TITLE: B-297381.5; B-297381.6, SI International, SEIT, Inc., July 19, 2006
BNUMBER: B-297381.5; B-297381.6
DATE: July 19, 2006
*******************************************************************
B-297381.5; B-297381.6, SI International, SEIT, Inc., July 19, 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: SI International, SEIT, Inc.

   File: B-297381.5; B-297381.6

   Date: July 19, 2006

   Richard J. Vacura, Esq., Michael E. Anderson, Esq., Jonathan T. Linde,
   Esq., and Tim A. O'Brien, Esq., Morrison & Foerster LLP, for the
   protester.

   Richard P. Rector, Esq., David E. Fletcher, Esq., Eliza P. Nagle, Esq.,
   Eric M. O'Neill, Esq., and Nancy O. Dix, Esq., DLA Piper Rudnick Gray Cary
   US LLP, for Datatrac Information Services, Inc., an intervenor.

   Mark A. Allen, Esq., and Joel R. Alvarey, Esq., Department of Homeland
   Security, for the agency.

   Sharon L. Larkin, Esq., and James A. Spangenberg, Esq., Office of the
   General Counsel, GAO, participated in the preparation of the decision.

   DIGEST

   1. In a competition conducted among vendors holding General Services
   Administration (GSA) Federal Supply Schedule (FSS) contracts, agency
   reasonably found that both the awardee and protester met the
   solicitation's requirements for an "emergency plan," where both plans
   adequately addressed the objectives and requirements of the solicitation
   and both vendors included the price for the plan in their quotations.

   2. Discussions that were part of the agency's implementation of limited
   corrective action were not unfair, where the issues raised during
   discussions reasonably addressed the procurement flaws identified by GAO
   in a prior protest, and the agency raised with the vendors areas of
   weakness in their quotations; agency was not required to raise with the
   protester features that were identified as strengths, even where the
   agency considered them only to be of "limited value."

   3. Source selection decision was reasonable, where agency selected the
   lower priced quotation between two vendors whose quotations were
   reasonably found to be technically equal.

   DECISION

   SI International, SEIT, Inc. (SI) protests the award of a blanket purchase
   agreement (BPA) and "first call" to Datatrac Information Services, Inc.
   (Datatrac), issued by the Department of Homeland Security, United States
   Citizenship & Immigration Services (USCIS), under request for quotations
   (RFQ) No. HSSCCG-05-Q-0020 for records digitization services.

   We deny the protest.

   BACKGROUND

   Currently, over 84 million "Alien Files" (A-files) are maintained and
   distributed among the National Record Center and various USCIS facilities.
   Performance Work Statement (PWS) para. 1. When USCIS personnel need to
   locate information from an A-file not located in their office, they query
   the National File Tracking System (NFTS) or other tracking and indexing
   system to locate the file and request personnel at that location to
   physically mail either the A-file or a copy of it. As part of an overall
   estimated $150 million digitization effort to significantly reduce
   paper-based processes at USCIS, the USCIS has a need for a contractor to
   provide electronic access to all A-file data. RFQ sections 1, 2.4; PWS
   para. 1.

   The RFQ sought to award a BPA to a contractor to provide a variety of
   records management services as part of this digitization effort. Work
   performed through the BPA will be ordered as "calls" on either a
   fixed-price or time-and-materials basis, depending on the nature of the
   call. RFQ sect. 2.7. The "first call," which is at issue in this protest,
   was issued on a fixed-price basis and included the following records
   management services: (1) maintain a "contractor owned-contractor operated"
   facility in accordance with National Archives and Records Administration
   standards to process and scan A-files, (2) arrange a delivery system for
   the A-files to be transferred between facilities, (3) scan and index paper
   A-files and related documents into a digitized format, and (4) provide and
   maintain a temporary file storage solution of digitized files in a format
   approved by the government and accessible to USCIS customers. PWS paras.
   1, 12.2. The A-files to be processed for the first call included alien
   registration files, "I-485" forms, certificate files, master index files,
   "flex-o-line" files, and historical files, with the understanding that
   this list of file types would be expanded in later calls as processes and
   technologies became more fully defined. Id. para. 1. The agency explains
   that the processing of these files, while necessary, is not "mission
   critical." SI Hearing Transcript (Tr.) at 226, 422, 591.[1]

   Competition for the BPA and first call was limited to only those vendors
   that held contracts under General Services Administration (GSA) Federal
   Supply Schedule (FSS) Group 36 for Office Imaging and Document Solutions.
   RFQ sect. 2. The RFQ stated that the duration of the BPA would be 5 years
   or the expiration of the vendor's FSS contract, whichever comes first. Id.
   sect. 2.6. The solicitation provided that award of the BPA and first call
   would be made on a "best value" basis, considering technical and price
   factors. The technical factors--BPA management approach, resumes of key
   personnel, performance approach for the initial call, and past
   performance--were equally weighted and combined were "significantly more
   important than" the price factor. Id. sect. 8.4. The RFQ also contemplated
   that evaluators could give "added weight" in the technical evaluation
   based on "Special Preference Factors," which included small business and
   HUBZone utilization, and having an approach that would "reach full
   operational status within 60 days of award." Id. sect. 8.5.5. The RFQ
   stated that pricing for the call would be evaluated for "realism and
   reasonableness." Id. sect. 8.6.3.

   The RFQ required each vendor, in its quotation, to provide a Project
   Management Plan (PMP) with the initial call that "shall include all
   requirements described in paragraph 4.2.1 of the initial call PWS." Id.
   sect. 7.8.1. Paragraph 4.2.1 of the PWS identified 12 different plans that
   were to make up the PMP, one of which was an emergency plan,[2] and
   referred vendors to "Attachment A.2" of the PWS for "detailed language of
   how the Contractor will address" the 12 plans in the PMP. With regard to
   the emergency plan, the evaluation of which is challenged here, Attachment
   A.2 states:

   5.0 EMERGENCY PLAN

   The Contractor shall submit an Emergency Plan that shall meet the
   following Objectives and Requirements.

     5.1 Objectives:

       * Establish contingency plans to ensure continuity of every operation
         during special and emergency situations such as fire, accidents,
         civil disturbances, national emergency, systems failure, labor
         walk-out, or other circumstances which could jeopardize the
         operations of USCIS Records Management Activities
       * Coordinate Contractor plans with those of the USCIS ensuring
         appropriate linkages between the plans

     5.2. Requirements:

       * Provide for the distribution of the Plan
       * Provide for the identification of key Contractor personnel in the
         event of an emergency
       * provide for orientation and training of the Contractor's employees
         regarding their responsibilities in the event the Emergency Plan is
         activated
       * Appropriate cross-references to related plans

     5.3 Records Management Operations

     The Contractor shall formalize any changes in the plan in accordance
     with paragraph 4.2.1 of the PWS [which required approval of Contracting
     Officer's Technical Representative].

   PWS, attach. A.2.

   In addition to the PMP, the PWS also required the contractor to assist the
   agency in developing a "Contingency Plan" relating to facility systems in
   accordance with a Systems Development Live Cycle (SDLC) Manual.[3] This
   contingency plan "describes the steps to be taken to ensure that an
   automated system or facility can be recovered from service disruptions in
   the event of emergencies and/or disasters." PWS para. 7.9.2. The
   contingency plan was to be developed post-award through the joint efforts
   of the agency and selected vendor, who would meet after award of the BPA
   and together evaluate a number of "project risk factors," such as
   development time and costs, mission criticality, system security, system
   performance, business processes, and development schedule, in order to
   best determine the plan that should be put in place to handle service
   disruptions. See Agency Report, Tab 12, SDLC Manual, at 32; Tr. at 722-25,
   728-35.

   In August 2005, SI and Datatrac responded to the RFQ with quotations of
   $14,647,920 and $13,785,450, respectively.[4] Out of a maximum possible
   technical score of 22 points, SI's quotation received a score of 22 and
   Datatrac's quotation received a score of 21. The 1-point difference was
   based on a weakness found under the performance approach factor because
   Datatrac's quotation indicated that the agency was to manifest A-files and
   place barcode shipping labels on the boxes of A-files to assist the firm
   with tracking the documents. The agency determined that since it did not
   have the processes or personnel to support this requirement, "the total
   cost to the Government to implement the Datatrac manifesting approach
   would be $772,650 plus about a six month delay in modifying the IT
   [Information Technology] systems to accommodate the Datatrac approach."
   Agency Report (AR), Tab 3, Best Value Analysis Report, at 1; Datatrac
   Protest Record, Tab P, Award Determination, at 1-2. After adding this
   additional amount to Datatrac's quoted price, the agency concluded that
   the weakness in Datatrac's quotation was such that award to SI based on
   its higher-rated quotation was worth the relatively small difference in
   adjusted price between quotations. Datatrac Protest Record, Tab P, Award
   Determination, at 3. USCIS awarded the BPA and first call to SI in
   September, and Datatrac protested, alleging numerous evaluation errors and
   contending that the discussions were inadequate.

   At the conclusion of a 2-day hearing on that protest, the GAO attorney
   handling the case conducted an "outcome prediction" alternative dispute
   resolution (ADR) conference and identified a number of issues as
   problematic. The first was that the agency may have conducted discussions
   unfairly by not raising with Datatrac the weakness arising from the firm's
   manifesting approach, while allowing SI to further revise its quotation
   regarding key personnel after the discussion period closed. Furthermore,
   the agency could not support its assessment that the weakness concerning
   manifesting translated to $772,650 in additional costs plus a 6-month
   delay to the government. In addition, it was not clear from the record
   whether SI had priced its emergency plan, as required under the RFQ. The
   GAO attorney suggested that the agency "reopen discussions to treat the
   vendors fairly" and "perform a new price analysis and cost technical
   tradeoff . . . in the two areas, the emergency plan and the evaluation of
   the manifesting costs." Datatrac Hearing Tr. at 597. The agency agreed to
   take corrective action, and our Office dismissed the protest. Thereafter,
   at SI's request, the agency disclosed vendors' proposed prices to the
   competitors. AR, Tab 5, Letter from USCIS to SI (Dec. 12, 2005).

   On December 16, the agency notified vendors of its intent to take limited
   corrective action. Although it did not identify the topics for discussion,
   the agency advised the vendors that

     [a]ny changes in the Price and Technical quote must be linked to
     discussion questions. No changes can be made to the Price and Technical
     Quote that are not linked to Discussion questions asked by the
     Government. Revisions to the Price and Technical Quote not linked to the
     Government's Discussion questions with a vendor will not be accepted,
     considered, or evaluated.

   AR, Tab 1, Letters from USCIS to SI and Datatrac (Dec. 16, 2005).

   On December 22, the agency issued letters to the three vendors that
   remained in the competitive range. All three were provided their "Original
   Request for Clarifications" and given the opportunity to further revise
   their responses to those requests. As the agency stated:

     If after your review of this information it is determined that the
     clarifications have an impact on the original prices submitted[,] please
     make the necessary adjustment to your price schedule. You will also be
     required to provide a detailed explanation on how the price was
     affected.

   AR, Tab 1, Letter from USCIS to SI (Dec. 22, 2005), at 1; Letter from
   USCIS to Datatrac (Dec. 22, 2005), at 1.

   In addition, the agency asked SI whether a statement in its price
   quotation that its emergency plan was not priced meant that

     you have not provided an Emergency Plan as required or that the
     Emergency Plan is available but at a separately negotiated price. Again,
     [if] after your review [of] this information it is determined that the
     Plan was not priced, please make the necessary adjustment to your price
     schedule. You will also be required to provide a detailed explanation on
     how the price was affected.

   AR, Tab 1, Letter from USCIS to SI (Dec. 22, 2005), at 1.

   Also, the agency advised Datatrac that USCIS "will not support manifesting
   and placing of barcode labels on boxes of files to be shipped to your
   facility" (which was the weakness that the agency had identified in the
   previous evaluation) and asked the firm to

     state how you will support internal tracking of A-files at your facility
     without [the Office of Records Services] providing you with a paper and
     electronic manifesting document. Also should the cost of your quote be
     affected by this change[,] please provide the new pricing along with a
     detailed explanation on how the price was affected.

   AR, Tab 1, Letter to Datatrac (Dec. 22, 2006), at 1.

   On December 23, SI asked the agency whether it could further revise its
   price based on "updated pricing from our team members." AR, Tab 1, Letter
   from SI to USCIS (Dec. 23, 2005). The agency responded that "[t]he
   government stands by the instructions in the letter dated December 22,
   2005 with respect to clarifications." AR, Tab 1, Letter from USCIS to SI
   (Dec. 30, 2005).

   On January 4, 2006, the date set for receipt of final revisions to the
   quotations, both Datatrac and SI responded with revisions to their
   technical approach and both vendors affirmed that they had made no change
   to their price quotations.

   In its response, Datatrac changed its manifesting approach so that the
   agency no longer was required to manifest or label boxes, and affirmed
   that Datatrac, and not the agency, would be responsible for these efforts.
   The firm provided additional detail about how it would track A-files in
   three "redlined" pages to be substituted into its quotation.[5] AR, Tab 1,
   Letter from Datatrac to USCIS (Jan. 4, 2006) and Revised para. 1.1.2.

   SI responded with several "clarifications and amendments" to its technical
   quotation, but stated that its price "has not changed based upon our
   understanding of the parameters set forth in your letter dated December
   22, 2005, which limited our ability to revise our price." AR, Tab 1,
   Letter from SI to USCIS (Jan. 4, 2006), at 1. With regard to its emergency
   plan, SI deleted a constraint and assumption in its price quotation, and
   affirmed that the "[c]omplete implementation of the Emergency Plan is
   included in SI['s] initial pricing, including the proposed Disaster
   Recovery Site described in A.6.5 of the Project Management Plan." Id. at
   12 (emphasis in original).

   On January 13, USCIS e-mailed SI requesting "clarification" on whether the
   deletion of the constraint and assumption coupled with the statement
   regarding emergency plan pricing meant that the "project management plan
   is deleted or does it mean that that is still included and that activation
   of the alternate site mention[ed] in the original PMP is included in the
   current original pricing." AR, Tab 1, E-mail from USCI to SI (Jan. 13,
   2006), at 1; see Tr. at 881.

   On January 17, SI responded that it did not intend to delete the disaster
   recovery site from its quotation and that the site constituted [REDACTED]
   of the total price quotation. SI then added:

     We understand [that] the Disaster Recovery Site was not expressly called
     out in the RFP, but it was proposed by [SI] as part of our value added
     solution. Should the government decide it does not want the Disaster
     Recovery Site as part of our value added solution, it is severable from
     the rest of our proposed Emergency Plan, and deleting it at the
     government's option will have no impact on the remaining Emergency Plan.
     If the Government does not want the Disaster Recovery Site, our proposed
     price would be reduced by [REDACTED] reducing our overall proposal price
     to [REDACTED].

   AR, Tab 1, Letter from SI to USCIS (Jan. 17, 2006), at 2-3.

   The vendors' responses to the clarification and discussion questions were
   forwarded to the technical evaluation team (TET), and the TET issued a
   "draft" report. In that draft report, the TET stated that "[a] significant
   strength in the SI . . . quote is a robust emergency plan that outlines
   the establishment of a disaster recovery site in support of contingency
   planning. SI . . . indicates the costs for this site are already included
   in the pricing." AR, Tab 3, Best Value Analysis Report, at 4; Tab 9, Draft
   Final TET Report, at 8. This evaluation conclusion differed from the
   findings preceding the earlier Datatrac protest, where the TET had rated
   SI's emergency plan as a strength, but not a significant strength, based
   on the inclusion of the disaster recovery site. The TET explains that it
   added the word "significant" to the evaluation since it was clear that
   SI's quotation now included the price for its emergency plan, whereas
   before it was unclear whether the price had been included. Tr. at 569,
   571, 1031-32.

   On February 9, the contract specialist[6] commented that the word
   "significant" "needs to be removed from the [draft] report" on the basis
   that SI had not changed its emergency plan since the initial evaluation.
   AR, Tab 9, Agency E-mails, at 53. However, on February 23, the contracting
   officer requested additional information regarding the value of the
   disaster recovery site, stating that "the [source selection authority
   (SSA)] must understand what the added value is and how significant
   `significant' is. Therefore we need for you to provide some additional
   information that will give the SSA a clearer understanding of significant
   and added value." Id. at 66.

   As a result of these inquiries, the TET members, chairperson, and advisor
   engaged in a series of communications among themselves and with the
   contract specialist and contracting officer (who was also the SSA)
   regarding Datatrac's and SI's emergency plans, the valuation of SI's
   disaster recovery site, and how to account for this in the evaluation. The
   TET informed the SSA that SI's proposed disaster recovery site was of
   "limited value" and therefore deserving only of a strength and not a
   significant strength in the final evaluation. The TET reasoned that "there
   is a small likelihood of using the Disaster Recovery site" since it would
   only be used in case of a "catastrophic event," and that "any harm from
   the disruption of scanning operations is mitigated by the fact that
   [USCIS] still [has] access to paper files." In this regard, the TET noted
   that the files to be scanned under the call were not "time sensitive" and
   did not need to be readily accessible. Furthermore, SI's disaster recovery
   site, as proposed, would not be operational immediately because site
   employees would need to obtain security clearances. The TET also noted
   that it had not determined whether a disaster recovery site was needed, or
   even "desirable," as that determination would not be made until a risk
   assessment and contingency plan were established under the SDLC process.
   Id. at 62; Tab 3, Best Value Analysis Report, at 5; Tr. at 420, 479-80,
   493-95, 1006. For the foregoing reasons, the word "significant" was
   removed from the final evaluation report; however, SI still received a
   strength for its "robust emergency plan" under the performance approach
   factor. AR, Tab 2, Final TET Report, at 8; Tab 3, Best Value Analysis
   Report, at 5.

   The TET concluded that SI's quotation deserved the maximum possible score
   under each of the evaluation factors, noting several strengths and no
   weaknesses under each factor, and concluding that the quotation provided
   "enhanced value to the government." AR, Tab 2, Final TET Report, at 16;
   Tab 3, Best Value Analysis Report, at 5. The TET also concluded that
   Datatrac's quotation deserved the maximum possible score under each of the
   evaluation factors, noting several strengths (albeit somewhat different
   strengths from SI) and no weaknesses under each factor. The previously
   assessed weakness associated with Datatrac's manifesting approach was
   removed because the TET found that Datatrac's explanation of its approach
   "demonstrat[ed] an outstanding knowledge of USCIS records processing" and
   that the approach provided "enhanced value to the Government." [7] AR, Tab
   2, Final TET Report, at 14; Tab 3, Best Value Analysis Report, at 5. The
   TET did not express a preference for either Datatrac or SI in its final
   report to the SSA.[8] AR, Tab 3, Best Value Analysis Report, at 5.

   In making his best value decision, the SSA considered the TET report
   findings, the communications among the evaluators concerning the
   evaluation and valuation of SI's emergency plan, and the vendors'
   prices.[9] The SSA considered the strengths in each firm's quotation,
   including the strength in SI's quotation relating to its "robust emergency
   plan," and specifically reviewed each firm's emergency plan for compliance
   with the RFQ. Tr. at 217, 234. Although the SSA noted that both SI's and
   Datatrac's quotations were "technically outstanding in all areas," he also
   considered that SI's price for the first call ($14,647,920) was $862,470
   higher than Datatrac's price of $13,785,450. AR, Tab 3, Best Value
   Analysis Report, at 6. The SSA specifically commented on SI's "attempted
   price reduction offer [of January 17 that] was made in response to the
   [contract specialist's] clarification request of 13 January 2006." Id. The
   SSA declined to reduce SI's price or delete the disaster recovery site
   from SI's quotation because he determined that the contract specialist's
   communication was only a clarification and was not an invitation to revise
   the price or technical quotation, and that SI's "offer" occurred after the
   date set for receipt of quotation revisions. He further concluded that in
   this best value competition for a fixed-price award, it was "not the
   Government's place to add or exclude features in a proposal." Id. at 6;
   Tr. at 168-85, 1071-72, 1077.

   After considering the technical merits and price of each quotation, the
   SSA selected Datatrac for award. The SSA concluded that Datatrac's
   lower-priced quotation "offers the best mix of technical and cost value in
   accordance with the award criteria" and that it "offers the best value to
   the Government, all factors considered." AR, Tab 3, Best Value Analysis
   Report, at 6. After receiving notice of award and a debriefing,
   SI protested to our Office.

   ANALYSIS

   SI protests the evaluation of both its and Datatrac's quotations. It
   argues that the agency misevaluated the vendors' emergency plans,
   misevaluated Datatrac under the special preference factors, and conducted
   a flawed price evaluation. SI also alleges unequal treatment of the
   vendors both in the evaluation of quotations and in the conduct of
   discussions. SI further asserts that the agency's discussions with it were
   inadequate.

   When an agency conducts a formal competition under the FSS program, we
   will review the agency's actions and source selection decision to ensure
   that the evaluation was fair and reasonable, and consistent with the terms
   of the solicitation. 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. As discussed below, based on our
   review of the record here, we find no basis to question the agency's award
   decision.

   Emergency Plan

   SI contends that SI's and Datatrac's emergency plans were evaluated
   unfairly under the RFQ. It complains that Datatrac's emergency plan does
   not meet the required objective of Attachment A.2 to "[e]stablish
   contingency plans to ensure continuity of every operation during special
   and emergency situations" because the plan lacks sufficient detail and
   does not include a disaster recovery site, which SI asserts is necessary
   to meet this objective. SI Comments at 8-9; SI Post-Hearing Comments
   at 5-8, 10-13. SI contends that the agency waived the required objective
   for the benefit of Datatrac without informing SI or allowing it to revise
   its quotation.

   The agency responds that both vendors' emergency plans met the
   requirements and objectives of Attachment A.2. The agency explains that
   neither vendor provided "complete" detailed plans and in fact that level
   of detail was not required by the RFQ. Tr. at 77, 205. According to the
   agency, vendors were only required to "address" the objective in order to
   give the agency an understanding of what the vendor would do on a
   "conceptual basis." Tr. at 74-75, 192, 214, 444, 446, 823. The agency
   contends that a disaster recovery site was not required under the RFQ, but
   was merely a "value added" feature included by SI in its quotation. Tr. at
   421.

   Based on our review, we find the agency's evaluation of the vendors'
   emergency plans unobjectionable. The record shows the neither SI nor
   Datatrac provided complete detailed emergency plans in their PMPs, but
   instead, for the most part, addressed the objectives and requirements of
   Attachment A.2 on a conceptual basis. In this regard, SI's emergency plan
   made reference to a "Disaster Recovery/Business Continuity Plan" and
   "Emergency Response Procedures," the details of which were not provided.
   Agency Hearing exh. 12, SI's Emergency Plan, at A-34-35. SI also
   identified a disaster recovery site to be used as a "backup" site in the
   event of a "major disruption in services," but did not provide the plans
   and procedures for operating this site. Id. at A-36. SI indicated that the
   firm would perform a "Business Impact Assessment," which would result in
   the development of a "Disaster Recovery Plan" that "provides recovery,
   resumption, and restoration procedures for all critical business and/or
   operations processes," but did not provide the details of this plan.[10]
   Id. at A-36-37. SI states that this analysis would be performed after
   contract award and would determine whether the disaster recovery site
   would be used. Tr. at 1281-82, 1285-86. The firm also conceptually
   described its "Business Continuity Approach" and "Contingency
   Capabilities." Agency Hearing exh. 12, SI's Emergency Plan, at A-37-38. As
   noted above, SI received a strength in the evaluation for its "robust
   emergency plan" and disaster recovery site. AR, Tab 2, Final TET Report,
   at 8.

   Datatrac's emergency plan provided an overview of the firm's "managerial
   framework for business continuity" and "emergency preparedness" response
   efforts for such events as "fire, smoke, bomb threats, or other
   life-threatening emergencies affecting the safety and/or well being" of
   personnel. The emergency plan included the establishment of an "Emergency
   Preparedness Team" to evaluate potentially dangerous situations and
   coordinate evaluations, and described how Datatrac would evaluate and
   react to potential "threats." The plan included emergency evacuation and
   reporting procedures, and dealt with such things as fire drills and fire
   exit procedures. The plan also described the "roles and responsibilities"
   of the site personnel (such as the project site manager, operations
   manager, supervisors, clerks, quality control manager, and administrative
   staff and IT personnel) with regard to emergency responses, and included
   "backups" for these persons. Agency Hearing exh. 13, Datatrac's Emergency
   Plan, at 47-53.

   Datatrac's emergency plan included a section titled "Disaster Recovery."
   This section referred to a "Disaster Recovery Plan," which Datatrac stated
   "will be implemented" in the event of a "total disruption" of services.
   Although this section of Datatrac's quotation mentioned such things as
   "loss of center operations" and "business recovery," Datatrac provided
   little detail regarding the actual "Disaster Recovery Plan." Id. at 53.
   Both the agency and Datatrac assert that the plan's details could not be
   developed until the parties work through the SDLC process post-award.[11]
   Tr. at 639-41, 775-76, 1115, 1117-20. The agency concluded that Datatrac's
   emergency plan, including its "Disaster Recovery Plan," met the objectives
   and requirements of Attachment A.2 and warranted neither a strength nor a
   weakness.[12] Tr. at 203, 524-25, 635.

   Based on our review, we find nothing unreasonable in the agency's
   judgment. While it is true that SI provided more detail than Datatrac
   regarding its disaster recovery approach, as stated above, neither SI nor
   Datatrac provided full disaster recovery or emergency plans. In fact, as
   indicated, completed plans were not required by the RFQ. In this regard,
   paragraph 4.2.1 of the PWS required only that vendors "address" the
   requirements and objectives of Attachment A.2, which both quotations did
   here. Although SI's emergency plan focused more on disaster recovery of IT
   systems and Datatrac's focused more on physical threat responses and
   emergency procedures, this demonstrates only that the vendors had
   different emphases in meeting the objectives of an emergency plan; the
   fact that Datatrac's approach does not mirror SI's does not mean that
   Datatrac's approach is insufficient, or that the agency's evaluation of
   these different approaches evidences unequal treatment. In fact,
   the record shows that the agency recognized that SI's plan was more
   detailed and "robust" than Datatrac's and included a disaster recovery
   site, and acknowledged this as a "strength" in the evaluation. Tr. at 212,
   405-06; AR, Tab 2, Final TET Report, at 8.

   SI complains, however, that Datatrac's emergency plan provided too little
   detail for the agency to determine what the agency was getting, or to
   sufficiently bind Datatrac to implement a fully developed disaster
   recovery plan without additional costs. We disagree. As described above,
   Datatrac provided sufficient detail regarding its approach for the agency
   to reasonably conclude that Datatrac understood, and would comply with,
   the objectives and requirements of Attachment A.2. With regard to the
   disaster recovery plan, the exact requirements of which would be fleshed
   out during the SDLC post-award process,[13] Datatrac promised to both
   develop and "implement" the plan and collaborate with the government to
   define SDLC "deliverable requirements," Agency Hearing exh. 13, Datatrac
   Emergency Plan, at 53; Datatrac Protest Record, Tab C, Datatrac's
   Technical Quotation, at 64-65, and included the price for both the
   development and implementation of the plan in its fixed-price quotation.
   Tr. at 1088, 1187-89; Datatrac Protest Record, Tab E, Datatrac Price
   Quotation, at 25-26. Therefore, to the extent that the SDLC process
   identified additional detail, or features that may be required as part of
   an acceptable disaster recovery plan, the agency found, and Datatrac
   conceded, that Datatrac is obligated to provide them at no additional cost
   to the government.[14] Tr. at 224-25, 251, 1066, 1150, 1175; Declaration
   of Datatrac's Chief Executive Officer para. 12.

   Additionally, we do not agree with SI's contention that a disaster
   recovery site is required by the RFQ, as nothing in the RFQ limits vendors
   to a particular approach for ensuring continuity of operations and nothing
   specifically requires the provision of a disaster recovery site. Indeed,
   as indicated, the approach for ensuring continuity of operations was to be
   defined through the SDLC post-award process, where an evaluation of
   permissible downtime and other risk factors is performed to determine how
   to best satisfy this requirement. AR, Tab 12, SDLC Manual, at 32; Tr. at
   93-94, 542-43, 638-41, 731-32, 761, 916. In this case, as the agency
   explains, a disaster recovery site likely is not going to be required,
   given that the work effort is not "mission critical" and thus some
   "downtime" for systems and facilities to be restored will likely be
   acceptable. Tr. at 225-26, 422, 591, 600, 818. This should have been
   reasonably evident to the vendors, given the nature of the files to be
   scanned, which included historical and other files for which immediate
   access would not be required. PWS para. 1; see Tr. at 1197-1201. Although
   SI may have placed greater importance on the continuity of operations
   requirement than the RFQ suggested, the record does not show that the firm
   was misled as to the requirements or otherwise induced to provide a
   disaster recovery site.[15] Indeed, the record affirms that SI fully
   understood--as demonstrated in its January 17 response to the agency's
   request for clarification--that a disaster recovery site "was not
   expressly called out in the RFP," but was part of the firm's "value added
   solution."[16] AR, Tab 1, Letter from SI to USCIS (Jan. 17, 2006), at 2.

   In sum, we find no basis to conclude that the agency relaxed the RFQ
   requirements for Datatrac or that Datatrac's emergency plan did not meet
   the requirement of Attachment A.2.

   Nonetheless, SI asserts that the evaluation was flawed since the
   evaluators believed that Datatrac "deferred" contingency planning and the
   costs for this planning until after award. This argument is based on an
   e-mail from the TET advisor sent during the re-evaluation, which stated:

     The Government requirement alludes to the contingency requirement but
     did not specifically state the contractor shall include in the quote the
     establishment and costs for a disaster recovery site. SI . . . based on
     the information in the Call decided to establish and cost the site.
     Datatrac did not interpret the requirement that way and did not include
     the costs. The Datatrac approach was to acknowledge the requirement and
     defer action on contingency planning until after award. Therefore,
     Datatrac through their action deferred contingency costs and did not
     include them in their quote. SI clearly did a better job in addressing
     the contingency requirements, albeit possibl[y] too much better. On the
     other hand, Datatrac may not have addressed these requirements
     adequately.

   AR, Tab 9, Agency E-mails, at 53-2.

   At the GAO hearing, the TET advisor explained that he did not mean to say
   that Datatrac deferred all contingency planning and related costs, but
   only those associated with a disaster recovery site. Tr. at 1015, 1017. He
   further stated that he found this to be consistent with the RFQ since the
   determination about whether a disaster recovery site is "desirable" will
   not be made until completion of the SDLC analysis. Tr. at 1015-17; see id.
   at 1066-67; AR, Tab 9, Agency E-mails, at 62. The recipients of the e-mail
   (the TET chair and contract specialist) also understood him to be
   referring to the disaster recovery site and not contingency planning in
   general. See Tr. at 673, 678, 912-13. In addition, the TET believed that
   Datatrac's quotation met the emergency or contingency planning
   requirements of the RFQ without a disaster recovery site. Tr. at 636-37,
   685.

   The TET advisor's e-mail also was provided to the SSA, who carefully
   considered the advisor's analysis and recommendations (as well as other
   comments from the TET) and rejected the concerns stated in the e-mail as
   not "credible" given that the TET did not have access to the firms' price
   quotations. Tr. at 247-48, 1086, 1100. The SSA personally reviewed both
   Datatrac's and SI's emergency plans, and confirmed that both met the
   objectives and requirements of the RFQ, and he had "no doubt" that the
   costs for both developing and implementing all aspects of the emergency
   plan were included in Datatrac's quotation. Tr. at 217, 234, 1088.
   Although he recognized that SI included the price for a disaster recovery
   site in its quotation, and that Datatrac did not, the SSA determined that
   a disaster recovery site was not required by the RFQ and that it was part
   of SI's "value added" approach for which SI's quotation was given a
   strength. Tr. at 421; AR, Tab 3, Best Value Analysis Report, at 6. Given
   the reasoned approach taken by the SSA, we cannot find the award improper
   on this basis.

   SI next asserts that the cost of its disaster recovery site should be
   removed from its quotation in order to make an "apples to apples" price
   comparison. SI complains that since the agency knew that SI proposed a
   feature that Datatrac did not, the agency was obligated to normalize the
   firms' prices, especially in light of its conclusion that the disaster
   recovery site was not likely to be required and was only of "limited
   value." However, SI has not cited to, and we are unaware of, any
   requirement in a best value evaluation involving the award of a fixed
   price contract where an agency is required to add, or delete, the costs of
   a "value added" feature, even one that the agency finds of little value.
   Here, the record shows that SI made a reasoned business judgment to
   include a disaster recovery site as part of its "value added solution."
   AR, Tab 1, Letter from SI to USCIS (Jan. 17, 2006), at 2. Although the TET
   evaluators discussed whether to "eliminate" the disaster recovery site
   costs from SI's quotation as a means of comparing "like quotes," AR, Tab
   9, Agency E-mails, at 53-2, the SSA, after considering these suggestions,
   concluded that this approach was not appropriate given that, in his view,
   this would constitute an impermissible "leveling" of quotations. Tr. at
   352, 1073-74. Under the circumstances, we find that agency could
   reasonably evaluate the desirability of that feature without normalizing
   the prices among vendors. See Marquette Med. Sys., B-277827.5, 99-1 CPD
   para. 90 at 6 n.7 (normalization of costs is not proper where the varying
   costs in competing quotations result from different technical approaches
   that are permitted by the solicitation).

   Discussions

   SI also asserts that the agency should have accepted its January 17
   attempt to eliminate the disaster recovery site from its quotation, or,
   given the agency's conclusion that the site was only of "limited value,"
   held further discussions to inform SI that the site was unimportant. It
   contends that the implementation of corrective action resulting from the
   prior protest was unfair, in that the discussions allowed Datatrac to
   improve its competitive standing by revising its manifesting approach, but
   did not afford SI a similar opportunity to improve its chance for award by
   revising its emergency plan. The agency responds that it had no obligation
   to consider SI's January 17 response or hold additional discussions with
   SI, and that the discussions were not unfair.

   Where discussions are held in order to implement a recommendation of our
   Office for corrective action, discussions and proposal revisions may be
   limited in appropriate circumstances. Rel-Tek Sys. & Design,
   Inc.--Modification of Remedy, B-280463.7, July 1, 1999, 99-2 CPD para. 1
   at 3; Serv-Air, Inc., B-258243.4, Mar. 3, 1995, 95-1 CPD para. 125 at 2-3.
   The agency here determined to limit discussions to only those areas that
   our Office's attorney identified as problematic during the prior
   protest--namely, the failure to discuss with Datatrac a weakness relating
   to its manifesting approach while allowing SI to revise its quotation
   after the discussion period closed, and the failure to confirm whether SI
   included the price for its emergency plan in its quotation. The agency
   made the determination to limit discussions with the vendors to only these
   issues, plus any previously issued clarifications or discussions, to
   remedy the unfair treatment and lack of meaningful discussions issues that
   our Office identified in the prior protest. The agency did not allow
   broader revisions because both vendors' prices had been disclosed (at SI's
   request), and the agency did not want to give one vendor an unfair
   competitive advantage over another. Tr. at 179-83.

   We do not decide whether it was appropriate for the agency to limit
   discussions in this case because SI did not timely protest the limitations
   the agency placed on the discussions prior to the closing date for receipt
   of revised proposals. See 4 C.F.R. sect. 21.2(a)(1) (2006); Smith of
   Galeton Gloves, Inc., B-271686, July 24, 1996, 96-2 CPD para. 36 at 7.
   However, we will consider whether the discussions were fairly conducted
   within the context of those limitations.

   The record shows that SI was not invited to broadly revise its emergency
   plan because the plan was not considered a weakness. The agency, instead,
   interpreted it to be a strength that was properly evaluated as part of
   SI's "value added" solution. Unlike the weakness previously assessed to
   Datatrac's quotation for its manifesting approach, USCIS had no duty to
   bring this assessed "strength" to SI's attention or to allow SI to revise
   its emergency plan to eliminate this "value added" feature.[17] See
   Federal Acquisition Regulation (FAR) sect. 15.306 (d)(3)[18]; Tr. at 351.

   With regard to SI's January 17 suggestion that the disaster recovery site
   feature was "severable" and could be deleted from SI's quotation to reduce
   the price, USCIS asserts that it rejected this option because this
   possible attempted revision occurred after the discussion period had
   closed (on January 4). Tr. at 182, 185, 944. In any event, SI now admits
   that this communication was not an attempt to revise its quotation; the
   feature was intended to remain in the quotation as originally identified,
   and information was provided in case the agency decided it did not want
   this feature.[19] Tr. at 1264.

   SI argues that the January 17 price reduction should have been allowed,
   however, since it was in response to "continued" discussions with the
   agency that took place after January 4. Because the agency sought
   additional information on January 13, SI argues, its response was within
   the scope of the limited correction action, which allowed revisions that
   were tied to discussion questions. We find nothing in the January 13
   request for clarification that would suggest that discussions were being
   "continued" or that invited further revisions to SI's quotation. To the
   contrary, the January 13 e-mail merely asked SI to confirm whether the
   cost of its disaster recovery site was included in its quotation. In any
   case, as noted, SI did not intend to modify its quotation in responding to
   this request for additional information. Based on this record, we find the
   agency's conduct of the limited discussions to be fair and
   unobjectionable. In contrast to the significant unaddressed weakness in
   Datatrac's manifesting plan for which it had previously been denied fair
   discussions, SI was not entitled to discussions regarding a strength, nor
   was the agency required to identify features of SI's value-added approach
   that it found to be of limited value. Furthermore, the agency was not
   required to accept SI's January 17 suggestion to delete the disaster
   recovery site from its quotation since it was submitted after the
   discussion period was closed and was not in response to continued
   discussions, as SI now asserts. On these bases, we find the agency's
   implementation of our recommended correction action to be reasonable and
   not unfair.

   Security Clearance "Waivers"

   SI also contends that Datatrac's quotation should not have received the
   maximum number of points under the special preference factors because
   there is doubt whether Datatrac's facilities will be fully operational
   within 60 days. This is so, SI argues, because Datatrac initially
   represented that one of its subcontractors had received security clearance
   "waivers," a representation which turned out to be false.

   Security clearance waivers were mentioned in only two places in Datatrac's
   quotation--in the past performance section and in connection with
   recruitment and retention--and was based on erroneous information provided
   to Datatrac, which Datatrac clarified during discussions. Datatrac Protest
   Record, Tab C, Technical Quotation, at 17, 78; AR, Tab 1, Letter from
   Datatrac to USCIS (Aug. 26, 2005), at 1; Tab 1, Letter from Datatrac to
   USCIS (Jan. 4, 2006), at 2. However, the record does not evidence that
   this inaccuracy was material to Datatrac's quotation, or that the agency
   relied on it in evaluating operational capability. Tr. at 616, 702-03.
   Indeed, Datatrac's quotation did not depend on the provision of waivers to
   be fully operational within 60 days. Rather, Datatrac's transition plan
   explains that Datatrac will "leverage [its] experience" to establish a
   digitization center within 60 days, describes the steps it will take to
   become fully operational within that time, establishes a transition
   schedule that does not depend on waivers, and includes commitment letters
   from the building owner, architect, and construction companying
   demonstrating that the facility build-out will be completed to applicable
   specifications within 45 days of award. Datatrac Protest Record, Tab D,
   PMP, at 66-69; Tr. at 619-20. Thus, the record shows that the agency had
   sufficient information available to it to reasonably conclude that
   Datatrac's facilities would be operational within 60 days and, thus,
   Datatrac was deserving of the special preference points.[20]

   Price Realism

   SI complains that the agency failed to consider in its price realism
   analysis "whether Datatrac's proposed resources, equipment, facility, and
   records management processes were adequate--at the proposed prices--to
   satisfy the RFQ requirements," in particular the manifesting requirements.
   Protest at 26. In this regard, the record shows that although Datatrac has
   revised its technical quotation concerning its manifesting procedures, the
   agency did not conduct a new price realism analysis to account for this
   additional work. The agency explains, however, that a new price realism
   analysis was not required since Datatrac did not alter its approach or
   take on additional work; it just eliminated a manifesting requirement
   previously imposed on the agency. Such changes, the agency concluded,
   would have "minimal effect" on Datatrac's price. Tr. at 138-39. The agency
   asserts that Datatrac's price was reasonable and that the firm could
   perform at the price proposed. Contracting Officer's Statement (May 11,
   2006) para. 37; Tr. at 137-38.

   The record here shows that although Datatrac's revised quotation provided
   further explanation of the firm's manifesting approach and eliminated the
   previous requirement that USCIS manifest and label boxes, Datatrac did not
   take on any new work other than to place a barcode label on the boxes. A
   comparison of Datatrac's initial and revised quotes show that its document
   tracking process was in no way otherwise affected, or changed, by the
   elimination of the manifesting requirement previously imposed on the
   agency. Compare Datatrac Record, Tab C, Datatrac Technical Quotation, at
   50-52 with AR, Tab 1, Attachment to Letter from Datatrac to USCIS (Jan. 4,
   2006), at 1-3. The protester has provided no evidence that placing
   barcodes on the boxes will result in significant additional cost, or that
   Datatrac cannot perform this additional work at the price quoted.
   Accordingly, we find no basis to sustain the protest on this ground.[21]

   Source Selection

   Finally, SI challenges the agency's "best value" decision, based on the
   arguments above and because the agency failed to acknowledge the
   weaknesses in Datatrac's quotation or the strengths in SI's. However, the
   record demonstrates that the TET conducted a thorough evaluation that was
   consistent with the RFQ and, based on this evaluation and his own
   independent judgment, the SSA made an informed, reasonable decision to
   select Datatrac for award. In making this determination, the SSA
   recognized the different strengths in each vendor's quotation, but found
   that both quotations were "technically outstanding in all areas" and
   deserving of the highest possible ratings under the technical factors. The
   SSA recognized that SI had proposed a "slightly superior feature" in the
   disaster recovery site, but overall found the quotations to be
   "technically equal," and further recognized that the TET did not identify
   a preference for either Datatrac or SI. Given that Datatrac's quotation
   was $862,470 less than SI's and provided, in the SSA's view, "the best mix
   of technical and cost value in accordance with the award criteria," the
   SSA selected Datatrac for award. AR, Tab 3, Best Value Analysis Report, at
   6. Based on our review of the record, we find the SSA's judgment to be
   reasonable.[22]

   The protest is denied.

   Gary L. Kepplinger

   General Counsel

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

   [1] Our Office conducted a 3-day hearing where five agency witnesses, two
   SI witnesses, and one Datatrac witness testified concerning the issues in
   this protest.

   [2] The other plans included a project organization and communications
   plan, security plan, quality control plan, quality improvement plan,
   reporting notices and invoices plan, transition plan, personnel plan,
   training plan, daily operations plan, backlog avoidance/reduction plan,
   and earned value management system. PWS para. 4.2.1.

   [3] The SDLC manual describes the "methodical progression of activities"
   that USCIS undertakes for "planning, developing, testing, implementing,
   maintaining, and retiring" agency systems. AR, Tab 12, SDLC Manual, para.
   ES1.0. In addition to developing a contingency plan, the vendor is also
   required to assist with other SDLC processes, including developing a
   sensitive system security plan, performing a risk assessment to identify
   threats and vulnerabilities, establishing security test and evaluation
   parameters, and assisting with acquiring facility certification and
   accreditation. PWS para. 7.9.2.

   [4] One other vendor, whose quotation is not relevant here, also responded
   to the RFQ.

   [5] The RFQ required changes to be accompanied by amended pages, stating
   that "[a]ny changes from the original quote shall be indicated through use
   of a vertical line, placed adjacent to the change, within the right side
   margin of the page." Vendors were also required to note the date of the
   amendment on the change page. The RFQ further cautioned that "[q]uote
   amendments shall be allowed only prior to the due date for quotes" and
   "[q]uote revisions shall be permitted only at the [contracting officer's]
   request. RFQ sect. 7.7.1.

   [6] The contract specialist for the re-evaluation served as the
   contracting officer under the first evaluation. After the Datatrac
   protest, a new contracting officer was appointed to oversee the evaluation
   and serve as the source selection authority. Tr. at 897-99.

   [7] Both Datatrac and SI also received 6 points under the "special
   preference factors" for using small businesses, performing in a HUBZone,
   and providing a plan to "standup" its facility within 60 days of award.
   AR, Tab 2, Final TET Report, at 9, 15.

   [8] The TET gave the third vendor's quotation a score that was less than
   the maximum and found the quotation to be inferior to both Datatrac's and
   SI's quotations. AR, Tab 2, Final TET Report, at 16.

   [9] A new price analysis was not performed, since neither vendor altered
   its price quotation. The SSA relied on the analysis performed prior to the
   Datatrac protest. Tr. at 137-38.

   [10] It is not clear from the record whether the "Disaster Recovery Plan"
   mentioned in connection with the Business Impact Assessment is the same as
   the "Disaster Recovery/Business Continuity Plan" mentioned elsewhere in
   the emergency plan section of SI's quotation.

   [11] This is similar to SI's "Disaster Recovery Plan" insofar as the
   details will not be known on either offeror's plan until after the
   "Business Impact Assessment" and SDLC processes are completed post-award.
   Tr. at 293-95, 302, 717-18.

   [12] SI asserts in its post-hearing comments that Datatrac did not
   cross-reference "related plans" as is also required by Attachment A.2.
   Although it is true that SI referred to "Section 7.3.5 [of the SDLC
   Manual], Contingency Plan" in its emergency plan, Agency Hearing exh. 12,
   SI's Emergency Plan, at A-34, and Datatrac did not expressly include a
   similar reference, it is evident from the hearing testimony that
   Datatrac's emergency plan overlaps with, and relates to, to the SDLC
   contingency plan requirements, in a manner similar to SI's. See Tr. at
   465-66, 480-82, 529, 544-46.

   [13] SI argues that Datatrac cannot "fill the [informational] void" of its
   emergency plan using the SDLC process because the emergency plan is
   required pre-award, whereas the SDLC planning occurs after award. SI
   Post-Hearing Comments at 14. However, as discussed above, a completed
   emergency plan is not required pre-award, and since both the emergency
   plan requirement identified in Attachment A.2 and SDLC requirements
   identified elsewhere in the solicitation (see, e.g., PWS para. 7.9.2)
   address system continuity, we find reasonable the agency's explanation
   that the SDLC process can, and will, be used to flesh out the details of
   the vendors' emergency plans.

   [14] SI asserts that Datatrac would not be bound to provide a disaster
   recovery site, citing agency witnesses' testimony that the addition of a
   site would result in an equitable adjustment to Datatrac's contract. See
   Protester's Post-Hearing Comments at 16. However, the witnesses'
   statements were based on their belief that an additional site was not
   required by the solicitation, and would not be required through the SDLC
   process. Under those circumstances, should the agency require a disaster
   recovery site, the witnesses anticipated that the requirement would lead
   to an equitable adjustment. Tr. at 532-36, 1022. On the other hand, if an
   additional site was required through the SDLC process, then the agency
   expected that Datatrac would provide it at no additional cost to the
   government. See Tr. at 224-25, 251, 1066, 1150, 1175.

   [15] SI also disputes the agency's conclusion that its disaster recovery
   plan was of only "limited value" and deserving of only a "strength" and
   not a "significant strength." In this regard, SI argues that the site is
   "essential" to meeting the Attachment A.2 objective of ensuring
   "continuity of every operation." See Tr. at 1220-21. According to SI, it
   cannot conceive of another way to meet this objective other than through a
   disaster recovery site. Tr. at 1221, 1263, 1288-89. However, due to the
   nature of the work, that it was not mission critical, and that other means
   for accessing A-files are available, the agency could reasonably determine
   that using the site was unlikely and, therefore, of limited value to the
   agency. AR, Tab 3, Best Value Analysis Report, at 5; Tab 9, Agency
   E-mails, at 62. Although SI disagrees with the agency's judgment, it has
   not shown it to be unreasonable. See Entz Aerodyne, Inc., B-293531, Mar.
   9, 2004, 2004 CPD para. 70 at 3. In any event, SI's quotation received a
   strength under the performance approach factor, in part, because of the
   proposed disaster recovery site.

   [16] Although SI's witness testified that the firm proposed the site in
   response to the RFQ's "derived" requirement to "ensure continuity of every
   operation," Tr. at 1258 (discussing PWS, attach. A.2), the firm's
   quotation and contemporaneous writings, which refer to the site as "not
   expressly called out in the RFP" and part of the firm's "value added
   solution," belie this post-protest testimony. Furthermore, nothing in SI's
   technical quotation or in the firm's discussion of its disaster recovery
   site suggests in any way that SI believed the site was specifically
   required by the RFQ. See AR, Tab 1, Letter from SI to USCIS (Jan. 17,
   2006), at 2; Agency Hearing exh. 12, SI's Emergency Plan, at A-36; Tr. at
   421.

   [17] To the extent the SI argues that USCIS was required to discuss the
   fact that the agency waived a required element of the RFQ, that is, the
   disaster recovery site feature, as discussed above, no such waiver
   occurred.

   [18] Although FAR Part 15 procedures do not directly apply to FSS buys,
   our Office looks to Part 15 as guidance when, as here, an agency treats
   vendor responses as if it were conducting a negotiated procurement. TDS,
   Inc., B-292674, Nov. 12, 2003, 2003 CPD para. 204 at 6 n.3.

   [19] That SI did not intend to revise its quotation is further supported
   by the fact that SI did not provide amendment pages in conformance with
   section 7.7.1 of the RFQ, as was required whenever a vendor changed its
   quotation.

   [20] We note that SI similarly does not have security clearance waivers,
   so it is in no better a position than Datatrac in this respect to be fully
   operational within 60 days. Tr. at 827-28.

   [21] SI also complains that the agency did not perform a price realism
   analysis regarding the vendors' emergency plans, but since no changes to
   either plan was made, a new cost realism analysis was not required. To the
   extent that SI complains that the agency did not either delete from SI's
   quotation the cost of its disaster recovery site, or add the costs for a
   site to Datatrac's quotation, as we discussed above, this cost adjustment
   was not required.

   [22] SI raises a number of other challenges to the agency's technical and
   price evaluation. We have reviewed each of the protest grounds and find
   them to be without merit.