BNUMBER:  B-280456.2 
DATE:  September 17, 1998
TITLE: Omega World Travel, Inc., B-280456.2, September 17, 1998
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Matter of:Omega World Travel, Inc.

File:     B-280456.2

Date:September 17, 1998

Barry Roberts, Esq., and Brian J. Hundertmark, Esq., Roberts & 
Hundertmark, for the protester.
Philip T. McCaffrey, Esq., U.S. General Accounting Office, for the 
agency.
Linda S. Lebowitz, Esq., and Michael R. Golden, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Where there is no requirement that an agency define its needs for 
commercial-off-the-shelf software by commercial brand name, the agency 
appropriately defined its needs for commercially available travel 
management software by using a broad commercial item description 
stated in terms of functional requirements.

DECISION

Omega World Travel, Inc. protests the terms of request for proposals 
(RFP) No. OAM-98-N-0005, issued by the U.S. General Accounting Office 
(GAO) for travel management services and a client/server-based travel 
subsystem software package.

We deny the protest.

The RFP was issued on June 1, 1998.  As relevant to this protest, the 
RFP stated that the agency required:

     a commercially available software package which supports travel 
     processing under federal regulations.  The software would be used 
     by travelers or administrative staff supporting the travel 
     function to create travel orders and travel vouchers compliant 
     with the appropriate travel rules.  The software must have the 
     capability to directly export the related accounting transactions 
     into GAO's Financial Management System.

RFP, Attachment B, section II, at 1.

The RFP listed technical and functional requirements in order for the 
software to be able to run on the GAO network.  As relevant here, the 
functional requirements were divided into the following four 
categories:  (1) pre-travel processes; (2) post-travel processes; (3) 
reports; and (4) special features.  RFP, Attachment B, sections I--IV, 
at 2-8.  For each category, specific and detailed software 
capabilities or features to be provided were listed.  For example, 
among other things, in the reports category, the software was required 
to "[r]eport outstanding travel advances," RFP, Attachment B, section 
III, at 7, and in the special features category, the software was 
required to "identify charges made to employees' personal government 
charge cards and the agency's central Government Transportation charge 
account."  RFP, Attachment B, section IV, at 8.  Offerors were 
advised, however, that the "RFP does not require that . . . the 
awardee have access to the government's charge card database."  RFP, 
Executive Summary, at 2.

The amended closing date for receipt of proposals was July 20.  RFP, 
amendment No. 1, June 24, 1998.  Omega did not submit a proposal by 
the stated closing time.

Omega objects to the agency's description of its software needs by 
listing in the RFP functional requirements for the software.  Omega 
believes that the agency should have described its needs by naming the 
commercially available software which the agency learned as part of 
its market research efforts would satisfy the RFP requirements.  We 
disagree.

Market research is conducted to determine if commercial items are 
available to meet the government's needs.  Federal Acquisition 
Regulation (FAR)  sec.  10.002(b); see also FAR  sec.  10.001(a)(3)(ii)(A).  
Here, the agency, through its market research efforts, identified 
PerDiemAzing and Gelco Travel Manager as commercially available 
software which would satisfy its needs.  However, there is no 
requirement that the agency, in defining its needs for commercial 
items, do so by listing commercial brand names.  Rather, FAR  sec.  
11.002(a)(2)(i)(A)-(C) authorizes an agency to describe its needs for 
commercial supplies or services in terms of functions to be performed, 
performance required, or essential physical characteristics.  See also 
FAR  sec.  12.202(b); Adventure Tech, Inc., B-253520, Sept. 29, 1993, 93-2 
CPD  para.  202 at 3-4.

Here, to acquire commercial travel management software, the agency 
appropriately used a broad commercial item description stated in terms 
of functional requirements.  More specifically, the agency divided the 
software's functional requirements into four categories and provided 
detailed descriptions of the software capabilities or features to be 
provided.  Contrary to Omega's objection, while the agency was aware 
of at least two commercial-off-the-shelf software products that would 
satisfy its needs, the agency was not obligated to specify these 
products in the RFP as the agency was not restricting its needs to a 
particular brand name product.  Instead, for this procurement for 
commercial-off-the-shelf software, it was incumbent upon the offerors 
to propose a commercial product to satisfy the government's functional 
requirements.

Omega also contends that the RFP requirements to "[r]eport outstanding 
travel advances," and to "identify charges made to employees' personal 
government charge cards" are restrictive of competition because only a 
travel agency that also owns the government charge card database--in 
this case, the incumbent contractor, American Express--can meet these 
requirements.  However, Omega's argument is based on a factually 
inaccurate premise.

The record shows that prior to the amended closing time, Omega was 
told that American Express was no longer the agency's travel charge 
card provider, and therefore would not have access to charge card 
information.  Moreover, the RFP's executive summary stated that the 
RFP did not require the awardee to have access to the government's 
charge card database.  Obviously, if the awardee did not have access 
to the government's charge card database, in order for the awardee to 
comply with the referenced reporting requirements, either the traveler 
or the government would have to furnish the necessary information to 
the awardee.  It is clear from this record that all potential offerors 
could compete on an equal basis and that Omega's concern that American 
Express essentially had an unfair competitive advantage because it 
owned the government charge card database was unfounded.

Finally, in its comments on the agency report, Omega challenges, for 
the first time, the functional requirement in the RFP that the 
commercially available software interface electronically with the 
agency's federal financial system software.  RFP, Attachment B, 
section IV, at 8.  Omega maintains that the interface process requires 
customization of the software, thereby rendering the software other 
than commercial-off-the-shelf.

This allegation, involving an alleged solicitation impropriety 
apparent prior to the July 20 amended closing time for receipt of 
proposals, is untimely as it was not raised prior to that closing 
time.  Bid Protest Regulations, 4 C.F.R.  sec.  21.2(a)(1) (1998); 
Engelhard Corp., B-237824, Mar. 23, 1990, 90-1 CPD  para.  324 at 7.  In any 
event, the agency explains that an interface is a separate program 
that allows two software programs, i.e., the travel management 
software and the financial systems software, to communicate with each 
other.  Omega has failed to show how the creation of an interface 
involves the customization of commercially available software.

The protest is denied.

Comptroller General
of the United States