TITLE:  Fiserv NCSI, Inc., B-293005, January 15, 2004
BNUMBER:  B-293005
DATE:  January 15, 2004
**********************************************************************
Fiserv NCSI, Inc., B-293005, January 15, 2004

   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.        

   Decision
    
Matter of:   Fiserv NCSI, Inc.
    
File:            B-293005
    
Date:              January 15, 2004
    
Michael R. Charness, Esq., and Robert J. Rothwell, Esq., Vinson & Elkins,
for the protester.
Carl L. Vacketta, Esq., and Kevin P. Mullen, Esq., Piper Rudnick, for
Covansys Corporation, an intervenor.
Leigh M. Hoburg, Esq., Department of Homeland Security, Federal Emergency
Management Agency, for the agency.
Glenn G. Wolcott, Esq., and Michael R. Golden, Esq., Office of the General
Counsel, GAO, participated in the preparation of the decision.
DIGEST
    
1.  In procurement for fixed-unit-price contract, agency reasonably
determined that awardee*s proposed prices were realistic where evaluation
record reflects agency*s thorough consideration of awardee*s proposed
technical approach that reasonably supported the agency*s conclusion that
awardee*s approach would meet the solicitation requirements, and agency
further examined the individual elements of awardee*s proposed prices,
including data related to direct labor, labor overhead, and other direct
and indirect costs.
    
2.  Where record establishes that agency reasonably compared protester*s
[deleted] approach, which necessitated a significantly higher price than
the price proposed by awardee in connection with its technology-intensive
approach, and excluded protester*s proposal from the competitive range on
the basis that, in order to be eligible for award, protester would have to
completely revise its proposed technical approach, errors or inaccuracies
in the government estimate are immaterial and do not provide a basis for
sustaining the protest.
DECISION
    
Fiserv NCSI, Inc. (NCSI) protests the Department of Homeland Security,
Federal Emergency Management Agency*s (FEMA) exclusion of NCSI*s proposal
from the competitive range under request for proposals (RFP) No.
EMW-2003-RP-0030 to perform various activities pursuant to the National
Flood Insurance Program (NFIP). NCSI protests that the agency improperly
evaluated the technical and price proposals submitted in response to the
solicitation and relied exclusively on a flawed government cost estimate
to exclude NCSI*s proposal from the competition.
    

   We deny the protest.
    
BACKGROUND
    
In October 2002, the agency began preparing to conduct a follow-on
procurement to replace the expiring contract for services supporting the
NFIP program; NCSI is the incumbent contractor, and has been the NFIP
servicing agent contractor for approximately 10 years.  The agency states
that in conducting previous procurements for these requirements it has
obtained *little to no competition,* and that, in *an effort to enhance
competition, restrictive conditions were removed from the
requirement[s].*[2]  Agency Report, Contracting Officer*s Statement, at 3.
    
In August 2003, the solicitation was published, seeking proposals to
function as the NFIP servicing agent contractor during a base period and
four 1-year option periods.  Agency Report, Tab 8.  Pursuant to the
solicitation, the successful offeror will be responsible for servicing
flood insurance policies that are written directly by the federal
government;[3] in that regard, the contractor will issue and service flood
insurance policies, collect premiums, adjust and settle claims, and
disseminate information to the public, lenders and agents.  Agency Report,
Tab 8, RFP, at 89. 
    
The solicitation requirements encompass three basic types of flood
insurance policies:  standard flood insurance policies (SFIP)[4]; group
flood insurance policies (GFIP)[5]; and repetitive loss target group
policies (RLTG)[6].  The solicitation contains contract line item numbers
(CLINs) for each of the three policy groups, along with estimated
quantities for each group, by contract period;[7] offerors were required
to propose fixed unit prices, per policy and by contract period, for
servicing each group of policies.  Agency Report, Tab 8, RFP, at 6. 
    
The solicitation provided that award would be based on the proposal
determined to be *most advantageous* to the government, taking into
consideration price and other non-price evaluation factors.[8]  Agency
Report, Tab 8, RFP, at 85.  With regard to price, the solicitation
provided that offerors* proposals would be evaluated as to price
reasonableness and realism,[9] and warned that *[a]n offeror*s proposal
may not be considered if the cost is unreasonably high or unrealistically
low.*  Id.           
    
Six months before issuing the solicitation, the contracting officer*s
technical representative (COTR) prepared an independent government cost
estimate (IGCE) related to the requirements being competed here.  Agency
Report, Tab 2.  In preparing that estimate, the COTR multiplied the prices
currently charged by NCSI under its incumbent contract by the estimated
quantities of SFIP contracts projected to be in force during the total
contract performance period, then added 4 percent for inflation and
$500,000 for transition costs; the total IGCE was $28.58 million.[10]  Id.
    
On or before the September 9 closing date, the agency received proposals
from two offerors:  NCSI and Covansys.  Thereafter, the offerors*
technical proposals were evaluated by a technical evaluation panel
(TEP),[11] and price proposals were evaluated by a business evaluation
committee (BEC).[12]  Although both offerors* technical proposals were
rated *acceptable,* the TEP found the offerors* technical approaches to be
substantially different.  Specifically, NCSI proposed a [deleted] approach
that essentially reflects the manner it has previously performed the
contract requirements.  In contrast, Covansys proposed a web‑based
approach, relying on state-of-the-art information technology (IT) to
eliminate many of the previously used manual processing requirements. 
Consistent with its [deleted] approach, NCSI contemplated a staff
comprised of [deleted] full-time equivalent (FTE) personnel; Covansys*s
initial proposal reflected a staff comprised of [deleted] FTEs.[13] 
Agency Report, Tab 25, at 1, 5.  Also consistent with their differing
technical approaches and proposed staffing levels, the offerors* proposed
prices were dramatically different.  NCSI*s proposal offered a price of
approximately [deleted] million; Covansys*s initial proposal offered a
price of approximately [deleted] million.[14]  Agency Report, Contracting
Officer*s Statement, at 6.  
    
In evaluating Covansys*s technical proposal, the TEP identified multiple
strengths related to what it described as Covansys*s *innovative web-based
IT systems solution.*  Agency Report, Tab 24, at 20.  Among other things,
the TEP noted that *[Covansys*s] financial systems are integrated into all
administrative systems,* and recognized that Covansys*s proposal *will
allow for real time data exchange,* provides the *ability to view all
documents on line,* and provides *[deleted].*  Id.  Further, the TEP noted
that Covansys *proposes to train and give FEMA staff on line access to
on-line claims files,* and that its quality assurance plan incorporates an
*[a]utomated diary system and reminder letters.*  Id.  The TEP summarized
its assessment of Covansys*s web-based approach, stating:       
    
[Covansys*s] website . . . provides great value added by offering an
efficient and effective means for reporting losses, settling losses and
for rapid assignment.  Real-time updates provide for accurate reserving
and performance tracking.  [Deleted].
Agency Report, Tab 24, at 21. 
    
In contrast, in evaluating NCSI*s proposal, the TEP identified multiple
weaknesses and limitations related to NCSI*s [deleted] approach,
describing NCSI*s proposal as *a business as usual approach* and
elaborating that *[n]o new or innovative approaches were presented.* 
Agency Report, Tab 24, at 15-16.  The TEP further stated, *[NCSI] is
proposing the same staffing of key individuals that are currently being
utilized on the existing contract* and noted *[t]here has . . . been some
difficulty in making sure that [non-key personnel] in lower level
positions know their jobs sufficiently to perform them properly.*  Agency
Report, Tab 24, at 17.  The agency also identified certain areas where
NCSI*s [deleted] approach appeared particularly inefficient.  For example,
with regard to servicing RLTG policies, a BEC adviser noted that NCSI*s
price proposal was based on its claims examiners handling an average of
approximately [deleted] claims per day, stating: *This load is below
standard.  They should be handling 4 to 7 per day.*  Agency Report, Tab
25, at 8.  Overall, this BEC adviser stated:  *They are proposing a staff
of [deleted] people to run this contract that I feel is ridiculous,*
adding that *[NCSI*s approach] still looks like a very [deleted] process
in all areas.  I feel that their staffing needs are extremely high and
unreasonable.* [15] Agency Report, Tab 25, at 7.      
    
The agency concluded that, in light of NCSI*s high cost/price--which was
directly related to its proposed [deleted] approach--NCSI*s proposal did
not stand a reasonable chance of being selected for award over Covansys*s
significantly lower-priced, technology‑intensive approach unless
NCSI completely revised its proposed technical approach.  Accordingly, the
agency determined that NCSI*s proposal was not in the competitive range
and notified NCSI of this determination on September 25.  This protest
followed. 
    
DISCUSSION
    
NCSI first protests that the agency failed to perform a proper price
realism analysis regarding Covansys*s proposal, complaining that *[h]ad
the FEMA evaluators performed a proper and thorough price realism
assessment, it would have been clear to them that Covansys*s proposed unit
prices were wholly out of line with the cost experience known to the
agency [based on NCSI*s past prices].*  Protest at 10. 
    
In awarding a fixed-price contract, the realism of an offeror*s proposed
prices are not generally considered, since the contractor is responsible
for contract costs and the resulting profit or loss.  See, e.g., Computer
Sys. Int*l, Inc., B‑276955.2, Aug. 13, 1997, 97-2 CPDP: 49 at 3. 
Nonetheless, an agency may, as here, advise offerors that, despite the
fixed-price nature of the contract, the agency intends to analyze each
offeror*s proposed price and technical approach to assess both
reasonableness and realism.  The Federal Acquisition Regulation (FAR)
identifies a number of price analysis techniques that may be used to
determine whether prices are reasonable and realistic, including
comparison of the proposed prices with each other, comparison with prior
contract prices for the same or similar services, and comparison with an
independent government estimate.  FAR S: 15.404‑1(b).    
    
Here, the record reflects the agency*s extensive, documented evaluation of
Covansys*s proposal to assess, first, Covansys*s understanding of the
solicitation requirements; next, whether its proposed approach would meet
the requirements; and finally, whether the elements of Covansys*s proposed
price were realistic for the work Covansys proposed to perform and the way
it proposed to perform it.  Agency Report, Tabs 24, 25, 28.  As summarized
above, the agency reached the conclusion that Covansys*s web-based,
technology‑intensive approach will reasonably meet the solicitation
requirements and will do so in a manner that necessitates substantially
fewer personnel and at a dramatically lower price than would be required
by NCSI*s [deleted] approach. 
    
More specifically, in performing its price realism analysis, the agency*s
BEC compared and contrasted various elements of Covansys*s and NCSI*s
proposals, first addressing the level and sophistication of information
technology that each offeror proposed to employ.  With regard to
Covansys*s proposal, the BEC stated: 
    
Covansys has a web-based system already in place that is ready to go on
day 1.  This means that FEMA would not have to go through a modernization
process after the contract is awarded.
    
Agency Report, Tab 28, at 8. 
    
In contrast, the BEC noted that NCSI was proposing to begin contract
performance by continuing to rely on a *proprietary mainframe,* referred
to as the *WYO/3000 System,* stating: 
    
[Although] FEMA is moving away from mainframe services into web
services[,] NCSI still relies on the WYO/3000 system to house its data and
logic, and proposes developing a new system, NFIPDirect.com[,] for this
contract.
    
Id. at 7. 
    
Similarly, with regard to Covansys*s software system, referred to as
*FloodConnect,* and its proposed management system, the BEC stated: 
    
The Covansys FloodConnect System is based on [a] reusable component,
object-oriented approach.  This is very important as it relates to
portability and modifications to rate and rules changes.  In addition this
approach is the same as the NextGen approach for modernizing the NFIP
systems.
Covansys*[s] Workflow Management System is integrated throughout their
technical solution [and] allows coordination with NFIP partners and
exchange of information in real time.  Exchanges, including claims
reporting, can be reported online, in real time, by agents, policy holders
and partners.
Covansys[*s] financial systems were designed to be integrated into all
administrative systems.  For every transaction, the FloodConnect system
records detailed financial journal entries[.]  [T]his allows them
[Covansys] to produce accurate preliminary NFIP financial statements
[deleted], requires no manual intervention and provides a complete
financial audit trail of every transaction. 
It looks like the FloodConnect System exceeds the requirements and sets
new, improved standards for our current method of flood processing.  The
FloodConnect system addresses more than just technology, it enables
efficiencies in operations by providing
integrated workflow management and process control, integrated records
management, integrated correspondence, integrated document production,
integrated financial management, etc.
Id. at 8-9. 
In contrast, in evaluating NCSI*s proposed software system, identified as
*AccessFlood,* the agency stated: 
AccessFlood . . . was built by converting logic from the mainframe into
rules for the on-line system[.]  [T]hat means they [NCSI] are maintaining
2 systems and will continue to do so in the immediate future.  It will
require a lot of time and effort to convert their current system into [a]
web services environment[.]  [T]hat is evident by NCSI*s proposed timeline
of [deleted] after contract award to decommission the WTO/3000 system.
NCSI[*]s AccessFlood systems is currently running a[n] older version of
Oracle, the rules for the current system are hard coded and heavily tied
to the mainframe.  It will require a lot of time and effort to convert
AccessFlood to a web services environment. 
The AccessFlood Rating Engine was built using Powerbuilder (Not a FEMA
standard and not a state of the art tool; not portable. . .); inflexible
--- doesn*t facilitate a timely turnaround for updates/changes/corrections
to the rules/code.  Inflexible -- requires Powerbuilder coders to go in
and make changes.  Doesn*t support web services.
Id. at 7-8.
    
Based on our review of the record, it is clear the agency considered each
offeror*s technical approach, along with the specific resources reasonably
associated with each approach, compared the proposals to each other and to
the solicitation*s requirements, and reasonably concluded that while both
offerors understood the solicitation requirements and could successfully
perform the requirements, Covansys*s approach would do so in a manner that
was considerably more efficient and economical.[16]  Further, the agency
concluded that NCSI*s considerably higher price was, in large part,
necessitated by its proposed technical approach; accordingly, the only way
that NCSI could realistically offer a price as low as that offered by
Covansys would be to substantially rewrite its technical proposal. 
    
On this record, we find no basis to question the agency*s determination
that Covansys*s proposal demonstrated a realistic understanding of the
solicitation requirements, and that Covansys*s proposed prices were
reasonable and realistic, given Covansys*s more efficient and economical
approach to satisfying the contract requirements.
    
NCSI next protests that the agency failed to perform a proper evaluation
of Covansys*s technical proposal.  Protest at 11-12.  In making this
assertion, NCSI relies primarily on its assertion, discussed above, that
Covansys*s proposed prices were unrealistic.  Id.  More specifically,
however, this portion of NCSI*s protest focuses on the per-unit price
Covansys proposed for servicing RLTG policies, as compared to the slightly
higher price it proposed to service GFIP policies.[17]  NCSI asserts that
the requirements related to servicing RLTG policies are *considerably
greater* than the requirements related to servicing GFIP policies, Protest
at 12;[18] accordingly, NCSI maintains that Covansys*s proposed pricing
demonstrated a lack of understanding regarding the RLTG requirements and,
therefore, that it was *irrational* for the agency to evaluate Covansys*s
technical proposal as *acceptable.*  Protest at 11.  
    
In reviewing protests alleging improper technical evaluations, our Office
will not reevaluate proposals.  Rather, we will examine the record to
determine whether the agency*s judgment was reasonable and in accord with
the RFP criteria and applicable procurement statutes and regulations.  See
Rolf Jensen & Assocs., Inc., B‑289475.2, B-289475.3, July 1, 2002,
2002 CPD P: 110 at 5.  A protester*s mere disagreement with an agency*s
judgment does not establish that an evaluation was unreasonable.  Id.
    
Here, the agency does not agree that, pursuant to Covansys*s proposed
approach, the resources required to service RLTG policies will be
substantially greater than those required to service GFIP policies.  Both
NCSI and the contracting officer have, during the course of this protest,
provided various tables, lists, and descriptions of the tasks each
believes are required to service the various policies, including the RLTG
policies.  Agency Report, Contracting Officer*s Statement, at 15; NCSI
Comments on Agency Report, Nov. 20, 2003, attachs. A, B; Agency Rebuttal
to NCSI Comments, Dec. 4, 2003; NCSI Response to Agency Rebuttal, Dec. 15,
2003.  NCSI specifically describes the process related to servicing RLTG
policies as encompassing *the review of large, bulky paper files that
require considerable time and effort by claims examiners, and result in
much higher costs,* adding that *[t]he labor-intensive review cannot be
automated because the examiners have no choice but to review the
pre-existing paper files to perform their work.*  Protester*s Comments on
Agency Report, Nov. 20, 2003, attach. A.  The agency responds that
Covansys has proposed to load all claim documents, including adjuster
notes, onto the Internet for access by the agency, the adjuster, and FEMA
personnel, thereby eliminating multiple administrative steps, including
document copying and mailing.  Agency Rebuttal to NCSI Comments, Dec. 4,
2003, at 9.  The agency similarly identifies various administrative
procedures, including resolution of conflicting data from multiple sources
in different geographic areas, that Covansys*s approach will either
eliminate or perform considerably more efficiently due to its extensive
reliance on electronic transmissions that facilitate simultaneous
real-time review of information by underwriters, agents, and adjusters. 
Id. 
    
Based on our review of the record, we conclude that NCSI*s assertions that
the agency unreasonably rated Covansys*s technical proposal as
*acceptable* constitute mere disagreement with the agency*s judgments and
provide no basis for sustaining its protest.    
    
Finally, NCSI protests that the agency excluded NCSI*s proposal from the
competitive range *based solely* on comparison of NCSI*s price to a flawed
IGCE.[19]  NCSI*s protest asserts that the COTR*s estimate was low by
*over $10 million,* maintaining that *[w]hen NCSI*s historical costs are
applied to the Workload Estimates in the Solicitation, the total price [of
the IGCE] is $38,098,900.* [20]  Protest at 11.[21]  We agree that the
IGCE was materially flawed.[22]  Nonetheless, we reject NCSI*s assertion
that the agency*s consideration of the IGCE was the sole--or even the
primary--basis for the agency*s decision to exclude NCSI*s proposal from
further consideration.  Accordingly, we decline to sustain NCSI*s
protest.       
    
In responding to this portion of the protest, the agency states that the
IGCE was merely one *data point* and, as such, *only a starting point* in
the ultimate decision to eliminate NCSI*s proposal from the competitive
range.  Agency Report, Contracting Officer*s Statement, at 21; Agency
Rebuttal to NCSI Comments, Dec. 4, 2003, at 3.  The agency explains that,
more significantly than its consideration of the IGCE, the agency compared
NCSI*s proposed price and proposed approach to Covansys*s proposed price
and its proposed approach, and concluded from that comparison that NCSI*s
proposal had no reasonable chance of being selected for award, absent
NCSI*s extensive modifications to its proposed technical approach.  For
the reasons discussed above, we believe the record reasonably supports
that determination. 
    
In asserting that the agency*s comparison of NCSI*s [deleted] million
price to the flawed IGCE was the sole basis for excluding its proposal,
NCSI focuses on a single sentence in the agency*s BEC report, which, in
fact, references only a comparison to the IGCE.  Agency Report, Tab 28, at
4 (*The basis for the decision is that NCSI*s price is [deleted] above the
IGCE*).  However, in the same paragraph of this report, the agency also
states, *even with extensive modification, NCSI would not have a
reasonable opportunity for selection.*  Id.  NCSI fails to acknowledge
that, in addition to the IGCE reference quoted above, this same BEC report
contains a detailed, substantive discussion regarding the two proposals
and their substantially different technical approaches, concluding:  *The
Covansys offer indicates improved efficiency by the use of
e[lectronic]-applications in comparison to the NCSI proposal.*[23] 
    
The Federal Acquisition Regulation (FAR) authorizes the contracting
officer to exclude proposals from the competitive range that are not among
the *most highly rated.*  FAR S: 15.306(c)(1).  Further, an agency is not
generally required to include a proposal in the competitive range when, in
order to be selected for award, the offeror would have to essentially
rewrite its entire proposal.  See, e.g., Source AV, Inc., B-234521, June
20, 1989, 89-1 CPD P: 578.  Finally, agencies are not required to retain a
proposal in the competitive range simply to avoid a competitive range of
one, since conducting discussions and requesting final revised proposals
from offerors with no reasonable chance of award would benefit neither the
offerors nor the government.  SDS Petroleum Prods., Inc., B-280430, Sept.
1, 1998, 98-2 CPD P: 59 at 5.
    
As discussed above, the report identified specific areas of performance
where the agency believed that NCSI*s approach, while acceptable, was
materially inferior to that of Covansys from a technology, efficiency and
resource standpoint.  Agency Report, Tab 28, at 9.  Accordingly, based on
the record as a whole, including the entire BEC report, we reject NCSI*s
assertion that the IGCE was a determinative factor in excluding its
proposal from the competitive range.[24]  To the contrary, it is clear the
agency reasonably concluded that, in light of the materially divergent
technical approaches that were proposed, NCSI*s [deleted] proposal--that
necessitated a significantly higher price--had no reasonable chance of
being selected for award without major revisions.  We find nothing
unreasonable in this determination. 
    
The protest is denied. 
    
Anthony H. Gamboa
General Counsel
    

   ------------------------

   [1] The NFIP, established in 1968, is a federal program enabling property
owners in participating communities to purchase insurance as a protection
against flood losses in exchange for State and community floodplain
management regulations that reduce future flood damages. 
[2] For example, the agency removed certain geographic restrictions
regarding the location of the offeror.  Agency Report, Contracting
Officer*s Statement, at 3.
[3] Since 1983, the vast majority (currently, nearly 95 percent) of all
NFIP policies have been written by *Write Your Own* (WYO) companies--that
is, private insurance companies that are authorized by the federal
government to write and service NFIP policies in their own names.  The WYO
companies receive an expense allowance for policies written and claims
processed, while the federal government retains the underwriting risk. 
Agency Report, Tab 8, RFP, at 89.  Under the solicitation at issue here,
the contractor is responsible for servicing the remaining *direct*
insurance policies‑‑that is, the NFIP policies for which the
federal government is the named insurer.     
[4] This is the basic insurance policy under the NFIP and represents
approximately 66 percent of the total estimated number of insurance
policies the contractor will be required to service.  Agency Report, Tab
18, at 2.  
[5] The GFIP policies provide a low-cost mechanism for insuring disaster
aide recipients, providing a minimum level of insurance coverage for 3
years tied to the consumer price index.  Agency Report, Tab 8, RFP, at
93.  The GFIP policies represent approximately 14 percent of the total
estimated number of insurance policies the contractor will be required to
service.  Agency Report, Tab 18, at 2.   
[6] The RLTG policies are issued for properties that have sustained
repetitive losses.  The solicitation requires that the contractor perform
certain monitoring and oversight activities related to these policies that
are not required to service the SFIP and GFIP policies.  Agency Report,
Tab 8, RFP, at 94.  The RLTG policies represent approximately 20 percent
of the total estimated number of insurance policies the contractor will be
required to service.       
[7] The solicitation also contained a separate CLIN for transition costs. 
[8] The non-price evaluation factors were:  ability to perform major and
other requirements; corporate experience and past performance; and
staffing and key personnel.  Agency Report, Tab 8, RFP, at 86-87.  The
solicitation provided that non‑price factors would be more important
than price.  Agency Report, Tab 8, RFP, at 85.
[9] Section M of the solicitation stated that, that in performing the
price realism analysis, the agency would review the skill mix, specific
level of effort, and material proposed for performing the solicitation
requirements and would determine whether the offeror*s proposed price/cost
elements are *realistic for the work to be performed, reflect a clear
understanding of the requirements, and are consistent with the approach
described in the offeror*s technical proposal.*  Agency Report, Tab 8,
at 88.  The solicitation also required that each offeror submit pricing
information regarding individual pricing elements, including direct labor,
direct materials, overhead, travel and consultants.  Agency Report, Tab 8,
RFP, at 76‑77.
[10] The COTR*s estimate did not reflect the costs associated with
servicing GFIP or RLTG policies.  Id.  These two groups of policies,
combined, are projected to constitute approximately one-third of the total
policies to be serviced.  Agency Report, Tab 18, at 2. 
[11] In evaluating technical proposals, the TEP assigned adjectival
ratings of *superior,* *acceptable,* *marginal,* and *unacceptable.* 
Agency Report, Tab 24, at 7.   
[12] The solicitation provided that offerors* total evaluated prices would
be determined by multiplying the proposed unit prices by the estimated
quantities for each CLIN and adding the results for the base period and
all option periods.  Agency Report, Tab 8, RFP, at 87.
[13] Following discussions, Covansys increased its proposed staffing level
to [deleted] FTEs. 
[14] Following discussions, Covansys increased its proposed price to
approximately $25.14 million.       
[15] NCSI does not dispute that its proposed technical approach
contemplates a great deal of [deleted]; nor does NCSI assert that, if
given the opportunity, it would materially alter its proposed approach. 
[16] The record also establishes that, for each contract period, the
agency performed a documented analysis of Covansys*s price elements,
including direct labor, labor overhead, other direct costs (including
travel, training, consumable equipment, and consultants,) and its proposed
general and administrative (G&A) rate.  Agency Report, Tab 33, at 11-54. 
NCSI has not challenged this portion of the agency*s evaluation.
[17] For the base period, Covansys proposed the following unit
prices:                       SFIP - $1.94; GFIP - $2.33; RLTG - $2.04. 
NCSI proposed the following unit prices:  SFIP * [deleted]; GFIP *
[deleted]; RLTG * [deleted].  Agency Report, Tab 22, at 1. 
[18] As noted above, RLTG policies relate to properties that have
sustained repetitive losses and the solicitation contemplates certain
activities to service these policies that are not required for GFIP or
SFIP policies; for example, when an RLTG claim is submitted, all claims
submitted for the insured property during the preceding 3 years must be
reviewed. 
[19] As discussed above, prior to issuing the solicitation, the COTR
calculated an $28.5 million IGCE by applying NCSI*s current contract
prices to the estimated quantities of SFIP contracts projected to be in
force during the contract period; the IGCE did not include costs for
servicing GFIP or RLTG policies.  Agency Report, Tab 2.         
[20] In a footnote, NCSI*s protest asserts that the [deleted] million
difference between its [deleted] million price and the $38 million that
NCSI maintains the IGCE should have been was attributable to *changes* to
the performance work statement (PWS) requirements, and to NCSI*s proposal
of *a slightly increased profit.*  Protest at 11.  The agency maintains
that only minor changes were made to the PWS requirements.  Agency Report,
Contracting Officer*s Statement, at 18.  
[21] Subsequently, NCSI raised its calculation of what it asserts an
appropriate IGCE would be to $43 million.  NCSI Comments on Agency Report,
Nov. 20, 2003.
[22] The IGCE fails to reflect the costs associated with servicing GFIP
and RLTG policies; as noted above, these policies, combined, represent
approximately one‑third of the total estimated number of policies to
be serviced under this solicitation.  Agency Report, Tab 2.   
[23] Preceding this conclusion, the BEC report contains the detailed
substantive discussion, quoted in the decision above, comparing various
technical aspects of the two proposals. 
[24] Even if we were to conclude that the flawed IGCE played a significant
role in the agency*s determination, NCSI has not demonstrated that it was
prejudiced.  Specifically, although NCSI asserts that if the agency had
included NCSI in discussions, NCSI would have lowered its price, NCSI has
never suggested that it would--or could--have offered a price as low as
Covansys*s.  To the contrary, all of NCSI*s arguments in pursuing this
protest reflect its position that NCSI could not perform the contract
requirements at that price.  In light of our conclusion, above,  that the
agency reasonably rated Covansys*s technical proposal as *acceptable,* it
is clear from NCSI*s own submissions that, while discussions with NCSI may
well have resulted in some reduction of NCSI*s price, such reduction would
have been insufficient to place NCSI in line for award.