TITLE: B-298102; B-298102.3, GC Services Limited Partnership, June 14, 2006
BNUMBER: B-298102; B-298102.3
DATE: June 14, 2006
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B-298102; B-298102.3, GC Services Limited Partnership, June 14, 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

   Decision

   Matter of: GC Services Limited Partnership

   File: B-298102; B-298102.3

   Date: June 14, 2006

   James J. McCullough, Esq., Deneen J. Melander, Esq., and Steven A.
   Alerding, Esq., Fried, Frank, Harris, Shriver & Jacobson LLP, for the
   protester.

   Charles R. Marvin, Jr., Esq., Sharon A. Jenks, Esq., and Carol F.
   Westmoreland, Esq., Venable LLP, for The CBE Group, Inc.; Scott M.
   Heimberg, Esq., Thomas P. McLish, Esq., and Andrea T. Vavonese, Esq., Akin
   Gump Strauss Hauer & Feld, LLP, for Linebarger Goggan Blair & Sampson,
   LLP; and William L. Walsh, Jr., Esq., Scott Hommer III, Esq., Peter A.
   Riesen, Esq., and Keir X. Bancroft, Esq., Venable LLP, for Pioneer Credit
   Recovery, Inc., the intervenors.

   Richard M. Sudder II, Esq., H.R. Roberson, Esq., and Lori R. Larson, Esq.,
   Internal Revenue Service, and Thedlus L. Thompson, Esq., General Services
   Administration, for the agencies.

   Edward Goldstein, Esq., and Christine S. Melody, Esq., Office of the
   General Counsel, GAO, participated in the preparation of the decision.

   DIGEST

   Protester's challenge to agency's technical evaluation of its quotation in
   response to solicitation for private debt collection services is denied
   where the record shows that the agency's evaluation was reasonable and
   consistent with the terms of the solicitation.

   DECISION

   GC Services Limited Partnership protests the issuance of task orders to
   The CBE Group, Inc., Pioneer Credit Recovery, Inc., and Linebarger Goggan
   Blair & Sampson, LLP under request for quotations (RFQ) No.
   TIRNO-05-Q-00187, by the Department of the Treasury, Internal Revenue
   Service (IRS), for private debt collection services. GC Services
   challenges the IRS's evaluation of its quotation, the evaluation of
   Linebarger's quotation, as well as the IRS's alleged failure to make a
   proper affirmative determination of responsibility for Linebarger.

   We deny the protest in part and dismiss it in part.

   BACKGROUND

   On October 22, 2004, Congress enacted the American Jobs Creation Act (the
   "Act"), which, in relevant part, authorizes the IRS to contract with
   private debt collection firms to assist with the recovery of outstanding
   federal tax debts. See Pub. L. No. 105-357, Title VIII, Sec. 881(a),
   codified at 26 U.S.C. sect. 6306. Towards this end, the Act provides that
   the IRS may allow private debt collection firms to retain, as a fee for
   their services, up to 25 percent of the amounts that they collect for the
   government. Id. In implementing the provisions of the Act, the IRS has
   adopted a two-phase approach. The first phase, the "limited implementation
   phase," provides for placing only a small number of tax debt accounts with
   a limited number of private debt collection agencies--effectively a pilot
   program. Agency Report (AR) at 2. Provided this limited phase proves
   successful, the IRS "will launch into full implementation of its program."
   Id. At issue in this case is the IRS's issuance of debt collection task
   orders to three firms for the first phase of its private debt collection
   program.

   On October 15, 2005, the IRS issued the subject RFQ for private debt
   collection services, which limited the field of competition to vendors
   holding Federal Supply Schedule (FSS) contracts under the General Services
   Administration's (GSA) "Financial and Business Solutions" schedule, Debt
   Collection Services schedule (GSA FABS Schedule 520, Special Item Number
   (SIN) 4, Debt Collection). RFQ at 2. The RFQ contemplated the issuance of
   "fee-for-service" task orders to three vendors, each for a base period of
   1 year, plus 1 option year. Id. The IRS indicates that the combined
   contract value for the three task orders is between $20 million and
   $25 million. Contracting Officer's (CO) Statement at 1.

   Under the terms of the RFQ, vendors were required to submit quotations
   with two separate volumes. Volume 1, which was limited to 45 double-spaced
   pages, was to contain information addressing three technical evaluation
   factors, listed in descending order of importance: (1) relevant experience
   and past performance, (2) technical approach, and (3) management plan. RFQ
   at 56-57. In addressing these factors, vendors were cautioned that their
   quotations "SHALL NOT MERELY OFFER TO PERFORM WORK IN ACCORDANCE WITH THE
   STATEMENT OF WORK, BUT SHALL OUTLINE THE ACTUAL WORK PROPOSED AS
   SPECIFICALLY AS PRACTICAL." RFQ at 55.

   Volume 2 was reserved for vendors' completed pricing schedules, which
   divided pricing between debt collection commission fees--based on dollars
   actually collected---and administrative resolution fees. RFQ at 20.
   Vendors were to specify their commission fees for tax debt accounts (1)
   under $1,500; (2) between $1,501 and $5,000; (3) between $5,001 and
   $10,000; and (4) greater than $10,000. Id. They were further required t o
   specify a fee for handling administrative resolutions, which involves
   closing a collection case without payment for reasons such as death of the
   taxpayer, and for handling administrative resolutions due to an
   installment agreement exceeding 60 months. Id.

   Regarding the first four fee categories, the RFQ provided the following
   "target rates" that the IRS believed to be realistic commission fees: (1)
   24 percent; (2) 23 percent; (3) 22 percent; and (4) 21 percent. AR at 3;
   RFQ at 20. Vendors quoting fees other than the target rates were required
   to provide supporting rationale "as to why a rate other than the target
   rate was proposed." RFQ at 55.

   The RFQ further explained that the selection process would be comprised of
   three steps. Under the first step, the IRS would confirm whether vendors
   had existing FSS contracts. Under the second step, the IRS would evaluate
   vendors based on the technical evaluation factors, rank the vendors, and
   determine the "most highly qualified." RFQ at 55. As the third step, which
   included only the vendors determined to be the most highly qualified, the
   IRS would negotiate with the selected vendors the same commission and
   administrative resolution fees--"the same fee for all awardees for each
   line item." Id. If the IRS was unable to reach agreement on a vendor's
   fee, the RFQ indicated that the vendor would be eliminated from further
   consideration. Id.

   Under the relevant experience and past performance factor, vendors were to
   demonstrate their "relevant experience (i.e., similar in nature, scope and
   size) in the collection of debt owed . . . a wide variety of collection
   experience, on a nationwide basis," as well as "a level of accomplishment
   in a competitive environment." RFQ at 56. Within this information, each
   vendor was required to identify a minimum of five projects/customers,
   within the past 5 years, demonstrating its "nationwide ability to collect
   debt," "its ability in collecting a broad range (various types) of debt,
   and its success in a competitive collection environment." Id. Debt
   recovery rates were also to be evaluated under this factor; vendors
   therefore were required to include the recovery rates for each project
   cited. Moreover, the RFQ indicated that "[p]roposed key personnel" would
   be evaluated based on "their recent experience in managing collection
   contracts/projects similar in nature, scope and size, and on the success
   of those projects, based on personnel turnover rates and recovery rates."
   In this regard, the RFQ stated: "Note. The Project Manager is the key
   personnel position." Id.

   With regard to the technical approach factor, the RFQ provided for
   evaluation of a vendor's approach to meeting the requirements of the IRS's
   debt collection program and required each vendor to specifically address
   its "use of new versus experienced collectors; its monitoring and
   compliance programs, and its ability to provide for Federal Government
   monitoring of its systems." RFQ at 57. Vendors were required to describe
   how they intended to "meet and maintain the requirements for physical
   security and data integrity standards for taxpayer information" and how
   they would "meet and maintain physical security, data integrity,
   communications security, and personnel security." Id. The RFQ also stated
   that the IRS would evaluate the vendors' " approach to meeting privacy and
   safeguard requirements," and required vendors to provide "specific
   examples of implemented [Federal Information Security Management Act
   (FISMA)] compliant security controls" as well as "compliance with Federal
   Privacy Act requirements." Id.

   Under the third factor, management plan, the RFQ indicated that the IRS
   would evaluate how vendors proposed to "organize, staff, and manage" the
   requirements, as well as their approach to "the Complaint Process." RFQ at
   57. Vendors were required to describe their training plan, which was
   required to include "training of staff on all applicable Federal, State
   and local laws and regulations, the Taxpayer Bill of Rights, and IRS
   Policies and Procedures, and training provided for interaction with
   taxpayers." Id. The RFQ also indicated that the IRS intended to evaluate
   each vendor's approach to "initial training versus refresher training."
   Id.

   The IRS received 33 responsive quotations by the November 15 RFQ closing
   date. In evaluating vendors' quotations, the IRS developed "Evaluation
   Scoring Sheets" for the purpose of allowing evaluators to score each
   quotation under the three evaluation factors. AR, Tab K, Evaluation Plan.
   The scoring sheets subdivided the three evaluation factors into various
   discrete subfactors. Under the "relevant experience and past performance"
   factor, the scoring sheet included seven subfactors, "technical approach"
   was comprised of seven subfactors, and "management approach" was divided
   into five subfactors. Evaluators assigned one of the following adjectival
   ratings for each subfactor:

    Adjectival   Definition                                                   
      Rating     
   Exceptional   Proposal demonstrates a good understanding of the            
                 Government's objectives and contains an approach that        
   Low Risk      exceeds the solicitation requirements. Has one or more       
                 strengths that will benefit the Government. High probability 
                 of success with an overall low degree of risk in meeting the 
                 Government's requirements                                    
   Acceptable    Proposal demonstrates an acceptable understanding of the     
                 Government's objectives and contains an approach that meets  
   Moderate/High the solicitation requirements. Fair probability of success   
   Risk          with overall acceptable degree of risk in meeting the        
                 Government's requirements.                                   
   Marginal      Proposal demonstrates a minimal understating of the          
   Unknown Risk  Government's objectives. Overall quality of approach cannot  
                 be determined because of errors and/or omissions which may   
                 be capable of being corrected without a major rewrite or     
                 revision of the proposal                                     
   Unacceptable  Proposal fails to demonstrate an understanding of the        
   High Risk     Government's objectives [and] contains major errors and/or   
                 omissions that cannot be corrected without a major rewrite   
                 or revision of the proposal. Presents an unacceptably high   
                 degree of risk in meeting the Government's requirements.     
                 Proposal is not acceptable for award.                        

   AR, Tab K, Evaluation Plan, Evaluation Scoring Sheets.[1]

   Under the IRS's evaluation scheme, each adjectival rating had a point
   value: exceptional (low risk) -- 4 points; acceptable (moderate risk) -- 3
   points; marginal (unknown risk) -- 2 points; and unacceptable (high risk)
   -- 0 points. Based on this system, the highest raw score a vendor could
   receive was 76 points.[2] To account for the differing relative weights of
   the evaluation factors, the IRS applied the following weighting multiple
   for each technical evaluation factor: relevant experience and past
   performance -- weighted by a factor of 4.5, technical approach -- weighted
   by a factor of 3.0, and management approach -- weighted by a factor of
   2.5. Thus, 260 points was the highest total score a vendor could receive,
   assuming it received an exceptional rating under each subfactor.[3]

   After reaching consensus in evaluating the 33 vendors' quotations under
   the technical factors and then ranking the vendors by their technical
   scores, the IRS evaluated the proposed fees of the three vendors with the
   highest overall technical scores: The CBE Group, Pioneer Credit Recovery,
   Inc., and Linebarger, which had [deleted] (250 points). These firms
   accepted the IRS's target fees for general collection activities and the
   IRS was further able to negotiate the same proposed fee of $100 per
   administrative resolution with each of these firms.[4] As a consequence,
   the IRS issued task orders to these firms under their respective FSS
   contracts on March 8, 2006.

   Based on the IRS's evaluation of its quotation, GC Services was ranked
   ninth overall with a total score of 219.5 points. [Deleted]. After
   learning of the agency's decision, GC Services filed this protest.

   ANALYSIS

   In its protest, GC Services challenges the IRS's evaluation of its
   quotation in every instance where it received other than an "exceptional"
   rating for a technical evaluation subfactor under each of the three
   technical evaluation factors -- relevant experience and past performance,
   technical approach, and management plan. GC Services also argues that the
   IRS's evaluation of Linebarger's quotation was unreasonable where the IRS
   rated Linebarger as equal or superior to GC Services under numerous
   technical evaluation subfactors, and that the evaluation record reflects
   disparate treatment in the IRS's evaluation of Linebarger and GC
   Services.[5] As a final matter, GC Services contends that the IRS failed
   to make a proper affirmative determination of responsibility for
   Linebarger.

   I. Technical Evaluation of GC Services

   The FSS program, directed and managed by GSA, gives federal agencies a
   simplified process for obtaining commonly used commercial supplies and
   services. FAR sect. 8.402(a). Where, as here, an agency issues an RFQ
   under FAR Subpart 8.4 and conducts a competition (see FAR sect. 8.405-2),
   we will review the record to ensure that the agency's evaluation is
   reasonable and consistent with the terms of the solicitation. See RVJ
   Int'l, Inc., B-292161, B-292161.2, July 2, 2003, 2003 CPD para. 124 at 5.
   In a competitive FSS procurement, it is the vendor's burden to submit a
   quotation that is adequately written and establishes the merits of the
   quotation. Verizon Fed., Inc., B-293527, Mar. 26, 2004, 2004 CPD para. 186
   at 4; Godwin Corp., B-290291, June 17, 2002, 2002 CPD para. 103 at 4. In
   reviewing an agency's technical evaluation of vendor submissions under an
   RFQ, we will not reevaluate the quotations; we will only consider whether
   the agency's evaluation was reasonable and in accord with the evaluation
   criteria listed in the solicitation and applicable procurement statutes
   and regulations. American Recycling Sys., Inc., B-292500, Aug. 18, 2003,
   2003 CPD para. 143 at 4. The protester's mere disagreement with the
   agency's judgment does not establish that an evaluation was unreasonable.
   Hanford Envtl. Health Found., B-292858.2, B-292858.5, Apr. 7, 2004, 2004
   CPD para. 164 at 4. Based on our review of the record here, GC Services'
   challenges to the IRS's evaluation of its quotation amount to little more
   than disagreement with the agency's judgments and thus fail to establish
   that the IRS's evaluation was unreasonable.

   As a preliminary matter, we note that, although challenged by GC Services,
   we need not address the IRS's evaluation of each subfactor for which GC
   Services received other than a rating of "exceptional" since GC Services
   was not prejudiced by any alleged errors in the evaluation under the
   subfactors not addressed in our decision. Based on the point scoring
   system employed by the IRS, five vendors in addition to the three awardees
   had total scores higher than GC Services, and GC Services has only
   challenged the IRS's evaluation of one of the awardees, Linebarger. Of the
   three awardees, Linebarger received [deleted] score of 250 points. The
   total evaluated point scores for the vendors ranked fourth through eighth,
   between Linebarger and GC Services, were as follows: (4) 241 (5) 240, (6)
   234.5, (7) 233.5, and (8) 223.5. AR, Tab L, Source Selection Statement at
   3. Even assuming that GC Services received the highest ratings for every
   subfactor not addressed by our Office, the highest possible total score GC
   Services could have received would have been 233.5 points.[6] With a total
   score of 233.5 points, GC Services would have been tied with the seventh
   ranked vendor--not one of the "most highly qualified" firms for
   consideration by the IRS--and thus, without a reasonable possibility of
   award. See Joint Mgmt. & Tech. Servs., B-294229, B-294229.2, Sept. 22,
   2004, 2004 CPD para. 208 at 7; Citrus College; KEI Pearson, Inc., B-293543
   et al., Apr. 9, 2004, 2004 CPD para. 104 at 7 (prejudice is an essential
   element of every viable protest, and where none is shown or otherwise
   apparent, protest will not be sustained, even if the agency's actions may
   arguably have been improper).

   The specifics of the IRS's technical evaluation of GC Services' quotation
   are discussed below.

   A. Relevant Experience and Past Performance Factor

   Under this factor, GC Services received "exceptional" ratings for four
   subfactors and ratings of "acceptable" for three of the subfactors. GC
   Services challenges each of its "acceptable" ratings, arguing that it
   should have received "exceptional" ratings under these subfactors as well.
   We discuss below, and deny, GC Services' challenge to its "acceptable"
   rating under the subfactor relating to the experience of proposed key
   personnel.[7]

   The subfactor at issue provided as follows:

     Proposed key personnel have recent experience in managing collection
     contracts/projects similar in nature, scope and size, and on the success
     of those projects, based on personnel turnover rates and recovery rates.
     (resumes and proposal).

   AR, Tab K, Evaluation Plan, Evaluator Scoring Sheets. In evaluating
   vendors' submissions under this subfactor, the IRS considered the
   experience of vendors' key personnel "based on personnel turnover rates
   and recovery rates."[8] Id. GC Services argues that in evaluating its
   quotation as only "acceptable" under this subfactor, the IRS improperly
   downgraded its quotation for not providing personnel turnover and recovery
   rate information for its alternate project manager and for not providing
   recovery rate information for its project manager. As to the first issue,
   GC Services maintains that the RFQ required personnel turnover and
   recovery rate information only for the key personnel, which, according to
   GC Services, did not include the alternate project manager but rather was
   limited solely to the project manager. In support of this contention, GC
   Services cites the section of the RFQ outlining the evaluation of key
   personnel, which states, "Note: The Project Manager is the key personnel
   position." RFQ at 56. Regarding the second issue, GC Services asserts that
   its quotation did in fact contain recovery rate information for its
   project manager in connection with one of its past performance
   projects--specifically, its [deleted] project.

   The record reflects that the IRS's technical evaluators considered the
   resumes submitted by GC Services for both its project manager and
   alternate project manager and credited their many years of experience as
   strengths. The evaluators also identified the fact that GC Services did
   not provide any "specific information . . . on recovery rates or staff
   turnover rates for either the [project manager or alternate project
   manager]" as a weakness, noting the section of the RFQ stating that the
   "`key personnel will be evaluated based on their recent experience . . .
   based on personnel turnover rates and recovery rates (emphasis added). '"
   AR, Tab M, GC Services - Consensus Evaluation Scoring Sheet, Relevant
   Experience and Past Performance, Subfactor 1g. Notwithstanding the lack of
   information provided by GC Services, the record further reflects that the
   evaluators did in fact attribute recovery rate information to its project
   manager based on his involvement with the [deleted] project, which GC
   Services discussed in its quotation. Id.

   With regard to GC Services' principal argument, that it was not required
   to provide recovery rate or personnel turnover rate information for its
   alternate project manager since the alternate project manager was not the
   key personnel, GC Services misapprehends the weakness attributed to its
   quotation. It was not downgraded for failing to provide required
   information solely for its alternate project manager. Rather, the IRS
   faulted GC Services for failing to include personnel turnover and recovery
   rate information for either its project manager or its alternate project
   manager. The record reflects, and GC Services has not disputed, that it
   did not provide any information regarding its project manager's personnel
   turnover rate, despite the fact that such information was clearly required
   by the RFQ. Moreover, while the record reflects that the IRS did in fact
   credit its project manager with recovery rate information based on his
   work under the [deleted] project, rendering GC Services' second contention
   factually erroneous, the IRS had to "extrapolate" a recovery rate based on
   the [deleted] project owing to GC Services' failure to discuss or specify
   a recovery rate for the particular project manager in its quotation. CO
   Statement at 6. Despite GC Services' omissions, the IRS rated its
   quotation as "acceptable" under this factor and we can find nothing
   unreasonable with the IRS's decision in this regard.[9]

   B. Technical Approach Factor

   Under this factor, the IRS evaluated GC Services as "acceptable" under
   four of the seven subfactors and "exceptional" under the remaining three
   subfactors. GC Services challenges each of its "acceptable" ratings,
   arguing that it should have instead received a rating of "exceptional"
   under these subfactors as well. In the discussion below, we first list
   each of the four subfactors under which GC Services received an acceptable
   rating (quoting from the evaluation plan in the evaluator scoring sheets),
   followed by our analysis of the protester's contentions. For the reasons
   discussed, we deny GC Services' protest with regard to this factor.

     1. Subfactor c -- "Offeror clearly describes how the vendor will meet
     and maintain the physical security requirements, personnel security,
     Federal Privacy Act requirements and safeguard requirements."

   In evaluating GC Services' quotation as acceptable under this subfactor,
   the IRS determined that GC Services' quotation did not provide sufficient
   information regarding the salient characteristics of its "data center" for
   storing taxpayer information. Specifically, the IRS noted as a weakness
   the fact that GC Services did not indicate whether the data center would
   be "slab-to-slab" or alarmed above false ceilings. AR, Tab M, GC Services
   -- Consensus Evaluation Scoring Sheet, Technical Approach, Subfactor 2c.

   GC Services contends that the weakness attributed to its quotation for
   failing to identify whether its data center would be "slab-to-slab" or
   alarmed above false ceilings was unreasonable. According to GC Services,
   the IRS should have recognized that it would meet these security
   requirements since its quotation indicated that it intended to use a
   facility in [deleted], which it currently uses to collect state taxes, and
   that "[e]xternal auditors, experienced in federal & IRS security
   requirement, tested GCS security." GC Services' Quotation at 2. The IRS,
   however, had no knowledge or reason to know the security features of GC
   Services' [deleted] facility, which was used to collect state taxes, not
   federal debts, nor did GC Services identify the "external auditors" or
   elaborate on the testing performed in connection with its security. As a
   consequence, GC Services' references to these aspects of its quotation do
   not support a conclusion that the agency's evaluation was
   unreasonable.[10]

   GC Services also argues that the IRS improperly downgraded its quotation
   under this subfactor after concluding that GC Services should have
   included greater detail in its quotation. Specifically, GC Services takes
   issue with the evaluation comments indicating that GC Services would have
   benefited from including "information on how they monitor all entryways,
   reception areas, loading and shipping entrances, variations for
   after-hours security, intrusion monitoring, security agency for
   surveillance etc.," and "additional details " regarding its plans for
   preserving taxpayer privacy. AR, Tab M, GC Services -- Consensus
   Evaluation Scoring Sheet, Technical Approach, Subfactor 2c. According to
   GC Services, such information was not required, and, in any event, its
   quotation included such detail.

   It is important to note that the IRS rated GC Services as acceptable under
   this subfactor. While GC Services maintains that the evaluator comments
   concern information that was not required, the question at hand is whether
   GC Services deserved a rating of "exceptional" under this subfactor, which
   required GC Services to exceed the IRS's requirements. In support of its
   assertion that it did in fact provide the level of detail which the IRS
   indicated was absent from its quotation, GC Services cites the following
   section of its quotation regarding its physical security measures:

     [deleted]

   AR, Tab F, GC Services Quotation, at 26-27.

   While this information does provide information regarding the security
   planned for its facility, it does not provide, as noted by the evaluators,
   "information on how they monitor all entryways, reception areas, loading
   and shipping entrances, variations for after-hours security, intrusion
   monitoring, security agency for surveillance etc." AR, Tab M, GC Services
   -- Consensus Evaluation Scoring Sheet, Technical Approach, Subfactor 2c.
   GC Services also contends that its quotation contained the level of detail
   sought by the IRS regarding its plans for preserving taxpayer privacy. In
   support of this contention, GC Services cites sections of its quotation
   primarily pertaining to various information security measures, which the
   IRS did not view as germane to additional detail regarding preserving
   taxpayer privacy. We view GC Services' challenges under this subfactor as
   presenting nothing more than its disagreement with the agency's assessment
   of its quotation; this disagreement does not render the agency's
   evaluation unreasonable.

     2. Subfactor e -- "Proposed labor mix is sufficient to provide required
     services (i.e., new versus experienced collectors assigned to the IRS
     task)."

   With regard to this subfactor, GC Services disagrees with its "acceptable"
   rating, alleging that it was unreasonably downgraded for not including
   sufficient detail regarding how many personnel it would use to staff the
   IRS project or its staffing of "new" versus "experienced" debt collectors.
   GC Services argues the level of detail desired by the IRS was unreasonable
   since staffing could not be known until after award "when the IRS
   discloses the number of accounts and frequency of payments." Protest, Mar.
   17, 2006, at 10.

   In evaluating GC Services as acceptable under this subfactor, the IRS
   evaluators noted that GC Services planned to assign current experienced
   employees and recruit new employees for the IRS project, and that it
   intended to use experienced personnel from among the ranks of individuals
   working on state tax collection matters for its "front-line staff." AR,
   Tab M, GC Services -- Consensus Evaluation Scoring Sheet, Technical
   Approach, Subfactor 2e. The evaluators also commented that GC Services
   "did not disclose the total staff that will be dedicated to the IRS
   office" but indicated that it planned to staff the project with an "intact
   team," utilizing the employees and managers of its [deleted]. Id.

   As an initial matter, it does not appear, as GC Services suggests, that
   the IRS downgraded GC Services for failing to identify its "total staff."
   Rather, the comment regarding GC Services' nondisclosure of its total
   staff appears merely to describe the information contained in GC Services'
   quotation. The IRS's primary concern under this subfactor related to the
   limited information provided by GC Services regarding its intended mix of
   new versus experienced collectors in performing the debt collection
   requirements--the critical information required under the subfactor. Based
   on the limited information it provided, the IRS concluded that GC Services
   did not warrant an "exceptional" rating under the subfactor.

   Specifically, the IRS noted that GC Services did not "address the labor
   mix as a ratio or otherwise quantify use of new versus experienced
   collectors," nor did GC Services describe the qualifications of what it
   considered to be an "experienced" collector " in terms of average tenure
   or other qualifications such as minimal or no complaints, etc." AR, Tab M,
   GC Services -- Consensus Evaluation Scoring Sheet, Technical Approach,
   Subfactor 2e. Since, contrary to GC Services' argument, this type of
   information did not require specific numbers or identities of individuals,
   the information sought by the IRS was not dependent on knowing the "number
   of accounts and frequency of payments," and the IRS's evaluation of GC
   Services' quo tation in this regard as acceptable was reasonable and
   consistent with the terms of the RFQ.

   GC Services also cites to various statements in its quotation to
   demonstrate that it provided relevant detail regarding its staffing.
   Specifically, GC Services cites a "staffing chart" in its quotation, which
   reflected "representative" staffing. Protester's Comments at 28. The chart
   upon which GC Services relies, however, does not address the mix of new
   versus experienced collectors; rather, it provides nothing more than its
   management organization. In rebuttal of the agency's contention that it
   did not define what it considered to be an "experienced" collector, GC
   Services cites the fact that it planned to use its staff of collectors who
   have "experience with the [deleted]," as well as "the skills that will be
   demanded from potential new employees, including customer acumen,
   excellent listening skills, helpful and resourceful problem solving, and
   procedure orientation." AR, Tab F, GC Services Quotation at 13;
   Protester's Comments at 30. The first comment, however, does not identify
   the tenure of the collectors and the second speaks to new employees; as a
   consequence, the information does not aid in understanding GC Services'
   staffing mix or particularly indicate the experience of its collectors.
   Thus, the information upon which GC Services relies does not suggest that
   the agency's evaluation was unreasonable.[11]

     3. Subfactor f -- "Offer outlines the proposed [private collection
     agency] quality control (monitoring) of employee actions as well as how
     they intend to provide the ability for the IRS to monitor their systems
     and employee actions on IRS accounts."

   As indicated by the agency, evaluation under this subfactor focused on two
   elements: (1) internal quality control - how the vendors monitor their
   employees, and (2) how the vendors provide for the IRS to monitor their
   systems and employees' actions. Supplemental CO Statement at 11. In
   evaluating GC Services under this factor, the IRS commented that "[t]hey
   fail to provide number of cases and process for their monitoring" and
   "they fail to describe how they will equip (computer system) and train the
   IRS at our site of choice." AR, Tab M, GC Services -- Consensus Evaluation
   Scoring Sheet, Technical Approach, Subfactor 2f. With regard to the second
   concern, the evaluators noted sections of the RFQ providing that the
   contractor "shall provide IRS access to accounts maintained on the
   Contractor's computer system. The Contractor shall provide a system at the
   IRS['s] designated site, which shall be set-up and maintained by the
   Contractor," that the contractor shall provide "view access to data
   elements outlined by IRS," and requiring the contractor to provide
   training on how to use the contractor's system. AR, Tab M, GC Services --
   Consensus Evaluation Scoring Sheet, Technical Approach, Subfactor 2f; RFQ
   sections J.7.4, J.7.4.1, J.7.4.2.

   In attempting to rebut the evaluators' comments, GC Services argues that
   identifying the number of cases monitored was not possible because the
   volume and frequency of accounts could not be known until after award. The
   IRS, however, explained that it was not seeking a specific number of
   cases, but rather some insight regarding the scale of the cases that GC
   Services would monitor, such as "one out of ten calls or one out of twenty
   calls" or some "percentage" of accounts reviewed. Supplemental CO
   Statement at 11. By way of example, the IRS notes that Linebarger provided
   that it would [deleted]. Linebarger's Quotation at 22. While GC Services
   contends that Linebarger's representation was meaningless, since it does
   not define "[deleted]," and argues that Linebarger similarly did not
   identify the number of cases that it would monitor, the agency reasonably
   viewed the information provided by Linebarger as identifying the process
   by which cases would be culled for monitoring as well as the frequency,
   while GC Services' quotation was silent regarding these issues.

   GC Services also contends that it did in fact provide a detailed account
   of its process for monitoring its own employees. Specifically, GC Services
   notes several sections of its quotation stating that it "will institute a
   [deleted]," it "will [deleted]" and it "will [deleted]." AR, Tab F, GC
   Services Quotation, at 13-14.

   The record reflects that the IRS specifically considered these elements of
   GC Services' quotation, (e.g., the evaluators noted that GC Services
   "[deleted]"), but noted that GC Services' quotation would have been
   strengthened by a clearer explanation of "the process for monitoring." AR,
   Tab M, GC Services - Consensus Evaluation Scoring Sheet, Technical
   Approach, Subfactor 2f. In this regard, the contracting officer explained
   that while GC Services provided for a "[deleted]," GC Services did not
   address how it "would approach this work, nor did it provide their process
   or methodology for monitoring the quality of its employees." Supplemental
   CO Statement at 11. Given the agency's consideration of the information
   relied upon by GC Services, there is nothing to suggest that the agency's
   evaluation was unreasonable, other than GC Services' assessment of its own
   quotation. We view this as mere disagreement with the agency's evaluation.

   GC Services further asserts that it also provided detail regarding how the
   IRS will be equipped and trained on the GC Services system. Specifically,
   GC Services cites sections in its quotation regarding two software
   applications, one which would "[deleted]" and the other, a "[deleted]." GC
   Services' Quotation at 14. These software applications, however, do not
   address the agency's specific concern--the lack of information regarding
   how GC Services would provide the IRS with the ability to monitor accounts
   maintained on GC Services' computer systems. The evaluators specifically
   noted the RFQ requirements in this regard. Moreover, GC Services'
   quotation did not cite any information regarding how it intended to train
   the IRS on its monitoring system.[12] Given the evaluation record, there
   was nothing unreasonable with the IRS's decision to rate GC Services as
   acceptable under this subfactor.

     4. Subfactor g -- "Offer demonstrates a clear understanding of the
     Statement of Work, relevant to meeting and maintaining the work
     performance in a secure environment."

   Under this subfactor, the IRS considered vendors' ability to meet the
   RFQ's security requirements. GC Services disagrees with its "acceptable"
   rating under this subfactor, challenging the IRS's conclusion that its
   quotation would have benefited "from additional specificity and details
   regarding personnel security and disaster recovery." AR, Tab M, GC
   Services -- Consensus Evaluation Scoring Sheet, Technical Approach,
   Subfactor 2g. According to GC Services, its quotation provided greater
   detail regarding its personnel security and disaster recovery than did
   Linebarger's, which received a rating of "exceptional " under this
   subfactor.

   Our review of the record confirms the reasonableness of GC Services' and
   Linebarger's ratings. In this regard, the record shows that Linebarger's
   quotation had several characteristics which were considered strengths by
   the IRS, and were absent from GC Services' quotation. In fact, GC Services
   has not identified any strengths in its quotation under this subfactor
   which would have warranted a rating higher than acceptable; rather, GC
   Services merely identifies details of its quotation, which the IRS
   considered and noted in its evaluation. For example, the IRS noted that GC
   Services provided for a "[deleted]." AR, M, GC Services -- Consensus
   Evaluation Scoring Sheet, Subfactor 2g. With regard to Linebarger,
   however, the IRS identified numerous aspects of its quotation as notable
   strengths. For example, the IRS highlighted Linebarger's [deleted]
   certification, which one of the evaluators described "as one of the most
   stringent security certifications," the fact that Linebarger would
   [deleted], and its "additional advantage" of an "[deleted]" which would
   "[deleted]." AR, Tab M, Linebarger -- Consensus Evaluation Scoring Sheet,
   Technical Approach, Subfactor 2g. Although GC Services believes that its
   quotation was superior to that of Linebarger, it has not shown the
   agency's judgments to be unreasonable.

   C. Management Plan Factor

   The IRS evaluated GC Services as "marginal" under two of the five
   subfactors under this factor, "acceptable" under two of the subfactors,
   and "exceptional" under the remaining subfactor. GC Services challenges
   each of its "marginal" and "acceptable" ratings, arguing that it should
   have instead received ratings of "exceptional." We discuss the two
   subfactors under which GC Services received a rating of "marginal" and
   deny GC Services' challenges with regard to these subfactors.

     1. Subfactor b -- "The proposal describes the vendor's management plan
     compliance controls for training their employees in applicable Federal,
     State and local laws and regulations -- both initial and refresher."

   Under subfactor b, the IRS considered vendors' plans for initial and
   refresher training of employees "in applicable Federal, State and local
   laws and regulations." Id. GC Services received a rating of "marginal"
   under this subfactor. In evaluating GC Services under this subfactor, the
   IRS noted that GC Services' training plan did not discuss "passing scores
   or satisfactory training standards, [Fair Debt Collection Procedures Act]
   testing, [or] length and depth of the training." AR, Tab M, GC Services -
   Consensus Evaluation Scoring Sheet, Management Plan, Subfactor 3b. Due to
   these omissions, the evaluators concluded that " [t]he lack of specificity
   equates to an unknown risk level and a marginal rating." Id. GC Services
   argued in its comments that its "marginal" rating was unreasonable since
   the RFQ only required vendors to "describe" their training plans, that it
   had dedicated 3-1/2 pages of its quotation to its plan, and that the level
   of detail expected by the IRS could not be provided because the IRS's
   training curriculum would not be available until after award. GC Services
   also argued that the IRS' s evaluation of Linebarger as "exceptional"
   under this factor was premised upon a misunderstanding of information in
   its quotation, and that the IRS did not similarly downgrade Linebarger for
   failing to provide information on passing scores or satisfactory training
   standards.

   The RFQ required each vendor to describe its training plan, "which shall
   include training of staff on all applicable Federal State, and local laws,
   and regulations, the Tax Payer Bill of Rights, and IRS Policies and
   Procedures, and training provided for interaction with taxpayers." RFQ at
   57. While GC Services concludes that it could not provide the level of
   detail sought by the IRS, it has not explained why the information sought
   by the IRS could not be provided absent the IRS curriculum information. In
   fact, the IRS was concerned about the degree to which vendors addressed
   the applicable laws and regulations in their training plans. Thus, "the
   more directly a vendor addressed these laws and regulations indicate[d] to
   the IRS how well the vendor understood the importance of these laws and
   regulations to the program." RFQ at 57; Supplemental CO Statement at 14.

   In the IRS's view, GC Services' quotation evidenced a " general lack of
   acknowledgment of the importance of these laws, particularly the Fair Debt
   Collection Practices Act," "the principal federal law governing the
   Private Collection industry," CO Statement at 9, which "demonstrated a
   minimal understanding of the Government's objective's objectives in this
   area." Supplemental CO Statement at 15. In this regard, the IRS evaluators
   commented, and the record reflects, that GC Services' quotation makes only
   a passing reference to the Fair Debt Collection Practices Act, regarding
   the issue of appropriate calling times. Thus, while GC Services may
   disagree with the agency's evaluation of its training plan, there is
   nothing to suggest that the IRS's evaluation was unreasonable.

   With regard to GC Services' arguments challenging the IRS's evaluation of
   Linebarger as "exceptional" under this factor, we need not address GC
   Services' arguments in this regard since, as discussed below, we conclude
   that GC Services would not have been in line for award and therefore lacks
   standing to challenge the evaluation of Linebarger.[13]

     2. Subfactor c -- "The proposal describes the vendor's management plan
     and compliance controls for training their employees in Taxpayer Bill of
     Rights, IRS policies and procedures, interaction with taxpayers -- both
     initial and refresher."

   GC Services challenges its "marginal" rating under this subfactor. In
   evaluating GC Services' quotation under this subfactor, the IRS noted
   generally that additional information regarding the "length and depth" of
   training would have strengthened GC Services' quotation. AR, Tab M, GC
   Services -- Consensus Evaluation Sheet, Management Plan, Subfactor 3c. As
   a specific weakness the evaluators highlighted the fact that GC Services
   did not mention the Taxpayer Bill of Rights in describing its training
   plan. While acknowledging that "the taxpayer service message does
   permeate" GC Services' quotation, the evaluators concluded that GC
   Services did not adequately describe its training plan and that it
   demonstrated "a minimal understanding of the Government's objectives and
   raises an unknown degree of risk in meeting solicitation requirements."
   Id. In addition, the evaluators noted that GC Services did not make
   specific reference to refresher training on "[the Taxpayer Bill of
   Rights], IRS Policies and Procedures, or interactions with taxpayers" and
   failed to describe the frequency or duration of refresher training. Id.

   GC Services principally challenges the IRS's decision to downgrade its
   quotation for failing to mention the Taxpayer Bill of Rights.[14]
   According to GC Services, the IRS has unreasonably elevated "form over
   substance" in this regard. Protester's Comments at 44; Protester's
   Supplemental Comments at 24. While it did not specifically identify the
   Taxpayer Bill of Rights in its training plan, GC Services maintains that
   it did in fact address the Taxpayer Bill of Rights since its training plan
   generally describes the "concerns raised by these laws" and provides for
   "training as to `relevant laws, rules, and regulations.'" Protester's
   Comments at 44.

   As explained by the contracting officer, however, the RFQ specifically
   required vendors to describe their training of staff on the Taxpayer Bill
   of Rights, and the IRS viewed how directly a vendor addressed training
   pertaining to the Taxpayer Bill of Rights and IRS policies and procedures
   as an indication of how well the vendor understood the importance the IRS
   placed on these issues. Supplemental CO Statement at 15-16. By failing to
   mention the Taxpayer Bill of Rights, GC Services, in the IRS's view,
   demonstrated its lack of understanding of the requirements. Id.

   It was GC Services' obligation to include sufficient information in its
   quotation for the agency to determine whether the quotation would meet its
   needs; it was not the IRS's obligation during the evaluation process to
   fill in the gaps or to perform a "leap of faith" based on generalized
   statements contained in GC Services' quotation. G&M Indus., B-290354, July
   17, 2002, 2002 CPD para. 125 at 4; Robotic Sys. Tech., B-278195.2, Jan. 7,
   1998, 98-1 CPD para. 20 at 9. Since GC Services had the burden of
   submitting a quotation which discussed its proposed training on the
   Taxpayer Bill of Rights, yet did so in only the most general terms, we
   have no basis to question the reasonableness of the agency's concerns
   regarding GC Services' understanding of the requirements.

   GC Services also maintains that contrary to the agency's assertions, it
   described the frequency and duration of refresher training. Specifically,
   GC Services cites sections of its quotation stating that "[m] anagement
   holds monthly complaint avoidance seminars as well as training for other
   salient topics," and a section of its quotation regarding inspections,
   stating that "[s]afeguard Inspections as scheduled by the IRS . . . will
   ensure that . . . employees and any affected officers will receive initial
   and annual disclosure and safeguards awareness training." GC Services
   Quotation at 42, 34. The IRS, however, reasonably replies that the monthly
   training appeared to only address management, not all employees, as
   required by the RFQ, and the record reflects that GC Services' statements
   regarding training of non-management employees are general in nature
   (e.g., "[e]very [GC Services] Tax Assistant receives . . . ongoing
   training throughout their tenure with the company," and "[r]etraining
   occurs in response to any performance or quality issues and also to
   disseminate newly promulgated laws, rules, or regulations"). GC Services
   Quotation at 42. Based on this record, GC Services has failed to establish
   that the agency's conclusions in this regard were unreasonable.[15]

   II. IRS's Evaluation of and Responsibility Determination for Linebarger

   GC Services raises numerous arguments challenging the IRS's technical
   evaluation of Linebarger's quotation and also challenges the IRS's
   responsibility determination in connection with Linebarger. Regarding the
   latter basis of protest, GC Services argues that the IRS failed to make a
   proper affirmative determination of responsibility in connection with the
   award to Linebarger based on the erroneous assumption that it was not
   required to make a responsibility determination since it was merely
   placing an order under Linebarger's FSS contract.

   Based on our conclusions regarding the IRS's evaluation of GC Services'
   quotation, we dismiss these bases of protest since GC Services lacks
   standing to challenge the award to Linebarger. In order to have standing
   to protest a federal procurement, a protester must be an interested party,
   that is, an actual or prospective offeror whose direct economic interest
   would be affected by the award of, or the failure to award, a contract.
   Bid Protest Regulations, 4 C.F.R. sect. 21.0(a) (2006). A protester is not
   an interested party where it would not be in line for contract award if
   its protest were sustained. Durocher Dock & Dredge/Black & Veatch, A Joint
   Venture, B-280853, Nov. 24, 1998, 98-2 CPD para.149 at 8. As noted above,
   several other firms would be in line for award if we found the award to
   Linebarger improper. Accordingly, GC Services is not an interested party
   to challenge Linebarger's evaluation or the affirmative determination of
   responsibility.[16] See IAP World Servs., Inc., B-297084, Nov. 1, 2005,
   2005 CPD para. 199 at 4-5; JAVIS Automation & Eng'g. Inc., B-290556.2,
   Aug. 9, 2002, 2002 CPD para. 145 at 6.

   CONCLUSION

   In sum, we deny GC Services' arguments challenging the agency's evaluation
   of its quotation with regard to the following factors and subfactors: (1)
   relevant experience and past performance, subfactor g; (2) technical
   approach, subfactors c, e, f, and g; and (3) management plan, subfactors b
   and c. Moreover, as a result of denying GC Services' protest with regard
   to these issues, we dismiss its bases of protest challenging the agency's
   evaluation of Linebarger's quotation and the responsibility determination
   in connection with Linebarger since GC Services would not have been in
   line for award and therefore is not an interested party for the purpose of
   challenging the IRS 's issuance of a task order to Linebarger.

   The protest is denied in part and dismissed in part.

   Anthony H. Gamboa

   General Counsel

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

   [1] Here, and in many other instances, the record refers to the vendors'
   responses to the request for quotations as proposals, rather than
   quotations.

   [2] The 76 maximum score is based on the following: relevant experience
   and past performance - 7 subfactors multiplied by 4 points (maximum number
   of points for exceptional rating) for 28 points, technical approach - 7
   subfactors multiplied by 4 points for 28 points, and management approach -
   5 subfactors multiplied by 4 points for 20 points.

   [3] The 260 maximum score is the sum of the following: 126 points for
   relevant experience and past performance (28 maximum raw score multiplied
   by the 4.5 weighting factor); 84 points for technical approach (28 maximum
   raw score multiplied by the 3.0 weighting factor); and 50 points for
   management approach (20 maximum raw score multiplied by the 2.5 weighting
   factor).

   [4] The administrative resolution fees quoted by the three firms were
   [deleted]: (1) The CBE Group quoted [deleted] per resolution; Pioneer also
   quoted [deleted] per resolution; and Linebarger quoted [deleted] per
   resolution. AR, Tab L, Source Selection Statement.

   [5] During the development of the protest, our Office dismissed GC
   Services' protest of the IRS's evaluation of The CBE Group and Pioneer for
   failing to state a valid basis of protest. GC Services had argued that it
   was not possible for these vendors to have submitted quotations with the
   level of detail that the IRS required of GC Services and that the
   evaluation was therefore unequal. Protest, Mar. 17, 2006, at 14. Because
   GC Services failed to provide any evidence or details supporting its
   contentions, we concluded that GC Services' bare allegations were nothing
   more than speculation, which did not meet the standard for a legally
   sufficient protest. Science Applications Int'l Corp., B-265607, Sept. 1,
   1995, 95-2 CPD para. 99 at 2-3.

   [6] The score of 233.5 represents GC Service's total score based upon our
   decision denying its protests with regard to seven subfactors.
   Specifically, by denying GC Services' challenge to its acceptable rating
   for one of the subfactors under the relevant experience and past
   performance, the highest possible raw score GC Services could have
   received under this factor was 27 points, for a total score of 121.5 when
   multiplied by the applicable weighting factor (4). Under the second
   factor, technical approach, we deny each instance (a total of four) where
   GC Services challenges its "acceptable" rating as being too low, thus its
   raw score of 24 points, and total score of 72 points when multiplied by
   the weighting factor (3), remained unchanged for this factor. Under the
   third factor, management plan, we deny GC Services' challenges to its
   "marginal" ratings under two subfactors; thus the highest possible raw
   score GC Services could have received under this factor was 16 points,
   which, when multiplied by the weighting factor (2.5), resulted in a total
   score of 40 points. When the total scores of the three factors are added
   together, they equal 233.5 points.

   [7] The RFQ instructed each vendor to identify a minimum of five
   projects/customers for the purpose of providing references and provided
   for the references to submit questionnaires addressing the vendor's past
   performance. When more than five reference questionnaires were received
   for a vendor, the IRS "randomly selected five references." Supplemental AR
   at 11. The IRS indicates that it received 12 references for GC Services
   and randomly selected 5. However, the record reflects that of the five
   references selected, two were submitted by the same company, [deleted],
   for the same project, 4 days apart, with the second [deleted] reference
   indicating that it "revised" and "supersedes" the first. Thus, it appears
   that the IRS mistakenly considered only four references in its evaluation
   of GC Services. This error, however, could not have prejudiced GC Services
   because, as more fully discussed in the decision, even if it had received
   the highest rating under those experience and past performance subfactors
   to which its references were relevant--the subfactor addressed in our
   decision under the experience and past performance factor did not involve
   a consideration of vendors' references--its total point score would still
   not have placed it among the most highly rated vendors.

   [8] It is apparent from the record that the phrase "recovery rate"
   concerns the percentage of recovery of an outstanding debt.

   [9] GC Services also argued that there was disparate treatment in the
   evaluation since it received a rating of "acceptable" while Linebarger
   received the higher rating of "exceptional." According to GC Services, its
   project manager is "significantly more qualified" than Linebarger's
   project manager and Linebarger failed to provide key information in order
   to properly evaluate the personnel turnover and recovery rates identified
   for Linebarger's project manager. Protester's Comments at 22. The record
   reflects that the IRS evaluated the merits of each quotation on its own
   and GC Services concedes that the IRS identified the experience of its
   project manager as a strength under this subfactor. Protester's Comments
   at 20-21. Thus, there is nothing to suggest that the IRS misevaluated GC
   Services' quotation in this regard. In addition, regarding the key
   information which GC Services complains was missing from Linebarger's
   quotation, the record reflects that Linebarger provided specific turnover
   and recovery rates for its project manager.

   [10] GC Services also contends that the IRS did not downgrade Linebarger
   for failing to indicate whether its data facility was "slab-to-slab" or
   had alarmed ceilings. The record reflects, however, that unlike GC
   Services, Linebarger indicated that its facility was certified under the
   [deleted], and provided an explanation of the certification process. The
   IRS reasonably viewed this certification as addressing security concerns
   in connection with its data facility.

   [11] GC Services also argues that Linebarger did not provide any greater
   level of detail in addressing this subfactor despite its higher rating of
   "exceptional." The record, however, reflects that the IRS credited
   Linebarger's quotation for providing a detailed [deleted], which was
   derived from information provided in the RFQ. In addition, the IRS
   reasonably credited Linebarger for addressing its mix of new versus
   experienced staffing given that Linebarger indicated that [deleted]. AR,
   Supplemental CO Statement at 10. Again, while GC Services may disagree
   with the IRS's evaluation of Linebarger's quotation, which utilized a
   different approach than did GC Services, the record does not support a
   finding that the IRS's evaluation of these quotations was unreasonable.

   [12] GC Services argues that Linebarger's quotation provided "very few"
   details regarding IRS monitoring and training. The record, however,
   reflects that, unlike GC Services, Linebarger indicated that its
   information technology system provides the IRS with "[deleted]," that
   "[deleted]," and that it would provide the IRS with training. Linebarger's
   Quotation at 24.

   [13] To the extent GC Services indirectly challenges its own evaluation by
   continuing to maintain that the IRS failed to assign the same weaknesses
   to Linebarger it had assigned to GC Services--specifically, GC Services'
   failure to discuss "passing scores" or "satisfactory training standards"
   in its training plan--GC Services fails to challenge the IRS's primary
   concern that its training plan fundamentally failed to acknowledge the
   importance of various federal and state laws, particularly the Fair Debt
   Collection Practices Act. As a consequence, GC Services has not
   established that the IRS acted unreasonably in assigning its quotation a
   rating of "marginal" under this subfactor.

   [14] GC Services also restates the argument that the level of detail
   expected by the IRS could not have been provided because the IRS's
   training curriculum was not available until after award. Again, however,
   while GC Services concludes that it could not provide the level of detail
   sought by the IRS, the RFQ nonetheless required GC Services to describe
   its Training Plan "which shall include training of staff on all applicable
   Federal State, and local laws, and regulations, the Tax Payer Bill of
   Rights, and IRS Policies and Procedures, and training provided for
   interaction with taxpayers," and GC Services does not explain why the
   training information sought by the IRS could not have been provided absent
   the curriculum information. RFQ at 57.

   [15] GC Services also raises numerous arguments challenging the IRS's
   evaluation of Linebarger's quotation. For example, GC Services contends
   that Linebarger was not similarly downgraded by the IRS for failing to
   detail the duration of its refresher training. The IRS, however, explains
   that the duration of Linebarger's training was not an issue because it was
   satisfied by the "depth" of Linebarger's training plan. Supplemental
   Agency Report at 42. We view these challenges to Linebarger's evaluation
   as little more than disagreement with the IRS's conclusions under this
   subfactor, which does not render the agency's evaluation unreasonable. In
   any event, as discussed below, GC Services does not have standing to
   challenge the IRS's evaluation of Linebarger's quotation since GC Services
   would not be in line for award even assuming those challenges were found
   to have merit.

   [16] In response to our request, GSA, the agency responsible for
   administering the FSS, submitted comments regarding whether the IRS was
   required to make an affirmative determination of responsibility for
   Linebarger before it placed a task order under Linebarger's FSS contract.
   In its response, GSA affirmatively stated that "GSA is tasked with making
   determinations of responsibility pertaining to FSS contractors, thus
   ordering agencies are not required to make an affirmative responsibility
   determination prior to placing a FSS order." GSA Letter, May 17, 2006 at
   1.