BNUMBER:  B-278678 
DATE:  February 27, 1998
TITLE: The American Indian Center, Inc., B-278678, February 27, 1998
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Matter of:The American Indian Center, Inc.

File:     B-278678

Date:February 27, 1998

Mary Helen Deer and T. Craig Anderson for the protester.
Terrence J. Tychan, Department of Health & Human Services, for the 
agency.
Jennifer Westfall-McGrail, Esq., and Christine S. Melody, Esq., Office 
of the General Counsel, GAO, participated in the preparation of the 
decision.

DIGEST

1.  Protest objecting to technical evaluation of proposal is denied 
where record demonstrates that evaluators' judgments as to merits of 
proposal were reasonable.

2.  General Accounting Office will not consider complaint that awardee 
lacks the stability of management and financial integrity necessary 
for performance since such a complaint is in essence a challenge to 
the contracting officer's affirmative determination of responsibility. 

DECISION

The American Indian Center, Inc. (AIC) protests the evaluation of its 
proposal and the award of a contract to the Dallas Inter-tribal 
Center, Inc. (DIC) under request for proposals (RFP) No. 
246-97-R-0012, issued by the Department of Health and Human Services, 
Indian Health Service, for operation of a medical and dental clinic 
serving the Indian population of the Dallas, Texas metropolitan area.  
The protester contends that the evaluators' criticisms of its proposal 
were unfounded and that the awardee should have been found ineligible 
for award.

We deny the protest.

The RFP solicited proposals to furnish, equip, and staff an outpatient 
medical and dental clinic accessible to the Indian population of the 
Dallas metropolitan region.  The solicitation advised offerors that 
technical factors, the most important of which were program 
description (worth 35 percent of an offeror's technical score), health 
problem statements (worth 20 percent), and equipment and facilities 
(also worth 20 percent), would be of paramount importance in the 
selection of an awardee,[1] but that cost would be a discriminating 
factor in the event there was no significant difference in the 
technical evaluations of two or more offers.  RFP  sec.  M.  Competition 
under the solicitation was limited to Indian-owned firms, and award of 
a cost reimbursement contract was contemplated.

Two proposals were received by the September 2, 1997, closing date, 
one from AIC and one from the incumbent contractor, DIC.  Upon initial 
evaluation, AIC's proposal received a score of 86 and DIC's a score of 
64 out of a total of 100 available points.  After holding discussions 
with both offerors and furnishing them with the opportunity to revise 
their proposals, the evaluators reevaluated and rescored the 
proposals.  The evaluators found that DIC had furnished information 
that had been missing from its initial proposal and awarded the 
proposal a significantly improved score of 97.5.  AIC's proposal, on 
the other hand, received a substantially lower score of 68 because the 
revised proposal confirmed some of the weaknesses initially noted by 
the evaluators.  Among the weaknesses noted in AIC's proposal were the 
location of its clinic at a site not accessible by public 
transportation; its proposed reliance on volunteers to transport and 
install government-owned equipment at its facility; its failure to 
have hired or obtained commitments from required staff; and its 
failure to have submitted property and procurement manuals.

After evaluation of AIC's and DIC's costs proposals, the agency 
concluded that their evaluated costs were virtually equal (AIC, 
$681,487.62; DIC, $681,975.69).  Because DIC had received a 
significantly higher technical score than AIC and its costs were 
considered reasonable, DIC was selected for award.  A contract was 
awarded to DIC on October 31.  AIC received a telephonic debriefing on 
November 13, and protested to our Office on November 19.

The protester takes issue with the agency's evaluation of its 
proposal.  The evaluation of technical proposals is primarily the 
responsibility of the contracting agency since the agency is 
responsible for defining its needs and the best method of 
accommodating them, and it must bear the burden of any difficulties 
resulting from a defective evaluation.  Federal Envtl. Servs., Inc., 
B-250135.4, May 24, 1993, 93-1 CPD  para.  398 at 8-9.  In reviewing 
protests challenging an agency's evaluation of proposals, we will not 
substitute our judgment for that of the agency regarding the merits of 
proposals; rather, we will examine the agency's evaluation to ensure 
that it was reasonable and consistent with the stated evaluation 
criteria and applicable statutes and regulations.  Young Enters., 
Inc., B-256851.2, Aug. 11, 1994, 94-2 CPD  para.  159 at 3.  A protester's 
mere disagreement with the agency's evaluation does not render it 
unreasonable.  CORVAC, Inc., B-244766, Nov. 13, 1991, 91-2 CPD  para.  454 
at 5.  Here, we conclude that the agency's evaluation of AIC's 
proposal was reasonable.

As noted above, one of the principal weaknesses the agency found in 
AIC's proposal was the location of its clinic at a site not accessible 
by public transportation.  The proposal was downgraded for this 
weakness under the health problem statements evaluation factor, 
receiving 13.5 of 20 available points.  AIC asserts that the location 
of its clinic--1 mile south of Highway 183 in Euless, Texas, which is 
midway between Dallas and Fort Worth--is a strength rather than a 
weakness because Euless is more centrally located, relative to the 
population the clinic is intended to serve, than is the south-Dallas 
location of the DIC clinic.  The protester further argues that the 
lack of public transportation to its location does not render the 
facility inaccessible to clients without personal transportation 
because it proposed to furnish shuttle van service between the clinic 
and several locations accessible by the Dallas and Fort Worth public 
transportation systems.

We think that the evaluators reasonably viewed the location of AIC's 
clinic, regardless of how central to the population it is intended to 
serve, as a weakness due to its inaccessibility by public 
transportation.  Although the protester insists that the vast majority 
(i.e., 75 percent) of clinic patrons have access to personal 
automobiles for travel to and from the clinic, there remains a 
significant number (i.e., 25 percent) who are dependent on public 
transportation for access to the clinic.  We recognize that AIC 
proposed shuttle van service as a solution to the inaccessibility 
problem; it is clear from the record that the evaluators did not view 
the proposed service, which relies on a single van to ferry patients 
back and forth to a variety of different drop-off points, as providing 
the same level of access as public transportation directly to the 
site, however, and we see no basis upon which to question their 
judgment in this regard.

Under the equipment and facilities factor, AIC's proposal received 9.5 
of 20 points; the agency identified as a weakness AIC's proposed 
reliance on volunteers to transport and install government-owned 
equipment at its facility.  The protester argues that its proposed 
reliance on volunteer labor should not have been viewed as a weakness 
because the nondental equipment would not require specially trained 
personnel to move it from one site to another.  The protester has not 
argued that relocation of the dental equipment could be accomplished 
by nonprofessionals; thus, regardless of whether or not volunteers 
could successfully transport and reassemble the nondental items, we 
think that the evaluators had a reasonable basis for viewing the 
protester's failure to propose to employ professional movers as a 
weakness.[2]

The proposal also was downgraded under the program description factor 
(under which it received 23.5 of 35 points) in part because the 
evaluators found that AIC had failed to hire or obtain commitments 
from required staff.  AIC argues that it was unfair for the evaluators 
to downgrade its proposal for failing to include letters of commitment 
from proposed staffers given that the RFP did not require such 
letters.

Although the solicitation did not explicitly require the submission of 
letters of commitment from proposed clinic staffers, it did require 
offerors to "[p]rovide information on how the project is to be 
organized, staffed and managed."  RFP 
 sec.  L-14.G.4.a.(3)  (Emphasis added).  AIC responded to this request for 
information by stating, on page 30 of its proposal, as follows:

     Professional staff from physicians to support staff will be hired 
     to staff the clinic to meet all requirements for standards and 
     for the State of Texas.  If AIC is successful in being awarded 
     this contract, it is the intention to give the staff of the 
     current contracted clinic the first opportunity to retain their 
     positions.  For those positions left unfilled, advertisements 
     will be placed in the local newspapers. 

According to the protester, these sentences clearly conveyed its 
intent to hire the incumbent's work force.

We do not think that the excerpt from its proposal cited by the 
protester conveyed the information that AIC apparently intended, i.e., 
that it intended to offer positions to the staff currently working at 
the DIC clinic and had reason to expect that they would accept.  
Rather, the excerpt gave the impression the DIC staffers would not be 
approached unless and until AIC received the award--and that no other 
efforts at recruitment would be made until after the positions had 
been offered to the incumbent employees.  We think that it was 
reasonable for the evaluators to have viewed this approach to 
recruitment as insufficient to ensure that AIC would be prepared to 
begin furnishing services on the contract's scheduled starting 
date--and therefore to have downgraded the proposal under the program 
description criterion.[3]

Finally, AIC argues that DIC should have been found ineligible for 
award due to its management instability and lack of financial 
accountability.  

Whether an offeror has the organization and financial controls 
necessary for successful performance is a matter bearing on its 
responsibility.[4]  See Federal Acquisition Regulation  sec.  9.104-1(e).  
Thus, where a protester argues that an awardee lacks these elements, 
it is in essence challenging the contracting officer's affirmative 
determination of the awardee's responsibility.  Because the 
determination that an offeror is capable of performing a contract is 
based in large measure on subjective judgments which generally are not 
readily susceptible of reasoned review, we do not consider such 
challenges absent a showing of possible bad faith on the part of 
government officials or that definitive responsibility criteria in the 
solicitation were not met.  Bid Protest Regulations, 4 C.F.R.  sec.  
21.5(c) (1997); King-Fisher Co., B-236687.2. Feb. 12, 1990, 90-1 CPD  para.  
177 at 2.  Such a showing has not been made here.

The protest is denied.

Comptroller General
of the United States

1. The remaining technical evaluation factors were staff organization 
and supervision (worth 10 percent of the technical score), quality 
assurance and program evaluation (worth 5 percent), staffing 
description (worth 5 percent), and management systems (worth 5 
percent).

2. The evaluators also noted, as a weakness relating to AIC's 
equipment, that the acquisition of DIC's equipment would not include 
the "head x-ray," which belonged to DIC, and that AIC had not 
explained how it otherwise intended to acquire such a unit.  We think 
that this criticism of AIC's proposal was unreasonable since, as the 
protester points out, the catalogue of government-owned equipment 
furnished with the RFP identified several panoramic x-ray machines as 
available for transfer to the awardee.  To the extent that this 
listing was in error (and a necessary x-ray machine identified as 
belonging to the government in fact belonged to DIC), we think that it 
was incumbent upon the agency to raise the matter with AIC and give 
the protester the opportunity to explain how it could otherwise 
acquire the necessary item before penalizing it for failing to propose 
to furnish it.  We do not think that the failure to discuss this item 
resulted in prejudice to AIC, however, because it is apparent from the 
record that even if this deficiency had been corrected, AIC would 
still have received a relatively low score under the equipment and 
facilities criterion due to the previously discussed concerns 
regarding the moving of equipment.  In fact, even assuming AIC's 
proposal had received full points under this factor (increasing its 
score by 10.5 points), its overall score (78.5) would remain 
considerably lower than the awardee's (97.5).  Given that the 
offerors' costs were virtually equal, there is no basis to conclude 
that such an increase in score would have affected the award decision.

3. We need not address the protester's final complaint regarding the 
evaluation of its technical proposal--i.e., that it was improperly 
downgraded under the management systems criterion due to its failure 
to furnish property management and procurement manuals--because any 
downgrading of the proposal on this basis was de minimis.  In this 
regard, AIC's proposal received a score of 3.5 of a maximum possible 
of 5 under the Management Systems criterion, meaning that it lost only 
1.5 points for failing to furnish the manuals. 

4. While traditional responsibility factors may be used as technical 
evaluation factors in a negotiated procurement when a comparative 
evaluation is to be made, Docusort, Inc., B-254852, Jan. 25, 1994, 
94-1 CPD  para.  38 at 6, the RFP here did not provide for consideration of 
such factors.