TITLE: B-311273; B-311273.2, Professional Performance Development Group, Inc., June 2, 2008
BNUMBER: B-311273; B-311273.2
DATE: June 2, 2008
************************************************************************************
B-311273; B-311273.2, Professional Performance Development Group, Inc., June 2, 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: Professional Performance Development Group, Inc.

   File: B-311273; B-311273.2

   Date: June 2, 2008

   John S. Pachter, Esq., Jonathan D. Shaffer, Esq., Mary Pat Gregory, Esq.,
   Kathryn T. Muldoon, Esq., and Le'Ontra B. Greenspan, Esq., Smith Pachter
   McWhorter PLC, for the protester.
   Krystal A. Jordan, Esq., Department of Health and Human Services, for the
   agency.
   Katherine I. Riback, Esq., Sharon L. Larkin, Esq., and
   James A. Spangenberg, Esq., Office of the General Counsel, GAO,
   participated in the preparation of the decision.

   DIGEST

   Protester's proposal was reasonably evaluated by the contracting agency as
   technically unacceptable and excluded from the competitive range, where
   the proposal contained numerous informational deficiencies and the agency
   reasonably determined that discussions would not likely improve the
   proposal such that it would have a reasonable chance for award.

   DECISION

   Professional Performance Development Group, Inc., (PPDG) protests the
   exclusion of its proposal from the competitive range under request for
   proposals (RFP) No. FOHS2008REGA, issued by the Department of Health and
   Human Services (HHS), Federal Occupational Health Services (FOHS) for
   occupational health and clinical services. PPDG argues that the agency's
   technical evaluation of its proposal was improper.

   We deny the protest.

   BACKGROUND

   The FOHS is a fee for service operation that, among other functions,
   assists federal managers in establishing occupational health services for
   federal employees; counseling employees at physical or emotional risk from
   alcoholism, drug abuse, stress, or other job-related factors; and
   promoting employee wellness and physical fitness. RFP sect. C.1. To this
   end, the FOHS has several thousand interagency agreements to provide basic
   occupational health and clinical services to federal employees through
   FOHS's occupational health centers. Contracting Officer's Statement at 1.

   The RFP, which contemplated the award of a time-and-materials contract for
   a base year with four 1-year options, sought a contractor to provide the
   occupational health and clinical services specified in FOHS's interagency
   agreements in FOHS Region A.[1] RFP sections B.1, C.1, F.1. These services
   included, among other things, providing health screenings, first aid and
   treatment for minor illnesses and injuries, health awareness and education
   programs, and emergency responses. Id. sect. C.1.2. The solicitation's
   statement of work required the recruitment, retention, orientation,
   training, and oversight of all health care professionals and
   administrative staff necessary to deliver the required services at FOHS's
   "Service Provision Sites," which are permanent health centers typically
   located in buildings where there is a large concentration of federal
   employees. Id. In addition to routine staffing, temporary staffing is
   required to support federal response to natural disasters or other
   emergencies.

   The RFP identified six evaluation factors, which were weighted on a
   100-point scale: key personnel and personnel management (25 points),
   transition plan (20 points), corporate experience and capabilities (15
   points), general technical approach (15 points), quality assurance (15
   points), and past performance (10 points). The solicitation also stated
   that the six factors, when combined, were "relatively equal to price."
   Award was to be made to the responsible offeror whose proposal was
   determined to be the "most advantageous" to the government, all factors
   considered. Id. sect. M.2.a.

   The RFP included detailed instructions regarding the submission of
   proposals. Each offeror's technical proposal was not to exceed 35 pages,
   excluding resumes. Id. sect. L.2. The RFP contained the following
   instruction to offerors:

     Information requested herein must be furnished in writing fully and
     completely in compliance with instructions. The information requested
     and the manner of submittal is essential to permit prompt evaluation of
     all offers on a fair and uniform basis. Simple statements of compliance
     (i.e., `understood'; `will comply') without the detailed description of
     how compliance will be met may not be considered sufficient evidence
     that the proposed services can technically meet the requirements of this
     RFP. Accordingly, any offer in which material information requested is
     not furnished, or where indirect or incomplete answers or information
     are provided may be considered not acceptable or determined to be
     outside the competitive range.

   Id.

   Twelve offerors, including PPDG, submitted proposals by the closing date
   stated in the solicitation. After reviewing the proposals, the technical
   evaluation panel (TEP) determined that 10 of the proposals were
   technically unacceptable, including PPDG's proposal, which received a
   score of 62 points out of a possible 100 points. Although the TEP noted a
   few strengths in the evaluation of PPDG's proposal, the TEP determined
   that PPDG's proposal, in numerous other instances, failed to provide
   information (or provided confusing or misleading information) that was
   required or contemplated by the solicitation, which resulted in the
   assessment of numerous "weaknesses" and "deficiencies" and low point
   scores under the evaluation factors.

   For example, under the key personnel and personnel management factor
   (where PPDG's proposal received 17 out of 25 points), the TEP found that
   PPDG's proposal failed to provide a compensation plan for a pandemic
   event, address how the firm would manage a "large scale" pandemic event,
   and include an "incentive plan for [employee] retention"; the proposal
   also contained "confusing" information regarding PPDG's "Training
   Documentation" system and relied on "untested relationships [with] per
   diem nurses." Agency Report (AR), Tab 10, Consensus Technical Evaluation,
   at 3. Under the transition plan factor (where PPDG's proposal received 14
   out of 20 points), the TEP found that PPDG's proposal lacked an
   organizational chart with identified lines of communication, and the
   proposal was "unclear" or "unrealistic" with regard to its recruitment
   timelines, employee orientation, and communication with employees. Id. at
   4. Under the corporate experience and capability factor (where PPDG's
   proposal received 8 out of 15 points), the TEP concluded that PPDG's
   experience was "limited," and the proposal included "misleading
   statements." Id. at 5. Under the general technical approach factor (where
   PPDG's proposal received 9 out of 15 points), the TEP determined that PPDG
   did not provide a "company problem resolution plan," and did not specify
   any "methods" to manage or carry out day-to-day operations, and that the
   roles of the "PM" (project manager) and "PD" (project director) were
   unclear. Id. at 6. Under the quality assurance factor (where PPDG's
   proposal received 4 out of 15 points), the TEP concluded that PPDG's
   quality assurance plan lacked required detail, relied on "[g]eneric
   phrases" that did not specify how tasks would be accomplished, failed to
   incorporate such things as site surveys or client satisfaction surveys,
   and did not contain any description of its malpractice coverage. Id. at 7.

   Based on the TEP's documented evaluation of multiple proposal
   deficiencies, the contracting officer determined that PPDG's proposal was
   technically unacceptable and should not be included in the competitive
   range. PPDG subsequently filed its protest with our Office. PPDG
   challenges numerous findings in the TEP's evaluation report, essentially
   arguing that given the 35-page limitation on technical proposals, PPDG's
   proposal provided sufficient information to be considered technically
   acceptable, and that it should have been given the opportunity to address
   the agency's concerns during discussions.

   In reviewing an agency's decision to exclude a proposal from the
   competitive range, we look first to the agency's evaluation of proposals
   to determine whether the evaluation had a reasonable basis. In reviewing
   an agency's evaluation, we will not independently determine the merits of
   a proposal, but will examine the record to ensure that the evaluation was
   reasonable and consistent with the evaluation criteria and applicable
   procurement laws and regulations. Safeguard Maint. Corp., B-260983.3, Oct.
   13, 1995, 96-2 CPD para. 116 at 4. An offeror must submit an initial
   proposal that is adequately written and that affirmatively states its
   merits, or run the risk of having its proposal rejected as technically
   unacceptable. Global Eng'g & Constr. Joint Venture, B-275999.4,
   B-275999.5, Oct. 6, 1997, 97-2 CPD para. 125 at 3. Statements that are
   essentially blanket offers of compliance with the stated requirements are
   not an adequate substitute for detailed information necessary to establish
   how an offeror proposes to meet the agency's needs. Ervin & Assocs., Inc.,
   B-280993, Dec. 17, 1998, 98-2 CPD para. 151 at 6. Agencies may exclude
   proposals with significant informational deficiencies from further
   consideration, whether the deficiencies are attributable to omitted, or
   merely inadequate, information addressing fundamental factors. Generally,
   offers that are technically unacceptable as submitted and would require
   major revisions to become acceptable are not required to be included in
   the competitive range for discussion purposes. Global Eng'g & Constr.
   Joint Venture, supra.

   As explained in detail below, we find that HHS's evaluation of PPDG's
   proposal, and the subsequent decision to exclude the proposal from the
   competitive range, were reasonable and consistent with the solicitation.
   The record reflects that the proposal, in large part, either parroted back
   in whole or part the RFP's requirements, with a statement of PPDG's intent
   to meet the requirements, or simply lacked the required information or
   detail for the agency to determine that PPDG understood the RFP's
   requirements. Although it is true that proposals were limited to 35 pages
   in length, and therefore exhaustive detail could not be provided, our
   review of the record confirms the reasonableness of the agency's judgment
   that PPDG failed to provide the level of detail that reasonably could be
   expected, within the page limitation stated in the RFP.[2] Although we do
   not specifically address here all of the protester's arguments concerning
   the evaluation of its proposal, we have fully considered all of them and
   find that they afford no basis to question the agency's evaluation.[3]

   KEY PERSONNEL AND PERSONNEL MANAGEMENT

   Under the key personnel and personnel management factor, among other
   things, offerors were required to provide a description of the
   methodologies to respond quickly to unforeseen emergencies or disasters
   that would require a temporary surge in staffing by 50 percent, as well as
   methodologies to respond to a reduction in staffing needs during, for
   example, "extended building closures during a severe pandemic." RFP sect.
   M.4.2.1. Offerors also were required to state how they would "compensate
   their staff during such a pandemic." Id.

   As noted above, the agency identified numerous "weaknesses/deficiencies"
   in PPDG's proposal under the key personnel and management factor. Among
   other identified concerns, the agency stated that PPDG's proposal lacked
   the detailed "methodologies" required by the RFP to explain how the firm
   would hire sufficient staff to meet unforeseen emergencies. HHS's Legal
   Memorandum at 16-17. In response, PPDG asserts that it provided a
   [DELETED] in its proposal that included [DELETED]. Protester's Comments at
   14. However, our review of the record confirms that these areas of the
   proposal were replete with "will do" statements and did not adequately
   explain "how" PPDG would meet the staffing needs during a surge event.[4]
   Since the RFP required offerors to adequately explain how they would
   accomplish requirements and cautioned them against relying on "will
   comply" language, we find reasonable the agency's conclusion that PPDG's
   proposal was deserving of proposal weaknesses and deficiencies under this
   evaluation factor for failing to provide adequate information in its
   proposal.

   For example, the TEP assessed a "weakness/deficiency" to PPDG's proposal
   because PPDG relied on "untested relationships" with the per diem nurses
   to meet the "surge capacity" requirements of the contract. AR, Tab 10,
   Consensus Technical Evaluation, at 3. According to the agency, PPDG did
   not show that these per diem nurses were readily available or that PPDG
   had an actual relationship with these nurses; rather, PPDG's proposal
   stated only that the [DELETED] AR, Tab 4, PPDG's Technical Proposal, at 9;
   HHS's Legal Memorandum at 16. Although the agency recognized that PPDG's
   proposal identified, as [DELETED] the agency reasonably concluded that
   this did not demonstrate that PPDG could use per diem nurses in sufficient
   numbers to meet the surge requirements. HHS's Legal Memorandum at 17.
   Although PPDG disagrees with this assessment, it has not shown it to be
   unreasonable.[5]

   The agency also assessed a "weakness/deficiency" to PPDG's proposal
   because the proposal addressed building closures in only one or two
   locations in the event of a pandemic and "[did] not address how [the firm]
   would manage in a large scale event" affecting many or all sites." [6] AR,
   Tab 10, Consensus Technical Evaluation, at 3. The agency noted, as well,
   that PPDG's proposal failed to address how employees would be compensated
   during a pandemic. Id. The agency found that this did not evidence that
   PPDG understood the serious impact of a pandemic, which increased the
   likelihood that PPDG would be unable to meet the contract requirements
   during such a critical time. Contracting Officer's Statement at 6, 8.

   In response to the agency's criticism, PPDG contends that the term
   "pandemic" was never defined in the solicitation and, since the RFP did
   not state that natural disasters could result in multiple site closings,
   PPDG's proposal should not have been penalized. Protester's Comments at
   16. PPDG asserts that it is "difficult to imagine a pandemic or natural
   disaster that would affect most or all of the sites." Protest at 7.
   However, the protester also admits that a pandemic is "an epidemic that
   spreads through human populations across a large region (for example a
   continent), or even worldwide," thus recognizing the widespread impact of
   a pandemic. Protester's Comments at 9. Under the circumstances, we think
   that the protester did not reasonably address the impact of widespread
   building closures in its proposal, as was required by the RFP.

   In addition, we find no error in the agency's assessed
   "weakness/deficiency" concerning PPDG's proposed compensation plan. In
   this regard, the RFP required the offerors to address employee
   compensation during pandemic events, RFP sect. M.4.2.1., and PPDG concedes
   that its proposal did not "specifically address" compensation of employees
   under the pandemic and natural disaster plan. Protest at 5. Although the
   protester contends that there is "no reason to differentiate between a
   routine [payroll] process and a pandemic payroll situation because
   employees will be compensated in accordance with governing laws under both
   situations," and that there are "as many as sixty variables" that
   influence compensation during a pandemic, Protester's Comments at 9, 11,
   these arguments appear nowhere in its proposal and do not excuse the
   protester's failure to respond to a requirement of the RFP.[7]

   TRANSITION PLAN

   The transition plan evaluation factor required offerors to submit a
   transition plan that detailed the methods that would be used to ensure a
   smooth transition from the incumbent contractor to the offeror. Among
   other things, offerors were required to submit an "organizational chart
   that displays internal and external organizational relationships,"
   identify the "[m]ethods to orient and educate incumbents/new hires about
   the offeror's company and [employee] benefits," and provide a "Recruitment
   and Retention Plan." RFP sect. M.4.2.2.

   As noted above, the TEP identified several "weaknesses/deficiencies" in
   PPDG's proposal under the transition plan factor. One of the
   "weaknesses/deficiencies" was the firm's failure to provide an
   organizational chart. AR, Tab 10, Consensus Technical Evaluation, at 4.
   Our review of the record confirms, and PPDG concedes, that PPDG failed to
   provide an organizational chart as required by the solicitation. Although
   PPDG contends that the assessment of a weakness for this omission
   "elevates form over substance," since elsewhere in its proposal PPDG
   provided "extensive narrative" concerning the organization and roles of
   its management personnel, Protester's Comments at 37, our review of PPDG's
   proposal reveals only a few general statements about the roles of four
   positions, which do not satisfy the RFP requirement for an organizational
   chart.

   The TEP also assessed a "weakness/deficiency" because PPDG's proposal was
   unclear about "who" would perform the orientation of the new and incumbent
   staff and "how" the orientation would be conducted. AR, Tab 10, Consensus
   Technical Evaluation, at 4. With regard to "who" would perform the
   orientation, PPDG's proposal stated that orientation is [DELETED]. AR, Tab
   4, PPDG's Technical Proposal, at 6. With regard to "how" the orientation
   would be conducted, PPDG's proposal stated that [DELETED] AR, Tab 4,
   PPDG's Technical Proposal, at 6.

   The agency explains, however, that it was unclear from PPDG's proposal
   which of the [DELETED] listed individuals would be conducting the
   orientation and, because of the large number of sites and staff, it was
   "imperative" that the offeror clearly define who will orient the new
   staff. Contracting Officer's Statement at 12. In addition, the agency
   determined that the written materials that PPDG identified for use during
   the orientation do not address PPDG's "company and its benefits," as is
   required by the RFP. Id., See RFP sect. M.4.2. Since PPDG did not satisfy
   the RFP requirements, we conclude that the agency could reasonably
   downgrade PPDG's proposal under the transition plan factor on this basis.

   The TEP also assessed a proposal "weakness/deficiency" because PPDG
   proposed "[u]nrealistic recruitment and retention timelines." PPDG
   contends that this weakness is unsupported by the record and is
   inconsistent with an identified strength for providing a "[g]ood
   recruitment and retention plan." AR, Tab 10, Consensus Technical
   Evaluation, at 4. The agency explains that, while the plan itself was
   "thorough," the timelines proposed were "unrealistic"; thus, HHS assessed
   both a strength and a weakness to PPDG's proposal under this evaluation
   factor. HHS's Supp. Legal Memorandum at 23.

   We agree with the agency that there is nothing inconsistent with the
   assessment of both a strength and a weakness to PPDG's proposal, and we
   further find that the agency's conclusions are reasonable. Although the
   record confirms that PPDG provided a detailed timeline in its proposal for
   transition events, the agency persuasively explained in its report why the
   short deadlines for accomplishing particular tasks did not appear to be
   realistic, given the size and scope of the contract. For example, PPDG
   claimed that it will be able to process incumbent employees, perform
   background checks, test for competencies, and submit the information to
   the project officer within 10 days of contract award; in addition, the
   proposal provided for only 6 days of orientation involving staffing
   services in 22 states for the entire contract. Both of these timelines,
   the agency reasonably determined, were "unrealistic." Supp. Contracting
   Officer's Statement at 3-4. Although PPDG disagrees with the agency's
   assessment, it has not shown it to be unreasonable.

   CORPORATE EXPERIENCE & CAPABILITY

   Under the corporate experience and capability factor, offerors were to
   "describe past experiences and current capabilities which enable the
   Offeror to operate a Federal occupational health program of the scope and
   complexity described in the statement of work, focusing on work
   successfully accomplished within the past 5 years." RFP sect. M.4.2.3. The
   offeror also was required to "cite the population served, the volume and
   types of services provided, the range of categories employed, [and list]
   any innovations developed, and significant occupational health and program
   management problems solved." Id.

   Among the several "weaknesses/deficiencies" identified under this factor,
   the TEP found that PPDG provided "misleading" information in its proposal,
   implying that the firm was the current FOHS contractor in Texas,
   Louisiana, Oklahoma, Arkansas, and Kentucky. AR, Tab 10, Consensus
   Technical Evaluation, at 5. Specifically, the agency took issue with a
   chart provided in PPDG's proposal that purports to identify the company's
   "Professional Performance Experience." This chart listed each of the
   designated personnel labor categories, and the geographic location of
   "current/past" performance for each labor category. AR, Tab 4, PPDG's
   Technical Proposal, at 25. This suggested to the agency that PPDG was
   claiming that it had experience in all of the stated geographic areas,
   when in fact it did not. Although PPDG contends that its proposal was not
   misleading and informed the agency that the experience was that of
   individuals, and not PPDG "as a whole," Protester's Comments at 49, our
   review confirms that, at best, the proposal was unclear. Since PPDG has
   the burden of submitting an adequately written proposal, we find no error
   in the agency's assessment of a weakness here. Global Eng'g & Constr.
   Joint Venture, supra, at 3.

   The agency also assessed PPDG's proposal a "weakness/deficiency" because
   the firm "failed to provide innovations developed, and [failed to
   identify] significant occupational health and program management problems
   solved." AR, Tab 10, Consensus Technical Evaluation, at 5. In this regard,
   the agency explains that although PPDG listed what the firm determined to
   be innovations (which included a [DELETED]) PPDG's proposal omitted any
   explanation of how or why these items were innovative, unique, or
   pioneering. For example, the agency could not understand how a 401(k) plan
   could be construed as an innovation. HHS's Legal Memorandum at 35-36.

   PPDG argues that its proposal should not have been downgraded because the
   solicitation calls for occupational health staffing and services, and not
   research and development, and that its technical proposal was limited to
   35 pages. Protester's Comments at 44. However, PPDG misses the point.
   PPDG's proposal failed to explain how the innovations identified in its
   proposal satisfied this requirement. Based on our review of the record, we
   find the agency's evaluation of PPDG's proposal, under the corporate
   experience and capability factor, to be reasonable.

   GENERAL TECHNICAL APPROACH

   Under the general technical approach evaluation factor, offerors were
   required to describe, among other things, "the corporate infrastructure
   and management roles of the project director, other key personnel, [and
   others] employed in project management." In addition, offerors were to
   provide a description of "their company problem resolution plan and how it
   would work with [the] FOH[S] specific problem resolution policy." RFP
   sect. M.4.2.4.

   The TEP assessed multiple "weaknesses/deficiencies" to PPDG's proposal
   under this factor, including a weakness because the roles of the "PM"
   (project manager) and "PD" (project director) were "not clear," and
   several of their responsibilities were found to overlap. AR, Tab 10,
   Consensus Technical Evaluation, at 6. The agency explains that this
   weakness was crucial because "differing roles and having clear lines of
   communication and responsibility is a key element in proper performance of
   a contract." HHS's Supp. Legal Memorandum at 29. PPDG contends that the
   agency's evaluation is flawed, because PPDG did not propose a "project
   manager", instead, it proposed a "contract manager." Protester's Comments
   at 55; Protester's Supp. Comments at 17. However, the record demonstrates
   that the agency evaluated PPDG's proposed contract manager and merely
   referred to this position as the "PM" in the evaluation record. We find
   that the misstatement of the position name had no impact on the
   reasonableness of the evaluation. Furthermore, the record confirms that
   PPDG's proposal was unclear with regard to the overlapping roles of the
   project director and contract manager, which was the basis for the
   weakness assessed.

   The TEP also assessed a "weakness/deficiency" to PPDG's proposal because
   the proposal contained "[n]o company problem resolution plan," as required
   by the solicitation. AR, Tab 10, Consensus Technical Evaluation, at 6. The
   agency explains that PPDG's lack of a plan is significant because "problem
   resolution between the FOHS, its customers and contractors consumes a
   tremendous amount of time on a daily basis," and if problems are not
   addressed "in a timely and systematic way," this could lead to lost
   business. HHS's Supp. Legal Memorandum at 30.

   PPDG contends that it identified potential problems and discussed "how
   those problems would be handled" throughout its proposal.[8] Protester's
   Comments at 56. However, our review of the record confirms that the agency
   reasonably determined that PPDG's proposal did not contain the required
   problem resolution plan. Although PPDG's proposal contained general
   references, in various parts of the proposal, to tasks that could
   constitute elements of a problem resolution plan, the agency was not
   required to piece together disparate parts of the firm's proposal to
   determine its intent; rather, it was PPDG's responsibility to submit a
   problem resolution plan as required by the RFP. Interaction Research
   Inst., Inc., B-234141.7, June 30, 1989, 89-2 CPD para. 15 at 4-5. On this
   basis, we find the evaluation reasonable.

   QUALITY ASSURANCE

   Under the quality assurance factor, offerors were required to provide a
   proposed "quality assurance/quality improvement (QA/QI) plan" specific to
   the FOHS. This plan was to include "detail of processes for site visit
   quality reviews including review of health unit records, and enhancing
   effectiveness of internal supervision and performance of staff, client
   satisfaction surveys, orientation and training evaluations, and other
   feedback for improved operations." The plan was also to include
   descriptions of the offeror's "malpractice and other insurance coverage."
   RFP sect. M.4.2.5.

   Among the several "weaknesses/deficiencies" identified in the evaluation,
   the TEP noted that PPDG's plan "lacked detail [that was] required of this
   element." The TEP assigned weaknesses and deficiencies because PPDG's
   QA/QI plan included "generic phrases" such as "will monitor," without
   specifying "who" or "how" the tasks would be accomplished. Additionally,
   the TEP found that PPDG's proposal failed to provide "benchmark[s] or
   specific indicators" that would be measured, and failed to discuss its
   malpractice or other insurance coverage. AR, Tab 10, Consensus Technical
   Evaluation, at 7.

   The protester disagrees with the agency's evaluation of its proposal under
   this factor. PPDG contends that its proposed [DELETED] which PPDG
   describes in its comments as a [DELETED] is responsive to the
   solicitation's requirement.[9] Protester's Comments at 57. PPDG states,
   also, that it discussed "throughout" its proposal, and specifically in the
   quality assurance section of its proposal, "its proactive approach to
   preventing problems and the process by which it will solve potential
   problems." Id. at 58. The protester does acknowledge that its proposal did
   not address its malpractice or other insurance coverage; however, it
   argues that because it failed to provide only one of the many required
   items under this evaluation factor, the agency should only have deducted
   one point from the maximum total point score for this evaluation factor.
   Protester's Supp. Comments at 32.

   We find the agency's evaluation of PPDG's proposal under the quality
   assurance factor to be reasonable. We note that the agency did assess
   PPDG's proposal a "strength" for its use of the [DELETED] but that the
   agency reasonably concluded that the firm failed to include the detailed
   information required by the solicitation under this evaluation factor. As
   noted above, the agency was not required to piece together other areas of
   PPDG's proposal to determine the details of PPDG's QA/QI plan, see
   Interaction Research Inst., Inc., supra, at 4-5, and PPDG conceded that it
   omitted some required information, such as a description of its
   malpractice coverage. On these facts, we find the agency's assessment of
   weaknesses and deficiencies under this evaluation factor to be reasonable.

   CONCLUSION

   Given our determination that the agency's evaluation of PPDG's proposal
   was reasonable and consistent with the solicitation, and in view of the
   agency's conclusion that the proposal was technically unacceptable as a
   result of the weaknesses and deficiencies identified in the evaluation, we
   find that it likewise was reasonable for the agency to conclude that
   PPDG's proposal had no reasonable chance for award and to exclude PPDG's
   proposal from the competitive range. Lakeside Escrow & Title Agency, Inc.,
   B-310331.3, Jan. 7, 2008, 2008 CPD para. 14 at 7-8.

   To the extent that the protester argues that the deficiencies cited by the
   agency could have been addressed through "clarifications," we note that
   the informational deficiencies identified would have required major
   revisions to PPDG's proposal and, thus, could not be addressed through
   clarifications. Federal Acquisition Regulation (FAR) sect. 15.306(a). To
   the extent that PPDG argues that the agency should have held discussions
   with the firm, discussions need only be held with those offerors whose
   proposals are included in the competitive range and, as noted above,
   PPDG's proposal was properly excluded from the competitive range.
   Therefore, the agency was not required to hold discussions with PPDG here.
   FAR sect. 15.306(b), (c); Essex Electro Eng'rs, Inc., B-284149;
   B-284149.2, Feb. 28, 2000, 2000 CPD para. 72 at 12.[10]

   The protest is denied.

   Gary L. Kepplinger
   General Counsel

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

   [1] Region A covers the following states: Texas, Missouri, Minnesota,
   Kansas, Indiana, Nebraska, Oklahoma, Arkansas, Louisiana, Illinois,
   Indiana, Wisconsin, Michigan, Ohio, Kentucky, Tennessee, North Carolina,
   South Carolina, Georgia, Mississippi, Florida, and Puerto Rico. RFP sect.
   B.3.

   [2] If PPDG believed that the page limitation was unrealistic and did not
   provide offerors with an adequate opportunity to respond to the
   solicitation's requirements, then it should have protested this limitation
   before the due date for proposals. 4 C.F.R. sect. 21.2(a)(1) (2008).

   [3] Although our decision discusses several of the protester's specific
   challenges to proposal weaknesses, we note that the protester also asserts
   that HHS did not give sufficient weight to proposal strengths that were
   recognized by one or more of the evaluators. However, we agree with the
   agency that the isolated comments of a few evaluators did not reflect the
   consensus opinion of the TEP, and therefore the agency reasonably
   determined not to credit PPDG's proposal with strengths based on these
   isolated comments.

   [4] For example, the proposal asserts that PPDG [DELETED] but does not
   explain how it will accomplish these activities. AR, Tab 4, PPDG's
   Technical Proposal, at 9.

   [5] Although PPDG contends that having "tested relationships" is not
   required by the RFP, we find that the agency's consideration of whether
   PPDG has established relationships with its per diem nurses is reasonably
   encompassed within the stated evaluation criteria, which required the
   agency to evaluate how an offeror would respond to temporary staffing
   surges. RFP sect. M.4.2.1.

   [6] There are 86 sites in Region A.

   [7] If the protester believed, as these arguments suggest, that the
   proposal requirement was unreasonable, it should have protested the
   solicitation requirement before proposals were due. See 4 C.F.R. sect.
   21.2(a)(1).

   [8] PPDG contends that a problem resolution plan is contained within its
   [DELETED] which PPDG argues includes [DELETED] Protester's Comments at 55.
   However, this scorecard was proposed in response to the RFP's requirements
   for a quality assurance and quality improvement plan, and does not
   specifically address the problem resolution plan requirement of the RFP.
   In any event, the agency properly credited PPDG's proposal for its
   [DELETED] under the quality assurance factor, as further discussed below.
   See AR, Tab 10, Consensus Technical Evaluation, at 7.

   [9] According to PPDG, the [DELETED] and acts [DELETED]. Protester's
   Comments at 57.

   [10] The protester cites Alliant Techsystems Inc.; Olin Corp., B-260215.4;
   B-260215.5, Aug. 4, 1995, 95-2 CPD para. 79, for the proposition that
   portions of its proposal could have been improved during discussions.
   Protester's Comments at 4; Protester's Supp. Comments at 2. We disagree
   with the protester's application of that case to this protest. Alliant
   stands for the proposition that an agency must hold meaningful discussions
   with offerors in the competitive range. Here, unlike the protester in
   Alliant, PPDG's proposal was determined to be technically unacceptable and
   was properly not included in the competitive range. Therefore, the agency
   was not required to conduct discussions with PPDG regarding its
   weaknesses, significant weaknesses, or deficiencies.