The Government Accountability Office (GAO) has just issued a decision reiterating the rule that in a best value tradeoff analysis, meaningful (meaning meaningful) consideration must be given to cost or price. Even in a competition where price is of lesser importance than technical factors, an agency must meaningfully consider cost or price in making the source selection decision.
In the case, the agency (Veterans Affairs) picked the highest rated technical proposal and compared its prices to its GSA schedule rates. Not enough, says GAO. The agency focused almost exclusively on the question of price reasonableness as determined by comparison to the awardee's GSA schedule pricing. GAO determined the lack of any meaningful consideration given to price in the tradeoff decision vitiated the selection.
In a best value procurement, it is the function of the source selection authority (SSA) to perform a price/technical tradeoff analysis meaning the SSA must determine whether a proposal's technical superiority is worth its higher price. A rule to remember. So the tradeoff analysis must include an analysis of all the proposals in the competitive range comparing each to the other on both technical and price in order to determine best value. In this case, neither the evaluated prices of the three proposals in the range, nor the differences between these prices were set forth in the SSA's tradeoff decision.
We've already reported on GAO decisions in which GAO makes it clear that the tradeoff analysis must be made on all proposals within the competitive range. It is insufficient to pick the highest rated technical proposals and make an award to them. Price must also be considered and not in the abstract or as part of a price reasonableness analysis. The heart of best value is finding, by comparison, the very best value considering the tradeoff between technical excellence and price.
Protest sustained. Reevaluation and new tradeoff analysis with rationale for any tradeoffs, including benefits associated with any price premium, recommended. Costs and attorneys fees awarded.