BNUMBER:  B-280872.2; B-280872.3  
DATE:  December 9, 1998
TITLE: Venture Productions, B-280872.2; B-280872.3, December 9, 1998
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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:Venture Productions

File:     B-280872.2; B-280872.3 

Date:December 9, 1998

Andrew J. Mohr, Esq., and John J. O'Brien, Esq., Cohen Mohr, for the 
protester.
Jed. L. Babbin, Esq., and Sharon L. Babbin, Esq., Tighe, Patton, 
Tabackman & Babbin, for Film House, Inc., an intervenor.
Mary E. Clark, Esq., Defense Logistics Agency, for the agency.
Ralph O. White, Esq., and Christine S. Melody, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Protest challenging agency assessment of past performance is denied 
where the record shows that the evaluators performed a reasonable 
assessment of proposals in accordance with the solicitation's 
evaluation scheme, and did not deviate from the solicitation's scheme 
by using a past performance rating plan different from the rating plan 
used for the other evaluation factors.  

DECISION

Venture Productions protests the award of a contract to Film House, 
Inc. by the Television-Audio Support Activity, Defense Logistics 
Agency, pursuant to request for proposals (RFP) No. MDA113-97-R-0018, 
issued to purchase creative development, scripting, and production 
services associated with brief informational radio and television 
segments, known as "spot announcements," for use by the Armed Forces 
Radio and Television Service (AFRTS).  Venture argues that the 
agency's evaluation of past performance was unreasonable.

We deny the protest.

The RFP, issued on February 5, 1998, anticipates award of a 1-year 
indefinite-delivery, indefinite-quantity contract with four 1-year 
option periods, to the offeror whose proposal represents the best 
value to the government.  The RFP sets forth five evaluation factors:  
(1) organizational experience; (2) organizational past performance; 
(3) ability as demonstrated by samples of recent spot announcements; 
(4) ability as demonstrated by a creative proposal for two mock spot 
announcements; and (5) price proposal for the mock spot announcements.  
RFP, amend. 0001,  sec.  M.2. 

The first four factors are approximately equal in importance, and 
collectively are significantly more important than the price factor.  
Id. at  sec.  M.3.  For each year of the contract, the RFP anticipates 
ordering a minimum of $3.5 million and a maximum of $5 million of spot 
announcements.  RFP  sec.  B.  

In evaluating proposals, the agency used a source selection plan that 
assigned 200 points to each of the four non-price evaluation factors.  
Although the total number of points assigned to each factor was the 
same, the agency used two different assessment schemes for assigning 
the points.  

For all of the evaluation factors except organizational past 
performance (including the price proposal factor), the 200 available 
points were allocated equally to the two subfactors under each 
factor.[1]  Under each subfactor, the evaluators assigned adjectival 
ratings and point scores in five-point increments as set forth below:

        Rating           Point Range
        Excellent        85/90/95/100 points
        Very Good        65/70/75/80 points
        Good             45/50/55/60 points
        Fair             25/30/35/40 points
        Poor             0/5/10/15/20 points

For the organizational past performance factor, however, no subfactors 
were evaluated, and the 200 available points were allocated as 
follows:

        Rating           Points 
        Excellent        200 points
        Good             150 points
        Inconclusive     100 points
        Marginal          50 points
        Poor               0 points

Evaluation Plan at 5-7.

At the conclusion of the evaluation, the proposals of Venture and Film 
House were the most highly rated.  The results of their evaluations[2] 
are shown below:

EVALUATION FACTOR            VENTURE            FILM HOUSE

Organizational 
Experience                  Excellent
                           200 points            Excellent
                                               197.5 points

Organizational 
Past Performance              Good
                           150 points            Excellent
                                                200 points

Ability as Demonstrated by Samples of Recent Spot AnnouncementsExcellent
                          171.25 points          Excellent
                                               176.25 points

Ability as Demonstrated by Two Mock Spot AnnouncementsExcellent
                          178.75 points          Excellent
                                               173.75 points

Price Proposal for Mock Spot AnnouncementsExcellent
                           200 points            Excellent
                                                185 points

TOTAL SCORE                 Excellent
                           900 points            Excellent
                                               932.5 points
Based on these results, the agency awarded to Film House after 
concluding that its proposal offered the best value to the government.  
This protest followed.

Venture's challenge to the evaluation here focuses entirely on the 
agency's assessment of past performance[3]--the only area where 
Venture, the incumbent for these services, did not receive a rating of 
excellent.  Venture argues that the rating plan used to rate past 
performance deviated from the evaluation scheme by scoring this factor 
differently from the other evaluation factors; that the evaluation 
wrongly elevated criticisms of its past performance as the incumbent 
by various AFRTS users over the more favorable comments of its other 
past performance references; and that the agency improperly allowed 
only one member of the evaluation team to prepare the past performance 
rating until immediately prior to award, when the remaining evaluators 
were asked to review and verify the earlier rating.

Venture's contention that the source selection plan used here violated 
the evaluation scheme ignores the distinction between an evaluation 
scheme included in the RFP, and a source selection plan provided to 
evaluators as a guideline.  As between these two documents, it is the 
RFP--and the evaluation scheme set forth therein--that forms the 
compact between the agency and the offerors about how proposals will 
be evaluated.  Loral Aeronutronic, B-259857.2, B-259858.2, July 5, 
1995, 95-2 CPD  para.  213 at 9.  Source selection plans are internal agency 
instructions and do not give rights to outside parties.  Id. at 9-10.  
Instead, when a protester challenges an evaluation of its past 
performance and experience, we examine the record to determine whether 
the agency's judgment was reasonable and consistent with the stated 
evaluation criteria and with applicable statutes and regulations.  
IGIT, Inc., B-275299.2, June 23, 1997, 97-2 CPD  para.  7 at 5; ESCO, Inc., 
B-225565, Apr. 29, 1987, 87-1 CPD  para.  450 at 7.

The RFP here advised offerors that each of the five evaluation factors 
would be approximately equal in importance.  The record shows that the 
organizational past performance evaluation factor, like each of the 
other evaluation factors, was worth 200 points.  Despite the 
protester's arguments to the contrary, there is no evidence that this 
factor was weighted more heavily than any other factor.

The protester also argues that the stated evaluation scheme was 
violated by the agency's decision to use a separate rating scale for 
the organizational past performance factor than was used for the other 
evaluation factors.  The protester argues that since there are fewer 
degrees of gradation in the rating scale for this factor, slight 
variations in an offeror's past performance were translated into large 
point differences; however, the protester offers no precedent to 
support its view that this kind of evaluation approach is improper, or 
results in an unreasonable result.  In fact, we have upheld an 
agency's use of a different scheme for assessing past performance than 
was used for assessing other evaluation factors.  See Pan Am World 
Servs., Inc., B-235976, Sept. 28, 1989, 89-2 CPD  para.  283 at 3-4 
(complaint that agency failed to assign a color rating to the past 
performance evaluation, as it did in other areas of the evaluation, 
was denied where the agency used a different method for assessing past 
performance but the method nonetheless reached a rational result).  As 
set forth below, our review finds nothing unreasonable or irrational 
about the agency's rating of Venture's proposal in the area of past 
performance.

The record here--and in particular, the past performance survey sheets 
completed by Venture's references, including AFRTS users--shows that, 
other than AFRTS, all of Venture's references gave very favorable 
reviews of Venture's past performance.  However, our review of the 
four past performance survey sheets completed by AFRTS users of 
Venture's services under the prior contract reveal significant 
concerns about Venture's past performance as the incumbent here.  
Specifically, the evaluation summary report explains that the AFRTS 
respondents identified [deleted].  Evaluation Summary, June 12, 1998, 
at 2.  These responses do not support Venture's claim that it should 
have received an "excellent" rating in the area of past 
performance.[4] 

While Venture argues that the agency wrongly treated the past 
performance assessments prepared by several AFRTS users as separate 
references, even though the evaluation panel was directed not to do so 
by the contracting officer, we need not reach the issue of whether the 
AFRTS assessments were considered collectively or separately.  
Regardless of whether the agency considered these assessments 
collectively as the response of one reference--AFRTS--or whether the 
agency considered each of the AFRTS users as a separate reference and 
balanced their assessments against those of Venture's other 
references, we conclude that the rating was reasonable.  In fact, it 
is hard to imagine information more germane to the agency's assessment 
of Venture's past performance than Venture's problems performing these 
same services as the incumbent; based on our review of the record, we 
find the rating of "good" consistent with the overall feedback 
received  and consistent with the stated evaluation scheme.  IGIT, 
Inc., supra, at 6.  

Finally, we turn to Venture's complaint that only one member of the 
evaluation panel prepared the past performance rating, and the entire 
evaluation panel only verified the assessment immediately prior to 
award.  While the facts of Venture's allegation are correct, we fail 
to see how this approach was improper, or how Venture was harmed in 
this regard.  All of the evaluation team members were eventually given 
an opportunity to verify the assessment, and to make any changes they 
thought appropriate, and eventually, all of the evaluation panel 
members signed a memorandum agreeing to the past performance rating 
awarded earlier.  Memorandum from the Evaluation Panel to the 
Contracting Office (Aug. 17, 1998).  We see nothing unreasonable or 
improper about the agency's method of preparing this assessment.

The protest is denied.

Comptroller General
of the United States

1. The evaluation subfactors are not set forth here as they are not 
relevant to this decision.

2. The information here is compiled from the Contracting Officer's 
Report, undated, at 7-8, where it was presented in a slightly 
different format.

3. Initially, and in two supplemental protests, Venture raised other 
issues which were subsequently withdrawn or effectively 
abandoned--i.e., Venture expressly withdrew its allegations of 
evaluator bias, and elected not to reply in its comments to the 
agency's detailed response to Venture's claims that the agency held 
discussions with only one offeror, and violated government-wide 
guidance promulgated by the Office of Federal Procurement Policy.  
Accordingly, Venture has provided our Office with no basis to reject 
the agency's explanations of its actions in these areas.  Appalachian 
Council, Inc., B-256179, May 20, 1994, 94-1 CPD  para.  319 at 8 n.8.

4. While Venture also contends that the AFRTS responses were 
unreasonable and should be discounted, we disagree.  These responses 
are consistent with concerns set forth in contemporaneous materials 
discussed with Venture in Management Review Conferences in both 1996 
and 1997.  Venture was advised of these concerns at the time, and was 
permitted to respond.  These materials are set forth in the Agency 
Report at Tab 11, and include Department of Defense Letters to Venture 
dated Sept. 3, 1997, and June 6, 1996, and Venture's responses 
thereto.  These materials lead us to conclude that the AFRTS 
assessments reasonably relate to the agency's documented experience 
with Venture.