BNUMBER:  B-280969 
DATE:  December 14, 1998
TITLE: MCR Federal, Inc., B-280969, December 14, 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:MCR Federal, Inc.

File:     B-280969

Date:December 14, 1998

William L. Walsh, Jr., Esq., J. Scott Hommer, III, Esq., Wm. Craig 
Dubishar, Esq., and Paul N. Wengert, Esq., Venable, Baetjer and 
Howard, for the protester.
David R. Johnson, Esq., Gibson, Dunn & Crutcher, for 
PricewaterhouseCoopers, an intervenor.
John F. Ruoff, Esq., Defense Finance and Accounting Service, for the 
agency.
Susan K. McAuliffe, Esq., and Christine S. Melody, Esq., Office of the 
General Counsel, GAO, participated in the preparation of the decision.

DIGEST

Protest of proposal evaluation and source selection under solicitation 
where technical factors are more important than price is sustained 
where the contracting officer's determination that the awardee's 
lower-priced proposal was technically superior to that of the 
protester is inconsistent with the solicitation's evaluation scheme, 
and where the record provides insufficient contemporaneous 
documentation to either support agency's post-protest assertion that 
the proposals are technically comparable--so that price would become 
an appropriate discriminator for award--or show that the source 
selection authority ever considered whether the protester's higher 
rating in one area (key personnel) was worth the cost premium 
associated with its proposal.

DECISION

MCR Federal, Inc. protests the award of contracts to KPMG Peat 
Marwick, (KPMG) and PricewaterhouseCoopers (PWC) under request for 
proposals (RFP) No. MDA220-98-R-0004, issued by the Defense Finance 
and Accounting Service (DFAS) for contract reconciliation services.[1]  
MCR challenges the agency's source selection decision as inconsistent 
with the stated evaluation scheme for award.

We sustain the protest of the award to PWC, and deny the protest of 
the award to KPMG.

The RFP, issued February 17, 1998, contemplated the award of multiple 
indefinite-delivery/indefinite-quantity, time-and-materials technical 
support services contracts to be performed over 1 base year, with up 
to 4 option years.  RFP  sec.  B, L.9.  Award was to be made to the 
offerors determined to have submitted the proposals most advantageous 
(in terms of offering the best value) to the government, considering 
price and other factors.  RFP  sec.  M.3(b).  Section M of the RFP provided 
three criteria to be considered by the agency in its determination as 
to which proposals offered the best value:  technical factors, past 
performance, and price.  Section M.3(d) of the RFP provided that 
"[w]hen combined, all evaluation factors other than cost or price are 
significantly more important than cost or price."

The RFP provided the following technical evaluation factors for award, 
listed in "descending order of importance":  (1) technical approach 
(where the first subfactor, sample tasks, was "substantially more 
important" than the second subfactor, overall understanding and 
approach in the tasking areas); (2) key personnel; and (3) management 
plan.  RFP  sec.  M.2(a).  Adjectival ratings were provided for use as 
"general guidance" in assessing the proposals under each technical 
factor, and for rating the overall technical proposal.[2]  RFP  sec.  
M.2(b).

Past performance, identified as an additional non-cost factor for 
evaluation in the best value analysis, was to be considered as equal 
in importance to technical approach, the most important of the three 
stated technical evaluation factors.  RFP  sec.  M.7(a).  Past performance 
evaluations were to be based on information provided by the offerors 
in their proposals, detailing previous or current contracts of similar 
scope, magnitude, and complexity, as well as additional information 
obtained by the agency.  RFP  sec.  L.4(c), M.7(c).  The past performance 
of proposed critical subcontractors was to be considered "to the 
extent warranted by the subcontractor's involvement in the proposed 
effort."  RFP  sec.  M.7(b).  An adjectival rating was to be assigned to 
each proposal for past performance.[3]  RFP  sec.  M.7(d).

Seven initial proposals were submitted by the April 30 closing time 
for receipt of proposals; two proposals were found to be unacceptable 
and were excluded from the competitive range.  By letters of June 9, 
the agency conducted written discussions with the remaining five 
offerors, including MCR, KPMG, and PWC.[4]  Each of the competitive 
range technical proposals had been rated "marginal" overall, and the 
discussion letters, tailored for each offeror, included questions 
about those areas of their proposals that did not satisfy RFP 
requirements.  All offerors were also reminded during discussions 
about certain price-related requirements, and some of the offerors 
were requested to provide clarification in certain minor areas (e.g., 
although the firm's management plan proposal was found acceptable, MCR 
was requested to clarify a reconciliation approach depicted in an 
exhibit to that portion of the firm's technical proposal).  The five 
competitive range proposals' evaluated prices, prior to discussions, 
ranged between $[deleted] and $[deleted].

Revised proposals and final proposal revisions were received and 
evaluated.  The following chart shows the final overall technical and 
past performance ratings assigned to the final proposals:

Offeror   Overall TechnicalPast PerformanceEvaluated Price
PWC       Acceptable     Better         $[deleted]
KPMG      Better         Outstanding    $[deleted]
MCR       Acceptable     Better         $[deleted]
Offeror A Acceptable     Satisfactory   $[deleted]
Offeror B Better         Satisfactory   $[deleted]

Contracting Officer's Statement at 7.  The overall technical ratings, 
listed above, for the protester's and awardees' proposals were based 
on the following underlying adjectival ratings assigned to the 
proposals under each of the three technical evaluation factors:

               MCR's Proposal PWC's Proposal KPMG's Proposal
Technical ApproachAcceptable  Acceptable     Better
-Sample Task 1 Acceptable     Acceptable     Acceptable
 Sample Task 2 Acceptable     Acceptable     Better
-Overall UnderstandingAcceptableBetter       Outstanding
 and Approach
Key Personnel  Better         Acceptable     Acceptable
Management PlanAcceptable     Acceptable     Better

Id.  The contracting officer ranked the offerors' proposals in terms 
of technical merit in the following order:  (1) Offeror B; (2) KPMG; 
(3) PWC; (4) MCR; and (5) Offeror A.  His written rationale for this 
technical merit ranking was included as an itemized list in the 
Business Clearance Memorandum prepared prior to award.  That list 
included the following noted discriminators with respect to PWC and 
MCR:

     [PWC's] proposal was rated higher than MCR's and [Offeror A's] 
     because they scored a "Better" in the overall understanding of 
     the technical approach. . . .  MCR's proposal was rated higher 
     than [Offeror A's] proposal because they were rated "Better" on 
     their Key Personnel.  [Emphasis added.]

Rationale for Ranking, Business Clearance Memorandum, Aug. 10, 1998, 
Attachment 8 at 1.

The contracting officer then listed the overall ranking of proposals 
for best value, which ranking is explained only in a general 
descriptive heading to the list which provides that the order is based 
on a consideration of the evaluated technical proposals, past 
performance, and price.  The proposals were ranked in the following 
overall order in terms of offering the best value to the government:  
(1) KPMG; (2) PWC; (3) MCR; (4) Offeror A; and (5) Offeror B.  Id. at 
2.  The only other information provided in this best value overall 
ranking was the technical proposal's overall adjectival rating, the 
proposal's adjectival ratings for past performance (with separate 
ratings for the past performance proposal submission and the client 
survey responses), and the proposal's evaluated price.  The source 
selection authority (SSA) adopted the best value ranking of the 
proposals presented by the contracting officer, without providing 
additional comments about the merits of or differences between the 
proposals.  Business Clearance Memorandum at 2.  The agency decided to 
award two contracts, and the SSA selected the offers submitted by KPMG 
and PWC for award.  After a debriefing held by DFAS with the firm, MCR 
filed this protest.

MCR contends that the agency's best value determination regarding the 
PWC proposal, and the resulting award to that firm, is improper, 
since, under the stated evaluation factors for award, it is based on a 
determination of technical superiority that is inconsistent with the 
stated evaluation scheme for award.  Specifically, MCR points out 
that, since, under the stated evaluation factors for award, key 
personnel is more important than the subfactor of overall 
understanding and approach, the protester's higher evaluation rating 
for key personnel shows that its proposal should have been ranked 
ahead of the PWC proposal for technical merit, requiring the SSA to 
conduct a price/technical tradeoff analysis prior to awarding the 
contract to PWC.  MCR contends that the record does not include 
contemporaneous documentation to either demonstrate that the PWC and 
MCR proposals were technically equivalent, making price the 
determinative factor for award, or to show that the SSA meaningfully 
considered and differentiated between the merits of the proposals.  
MCR argues that the evaluation record shows that the PWC proposal was 
ranked as technically superior to the MCR proposal on an improper 
basis.  We agree.

In reviewing protests against allegedly improper evaluations, it is 
not our role to reevaluate proposals.  Rather, our Office examines the 
record to determine whether the agency's judgment was reasonable and 
in accord with the solicitation's stated evaluation criteria.  All 
Star Maintenance, Inc., B-271119, June 17, 1996, 96-1 CPD  para.  278 at 3.  
In a negotiated procurement, contracting officials have broad 
discretion in determining the manner and extent to which they will 
make use of technical and cost evaluation results.  PharmChem Labs., 
Inc., B-244385, Oct. 8, 1991, 91-2 CPD  para.  317 at 4.  However, they do 
not have the discretion to announce in the solicitation that they will 
use one evaluation plan, and then follow another; once offerors are 
informed of the criteria against which their proposals will be 
evaluated, the agency must adhere to those criteria in evaluating 
proposals and making its award decision, or inform all offerors of any 
significant changes made in the evaluation scheme.  Dewberry & Davis, 
B-247116, May 5, 1992, 92-1 CPD  para.  421 at 5.

Of course, agencies may make cost/technical tradeoffs in deciding 
between competing proposals; the propriety of such a tradeoff turns 
not on the difference in technical scores, per se, but on whether the 
contracting agency's judgment concerning the significance of that 
difference was reasonable in light of the solicitation's evaluation 
scheme.  Dayton T. Brown, Inc., B-229664, Mar. 30, 1988, 88-1 CPD  para.  
321 at 4-5.  However, where cost is secondary to technical 
considerations under a solicitation's evaluation scheme, as here, 
selection of a lower-priced proposal over a proposal with a higher 
technical rating requires an adequate justification, i.e., one showing 
the agency reasonably concluded that notwithstanding the point or 
adjectival differential between the two proposals, they were 
essentially equal in technical merit, or that the differential in the 
evaluation ratings between the proposals is not worth the cost premium 
associated with selection of the higher technically rated proposal.  
Dewberry & Davis, supra; Dayton T. Brown, Inc., supra, at 6-7.  Where 
there is inadequate supporting rationale in the record for a decision 
to make award to a lower-priced offeror with a lower technical ranking 
notwithstanding a solicitation's emphasis on technical factors, we 
cannot conclude that the agency had a reasonable basis for its 
decision.  Dewberry & Davis, supra.

MCR's proposal is approximately [deleted] percent higher in price than 
PWC's.  The RFP provided, however, that non-cost factors were more 
important than price.  MCR's and PWC's proposals received identical 
ratings for all technical factors and subfactors, with two exceptions.  
MCR's proposal received a "better," while PWC's received an 
"acceptable," for key personnel.  For overall understanding and 
approach, the situation was reversed:  PWC's proposal was rated 
"better," while MCR's was "acceptable."  Key personnel was the second 
most important technical evaluation factor, and it was more important 
than overall understanding and approach, the less important subfactor 
of the technical approach factor.[5]  There is no discussion, or even 
acknowledgment, in this record that reflects the fact that the MCR 
proposal received a higher rating than the PWC proposal under a more 
important evaluation factor than the subfactor under which the PWC 
proposal was more highly rated.  Rather, the record plainly shows that 
the PWC proposal was found to be technically higher rated overall 
because of its higher rating under that single subfactor.  Whether the 
evaluators, the contracting officer, or the SSA meant something other 
than what the record clearly states--that "[PWC's] proposal was rated 
higher than MCR's . . . because they scored a 'Better' in the overall 
understanding of the technical approach,"--is not apparent from any 
document in the record.  As it stands, however, this judgment is 
squarely inconsistent with the stated evaluation scheme.

The record shows that the SSA was unaware of this improper basis for 
technically ranking these two proposals, and that this ranking, once 
combined with past performance and price information, led to the best 
value overall ranking.  There is no other documentation in the 
evaluation or source selection record that shows any comparison of (or 
any discussion of the differences between) the proposals to establish 
how the selection of PWC for award was consistent with the RFP's 
evaluation scheme, which provided that technical merit was more 
important than price.  There is no support for either of the agency's 
post-protest suggestions:  that the proposals were viewed as 
technically comparable, so that low price could become an appropriate 
determining factor for award; or, alternatively, that an award on the 
basis of MCR's technically higher-rated proposal would not be worth 
the cost premium involved.  While we recognize that either of these 
approaches could have reasonably been adopted, neither was.  Moreover, 
given this evaluation record and the RFP's evaluation scheme, which 
ranked key personnel as an important technical evaluation factor for 
award, the agency could have made award to MCR if it determined that 
the protester's proposal was technically superior, due to its higher 
key personnel rating, and that it was worth the cost premium 
associated with it.  Instead, the record shows that the agency ranked 
the proposals in a way inconsistent with the stated evaluation 
factors, and failed to discuss its overall comparison of the proposals 
and what effect the price difference would have had in a proper 
price/technical tradeoff.  Ogden Support Servs., Inc., B-270012.2, 
Mar. 19, 1996, 96-1 CPD  para.  177 at 6-7; Dewberry & Davis, supra, at 6-7.  
Accordingly, we sustain this aspect of the protest.

MCR raises additional evaluation challenges which we have reviewed, 
but have found to provide no independent basis for sustaining the 
protest.  MCR alleges that the evaluation of its past performance 
(overall "better" based upon a "better" rating for proposal 
information and an "outstanding" rating for client survey), and that 
of PWC (overall "better" based upon "better" ratings for both 
subfactors) is flawed.  In essence, MCR contends its subfactor past 
performance ratings should have been "rounded up," while PWC's should 
have been lowered for alleged personnel retention problems and 
concerns about its management interaction with the agency.  Our review 
of the record does not support the protester's contentions regarding 
the past performance evaluation.

First, although requested, no client survey was received for MCR 
itself; only one survey response was received, and it described the 
outstanding past performance of a [deleted] subcontractor to MCR.  In 
accordance with the RFP's evaluation scheme, at  sec.  M.7(b), a 
subcontractor's past performance could be considered only to the 
extent warranted by the subcontractor's involvement in the performance 
of the contract.  Since the subcontractor here will be performing only 
[deleted] of the overall work required under the RFP, we do not find 
reasonable the protester's contention that MCR's overall past 
performance rating should be increased (to "outstanding") solely on 
the basis of this subcontractor's favorable performance survey.[6]

The protester contends that PWC's proposal should be downgraded due to 
alleged personnel retention problems, and a notation in the evaluation 
record regarding the failure of PWC management to interact with the 
agency.  However, our review of the record shows that the protester 
has not provided any credible support for the claimed personnel 
retention problems; and as for the cited management interaction 
concern, the record reasonably shows that this was appropriately 
considered by the agency--in fact, the PWC past performance rating 
would have been "outstanding" but for the reduction for this stated 
minor concern.[7]

MCR also contends that the evaluation of the proposals was improper 
because, although its proposal was rated at times on the basis of a 
straight averaging of subfactor ratings, the ratings of other 
offerors' proposals were, at times, "rounded up."  For example, MCR's 
proposal received two "better" ratings and three "acceptable" ratings 
for the five items targeted for consideration by the evaluators under 
the least important technical evaluation factor, management plan, for 
which factor its proposal was rated as "acceptable" overall.  MCR 
contends that, instead, the agency should have rated MCR's management 
plan as "better" overall.  To support its argument, MCR points out 
that the evaluation record shows another offeror's rating was rounded 
up where similar ratings were received under a different evaluation 
area--the example MCR provides involves the evaluation of the KPMG 
proposal under the sample task 2 sub-subfactor of the technical 
approach factor, where for the five items targeted for consideration 
by the evaluators, the KPMG proposal received three "acceptable" and 
two "better" ratings, but a rating of "better" overall for the 
sub-subfactor.

To the extent MCR seeks a mathematical or mechanical application of 
evaluation ratings for all offerors' proposals, its contention is 
without merit, since evaluation ratings are for use only as general 
guides to intelligent decision-making, and need not be mechanically 
applied to reach an overall assessment rating; rather, it is the 
documented qualitative findings about the proposals that govern the 
reasonableness of an agency's overall proposal assessment.  See Wesley 
Med. Resources, Inc.; Human Resource Sys. Inc., B-261938.5, 
B-261938.6, Nov. 20, 1995, 95-2 CPD  para.  230 at 9, n.2.  Here, our review 
of the record confirms the reasonableness of the evaluation of the 
protester's proposal under the management plan factor--while MCR 
submitted a favorable, complete management plan, it simply did not 
significantly exceed many of the RFP requirements, as required for the 
higher evaluation rating.  As for MCR's challenge, by comparison, to 
the "rounded up" rating received by the KPMG proposal under the sample 
task 2 sub-subfactor, we think the strengths of that proposal for 
sample task 2 support the favorable rating received, which, with the 
KPMG proposal's unchallenged "outstanding" rating under the overall 
understanding and approach factor, amply support the reasonableness of 
that proposal's higher technical approach rating.[8]

MCR also challenges the adequacy of discussions held with the firm.[9]  
The protester essentially contends that the agency should have 
discussed with it those areas in which its proposal could have 
received a higher rating, since any higher ratings may have materially 
improved its potential for award.  The protester also generally 
alleges that discussions were unfair, since the awardees were 
questioned about certain areas of their initial proposals that were 
found "marginal" (where MCR's proposal had been found "acceptable" in 
those areas, and the areas were not discussed with MCR), and those 
offerors' revised proposals' ratings improved to equal or exceed MCR's 
proposal's ratings.

This solicitation was issued after the January 1, 1998 effective date 
of the revised discussion rules of Part 15 of the Federal Acquisition 
Regulation.  Those revised rules, in pertinent part, provide, at  sec.  
15.306(d)(3), that:

     The contracting officer shall . . . indicate to, or discuss with, 
     each offeror still being considered for award, significant 
     weaknesses, deficiencies, and other aspects of its proposal . . . 
     that could, in the opinion of the contracting officer, be altered 
     or explained to enhance materially the proposal's potential for 
     award.  The scope and extent of discussions are a matter of 
     contracting officer judgment.

Discussions must be meaningful, equitable, not misleading, and fair.  
I.T.S. Corp., B-280431, Sept. 29, 1998, 98-2 CPD  para.  89 at 6.  We have 
reviewed each of the protester's alleged discussion improprieties and 
conclude that they lack merit--the record shows that the agency's 
actions were reasonable and proper.

MCR contends that, if the agency had raised any question (MCR does not 
identify which question it believes would be appropriate) about its 
proposal's sample task 2 response, it might have been able to improve 
its proposal rating for the subfactor to "better," as KPMG had done in 
response to discussions with the firm about its "marginal" response to 
sample task 2.[10]   MCR is essentially arguing that, since this is an 
area where its proposal received less than a perfect rating (even 
though not a "marginal" one), it should have been discussed to place 
its proposal in a more advantageous competitive position for award.  
We do not read the revised Part 15 language to change the legal 
standard so as to require discussion of all proposal areas where 
ratings could be improved.[11]  See DAE Corp., B-259866, B-259866.2, 
May 8, 1995, 95-2 CPD 12  para.  at 4-5 (an agency is not required to 
discuss every aspect of an offeror's acceptable proposal that receives 
less than the maximum score).

We recommend that the DFAS document a reasoned source selection 
determination that, in accordance with the stated evaluation factors 
for award, considers the comparative merits of the technical and past 
performance proposals, as well as the offerors' proposed prices, to 
determine which offer is the most advantageous to the government.  If 
an offeror other than PWC is selected for award of the contract that 
has been awarded to PWC, the DFAS should terminate PWC's contract for 
the convenience of the government and make award to that offeror.  We 
also recommend that the protester be reimbursed the reasonable cost of 
filing and pursuing its protest, including attorneys' fees.  4 C.F.R.  sec.  
21.8(d)(1) (1998).  The 
protester should submit its claim for costs, detailing and certifying 
the time expended and costs incurred, with the contracting agency 
within 60 days after receipt of this decision.  4 C.F.R.  sec.  21.8(f)(1).

The protest of the award to PWC is sustained; the protest of the award 
to KPMG is denied.

Comptroller General
of the United States

1. The contractor is to provide reconciliation and special studies 
services to DFAS and other Department of Defense entities to reconcile 
accounting, finance, and contractual records, including out-of-balance 
conditions, problem financial records, and contract close-out 
requirements.

2. The RFP provided the following adjectival ratings:  "outstanding" 
(proposal very significantly exceeds most or all solicitation 
requirements); "better" (proposal fully meets all solicitation 
requirements and significantly exceeds many of the solicitation 
requirements); "acceptable" (proposal meets all solicitation 
requirements); "marginal" (proposal is deemed less than acceptable, 
but has a reasonable chance of becoming at least acceptable after 
discussions); and "unacceptable" (proposal has many deficiencies or 
gross omissions).  RFP  sec.  M.2(b).

3. The RFP provided the following adjectival ratings for past 
performance:  "neutral" (no relevant past performance information was 
available for evaluation); "outstanding" (past performance information 
demonstrates no risk anticipated with delivery, quality, degradation 
of performance, or lack of customer satisfaction); "better" (very 
little risk is anticipated); "satisfactory" (some potential risk 
exists); and "marginal" (significant potential risk in performance of 
the contract requirements).  RFP  sec.  M.7(d).

4. PWC's proposal and discussion responses were submitted by Coopers & 
Lybrand, LLP, the incumbent contractor of these services; that firm 
merged with Pricewaterhouse, LLP, on July 1, to form PWC.  Although 
references in the evaluation record are made to Coopers & Lybrand, we 
reference them in this decision as PWC.

5. As the protester points out, the RFP language suggests that the key 
personnel factor may be as much as three times as important as the 
subfactor for overall understanding and approach.  While the RFP 
provided no point formula for weighing each factor and subfactor, it 
did provide that the factors were listed in a descending order of 
importance.  In a reasonable descending progression of factor 
importance, where the second factor (here, key personnel) is not 
substantially less important than the first factor (technical 
approach), a substantially less important subfactor of that first 
factor necessarily must be of less weight than the second factor.  For 
example, assuming a 50-30-20 point differential among the three 
technical evaluation factors here, since the RFP provides that the 
first subfactor (sample tasks) is substantially more important than 
the second subfactor (overall understanding and approach), the 50 
points for technical approach reasonably may be divided into a 30-20 
(or even 40-10) point split between the two stated subfactors.  In 
this example, the 30 points for key personnel clearly outweigh the 20 
(or even 10) points for the subfactor for overall understanding and 
approach of the technical approach factor.

6. MCR generally alleges that PWC's proposal should be assessed as 
having greater risk, since the awardees' price is low compared to the 
actual costs of the predecessor contract and the government estimate.  
The record shows, however, that the agency reasonably had no concern 
about the realism of PWC's lower price, since [deleted], were 
adequately supported in the PWC proposal.  MCR also contends that the 
awardee's previous personnel retention problems warrant a higher risk 
assessment for the PWC proposal.  However, the protester fails to 
provide persuasive evidence of the existence of any such problems, 
which otherwise are not documented in the record; in fact, the agency 
reports that substituted personnel under the prior contract were 
commended for having improved qualifications.

7. There is much discussion in the record between the parties 
concerning whether the agency was required to assign an overall 
adjectival rating to each proposal after combining the technical and 
past performance evaluation ratings.  Our review of the record shows 
that the RFP did not expressly require such an overall rating, and the 
agency did not assign an overall rating to the proposals, but the 
Business Clearance Memorandum, June 9, 1998, at 12, did refer to an 
"overall" (although not necessarily adjectival) rating.  In any event, 
the protester's argument is based upon its allegation that its past 
performance rating should be higher, which, MCR contends, would boost 
its proposal's overall rating higher than that of PWC's proposal, 
since past performance is as important as the technical approach 
evaluation factor.  In light of our above discussion confirming the 
reasonableness of the "better" past performance ratings assigned to 
both the MCR and PWC proposals, we consider the protester's argument 
academic; the "better" past performance ratings in effect cancel each 
other out (since the evaluation scheme gives past performance as much 
importance as the technical approach factor), because both proposals 
were also rated "acceptable" for technical approach.

8. MCR only generally challenges the agency's determination to award a 
contract to KPMG, and has not provided any persuasive basis to 
question the award to KPMG, the higher technically rated, lower-priced 
offeror.  The propriety of the award to KPMG based on its proposal's 
technical superiority over the MCR proposal in both the most important 
and least important technical factors, as well as its higher past 
performance rating, and lower price, is reasonably supported by the 
record.

9. MCR also protests that the evaluation was flawed by the use of an 
unstated evaluation factor favoring the so-called "Fabulous Five" 
accounting firms, which include KPMG and PWC.  MCR's offered proof of 
this impropriety consists of certain investigative reports that it has 
recently learned about that examined earlier DFAS awards that were 
questioned on this basis.  DFAS explains that the reports concern 
procurements unrelated to the current one and were conducted prior to 
recent agency controls to prevent any such bias.  We have reviewed 
this record separate from the reports, which do not include review of 
the current procurement, since each procurement stands on its own.  
The record provides no support for the protester's allegations of 
improper bias toward the awardees.

10. Although MCR contends discussions were unequal, there is no 
showing in the record that KPMG was treated more favorably than MCR in 
discussions.  Just as with MCR, KPMG was told of those areas of its 
proposal that were considered "marginal." 

11. The protester also contends that if the agency had mentioned that 
an evaluator thought MCR's experience was [deleted], Technical 
Evaluation Consensus Report for MCR, June 26, 1998 at 6, that its 
[deleted] failed to significantly exceed many requirements, or that 
its past performance proposal had not been rated "outstanding" 
overall, it could have materially improved its potential for award.  
As discussed above, the record does not support the protester's 
contention that discussions were required in these relatively minor 
aspects of the evaluation record.  Specifically, our review shows:  
there is no indication that the firm's proposal was downgraded for the 
[deleted] comment of one evaluator--in fact, the evaluation record 
shows that this was a very minor point expressed about the firm's 
overall understanding and approach, which otherwise was viewed 
favorably by the evaluators; given the firm's high ratings for past 
performance (which, related to the above discussion, specifically 
included credit for MCR's [deleted], there is no credible basis for 
the protester to contend the agency was required to discuss how the 
protester could improve its rating to the highest possible overall 
rating of "outstanding"; and, as for the acceptable [deleted] 
submitted by MCR, there is no showing in the record that more detailed 
discussions were warranted in this area, which had, in fact, been 
identified in discussions with MCR as an area to address in the firm's 
final proposal.