TITLE: B-294722.4, SGT, Inc., July 28, 2005
BNUMBER: B-294722.4
DATE: July 28, 2005
************************************
B-294722.4, SGT, Inc., July 28, 2005

   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: SGT, Inc.

   File: B-294722.4

   Date: July 28, 2005

   Andrew P. Hallowell, Esq. and Jennifer M. Morrison, Esq., Piliero, Mazza &
   Pargament PLLC, for the protester.

   Amy J. Weisman, Esq., and Kevin P. Travis, Esq., Space and Naval Warfare
   Systems Command, for the agency.

   Jonathan L. Kang, Esq., and Michael R. Golden, Esq., Office of the General
   Counsel, GAO, participated in the preparation of the decision.

   DIGEST

   1. Protest challenging agency's evaluation of protester's cost proposal is
   denied where the agency's cost realism adjustments were reasonable.

   2. Protest challenging evaluation of protester's technical proposal is
   denied where the record supports the agency's evaluation.

   DECISION

   SGT, Inc. protests the award of a contract to Systems Integration &
   Management, Inc. (SIM) under request for proposals (RFP) No.
   N00039-04-R-0005, issued by the Space and Naval Warfare Systems Command
   (SPAWAR) for a business, operations and administrative support services
   (BOASS) contract at the U.S. Navy SPAWAR Information Technology Center in
   New Orleans, Louisiana. The protester argues that the agency improperly
   evaluated its cost and technical proposal.

   We deny the protest.

   The RFP anticipates award of an indefinite-delivery/indefinite-quantity
   (ID/IQ) contract, which provides for cost-plus-award-fee and
   fixed-price-award-fee task orders. The competition was restricted to
   offerors who are participants in the Small Business Administration's 8(a)
   program for small, disadvantaged businesses. The RFP sought proposals to
   provide "all management, supervision, labor, administrative support,
   reporting requirements, supplies, and associated support services"
   required to support the SPAWAR Information Technology Center. RFP at 1.
   The base performance period for the contract is 1 year, with four 1-year
   option periods.

   The RFP states that award would be made to "the responsible Offeror whose
   offer conforming to the solicitation, is determined to provide the `best
   value' to the Government." RFP sect. M-2(a). The evaluation factors were,
   in descending order of importance: corporate experience and past
   performance, technical and management approach, ability to perform 50
   percent of the work and manage subcontractors, personnel resumes, and
   transition plan. Id. at M-2(c). The non-cost evaluation criteria were
   "significantly more important than cost." Id. at M-2(b).

   Offerors were advised that the agency would review proposals for cost
   realism:

   Cost realism will be performed on the cost proposal. The cost realism
   analysis shall (a) verify the proposed rates against [Defense Contract
   Audit Agency (DCAA)] audited rates; (b) assess the degree to which
   uncompensated overtime is utilized, and (c) assess escalation and how it
   is derived. Proposed costs may be adjusted, for purposes of evaluation,
   based upon the results of the cost realism analysis. The resulting
   realistic cost estimate will be used in the evaluation.

   RFP sect. M-2.

   SGT proposed to perform the contract utilizing the incumbent contractor,
   Systems Engineering & Security, Inc. (SES), as a subcontractor. Under
   SGT's proposal, SGT would perform [deleted] percent of the work, with SES
   performing [deleted] percent of the work. Agency Report (AR), Tab 19, SGT
   Proposal, Vol. I., at C-7. All SGT personnel would be hired from SES's
   incumbent staff, and the proposed direct labor rates for SGT and SES were
   based on that staff. Id., Vol. II, sect. 2.1.2.

   The agency requested that DCAA audit offerors' cost proposals. DCAA's
   analysis of SGT's and SES's proposal stated that DCAA could not establish
   an evaluated rate for the majority of SGT's proposed rates. AR, Tab 10,
   DCAA SES Cost Audit, June 28, 2004, at 3; Tab 9, DCAA SGT Cost Audit, July
   14, 2004, at 3. After receiving DCAA's report on SGT's proposed costs, the
   Navy's cost evaluation board (CEB) compared SGT's and SES's proposed rates
   to the evaluated rates from the next-most recent DCAA audit of SES's rates
   under the incumbent contract, dated September 2003. AR, Tab 8, Original
   CEB Report, at 5. Based on its review of the September 2003 DCAA audit,
   the agency's analysis concluded that SGT's proposed costs could not be
   confirmed and adjusted its proposed costs upward by a total of [deleted].
   Id.

   The contract was initially awarded to SIM on August 23, 2004. Two
   disappointed offerors, other than SGT, filed protests with our Office. The
   agency advised our Office on October 13, 2004 that it would take
   corrective action in response to the protests, and we subsequently
   dismissed both protests as academic.

   During its corrective action, the agency advised offerors that it would
   reevaluate existing proposals; offerors were not allowed to submit
   proposal revisions, but instead were instructed to either withdraw or
   extend their proposals under the same terms and pricing. The agency
   convened a new technical evaluation board (TEB) and CEB to reevaluate
   proposals, each with entirely new members. Memorandum of Law at 11. The
   reevaluation TEB reviewed each offeror's proposal without consulting the
   original TEB's work. Id. The reevaluation of SGT's technical proposal
   produced lower ratings under several evaluation factors as compared to the
   initial evaluation. Protest at 6. The reevaluation CEB reviewed the work
   of the original CEB. AR, Tab 13, Reevaluation CEB Report, at 2-3. The
   reevaluation CEB first determined that the original CEB's "overall
   methodology was sound," and then reexamined the cost analyses performed
   for each offeror. Id. The reevaluation CEB concluded that the original
   CEB's cost analysis of SGT's proposal was reasonable, and made no changes
   to the cost realism adjustments. Id., attach. 12, at 1-2. The agency did
   not conduct discussions during the original or the revised evaluations.

   After the reevaluation, SGT, SIM and a third offeror, were the three most
   highly-rated offerors among whom the agency conducted a cost-technical
   trade-off analysis. AR, Tab 7, Source Selection Decision (SSD), at 2. The
   agency evaluated these proposals as follows:[1]

   +------------------------------------------------------------------------+
   |                    |       SGT       |      SIM       |   Offeror C    |
   |--------------------+-----------------+----------------+----------------|
   |Technical           | Good, low risk  |Outstanding, low| Good, low risk |
   |                    |                 |      risk      |                |
   |--------------------+-----------------+----------------+----------------|
   |Corporate Experience|Outstanding, low |Outstanding, low|Outstanding, low|
   |And Past Performance|      risk       |      risk      |      risk      |
   |--------------------+-----------------+----------------+----------------|
   |Technical And       |Satisfactory, low|Outstanding, low|Outstanding, low|
   |Management Approach |      risk       |      risk      |      risk      |
   |--------------------+-----------------+----------------+----------------|
   |Ability To Perform  |  Satisfactory,  |Outstanding, low| Good, low risk |
   |50% Of Work And     |  moderate risk  |      risk      |                |
   |Manage              |                 |                |                |
   |Subcontractors      |                 |                |                |
   |--------------------+-----------------+----------------+----------------|
   |Personnel Resumes   | Good, low risk  | Good, low risk |   Marginal,    |
   |                    |                 |                | moderate risk  |
   |--------------------+-----------------+----------------+----------------|
   |Transition Plan     | Good, low risk  |Outstanding, low|Unsatisfactory, |
   |                    |                 |      risk      |   high risk    |
   |--------------------+-----------------+----------------+----------------|
   |Proposed Cost       |    [deleted]    |  $65,294,733   |   [deleted]    |
   |--------------------+-----------------+----------------+----------------|
   |Evaluated Cost      |    [deleted]    |  $68,514,755   |   [deleted]    |
   +------------------------------------------------------------------------+

   Id. at 1, 4-5.

   Based on its trade-off analysis, the agency's source selection authority
   again selected SIM for award on April 6, 2005. AR, Tab 7, SSD, at 6.
   Following its debriefing, SGT filed this protest.

   DISCUSSION

   Cost Realism Analysis

   SGT contends that the agency improperly refused to accept its proposed
   costs and that the agency's cost realism analysis was flawed.
   Specifically, SGT alleges that the agency unreasonably ignored language in
   DCAA's audit that SGT argues approved its proposed direct labor rates and,
   consequently, improperly adjusted SGT's proposed rates based on DCAA's
   September 2003 audit of SES's direct labor rates under the incumbent
   contract.[2]

    

   As discussed above, SGT proposed to perform the contract using SES
   personnel. SES would terminate certain of its personnel currently
   performing the incumbent contract and SGT would hire those individuals;
   the balance of the incumbent staff would be retained by SES to perform the
   subcontract work. AR, Tab 19, SGT Proposal, Vol. II, sect. 2.1.2. The
   majority of the labor categories, approximately
   two-thirds, were proposed for performance by both SGT and SES staff. AR,
   Tab 10, DCAA SES Cost Audit, June 28, 2004, at 2; Tab 9, DCAA SGT Cost
   Audit, July 14, 2004, at 2. The position of project manager would be
   provided by [deleted], while certain other positions would be performed
   exclusively by either SGT or SES personnel. Id. SGT explained that it
   would pay the same salaries currently provided for SES incumbent staff:

   SGT will offer a salary that is at least equal to the incumbent employee's
   current salary. SGT will not reduce the base salaries of current incumbent
   employees who continue to perform the same work on the BOASS contract. We
   have assured this by working with the incumbent contractor, SES, and have
   developed average salaries for each proposed labor category that are based
   on the actual salaries of SES employees currently working on the contract.

   AR, Tab 19, SGT Proposal, Vol. II, sect. 5.1.

   In its review of SGT's proposed costs, DCAA first evaluated the proposed
   rate for SGT's program manager. DCAA adjusted the proposed rate based on
   the salary identified in SGT's hiring letter, which indicated a higher
   rate. AR, Tab 9, DCAA SGT Cost Audit, July 14, 2004, at 3.

   Next, as relevant here, DCAA evaluated SGT's and SES's proposed labor
   categories that were exempt from the Service Contract Act (SCA). These
   categories comprised the bulk of the labor categories, and were to be
   performed by either or both SGT and SES at the same labor rates:

   For Exempt personnel . . . [t]he labor rates for each labor category are
   based on the actual salaries of employees currently working on the
   [incumbent] contract. An average labor rate by labor category was
   calculated using these actual salaries. The SES labor category
   descriptions are consistent to the labor category descriptions provided in
   the solicitation and have been adopted for use by SGT.

   AR, Tab 19, SGT Proposal, Vol. II, sect. 2.1.2.

   Because SGT's and SES's proposed direct labor rates were based on SES
   incumbent staff, DCAA reviewed SGT's and SES's rates based on "average
   payroll data dated June 8, 2004," provided by SES to DCAA. AR, Tab 10,
   DCAA SES Cost Audit, June 28, 2004, at 3; Tab 9, DCAA SGT Cost Audit, July
   14, 2004, at 3. DCAA's audit of SGT's and SES's cost proposals "verified
   the proposed direct labor rates to the contractor's supporting labor
   data."[3] AR, Tab 9, DCAA SGT Cost Audit, July 14, 2004, at 1. DCAA
   concluded that it could not establish evaluated rates for these labor
   categories:

   SES furnished us with their category payroll data dated June 8, 2004. We
   compared the proposed base hourly rates to the payroll data. No
   differences were noted. However, the subcontractor informed us at the
   entrance conference that this is a Task Order proposal; and, as a result,
   the Tasks will be defined at negotiations. The subcontractor informed us
   that some of the SES personnel identified in this proposal will be
   terminated by SES and hired by SGT, Inc., the prime contractor. The
   employees who will be affected by this change will not be identified until
   after this contract is negotiated. Therefore, since we were unable to
   identify the employees who will be retained by SES and could not determine
   the rate that the terminated individuals will be paid by the prime
   contractor, we were unable to establish evaluated base hourly rates for
   these labor categories.

   AR, Tab 10, DCAA SES Cost Audit, June 28, 2004, at 3; Tab 9, DCAA SGT Cost
   Audit, July 14, 2004, at 3.

   In its review of SGT's cost proposal, the original CEB concluded that,
   because DCAA could not evaluate SGT's and SES's proposed rates for
   SCA-exempt labor categories, an alternative means of cost analysis was
   required:

   Since DCAA was unable to identify the employees who will be retained by
   SES and could not determine the labor rate that the terminated individuals
   will be paid by SGT, DCAA was unable to establish evaluated hourly rates
   for these labor categories. Thus, to perform a cost analysis, the CEB
   compared the proposed hourly labor rates to SES's, incumbent contractor,
   FY 2004 labor rates provided in [DCAA] Report No. 6311-2003D2800105 dated
   9 September 2003.

   AR, Tab 8, Original CEB Report, at 8.

   The September 2003 DCAA audit analyzed SES's rates for performing the
   incumbent contract. AR, Tab 11, DCAA SES Cost Audit, Sept. 9, 2003, at 1.
   The original CEB analysis concluded that, based on a comparison of SGT's
   and SES's proposed rates with the SES rates in the September 2003 DCAA
   audit, there were "significant differences between the proposed direct
   labor base rates and the evaluated direct labor rates."[4] AR, Tab 8,
   Original CEB Report, at 8. The original CEB's cost analysis of the
   proposed direct labor rates consisted of adjusting all of the direct labor
   rates for all labor categories, other than the program manager, to the
   level of the September 2003 rates.[5] Id.

   The cost realism adjustments to the direct labor rates increased SGT's
   evaluated direct labor costs by [deleted] and its overhead by [deleted].
   The adjusted direct labor rates also increased SES's evaluated subcontract
   costs by [deleted]. Id. The original CEB then applied the SGT's adjusted
   G&A rate, resulting in an increase of [deleted]. Id. The adjustments to
   SGT's evaluated cost totaled [deleted]. Id.

   Because the reevaluation CEB was responsible for the cost analysis that
   formed the basis for the award, our focus is on that CEB's cost realism
   analysis. As discussed above, the reevaluation CEB validated the original
   CEB's cost analysis methodology, confirmed the analysis of proposals, and,
   in the case of SGT, agreed that no changes were required to the original
   CEB's adjustments to SGT's cost proposal.

   When an agency evaluates proposals for the award of a cost-reimbursement
   contract, an offeror's proposed costs are not considered controlling,
   because regardless of the costs proposed, the government is bound to pay
   the contractor its actual and allowable costs. Federal Acquisition
   Regulation (FAR) sections 15.305(a)(1); 15.404-1(d). Consequently, a cost
   realism analysis must be performed by the agency to determine the extent
   to which an offeror's proposed costs represent what the contract should
   cost, assuming reasonable economy and efficiency. FAR sect.
   15.404-1(d)(2); Hanford Envtl. Health Found., B-292858.2, B-292858.5, Apr.
   7, 2004, 2004 CPD para. 164 at 8-9. The evaluation of competing cost
   proposals requires the exercise of informed judgment by the contracting
   agency involved, since it is in the best position to assess the realism of
   cost and technical approaches and must bear the burden resulting from a
   defective cost realism analysis. Because the contracting agency is in the
   best position to make this determination, we review an agency's judgment
   in this area only to see that the agency's cost realism evaluation was
   reasonably based and not arbitrary. Hanford Envtl. Health Found., supra,
   at 8-9. An agency's cost realism analysis need not achieve scientific
   certainty; rather, the methodology employed must be reasonably adequate
   and provide some measure of confidence that the rates proposed are
   reasonable and realistic in view of other cost information reasonably
   available to the agency as of the time of its evaluation.

   See Metro Mach. Corp., B-295744; B-295744.2, Apr. 21, 2005, 2005 CPD para.
   112 at 10-11; Science Applications Int'l Corp., B-290971 et al., Oct. 16,
   2002, 2002 CPD para. 184 at 17.

   SGT first argues that DCAA's audit of its cost proposal confirmed that
   SES's payroll submitted for purposes of DCAA's audit supported the
   proposed rates for the SCA-exempt labor categories. Specifically, SGT
   contends that DCAA compared the proposed salaries and labor rates, and
   that "[n]o differences were noted." AR, Tab 10, DCAA SES Cost Audit, June
   28, 2004, at 3; Tab 9, DCAA SGT Cost Audit, July 14, 2004, at 3. Thus,
   SGT, argues, the agency improperly rejected its proposed rates.

   While it is true that DCAA compared SES's labor rates to its payroll data,
   there is no basis in the record to conclude that DCAA intended to
   recommend that SGT's and SES's proposed rates to be accepted as a
   reasonable estimate of the labor rates that will be applicable to the
   contract. To the contrary, DCAA's reports for SGT and SES both indicated
   that DCAA was "unable to establish evaluated base hourly rates for these
   labor categories" because it was unclear how personnel would be
   distributed between the two firms. AR, Tab 10, DCAA SES Cost Audit, June
   28, 2004, at 3; Tab 9, DCAA SGT Cost Audit, July 14, 2004, at 3. We find
   this conclusion reasonable, as each company proposed its own indirect
   rates, and thus allocation of an employee to either SGT or SES would
   affect the rate charged for that employee. Furthermore, although SGT
   proposed to pay "no less" than SES's current rates, this statement left
   open the possibility that SGT could pay more than the incumbent salaries.
   In any case, based on the data provided by SES, DCAA was unable to provide
   evaluated rates for the SCA-exempt positions, representing 18 of 25 SGT
   labor categories, and 17 of 25 SES labor categories. AR, Tab 10, DCAA SES
   Cost Audit, June 28, 2004, at 2; Tab 9, DCAA SGT Cost Audit, July 14,
   2004, at 2.

   During a hearing conducted by our Office, the reevaluation CEB chair
   stated that the reevaluation CEB understood DCAA's report regarding SGT's
   and SES's SCA-exempt labor categories to mean that SGT's approach of
   proposing labor categories that either SGT or SES employees might fill
   effectively precluded DCAA's analysis of the proposed rates because the
   allocation of employees between the companies was not known at the time of
   proposal submission. Tr. at 34:11-35:9; see also AR, Tab 8, Original CEB
   Report at 7-8; Tab 13, Reevaluation CEB Report, attach. 12, at 1.

   Although a contracting agency can utilize the services of DCAA when
   performing a cost realism analysis rather than perform all aspects of the
   evaluation itself, the audit agency is but one tool upon which the agency
   may elect to rely. See Metro Mach. Corp., supra, at 11. In our view, the
   agency had a reasonable basis to conclude that the DCAA audit of SGT's and
   SES's cost proposal did not provide information that would allow the
   agency to accept the rates as proposed, and that therefore an additional
   analysis of the cost proposal was required.

   SGT next argues that the agency unreasonably relied on the DCAA audit of
   SES's rates under the incumbent contract in September 2003 as the standard
   to evaluate SGT's and SES's proposed direct labor rates.[6] SGT challenges
   the use of the September 2003 rates asserting that these rates were
   outdated at the time proposals were submitted in May of 2004. SGT argues
   that SES had experienced turnover in its staff, which resulted in
   lower-cost staff replacing higher-cost staff during the months between the
   September 2003 DCAA audit of SES's rates, which were based on SES's August
   29, 2003 payroll data for the incumbent contract, and the submission of
   SGT's proposal in May 2004. Protester's Comments at 5. SGT submitted as
   part of its comments exhibits showing staff turnover during this time. See
   Protester's Supplemental Comments, exh. 3. SGT, however, did not clearly
   demonstrate in its proposal (and during this protest, for that matter),
   that staffing changes had any effect on the proposed rates, i.e., that
   higher-salaried personnel who performed work for SES and were evaluated
   under the September 2003 audit were individuals who had left SES's
   employment, and that the salaries of lower-cost replacements for these
   individuals were the basis for the cost proposal in May 2004. It was SGT's
   obligation to demonstrate in its proposal the basis for the change in its
   rates from what the agency had experienced under the incumbent contract to
   the proposed rates inasmuch as it was SGT's burden to submit an adequately
   written cost proposal for the agency to evaluate, especially where, as
   here, offerors are specifically on notice that the agency intended to make
   award based on initial proposals without discussions.[7] See EER Sys.,
   Inc., B-290971.3, B-290971.6, Oct. 23, 2002, 2002 CPD para. 186 at 14.
   Because SGT's proposal provided no explanation regarding what SGT now says
   was a significant reduction in SES's previously incurred labor costs, in
   our view, the agency reasonably relied upon the most recent fully-audited
   rates provided by DCAA of SES's rates under the incumbent contract.[8]

   In sum, we conclude that, in light of DCAA's inability to develop
   evaluated direct labor rates based on SGT's cost proposal and staffing
   approach, the agency's experience with SES's costs under the incumbent
   proposal as detailed in the September 2003 DCAA audit, and in the absence
   of other data in SGT's proposal that would address the agency's concerns,
   the agency's cost realism analysis was reasonable. The adjustments to both
   the SCA-exempt and non-exempt rates and the use of the September 2003
   audited rates as the most recently evaluated rates were reasonable in
   light of the information available to the agency. This aspect of the
   protest is denied.[9]

   Technical Evaluation

   SGT raises several objections to the agency's evaluation of its technical
   proposal.[10] In reviewing a procuring agency's evaluation of an offeror's
   technical proposal, our role is limited to ensuring that the evaluation
   was reasonable and consistent with the terms of the solicitation and
   applicable statutes and regulations. Urban-Meridian Joint Venture,
   B-287168, B-287168.2, May 7, 2001, 2001 CPD para. 91 at 2. Our Office will
   not question an agency's evaluation judgments absent evidence that those
   judgments were unreasonable or contrary to the stated evaluation criteria.
   Kay & Assocs., Inc., B-291269, Dec. 11, 2002, 2003 CPD para. 12 at 4.

   SGT argues that the agency improperly evaluated its technical proposal
   under eight areas for the technical and management approach evaluation
   factor, the ability to perform 50 percent of the work and manage
   subcontractors evaluation factor, and the transition factor. We have
   reviewed all of the protester's contentions and find them to be without
   merit. In each case, we conclude that the agency reasonably evaluated
   SGT's and SIM's proposals, and reasonably identified differences or
   similarities between the proposals that warranted their respective
   evaluation ratings.[11]

   For example, SGT argues that the agency improperly credited SIM with
   proposing a "Team SIM Council" that "advises the [program manager] on key
   issues," but did not find a similar strength in SGT's proposal. AR, Tab
   22, SGT Proposal, at I.2.7-8. The agency's evaluation of SIM determined
   that:

   SIM has proposed an advisory council with a charter that outlines the role
   and responsibility of the council. The council will assist in resolution
   of management issues and facilitate access to corporate resources.
   [deleted]

   AR, Tab 20, Revaluation TEB Report, SIM Evaluation, at 3. SGT contends
   that its proposal offered the same benefits as SIM's. SGT's proposal,
   however, does not describe a formal council in the same manner as SGT, but
   instead states that [deleted]. AR, Tab 19, SGT Proposal, Vol. I, at B-16.
   SGT additionally notes that [deleted]. Id., Vol. I, at C-7.

   Although SGT argues that its proposal offered strengths similar to SIM's,
   we believe that the agency reasonably identified discriminating features
   in SIM's proposal that warranted a strength for SIM, but not for SGT.
   SIM's proposal provided a formal organizational structure specifically
   charged with advising the program manager on management issues, whereas
   SGT's proposal provided only isolated references to general resources
   available to its own program manager. In sum, SGT provides no basis to
   challenge the agency's evaluation of strengths for SIM or the lack of a
   corresponding strength in its own proposal. Urban-Meridian Joint Venture,
   supra; Kay & Assocs., Inc., supra.

   As another example, SGT contends that SIM was improperly given a strength
   for proposing a dedicated "risk manager" because this position was not a
   required position under the PWS. The agency determined that "SIM offered a
   detailed Risk Mitigation Plan," that "emphasizes pro-active planning and
   includes a dedicated risk manager." AR, Tab 21, Reevaluation Source
   Selection Advisory Counsel (SSAC) Report, at 40; Tab 20, Revaluation TEB
   Report, SIM evaluation, at 4. Since the RFP sought detailed technical
   proposals, and included technical evaluation criteria, offerors here were
   on notice that qualitative distinctions would be made under various
   evaluation factors. In such procurements, evaluation strengths properly
   may be found where a proposal includes enhancements or features not
   expressly identified in the solicitation, provided the strength is
   consistent with the stated evaluation criteria. Medical Dev. Int'l,
   B-281484.2, Mar. 29, 1999, 99-1 CPD para. 68
   at 6-7. The RFP stated that evaluation elements for the technical and
   management approach evaluation factor included "[c]omprehensiveness of the
   proposed approach, and likelihood of successfully meeting the solicitation
   requirements," and "[c]omprehensiveness of Program Management Plan,
   including the demonstrated likelihood of successful program management to
   meet the solicitation requirements." RFP sect. M-2. The SIM proposal
   linked its risk management structure to the ability of the firm to provide
   the work required by the PWS without interruption. AR, Tab 22, SIM
   Proposal, Vol. I, at 2.20-21. We conclude that the agency reasonably
   credited SIM's proposal with a strength for offering a risk manager,
   consistent with the stated evaluation criteria.

   SGT also argues that the agency improperly evaluated its proposal under
   the key personnel resumes evaluation factor. Offerors were required to
   provide at least 1, but no more than 10, key personnel resumes. RFP sect.
   L-6 at 95. SGT provided 6 resumes, of which 4 were found to exceed the
   minimum experience requirements, with the other 2 failing to meet the
   requirements. AR, Tab 21, Reevaluation SSAC Report, at 39.

   For one of the project manager positions, the agency concluded that the
   proposed individual's experience did not clearly meet the RFP requirements
   for the position. SGT argues that the agency unreasonably determined that
   the proposed individual did not possess the required 5 years of
   specialized experience in "complete engineering project development from
   inception to deployment, expertise in management and control of funds, and
   managing multi-task contracts." AR, Tab 21, Revaluation TEB Report, SGT
   evaluation, at 7-8; Tab 18, revised labor category descriptions, at 1.
   With regard to the "management and control of funds" criterion, a review
   of the proposed individual's employment does not clearly demonstrate
   experience in this area. AR, Tab 19, SGT Proposal, Vol. I, at D-9-10. In
   its comments, the protester describes two of the proposed individual's
   positions, arguing that they together constitute the required 5 years of
   specialized experience. For these positions, however, the protester's
   summary shows that the proposed individual has only 3 years and 1 month
   "experience in management and control of funds." Protester's Comments at
   16. We thus conclude that the agency's evaluation reasonably determined
   that the proposed project manager did not meet the RFP requirement for
   specialized experience.

   For SGT's proposed customer service engineer supervisor, the agency
   concluded also that the proposed individual did not meet the minimum
   experience requirements. The RFP stated that the customer service engineer
   supervisor must have 11 years of general experience and 5 years of
   specialized experience. RFP, Revised Labor Category Descriptions, at 11.
   The agency determined that the proposed individual did not meet the 5-year
   requirement because experience was listed from October 1999 to the
   present. AR, Tab 20, Revaluation TEB Report, SGT evaluation, at 8-9; Tab
   19, SGT proposal, Vol. I, at D-11. The agency argues that the individual's
   specialized experience should only have been counted up to the date of the
   proposal, which was May 2004, resulting in 4 years and 8 months. However,
   where the individual's resume says "to present," and the reevaluation took
   place in April 2005 following offerors' confirmation of their proposals,
   we think that the agency reasonably should have counted his experience as
   of the date of the reevaluation.

   Nonetheless, we believe the agency reasonably determined that the overall
   general experience requirement of 11 years (the required 8 years plus 3
   additional years to account for the individual's lack of a bachelor's
   degree) was not met because the description of the individual's experience
   with the Navy did not clearly meet the requirements of the RFP. The
   individual's resume provided only a general description of the
   individual's 20 years of experience in the Navy working on advanced data
   processing work analysis. AR, Tab 19, SGT Proposal, Vol. I, at D-11. This
   description did not clearly fit the RFP's requirement of 11 years of
   "information systems development, network and other work in the
   client/server field, or related fields." RFP, Revised Labor Category
   Descriptions, at 11. Although SGT argues that the agency could have
   reviewed his records to determine if this individual's work met the
   requirements, there is no obligation for the Navy to do so; to the
   contrary, it is an offeror's obligation to fully detail how a key
   personnel resume meets the RFP requirements. Tessada & Assoc., Inc.,
   B-293942, July 15, 2004, 2004 CPD para. 170 at 5-6.

   The protest is denied.

   Anthony H. Gamboa

   General Counsel

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

   [1] Ratings for each evaluation factor were: outstanding, good,
   satisfactory, marginal and unacceptable. RFP sect. M-4.1. A risk rating of
   low, moderate, or high risk was also assigned each factor. Id. sect.
   M-4.2.

   [2] SGT additionally argues that the agency treated SGT unequally as
   compared to other offerors regarding certain elements of the cost
   evaluation. We find this allegation without merit. Based on our review of
   the record, we conclude that the agency treated similarly-situated
   offerors equally.

   [3] DCAA also evaluated offerors' indirect rates. DCAA concluded that
   SES's proposed indirect rates were "in line with the historical rates."
   AR, Tab 10, DCAA SES Cost Audit, June 28, 2004, at 5. DCAA determined that
   SGT's proposed G&A rate was [deleted], and adjusted it [deleted]. AR, Tab
   9, DCAA SGT Cost Audit, July 14, 2004, at 4-5. SGT did not protest this
   adjustment to its G&A rate.

   [4] For the remainder of the SGT and SES labor categories, comprised of
   SCA

   non-exempt positions, DCAA compared the proposed rates to the applicable
   Department of Labor wage determination rates. As the reevaluation CEB
   chair explained, however, the agency was concerned that DCAA evaluated
   these proposed rates against the DOL wage determination, only, and did not
   review the actual salaries incurred by SES under the incumbent contract
   for these labor categories. The agency concluded that the proposed wage
   determination rates did not reflect the actual incumbent salaries because
   they were [deleted] the rates from the September 2003 DCAA audit of SES's
   rates. Hearing Transcript (Tr.) at 31:7-32:16, 92:5-93:-7. Consequently,
   for offerors, such as SGT, whose proposals relied upon using the incumbent
   workforce, the agency applied the September 2003 evaluated rates,
   regardless of whether DCAA had determined that the wage determined
   positions were in fact in line with the wage rates. Tr. at 181:2-8. We
   conclude that this adjustment was reasonable in light of the agency's
   concerns regarding SGT's proposed costs as being [deleted] experienced by
   SES under the incumbent contract.

   [5] In its cost analysis, the agency applied SGT's proposed rate for the
   program manager, and not the evaluated rate established by DCAA based on
   the individual's employment letter. The agency has acknowledged that using
   the proposed rate was an error by the original CEB, and was not corrected
   by the reevaluation CEB. Agency Post-Hearing Comments, at 3 n.12. However,
   because the incorrect rate used by the agency is in fact lower than the
   actual rate, there is no prejudice to SGT. See 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).

   [6] The reevaluation CEB chair stated that, prior to the issuance of the
   RFP, the agency used the September 2003 DCAA audit of SES's labor rates
   under the incumbent contract to establish a "benchmark" to develop the
   agency most probable cost estimate for the solicitation. Tr. at
   54:18-56:15, 92:5-93:7. The original CEB also conducted a "spot check"
   analysis to compare SES cost data under the incumbent contract at the time
   of proposal submission to the September 2003 DCAA audit rates. Tr. at
   116:7-117:4. The agency now contends that the benchmark and spot check
   analyses validated the use of the SES September 2003 audited rates for the
   cost realism analysis for SGT's proposal. As the agency acknowledges,
   however, the record contains no information regarding the methodology
   behind or results of the initial benchmarking or the spot check analyses.
   Tr. at 78:18-79:15, 93:8-18, 166:5-22. Although the agency submitted a
   declaration by the original CEB chair, concerning the spot check, this
   declaration also does not disclose any detail regarding the purported
   analysis. Original CEB Chair Decl. para. 2. Because the agency has not
   provided any evidence regarding these analyses, we find that they provide
   no support for the agency's actions in this procurement.

   [7] The RFP incorporated FAR sect. 52.215-1(f)(4), which states that the
   agency intends to award without discussions: "The Government intends to
   evaluate proposals and award a contracting without discussions with
   offerors . . . The offeror's initial proposal should contain the offeror's
   best terms from a cost or price and technical standpoint."

   [8] During the course of this protest, the agency has offered several
   post-hoc explanations as to why the use of the September 2003 rates was
   appropriate. In addition to the benchmark and spot-check arguments,
   discussed above, the agency prepared for purposes of this protest several
   analyses of SES's cost data from various points in time under the
   incumbent contract, which the agency argued showed that SES's costs at the
   time of proposal submission in May 2004 were similar to those in September
   2003. See Memorandum of Law at 20-21; Supplemental Memorandum of Law at
   3-5; Hearing Exhs. 5-7. In general, although we consider the entire
   record, including statements and arguments made in response to a protest
   in determining whether an agency's selection decision is supportable, we
   accord greater weight to contemporaneous source selection materials rather
   than judgments made in response to protest contentions. See Boeing
   Sikorsky Aircraft Support, B-277263.2, B-277263.3, Sept. 29, 1997, 97-2
   CPD para. 91 at 15. Here, because we conclude that the agency has neither
   sufficiently linked its post-protest rationales to contemporaneous
   decisions nor demonstrated that such rationales in fact support its
   decisions, we exclude these from our decision.

   [9] The protester additionally contends that the agency should have
   conducted discussions regarding its cost proposal. Where a solicitation
   advises offerors that award may be made on the basis of initial proposals
   without discussions, agencies have broad discretion in deciding whether to
   hold discussions. Modern Techs. Corp., B-278695 et al., Mar. 4, 1998, 98-1
   CPD para. 81 at 14. Although discussions may have addressed doubts or
   concerns regarding SGT's cost proposal, the agency was within its
   discretion not to do so, and the protester's disagreement with that
   decision does not demonstrate that the agency's decision was unreasonable.
   Id.

   [10] SGT notes that it received higher ratings under the initial
   evaluation as compared to the revised evaluation, and protests that the
   agency does not specifically provide a rationale for the lower scores.
   Where an agency conducts a reevaluation of offerors that results in a
   different ratings, we will not question the reasonableness of the revised
   ratings simply because they differ from the initial ratings--particularly
   where, as here, different evaluators were involved. We have long
   recognized that different evaluation panels can reasonably reach different
   conclusions regarding the quality of an offeror's proposal, given the
   subjective judgment necessarily exercised by evaluators. SOS Interpreting,
   Ltd., B-293026.4, B-293026.5, Aug. 25, 2004, 2005 CPD para. 25 at 7. As
   discussed above, we find no basis to challenge the reasonableness of those
   revised evaluations in a manner that prejudices SGT.

   [11] We have reviewed all of the challenges raised by SGT to its technical
   evaluation and conclude that all issues not fully discussed herein also
   lack merit.