TITLE: B-299504; B-299504.2, IBM Corporation, June 4, 2007
BNUMBER: B-299504; B-299504.2
DATE: June 4, 2007
***************************************************
B-299504; B-299504.2, IBM Corporation, June 4, 2007

   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: IBM Corporation

   File: B-299504; B-299504.2

   Date: June 4, 2007

   Thomas P. Humphrey, Esq., John E. McCarthy Jr., Esq., David Z.
   Bodenheimer, Esq., Adelicia Cliffe Taylor, Esq., Jane R. Foster, Esq., and
   Derek A. Hahn, Esq., Crowell & Moring LLP, for the protester.

   Mark D. Colley, Esq., Christopher R. Yukins, Esq., Kristen E. Ittig, Esq.,
   Cameron W. Fogle, Esq., and Antonella Karlin, Esq., Arnold & Porter LLP,
   for CGI Federal, Inc., an intervenor.

   Avital G. Zemel, Esq., and Kenneth A. Redden, Esq., Environmental
   Protection Agency, for the agency.

   Jonathan L. Kang, Esq., and Ralph O. White, Esq., Office of the General
   Counsel, GAO, participated in the preparation of the decision.

   DIGEST

   1. Protest challenging agency's evaluation of offerors' price and cost
   proposals is sustained where agency improperly adjusted upward portions of
   protester's fixed-price proposal.

   2. Protest alleging unreasonable technical evaluation is denied where
   record supports agency's evaluation of protester's personnel approach.

   3. Protest alleging misleading discussions is denied where protester
   unreasonably relied on oral advice allegedly provided by agency during
   discussions which deviated from solicitation instructions.

   DECISION

   IBM Corporation protests the award of a contract to CGI Federal, Inc.
   under request for proposals (RFP) No. PR-HQ-05-12521, issued by the
   Environmental Protection Agency (EPA) for the upgrade of the agency's
   financial management system. The protester contends that the EPA's
   evaluation of the offerors' price and technical proposals was
   unreasonable. The protester also alleges that the agency did not conduct
   meaningful discussions, and that the source selection decision was flawed.

   We sustain the protest.

   BACKGROUND

   The EPA's Financial System Modernization Project (FSMP) calls for the
   acquisition, implementation and hosting[1] of a software solution to
   provide a new agency-wide financial management system for the agency's
   Office of the Chief Financial Officer. The RFP sought proposals for the
   new software solution and anticipated award of an
   indefinite-delivery/indefinite-quantity (ID/IQ) contract with a 5-year
   base term, and five 1-year options. The work under the contract will be
   performed through the issuance of performance-based task orders.

   The RFP identified two technical evaluation factors, technical merit (375
   total points) and oral presentations and solution demonstration (125 total
   points).[2] RFP at M-2-M-8. Offerors were required to submit proposals in
   six volumes, titled: (1) minimum requirements matrix, (2) software
   solution, (3) technical merit, (4) supporting documentation, (5) price
   proposal,[3] and (6) solicitation set. RFP attach. 5, Proposal
   Instructions. The "minimum qualifications matrix" volume was to be used by
   each offeror to identify whether its proposal met each requirement, and,
   if not, how the offeror would meet the requirement in the future. Id. at
   attach. 6, Minimum Qualifications Matrix. Each offeror's matrix was
   evaluated, overall, on a pass/fail basis. Id. Offerors were also required
   to address potential conflicts of interest and provide a subcontracting
   plan. RFP at M-8-M-9.

   The RFP allowed offerors to propose how they would be reimbursed by the
   agency for the work under each area of the contract, i.e., on a
   fixed-price, labor hour, or time and materials (T&M) basis. RFP attach. 5,
   at 17. The RFP also instructed offerors to include any assumptions or
   exclusions from their price and cost proposals, including "contingency
   allowances" for expected and unknown risks, RFP attach. 5, at 7, and
   advised that the agency would evaluate proposals based on cost and price
   realism. RFP at M-2. The agency further explained, during discussions,
   that it would evaluate the "total cost of ownership" of each proposed
   approach, as follows:

     [P]ursuant to the definition of cost realism included in provision M.4
     of the solicitation, EPA intends to consider the total cost of ownership
     of the proposed solution as part of its evaluation of overall cost.
     Total costs of ownership include [the offeror's] proposed price, the
     costs to EPA for the operations and maintenance of EPA legacy systems
     (as identified in Attachment 10 of the solicitation), as well as the
     costs to EPA of EPA and [program management office] contractor resources
     allocated to the project (as identified in Attachment 5 to the
     solicitation).

   Agency Report (AR), Tab 26, Agency Request for Final Proposal Revisions,
   Oct. 19, 2006.

   The RFP stated that award would be made to the "responsible offeror(s)
   whose offer conforms to the solicitation and is most advantageous to the
   Government cost or other factors considered," and that "all evaluation
   factors other than cost or price when combined are significantly more
   important than cost or price." RFP at M-2.

   The EPA received four proposals, and performed an initial price and cost
   and technical evaluation of each of them. Two of the four offerors were
   eliminated from further consideration, leaving only CGI and IBM. The
   agency then conducted discussions with these offerors, and requested final
   proposal revisions (FPRs).

   In its FPR, IBM proposed to perform all work on a fixed-price basis, with
   the exception of one portion of the hosting requirements (described in
   detail below), which was proposed on a T&M basis. AR, Tab 41, Source
   Selection Determination (SSD), at 69. CGI proposed to perform [deleted] of
   the work on a fixed-price basis, and [deleted] of the effort on a T&M
   basis. Id. There is no dispute in the record that CGI proposed to perform
   [deleted].

   A technical evaluation panel (TEP) evaluated each FPR, and provided
   separate reports to the contracting officer (CO). AR, Tab 31, TEP Final
   Technical Report, Tab 38, TEP Final Price and Cost Report. The CO reviewed
   the separate TEP reports and prepared a selection decision with final
   technical and price and cost evaluations for each offeror. AR, Tab 41,
   SSD.

   The CO concluded that each offeror proposed an acceptable minimum
   requirements matrix, subcontracting plan, and conflict of interest plan.
   Id. at 10-13. For the technical evaluations, the CO evaluated the offerors
   as follows:

   +------------------------------------------------------------------------+
   |                                             |     IBM     |    CGI     |
   |---------------------------------------------+-------------+------------|
   |TECHNICAL MERIT                              |    256.2    |    240     |
   |---------------------------------------------+-------------+------------|
   |Technical and Functional                     |     72      |     54     |
   |                                             |             |            |
   |-- Software Solution                         |    40.5     |    40.5    |
   |                                             |             |            |
   |-- Implementation                            |    40.5     |    40.5    |
   |                                             |             |            |
   |-- Hosting                                   |             |            |
   |---------------------------------------------+-------------+------------|
   |Experience and Past Performance              |    37.6     |    37.6    |
   |                                             |             |            |
   |-- Organization Experience                   |    37.6     |    28.2    |
   |                                             |             |            |
   |-- Past Performance                          |             |            |
   |---------------------------------------------+-------------+------------|
   |Management Approach                          |    16.8     |    16.8    |
   |                                             |             |            |
   |-- Approach                                  |    11.2     |    22.4    |
   |                                             |             |            |
   |-- Personnel                                 |             |            |
   |---------------------------------------------+-------------+------------|
   |ORAL PRESENTATIONS AND SOLUTION DEMONSTRATION|     90      |     80     |
   |---------------------------------------------+-------------+------------|
   |Oral Presentation                            |     20      |     20     |
   |---------------------------------------------+-------------+------------|
   |Solution Demonstration                       |     20      |     15     |
   |                                             |             |            |
   |-- Business Scenarios                        |     15      |     15     |
   |                                             |             |            |
   |-- Ability to Satisfy Goals of FSMP          |     20      |     15     |
   |                                             |             |            |
   |-- Navigation and Ease of Use                |     15      |     15     |
   |                                             |             |            |
   |-- Effectiveness of Offeror's Team           |             |            |
   |---------------------------------------------+-------------+------------|
   |TOTAL SCORE (500 possible points)            |    346.2    |    320     |
   +------------------------------------------------------------------------+

   AR, Tab 41, SSD at 5.

   For the price and cost evaluation, the CO made adjustments to offerors'
   proposals based on "cost realism" and "total cost of ownership" analyses.
   Id. at 52-71. As relevant to the protest, the agency made four adjustments
   to IBM's price and cost proposal based on two general types of cost
   concerns. The first two adjustments were based on the agency's concern
   that IBM's proposal did not capture all of the costs of IBM's approach to
   the work, and that IBM would seek reimbursement for those costs. The third
   and fourth adjustments to IBM's proposal were based on the agency's
   concern that additional agency resources would be required based on IBM's
   proposed approach.[4]

   First, the EPA determined that both IBM's and CGI's proposals required
   upward adjustments regarding the agency's Superfund Cost Recovery Package
   and Image On-Line System (SCORPIOS) legacy application. The RFP explained
   that "SCORPIOS summarizes the dollars spent on Superfund cleanup sites and
   supports the recovery of those costs." RFP attach. 1, EPA Legacy System
   Table, at 10-2.

   Although neither IBM nor CGI proposed to replace SCORPIOS initially, their
   FPRs both proposed to replace SCORPIOS. IBM's FPR states that: "The IBM
   FSMP solution replaces 15 of 19 legacy applications including SCORPIOS to
   realize the benefits of an integrated solution." AR, Tab 27, IBM FPR, Vol.
   3, at 3 (emphasis in original, denoting FPR change). In the cost section
   of its FPR, IBM stated that "[i]n implementation, IBM is replacing 15 of
   19 legacy applications and delivering the systems in two releases over a
   26 month period." Id., Vol. 5, at 2. In its charts and diagrams detailing
   the replacement of legacy applications, IBM's FPR stated that SCORPIOS
   would be replaced in Release Two of IBM's solution. Id., Vol. 3, at 9,
   Figures B-4, B-5. With regard to the pricing of the SCORPIOS replacement,
   IBM stated that for all areas other than a portion of its hosting
   proposal, "IBM proposes firm fixed price (FFP) as the task pricing type
   for each of the PWS task areas." AR, Tab 27, IBM FPR, Vol. 5, at 43.

   Despite IBM's proposal to replace SCORPIOS on a fixed-price basis, the
   agency concluded that the company had not adequately explained its price
   and cost proposal or technical approach in its FPR. The agency calculated
   an adjustment based on what the agency viewed as the likely cost of
   replacing SCORPIOS. AR, Tab 41, SSD at 54. Similarly, the EPA concluded
   that CGI's proposal to replace SCORPIOS on a T&M basis lacked a sufficient
   number of hours to perform the work, and adjusted its proposal on that
   basis. Id.

   Second, the EPA concluded that IBM's proposal required an adjustment for
   its Tier 3 hosting solution and contingency allotment. The RFP required
   offerors to provide hosting for all software applications, other than
   agency legacy applications, and divided these hosting requirements into
   three tiers:

     Tier 1: Basic Data Center, manage the computers and infrastructure

     Tier 2: Tier 1 plus manage the application, help desk, break-fix, run
     jobs, small patches

     Tier 3: Tier 2 plus systems development and integration including major
     new releases

   RFP attach. 5, Proposal Instructions, at 9-10.

   During discussions, the agency clarified for both offerors that the Tier 3
   hosting requirements would fall into two categories: (1) contractor-driven
   changes required by an offeror's own solution; and (2) government-driven
   changes required by the agency to meet new and updated requirements, such
   as legislative mandates or changes to government accounting rules. AR, Tab
   29, Summary of Discussions, at 10; see also, Tab 41, SSD, at 54-55;
   Hearing Transcript (Tr.) at 233:8-14.[5]

   Initially, IBM proposed to perform all hosting work, including Tier 3
   hosting, on a fixed-price basis. In its FPR, however, IBM proposed to
   provide Tier 3 hosting on a T&M basis, but expressly estimated $0 for the
   effort. Specifically, IBM stated "[t]his scope is zeroed and will be
   directed on [a] T&M basis as required by EPA." AR, Tab 27, IBM FPR, Vol.
   5, at 13. With respect to the "major new releases" component of Tier 3
   hosting, IBM advised as follows:

     [deleted].

   AR, Tab 27, IBM FPR, Vol. 3, at 80-81.

   The EPA concluded that an upward adjustment to IBM's proposal was required
   for cost realism because IBM had not included any costs for anticipated
   future releases of its proposed software solution, [deleted]. AR, Tab 41,
   SSD at 55. The EPA adjusted IBM's Tier 3 costs upward to cover future
   releases and also made an adjustment to provide a contingency allowance
   relating to Tier 3 hosting. Id. Although IBM had included contingency
   allowances for other areas of its proposal, it did not do so for Tier 3
   hosting. Thus, the EPA calculated an adjustment by using the contingency
   rate found elsewhere in IBM's proposal. AR, Tab 41, SSD at 56.

   Third, the agency determined that IBM's proposal would require EPA to
   incur additional costs for agency personnel in the implementation stage of
   the work. The RFP required offerors to state their assumptions about the
   number of hours that EPA staff would need to contribute to the
   implementation effort here. RFP attach. 5, at 7. IBM's initial proposal
   assumed approximately 214,000 hours of EPA staff effort. During
   discussions, the agency advised both offerors that it could provide only a
   limited number of staff hours to assist with implementation, as follows:

     EPA clarifies that the EPA Resource levels identified during discussions
     are limited to the development portion of any resultant contract, i.e.
     EPA can dedicate no more than 20 full time employees to the project
     until the proposed solution becomes the Agency financial system of
     record. Additional subject matter experts can be provided by the
     Government intermittently, but not for more than one week per occasion.

   AR, Tab 41, SSD at 57.

   IBM's FPR reduced its assumption for the number of EPA staff hours
   required to a level consistent with the agency's notice that only 20 FTEs
   per year would be available, but IBM did not increase its proposed hours
   to cover the estimated 214,000 hours of EPA staff effort it estimated its
   approach required; rather, IBM increased its proposed staffing by 19,436
   hours. The CO assumed that EPA staff would be required to address any
   short-fall, and calculated the cost of the additional agency staff time
   and added the amount as an adjustment to IBM's evaluated price and cost.
   In contrast, the agency did not make any adjustments to CGI's proposal for
   EPA implementation resources.[6]

   Fourth, and finally, the EPA calculated that the agency would incur
   additional ongoing maintenance costs associated with the timing of IBM's
   plan to replace the agency's Integrated Financial Management System (IFMS)
   legacy application.[7] In this regard, for each of the legacy system
   applications, including IFMS, the RFP identified the agency's annual costs
   for operations and maintenance. Id. Offerors were required to identify the
   timeframe for replacement of legacy applications, and complete a chart
   indicating the agency's costs for continuing to provide support for the
   applications during the transition. Id. at 10-4. Although IBM stated that
   it would replace IFMS during the first stage of its proposed solution, the
   agency concluded that IFMS could not be replaced until the second stage of
   IBM's proposed solution. AR, Tab 41, SSD at 53-54. The EPA therefore
   determined that it would incur operations and maintenance costs during the
   additional time that the agency would be required to maintain IFMS.

   The CO's final evaluation of IBM's and CGI's price and cost proposal, with
   adjustments, was as follows:

+------------------------------------------------------------------------------+
|                                |          IBM          |         CGI         |
|--------------------------------+-----------------------+---------------------|
|PROPOSED PRICE[8]               |     $102,585,787      |     $84,083,464     |
|--------------------------------+-----------------------+---------------------|
|TOTAL COST OF OWNERSHIP[9]      |     $126,658,999      |    $110,482,570     |
|--------------------------------+-----------------------+---------------------|
|-- EPA Legacy System Costs      |      $17,266,664      |     $22,384,000     |
|--------------------------------+-----------------------+---------------------|
|-- EPA Resources                |      $4,680,060       |     $3,414,840      |
|--------------------------------+-----------------------+---------------------|
|-- PMO Resources                |      $2,126,488       |      $600,266       |
|--------------------------------+---------------------------------------------|
|COST REALISM ADJUSTMENTS[10]    |                                             |
|--------------------------------+---------------------------------------------|
|-- IMFS Retirement              |    $0 - $5,038,334    |      $249,344       |
|--------------------------------+-----------------------+---------------------|
|-- SCORPIOS Retirement          |      $1,250,000       |     $2,375,000      |
|--------------------------------+-----------------------+---------------------|
|-- SCORPIOS Replacement         |      $7,086,000       |     $2,942,540      |
|--------------------------------+-----------------------+---------------------|
|-- Tier III Hosting             |$6,000,000 - $7,313,829|         --          |
|--------------------------------+-----------------------+---------------------|
|-- Tier III Contingency         | $360,000 - $2,222,800 |         --          |
|--------------------------------+-----------------------+---------------------|
|-- EPA Resources, Hosting       |      $1,735,008       |       $98,736       |
|--------------------------------+-----------------------+---------------------|
|-- EPA Resources, Implementation|    $0 - $7,229,508    |         --          |
|--------------------------------+-----------------------+---------------------|
|-- PMO Contractor Hours         |          --           |$360,584 - $2,634,742|
|--------------------------------+-----------------------+---------------------|
|-- [deleted]                    |          --           |     $[deleted]      |
|--------------------------------+-----------------------+---------------------|
|-- Momentum Budgeting           |          --           |     $1,048,306      |
|--------------------------------+-----------------------+---------------------|
|-- BAS/IRMS                     |          --           |     $2,909,982      |
|--------------------------------+-----------------------+---------------------|
|-- Training                     |          --           |   $0 - $1,363,677   |
|--------------------------------+-----------------------+---------------------|
|-- Testing                      |          --           |      $500,000       |
|--------------------------------+-----------------------+---------------------|
|MOST PROBABLE COST[11]          |    $143,090,007 --    |   $120,967,063 --   |
|                                |                       |                     |
|                                |     $158,534,478      |    $125,004,898     |
+------------------------------------------------------------------------------+

   AR, Tab 41, SSD at 52.

   Based on her evaluations, the CO recommended that the contract be awarded
   to CGI. The CO concluded that CGI's technical proposal was "highly
   competitive with IBM, more so than even the 26.2 point differential over
   500 points would indicate due to the significantly greater performance and
   cost risks [associated with IBM's approach]." Id. at 72. With regard to
   the price or cost difference between the offerors, the CO stated that "the
   price savings of CGI's offer of $18.5 Million as proposed is likely to
   widen significantly when the Government considers total cost of ownership
   items such as EPA legacy system costs, EPA and [program management office]
   resource costs, and cost adjustments related to the realism of the
   offers." Id.

   The CO signed the selection decision on January 1, 2007, and presented it
   to the source selection authority (SSA) for his approval. In meetings on
   January 8 and 12, the SSA met with the TEP chair and other representatives
   of the Office of the Chief Financial Officer, who expressed concerns about
   the proposed selection decision and about the Office's view that IBM's
   proposal, and not CGI's, represented the best value to the government.
   Decl. of SSA, at 1-2; Decl. of TEP Chair, at 1. By memorandum, dated
   January 23, the TEP chair outlined his recommendation that the agency
   conduct additional discussions with the offerors. Decl. of TEP Chair, at
   1; AR, Tab 41, "FSMP Proposal Further Discussion Items." The TEP chair
   drafted a second memorandum, dated January 30, titled "Response to Source
   Selection Document," which further expressed the TEP chair's disagreement
   with the CO's award recommendation. Although the SSA reviewed the January
   23 memorandum, but not the January 30 memorandum, he states that he was
   fully aware of the concerns expressed about the proposed selection
   decision.[12] Decl. of SSA, at 1-2. The SSA approved the award to CGI by
   signing the selection decision on January 31. AR, Tab 41, SSD, at 73; see
   also Decl. of SSA, at 3. This protest followed.

   DISCUSSION

   IBM argues that the EPA improperly evaluated proposals, failed to conduct
   meaningful and equal discussions and, as a result, made an unreasonable
   selection decision. As discussed in detail below, we conclude that the
   agency improperly adjusted fixed-price elements of IBM's proposal and
   performed an unreasonable evaluation of CGI's price and cost proposal.
   With regard to IBM's allegations concerning the technical evaluation, we
   find that the record supports the agency's evaluation, and that the agency
   conducted meaningful discussions with IBM. Because of the flaws in the
   price and cost evaluation, however, we conclude that the selection
   decision was unreasonable.

   As a preliminary matter, our discussion of several of the issues set forth
   below necessarily addresses differences between the contemporaneous
   written record, and positions taken by the agency in response to the
   protest. While we consider the entire record in resolving a protest,
   including statements and arguments in response to a protest, in
   determining whether an agency's selection decision is supportable, we
   accord greater weight to contemporaneous evaluation and source selection
   materials than to new judgments made in response to protest contentions.
   Boeing Sikorsky Aircraft Support, B-277263.2, B-277263.3, Sept. 29, 1997,
   97-2 CPD para. 91 at 15. In this regard, we accord lesser weight to
   post-hoc arguments or analyses because we are concerned that judgments
   made "in the heat of an adversarial process" may not represent the fair
   and considered judgment of the agency, which is a prerequisite of a
   rational evaluation and source selection process. Id. In contrast,
   post-protest explanations that provide a detailed rationale for
   contemporaneous conclusions and simply fill in previously unrecorded
   details will generally be considered in our review of evaluations and
   award determinations, so long as those explanations are credible and
   consistent with the contemporaneous record. ITT Fed. Servs. Int'l Corp.,
   B-283307, B-283307.2, Nov. 3, 1999, 99-2 CPD para. 76 at 6. As discussed
   below, in several areas the agency's response to this protest is not
   supported by the contemporaneous record.

   Price and Cost Evaluation Issues

   The protester first argues that the EPA made improper "realism"
   adjustments to certain fixed-price elements of IBM's proposal, and failed
   to equally or reasonably evaluate CGI's proposal. As discussed above, the
   agency stated that it would perform both a cost realism and price realism
   analysis, as well as assess the "total cost of ownership" associated with
   offerors' proposals. In the discussion that follows, we address the
   adjustments that were made to IBM's proposal for SCORPIOS replacement,
   Tier 3 hosting requirements, EPA implementation efforts, and IFMS
   retirement costs. We conclude with a discussion of EPA's evaluation of
   certain elements of CGI's costs.

   A cost realism analysis is required when an agency evaluates proposals for
   the award of a cost-reimbursement contract. Under such a contract, an
   offeror's proposed costs are not considered controlling because,
   regardless of the costs proposed, the government is bound to pay the
   contractor its actual and allowable costs. Federal Acquisition Regulation
   (FAR) sections 15.305(a)(1), 15.404-1(d). Consequently, an agency must
   perform a cost realism analysis to determine the extent to which an
   offeror's proposed costs represent what the contract should cost, assuming
   reasonable economy and efficiency. FAR sect. 15.404-1(d)(2); Hanford
   Envtl. Health Found., B-292858.2, B-292858.5, Apr. 7, 2004, 2004 CPD para.
   164 at 8-9. Although there is no requirement that an agency perform a cost
   realism analysis when offerors propose to perform work on a T&M basis with
   fixed-price labor rates, agencies may, as here, provide for such an
   evaluation in a solicitation. Resource Consultants, Inc., B-290163,
   B-290163.2, June 7, 2002, 2002 CPD para. 94 at n.1. Cost realism may
   involve adjustments to proposed costs to calculate the most probable cost
   to the government of the offeror's proposed approach.

   In contrast, where an RFP contemplates the award of a fixed-price
   contract, or fixed-price portion of a contract, an agency may also provide
   in the solicitation for the use of a price realism analysis for the
   limited purpose of measuring an offeror's understanding of the
   requirements or to assess the risk inherent in an offeror's proposal.
   Puglia Eng'g of California, Inc., B-297413 et al., Jan. 20, 2006, 2006 CPD
   para. 33 at 6-7. Although the FAR does not use the term "price realism,"
   it provides that cost realism analysis may be used to evaluate fixed-price
   proposals as follows:

     Cost realism analyses may also be used on competitive fixed-price
     incentive contracts or, in exceptional cases, on other competitive
     fixed-price-type contracts when new requirements may not be fully
     understood by competing offerors, there are quality concerns, or past
     experience indicates that contractors' proposed costs have resulted in
     quality or service shortfalls. Results of the analysis may be used in
     performance risk assessments and responsibility determinations. However,
     proposals shall be evaluated using the criteria in the solicitation, and
     the offered prices shall not be adjusted as a result of the analysis.

   FAR sect. 15.404-1(d)(3).

   Thus, as the FAR explains, a price realism analysis may affect the
   technical evaluation, but cannot result in an adjustment of an offeror's
   proposed fixed prices. Id.; see also Puglia Eng'g of California, Inc.,
   supra; Verestar Gov't Servs. Group, B-291854, B-291854.2, Apr. 3, 2003,
   2003 CPD para. 68 at 6 n.3; Marquette Med. Sys., Inc., B-277827.5,
   B-277827.7, Apr. 29, 1999, 99-1 CPD para. 90 at 6. Specifically, an agency
   cannot make upward price adjustments for cost elements that the agency
   thinks may be priced too low. All Phase Environmental, Inc., B-292919.2 et
   al., Feb. 4, 2004, 2004 CPD para. 62 at 8.

   SCORPIOS Replacement

   The EPA determined that IBM's proposal for replacing the SCORPIOS legacy
   application required a cost adjustment to address the agency's concerns
   that IBM did not adequately understand the effort required. IBM contends
   that the adjustment was improper because its FPR clearly commits IBM to
   replace SCORPIOS at a fixed price.[13] We agree with IBM.

   The record shows that the agency did not reject or otherwise criticize
   IBM's technical proposal based on any deficiencies, weaknesses or lack of
   details regarding its proposal to replace SCORPIOS.[14] Specifically, the
   selection decision found that IBM's proposal under the Software Solution
   and Implementation subfactors met the RFP requirements, and the agency did
   not identify any concerns regarding SCORPIOS.[15] See AR, Tab 41, SSD at
   13-28. Instead, the criticism regarding SCORPIOS was expressed solely in
   the price and cost evaluation, in the form of an adjustment to IBM's
   proposed price.

   The CO explained during the hearing that she could not determine whether
   IBM's proposal was offering to replace SCORPIOS on a fixed-price or a T&M
   basis. Tr. at 125:16-126:4. Since the agency was concerned that SCORPIOS
   would have to be rebuilt, and that doing so would require approximately
   40,000 hours, it calculated the cost of that time as $7,086,000, using
   IBM's labor rates. AR, Tab 41, SSD at 54. Specifically, the CO was
   concerned that, although IBM proposed no costs associated with replacing
   SCORPIOS, the agency would be required to reimburse IBM the $7.1 million
   estimated cost to replace the application.[16] Tr. at 129:8-22.

   Our review of the record shows that IBM's proposal committed to replacing
   SCORPIOS. IBM's proposal stated that it "replaces 15 of 19 legacy
   applications including SCORPIOS." AR, Tab 27, IBM FPR, Vol. 3, at 3. IBM
   also identified SCORPIOS as being replaced in Release 2 of its proposed
   software solution. Id. at 9, Figures B-4, B-5. In addition, the record
   shows that the agency understood that IBM proposed to replace SCORPIOS on
   a fixed-price basis. The selection decision states that "IBM has proposed
   to perform the entire priced effort on a [fixed-price] basis. This
   excludes Tier 3 hosting which IBM did not price." AR, Tab 41, SSD at 69.
   Aside from Tier 3 hosting, the agency did not identify any other area of
   IBM's proposal that was not proposed on a fixed-price basis. The CO also
   testified at the hearing that she understood Release Two of IBM's
   solution, where SCORPIOS replacement would take place, to be proposed as
   part of the fixed price proposal. Tr. at 169:16-19.

   In sum, the EPA's criticism of IBM's approach to SCORPIOS replacement was
   focused primarily on IBM's understanding of the requirement and whether
   the firm would be able to perform the work. The contemporaneous record
   shows that the agency did not specifically challenge IBM's intent to
   perform the work on a fixed-price basis, but nonetheless adjusted IBM's
   proposed price based on the concern that there would be additional costs
   to the government. Because IBM proposed to replace SCORPIOS on a
   fixed-price basis, the agency's adjustment to IBM's price was improper. As
   the FAR and our cases make clear, an agency may account for concerns
   regarding an offerors' understanding of a requirement in the form of a
   performance risk evaluation, but may not adjust a fixed-price for purposes
   of evaluation.[17] FAR sect. 15.404-1(d)(3); Puglia Eng'g of California,
   Inc., supra, Verestar Gov't Servs. Group, supra; All Phase Environmental,
   Inc., supra. On this basis, we conclude that the cost and price adjustment
   here was improper.

   Tier 3 Hosting Requirements

   As discussed above, the EPA concluded that IBM's proposal for Tier 3
   hosting, which was offered on a T&M basis, required a cost adjustment
   because IBM estimated $0 for this effort. Tier 3 hosting involved two
   categories of change requirements for offerors' software solutions:
   contractor-driven changes and government-driven changes.

   With respect to contractor-driven changes, the agency determined that
   IBM's proposal required certain major releases, or upgrades, to its
   software solution, but did not include any costs in its T&M proposal for
   Tier 3 hosting to provide these releases. As mentioned earlier, IBM's FPR
   changed its Tier 3 hosting approach from a fixed-price proposal to a T&M
   proposal, and estimated $0 for the effort. AR, Tab 27, IBM FPR, Vol. 5, at
   13. The agency thus concluded that IBM's proposal posed a risk because its
   solution stated that major releases would be required, but identified no
   costs associated with the effort. Id. 54-55; Vol. 3, at 80-81. The
   protester argues that no adjustment was needed because its proposal stated
   that, with the exception of government-driven, all other Tier 3 changes
   would be provided under Tier 2. Protester's Comments on the Agency Report,
   at 42-43; Protester's Post-Hearing Comments, at 31-32.

   In our view, IBM's proposal did not clearly establish that it would
   provide the required major releases under the fixed-price portion of its
   proposal for Tiers 1 or 2. Thus, we conclude that the EPA, consistent with
   the evaluation scheme, reasonably determined that an adjustment to IBM's
   T&M proposal was necessary to reflect the cost of contractor-driven
   changes under the Tier 3 hosting requirements. We also think the agency's
   adjustment for contingency costs related to Tier 3 hosting was similarly
   reasonable, in that it was based on RFP requirements for contingency
   allowances. To the extent that IBM believes that the EPA misevaluated its
   proposal in this regard, the protester has not demonstrated that the
   agency's evaluation was unreasonable. A protester's mere disagreement with
   the agency's judgment in its determination of the relative merit of
   competing proposals does not establish that the evaluation was
   unreasonable. Synectic Solutions, Inc., B-299086, Feb. 7, 2007, 2007 CPD
   para. 36 at 7.

   The protester next argues that the agency's evaluation of required major
   releases under Tier 3 was unequal, because the agency ignored a similar
   concern regarding CGI's proposal. We agree. CGI's proposal expressly
   limited the amount of Tier 3 hosting services it would provide on a
   fixed-price basis. Specifically, the proposal advised that "Team CGI
   included [deleted] minor releases over the course of the 10 year contract.
   [deleted]." AR, Tab 28, CGI FPR, Vol. 5, at 17. As the agency evaluators
   concluded, "CGI has clearly bounded the scope of the services by
   specifying that the Tier 3 work is limited to [deleted] `minor releases.'"
   AR, Tab 38, TEP Final Price and Cost Report, at 16.

   Put differently, CGI's approach, on its face, excluded any future major
   releases. Despite this exclusion of major releases, CGI's proposal
   explained:

     [deleted]

   AR, Tab 28, CGI FPR, Vol. 2, at 2-86, Table 5.

   The TEP identified this discrepancy between CGI's proposal's anticipated
   need for major releases, and its limitation of Tier 3 upgrades to "minor
   releases," as a concern. Specifically, the TEP advised that "[s]ince the
   distinction is not abundantly clear between a major and minor release, EPA
   may incur a cost impact if a major release is required." AR, Tab 38, TEP
   Final Price and Cost Report, at 16. During the hearing, the TEP evaluator
   stated that the TEP understood that if a major release were required over
   the 10-year potential term of the contract, CGI's proposed fixed-price
   would not cover such an event.[18] Tr. at 420-21, 424. Nonetheless, the
   selection decision did not address the TEP's concern regarding this
   issue.[19] As a result, we agree that the evaluation of CGI's proposal was
   unreasonable to the extent that the agency did not resolve this concern,
   i.e., whether CGI's "bounded" proposal for Tier 3 hosting met the
   solicitation requirements for major releases.

   As to the second category under Tier 3 hosting, government-driven changes,
   the agency concluded that an adjustment to the T&M portion of IBM's
   proposal was required. In this regard, the agency clearly advised offerors
   that certain government-driven changes would be required during contract
   performance, and IBM stated that it would provide those changes on a T&M
   basis as directed--but provided an estimate of $0 for the effort. As with
   the first category of changes, we find that IBM has not established how it
   will provide government-driven changes within the context of the $0
   estimate for the effort. We thus conclude that some adjustment by the
   agency to IBM's proposal to account for government-driven changes was
   reasonable.

   As to the quantum of the adjustment for both categories of changes,
   however, we conclude the agency did not have a rational basis for the
   adjustments it made. The agency made two adjustments to IBM's Tier 3
   proposal: a $6,000,000 - $7,313,829 adjustment for Tier 3 hosting, and a
   $360,000 - $2,222,800 adjustment for the contingency reserve for Tier 3.
   AR, Tab 41, SSD at 54-55. The agency made no adjustments to CGI's
   proposal.

   The record indicates that the EPA never calculated a most probable cost
   for either category of the potential Tier 3 costs. Rather, in the case of
   IBM, the agency simply added back to IBM's proposal certain of the costs
   deleted from its FPR. Id. at 55, n.190. The record does not show that the
   agency had any support for this adjustment. Tr. at 206:15-207:9;
   389:12-390:15. For this reason, we conclude the quantum of the adjustment
   to IBM's proposal is not supported by the record.

   Additionally, because the EPA did not have a clear understanding of the
   scope of the government-driven changes required as part of Tier 3 hosting,
   the agency had no basis to determine whether CGI's limited commitment to
   perform Tier 3 hosting met all of the solicitation requirements.[20] Thus,
   we find that the agency's evaluation of CGI's proposal is not supported by
   the record

   EPA Implementation Resources

   The EPA determined that for the implementation effort, IBM's proposal did
   not adequately explain a change to its assumptions regarding the level of
   effort that the agency would provide to support IBM's proposed solution.
   IBM contends the adjustment was improper because, regardless of the
   estimated level of hours it identified in its proposal for the agency and
   for itself, IBM still committed to perform the implementation work on a
   fixed-price basis. We agree with IBM.

   As discussed above, offerors were required to state their assumptions
   regarding the level of effort the agency would provide to support the
   offerors' solutions. During discussions, the agency advised offerors that
   it would limit the support provided by EPA staff to 20 FTEs per year for
   the implementation effort. The agency acknowledges that IBM's FPR
   appropriately reduced the number of EPA hours proposed from 214,000 to
   85,026 for the term of the contract, to reflect the 20 FTE level
   identified during discussions. Agency Post-Hearing Comments, at 14. While
   IBM decreased EPA staffing hours by 128,974 hours, it increased its own
   staffing by only 19,436 hours. The EPA determined that an adjustment to
   IBM's proposal was required because IBM did not adequately explain how it
   would perform the work under its proposal in light of the revised
   staffing. Specifically the agency concluded that because IBM did not
   increase its own staffing to cover the reduction in the EPA staffing
   effort, the agency would be required to make up the difference by
   providing more EPA staff resources. AR, Tab 41, SSD at 57.

   The CO calculated the adjustment to IBM's proposal based on the difference
   between the original hours proposed by IBM, less the increase in IBM staff
   hours, multiplied by a rate of $66 per hour established for EPA personnel.
   Id. On this basis, the CO concluded that "the value of this effort, if
   needed and ultimately performed by EPA staff, would be approximately
   $7,229,508 [] dollars. Therefore the CO has established a range for the
   probable cost impact of $0 to $7,229,508." Id.

   We find that the agency's adjustment was improper because the agency
   unreasonably assumed, given IBM's proposal commitments, that agency
   personnel would be required to perform any additional needed work.[21]
   This conclusion was not reasonable because IBM's FPR assumptions
   identified a specific number of hours to be provided by the agency during
   implementation, and thereby left the balance of the implementation effort
   to be performed under IBM's fixed-price proposal. Thus regardless of the
   number of hours IBM estimated for its own effort, it would still be
   required to perform at its fixed-price. We conclude that the agency's
   evaluation was unreasonable because: (1) EPA ignored the fixed-price
   nature of IBM's proposal, and (2) the adjustment made--regardless of how
   it is categorized--was not supported by the record.[22]

   IFMS Retirement

   The CO determined that IBM's proposal for replacing EPA's Integrated
   Financial Management System required a cost adjustment to reflect
   additional costs the agency would incur in maintaining that application
   during the transition to IBM's software solution. IBM argues that the
   adjustment was improper because the agency did not establish the
   likelihood that the agency would incur additional costs with sufficient
   certainty. We agree with the agency.

   The EPA's "total cost of ownership" assessment evaluated the costs to the
   agency for maintaining legacy system applications such as IFMS, during the
   contractor's transition to its solution. The selection decision noted that
   although "IFMS will be retired during the second year of the contract"
   there were "inconsistencies between when and how accounts receivable and
   Project/Cost functions would be implemented." AR, Tab 41, SSD at 53-54.
   These two required functions are currently provided through IFMS. Id. at
   54. The agency's concern, therefore, was that although IBM's proposal
   stated that costs to the agency for IFMS would terminate by the end of
   Release One of IBM's software solution, the fact that the two functions
   would not be provided under the solution until Release Two, meant that the
   agency would continue to incur expenses in providing those functions
   through IFMS.

   Under IBM's proposal, Release One is scheduled for months 1 through 14 of
   contract performance, and Release Two is scheduled for months 15 through
   29. AR, Tab 27, IBM FPR, Vol. 3, at 30-31. IBM's proposal stated that IFMS
   will be replaced in Release One of the IBM solution. IBM FPR, Vol. 3, at
   9, Figure B-4. The agency concluded that the retirement of IFMS would take
   place in month 14 of the contract, based on IBM's calculation of legacy
   costs for the agency, which terminated at that time.[23] AR, Tab 27, IBM
   FPR Vol. 5, at 41, Table C-19. The technical volume of IBM's proposal,
   however, states that the accounts receivable and project/cost functions
   will be replaced in Release Two of the IBM solution. IBM FPR, Vol. 3, at
   9-10, Figures B-5, B-6.

   We conclude that the agency reasonably identified a cost risk on the
   grounds that "it is not clear from IBM's proposal that this functionality
   will be available prior to [IBM's software] Release 2." AR, Tab 41, SSD at
   54. The agency assessed a "range for net cost risk of $0 to $5,038,334"
   for agency operations and maintenance costs through Release Two.[24] Id.
   On this record, we conclude that the adjustment of IBM's total cost of
   ownership to the agency for continued IFMS legacy costs was reasonable and
   consistent with the RFP's evaluation scheme, given IBM's proposed schedule
   for IFMS retirement.[25]

   Other CGI Costs

   The protester also alleges that the EPA unreasonably evaluated several
   aspects of CGI's proposal. As discussed below, we conclude that the
   agency's evaluation of CGI's proposal was unreasonable only regarding the
   [deleted] of its software solution; we deny the remaining IBM challenges
   to the EPA's evaluation of CGI's price and cost proposal.

   CGI proposed to provide its proprietary Momentum software solution to
   perform the FMSP contract; [deleted] CGI's Momentum software. AR, Tab 28,
   CGI FPR, Vol. 2, at 2-104-05. In its proposal, CGI stated that it will
   [deleted]. Id. at 2-105. As discussed above, CGI's proposal for Tier 3
   hosting was limited to providing [deleted] "minor releases" to its
   software. Id., Vol. 5, at 17. In contrast, CGI's proposal identified a
   "major release" as "[deleted]." Id., Vol. 2, at 2-86, Table 5. CGI's
   fixed-price proposal for Tier 3 hosting included upgrades to Momentum
   [deleted] as part of the [deleted] minor releases. See Tr. 468:3-469:3;
   AR, Tab 28, CGI FPR, Vol. 3, at B-73-74.

   In its final technical report, the TEP concluded that CGI's [deleted] was
   a strength. AR, Tab 31, TEP Final Technical Report, at 17. In its final
   price and cost report, however, the TEP concluded that CGI's approach
   posed other risks because "CGI will have to [deleted]," and that the risks
   posed a likely cost risk to the agency. AR, Tab 38, TEP Final Price and
   Cost Report, at 11. The TEP was concerned that if the [deleted] required
   CGI to "[deleted]," then the effort might be a "major release" that was
   outside the scope of CGI's fixed-price proposal for Tier 3 hosting. Tr. at
   473:14-23, 475:2-476:7, 476:13-477:13. The TEP concluded that the likely
   cost risk to the government would "not be less than" $[deleted]. AR, Tab
   38, TEP Final Price and Cost Report, at 11.

   In the selection decision, the CO agreed with the TEP that CGI's proposed
   cost should be adjusted to account for the [deleted] risk. AR, Tab 41, SSD
   at 59-60. The CO determined, however, that because CGI had already
   proposed to provide software upgrades in its fixed-price proposal for Tier
   3 hosting, the cost risk would only be $[deleted], i.e., the difference
   between the TEP's estimate of $[deleted] for [deleted] and the $[deleted]
   that CGI had already proposed for Tier 3 hosting. Id.

   We conclude that the CO's determination was unreasonable because it did
   not address the TEP's concern that CGI's proposal to [deleted] was an
   upgrade that might not be covered by its existing Tier 3 hosting
   proposal.[26] The TEP believed that CGI's [deleted] posed an additional
   $[deleted] in cost risk because that effort might constitute a "major,"
   rather than a "minor" release. Thus, it was unreasonable for the CO to
   conclude that CGI's existing Tier 3 proposal, which by its terms covered
   only "minor releases," addressed that cost risk. In this regard, the CO
   did not dispute the $[deleted] cost risk concern, but rather believed
   without any support that this amount would be absorbed by CGI's Tier 3
   proposal. Although the CO here accepted the TEP's cost risk estimate of
   $4.3 million for [deleted], she had no basis to conclude that the actual
   risk would be limited to $[deleted].

   In sum we conclude that the EPA's evaluation of IBM and CGI's price
   proposals was flawed and sustain the protest on this basis. Our review of
   the record shows that the agency should not have included "adjustments" to
   IBM's proposed price/cost as follows: (1) SCORPIOS Replacement, and (2)
   EPA Resources, Implementation. These two errors lead to a reduction of
   between $7,086,000 to $14,315,508 in IBM's "most probable cost." The
   agency's evaluation of CGI's price and cost proposal for providing Tier 3
   hosting was also flawed because it did not consider CGI's proposal with
   regard to the need for major releases. In addition, the agency did not
   have a clear basis for determining the size of the adjustment for Tier 3
   hosting for either offeror's proposal. Finally, we conclude that the
   agency's evaluation of CGI's proposal to [deleted] was unreasonable.[27]

   Technical Evaluation Issues

   IBM raises several challenges to the EPA's evaluation of its proposal, and
   argues that the agency treated the offerors unequally. We have considered
   all of the allegations regarding the technical evaluation, and find that
   none warrant sustaining the protest.

   For example, the protester contends that the agency's evaluation of its
   proposal under the personnel subfactor of the management approach
   evaluation factor was flawed because it unreasonably criticized the
   staffing approach for project managers.

   The EPA's evaluation of IBM's proposal concluded that IBM had proposed
   approximately 14,000 hours for the project manager labor category over the
   24-month implementation period, but that IBM had identified only two
   individuals with a project manager title. AR, Tab 41, SSD at 43; Tr. at
   335:12-15. Thus, the contacting officer concluded that IBM's proposed
   staffing of two identifiable project managers did not provide an adequate
   approach to filling the hours it proposed. This issue--whether the project
   managers proposed could perform the 14,000 hours identified in IBM's
   proposal--was the sole criticism discussed regarding IBM's proposal under
   the personnel subfactor, and led to IBM's score of 11.2 out of 28 possible
   points for the personnel element of the management approach subfactor.[28]

   During the hearing, the CO explained the she relied on IBM's technical
   proposal to determine the hours proposed for the project manager position.
   Tr. at 348:14-20; see also AR, Tab 41, SSD at 43, Tab 31, TEP Final
   Technical Report, at 61. The CO states that she also relied on the TEP
   Final Technical Report on IBM's technical proposal, but also independently
   calculated the hours in IBM's technical proposal for her conclusion. Tr.
   at 336:12-338:8.

   The protester points to a disagreement between the CO and TEP regarding
   the staffing proposed in IBM's Price and Cost proposal. AR, Draft TEP
   Final Price and Cost Report, Dec. 8, 2006, at 26-27. We conclude the CO
   reasonably relied on the information in the technical proposal for
   purposes of evaluating the personnel element, and the protester does not
   provide a reasonable basis to challenge the CO's analysis regarding that
   proposal.

   To the extent that the protester argues that its own proposal was
   inconsistent as between its technical and price and cost volumes, and that
   the CO should have relied on the more favorable of the two possible
   interpretations under its proposal, we disagree. It is an offeror's
   responsibility to submit a well-written proposal, with adequately detailed
   information, which allows a meaningful review by the procuring agency.
   CACI Techs., Inc., B-296946, Oct. 27, 2005, 2005 CPD para. 198 at 5. In
   this regard, the CO noted that the RFP required offerors' technical and
   price proposals to match regarding areas such as proposed staffing, and
   that the protester's proposal did not do so. Tr. at 347:16-348:13.

   Discussions

   The protester next argues that the EPA failed to conduct meaningful
   discussions regarding several issues. The record, however, does not
   support the protester's allegations with regard to any of the areas where
   it argues that the agency failed to provide meaningful discussions.

   For example, IBM argues that it was misled during discussions regarding
   page limitations. Specifically, IBM claims that the agency advised IBM
   that Volume 3 of its proposal exceeded the page limitation, but orally
   advised that IBM could include additional pages regarding its work
   breakdown structure (WBS) and integrated master plan (IMP) in Volume 5,
   rather than Volume 3 of its proposal--despite the fact that the RFP
   expressly required that these matters be addressed in Volume 3. IBM
   contends that it relied on the agency's advice and placed those items in
   Volume 5, which, unlike Volume 3, had no page limitations. In evaluating
   IBM's proposal, the agency did not provide the WBS and IMS documents to
   the evaluators because they were not contained in Volume 3; the agency
   evaluators concluded that the absence of a detailed WBS and IMP
   constituted a weakness in the proposal. AR, Tab 41, SSD at 23.

   The protester argues that the agency's discussions here were misleading,
   and therefore not consistent with the agency's obligation to ensure that
   discussions are meaningful. See L-3 Comm. Corp., BT Fuze Prods. Div.,
   B-299227, B-299227.2, Mar. 14, 2007, 2007 CPD para. __ at 18-19. The
   agency denies making such a statement, and notes that such instructions
   would have been contrary to the RFP instructions.

   Because the allegedly misleading agency statements would have resulted in
   a material deviation from the solicitation, namely the page limitation,
   the protester could not reasonably rely on such oral advice--even if the
   record demonstrated that the agency made such a statement, which it does
   not. S3 LTD, B-287019.2 et al., Sept. 14, 2001, 2001 CPD para. 165 at 6.
   Offerors cannot rely on oral modifications to an RFP which are
   inconsistent with its written terms, absent a written amendment to the RFP
   or written confirmation of the oral modification. Id. This clear principle
   provides fairness to all parties by ensuring that competitions are
   conducted under equal terms, and protects both protesters and agencies
   from the kind of credibility disputes raised here, as well as protecting
   the integrity of the procurement process overall. Id.

   Selection Decision

   The selection decision states that the difference between the offerors'
   proposals was $18.5 million, and that the difference was "likely to widen
   significantly." AR, Tab 41, SSD at 72. The record shows, as discussed
   above, that the agency's adjustments to the offerors' price and cost
   proposals had numerous errors that materially affected the evaluation. In
   addition, the agency's evaluation of Tier 3 hosting was flawed because the
   agency lacked a clear basis for the adjustments to IBM's proposal and
   because of the errors regarding the evaluation of CGI's proposal. The
   agency's evaluation of CGI's proposal regarding [deleted] was also flawed.
   Moreover, the selection decision relied upon its determination that IBM's
   proposal presented "significantly greater performance and cost risks" as
   compared to CGI--a determination that may no longer be valid given the
   evaluation errors discussed above. AR, Tab 41, SSD at 72. Because these
   evaluation errors in the selection decision result in a material change to
   the relative difference between the evaluated price and cost of these
   proposals, we conclude that IBM was prejudiced and thus the selection of
   CGI's proposal for award cannot stand. See McDonald Bradley, B-270126,
   Feb. 8, 1996, 96-1 CPD para. 54 at 3; Statistica, Inc. v. Christopher, 102
   F.3d 1577, 1581 (Fed. Cir. 1996).

   CONCLUSION AND RECOMMENDATION

   We recommend that the EPA reevaluate offerors' proposals, consistent with
   this decision. We further recommend that the agency reexamine its
   requirements regarding its SCORPIOS application, and provide offerors an
   opportunity to revise their proposals if the agency believes, as it now
   argues, that neither offeror's proposed software solution is suitable for
   addressing the agency's requirements currently met by the SCORPIOS
   application. At the conclusion of this process, we recommend that the
   agency make a new source selection decision.[29] If CGI is not determined
   to offer the best value to the government, the agency should terminate
   CGI's contract for the convenience of the government.

   We also recommend that IBM be reimbursed the costs of filing and pursuing
   this protest, including reasonable attorney fees. Bid Protest Regulations,
   4 C.F.R. sect. 21.8(d)(1) (2007). IBM should submit its certified claim
   for costs, detailing the time expended and cost incurred, directly to the
   contracting agency within 60 days after receipt of this decision. 4 C.F.R.
   sect. 21.8(f)(1).

   The protest is sustained.

   Gary L. Kepplinger
   General Counsel

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

   [1] Hosting generally means storing and maintaining software or data on
   one computer, and allowing other computers to access it.

   [2] The technical merit evaluation factor had three subfactors: (1)
   technical and functional, with three elements--(i) software solution, (ii)
   implementation, and (iii) hosting; (2) experience and past performance,
   with two elements-- (i) organizational experience, and (ii) past
   performance; and (3) management approach, with two elements--(i) approach,
   and (ii) personnel. The oral presentations and solution demonstration
   evaluation factor had two subfactors: (1) oral presentation; and (2)
   solution demonstration, with four elements-- (i) business scenarios, (ii)
   ability to satisfy the goals of the FSMP, (iii) navigation and ease of
   use, and (iv) effectiveness of the offeror's team. RFP at M-2-M-8.

   [3] Although the RFP requested that offerors submit "price" proposals, the
   record of the agency's evaluation of proposals refers to both price and
   cost proposals, and price and cost evaluations. Here, we use the term
   "price and cost" to refer to both the proposals and the evaluations.

   [4] The protester does not challenge adjustments to its proposed price or
   cost that are not identified here.

   [5] Our Office conducted a hearing on May 8-9, 2007 to further develop
   certain protest issues. We took the testimony of the contracting officer
   and a TEP evaluator who was designated by the agency as a witness who
   could address issues regarding that panel.

   [6] For the record, EPA's adjustment for implementation costs blurs the
   distinction between a realism adjustment and an assessment of costs that
   the government will incur for its own required efforts. Specifically, the
   EPA lists the adjustment in the selection decision as a realism increase
   to IBM's price; however, the agency calculates the adjustment as the cost
   of additional EPA personnel required to assist with the implementation.

   [7] IFMS is the EPA's core financial system. It supports budget and
   accounting functions, such as updating ledgers and preparing financial
   statements and budget reports. RFP attach. 1, EPA Legacy System Table, at
   10-2.

   [8] As noted above, these proposals contained both fixed-price and T&M
   components.

   [9] The total cost of ownership in the chart above is comprised of the
   offerors' proposed price and cost, plus the agency's estimated amounts for
   resources the agency would need to provide for EPA legacy system operation
   and maintenance, EPA resources, and program management office contractor
   (PMO) costs.

   [10] The items listed as "cost realism adjustments" in the chart above are
   the adjustments made by the agency to the offerors' proposals, including
   cost realism adjustments to offerors' time and materials and fixed-price
   proposal elements, and additional total cost of ownership adjustments
   which were not included in the previous category. Several categories, and
   the totals, reflect a range of the agency's estimate of probable costs.

   [11] The most probable cost is comprised of the offeror's proposed price
   and cost, the total cost of ownership, and all of the cost realism
   adjustments.

   [12] During the protest, the parties have disputed the accuracy and
   relevance of this second memorandum, which purports to identify numerous
   flaws and uncertainties in the selection decision. As, discussed below, we
   conclude that the record shows that the agency's evaluation of offerors'
   price and cost proposals was flawed, and that these flaws had a material
   effect on the award decision. We need not address the parties' contentions
   regarding the validity or relevance of the TEP chair's criticisms of the
   selection decision.

   [13] The protester does not challenge the agency's evaluation of costs
   associated with the retirement of SCORPIOS, as opposed to these challenges
   of the replacement costs.

   [14] The RFP did not require offerors to provide SCORPIOS functionality,
   nor did it require offerors to replace SCORPIOS. The RFP did not discuss
   SCORPIOS in the "Concept of Operations" summary detailing the agency's
   requirements, RFP attach. 4, and did not identify SCORPIOS in the list of
   requirements in the minimum requirements matrix.

   [15] The agency notes that the RFP required offerors to provide a detailed
   approach linking the cost or price proposals to specific areas of
   offerors' technical proposals. Tr. at 121:7-22 (citing RFP attach. 5,
   sect. 1.2.5). During the hearing, the CO and the TEP evaluator also stated
   that the agency believed that neither IBM nor CGI could perform the work
   because the functionality for SCORPIOS was inherently beyond the scope of
   the financial management software solutions proposed by the offerors. Tr.
   at 159:8-14, 563:18-22, 589:20-590:17.

   [16] With regard to CGI's proposal, the contracting officer's concerns
   were essentially the same. AR, Tab 41, SSD, at 58-59. Although CGI
   estimated that the replacement effort would require 10,060 hours, the
   agency increased CGI's cost for this effort to the 40,000 hours estimated
   by the TEP. Id. at 59.

   [17] In some respects, IBM's proposal appears analogous to a below-cost
   offer to the extent that SCORPIOS replacement was added to IBM's FPR,
   without a clear increase to the fixed price. The fact that a firm, in its
   business judgment, submits an offer that may not include any profit or be
   below-cost, or may be an attempted buy-in, does not render the firm
   ineligible for award. All Phase Environmental, Inc., supra; McDonnell
   Douglas Corp., B-259694.2, B-259694.3, June 16, 1995, 95-2 CPD para. 51 at
   9. This is so because below-cost pricing is not prohibited and the
   government cannot withhold an award from a responsible offeror merely
   because its low offer is, or may be, below cost. All Phase Environmental,
   Inc., supra. To the extent the agency wanted to question IBM's willingness
   to perform or its responsibility (which would have involved an inquiry
   about IBM's capability to absorb these costs itself) the agency could have
   done so. What the agency could not do in conducting a price realism
   analysis, was make upward price adjustments for cost elements that the
   agency thinks may be priced too low. Id.

   [18] To the extent that the agency stated in the SSD that IBM's proposal
   is technically unacceptable because of the failure to propose costs for
   Tier 3 hosting, AR, Tab 41, SSD at 72, this criticism would appear to
   apply in equal force to CGI based on that offeror's failure to include
   major releases in its Tier 3 proposal.

   [19] CGI argues in its comments on the hearing that it is not certain that
   CGI's software would require a major release, and that, in any event,
   CGI's proposed [deleted] would address such concerns. CGI Post-Hearing
   Comments, at 26-27. However, the contemporaneous record does not show that
   the agency considered these arguments in evaluating CGI's proposal, or
   otherwise understood CGI's proposal in the manner now advanced in CGI's
   comments.

   [20] The record here suggests that CGI's proposal for [deleted] may cover
   government-driven changes. See AR, Tab 28, CGI FPR, Vol. 3, at B-73. To
   the extent that the agency believed, however, that there would be certain
   government-driven changes required under Tier 3, CGI's proposal does not
   appear to address this requirement. The contracting officer did not
   discuss CGI's Tier 3 proposal in the price and cost evaluation, and thus
   there is no record as to whether the agency ever determined whether CGI's
   proposal provided Tier 3 hosting for government-driven requirements.

   [21] As the protester notes, the EPA determination conflicts with its own
   statement to offerors that the agency would not be able to provide more
   than 20 FTEs per year in support of implementation.

   [22] The agency also argues that certain limitations in IBM's proposal
   meant that a reduction to EPA staff hours would not be made up by IBM
   efforts under the fixed-price portion of its proposal. See Agency
   Post-Hearing Comments at 14-15. We do not believe that this post-protest
   argument provides a basis to support the agency's evaluation here.
   Although the agency now points to several areas of IBM's proposal
   suggesting limitations, this analysis is not reflected in the
   contemporaneous record, and the agency does not argue that the CO
   considered these issues at the time of the evaluations.

   [23] IBM's proposal lists IFMS legacy costs for the first 12 months as
   $6,100,000, and $1,016,666 for the second 12 months--the agency noted that
   the second figure was the same annual rate as the first 12 months,
   prorated to cover only the first 2 months of the second year. AR, Tab 41,
   SSD at 54.

   [24] The $5,083,334 figure was the difference between the $6,100,000
   identified in the RFP for a 12-month period of agency IFMS costs, and the
   $1,016,666 for 2 months already contained in IBM's proposal for the second
   year of performance. AR, Tab 41, SSD at 54 n.182.

   [25] The adjustment for IMFS can be distinguished from the agency's
   adjustment for EPA implementation resources. The IFMS adjustment concerned
   a cost for the agency's own efforts that the RFP advised offerors would be
   considered; the implementation adjustment addressed IBM's assumptions
   regarding the level of effort its proposal would require from the agency
   personnel. We conclude that the EPA implementation adjustment was
   unreasonable because IBM had stated that it would perform the
   implementation work on a fixed price basis; thus any reduction in staffing
   from EPA would be required to be performed by IBM under the terms of its
   fixed-price proposal.

   [26] The contracting officer also noted that CGI's proposed [deleted]
   cover the $[deleted] value. AR, Tab 41, SSD at 59-60. We note that the
   $[deleted] would almost cover the $[deleted] adjustment identified by the
   contracting officer, but would not cover the $[deleted] concern identified
   by the TEP.

   [27] The protester has also raised various issues regarding certain other
   price and cost errors regarding the evaluation of offerors' proposals. We
   have reviewed all of the protester's arguments, and conclude that only
   those identified above provide a basis to sustain the protest.

   [28] During the hearing, the TEP evaluator confirmed that the project
   manager hour issue was the TEP's "predominant" concern regarding IBM's
   proposal under this subfactor. Tr. At 607:3-22.

   [29] The protester also requests that we recommend that EPA's Office of
   the Chief Financial Officer have significant input into any future source
   selection decisions. In our view, this is a matter within the agency's
   discretion; we will not make specific recommendations regarding the
   staffing or composition of a source selection team absent circumstances
   not present here, such as clear evidence of bad faith on the part of the
   agency. See, e.g., Beneco Enters., Inc., B-283512.3, July 10, 2000, 2000
   CPD para. 176.