TITLE: Metropolitan Interpreters & Translators, B-285394.2; B-285394.3; B-285394.4, December 1, 2000
BNUMBER: B-285394.2; B-285394.3; B-285394.4
DATE: December 1, 2000
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Metropolitan Interpreters & Translators, B-285394.2; B-285394.3; B-285394.4,
December 1, 2000
Decision
Matter of: Metropolitan Interpreters & Translators
File: B-285394.2; B-285394.3; B-285394.4
Date: December 1, 2000
Patrick K. O'keefe, Esq., and Thomas F. Burke, Esq., McKenna & Cuneo, for
the protester.
Pamela J. Mazza, Esq., and Philip M. Dearborn III, Esq., Piliero, Mazza &
Pargament, for Comprehensive Technologies International, Inc., an
intervenor.
J. Michael Sawyers, Esq., Drug Enforcement Administration, for the agency.
David A. Ashen, Esq., and John M. Melody, Esq., Office of the General
Counsel, GAO, participated in the preparation of the decision.
DIGEST
Protest of award of contract for linguist services is denied where agency
reasonably determined technical advantages of the awardee's proposal were
worth its higher price; awardee's proposal was evaluated superior to
protester's under the second and third most important technical evaluation
factors, both proposals were evaluated acceptable under most important
factor, and technical considerations were substantially more important than
price.
DECISION
Metropolitan Interpreters & Translators protests the Drug Enforcement
Administration's (DEA) award of a contract to Comprehensive Technologies
International, Inc. (CTI) under request for proposals (RFP) No.
DEA-99-R-0004, for linguist services for DEA's New York Field Division
(NYFD). Metropolitan primarily challenges the technical evaluation.
We deny the protest.
The RFP anticipated the award of a fixed-price,
indefinite-delivery/indefinite-quantity labor-hour contract, for a base year
with 4 option years, for linguist services--including monitoring,
transcribing and interpreting--and automated data processing (ADP) services
in support of judicially authorized communications intercepts. Although the
majority of the linguist work required is for translating Spanish to
English, the contractor is required to furnish upon request linguists
knowledgeable and proficient in 42 specified languages and dialects, as well
as in numerous other generally described languages (e.g., "[a]ll other
Eastern European," "[a]ll other Western/European," and "[a]ll other Asian").
RFP, Statement of Work (SOW), sect. C.10. The RFP specified a required core unit
of 23 persons--a project manager, 10 linguists, 2 linguist supervisors, a
clerical assistant, 2 computer data librarians, an ADP task manager, 2
communications specialists, 2 computer programmers, a senior data
technician, and a systems analyst--for whom offerors were to furnish resumes
and letters of commitment. SOW sect.sect. C.2, C.11; RFP sect. L.6-3, at L-20. However,
while the minimum workload under the contract required only 12 core
linguists and linguist supervisors, the maximum workload under the contract
required 205 linguists and linguist supervisors. RFP sect. B.9.
Award was to be made to the responsible offeror whose conforming proposal
represented the best value, and was most advantageous to the government. RFP
sect. M.2(A). The RFP provided for proposals to be evaluated based on the
following seven enumerated evaluation factors: (1) offeror's ability to
furnish qualified personnel to perform the required services, including
consideration of the quality and qualifications of the proposed core
personnel, the offeror's ability to furnish additional personnel beyond the
core personnel, and whether the offeror has demonstrated "by reasoning or
evidence that the hiring/selection and retention policies/procedures are
adequate to support successful performance"; (2) quality control plan; (3)
management plan and ability to manage all aspects of the contract, including
corporate commitment, hiring, retaining and training employees, scheduling,
security issues, reporting requirements, performance risk, schedule risk,
and cost risk; (4) security plan; (5) past performance/risk assessment,
under which the agency was to consider the offeror's previous work
experience in similar or related work, performance improvements, and
completed past performance surveys and ratings; (6) compliance with the RFP
instructions; and (7) cost/price. RFP sect. M.5. The RFP stated that the seven
factors, as set forth above, were "listed in equal or descending order of
importance," RFP sect. M.5, but it also added that the "technical factors . . .
are in descending order of importance," and that the "combination of all
technical factors is substantially more important than the cost/price." RFP
sect. M.2.
Six proposals were received in response to the RFP; only Metropolitan's and
CTI's were included in the competitive range. DEA furnished these offerors
with written discussion questions, afforded them an opportunity to request
clarification of the questions, and requested revised proposals. The final
evaluation results are set out in the following chart:
CTI Metropolitan
TECHNICAL Acceptable Acceptable
Qualified Personnel
Quality Control Plan Exceptional Acceptable
Management Plan Exceptional Acceptable
Security Plan Acceptable Acceptable
Overall Past Performance/Risk Acceptable Exceptional
Assessment Exceptional Exceptional
Relevancy Acceptable Acceptable
Performance Improvements Acceptable Exceptional
Past Performance Surveys
Compliance with the RFP Acceptable Acceptable
OVERALL TECHNICAL Acceptable Acceptable
Evaluated Cost/Price $84,411,097 $[DELETED]
Although Metropolitan's evaluated price was lower than CTI's, and both
proposals were rated acceptable overall, DEA determined that there was less
overall risk associated with CTI's proposal and that the lesser risk was
worth the additional cost of the proposal. In this regard, the agency
determined that Metropolitan's proposal provided insufficient assurance of
its ability to recruit and retain new employees; CTI's quality control plan
was exceptional, while Metropolitan's was only acceptable; Metropolitan
proposed [DELETED] under which the lines of responsibility and authority
were not clear, and which failed to provide for [DELETED]; and CTI's
proposal indicated the availability of financial resources which would be
useful in performing the contract. DEA determined that CTI's proposal
represented the best value to the government.
Upon learning of the resulting award to CTI, and after being debriefed by
the agency, Metropolitan filed this protest with our Office. Metropolitan
raises numerous arguments. We discuss the principal arguments below.
ABILITY TO FURNISH QUALIFIED PERSONNEL
Metropolitan challenges the agency's evaluation of offerors' ability to
furnish qualified personnel. In this regard, as noted above, although DEA
rated both proposals as acceptable under this factor, the agency evaluated
Metropolitan's as weak and took this weakness into account in the tradeoff
analysis. Metropolitan essentially argues that DEA's criticism unreasonably
failed to account for the fact that Metropolitan was furnishing the majority
of the staffing for this requirement. In this regard, Metropolitan asserts
that, of the 55 to 70 linguists employed by DEA's NYFD in the last year, it
was furnishing 49 of the linguists in the period immediately before
submission of initial proposals and 47 of the linguists in the period
immediately before submission of revised proposals. In addition,
Metropolitan states that its proposed ADP subcontractor was furnishing all
of the ADP personnel supporting the NYFD's communications intercept
operations. Metropolitan Comments, Oct. 31, 2000, Declaration of
Metropolitan New York Project Manager, at 4-5. DEA confirms that, while the
percentage varied over time, Metropolitan furnished as much as approximately
65 percent of the fiscal year 2000 NYFD linguist requirement. In contrast,
while CTI's team had significant linguist contracts at a number of locations
around the country (e.g., in California, Texas and at DEA's headquarters in
Virginia), and [DELETED] of its proposed 23 core staff were currently
working at the NYFD, DEA reports that CTI furnished only approximately
10 percent of the NYFD's linguist requirement and 90 percent of its ADP
requirement from 1992 to 1997, and a CTI team member was furnishing only
approximately 10 percent of the linguist requirement at the time of award.
Agency Comments, Oct. 27, 2000, at 1. (According to Metropolitan, it has
furnished 90 percent of the NYFD's linguist requirement since April 2000.
Metropolitan Comments, Oct. 31, 2000, Declaration of Metropolitan New York
Project Manager, at 5.) Metropolitan concludes that, in finding its proposal
weak in this area, the agency failed to account for the fact that all of its
23 proposed core unit personnel, as well as [DELETED] additional non-core
staff for whom it furnished resumes, are "incumbent" staff working for
Metropolitan team members in the NYFD. [1]
DEA recognized in its evaluation that Metropolitan was proposing to retain
qualified incumbent employees. Source Selection Document--Final Offer at 4.
In this regard, we note that Metropolitan furnished letters of commitment,
not only for its 23 core linguists and ADP personnel, but also for [DELETED]
additional linguists ([DELETED] for Spanish and [DELETED] for other
languages) employed by Metropolitan team members, and furnished resumes for
a number of other linguists, some of whom apparently were employed by
Metropolitan team members. (CTI also proposed to recruit qualified incumbent
and former linguists at the NYFD. CTI Technical Proposal at 18, 23.) DEA
found, however, that Metropolitan's proposal did not demonstrate how, over
the long run, qualified personnel would be provided. As stated in the
agency's evaluation of proposals, "the retention plan and training of new
employees were not fully addressed in the final offer. . . . Metropolitan
did not demonstrate that the proposed recruitment and retention plan would
mitigate any future performance problems." Source Selection Document--Final
Offer at 4. DEA concludes that it reasonably found a weakness in
Metropolitan's proposal in this area.
In reviewing an agency's evaluation of proposals and source selection
decision, our review is confined to a determination of whether the agency
acted reasonably and consistent with the stated evaluation factors and
applicable procurement statutes and regulations. Main Bldg. Maintenance,
Inc., B-260945.4, Sept. 29, 1995, 95-2 CPD para. 214 at 4.
Preliminarily, the agency's focus on the offerors' ability to recruit new,
additional employees and retain their workforce over time was reasonable. As
noted above, the RFP contemplated a contract period of up to 5 years and
provided for the possibility of a significant increase in workload over that
period; while the minimum workload under the RFP required only 12 core
linguists and linguist supervisors, the maximum workload required 205
linguists and linguist supervisors. RFP sect. B.9. In other words, the maximum
workload with respect to linguists the contractor could be required to
furnish was nearly three times the prior maximum workload (according to the
protester) in the periods prior to submission of initial and revised
proposals and approximately four times the level of staffing furnished by
Metropolitan team members during those periods. Metropolitan Comments, Oct.
31, 2000, Declaration of Metropolitan New York Project Manager, at 4-5. [2]
We also find nothing unreasonable in DEA's evaluation of the proposals in
this area. With respect to the proposed approaches to satisfying future
staffing requirements, Metropolitan's and CTI's proposals included many of
the same details. For example, both proposals discussed: [DELETED].
Metropolitan Technical Proposal at 2-4, 2-19 to 2-20, 2-23 to 2-25, 4-8, and
5-3 to 5-17; Metropolitan Discussion Response at 1, 3 and 5; CTI Technical
Proposal at 16-18, 20-22, and 93-100; CTI Discussion Response at 2. In
addition, both proposals discussed approaches to ensuring that work will be
available to linguists on a continuing basis, thus facilitating recruitment
and retention. Metropolitan proposed [DELETED] during lulls in work at the
DEA facility and while employees are awaiting the required DEA security
clearance, while CTI described in its proposal its success in offering
employees faced with downtime [DELETED]. Metropolitan Technical Proposal at
2-26; Metropolitan Discussion Response at 1, 3, 5; CTI Technical Proposal at
27. Further, both offerors claimed low linguist turnover rates: Metropolitan
identified a staff turnover rate of about [DELETED] percent per year, while
CTI claimed a retention rate over the past 3 years of [DELETED] percent for
translators (and [DELETED] percent for ADP personnel). Metropolitan
Technical Proposal at 2-25; CTI Technical Proposal at 22. [3]
Beyond these similarities, however, CTI's proposal furnished additional
detail in several significant areas. For example, CTI proposed to recruit
through [DELETED]. CTI Technical Proposal at 17; CTI Discussion Response
at 2. Further, CTI's proposal included details regarding the fringe benefits
it offers its staff, including [DELETED]. CTI Technical Proposal at 23-25,
33. In contrast, although Metropolitan's proposal indicated that it would
[DELETED] for its linguists, it generally stated only that "[w]e offer
[DELETED]" and that the firm [DELETED] for current linguistic and ADP
incumbent employees. Metropolitan Technical Proposal at 2-19; Metropolitan
Discussion Response at 4-5. [4] We think that, in the evaluation of the
firm's ability to recruit additional linguists and retaining existing staff
over the potential 5-year period of the contract, DEA reasonably could view
Metropolitan's failure to more specifically describe its fringe benefits as
a relative weakness. It follows that DEA reasonably could differentiate
between the proposals on this basis.
MANAGEMENT PLAN
Metropolitan challenges the agency's evaluation of the offerors' proposed
management plans. In this regard, a significant factor in the evaluation
under this factor was the evaluated weakness of Metropolitan's proposed
organizational approach to performing the contract. RFP sect. M.5(3); Source
Selection Document--Final Offer at 7, attach. 5, Trade-off Analysis;
Contracting Officer's Statement at 4-6. As noted by the agency, Metropolitan
provided in its proposal that [DELETED]. Metropolitan Technical Proposal at
4-62. In addition, Metropolitan's proposal provided that [DELETED].
Metropolitan Technical Proposal at 2-18, 4-4, and 4-13; Society of Federal
Linguists, Newsletter, Online Version, Nov. 1999, at
.
During discussions, DEA asked Metropolitan to explain its organizational
approach. The agency advised Metropolitan that the "proposed management plan
shows [DELETED]," and that this management approach "defeats the purpose of
having a prime contractor responsible for the entire NYFD requirement."
Agency Discussion Questions to Metropolitan, Apr. 7, 2000, at questions 18,
19. In its response, Metropolitan stated that the contract would be
performed by an integrated team in which it would be the sole provider of
program and contract management support and would be responsible for all
aspects of the contract; Metropolitan denied any intention that [DELETED]
would have an active role in meetings, administrative functions and
operational reports, and indicated that these functions would be [DELETED].
Metropolitan Discussion Response at 9-10. DEA, however, continued to view
Metropolitan's proposed team approach as potentially diminishing the benefit
of having a single prime contractor; according to the agency, the
arrangement posed schedule and performance risk because there were no clear
lines of responsibility and authority within the team. Source Selection
Document--Final Offer at 7.
The agency's concern was reasonable. It is undisputed that having multiple
contractors could potentially cause performance problems. As acknowledged by
Metropolitan (as well as CTI) in its proposal, DEA has had prior problems
dealing with multiple contractors in connection with its communications
intercept operations; indeed, Metropolitan's proposal appears to attribute
"the fractious environment noted within the New York wire room and ancillary
operations" to having "many independent company representatives."
Metropolitan Technical Proposal at 4-3; CTI Technical Proposal at 6; Source
Selection Document--Final Offer, attach. 5, Trade-off Analysis.
Notwithstanding Metropolitan's assertion that it would be responsible for
all aspects of the contract, we think the agency reasonably could conclude
from (1) [DELETED], and (2) [DELETED], that the lines of responsibility and
authority within the Metropolitan team remained unclear and that in practice
management of the contract could be fractured, such that there was potential
performance risk inherent in Metropolitan's management approach.
Metropolitan asserts that the agency's concern should have extended equally
to CTI's proposed approach, which provided for a [DELETED] consisting of
senior representatives of CTI and its [DELETED]. CTI Technical Proposal at
80. However, there was a reasonable basis for distinguishing between CTI's
proposal of [DELETED] and Metropolitan's proposal of [DELETED]; that is, the
agency reasonably could conclude from the descriptions of the two approaches
that Metropolitan's [DELETED] would be more involved in the operational
management of the contract effort than would CTI's [DELETED]. Id. at 74-75,
80. Further, the apparent participation of [DELETED] in Metropolitan's
contract effort could only magnify any concern as to the unified contract
effort likely under Metropolitan's approach. We conclude that the evaluation
in this area was reasonable.
BAIT AND SWITCH
Metropolitan alleges that CTI misrepresented the availability of its
proposed core personnel. As noted, the RFP specified a required core unit of
23 persons--including a project manager, 10 linguists, 2 linguist
supervisors, a clerical assistant, 2 computer data librarians, an ADP task
manager, 2 communications specialists, 2 computer programmers, a senior data
technician, and a systems analyst--who were considered to be "essential for
the successful completion of all work assigned under this contract," and for
whom offerors were to furnish resumes and letters of commitment. SOW sect.sect. C.2,
C.11; RFP sect.sect. H.13, H.14, L.6-3 at L-20. Metropolitan cites as evidence that
CTI misrepresented the availability of its proposed core personnel the fact
that CTI began immediately after award to attempt to recruit incumbent ADP
personnel; it further points to the fact that CTI has acknowledged that it
will replace 7 of the 23 proposed core personnel.
An offeror may not propose to use specific personnel that it does not expect
to use during contract performance; doing so would have an adverse effect on
the integrity of the competitive procurement system and generally provide a
basis for proposal rejection. CBIS Fed. Inc., B-245844.2, Mar. 27, 1992,
92-1 CPD para. 308 at 5. The elements of such a "bait and switch," that would
render a contract award improper, are as follows: (1) the awardee
represented in its proposal that it would rely on certain specified
personnel in performing the services; (2) the agency relied on this
representation in evaluating the proposal; and (3) it was foreseeable that
the individuals named in the proposal would not be available to perform the
contract work. Ann Riley & Assocs., Ltd.--Recon., B-271741.3, Mar. 10, 1997,
97-1 CPD para. 122 at 2-3.
There is no basis for concluding that CTI misrepresented its intentions with
respect to proposed personnel. CTI has explained the circumstances of its
inability to secure the services of each of the unavailable proposed core
individuals. CTI has furnished an affidavit in which its Senior Vice
President for Operations explains that it intended to perform the contract
with its proposed core personnel but that when it contacted them after the
July 28, 2000 notification of award, 7 of the 23 core personnel--including
[DELETED]--stated that they were unable to honor their letters of commitment
(executed in September and November 1999). Among the reasons cited were the
acceptance of positions with other companies, an intended move to Mexico,
and a desire to remain in Puerto Rico. Declaration of CTI Senior Vice
President for Operations. These explanations, which we find credible,
support the view that the employee substitutions were not part of an
improper "bait and switch." Moreover, the substitution of incumbent
employees with an agency's permission, and where there has been no
misrepresentation, is not an improper "bait and switch." Airwork
Ltd.-Vinnell Corp. (A Joint Venture), B-285247, B-285247.2, Aug. 8, 2000,
2000 CPD para. ___ at 6; A&T Eng'g Techs., VECTOR Research Div., B-282670,
B-282670.2, Aug. 13, 1999, 99-2 CPD para. 37 at 8. Here, CTI expressly stated in
its proposal that [DELETED]. CTI Technical Proposal at 23. We thus conclude
that Metropolitan's arguments in this regard are without merit.
OTHER ISSUES
Metropolitan alleges that there was an organizational conflict of interest
arising from the fact that the spouse of the owner of a subcontractor
proposed by CTI is a DEA diversion investigator in the NYFD. According to
the protester, the investigator allegedly offered advice to CTI personnel on
testing results and with respect to conference costs during a visit to CTI's
staff during a 3-day recruiting conference held at a hotel in October 1999.
DEA, however, reports that the investigator had no involvement in the
procurement process, and the record furnishes no basis for questioning its
position in this regard. Contracting Officer's Statement at 9; DEA Comments,
Oct. 27, 2000, at 3-4; Declaration of DEA Diversion Investigator; see CTI
Comments, Oct. 31, 2000, Declaration of CTI Division Manager.
Metropolitan also challenges DEA's consideration of offerors' financial
resources. DEA noted during the evaluation that CTI's offer indicated the
availability of [DELETED] and that such resources were critical to
successfully performing the contract here; DEA noted that the agency
historically has been late in paying invoices, and concluded that [DELETED]
would permit the contractor to meet its payroll and pay subcontractors,
thereby avoiding any disruption of service due to late payments under the
contract. The agency found that Metropolitan's failure to specify comparable
resources represented a performance risk. Source Selection Document-Final
Offer, attach. 5, Trade-off Analysis. Metropolitan argues that DEA's failure
to advise it during discussions of the agency's concern in this regard
rendered the discussions inadequate. See FAR sect. 15.306(d)(3); Du and Assocs.,
Inc., B-280283.3, Dec. 22, 1998, 98-2 CPD para. 156 at 7 (discussions must be
meaningful, equitable, and not misleading).
Competitive prejudice is necessary before we will sustain a protest; where
the record does not demonstrate that the protester would have a reasonable
chance of receiving award but for the agency's actions, we will not sustain
a protest, even if a deficiency in the procurement is found.
McDonald-Bradley, B-270126, Feb. 8, 1996, 96-1 CPD para. 54 at 3; see
Statistica, Inc. v. Christopher, 102 F.3d 1577, 1581 (Fed. Cir. 1996). We
find no competitive prejudice here. Metropolitan does not argue that it did
not know that DEA historically has been late in paying invoices, nor has it
shown the existence of other available comparable financial resources that
it would have offered had it been advised of the agency's concern with
respect to financing contract performance. Northrop Worldwide Aircraft
Servs., Inc.--Recon., B-262181.3, June 4, 1996, 96-1 CPD para. 263 at 3. Rather,
Metropolitan simply points to the financial statements it submitted with its
proposal, its general representation that it has "sufficient lines of credit
and cash reserves," and the fact that it has previously furnished a
significant portion of NYFD's linguist requirement, as evidence of its
capability to finance performance. Metropolitan Business Management Proposal
at 1, sect. 5; Metropolitan Comments, Sept. 22, 2000, at 15. None of these
references establish that Metropolitan has [DELETED] that could be relied on
when DEA is late in paying contractor invoices.
Metropolitan challenges DEA's consideration of offerors' accounting systems.
DEA noted during the evaluation that CTI's proposal indicated that the
company had an accounting system that was approved by the Defense Contract
Audit Agency (DCAA) as adequate for accumulating, reporting and billing
costs on government contracts, and that thus could be used to track the
costs associated with any necessary contract modifications. Source Selection
Document--Final Offer, attach 5, Trade-off Analysis. (As explained in a
declaration by its Vice President of Operations, Metropolitan's Cost
Monitoring and Control System "tracks [DELETED]." Metropolitan Comments,
Oct. 31, 2000, Declaration of Metropolitan Vice President of Operations at
10.) Metropolitan asserts that a cost-based accounting system was not
required under the solicitation, which provided for fixed hourly labor
rates, and that, if Metropolitan had been advised during discussions of the
agency's concern in this regard, it would have informed the agency that
[DELETED] use DCAA-approved accounting systems. Id.
Again, we find no competitive prejudice to Metropolitan. First, even if
Metropolitan had been advised that the agency intended to take into account
in the evaluation whether offerors had a DCAA-approved cost-based accounting
system, Metropolitan has not demonstrated that discussions would have
materially affected its evaluation. The fact that [DELETED] use
DCAA-approved cost-based accounting systems would not alter the fact that
Metropolitan does not. More importantly, the contemporaneous evaluation
record indicates that this was but one of a number of discriminators taken
into account by the agency. In this regard, Metropolitan has made no showing
that the higher, exceptional rating for CTI's proposal under the quality
control evaluation factor (the second most important technical evaluation
factor) was unreasonable, and, as discussed above, DEA reasonably found
CTI's proposal to be superior to Metropolitan's under the management plan
factor (the third most important technical evaluation factor). Given CTI's
evaluated superiority under the second and third most important technical
evaluation factors, the acceptable ratings for both proposals under the most
important factor (qualified personnel), and the fact that technical
considerations were substantially more important than price, we cannot
conclude that Metropolitan would have had a reasonable chance for award had
the agency not taken offerors' accounting systems into account in the
evaluation.
The protest is denied.
Anthony H. Gamboa
Acting General Counsel
Notes
1. Metropolitan further alleges that CTI's proposed [DELETED] should have
been found unacceptable because he previously had been escorted from DEA's
NYFD's facilities and will not be permitted access to the facilities in the
future. However, DEA has furnished a declaration from an assistant special
agent-in-charge of the NYFD, in which she states that, while there appears
to have been an incident involving this individual over 8 years ago, the
agency has not determined that he is unacceptable on that account; according
to the assistant special agent-in-charge, the proposed [DELETED] will be
subject to the normal screening and background check required of any new
contract employee, and she has no basis for concluding that he will be found
unacceptable simply due to the prior incident. DEA Comments, Nov. 7, 2000,
Declaration of Assistant Special Agent-in-Charge NYFD. Given DEA's position,
there simply is no basis to find that CTI's proposed [DELETED] was
unacceptable so as to render CTI's proposal noncompliant with the RFP's
staffing requirements.
2. The number of linguists furnished by Metropolitan after April 2000 is
unclear.
3. As noted by Metropolitan, the public record reflects a decrease in CTI's
overall workforce from 490 in 1996 to 250 in both 1998 and the most recent
year for which information is available. Metropolitan Initial Protest, Tab
3. CTI attributes this to a reduction in the number of contracts, noting
that it became ineligible to compete for some requirements for which it
previously held contracts when it graduated from the Small Business
Administration's 8(a) program and became other than small. CTI Comments,
Oct. 11, 2000, at 4.
4. Metropolitan's proposal also generally indicated that its team member
furnishing ADP personnel offers [DELETED]. Metropolitan Technical Proposal
at 4-77. Metropolitan also proposed [DELETED]. Metropolitan Technical
Proposal at 6-4; Metropolitan Discussion Response at 6.