TITLE: B-296493.5, Advanced Technology Systems, Inc., September 26, 2006
BNUMBER: B-296493.5
DATE: September 26, 2006
*****************************************************************
B-296493.5, Advanced Technology Systems, Inc., September 26, 2006

   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: Advanced Technology Systems, Inc.

   File: B-296493.5

   Date: September 26, 2006

   William A. Roberts III, Esq., Richard B. O'Keeffe Jr., Esq., and Michael
   S. Caldwell, Esq., Wiley Rein & Fielding, for the protester.

   Jonathan D. Shaffer, Esq., John S. Pachter, Esq., Tamara F. Dunlap, Esq.,
   and Mary Pat Gregory, Esq., Smith Pachter McWhorter PLC, for Pyramid
   Systems Inc., an intervenor.

   R. Rene Dupuy, Esq., and Joseph L. Brinkley, Esq., Department of Housing
   and Urban Development, for the agency.

   Louis A. Chiarella, Esq., and Christine S. Melody, Esq., Office of the
   General Counsel, GAO, participated in the preparation of the decision.

   DIGEST

   1. Protest challenging the evaluation of technical proposals is denied
   where the record establishes that the agency's evaluation was reasonable
   and consistent with the evaluation criteria.

   2. Protest challenging the evaluation of vendors' past performance is
   denied where the record establishes that the agency's evaluation was
   reasonable and consistent with the stated evaluation criteria.

   3. An agency's unreasonable conclusions regarding the awardee's proposed
   staffing levels did not prejudice the protester since these conclusions
   were not a material element in the agency's determination that the
   awardee's higher technically rated, higher-priced quotation represented
   the best value to the government.

   DECISION

   Advanced Technology Systems, Inc. (ATS) protests the award of a blanket
   purchase agreement (BPA) by the Department of Housing and Urban
   Development (HUD) to Pyramid Systems Inc. (PSI) under that firm's General
   Services Administration (GSA) Federal Supply Schedule (FSS) contract,
   pursuant to request for quotations (RFQ) No. R-OPC-22661 for operational
   support and corrective maintenance services in support of the HUD Tenant
   Rental Assistance Certification System (TRACS).[1] ATS argues that the
   agency's evaluation of vendors' quotations was unreasonable and the
   subsequent source selection decision improper.

   We deny the protest.

   BACKGROUND

   TRACS is a computer system developed to help improve HUD's financial
   controls over agency-administered multifamily housing assistance programs,
   by automating manual procedures and incorporating automated controls.
   TRACS represents HUD's official source of data on multifamily housing
   subsidy contracts, tenant rental assistance information, and voucher
   payments. TRACS is designed to collect tenant data, certify tenant
   eligibility for financial assistance under various project-based
   assistance programs, authorize payment, and then process requests for
   payment (vouchers) to project owners, management agents, and other
   third-party contract administrators. In fiscal year 2003, TRACS processed
   approximately 221,000 financial transactions worth approximately $4.7
   billion. As currently configured, TRACS consists of three primary business
   systems and seven significant subsystems that together provide HUD with an
   integrated tenant/voucher/contract data database and corresponding
   financial management system. Agency Report (AR), July 20, 2006, at 3-4;
   Tab 2, HUD Request for Contract Services, at 8.

   The RFQ, issued on August 20, 2004, contemplated the award of a
   fixed-price BPA for a base year with four 1-year options to provide
   various supporting maintenance, development, and project management
   services in furtherance of TRACS.[2] The solicitation included a
   performance work statement (PWS), instructions to vendors on the
   submission of quotations, and evaluation factors for award. The RFQ
   identified five evaluation factors, all of equal importance: technical
   capability; project management; past performance; staffing and resources;
   and price. Award was to be made to the vendor whose written quotation and
   oral presentation were determined to be the "best value" to the
   government, all factors considered. RFQ amend. 1, Revised Evaluation
   Factors, at 2.

   Six vendors, including ATS and PSI, submitted quotations consisting of
   technical and price proposals by the September 16 closing date. HUD then
   held individual oral presentations with vendors on October 12 and 13. An
   agency technical evaluation team (TET) evaluated vendors' technical
   proposals using an adjectival rating scheme: excellent, very good, good,
   fair, and poor. On April 15, 2005, the TET provided the source selection
   authority (SSA) with its final evaluation ratings of vendors' quotations,
   including those of ATS and PSI, which were as follows:

                +----------------------------------------------+
                |        Factor        |    ATS    |    PSI    |
                |----------------------+-----------+-----------|
                |Technical Capability  | Excellent | Excellent |
                |----------------------+-----------+-----------|
                |Project Management    |   Good    | Very Good |
                |----------------------+-----------+-----------|
                |Past Performance      | Very Good | Excellent |
                |----------------------+-----------+-----------|
                |Staffing and Resources| Excellent | Excellent |
                |----------------------+-----------+-----------|
                |Overall               | Very Good | Excellent |
                |----------------------+-----------+-----------|
                |Price[3]              |$12,791,682|$13,008,602|
                +----------------------------------------------+

   AR, Tab 12, TET Report, at 2, 121.

   Based on consideration of vendors' technical ratings, prices, and total
   labor hours proposed, the TET recommended to the SSA that PSI's proposal
   represented the best value to the agency. Id. at 121. On April 28, after
   having reviewed the TET's report and findings, the SSA determined that
   PSI's higher-priced, higher technically rated quotation represented the
   best value to the government. Id., Tab 13, Source Selection Decision, Apr.
   28, 2005, at 1-2.

   On May 23, 2005, ATS filed a protest with our Office asserting that the
   agency's evaluation of offerors' quotations was unreasonable and the
   subsequent source selection decision improper. On July 29, our Office
   conducted a hearing in order to further develop certain of the protest
   issues. On August 1, HUD provided notice that it was taking corrective
   action in response to ATS's protest by reevaluating vendors' quotations
   and making a new source selection decision. Letter from HUD to GAO, Aug.
   1, 2005. Based on the agency's announced corrective action, we dismissed
   ATS's May 23 protest without rendering a decision on the merits. Advanced
   Tech. Sys., Inc., B-296493, B-296493.2, Aug. 3, 2005.

   On May 25, 2006, approximately a year later, HUD completed its
   reevaluation of vendors' technical and price proposals, with the final
   revised ratings for ATS and PSI as follows:

                +----------------------------------------------+
                |        Factor        |    ATS    |    PSI    |
                |----------------------+-----------+-----------|
                |Technical Capability  | Excellent | Excellent |
                |----------------------+-----------+-----------|
                |Project Management    | Very Good | Excellent |
                |----------------------+-----------+-----------|
                |Past Performance      | Very Good | Excellent |
                |----------------------+-----------+-----------|
                |Staffing and Resources| Excellent | Excellent |
                |----------------------+-----------+-----------|
                |Overall               | Very Good | Excellent |
                |----------------------+-----------+-----------|
                |Price                 |$12,791,682|$13,008,602|
                +----------------------------------------------+

   AR, Tab 25, Revised TET Report, at 104-11. After consideration of
   technical merit and price, the TET again recommended to the SSA that PSI's
   quotation represented the best value to the agency. Id. at 115. After
   reviewing the TET's findings and recommendations, the SSA again determined
   that PSI's higher-priced, higher technically rated quotation represented
   the best value to the government. Id., Tab 26, Source Selection Decision,
   May 25, 2006, at 1, 4.

   On June 1, HUD provided ATS with notice of its new award decision; ATS
   requested a debriefing the same day. HUD agreed to provide ATS with a
   brief explanation of the basis of its award decision, but without
   specifying when this would occur.[4] ATS then filed a second protest with
   our Office, challenging the agency's evaluation of vendors' quotations and
   award determination. Protest, June 9, 2006. On June 13, in a conference
   call conducted by our Office with the parties, the agency agreed to
   provide ATS with a brief explanation of its award decision and suspend
   performance of the awarded BPA, and ATS agreed to withdraw its protest.
   ATS subsequently withdrew its June 9 protest. GAO Confirmation of
   Withdrawal, June 15, 2006. On June 15, HUD furnished ATS with a brief
   explanation of its new award decision. On June 19, ATS filed its current
   protest.

   DISCUSSION

   ATS's protest raises numerous challenges to the agency's evaluation of
   vendors' quotations under several technical evaluation factors. ATS also
   contends that the agency reached irrational conclusions regarding PSI's
   proposed level of effort, which were then relied upon in the award
   determination. The protester contends that these alleged errors in the
   evaluation of vendors' quotations resulted in an improper source selection
   decision. Although we do not here specifically address all of ATS's
   arguments about the evaluation of quotations and the resulting source
   selection decision, we have fully considered all of them and find that
   they afford no basis to question the agency's selection decision here.

   Project Management Evaluation

   ATS challenges the agency's evaluation of vendors' technical proposals
   under the project management factor. Specifically, the protester contends
   that PSI's technical proposal failed to include various submissions
   required by the solicitation (e.g., various project plan details, project
   schedule). ATS also alleges that the agency erred in its determination
   that ATS's technical proposal did not propose specific management tools
   for the TRACS project, thereby making HUD's determination that this was a
   discriminator between PSI's and ATS's technical proposals unreasonable.
   Lastly, ATS argues that the agency's evaluation of PSI's technical
   proposal was improper because the awardee failed to provide a sufficiently
   detailed transition-in plan.[5]

   Where, as here, an agency conducts a formal competition under the FSS
   program for the award of a BPA or task order contract, we will review the
   agency's actions to ensure that the evaluation was reasonable and
   consistent with the solicitation and applicable procurement statutes and
   regulations. Worldwide Language Res., Inc., B-297210 et al., Nov. 28,
   2005, 2005 CPD para. 211 at 3; COMARK Fed. Sys., B-278343, B-278343.2,
   Jan. 20, 1998, 98-1 CPD para. 34 at 4-5. In reviewing an agency's
   evaluation, we will not reevaluate vendors' quotations, see Urban-Meridian
   Joint Venture, B-287168, B-287168.2, May 7, 2001, 2001 CPD para. 91 at 2,
   and an offeror's mere disagreement with the agency's evaluation is not
   sufficient to render the evaluation reasonable. Ben-Mar Enters., Inc.,
   B-295781, Apr. 7, 2005, 2005 CPD para. 68 at 7; Birdwell Bros. Painting &
   Refinishing, B-285035, July 5, 2000, 2000 CPD para. 129 at 5.

   ATS first contends that PSI's project management plan failed to include
   various submissions required by the solicitation. Specifically, the
   protester contends that much of the information required to be in each
   vendor's draft project plans and quality control plan (e.g., project
   schedule, program metrics) was completely absent from PSI's technical
   proposal, or so inadequate as to be noncompliant. ATS also alleges that
   PSI's project plan failed to identify which labor categories (i.e., skill
   levels) would perform each PWS task as required by the RFQ. The protester
   argues that PSI's failure to provide this information, which was material
   to the agency's evaluation, rendered PSI's quotation ineligible for award
   or, at the very least, rendered the agency's evaluation unreasonable.

   With regard to the project management factor, the RFQ stated that
   technical proposals were to demonstrate an understanding of work
   requirements, quality control methods, and effective methodologies for
   transition-in and transition-out activities. RFQ amend. 1, Revised
   Evaluation Factors, at 1; Revised Proposal Instructions, at 2. Vendors
   were also required to submit draft project plans for both the base period
   and a sample task order defining, among other things, the resource
   requirements (i.e., skill levels, facilities, computer resources), the
   schedule, the program metrics to be employed throughout the contract
   period, and a Gantt chart[6] reduced to its lowest level, with tasks
   defined in greater narrative detail in the corresponding section of the
   Project Plan.[7] RFQ amend. 1, Revised Proposal Instructions, at 2. The
   RFQ also required the submission of a quality control plan describing the
   methods to be used for identifying and preventing defects in the quality
   of deliverables supplied to the government. Vendors were instructed that
   the quality control plan should include, among other things, the metrics
   and performance measures to be applied to ensure quality service,
   products, and outcomes for maintenance, operational, and development tasks
   specified in the TRACS PWS. Id.

   PSI's technical proposal included draft project plans for both the base
   period and the sample task order, each of which contained a draft project
   schedule/Gantt chart; the technical proposal also contained a specific
   section which addressed the vendor's quality assurance and quality control
   processes (including metrics). AR, Tab 10, PSI's Quotation, Vol. I,
   Technical Proposal. PSI's technical proposal did not set forth the labor
   categories the vendor would employ for each task defined in the PWS and/or
   sample task order (detail required by the RFQ), but did set forth the
   proposed labor categories (and proposed hours by labor category) for the
   contract effort as a whole. The TET rated PSI's technical proposal as
   excellent with regard to project management. Specifically, the evaluators
   found that PSI's draft project plans and quality control plan demonstrated
   the vendor's understanding of the PWS work requirements and quality
   control methods. AR, Tab 25, Revised TET Report, at 57-59.

   In its report, the agency contends that the TET reasonably determined that
   PSI submitted acceptable project plans and quality control plan. HUD
   argues that both PSI's technical proposal and oral presentation addressed
   the metrics that the vendor plans to employ throughout the contract period
   to track progress and ensure the project achieves expected outcomes. The
   fact that ATS submitted a much more detailed schedule and Gantt chart, the
   agency argues, did not make PSI's submissions inadequate since PSI's
   submissions met all the requirements of the RFQ. AR, July 20, 2006, at
   10-12.

   In it comments on the agency report, the protester argues that even
   assuming PSI's abbreviated schedule and Gantt chart were sufficient to
   satisfy the RFQ's requirements, ATS's extensive and highly detailed
   schedule and Gantt chart were advantages of ATS's technical proposal and
   reflected a deeper understanding of the TRACS effort. Similarly, the
   protester asserts that the agency ignored the fact that PSI's generic
   listing of typical metrics was not comparable to ATS's detailed and
   TRACS-specific metrics. Comments, July 31, 2006, at 7-8.

   We find that the TET reasonably determined that PSI submitted an
   acceptable draft project plan, project schedule/Gantt chart, and quality
   control plan; the fact that ATS's proposal contained a more detailed
   schedule and Gantt chart does not show that PSI's submissions were
   inadequate. Further, while ATS contends that PSI's technical proposal
   failed to comply with various RFQ submission requirements, the protester
   has failed to show that any particular aspects of HUD's subsequent
   evaluation were unreasonable based on the information that was contained
   in PSI's technical proposal. For example, ATS argues that PSI's technical
   proposal lacked an adequate schedule and Gantt chart, yet ATS offers no
   basis to conclude that PSI's schedule and Gantt chart demonstrated that
   the awardee did not understand the TRACS work requirements.

   Lastly, the protester argues that its more detailed submissions should
   have been recognized as a strength by the agency because they were
   appreciably different than PSI's submissions and demonstrated a much
   greater understanding of the TRACS effort. In our view, this amounts to
   mere disagreement with the agency's evaluation, which does not render it
   unreasonable. Birdwell Bros. Painting & Refinishing, supra.

   ATS also asserts that the agency's evaluation of its project management
   plan was improper because HUD failed to recognize that ATS's technical
   proposal, like PSI's, included a specific management tool for the TRACS
   project. Specifically, the TET found that one of the strengths in PSI's
   technical proposal was its use of a risk management tool, Rational
   ClearQuest, and, conversely, that ATS's technical proposal did not present
   specific management tools for the TRACS project.[8] ATS contends that it
   did in fact propose a specific management tool for the project--it was
   simply a different management tool than that proposed by PSI but one that
   performed the same functions and had comparable features.

   Within its project management plan, PSI proposed the use of Rational
   ClearQuest as part of its risk management process. AR, Tab 10, PSI's
   Quotation, Vol. I, Technical Proposal, at 2-11. The TET considered
   Rational ClearQuest to be a "feature-rich" project management tool, and
   found this aspect of PSI's proposal to be a strength under the project
   management factor.[9] Id., Tab 25, Revised TET Report, at 59, 107. ATS's
   technical proposal also addressed automated project management tools.
   Specifically, ATS's Quality Control Plan stated that it used a tool called
   PVCS Tracker to manage configuration and change control issues through the
   project life cycle. Id., Tab 8, ATS's Quotation, Vol. I, Technical
   Proposal, App. D, Quality Control Plan, at 25, 28. However, under a
   separate section entitled "project management," ATS also stated that it
   would "use Microsoft Project as its main project planning and management
   tool." Id. at 28. In its oral presentation, ATS then stated that it
   planned to use PVCS Tracker, but had not made a final determination
   regarding its planned project management tool. Id., Tab 27, Declaration of
   TET Chairperson, July 20, 2005, at 5. The TET determined that ATS's
   project management plan met all stated requirements, but did not propose a
   specific management tool for the TRACS project. Id., Tab 25, Revised TET
   Report, at 13-14, 112.

   Subsequent to the filing of ATS's first protest in 2005, the agency
   submitted a statement from the TET chairperson comparing the features of
   Rational ClearQuest to PVCS Tracker and Microsoft Project. The lead agency
   evaluator stated that Rational ClearQuest was considered to be an
   innovative piece of software in the project management area, as it was
   interactive with the client and contractor and provided the ability to
   determine real-time project status (akin to a car's fuel gauge providing
   real-time status). Further, if there were a system issue, Rational
   ClearQuest (in conjunction with PSI's proposed web portal) would
   immediately send out a warning message. By contrast, PVCS Tracker is not
   as robust or innovative as Rational ClearQuest, and Microsoft Project is
   not an interactive, automated project management tool, but rather a static
   tool that does not provide real-time warnings or system status. Id., Tab
   27, Declaration of TET Chairperson, July 20, 2005, at 4-5, 8.

   ATS disputes the agency's determination that Rational ClearQuest is more
   robust than PVCS Tracker. Further, the protester contends that it clearly
   proposed to use PVCS Tracker and the fact that the agency may have had a
   preference for one management tool over another is not sufficient to
   support the agency's evaluation. Comments, July 31, 2006, at 8-9.

   We need not decide whether PVCS Tracker is comparable to Rational
   ClearQuest, as the record reflects that it was anything but clear what
   management tool or tools the protester was proposing to employ for the
   TRACS project. ATS's Quality Control Plan stated in one section that PVCS
   Tracker would be used to manage configuration and change control issues.
   AR, Tab 8, ATS's Quotation, Vol. I, Technical Proposal, App. D, Quality
   Control Plan, at 25. However, in a different section entitled project
   management, ATS stated that it would "use Microsoft Project as its main
   project planning and management tool." Id. at 28. ATS's subsequent oral
   presentation then added to the ambiguity here when the vendor stated that
   it planned to use PVCS Tracker, but also had not made a final
   determination regarding its planned project management tool. We find that,
   faced with such uncertainty, the TET reasonably determined that ATS's
   technical proposal did not present a specific management tool for the
   TRACS project.

   ATS also argues that HUD's preference for PSI-proposed Rational ClearQuest
   as the TRACS management tool is not a discriminator that justified the
   agency paying a higher price. Comments, July 31, 2006, at 9. The protester
   essentially contends that HUD's decision to view this aspect of PSI's
   technical proposal to be of value to the agency, as well as the weight
   given to it, were unreasonable. In our view, ATS has offered little more
   than mere disagreement with the agency's judgment about the value of PSI's
   proposed use of Rational ClearQuest; ATS has not established that this
   judgment was unreasonable. The OMO Group, Inc., B-294328, Oct. 19, 2004,
   2004 CPD para. 212 at 5, 8 (a protester's disagreement with an agency's
   evaluation does not establish that the evaluation was unreasonable).

   ATS also protests that the agency's evaluation of PSI's technical proposal
   under the project management factor was improper because PSI failed to
   provide a sufficiently detailed transition-in plan. The protester points
   to the fact that, in its original evaluation, the TET considered PSI's
   transition-in plan to be a weakness, thereby resulting in PSI receiving an
   evaluation rating of very good. However, while vendors' technical
   proposals remained unchanged, the TET's revised evaluation, without
   explanation, failed to identify a similar weakness in PSI's transition-in
   plan, thereby resulting in PSI receiving a revised project management
   rating of excellent, rather than very good. ATS argues that the agency's
   evaluation of PSI's technical proposal here was unreasonable, and to the
   extent that HUD lowered the standard for PSI here, it should have done the
   same for ATS, which was rated as very good instead of excellent under the
   project management factor.

   As set forth above, the RFQ required vendors' project management plans to
   demonstrate, among other things, an understanding of effective
   methodologies for transition-in and -out activities. RFQ amend. 1, Revised
   Evaluation Factors, at 1. The solicitation also instructed vendors to
   identify the tasks associated with the installation and setup of all
   necessary facilities, software, and firmware, and training tasks to meet
   the needs of new project resources. Additionally, the PWS established that
   instead of HUD's office facilities in Washington, DC, the contractor would
   provide the office space requirements necessary to perform the TRACS
   contract at a location within a 25-mile radius from HUD headquarters. PWS
   at 30.

   Incumbent contractor ATS submitted a transition plan as part of its
   technical proposal. With regard to transition-in, ATS's plan consisted of
   one paragraph and a brief, durational-type schedule; the plan did not
   address the physical relocation of the place of performance. AR, Tab 8,
   ATS's Quotation, Vol., I, Technical Proposal, App. C, Transition Plan. The
   TET in both its initial and revised evaluations found that ATS's
   transition-in plan consisted of generalized statements and lacked
   sufficient supporting details, and constituted a weakness. Id., Tab 12,
   TET Report, at 13; Tab 25, Revised TET Report, at 13. The TET's
   determination that ATS's transition-in plan lacked sufficient detail
   resulted in ATS receiving a very good (and not excellent) rating for
   project management.

   PSI also provided a transition plan as part of its technical proposal.
   Id., Tab 10, PSI's Quotation, Vol. I, Technical Proposal, App. C,
   Transition Plan. In its initial evaluation, the TET found that PSI's
   transition-in plan identified all tasks associated with the installation
   and setup of all necessary facilities and software, and that the sole
   deficiency was that the proposed 10-day transition-in period was
   considered an insufficient and unrealistic timeframe in which to perform
   successfully. Id., Tab 12, TET Report, at 61. The TET's revised evaluation
   did not find a similar weakness in PSI's transition-in plan. See id., Tab
   25, Revised TET Report, at 59-60. The agency explains that the reason that
   PSI's proposed 10-day transition-in period was not considered a weakness
   during the reevaluation of vendors' technical proposals was that the TET
   was aware that PSI actually did successfully transition-in (within
   10 days) in May 2005 after the initial award determination. AR, July 20,
   2006, at 14.

   ATS argues in response that while PSI may have performed some, or even
   most, of the transition-in tasks in May 2005, PSI did not completely
   transition and assume operational control of TRACS until June 2006.
   Moreover, the protester argues that the TET's evaluation of vendors'
   transition plans was still disparate because the agency did not also take
   into account ATS's prior successful physical relocations of TRACS when
   evaluating its transition plan. Comments, July 31, 2006, at 9-10.

   While agency evaluators may consider and rely upon information of which
   they are personally aware in the course of evaluating a vendor's
   quotation, see Del-Jen Int'l Corp., B-297960, May 5, 2006, 2006 CPD para.
   81 at 7, evaluators must treat all vendors equally. See Infrared Tech.
   Corp.--Recon., B-255709.2, Sept. 14, 1995, 95-2 CPD para. 132 at 4-5. We
   need not decide whether the TET's evaluation of vendors' transition plans
   was disparate, however, because the record demonstrates that any error
   here was not prejudicial to ATS.

   As a preliminary matter, we note that had the TET not considered PSI's
   transition-in performance in May 2005 (or, alternatively, if the TET had
   considered ATS's prior physical relocations of TRACS), it is clear from
   the record that the protester would have received at best a rating equal
   to that of PSI. More importantly, in its recommendations to the SSA,
   including a head-to-head comparison of PSI's and ATS's quotations, the TET
   did not focus on the vendors' adjectival ratings, but properly looked
   behind the ratings and considered the underlying qualitative merits that
   distinguished the vendors' technical proposals. With regard to project
   management, the TET did not find ATS's (or PSI's) transition plan to be a
   reason for recommending selection of PSI. Rather, the TET considered the
   key difference between the vendors' project management plans to be PSI's
   use of automated tools (i.e., Rational ClearQuest and a web portal) that
   ATS's technical proposal did not include. AR, Tab 25, Revised TET Report,
   at 112. The SSA also did not find vendors' transition plans to be a
   discriminating feature, determining instead that PSI's proposed automated
   tools were the difference between technical proposals that both
   demonstrated effective project management. Id., Tab 26, Source Selection
   Decision, May 25, 2006, at 2. As vendors' transition plans were not
   considered in the agency's award determination, any disparate evaluation
   here simply did not prejudice the protester.

   Past Performance Evaluation

   ATS protests that HUD's evaluation of vendors' past performance, under
   which PSI received an "excellent" and ATS a "very good" rating, was
   improper. ATS first argues that the agency's evaluation of ATS's past
   performance was unreasonable because HUD improperly determined that one of
   the vendor's three contract references did not involve same or similar
   work in the area of comparable IT architecture and software toolsets,
   thereby resulting in the assessment of a weakness. Further, ATS contends
   that the agency's evaluation of vendors' past performance was disparate,
   insofar as none of PSI's references met all criteria for same or similar
   work in the area of comparable IT architecture and software toolsets. The
   protester argues that had the agency properly evaluated vendors' past
   performance, then ATS and PSI would have been rated equally under this
   evaluation factor.

   Where a solicitation requires the evaluation of vendors' past performance,
   we will only examine the agency's evaluation to ensure that it was both
   reasonable and consistent with the solicitation's evaluation criteria,
   since determining the relative merits of vendors' past performance
   information is primarily a matter within the contracting agency's
   discretion. See Metro Mach. Corp., B-295744, B-295744.2, Apr. 21, 2005,
   2005 CPD para. 112 at 21; Hanley Indus., Inc., B-295318, Feb. 2, 2005,
   2005 CPD para. 20 at 4.

   Here, the RFQ required vendors to submit three references for work
   performed in the past 3 years that was "same or similar" to the effort
   identified in the PWS. RFQ amend. 1, Revised Proposal Instructions, at 4.
   For each contract reference provided, the solicitation required vendors to
   identify, among other things, the specific technical environment (e.g.,
   database type, reporting tools, software development language, Section 508
   tools, configuration management tools, and application service
   software/tool). Id. In turn, the PWS informed vendors of the existing
   TRACS infrastructure (e.g., IBM OS390 as the mainframe operating system;
   Advantage Gen as the application development tool, connectivity tool, and
   enterprise server platform development tool; Endevor as the applications
   configuration management software).[10] PWS, App. D, at 42.

   ATS's technical proposal contained three contract references: (1) ATS's
   incumbent TRACS contract; (2) ATS's Single Family Premiums Collection
   Subsystem (SFPCS) contract with HUD; and (3) the subcontract of proposed
   subcontractor Zen Technology, Inc. with HUD for the Program Accounting
   System and Line of Credit Control Systems (PAS/LOCCS). For each contract
   reference, ATS provided a narrative description of the work performed and
   purported relevance to the TRACS PWS, as well as the reference's technical
   operating environment. AR, Tab 8, ATS's Quotation, Vol. I, Technical
   Proposal. With regard to the Zen contract reference, ATS's technical
   proposal represented that the PAC/LOCCS technical environment utilized a
   Unisys 2200 mainframe operating system, and that the toolsets employed
   included ColdFusion, HTML, and JavaScript. Id. at 3-9.

   The TET found that ATS's TRACS and SFPCS references involved work that was
   the same as or similar to the work requirements here; the TET also
   determined that the demonstrated experience, relevance, and quality of
   ATS's performance on these two references warranted the assessment of
   three strengths. Id., Tab 25, Revised TET Report, at 16-17. However, with
   regard to ATS's third contract reference--proposed subcontractor Zen's
   work on PAS/LOCCS--the TET found that while the referenced work was the
   same as or similar to TRACS with regard to demonstrated experience with
   systems with multiple collections and feeder systems processes, it was not
   the same or similar with regard to comparable IT architecture and software
   toolsets.[11] Id. at 16. The TET considered the inability of ATS's Zen
   contract reference to demonstrate experience in TRACS toolsets and
   architecture to be a weakness. Id.

   ATS does not dispute that its Zen contract reference did not identify the
   specific mainframe operating system and/or software toolsets set forth in
   the PWS. Rather, ATS argues that PAS/LOCCS involved work that was the same
   as or similar to TRACS because they both operate in the same computing
   architecture, namely, the HUD Information Technology System (HITS)
   environment, and share a common web hosting environment, web security
   module, and common network storage system. Protest, June 19, 2006, at 30.
   We disagree. The agency reasonably determined that the PAC/LOCCS technical
   environment, as evidenced by its mainframe operating system and toolsets,
   was not the same as or similar to the TRACS technical environment. The
   fact that TRACS and PAS/LOCCS may share a common web hosting environment
   and network storage system, as the protester contends, simply does not
   mean that the two projects have a comparable IT architecture and software
   toolsets as defined by the solicitation here.

   ATS also argues that the agency evaluated vendors' past performance on a
   disparate basis with respect to whether the vendors' prior contracts
   involved use of TRACS software toolsets.

   It is fundamental that the contracting agency must provide a common basis
   for the preparation and the submission of quotations and not disparately
   evaluate vendors with respect to the same requirements. See Lockheed
   Martin Info. Sys., B-292836 et al., Dec. 18, 2003, 2003 CPD para. 230 at
   11-12; Rockwell Elec. Commerce Corp., B-286201 et al., Dec. 14, 2000, 2001
   CPD para. 65 at 5. Here, PSI's technical proposal contained three past
   performance references, including that of proposed subcontractor SPS under
   a contract with the US Patent & Trademark Office (USPTO) for the Revenue
   and Accounting Management System (RAM) project. AR, Tab 10, PSI's
   Quotation, Vol. I, Technical Proposal, at 3-11. PSI's technical proposal
   also included a description of the RAM project's type of work and
   technical environment, stating that SPS migrated USPTO's legacy system
   from a COBOL/ DMSII application to a distributed client/service Advantage
   Gen application, and SPS developed the RAM system using the information
   engineering methodology and Advantage Gen integrated tool suite. Id. at
   3-13 to 3-15. In its evaluation of PSI's past performance, the TET found
   that all three of PSI's references, including the SPS RAM reference,
   demonstrated comparable IT architecture and software toolsets to those
   identified in the solicitation. Id., Tab 25, Revised TET Report, at 61-62.

   The record reflects, as the protester contends, that PSI's SPS reference
   did not identify many of the specific toolsets for which ATS's Zen
   reference was faulted. However, it is clear that in evaluating vendors'
   past performance, including their use of products similar to the TRACS
   architecture and software toolsets, the agency's primary focus was on
   whether the references demonstrated use of Advantage Gen. As set forth
   above, the PWS identified Advantage Gen as a core toolset of TRACS--it was
   the application development tool, connectivity tool, and enterprise server
   platform development tool. The technical capability and staffing and
   resources evaluation factors also both emphasized the importance of
   Advantage Gen experience. Quite simply, the agency's decision to emphasize
   Advantage Gen use in its evaluation of vendors' past performance was not
   unreasonable or inconsistent with the stated evaluation criteria.

   The record clearly shows that all of PSI's references, including that of
   SPS, demonstrated use of Advantage Gen. By contrast, ATS's Zen reference
   did not demonstrate Advantage Gen use; the Zen reference also did not
   identify use of a mainframe operating system comparable to TRACS. In sum,
   rather than an improperly disparate evaluation of two vendors with a
   common set of underlying facts, the record shows an evaluation based on
   different underlying facts that reasonably resulted in different
   evaluation ratings.

   Technical Capability Evaluation

   ATS protests that HUD's evaluation of vendors' technical proposals under
   the technical capability factor was unreasonable. Specifically, the
   protester alleges that, notwithstanding the fact that ATS and PSI both
   received excellent ratings, the agency's consideration of "new
   technologies and toolsets" in its evaluation of PSI's technical proposal
   constituted an unstated evaluation criterion. Alternatively, ATS contends
   that the TET-identified "new technologies and toolsets" technical
   enhancement was not a distinguishing feature of PSI's technical proposal
   because ATS's technical proposal offered the same feature. Finally, ATS
   argues that HUD placed too much weight upon this discriminator in its
   source selection decision.

   The PWS established that one of the primary objectives of the procurement
   was enhancing the TRACS system to meet multifamily housing program
   objectives. PWS at 1. Specifically, in addition to providing operational
   support and corrective maintenance services on the current system, the PWS
   required the contractor to perform both perfective maintenance (i.e., the
   restructure of system components to expedite processes and functions
   and/or adapt and certify the system software to upgraded/ changing system
   architectural standards) and future development (addressing new functional
   modules, new interfaces, and new data-gathering requirements and
   processing techniques) tasks as identified.[12] Id. at 1, 19-23. The RFQ
   in turn stated, with regard to the technical capability factor, that
   vendors' technical proposals were to demonstrate the technical capability
   to provide expertise in information technology life-cycle support services
   as specified in the PWS for the stated maintenance, operations, and future
   development requirements. RFQ amend. 1, Revised Evaluation Criteria, at
   1-2.

   In its evaluation of ATS's technical proposal under the technical
   capability factor, the TET found that ATS fully met all stated
   requirements; the evaluators also identified three specific strengths and
   no weaknesses, and rated ATS's technical proposal as excellent. AR, Tab
   25, Revised TET Report, at 5-9.

   In the evaluation of PSI's technical proposal under this factor, the TET
   found that PSI also fully met all stated requirements. Again the TET
   identified three specific strengths and no weaknesses, and rated PSI's
   technical proposal as excellent. Id. at 54. One of the strengths that the
   TET found in PSI's technical proposal was the vendor's "demonstrated
   expertise with the migration of older, less efficient architectures
   (mainframe and client-server) and toolsets to emerging, more efficient
   (e.g., web-based, J2EE) technologies that are currently recommended as
   standards in . . . HUD's target architecture." Id. at 110, 55, 107. The
   protester does not challenge the TET's determination that PSI's technical
   proposal demonstrated expertise in new technologies and toolsets and in
   emerging technology migrations. The evaluators also found PSI's expertise
   in new technologies and toolsets to be a discriminator between PSI's and
   ATS's technical proposals. Specifically, the TET stated that "[t]he [PSI]
   team offered expertise in and availability of emerging technologies and
   toolsets that were not offered by ATS. The technologies and toolsets are
   those earmarked for the HUD Enterprise Architecture -- i.e., Java/JHSP,
   J2EE, and Oracle 9i." Id. at 112. The SSA subsequently found this
   technical distinction (i.e., that PSI offered expertise in new
   technologies and toolsets and emerging technology migrations that were not
   offered by ATS) to be one of the stated reasons for his determination that
   PSI's higher technically rated, higher-priced quotation represented the
   best value to the government. Id., Tab 26, Source Selection Decision, May
   25, 2006, at 2.

   We find HUD's consideration of expertise with new technologies and
   toolsets as part of the evaluation of vendors' technical capability here
   was consistent with the stated evaluation criteria. As set forth above,
   the PWS required the contractor to support the transition of the TRACS
   system to the new HITS infrastructure. Similarly, the RFQ established
   that, as part of the technical capability evaluation factor, vendors'
   technical proposals were to demonstrate the technical capability to
   provide expertise in information technology life-cycle support services
   for, among other things, the PWS's future development requirements. RFQ
   amend. 1, Revised Evaluation Factors, at 1-2. In light thereof, the agency
   did not employ an unstated evaluation criterion when finding as a strength
   that PSI's technical proposal demonstrated expertise with new technologies
   and toolsets and emerging technology migrations. See Ridoc Enter., Inc.,
   B-292962.4, July 6, 2004, 2004 CPD para. 169 at 4; Network Eng'g, Inc.,
   B-292996, Jan. 7, 2004, 2004 CPD para. 23 at 3.

   ATS also contends that the use of new technologies and toolsets was not in
   fact a discriminator between the technical proposals of PSI and ATS,
   because ATS also offered the same features.

   ATS's technical proposal, in both its technical capability and staffing
   and resources sections, stated, "We are very familiar with HUD's
   Enterprise Architecture (EA) strategies and desired technical environment.
   The ATS teaming partners have extensive experience in JAVA, J2EE, Oracle
   database, SUN Web Server, and SUN Java Server technologies." AR, Tab 8,
   ATS's Quotation, Vol. I, Technical Proposal, at 1-9, 4-14. While stating
   that it possessed extensive experience in various emerging technologies
   and toolsets, ATS's assertion was not supported by other aspects of its
   technical proposal. Specifically, none of the resumes of ATS's proposed
   key personnel demonstrated strong technical skills in emerging
   technologies and toolsets.[13] Similarly, none of the resumes of ATS's
   proposed key personnel (or any other aspect of the vendor's technical
   proposal) demonstrated expertise with the migration of older architectures
   to the specific emerging technologies that HUD contemplated here.[14] As a
   result, we find the TET's determination that only PSI's technical proposal
   demonstrated expertise with new technologies and toolsets to be
   reasonable.

   ATS argues that the emphasis placed by HUD on PSI's proposed use of new
   technologies and toolsets in the agency's price/technical tradeoff
   determination was unreasonable. The protester argues that, generally,
   PSI's technical proposal did not describe how it would apply these new
   technologies and toolsets to its efforts on the TRACS system.
   Additionally, ATS contends that HUD's reliance on this aspect of PSI's
   technical proposal is unreasonable given that any migration of TRACS to
   emerging technologies would be performed under a separately-negotiated
   future task order (i.e., that PSI did not propose to employ these new
   technologies and toolsets as part of its work effort under the fixed-price
   task order here). We find these allegations without merit.

   As discussed above, the record establishes that the TET reasonably
   determined that PSI's technical proposal demonstrated expertise with new
   technologies and toolsets, and provided detail about how such experience
   would support HUD's future enhancement and development efforts. AR, Tab
   25, Revised TET Report, at 110, 112. Further, while the TRACS future
   development enhancements were to be separately negotiated, and were not
   part of the fixed-price task order for operational support and corrective
   maintenance services, the RFQ established that the agency would consider
   vendors' ability to support future development efforts in its award
   decision here. Quite simply, the fact that PSI's expertise with emerging
   technologies and toolsets would generally not be part of the awardee's
   efforts under the fixed-price task order did not render the agency's
   evaluation inconsistent with the stated evaluation criteria. ATS
   essentially argues that HUD placed too much weight on this aspect of PSI's
   technical proposal. Again, in our view, ATS has offered little more than
   mere disagreement with the agency's judgment about the proper amount of
   weight or emphasis to be placed on the enhancements in PSI's technical
   proposal, which does not render the agency's evaluation unreasonable. The
   OMO Group, Inc., supra, at 8.

   Staffing and Resources Evaluation

   ATS argues that the agency's evaluation of vendors' technical proposals
   with regard to the staffing and resources factor was unreasonable.
   Specifically, ATS contends that HUD erroneously determined that PSI's
   technical proposal was superior to that of ATS with regard to Advantage
   Gen expertise when the facts in the record actually indicated the opposite
   to be true. The protester argues that because HUD chose to elevate the
   importance of vendors' Advantage Gen experience in its source selection
   decision, and was factually mistaken about which vendor here actually had
   greater Advantage Gen expertise, the agency's determination that PSI's
   quotation represented the best value to the government was improper.

   The RFQ required vendors to provide information about their proposed
   staffing and resources regarding skill levels, expertise, and years of
   experience. RFQ amend. 1, Revised Proposal Instructions, at 4-5. The
   solicitation also identified five key positions (project manager, business
   requirements analyst, information technology team lead, database
   administrator, and senior software engineer) for which vendors were to
   submit resumes, demonstrating, among other things, knowledge of
   information engineering/information engineering facility (IE/IEF) CASE
   Tools such as Advantage Gen for analysis. Id. at 5-6. The RFQ also stated,
   as part of the staffing and resources evaluation factor, that vendors'
   technical proposals were to demonstrate that the skill levels, expertise,
   and experience of proposed key personnel were adequate to perform the work
   required by the PWS. Id., Revised Evaluation Factors, at 2.

   ATS's technical proposal included resumes for its five proposed key
   personnel. Each resume included a chart that stated, "Demonstrated
   knowledge of IE/IEF CASE Tools such as Advantage Gen for analysis," and
   had a corresponding number of years experience. For example, the resume of
   ATS's project manager represented that the "Demonstrated knowledge of
   IE/IEF CASE Tools such as Advantage Gen for analysis" was 11 years'
   experience.[15] AR, Tab 8, ATS's Quotation, Vol. 1, Technical Proposal, at
   4-15.

   The TET rated both ATS's and PSI's quotations as excellent under the
   staffing and resources evaluation factor; each vendor was found to have
   five strengths and no weaknesses. In its recommendation to the SSA, the
   TET also stated, "With regard to Staffing and Resources, [PSI] proposed
   key staffs . . . have stronger credentials than ATS's proposed key staff,
   even though both received an rating of Excellent. [PSI]'s proposed key
   staff have significant expertise and experience in Advantage:Gen which is
   one of the core toolsets supporting the mainframe architecture for TRACS."
   Id., Tab 25, Revised TET Report, at 112. The SSA agreed with the TET that
   while ATS and PSI both offered excellent support personnel, the resumes
   for PSI's proposed key staff were stronger in the area of Advantage Gen
   expertise. Id., Tab 26, Source Selection Decision, May 25, 2006, at 2.

   ATS contends that, as reflected in the resumes of its key personnel, ATS
   has an average of 11 years of Advantage Gen expertise, while the resumes
   of PSI's key personnel evidenced only an average of 7.67 years of
   Advantage Gen expertise.[16] The agency does not challenge ATS's
   calculations. Rather, the agency argues that Advantage Gen is a commonly
   used software technology, that Advantage Gen expertise thus is not limited
   to incumbent ATS employees who have worked on TRACS, and that, based upon
   the expertise as demonstrated in the vendor's resumes, the TET's
   determination that PSI's proposed key personnel were highly experienced
   with Advantage Gen was reasonable. AR, July 20, 2006, at 17.

   While the resumes of ATS's proposed key personnel set forth each
   individual's knowledge of IE/IEF CASE Tools--such as Advantage
   Gen--generally, another section of ATS's technical proposal set forth the
   vendor's experience with Advantage Gen specifically, and indicated an
   average of 6 years' experience. Within its technical capability plan, ATS
   set forth the total combined experience with TRACS and related interface
   systems of its five proposed key personnel. AR, Tab 8, ATS's Quotation,
   Vol. I, Technical Proposal, at 1-7. Additionally, ATS provided a chart
   setting forth its combined experience with various individual TRACS
   technologies. Here ATS indicated that its team possessed 30 years'
   combined experience with Advantage Gen, or an average of 6 years'
   experience for each of its five proposed key personnel.[17] Id. By
   contrast, as set forth above, ATS argues that PSI's proposed key personnel
   possessed an average of 7.67 years of Advantage Gen experience. Therefore,
   even assuming that ATS's calculations of PSI's expertise are valid, the
   protester has failed to demonstrate that it possessed greater Advantage
   Gen experience here or that the agency's conclusions regarding vendors'
   relative experience were unreasonable.

   PSI Staffing Level Evaluation

   Finally, ATS argues that HUD's award determination was based on mistaken
   conclusions regarding PSI's proposed level of effort. The protester
   contends that while each quotation contained information regarding the
   vendor's proposed labor categories and labor hours, the information was
   not sufficient to provide the agency with the basis for any meaningful
   conclusions regarding the vendor's understanding of the PWS work
   requirements. Nevertheless, ATS argues, the agency concluded that PSI's
   proposed labor hours indicated the vendor's significant understanding of
   the TRACS requirements, and relied on this irrational determination when
   concluding that PSI's higher-priced, higher technically rated quotation
   represented the best value to the government.

   As set forth above, the RFQ included a PWS which contained a narrative
   description of all operational support and corrective maintenance service
   requirements for the TRACS project. Additionally, the PWS provided vendors
   with HUD's historic, level-of-effort information about each task.[18] For
   example, with regard to Database Administration, the PWS stated that the
   task occurred 250 times per year at an average of 4 hours per
   occurrence.[19] PWS at 5-6. Nonetheless, the RFQ contemplated the award of
   a fixed-price BPA, and the agency acknowledged that what it was procuring
   here was not a specified level of effort but a vendor's contractual
   commitment to successfully perform all TRACS PWS requirements (regardless
   of the actual effort required) for a fixed price. Hearing Transcript at
   16-17.

   The RFQ contained several instructions regarding the staffing/level of
   effort information that vendors were to submit. Specifically, the
   solicitation stated that vendors' price proposals were to identify their
   proposed FSS-contract labor categories, corresponding labor rates
   (including any discounts), and total number of hours proposed by labor
   category for each of the two contract line items (i.e., all operational
   support tasks, all corrective maintenance tasks).[20] RFQ amend. 1,
   Revised Proposal Instructions, at 9. Also, the staffing and resources
   evaluation factor required vendors to identify those labor categories that
   would be assigned to perform each of the tasks defined in the PWS and
   sample task order. RFQ amend. 1, Revised Evaluation Factors, at 2-3.
   Vendors' draft project plans (under the project management factor) were
   also to include, among other things, the resources (i.e., skill levels,
   facilities, computer resources) the vendors planned to employ. Id.,
   Revised Proposal Instructions, at 2.

   PSI's price proposal identified its proposed labor categories, labor
   rates, and total labor hours for each contract line item, AR, Tab 10,
   PSI's Quotation, Vol. II, Price Proposal, at 6-15; the vendor's technical
   proposal did not identify labor categories by PWS task as the RFQ
   required. See id., Vol. 1, Technical Proposal, at 4-1. However, neither
   PSI's nor ATS's quotation identified the vendor's total number of hours by
   PWS task, the number of hours by labor category by PWS task, or the price
   by PWS task, as such information was not required by the solicitation.

   After evaluating quotations under the stated evaluation factors, the TET
   prepared its conclusions regarding vendors' relative technical merit. The
   agency evaluators found that PSI was the highest technically rated vendor,
   based on the determination that PSI had excellent past performance and
   that all of PSI's proposed key staff brought strengths--ranging from
   in-depth technical expertise with TRACS software and toolsets, to
   demonstrated expertise with the migration of older, less efficient
   architectures to emerging, more efficient technologies--that would improve
   TRACS' reliability and performance. The TET also noted that PSI's
   technical proposal had clearly and concisely explained the vendor's
   strategy and approach for the phased migration of TRACS to the
   architectures proposed by the HUD enterprise architecture office. Further,
   PSI had proposed many "value-added" features, such as the automated
   project management tool Rational ClearQuest and a web portal, that were
   currently not available to the TRACS project. The TET also found that
   PSI's draft project plan for the sample task order was comprehensive and
   reasonable, and provided evidence of a strong development methodology.
   Id., Tab 25, Revised TET Report, at 110. Also as part of its conclusion
   here the TET stated, "Although the PSI Team's proposed price is not the
   lowest bid, they offered the highest number of hours of all bidders. This
   indicates a significant understanding of the amount of time and effort
   that is required to successfully support the TRACS project." Id.

   The TET then prepared an overall best value analysis of vendors'
   quotations, concluding that PSI's quotation offered the best value to HUD.
   The TET based this determination on the overall quality of PSI's
   quotation, especially under the technical, project management, and key
   personnel factors ("They provide HUD a complete range of technical skills
   and number of key personnel with several years experience designing,
   implementing, enhancing, and managing systems similar to the TRACS
   system"). Id. at 111. The TET also stated, "Although [PSI's] price
   proposal is the second highest, the proposal is comprehensive in terms of
   providing a more than adequate [level of effort] and plan for operations,
   maintenance, and modernization for the TRACS project." Id. The TET then
   conducted a head-to-head comparison of the quotations of PSI and ATS, in
   which PSI's technical advantages in technical capability, project
   management, and key staff were discussed.[21] Id. at 112.

   In the subsequent source selection decision, the SSA concluded that PSI's
   proposal represented the best technical solution and demonstrated numerous
   strengths. Specifically, the SSA found that PSI had distinguished itself
   in its ability to operate, maintain, develop, and manage the TRACS
   application as well as its strong past performance, particularly in
   projects similar to the TRACS project. The SSA also stated:

   While PSI's projected costs were higher than . . . [those] of the other
   vendors, it is clearly worth it to the Government to pay such additional
   costs in order to obtain the technical enhancements that it offers. PSI's
   strengths in terms of new technologies and toolsets and advanced project
   management tools are benefits to HUD that offset the additional cost.

   Id., Tab 26, Source Selection Decision, May 25, 2006, at 1. The SSA then
   conducted a head-to-head comparison of PSI's and ATS's quotations. Here
   the SSA identified the various strengths in technical capability, project
   management, past performance, and staffing and resources that the SSA
   believed justified the $216,920 price premium associated with PSI's
   quotation. Id. at 2. In a concluding paragraph the SSA then stated:

   [PSI] clearly prepared the best technical approach, and was . . . rated
   "Excellent" overall. The company proposed a staffing mix of time and
   resources and technical expertise in emerging technology toolsets that
   will best benefit the Government. The PSI Team was able to demonstrate a
   low risk of failure with a high probability for success over the next five
   years. Therefore, it is my determination that [PSI], based on technical
   merit and price, represents the best value to the Government and should be
   awarded the contract.

   Id. at 4.

   In our view, the staffing information contained in vendors' quotations was
   simply not sufficient from which to formulate meaningful conclusions here.
   As set forth above, the RFQ required vendors to identify labor categories,
   labor rates, and total number of hours proposed by labor category for each
   of the two contract line items, as well as labor categories by PWS task.
   However, the solicitation did not require, and vendors did not provide,
   information about the total number of hours by PWS task, the number of
   hours by labor category by PWS task, or the price by PWS task.[22] Thus,
   HUD's ability to analyze a vendor's planned staffing mix (i.e., the
   quality and quantity of the labor proposed) could only be done at the
   overall contract line item, and not the specific PWS task, level.

   Notwithstanding the lack of information about vendors' staffing plans, the
   TET reached various conclusions about PSI's proposed staffing levels. For
   example, the TET concluded that the quantity of PSI's proposed staffing
   ("they offered the highest number of hours of all the bidders") indicated
   a significant understanding of the effort required to successfully perform
   the TRACS work requirements, without also taking into account the quality
   of the staffing that the vendor had proposed. The fact that a vendor
   proposes a high number of hours does not indicate that the vendor
   understands the work, since the vendor may have also proposed
   under-qualified, or unqualified, labor categories for the work
   requirements. Similarly, a vendor who proposes a lower number of hours,
   but of higher quality labor, may have an equal or better understanding of
   a solicitation's work requirements.[23] Additionally, while the TET knew
   what labor categories PSI believed appropriate for each contract line
   item, PSI's quotation did not identify labor categories or estimated hours
   by PWS task. The TET's conclusions that PSI's level of effort and/or
   staffing mix indicated significant understanding of the TRACS requirements
   thus were unsupported by the information the agency had before it.

   While the record reflects that the TET's conclusions regarding PSI's
   staffing levels were unsupported, such conclusions were not material to
   the agency's source selection determination. See ESCO, Inc., B-225565,
   Apr. 29, 1987, 87-1 CPD para. 450 at 6; see also Allied Tech. Group, Inc.,
   B-271302, B-271302.2, July 4, 1996, 96-2 CPD para. 4 at 4 n.3. As set
   forth above, the TET's conclusions that PSI's quotation was both the
   highest technically rated and overall best value were based on the
   technical enhancements and advantages that the vendor was found to offer.
   Specifically, the TET repeatedly found it was PSI's strengths in the
   technical, project management, and key personnel factors (i.e., "they
   provide HUD a complete range of technical skills and number of key
   personnel with several years experience designing, implementing,
   enhancing, and managing systems similar to the TRACS system") that offset
   PSI's higher price. The TET's head-to-head comparison of PSI's and ATS's
   quotations also focused on PSI's advantages in technical capability,
   project management, and key staff.

   More importantly, the SSA's determinations that PSI's quotation
   represented the best technical solution and overall best value to the
   agency were based solely on the vendor's technical enhancements (e.g.,
   expertise with new technologies and toolsets, advanced project management
   tools) and not staffing levels. In this regard, when conducting a
   head-to-head comparison of ATS's and PSI's quotations, the SSA considered
   only PSI's advantages under the technical capability, project management,
   past performance, and staffing and resources factors as the rationale for
   what justified PSI's price premium; there is no mention of vendors'
   staffing levels in the SSA's analysis here.[24] Id. at 2. It is quite
   clear that the SSA's best value tradeoff focused only on PSI's technical
   advantages as compared to ATS's lower price, and that PSI's staffing was
   not a material aspect of the agency's decision here. In sum, in our view
   the record reflects that the conclusions reached by the agency regarding
   PSI's proposed level of effort were simply not material to the agency's
   source selection decision and thus do not provide a basis to question the
   agency's decision that PSI's quotation represented the best value to the
   government.

   The protest is denied.

   Gary L. Kepplinger
   General Counsel

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

   [1] While our decision refers to the "award" of a BPA, which is the
   terminology used by the parties here, the Federal Acquisition Regulation
   (FAR) in fact refers to the "establishment" of a BPA against an FSS
   contract. FAR sections 8.403(a)(2), 8.404(b).

   [2] The solicitation informed vendors that the awarded BPA could also
   result in the issuance of fixed-price, level-of-effort task orders for
   various analysis requirements in support of future enhancement and
   development efforts. RFQ at 5, Questions and Responses, at 5. A
   fixed-price, level-of-effort contract is suitable for the investigation or
   study in a specific research and development area, and payment is based on
   the effort expended rather than on the results achieved. FAR sect.
   16.207-2.

   [3] The evaluated price consisted of vendors' proposed prices for the base
   year and option year task orders, as well as prices for a sample task
   order. AR, Tab 12, TET Report, at 112.

   [4] When an unsuccessful vendor requests information on the award of an
   order or BPA under the FSS program that was based on factors other than
   price alone, the ordering activity is to provide a brief explanation of
   the basis for its award decision. FAR sect. 8.405.2(d).

   [5] ATS's also argues that HUD's evaluation of vendors' technical
   proposals under the project management factor was flawed because the
   agency did not properly evaluate (i.e., "closely scrutinize") whether
   vendors' proposed labor hours and categories demonstrated the ability to
   perform the PWS tasks, but nevertheless reached conclusions regarding
   PSI's proposed level of effort which were relied on in the award
   determination. Protest, June 19, 2006, at 20-23. As this protest issue
   spans multiple evaluation factors, our review is set forth separately
   below.

   [6] A Gantt chart is a horizontal bar chart developed as a production
   control tool by Henry L. Gantt. Frequently used in project management, a
   Gantt chart provides a graphical illustration of a schedule that helps
   plan, coordinate, and track individual tasks and subtasks within a
   project. AR, July 20, 2006, at 11 n.6.

   [7] The staffing and resources evaluation factor also stated that vendors
   were to identify those labor categories that would be assigned to perform
   each of the tasks defined in the PWS and sample task order. RFQ amend. 1,
   Revised Evaluation Factors, at 2-3.

   [8] Rational ClearQuest is an IBM-created project management software
   tool. It automates and tracks the tasks in the software development and
   maintenance process; it also identifies risks, timelines, and project
   status throughout the project life cycle. As a project management tool,
   Rational ClearQuest assists the project manager in limiting risk. AR, Tab
   27, Declaration of TET Chairperson, July 20, 2005, at 4.

   [9] The TET stated, "The PSI Team uses a risk management tool `Rational
   ClearQuest' for managing risk on its larger projects. Rational ClearQuest
   is customized for each project. . . . Thus, the risk management process
   can begin immediately upon project start-up. The PSI Team's baseline risk
   management plan is reviewed by the project/ task manager and adapted to
   the specific task at its inception." AR, Tab 25, Revised TET Report, at
   59.

   [10] The solicitation's instructions to vendors also set forth a complete
   listing of TRACS toolsets and architecture. RFQ amend. 1, Revised Proposal
   Instructions, at 1.

   [11] The TET stated, "[w]hile significant experience is demonstrated with
   mainframe and Internet tools at HUD, some of the primary toolsets used on
   the TRACS project are not represented. Specifically, the IBM mainframe
   operating system software (MVS/390), DB2, BMC, CICS and Endevor are not
   mentioned, nor are Advantage:Gen or EASEL." Id. at 16.

   [12] The PWS also detailed the specific future enhancement and development
   efforts that were to be provided in support of TRACS, stating, "The
   contractor shall support [the] transition to the new HUD Information
   Technology Services (HITS) infrastructure. The contractor shall perform
   analysis, testing, and make the necessary changes to TRACS to work
   properly on the new HITS hardware/software/ teleprocessing
   infrastructure." PWS at 2, 24.

   [13] We note that the resume of ATS's proposed business requirements
   analyst referenced Oracle among the many listed skills, but without
   identifying what level of experience existed. AR, Tab 8, ATS's Quotation,
   Vol. I, Technical Proposal, at 4-18. Likewise, the resumes of ATS's
   proposed information technology team lead and senior software engineer
   referenced Java among the listed skills, but again without identifying any
   level of experience. Id. at 4-21, 4-27. The fact that ATS's GSA contract
   mentions Oracle databases also does not demonstrate actual expertise. Id.,
   Vol. III, Price Proposal, GSA Contract, at 7.

   [14] ATS also alleges that the contracting officer here was fully aware of
   ATS's experience with the migration of the HUD Real Estate Management
   System (REMS) to the agency's enterprise architecture, and that such
   information was simply "too close at hand" for the agency to ignore in the
   evaluation of ATS's technical proposal here. Protest, June 19, 2006, at
   37. In certain circumstances we have determined that evaluators are
   prohibited from ignoring information of which they are personally aware,
   even if that information is not within the offeror's proposal. See GTS
   Duratek, Inc., B-280511.2, B-280511.3, Oct. 19, 1998, 98-2 CPD para. 130
   at 14; International Bus. Sys., Inc., B-275554, Mar. 3, 1997, 97-1 CPD
   para. 114 at 5. Even assuming it is appropriate to apply this principle
   here, ATS has failed to establish that its work on REMS involved the same
   new technologies and toolsets that HUD credited to PSI here.

   [15] Similar charts existed as part of the resumes of ATS's other key
   personnel, indicating experience of 7, 12, 12, and 13 years, respectively.

   [16] In some instances the resumes of PSI's proposed key personnel did not
   explicitly set forth years of Advantage Gen expertise and, thus, the
   protester's figures are the result of attempting to "glean" this
   information from the professional experience narratives included within
   the resumes. Protest, June 19, 2006, at 39-40. In other instances ATS did
   not accept the "bare assertions" contained within the resumes of PSI's
   proposed key personnel, and instead substituted the average amount of
   Advantage Gen experience, computed from those PSI proposed employees whose
   degree of expertise ATS believed it could reliably estimate. Id. at 40.

   [17] For purposes of the computation here we assume that ATS's use of the
   term "ATS Team" refers to only its five proposed key personnel and not all
   proposed TRACS team members (in which case the average Advantage Gen
   expertise would be less). ATS's oral presentation also represented that
   its team possessed a combined total of 30 years of Advantage Gen
   experience. AR, Tab 9, ATS's Oral Presentation, at 37.

   [18] The prior TRACS contract had been performed as a time-and-materials
   effort.

   [19] The PWS did not, however, set forth the number of hours by labor
   category for each PWS task.

   [20] The agency also informed vendors that their price proposals would be
   "closely scrutinized" to evaluate the methods used for calculating costs
   and the reasonableness with which those costs were assigned to PWS
   requirements. RFQ, Questions and Responses, at 11.

   [21] The TET also commented:

   In light of reduced budgets for existing and new projects, the Government
   must consider what results will be achieved based on the level of effort
   required for future initiatives. Future task orders will be issued either
   Firm Fixed-Price or Fixed-Price [level of effort] . . . . Assuming the
   labor rates remain the same for both maintenance and development efforts,
   the Government will receive a higher rate of return with [PSI] because of
   the lower average hourly rate that will provide a higher probability of
   successful completion of the required tasks.

   Id. at 112.

   [22] To the extent that ATS argues that HUD did not "closely scrutinize"
   vendors' quotations because the solicitation failed to require vendors to
   submit sufficient staffing information necessary to perform the requisite
   close scrutiny, we find that ATS essentially argues that the solicitation
   was defective, in which case its protest of such is untimely. See 4 C.F.R.
   sect. 21.2(a)(1) (2006).

   [23] Similarly, the TET's conclusion that PSI's lower average labor rate
   will be of value to the agency for future, fixed-priced, level-of-effort
   task orders is also based on mistaken assumptions. First, the TET's
   determination of average hourly labor rates was based on vendors' total
   prices and total proposed hours (as opposed to the average price for one
   hour of each labor category proposed). AR, Tab 25, Revised TET Report, at
   99. Since vendors proposed different numbers of hours for the various
   labor categories, this method of comparison does not permit the agency to
   validly ascertain whether PSI was actually less expensive than ATS for any
   common labor category. The TET's analysis also implicitly assumes that for
   future fixed-priced, level-of-effort task orders, vendors would utilize
   common labor categories and staffing levels--only then would the lower
   average hourly rate arguably be determinative of price. Further, the TET
   offers no explanation for its assertion that a lower average hourly rate
   will provide a higher probability of success.

   [24] In fact, the SSA's analysis contains only one phrase that even
   touches on the issue, a reference in the concluding paragraph to PSI's
   "staffing mix of time and resources and technical expertise." AR, Tab 26,
   Source Selection Decision, May 25, 2006, at 4. We see no basis to read
   this oblique reference as incorporating the TET's conclusions regarding
   PSI's staffing levels.