joint Venture, B-255756, Mar. 29, 1994, 94-1 CPD  para.  
223 at 5.

5. FSA also protests the evaluation of the Sunshine proposal under the 
product sourcing subfactor of the distribution/delivery 
system/location/site visits evaluation factor.  We agree with the 
protester that the record appears to show that, in accordance with the 
criteria set forth in the evaluation plan for the evaluation of 
proposed product sourcing, the awardee's proposal should have received 
a rating of acceptable (rather than highly acceptable) for the 
subfactor, due to the finding that the offeror had failed to provide 
two of the "top items."  Product sourcing, however, was only one of 
five equally weighted subfactors and the Sunshine proposal received 
higher ratings (of highly acceptable) than the FSA proposal did (where 
FSA's proposal was rated acceptable) under two of the remaining 
subfactors.  Therefore, even correcting the apparently erroneous 
subfactor rating, the awardee's proposal remains technically superior 
to the FSA proposal under the most important overall technical 
evaluation factor for award (i.e., distribution/delivery 
system/location/site visits).