TITLE: B-311074, ManTech International Corporation, April 15, 2008
BNUMBER: B-311074
DATE: April 15, 2008
***********************************************************
B-311074, ManTech International Corporation, April 15, 2008

   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: ManTech International Corporation

   File: B-311074

   Date: April 15, 2008

   Paul F. Khoury, Esq., William J. Grimaldi, Esq., John R.Prairie, Esq., and
   Brian G. Walsh, Esq., Wiley Rein, for the protester.

   Anne Perry, Esq., Jonathan Aronie, Esq., and Daniel Marcinak, Esq.,
   Sheppard Mullin, for Analex Corporation, the intervenor.

   Vincent A. Salgado, Esq., Daniel Hymer, Esq., and Laura M. Giza, Esq.,
   National Aeronautics & Space Administration, for the agency.

   David A. Ashen, Esq., and John M. Melody, Esq., Office of the General
   Counsel, GAO, participated in the preparation of the decision.

   DIGEST

   Protest by incumbent contractor that evaluation of offerors' proposed
   approaches to phase-in at start of contract failed to account for
   incumbency advantage is denied where agency recognized that incumbent
   protester's policies and incentives, reflected in 95 percent employee
   retention rate, had a high probability of maintaining incumbent workforce,
   thereby significantly reducing transition risk and warranting a
   significant strength, and also reasonably determined that awardee offered
   an exceptional strategy, with many incentives for incumbent employee
   retention, in support of plan to recruit [REDACTED] percent of incumbent
   workforce, thereby also warranting a significant strength.

   DECISION

   ManTech International Corporation protests the National Aeronautics and
   Space Administration's (NASA) award of a contract to Analex Corporation,
   under request for proposals (RFP) No. NNG06160944R, for Environmental Test
   and Integration Services (ETIS) at Goddard Space Flight Center (GSFC) in
   Greenbelt, Maryland. ManTech challenges the evaluation of proposals.

   We deny the protest.

   BACKGROUND

   GSFC functions as an end-to-end research and development laboratory for
   the development and operation of scientific instruments, spacecraft, space
   shuttle payloads, sounding rockets, balloons, satellite servicing, and
   supporting ground systems. RFP Statement of Work (SOW) sect. I. The
   solicitation contemplated award of a cost-plus-award-fee
   indefinite-delivery/indefinite-quantity contract, with a 5-year ordering
   period, to furnish environmental test and integration services, including
   structural dynamics testing; electromagnetic testing; space simulation
   testing; optical fabrication, assembly and testing; mechanical integration
   of space flight components into spacecraft; thermal blankets; and facility
   maintenance.

   Award was to be made to the offeror whose proposal represented the "best
   value" to the government, RFP sect. M.2; Federal Acquisition Regulation
   sect. 15.303(b)(6), based on three evaluation factors: (1) a
   numerically-scored mission suitability factor, which included subfactors
   for response to a representative task order (RTO)/understanding the
   requirements of the SOW (500 of 1,000 available points), management plan
   (300 points), safety and health plan (150 points), and small disadvantaged
   business participation (50 points); (2) cost; and (3) past performance.
   Overall, mission suitability was more important than cost, which was more
   important than past performance; cost was significantly less important
   than mission suitability and past performance combined. RFP sect. M.2.

   The solicitation RTO response requirement was of particular importance in
   the evaluation. In this regard, the solicitation as amended required
   offerors to furnish a written task plan responding to generic sample
   problems organized into 14 subtasks to be performed over a 6-month period;
   the response to the RTO was to "serve as a basis for the evaluation of how
   the offeror will carry out the tasks associated with the SOW," with the
   offeror being evaluated on "how it will implement and staff the RTO." RFP,
   Amend. 005, sect. M.3. The 14 subtasks were organized as follows:
   (1) environmental test of a spacecraft bus; (2) mechanical integration
   operations; (3) certification of an overhead crane; (4) optical
   integration support; (5) procurement of a thermal vacuum chamber;
   (6) advanced manufacturing tasks; (7) electrical cable harness
   fabrication; (8) design, fabrication and installation of thermal blankets;
   (9) ensuring safety requirements are satisfied for the subtasks;
   (10) facility maintenance; (11) contamination control and cleanroom
   operations; (12) information systems support for the test of a spacecraft;
   (13) integration and test engineering support; and (14) quality assurance
   and management support required for the other subtasks. The solicitation
   further provided that offerors' responses to subtasks (1) environmental
   test, (2) mechanical integration, (10) facility maintenance,
   (11) contamination control, (13) integration and test engineering support,
   and (14) quality assurance and management support, should include a
   "narrative response demonstrating the offeror's understanding of all
   referenced SOW [Work Breakdown Structure] content." RFP, Amend. 005, sect.
   L.12. In addition, a cost realism analysis was to be performed with
   respect to the overall proposed cost for the RTO; in the event that the
   proposed cost was adjusted upward or downward for cost realism by at least
   10 percent, the solicitation provided for a downward point adjustment to
   be made to the offeror's mission suitability score. RFP sections M.3, M.4.

   Analex, Mantech (the incumbent contractor), and Jacobs Technology, Inc.
   submitted proposals in response to the RFP. NASA included all three
   proposals in the competitive range; after discussions with offerors, the
   agency requested final proposal revisions (FPR). FPRs were evaluated as
   follows:

                                       Analex         ManTech       Jacobs    
                                     Very Good       Very Good    Very Good   
                                                                              
   Mission Suitability             (894.5 points)     (845.5)       (900)     
   RTO/SOW Understanding             Excellent       Very Good    Excellent   
                                                                              
                                       (485)           (430)        (455)     
   Management Plan                   Excellent       Excellent    Excellent   
                                                                              
                                       (279)           (276)        (297)     
   Safety and Health                    Good         Very Good       Good     
                                                                              
                                       (97.5)         (109.5)       (105)     
   Small Disadvantaged Business         Good           Good       Very Good   
                                                                              
                                        (33)           (30)          (43)     
   Past Performance                  Excellent       Excellent    Excellent   
   Evaluated Contract Cost          $151,193,104   $152,763,941  $[REDACTED]  

   Integrated Evaluation Panel Revised Final report at 10, 23, 55.

   Although each proposal received the same overall mission suitability
   rating of very good, NASA evaluated Analex's (as well as Jacobs') mission
   suitability proposal as superior to ManTech's. In this regard, Analex's
   mission suitability proposal received an overall excellent rating for RTO
   response/SOW understanding, the most important subfactor, on the basis of
   seven significant strengths, four strengths, and only one weakness. The
   significant strengths received by Analex's proposal in this area included:
   (1) an exceptionally thorough response to the thermal blankets subtask;
   (2) an exemplary and thorough response to the optical integration support
   subtask, with a thorough discussion of such considerations as gravity
   effects, structural deformation, cleanliness and contamination, and
   temperature and pressure effects; (3) an exceptionally thorough response
   to the certification of the crane subtask which demonstrated a superior
   technical approach; (4) a highly comprehensive technical approach to
   advanced manufacturing planning and fabrication; (5) demonstrating a
   superior understanding of the electrical cable harness fabrication
   subtask; (6) an extremely thorough and accurate response to the mechanical
   integration subtask which demonstrated an excellent understanding of the
   various tasks encompassed by the subtask and identified relevant technical
   challenges and associated resolutions; and (7) an exemplary, very thorough
   response to the integration and test engineering support subtask. Source
   Selection Decision (SSD) at 3-4; Integrated Evaluation Panel Revised Final
   Report at 23-41.

   In contrast, ManTech's mission suitability proposal received an overall
   very good rating for RTO response/SOW understanding on the basis of
   four significant strengths, three strengths, three weaknesses and one
   significant weakness. The significant strengths received by ManTech's
   proposal in this area included: (1) a superior response to the thermal
   blanket fabrication subtask, which demonstrated an innovative and detailed
   approach; (2) an exceptionally thorough response to the certification of
   the crane subtask which demonstrated a superior technical approach; (3)
   demonstrating an excellent understanding of the mechanical integration
   subtask; and (4) an excellent approach to the test and engineering support
   subtask. The three weaknesses included: (1) failing to provide adequate
   staffing for custodial property management of optical equipment; (2) an
   inadequate staffing skill mix for management of the crane certification
   and advanced manufacturing tasks; and (3) of particular significance here,
   inadequate staffing of many key positions (including finance manager,
   configuration management and cost control) required to manage the RTO. In
   addition, ManTech's mission suitability proposal also received a
   significant weakness in this area for failing to provide staffing for
   management of safety operations for the RTO, contract management and
   administrative support to management. SSD at 6-7; Integrated Evaluation
   Panel Revised Final Report at 80-104.

   All three proposals were rated excellent for past performance based on
   "excellent and highly relevant past performance." SSD at 9. As for the
   cost evaluation, the cost realism analysis of the proposed RTO costs did
   not result in an adjustment to the mission suitability score for any of
   the proposals. Regarding the separate calculation of overall contract
   cost, which was based on each offeror's total composite contract loaded
   rate for each government-designated direct labor category as applied to
   the government direct labor hour pricing model (which assumed a total of
   2,248,610 contract hours), Analex's evaluated cost ($151,193,104) was
   slightly lower than ManTech's ($152,763,941).

   The source selection authority (SSA) determined that Analex's and Jacobs'
   proposals were competitive, while ManTech's proposal overall was less
   competitive given its less competitive mission suitability proposal and
   slightly less competitive cost. As between Analex's and Jacobs' proposals,
   notwithstanding both having received an excellent rating under the RTO/SOW
   understanding subfactor, the SSA found a "compelling discriminator" in
   favor of Analex's proposal due to a "far superior understanding of the
   requirements in the [SOW]," as reflected in its technical response to the
   RTO, which "excelled in multiple areas critical to the contract." SSD at
   9. Having determined that the cost difference between Analex's and Jacobs'
   proposals did not represent a meaningful discriminator, and noting that
   the firms' past performance ratings were both excellent, the SSA concluded
   that Analex's proposal represented the best value to the government.

   After learning of the resulting award to Analex and being debriefed,
   ManTech filed this protest. ManTech generally asserts that NASA did not
   reasonably evaluate its approach to the RTO, and otherwise failed to
   account for ManTech's relative advantages as the incumbent contractor with
   respect to contract phase-in and past performance.

   In reviewing protests against allegedly improper evaluations, it is not
   our role to reevaluate proposals. Rather, we will examine the record to
   determine whether the agency's judgment was reasonable and in accord with
   the evaluation factors set forth in the RFP and applicable procurement
   statutes and regulations. 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. Here, we have reviewed all of ManTech's arguments and
   find no basis for questioning the award decision. We discuss ManTech's
   primary arguments below.

   RTO

   ManTech challenges the agency's assessment of a weakness and a significant
   weakness with respect to its response to subtask 14, for quality assurance
   and management support required to perform the RTO. In this regard,
   offerors were required to respond to subtask 14 by describing "their
   approach to providing Quality Assurance support for Subtasks 1 to 13,
   excluding Subtask 9, to ensure that the GSFC Quality Management System . .
   . is followed," and "their approach to the management support necessary
   for Subtasks 1 through 13." RFP, Amend. 005, RTO. Generally, offerors were
   required to identify in their RTO response the "technical approach, labor
   categories, projected hours, Government interface, the flow of activities
   . . . and any other information required to determine the adequacy and
   reasonableness of the offeror's plan"; the plan was to be "specific,
   detailed, and complete to demonstrate a clear and full understanding of
   the objectives," and should "demonstrate the techniques and procedures
   necessary to satisfy the requirements in a timely and cost effective
   manner." RFP, Amend. 5, sect. L.12. In addition, offerors were required to
   furnish as part of their cost proposals the basis for estimates for the
   RTO, giving the government "insight at the Subtask Level . . . into the
   cost estimating thought processes and methodologies used by the offeror in
   estimating the quantities of labor hours/costs, other direct costs, etc.
   required for successful performance of the RTO." RFP, Amend. 009, sect.
   L.13(i). As part of this requirement, offerors were specifically required
   to "[e]xplain in detail how Program Management and Administrative Support
   (purchasing, property, human relations, secretarial, etc.) are costed,"
   including an explanation of the estimating assumptions used for direct
   costs and the cost pool for indirect costs. Id.

   As noted above, ManTech's mission suitability proposal was assessed a
   significant weakness under the RTO/SOW understanding subfactor with
   respect to its response to subtask 14 on the basis that it failed to
   provide any staffing for management of safety operations for the RTO,
   contract management, and administrative support to management. In this
   regard, ManTech proposed no hours under the RTO for a safety operations
   manager, which the agency evaluated as "greatly increas[ing] the risk of
   harm to both personnel and critical equipment and infrastructure."
   Integrated Evaluation Panel Revised Final Report at 99-100. Further,
   although ManTech's proposed contract effort relied on subcontractors, its
   RTO proposal also did not include any hours for its contracts manager
   position, whose responsibilities under ManTech's overall proposal extended
   to both contract and subcontract management, as follows:

     [REDACTED].

   ManTech FPR Cost Proposal at 34. The agency determined that the absence of
   contracts manager hours "significantly increases the risk to schedule
   performance and constitutes a proposed flaw that appreciably increases the
   risk of unsuccessful contract performance." Integrated Evaluation Panel
   Revised Final Report at 99. Nor did ManTech propose any hours for
   administrative support to management in the performance of the RTO. While
   ManTech has not rebutted the agency's determination that ManTech's RTO
   proposal should have included hours for a safety operations manager, as
   discussed below, it has challenged the agency's determination that 166
   contracts manager hours were necessary for performance of the RTO.

   In addition, ManTech's mission suitability proposal was assessed a
   weakness under the RTO/SOW understanding subfactor for failing to include
   any configuration manager hours for several subtasks and for
   underestimating hours for other subtasks, thereby "significantly
   increas[ing] technical risk"; failing to provide staffing to perform cost
   control for four of the subtasks, thereby resulting in a "significant
   increase in cost and schedule risk"; and providing only [REDACTED] of the
   441 finance manager hours considered necessary by the agency for ManTech's
   RTO performance. Integrated Evaluation Panel Revised Final Report at
   92-98. Regarding the inadequacy of the finance manager hours, the only
   part of the evaluation in this area that ManTech has rebutted, ManTech's
   proposal described the responsibilities of the position as follows:

     [REDACTED]

   ManTech FPR Cost Proposal at 34. The agency determined that ManTech's
   inadequate finance manager RTO hours resulted in "high cost and schedule
   risk." Integrated Evaluation Panel Revised Final Report at 95.

   ManTech challenges the agency's determination regarding the contracts
   manager and finance manager on several grounds. First, ManTech asserts
   that the downgrading of its proposal for inadequate or no staffing in
   these areas unreasonably failed to take into account ManTech's specific
   approach to performing the RTO. In this regard, ManTech points to the
   explanation in its cost proposal that costs for "contract administration
   and financial support . . . are not included in the RTO price based on the
   low scope of work being priced." ManTech FPR Cost Proposal at 8.[1]

   ManTech's position is unpersuasive. The RTO comprised 13 subtasks in
   addition to the quality assurance/management support subtask 14, to be
   performed over a period of approximately 6 months commencing on or about
   the expected date of award. See, RFP, Amend. 006, RTO (RTO of 6 months
   commencing October 2007); RFP, Amend. 009, sect. L.13(l) (contract
   commencing October 2007); cf. NASA Requests for FPRs, Sept. 5, 2007
   (expected date of award December 2007). ManTech estimated the total direct
   labor staffing of its RTO effort as [REDACTED] direct prime and
   subcontractor labor hours ([REDACTED] of which were subcontractor hours),
   at a total cost (without fee, but including overhead, other direct costs,
   materials, and general and administrative costs) of $[REDACTED]. ManTech
   FPR Cost Proposal at 121-22. NASA determined that, given the effort
   required to perform the RTO, successful performance would require some
   effort by ManTech's proposed contracts manager, who, again, was described
   in ManTech's proposal as responsible for contract and subcontract
   management, supporting the program manager in contract administration
   (including interfacing with the contracting officer and tracking contract
   deliverables), and monitoring company performance for conformance to the
   original proposal. ManTech FPR Cost Proposal at 34; ManTech FPR Mission
   Suitability Proposal at 99. ManTech has not shown that the agency's
   conclusion was unreasonable; that is, it has not shown that there would be
   no need for contract administration and monitoring of contract
   performance, the described responsibility of ManTech's proposed contracts
   manager. It follows that it was reasonable for the agency to downgrade
   ManTech's proposal for failing to include any hours for this position.

   NASA further determined that successful performance of the RTO would
   require more than the proposed [REDACTED] hours of effort by ManTech's
   proposed finance manager. Again, the finance manger was described in
   ManTech's proposal as having extensive responsibilities, including being
   responsible for [REDACTED]. ManTech has not shown that, given the very
   extensive responsibilities assigned its proposed finance manager, the
   agency unreasonably determined that more than [REDACTED] hours of effort
   would be required.[2]

   Second, ManTech asserts that there was "simply no meaningful methodology
   for estimating the precise benefit certain overhead or contract-level
   positions would provide for these thirteen sample tasks." ManTech
   Comments, Mar. 20, 2008, at 8. However, NASA estimated the time required
   to perform each of the functions that ManTech's proposed contracts
   manager, finance manager, and administrative assistant would be required
   to perform with respect to the RTO, and ManTech has not shown this
   approach to be unreasonable. While ManTech has specifically challenged
   several of the calculations, the material issue here is whether
   significant required effort was not proposed.[3] In this regard, given the
   extensive responsibilities for contract performance assigned to ManTech's
   proposed contracts manager and finance manger, we find no basis to
   question the agency's determination that the deficits in proposed staffing
   for these positions were sufficiently significant to pose a risk to
   successful RTO performance. Given the above significant deficits in its
   proposed RTO staffing, as well as the fact that ManTech has not rebutted
   the agency's determination that it also failed to propose the requisite
   configuration manager, cost control and safety operations manager effort,
   we conclude that NASA reasonably downgraded ManTech's proposal for failing
   to propose adequate RTO effort in key areas.

   Third, ManTech asserts that NASA failed to subject Analex's RTO proposal
   to a similarly rigorous review. This argument is without merit. NASA
   states that it reviewed each offeror's proposal to determine whether the
   proposed RTO hours were within a reasonable range; according to the
   agency, where the proposed hours for a subtask or a particular position
   under a subtask were outside the reasonable range, the evaluators then
   conducted an in-depth analysis to determine what cost realism adjustment
   should be made. Agency Supplemental Report, Mar. 17, 2008, at 20;
   Contracting Officer's Supplemental Statement of Facts, Mar. 17, 2008, at
   4. The contemporaneous documentation of the evaluation furnished by the
   agency confirms that the evaluators in fact reviewed the labor hours
   proposed by Analex for the various subtasks and adjusted them where they
   were deemed unreasonable for the required work. Integrated Evaluation
   Panel Revised Final Report at 31-40, 132; Agency Supplemental Report, Mar.
   17, 2008, Attach. 1.

   The record also supports NASA's position that Analex included hours for
   performance of the contract management function and financial management
   function (as well as administrative support) in its RTO effort. In this
   regard, the agency cites to language in Analex's proposal indicating that
   the responsibilities of Analex's program manager include such tasks as
   [REDACTED], while Analex's business manager is generally responsible for
   [REDACTED]. Analex included hours for both positions in its RTO effort.
   Analex FPR Mission Suitability Proposal at B-80 to B-83, C-8 to C-13;
   Analex FPR Cost Proposal, Basis of Estimate, at 45-47. In addition, NASA
   cites to language in Analex's proposal indicating that both Analex's
   business manager and its financial analyst (also included in the RTO
   effort) are responsible for [REDACTED]. Id. [4]

   We recognize that not all of the specific activities considered in NASA's
   calculation of required staff hours during its in-depth reviews of
   ManTech's proposal (resulting from ManTech's failure to include any hours,
   or its apparent inclusion of very few hours, for a required function) can
   be discerned from Analex's proposal. The record, however, indicates that
   neither offeror described the expected activities of its proposed
   management and support positions in the exacting detail that NASA used in
   calculating the probable hours required for a particular required function
   when an offeror failed to propose hours for, or proposed a clearly
   inadequate number of hours, for the function. Analex FPR Mission
   Suitability Proposal at B-74 to B-89; ManTech Mission Suitability Proposal
   at 67-74.

   We further recognize that Analex proposed fewer RTO hours for its business
   manager ([REDACTED] hours) and its financial analyst ([REDACTED] indirect
   hours) than were calculated by the agency for ManTech's contracts manager
   (166 hours) and finance manager (441 hours). However, as noted by the
   agency, the offerors' approaches to performing the RTO were different,
   with the responsibilities of the offerors' management positions not
   necessarily corresponding. Thus, for example, a number of other Analex
   positions (including its program manager) were described in Analex's
   proposal as contributing to contract management, while the
   responsibilities assigned by ManTech to its finance manager were very
   extensive and would appear to encompass work performed by other Analex
   positions, including its program manager and section managers. ManTech FPR
   Cost Proposal at 34; Analex FPR Mission Suitability Proposal at B-80 to
   B-83, C-8 to C-12; Analex FPR Cost Proposal, Basis of Estimate, at 45-48.
   Furthermore, Analex's proposed overall RTO quality assurance/management
   support staffing ([REDACTED] hours under subtask 14) substantially
   exceeded ManTech's staffing in this area ([REDACTED] hours), including,
   for example, more than [REDACTED] times as many proposed hours for
   Analex's program manager as proposed for ManTech's ([REDACTED] hours
   versus [REDACTED] hours). Analex FPR Cost Proposal, Basis of Estimate,
   at 45-47; ManTech FPR Cost Proposal at 182. NASA concluded that Analex,
   unlike ManTech, had proposed sufficient overall staffing to perform the
   management functions necessary for successful RTO performance. ManTech has
   not shown NASA's conclusion to be unreasonable.

   Neither has ManTech furnished any basis to question NASA's assessment of
   weaknesses on account of ManTech's failure to staff or sufficiently staff
   some overall management responsibilities required for successful RTO
   performance, as well as its failure to staff or sufficiently staff
   management support required for several subtasks. In these circumstances,
   given Analex's evaluated seven significant strengths, four strengths, and
   only one weakness under the RTO response/SOW understanding subfactor,
   versus ManTech's evaluated four significant strengths, three strengths,
   three weaknesses and one significant weakness, we conclude that NASA
   reasonably found Analex's proposal to be more advantageous (with an
   excellent rating) than ManTech's (with a very good rating) under this
   subfactor.

   PHASE-IN

   ManTech challenges NASA's evaluation of offerors' approaches to phase-in
   at the start of the contract. In this regard, the RFP, which included a
   30-day phase-in period, provided that the government would evaluate under
   the management plan subfactor (under the mission suitability factor) each
   offeror's phase-in approach

     for continuity and a smooth transition with the incumbent Contractor
     during the 30-day phase-in period. The Government will evaluate how
     clearly the phase-in plan demonstrates an ability to assume full
     contract responsibility on the effective date of the contract. The
     Government will evaluate how the phase-in plan specifically address[es]
     . . . the proposed . . staffing plan. . . .

   RFP sect. M.3. ManTech asserts that the agency failed to recognize its
   advantage as the incumbent contractor.

   Analex's proposal was rated overall excellent under the management plan
   subfactor. This rating was based in part on two evaluated significant
   strengths, one for proposing (1) an "extremely well-planned, comprehensive
   and detailed phase-in plan that provides for a smooth transition and
   demonstrates a superb ability to assume full contract responsibility," and
   the other one for a superior approach to using bonuses tied to the award
   fees earned by Analex and other bonuses as an incentive to maximize
   overall employee morale and performance. SSD at 4; Integrated Evaluation
   Panel Revised Final Report at 41-53. In addition, Analex's proposal
   received four strengths under the management plan subfactor, for
   (1) proposing a good system (its online task order management system
   discussed above) to process task orders and manage multiple ongoing tasks,
   (2) a good approach for mitigating performance risks and for interfacing
   with government personnel, (3) a robust fringe benefits package, which
   would aid in recruiting and retaining employees, and (4) a thorough,
   comprehensive Mission Assurance Plan which demonstrated Analex's knowledge
   of and compliance with GSFC's Mission Assurance Guidelines. Analex's only
   evaluated weakness under this subfactor was an inadequate location
   allowance and severance pay policy. Integrated Evaluation Panel Revised
   Final Report at 41-53.

   ManTech's proposal likewise was rated overall excellent under the
   management plan subfactor. ManTech's rating was based in part on a single
   evaluated significant strength for a superior approach to phase-in,
   involving no major changeover of personnel, processes or procedures, which
   would significantly reduce the risk of phase-in. In addition, ManTech's
   proposal received six strengths under the management plan subfactor, for
   proposing (1) policies and incentives that have a high probability of
   retaining employees, maintaining high morale and increasing productivity
   in a union environment, (2) a good task order and property management
   system, (3) a good approach to managing workload variability,
   (4) desirable benefits for part-time workers, (5) an Integrated Knowledge
   Environment portal that demonstrated a good approach to managing contract
   work, and (6) a robust total compensation plan. In addition, ManTech's
   proposal received a weakness on the basis that, in contrast to Analex's
   thorough, comprehensive mission assurance plan, ManTech's significantly
   less detailed mission assurance plan was inadequate, failing to
   demonstrate compliance with GSFC's Mission Assurance Guidelines. SSD at 7;
   Integrated Evaluation Panel Revised Final Report at 104-18.

   Thus, the record indicates that NASA in fact recognized, and assigned
   ManTech's proposal a significant strength under the management plan
   subfactor on account of its superior approach to phase-in. NASA
   specifically recognized that, given ManTech's policies and incentives,
   reflected in a 95 percent employee retention rate over the past 5 years,
   ManTech had a high probability of maintaining its incumbent workforce,
   thereby significantly reducing transition risk. Integrated Evaluation
   Panel Revised Final Report at 104-06.

   However, NASA also recognized that Analex had proposed an "exceptional
   strategy," warranting a significant strength, in support of its proposal
   to hire [REDACTED] percent of the incumbent employees. In this regard, the
   agency noted that Analex had proposed a very attractive package for
   recruiting incumbent employees, including: [REDACTED]. In addition, NASA
   concluded that Analex's proposed superior approach to bonuses (for which
   it earned a second significant strength) would likewise increase the
   likelihood of recruiting incumbent employees. In this regard, the agency
   noted that Analex had proposed bonuses [REDACTED], in a total amount of up
   to approximately [REDACTED] percent of salaries, with the bonuses
   commencing when Analex earned an award fee of at least [REDACTED] percent.
   (In contrast, in ManTech's proposed approach of offering bonuses tied to
   the earned award fee, Mantech commenced the bonuses only when ManTech
   earned an award fee above [REDACTED] percent, and it only encouraged, but
   did not require, participation by its subcontractors.) NASA also
   determined that Analex's robust fringe benefits package would aid in
   recruiting employees. Finally, the agency determined that Analex's plan
   for [REDACTED], would greatly improve the likelihood of a successful
   transition. Integrated Evaluation Panel Revised Final Report at 41-45;
   Agency Supplemental Report, Mar. 17, 2008, at 4-11; ManTech FPR Mission
   Suitability Proposal at 113, 118; Analex FPR Mission Suitability Proposal
   at C-26.[5]

   We conclude that NASA reasonably determined that Analex offered an
   exceptional transition approach, with many incentives for incumbent
   employee retention, which warranted a significant strength under the
   management plan subfactor. Furthermore, ManTech has not shown that, given
   Analex's overall two significant strengths and four strengths under the
   management plan subfactor, it was unreasonable for the agency to rate
   Analex's proposal as excellent in this area. Certainly the fact that
   ManTech was the incumbent contractor here did not automatically entitle it
   to a higher rating under the management plan subfactor. See Karrar Sys.
   Corp., B-310661, B-310661.2, Mar. 3, 2008, 2008 CPD para. 51 at 4-5.

   PAST PERFORMANCE

   ManTech challenges the evaluation of Analex's past performance. In this
   regard, the RFP provided for evaluation of each offeror's record (as well
   as the record of any significant subcontractor and/or teaming partner)
   "performing services or delivering products that are similar in size,
   content, and complexity to the requirements of this solicitation," and
   indicated that "[i]n assessing relevance, the Government will consider the
   degree of similarity in size, content, and complexity to the requirements
   in this solicitation." RFP sect. M.5. The solicitation provided for
   six possible past performance ratings (excellent, very good, good, fair,
   poor, and neutral), each (other than the neutral rating) having both a
   performance and relevance aspect. Offerors were required to furnish
   information regarding their (or their significant subcontractors' and/or
   teaming partners) completed and ongoing contracts for similar efforts over
   $5 million within the last 3 years. In addition, the solicitation included
   a past performance questionnaire to be completed by the references for
   each of the listed prior contracts.

   As discussed above, both ManTech's and Analex's proposals were rated
   excellent for past performance based on "excellent and highly relevant
   past performance." SSD at 9. ManTech essentially asserts that Analex's
   experience with spaceflight hardware and support (as included in ManTech's
   incumbent contract) was of a sufficiently lesser magnitude than ManTech's
   as to preclude Analex and ManTech receiving the same past performance
   rating.

   The evaluation of an offeror's past performance, including the agency's
   determination of the relevance and scope of an offeror's performance
   history, is a matter of agency discretion that we will not find improper
   unless unreasonable, inconsistent with the solicitation criteria,
   undocumented, or inconsistent with applicable statutes or regulations.
   Family Entm't Servs., Inc., d/b/a/ IMC, B-291997.4, June 10, 2004, 2004
   CPD para. 128 at 5.

   Here, NASA's past performance evaluation was consistent with the
   solicitation and otherwise reasonable. In this regard, the past
   performance questionnaire included in the RFP described in some detail the
   broad range of the work to be performed at GSFC under the SOW. Among other
   information, the questionnaire requested the reference to complete an SOW
   Survey, that is, a chart organized by SOW element, including specific SOW
   services elements (structural test, electromagnetic test, space simulation
   test, mechanical integration, recertification, optical integration, and
   facility acquisition or modification), goods elements (electrical cable
   harness and thermal blankets), functional support elements (safety,
   facility maintenance, engineering, cleanroom operations and contamination
   control, logistics, quality assurance, and computer systems management),
   and management elements (senior management, project management, line
   management, and configuration management). For each SOW element, the
   reference was to rate the relevance of the contractor's performance
   (either "significant experience," "moderate experience" or "minimal/did
   not perform") and assign a performance rating (excellent, very good, good,
   fair, poor, and neutral). RFP Past Performance Questionnaire.

   Analex cited eight contracts in its past performance proposal, including
   three of its own and five performed by its teaming partners. NASA
   considered Analex's performance on the Glenn Engineering and Scientific
   Support (GESS) contract at NASA's Glenn Research Center to have "highly
   significant relevance" to the work under the SOW here. Presentation to
   SSA, Dec. 20, 2007, at 101. In this regard, the record indicates that the
   GESS contract included such work as engineering and conducting low-noise
   design and acoustic emissions verification for an International Space
   Station-based microgravity space experiment facility; operation of a
   structural dynamics laboratory, including design, set-up and performance
   of structural dynamics testing for space flight program hardware;
   electromagnetic testing of space experiment packages; space simulation
   testing, including developing thermal vacuum testing programs for advanced
   solar concentrators and dynamic power conversion systems; engineering
   services to integrate space-qualified experiment components in connection
   with Spacelab, SPACEHAB and the International Space Station's Fluids and
   Combustion facility; development of optical and electro-optical systems
   for use in microgravity space experiments; conducting safety reviews for
   flight hardware development and operation; and assembling and testing
   flight hardware in NASA cleanrooms. Analex Past Performance Proposal at
   9-24. The completed past performance questionnaire returned for the GESS
   contract, which was signed by the GESS program manager, indicated that
   Analex had significant experience with six of the above seven specific SOW
   services elements (including structural test, electromagnetic test, space
   simulation test, mechanical integration, optical integration, and facility
   acquisition or modification); moderate experience with one of the two SOW
   goods elements (electrical cable harness); significant experience with
   four and moderate experience with another of the seven SOW functional
   support elements; and significant experience with three and moderate
   experience with another of the four SOW management elements. The GESS
   program manager rated Analex's performance excellent overall and excellent
   in each of the above areas in which it had experience. According to the
   program manager, "Analex was a key contributor to the success of the GESS
   Contract. Their technical, cost and schedule performance on a variety of
   engineering tasks was outstanding." GESS Past Performance Questionnaire.

   Analex also listed its performance of the Microgravity Research,
   Development and Operations Contract (MRDOC) at NASA's Glenn Research
   Center. In this regard, the past performance questionnaire from the deputy
   chief for development (who served as the contracting officer's technical
   representative) generally described Analex's role as developing the Fluids
   and Combustion Facility, a space station microgravity experiment facility,
   and designing, developing, testing and integrating spaceflight hardware
   and software. In its proposal, Analex offered more specific examples of
   its work under the contract, noting such tasks as operating and conducting
   tests at the electromagnetic compatibility laboratory; designing and
   fabricating cables and test fixtures, and supporting vibration testing of
   flight hardware; designing, fabricating and integrating complex mechanical
   assemblies of flight hardware and ground support equipment; designing,
   fabricating and assembling imaging systems to observe combustion events
   inside the Combustion Integrated Rack combustion chamber for the
   International Space Station; coordinating efforts with the International
   Space Station authorities to ensure that hardware would work seamlessly
   with mechanical interfaces on the station; and designing, fabricating and
   testing power and data bus cables for flight hardware and ground support
   equipment. Analex Past Performance Proposal at 9-24. The completed past
   performance questionnaire for the MRDOC contract indicated that Analex had
   significant experience with four of the above seven specific SOW services
   elements (including structural test, electromagnetic test, mechanical
   integration, and optical integration), with two excellent and two very
   good ratings; significant experience with one of the two SOW goods
   elements (electrical cable harness), with an excellent rating; significant
   experience with one and moderate experience with two of the functional
   support service elements, with excellent ratings for two and a very good
   rating for the third element; and moderate experience with one of the
   management elements, with an excellent rating. The deputy chief for
   development at Glenn Research Center rated Analex's contract performance
   excellent overall.

   In addition to these two contracts, Analex listed its performance of the
   Expendable Launch Vehicle Integrated Service Contract at NASA's Kennedy
   Space Center, under which it furnished integrated safety, mission
   assurance, communications and telemetry, engineering services, and
   facility operations services in support of Expendable Launch Vehicle
   planning, processing and launch. Past Performance Database, Contract
   NAS1002026. The contracting officer's entry in the interim, June 2003 Past
   Performance Database listing for this contract described Analex's
   performance as "[o]verall very effective performance," with the contractor
   having "[m]et or exceeded all deliverable requirements"; Analex's
   performance received very good quality and timeliness ratings, and an
   excellent rating for cost control, in this interim evaluation. Id. In the
   subsequent (December 2006) past performance questionnaire for the
   procurement here, Analex's performance under this contract received
   excellent ratings for each applicable SOW element, including one of the
   SOW services elements (in which there was significant experience), six of
   the functional support elements (in which there was significant
   experience), and four of the management elements (in which there was
   significant experience). Overall, the questionnaire rated Analex's
   performance excellent, and described Analex as an "outstanding contractor"
   that was "extremely strong technically, & cost controls." Expendable
   Launch Vehicle Integrated Service Contract Past Performance Questionnaire.

   In addition to its own three contracts, Analex also listed five contracts
   performed by its team members. This included three contracts performed by
   its team member Jackson and Tull (J&T): a contract in which J&T designed,
   built and tested flight and non-flight hardware and ground support
   equipment for spacecraft subsystems and instruments, for which an overall
   excellent performance rating was received; another contract for design,
   building and testing of flight and non-flight hardware and ground support
   equipment, in which J&T had difficulty in recruiting personnel for
   performance in New Mexico and received an overall very good/good rating;
   and an overall, very much larger contract with one effort for flight
   servicing and support and another for mission operations, engineering and
   software, for which an overall, combined excellent performance rating was
   received. Past Performance Questionnaires, J&T Contracts NAS5-01090,
   F29601-01-D-0078/F29601-01-D-0077, HB80E4480N/HB80E4960N. Analex also
   listed team member Wyle Laboratories' performance on two contracts,
   including one in which the reference rated its performance as good, but
   indicated that there could have been better definition of requirements by
   the customer, and another much larger contract involving significant
   experience in the SOW areas of functional support and management, for
   which Wyle's overall performance received an excellent rating. Past
   Performance Questionnaires, Wyle Contracts 4400119123/4400110481,
   FA8601-04-D-0005.

   In summary, the record available to the agency indicated overall excellent
   performance by Analex itself on three contracts, and favorable performance
   by its team members, with excellent overall performance ratings for three
   of the five listed contracts. In addition, the record indicated that the
   Analex team had significant relevant experience for every SOW element
   other than the thermal blankets element, for which the team had moderate
   relevant experience.

   ManTech essentially asserts that only the SOW elements and work most
   directly tied to space flight hardware are fully relevant. However, its
   position is inconsistent with the scope of the past performance evaluation
   provided for under the solicitation. In this regard, as indicated by the
   past performance questionnaire specified in the RFP, which requested
   ratings of the relevance and quality of performance under a total of 20
   SOW elements, the past performance evaluation was not intended to be
   limited to only a few of the SOW elements or a particular type of work;
   rather, the past performance questionnaire evidenced the agency's
   determination that prior performance of a number of functions and types of
   work were relevant to the likelihood of successful performance of the
   contemplated contract here.

   In these circumstances, given the overall excellent past performance of
   Analex and the predominantly excellent past performance of its team
   members, and the fact that the Analex team had significant relevant
   experience in all but 1 of the 20 specified SOW elements (as well as
   moderate relevant experience in the 20^th element), we find that NASA
   reasonably rated Analex's past performance excellent.

   In summary, we conclude that NASA reasonably determined that Analex's
   proposal represented the best value to the government.

   The protest is denied.

   Gary L. Kepplinger
   General Counsel

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

   [1] ManTech asserts that since both offerors treated certain managerial
   and administrative positions in whole or in part as indirect costs, with
   ManTech proposing [REDACTED] percent of its contract and finance managers
   and [REDACTED] percent of its administrative assistant positions as
   indirect costs, and Analex proposing its financial analyst and
   administrative assistant positions as [REDACTED], the offerors proposed
   similar staffing approaches. As discussed below, however, ManTech proposed
   [REDACTED] contract manager and administrative assistant hours and
   inadequate finance manager hours as part of its RTO effort, while Analex
   proposed adequate staffing for comparable positions in those areas as part
   of its RTO effort. ManTech FPR Total Compensation Plan at 3; ManTech FPR
   Cost Plan at 6, 8, 188; ManTech FPR Mission Suitability Proposal at 74;
   Analex FPR Cost Proposal at 46, 48; Analex Basis of Estimate at 45-48.

   [2] ManTech, which proposed [REDACTED] administrative assistant hours,
   also challenges the agency determination that 70 administrative
   assistant hours were necessary for performance of the RTO. ManTech,
   however, has not shown that the agency was unreasonable in determining
   that, given the magnitude of the proposed RTO effort, successful contract
   performance would require [REDACTED] support from an administrative
   assistant.

   [3] The precise level of the missing RTO effort was not material to the
   cost evaluation because the calculated probable cost of the RTO was not
   included in the overall evaluated contract cost, and the variance of the
   probable cost from the proposed RTO cost was insufficient to require an
   adjustment to the mission suitability score.

   [4] Although ManTech has suggested that the portion of Analex's business
   manager's RTO effort allotted to [REDACTED] is irrelevant to contract
   management, we agree with the agency that the [REDACTED] reference appears
   to be a reference to Analex's proposed [REDACTED], for which its business
   manager is responsible and for which Analex's proposal received an
   evaluation strength, and thus in fact is relevant to performance of the
   contract management function. Analex FPR Mission Suitability Proposal at
   C-14 to C-15; Analex Phase-In Plan at C-6: Analex FPR Cost Proposal, Basis
   of Estimate, at 47.

   [5] Analex also proposed that in the event that the level-of-effort
   required for performance exceeded the available incumbent workforce, the
   Analex team could call upon [REDACTED] pre-cleared engineers and
   technicians in the Washington metropolitan area (where GSFC is located),
   as well as over [REDACTED] ETIS-qualified engineers and technicians at
   other Department of Defense and NASA locations. Analex FPR Management Plan
   at C-27 to C-28.