BNUMBER:  B-279173.5 
DATE:  July 22, 1998
TITLE: Acepex Management Corporation, B-279173.5, July 22, 1998
**********************************************************************

DOCUMENT FOR PUBLIC RELEASE
The decision issued on the date below was subject to a GAO Protective 
Order.  This redacted version has been approved for public release.
Matter of:Acepex Management Corporation

File:     B-279173.5

Date:July 22, 1998

James F. Nagle, Esq., Oles Morrison & Rinker, for the protester.
Brian J. Donovan, Esq., Jones & Donovan, for OMSERV Corporation, an 
intervenor.
Marian E. Sullivan, Esq., and John E. Lariccia, Esq., Department of 
the Air Force, for the agency.
John L. Formica, Esq., and Jerold D. Cohen, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

1.  Agency conducted meaningful discussions where it brought its 
principal concerns about the protester's proposal to the protester's 
attention through discussion questions that were not misleading; the 
agency was not required to hold discussions regarding every weakness 
identified in the proposal.

2.  Agency's determination, under an evaluation factor for "cost 
(price)," that the awardee's price for purposes of a fixed-price 
contract was realistic, complete, and reasonable based on a comparison 
with the other offerors' line item and total prices and the government 
estimate is unobjectionable.  
  
3.  Protest that the contracting agency unreasonably evaluated the 
protester's and awardee's competing proposals under certain technical 
evaluation criteria, including past performance, is denied where the 
record shows that the evaluation was reasonable; the protester's mere 
disagreement does not render the agency's judgment unreasonable. 

DECISION

Acepex Management Corporation protests the award of a contract to 
OMSERV Corporation under request for proposals (RFP) No. 
F04626-97-R0004, issued by the Department of the Air Force for 
military family housing maintenance (MFHM) services for Travis Air 
Force Base (AFB), California.
 
We deny the protest.

The RFP, issued on June 16, 1997, provided for the award of a 
fixed-price contract for a base period with four 1-year options.  The 
successful contractor under the RFP will be required to provide, with 
limited exception, all personnel, equipment, tools, materials, 
supervision, and other items necessary to perform the MFHM services.  
RFP  sec.  C.1.1.

The RFP stated that award would be made to the responsible offeror 
submitting the proposal determined to be most advantageous to the 
government, and listed the following evaluation criteria:  (1) Past 
Performance, (2) Staffing, (3) Quality Controls, (4) Maintenance 
Management, and (5) Cost (Price).  RFP  sec.  M-16C.b.  The RFP specified 
that the first four criteria would be evaluated under a 
color/adjectival rating scheme to assess how well the offeror's 
proposed approach meets the evaluation standards and requirements set 
forth in the solicitation, and for proposal risk to assess "the risk 
associated with [the] offeror's proposed approach as it relates to 
accomplishing the requirements of the solicitation."[1]  Id.  The RFP 
added that "[e]ach offeror's cost (price) proposal . . . will be 
evaluated to determine realism, completeness, and reasonableness in 
relation to the solicitation requirements."  Id. at  sec.  M-16C.b.(5). 

The RFP included detailed instructions for the preparation of 
proposals and requested that the offerors' proposals consist of three 
volumes.  Volume 1 was to include, among other things, a completed 
price schedule; volume 2 was to include the technical proposal, 
divided into three sections addressing staffing, quality control, and 
maintenance management; and volume 3 was to describe relevant past 
performance.  RFP  sec.  L-903.

The agency received 15 proposals, and included 10 proposals in the 
competitive range.  Discussions were held, and best and final offers 
(BAFO) were requested, received, and evaluated.  The agency 
conditionally awarded a contract to Crimson Enterprises as the offeror 
submitting the proposal determined most advantageous to the 
government.[2]

Three offerors, including Acepex, filed protests with our Office 
challenging the propriety of the conditional award to Crimson, each 
arguing, among other things, that the agency failed to conduct 
meaningful discussions.  On February 17, 1998, the agency informed our 
Office that it would reopen discussions, request and evaluate new 
BAFOs, and make a new source selection decision.  Shortly thereafter, 
our Office dismissed the protests as academic.  BMAR & Assoc., Inc.; 
Satellite Servs., Inc.; Acepex Management Corp., B-279173 et al., Feb. 
18, 1998.

The agency then conducted written discussions with the 10 offerors, 
and requested and received new BAFOs.  OMSERV's proposal was rated by 
the cognizant source selection evaluation team (SSET) as "blue" with 
"low" risk under the maintenance management and quality controls 
evaluation criteria, and "green" with "low" risk under the past 
performance and staffing evaluation criteria, at a price of 
$17,350,352.  Acepex's proposal was evaluated as "green" with "low" 
risk under each evaluation criterion, at a price of $20,307,543.  The 
source selection authority determined that OMSERV's proposal, which 
was the lowest-priced one received and was one of three proposals to 
have received two "blue" with "low" risk and two "green" with "low" 
risk ratings, represented the best value to the government.[3]  

Acepex protests that the agency "failed to engage in meaningful 
discussions by misleading [Acepex]."

In evaluating Acepex's proposal before the first round of protest 
filings, the SSET noted that Acepex's proposed "staffing level of 37 
full time equivalents is relatively low for our contract size.  This 
could pose a problem in delivering quality customer service . . . ."  
The SSET also noted that the work to be performed by Acepex's 
subcontractors would be limited to work on carpet, asbestos and lead 
abatement, and roofing.  The SSET accordingly rated Acepex's proposal 
under the staffing criterion as having "moderate" risk.  Initial 
Proposal Analysis Report (Protest Report Tab 23) at 11.

The agency found in evaluating Acepex's proposal under the maintenance 
management evaluation criterion that Acepex's proposed "7-10 day 
inventory stock level is not enough to deal with day to day 
operations," and that it would "greatly affect operations specifically 
during contingency and emergency situations."  The SSET further 
evaluated Acepex's proposed plan for answering emergency calls as 
"weak," noting that Acepex would "use an answering system to screen 
calls and dispatch workers" without any provision for notifying the 
cognizant supervisor to confirm if the work would be or was performed.  
The agency rated Acepex's proposal as having "moderate" risk under the 
maintenance management evaluation criterion.  Id. at 12.

When the agency reopened discussions in response to the protests filed 
at our Office, it issued three clarification requests to Acepex.  Each 
clarification request noted an evaluation criterion by name and RFP 
section, and the volume and section of the offeror's proposal to which 
the request was addressed.  Clarification request No. 1 asked for 
information regarding Acepex's past performance on government and 
commercial contracts.  Clarification request No. 2 asked:

     Explain how your company will provide and meet the requirements 
     of the Performance Work Statement with your proposed labor force 
     to ensure proper performance of service calls, change of 
     occupancy . . . and recurring maintenance work.

The agency also requested, in clarification request No. 3, that Acepex 
"[c]larify how [its] inventory (7-10 days stocking) on a project this 
size will support peak periods or contingencies," and explain "how the 
on call supervisor will be notified to confirm the standby worker 
performed work on emergency calls."

Acepex revised its past performance submission in response to the 
first clarification request.  The firm responded to the agency's 
expressed concerns regarding Acepex's proposed staffing level by 
raising its staffing level to 46 full-time equivalents (which included 
the addition of a quality control inspector), and noting that "there 
will be a significant amount of subcontracted work (e.g., roofing, 
carpet, etc.)."  Acepex also provided an explanation as to how it 
arrived at this staffing level, stating that it was based in part on 
the "quantities of jobs required by the RFP" and number of hours 
needed to provide the services based on Acepex's "direct experience" 
in providing such services.  Protest Report, Tab 33.

With regard to the agency's questions concerning the adequacy of 
Acepex's inventory levels, the protester stated that "[g]iven the 
Government's concern, Acepex has revised its inventory plan and will 
have sufficient parts and materials for 30 to 45 days in stock in 
house."  The offeror also explained that it had amended its plan for 
responding to emergency calls by providing for the notification of 
both the on-call supervisor and the worker and for their coordination 
in providing and completing the necessary services.  Id.

The agency determined that, because of Acepex's responses to the 
clarification requests, its BAFO merited ratings of "low" (rather than 
"moderate") risk under both the staffing and maintenance management 
evaluation criteria.

Acepex complains that it was misled during discussions by 
clarification requests Nos. 2 and 3, and thus made unnecessary 
modifications to its proposal.  Acepex argues that the agency, in 
questioning Acepex's initial staffing level, "overlooked the clear 
fact that Acepex proposed to contract out 24 percent of the major 
work, and that involved major roofing, floor refinishing, floor 
replacement, and carpeting."  Protest at 5.  The protester contends 
that had the agency properly evaluated Acepex's initial proposal, it 
would not have misled Acepex during discussions into raising its 
staffing level and, concomitantly, its price.  Acepex makes similar 
claims regarding its proposed 7 to 10 day inventory levels and 
handling of emergency calls.  For example, Acepex contends that the 7 
to 10 day inventory level it initially proposed is the 
industry-accepted standard, and that it was thus misled into amending 
its proposal to provide a greater inventory level and increased price.  
Id. at 6.

Agencies are required to advise competitive range offerors of proposal 
deficiencies so that the offerors are given an opportunity to satisfy 
the government's requirements.  Brown & Root, Inc. and Perini Corp., a 
joint venture, B-270505.2, 
B-270505.3, Sept. 12, 1996, 96-2 CPD  para.  143 at 6.  This obligation is 
not satisfied by discussions that improperly mislead an offeror into 
lowering the evaluated quality of its proposal.  Pan Am World Servs., 
Inc., et al., B-231840 et al., Nov. 7, 1988, 88-2 CPD  para.  446 at 11.

The record shows that the agency's discussions with Acepex were not 
misleading.  For example, contrary to the protester's arguments, the 
agency did not inform Acepex that its staffing or inventory levels 
were too low, nor did it request that Acepex increase its staffing or 
inventory levels.  Rather, the clarification requests, quoted above, 
sought explanations from Acepex as to how it would accomplish the 
requirements of the contract with the staffing and inventory levels 
proposed.  Acepex was free to provide explanations of how the agency's 
needs would be met by the staffing and inventory levels initially 
proposed, or to take some other action, such as raising its proposed 
staffing and/or inventory levels.  In this regard, we note that the 
explanations set forth in Acepex's submissions to our Office during 
the course of the protest regarding the adequacy of the staffing and 
inventory levels it initially proposed were not set forth in Acepex's 
initial proposal, its responses to the clarification requests, its 
subsequent BAFO, or other documents it provided to the agency during 
its consideration of Acepex's proposal.  That is, prior to this 
protest, the "clear fact" that Acepex proposed to subcontract 24 
percent of the work required was not mentioned, nor did Acepex ever 
assert that its proposed 7 to 10 day inventory level or its method for 
answering emergency calls was, as Acepex now claims, in accordance 
with industry standards.

Acepex adds that the agency failed to conduct meaningful discussions 
because during discussions the agency did not point out certain 
weaknesses in Acepex's proposal that were identified by the agency 
evaluators.  The protester lists a number of negative comments that 
appear on the evaluators' worksheets, and contends that had these 
perceived weaknesses been identified during discussions, Acepex could 
have addressed them and thus enhanced its prospects for award.

An agency is not required to afford an offeror all-encompassing 
discussions, or to discuss every aspect of an offeror's proposal that 
receives less than a maximum score.  Brown & Root, Inc. and Perini 
Corp., a joint venture, supra.  Neither is an agency required to 
advise an offeror of a minor weakness that is not considered 
significant, even where the weakness subsequently becomes the 
determinative factor between two closely ranked proposals.  Volmar 
Constr., Inc., B-270364, 
B-270364.2, Mar. 4, 1996, 96-1 CPD  para.  139 at 4-5.  Contracting agencies 
have wide discretion in determining the nature and scope of 
discussions, and their judgments will not be questioned unless shown 
to be without a rational basis.  Textron Marine Sys., B-255580.3, Aug. 
2, 1994, 94-2 CPD  para.  63 at 24.

The record shows that the agency apprised the protester of the 
principal areas of concern regarding the firm's proposal, e.g., the 
nature and extent of Acepex's past performance, and the adequacy of 
Acepex's proposed staffing and inventory levels and procedures for 
answering emergency calls.  The agency did not point out a variety of 
relatively minor weaknesses, and there is nothing in the record to 
suggest that these weaknesses materially affected the rating of 
Acepex's proposal or kept Acepex from having a reasonable chance for 
award.  In sum, the protester was not deprived of meaningful 
discussions.

Acepex argues that OMSERV's price is not realistic and that if the 
agency had performed a "cost realism analysis," as allegedly required, 
it would not have determined that OMSERV's price was "realistic, 
complete, and reasonable."  

As stated above, the RFP provided that an offeror's "cost (price) 
proposal" would be evaluated for "realism, completeness, and 
reasonableness in relation to the solicitation requirements."  The 
concept of cost realism generally applies to cost-reimbursement 
contracts where the RFP requires the submission of cost data and it is 
important for the government to measure the likely cost of performance 
before choosing from among competitors in the procurement.  Federal 
Acquisition Regulation (FAR)  sec.  15.605(c), 15.608, 15.805-3 (June 
1997).  Cost realism therefore ordinarily is not considered in the 
evaluation of proposals for a fixed-price contract such as the one 
involved here, since a fixed-price contract provides for a definite 
price and places the risk and responsibility for all contract costs 
and resulting profit or loss upon the contractor.  Volmar Constr., 
Inc., B-272188.2, Sept. 18, 1996, 96-2 CPD  para.  119 at 5; Sperry Corp., 
B-225492, B-225492.2, Mar. 25, 1987, 87-1 CPD  para.  341 at 3.  
Accordingly, and although an agency may provide for a "cost realism" 
analysis in the solicitation of fixed-priced proposals to measure an 
offeror's understanding of the solicitation requirements, even a 
fixed-price offer that is below cost is legally unobjectionable and 
cannot be rated lower or downgraded in the price evaluation for source 
selection by virtue of its low price.  Id. at 3-4.  On the other hand, 
an agency will perform a price analysis in such a solicitation since 
the risk of poor performance when a contractor is forced to provide 
services at little or no profit is of legitimate concern.  Volmar 
Constr., Inc., B-272188.2, supra; see FAR  sec.  15.805-2. 

We recognize that the RFP here used the term "cost" in the evaluation 
factor ("Cost (Price)"); we also recognize that in describing the 
factor the RFP provided that "proposals will be evaluated for cost 
realism."  RFP  sec.  M-16C.b.(5)(a).  Nevertheless, the RFP contemplated 
the award of a fixed-price contract, the evaluation factor specified 
"Price" along with "Cost," and the solicitation did not require the 
submission of cost data (only a price schedule).  Therefore, and 
consistent with the nature of a fixed-price contract, the evaluation 
factor cannot reasonably be viewed as being other than price, nor can 
the RFP reasonably be read as committing the agency, in evaluating 
proposals, to perform a cost analysis under FAR  sec.  15.805-3, as opposed 
to a price analysis to ascertain whether the offered prices were 
reasonable and realistic.  See The Cube Corp., B-277353, Oct. 2, 1997, 
97-2 CPD  para.  92 at 5.

Price analysis techniques that may be used to determine whether prices 
are reasonable and realistic include a comparison of the prices 
received with each other, FAR  sec.  15.805-2(a); with prior contract 
prices for the same or similar services, FAR  sec.  15.805-2(b); and with 
an independent government cost estimate.  FAR 
 sec.  15.805-2(e).  The depth of an agency's price analysis is a matter 
within the agency's discretion.  Ameriko-OMSERV, B-252879.5, Dec. 5, 
1994, 94-2 CPD  para.  219 at 4.

The Air Force's price analysis was based on a comparison of the 
offerors' proposed line item and total prices with each other and with 
the government estimate.  In this regard, the price analysis matrix 
prepared by the agency shows that OMSERV's total price was only 1 
percent lower than the next lowest-priced proposal, and 
6 and 12 percent lower than the third and fourth lowest-priced 
proposals.  Further, OMSERV's price was only 15 percent lower than 
Acepex's, and 16 percent lower than the agency estimate.  The agency 
concluded based on its comparison of OMSERV's price with the agency 
estimate and the prices of the other nine proposals received that 
OMSERV's price was complete, reasonable, and realistic.  Revised 
Proposal Analysis Report (Protest Report Tab 38) at 5-6.  Based on our 
review, we have no basis to question the reasonableness of the 
agency's determination.  See The Cube Corp., supra, at 5-6.

Acepex protests that the agency's evaluation of its and OMSERV's 
technical proposals was unreasonable.  The evaluation of technical 
proposals is a matter within the discretion of the contracting agency, 
since the agency is responsible for defining its needs and the best 
method of accommodating them.  Marine Animal Prods. Int'l, Inc., 
B-247150.2, July 13, 1992, 92-2 CPD  para.  16 at 5.  In reviewing an 
agency's evaluation, we will not reevaluate technical proposals, but 
instead will examine the agency's evaluation to ensure that it was 
reasonable and consistent with the solicitation's stated evaluation 
criteria.  MAR Inc., B-246889, Apr. 14, 1992, 92-1 CPD  para.  367 at 4.  An 
offeror's mere disagreement with the agency does not render the 
evaluation unreasonable.  McDonnell Douglas Corp., B-259694.2,
B-259694.3, June 16, 1995, 95-2 CPD  para.  51 at 18.

Acepex specifically challenges the agency's evaluation of its and 
OMSERV's proposals as "green" with "low" risk under the past 
performance evaluation criterion.

In evaluating Acepex's proposal under the past performance criterion, 
the agency found that Acepex had 8 years of experience in performing 
government contracts, and noted that the contract surveys it had 
received "indicated satisfactory performance with no major problems 
requiring corrective actions."  The agency found, however, that 
Acepex's experience in performing MFHM services was primarily as a 
"subcontractor or in a joint venture with another company" and that 
the subcontracts did not appear to have been similar in size and scope 
to the contract contemplated by the RFP.  The agency concluded that, 
while Acepex's proposal merited a rating of "green," there was 
"moderate potential . . . to cause disruption of schedule, increase in 
cost or degradation of performance."  The agency thus initially rated 
Acepex's proposal under the past performance criterion as having 
"moderate" risk.  Initial Proposal Analysis Report, supra, at 11.

As previously mentioned, the agency issued a clarification request 
regarding Acepex's past performance when it reopened discussions.  In 
responding to this request, Acepex represented that, among other 
things, its experience as a subcontractor in providing MFHM services 
includes "two current housing contracts 
[which] are of the same size and complexity as the current 
solicitation."  The agency determined that, although Acepex lacked 
experience as an MFHM services prime contractor, its proposal 
represented "low" (rather than "moderate") risk because Acepex's 
subcontracts were similar in size and scope to that contemplated by 
the RFP.  Revised Proposal Analysis Report, supra, at 10.

Acepex complains that the agency failed to contact five current 
contract references Acepex had listed in its proposal, including the 
contractor for which Acepex was performing the two MFHM subcontracts 
mentioned above.  Acepex notes that the SSET appeared somewhat 
concerned because Acepex had performed as a subcontractor on the two 
MFHM contracts discussed above, rather than as the prime contractor, 
and argues that "the fact that the contractual device [was] a 
subcontract should not be used against Acepex . . . ."  Protester's 
Comments at 17.

There is no legal requirement that all references in a proposal be 
checked.  Logicon RDA, B-261714.2, Dec. 22, 1995, 95-2 CPD  para.  286 at 7; 
Dragon Servs., Inc., B-255354, Feb. 25, 1994, 94-1 CPD  para.  151 at 8; 
Questech, Inc., B-236028, Nov. 1, 1989, 89-2 CPD  para.  407 at 3.  In 
reviewing the manner and conduct of an agency in contacting or 
choosing not to contact references listed by offerors in their 
proposals, we look to see if the agency proceeded in a reasonable and 
prudent manner.  See Int'l Bus. Sys., Inc., B-275554, Mar. 3, 1997, 
97-1 CPD  para.  114 at 5.   

The agency sent past performance questionnaires to six of the 
references listed by Acepex in its proposal.  The references chosen by 
the agency included three of the references listed in Acepex's 
proposal under the heading "military family housing maintenance 
contracts and subcontracts" (Acepex was performing one of the 
contracts during the evaluation), the reference listed by Acepex under 
the heading "hospital housekeeping services" (for which Acepex had 
performed four contracts and currently is performing a fifth), and at 
least one of the references listed under the heading "custodial 
services contracts" (Acepex is currently performing contracts for both 
of these references).  Despite Acepex's view to the contrary, we 
simply cannot see how the agency--which contacted three of the 
references listed for which Acepex had performed MFHM services, and a 
number of the references for which Acepex currently was performing 
services--acted unreasonably.  Also, given the inherent differences 
between acting as a prime contractor and as a subcontractor, it was 
not unreasonable for the agency, when evaluating Acepex's proposal 
under the past performance evaluation criterion, to have considered 
Acepex's performance of MFHM services similar in size and complexity 
as a subcontractor less favorably than if the same services had been 
performed by Acepex as a prime contractor.  See Robbins-Gioia, Inc., 
B-274318 et al., Dec. 4, 1996, 96-2 CPD  para.  222 at 20 (where we did not 
object to assigning a moderate risk rating to an offeror with no 
specific experience as a general contractor even though we recognized 
that the firm had performed similar tasks as a subcontractor).             

We also see no basis to object to the Air Force's evaluation of 
OMSERV's proposal under the past performance criterion ("green" with 
"low" risk).

In evaluating OMSERV's proposal, the agency initially found that, 
while OMSERV had successfully completed three MFHM services contracts 
as the prime contractor, the contracts were smaller in size and 
complexity than that contemplated by the RFP.  The agency thus 
evaluated OMSERV's proposal as "green" with "moderate" risk.  Initial 
Proposal Analysis Report, supra, at 13.

When the agency reopened discussions, it requested further information 
from OMSERV regarding its past experience.  OMSERV explained in its 
response that, although it had not performed a contract equal in size 
to that contemplated by the RFP, the three contracts it had performed 
(all for the Air Force) were similar in complexity and scope, and when 
considered together--as they had been performed concurrently for 2 
years--in size.  OMSERV submitted a chart in support of its 
explanation, which compared the work required under the "combined" 
contracts with the estimated work required under the Travis AFB 
contract, regarding, for example, the number of service calls (17,000 
for the combined contracts in comparison to an estimated 12,747 for 
the Travis AFB contract), and change of occupancy maintenances (700 
for the combined contracts in comparison to 715 estimated for the 
Travis AFB contract).  Based on this explanation, the agency raised 
OMSERV's risk rating under the past performance evaluation criterion 
from "moderate" to "low."               

Acepex points out, as did OMSERV in its response to the agency's 
clarification request, that 600 units required to be maintained by 
OMSERV were demolished by the agency during the performance of one of 
the three MFHM contracts, thus reducing the number of units maintained 
by OMSERV under the combined contracts to 1,751, in contrast to the 
2,486 units to be maintained at Travis AFB under this RFP.  As noted 
by the agency, however, prior to the demolition of the 600 units there 
was a period that appears from the record to approximate 1 year during 
which OMSERV was responsible for the maintenance of 2,351 units under 
the three contracts.  More importantly, the record demonstrates that, 
regardless of the number of units, OMSERV was required to perform, as 
mentioned above, a number of service calls and change of occupancy 
maintenances in its performance of the three contracts that is 
comparable to those estimated for performance under this RFP.  In sum, 
we do not agree that the agency acted unreasonably in evaluating 
OMSERV's proposal under the past performance criterion as "green" with 
"low" risk.[4]

Acepex also complains that the evaluation record fails to evidence 
that the agency considered 8 of 12 "added value items" that Acepex 
included in its proposal.  For example, the protester points out that 
the evaluation record does not specifically mention Acepex's offer to 
provide each occupied unit with a refrigerator magnet "in the shape of 
a house, with the phone numbers for the service call desk and 
emergency after hours displayed," and customer survey cards to be 
completed after a service technician responds to a service call or 
performs recurring maintenance in a dwelling.  Acepex adds that the 
evaluation record also does not evidence that the agency considered 
Acepex's offer, in response to the clarification request for further 
information regarding its staffing, to provide an additional quality 
control inspector.
         
The agency responds that, while Acepex's 12 added value items and 
addition of a quality inspector were considered, "they were not 
significant enough to merit higher ratings for Acepex's proposal or 
special mention in the evaluation record."  Supplemental Protest 
Report at 4.  

We find the agency's explanation plausible, given the relatively minor 
import of the value added items not specifically mentioned in the 
evaluation record.  With regard to the quality control inspector, as 
noted above, Acepex added the quality control inspector in its 
response to clarification request No. 2, and the record reflects that 
this response led to Acepex's proposal being evaluated as having 
"low," rather than "moderate" risk under the staffing evaluation 
criterion.[5]  Even if we were to conclude that the lack of specific 
mention of 8 of the 12 value added items and addition of one quality 
control inspector was the result of the agency's failure to consider 
these aspects of Acepex's proposal, we see no reasonable possibility 
that Acepex would have been prejudiced by such an oversight, given 
OMSERV's proposal's significantly superior technical rating and $3 
million, or 16 percent, price advantage.[6]

The protest is denied.

Comptroller General
of the United States  

1. The color/adjectival ratings used by the agency in evaluating 
proposals were blue/exceptional, green/acceptable, yellow/marginal, 
and red/unacceptable.  With regard to risk, the ratings used were 
high, moderate, and low.  Source Selection Evaluation Guide (Tab 6) at 
2, 6.

2. The procurement was undertaken as part of a cost comparison study 
regarding whether to perform the services in-house or by contract.  
The award was conditioned on completion of a public review period, any 
requests for review made under the cost comparison appeals process, 
and the availability of funds.

3. No proposal received a "blue" rating under more than two evaluation 
criteria, and the two other proposals that received two "blue" with 
"low" risk and two "green" with "low" risk ratings were higher priced 
($20,667,655 and $26,667,796).

4. The protester also complains that its past experience as an MFHM 
subcontractor should have been rated higher than OMSERV's "combined" 
past experience as an MFHM prime contractor.  As mentioned previously, 
it was not unreasonable for the agency to consider Acepex's past 
experience as an MFHM subcontractor less favorably than if the firm 
had performed the same work as a prime contractor; this aspect of 
Acepex's protest thus constitutes its mere disagreement with the 
agency's evaluation, and does not provide a basis upon which to find 
the evaluation  unreasonable.

5. Specifically, the first two lines of Acepex's response to 
clarification request No. 2 are as follows:

            Given the Government's concern, Acepex has raised its 
            staffing levels to 46 [full time equivalents] (48 
            individuals).  We have added a quality control inspector, 
            as well as increasing the staffing of general maintenance 
            workers, painters, plumbers, and janitors.

6. Acepex complains that the evaluation record, which consists of, 
among other things, the evaluators' worksheets, proposal analysis 
reports, and source selection statements, is poorly documented and 
"should be deprived of any deference."  For example, the protester 
complains that one evaluator used an evaluation form apparently of his 
own making, rather than the standard evaluation form used by the other 
evaluators.  While the evaluation record, including the evaluators' 
worksheets, is not a model of clarity, the agency's evaluation of 
proposals and its source selection are sufficiently detailed to allow 
for the review of Acepex's protest, so that the record is 
unobjectionable.  See Matrix Int'l Logistics, Inc., B-272388.2, Dec. 
9, 1996, 97-2 CPD  para.  89 at 5; Southwest Marine, Inc.; Am. Sys. Eng'g 
Corp., B-265865.3, B-265865.4, Jan. 23, 1996, 96-1 CPD  para.  56 at 10.