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Air Force interesting approach to best value. Wise to use this?

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Nash & Cibinic in February talked about combining source selection procedures. In the recent case linked here, K-MAR B-411262, the Air Force's approach to best value is interesting.

One the one hand the AF told offerors that past performance, evaluated qualitatively not pass/fail, is significantly more important than price. On the other other hand the AF essentially stated it would rank-order proposals by price and then evaluate past performance of only the lowest priced proposal and if that offeror was rated substantial confidence for past performance then the evaluation process would stop. The Air Force did just that and K-MAR protested because its proposal and its past performance wasn't considered. Protest denied.

In a footnote the GAO notes that K-MAR failed to protest the RFP's evaluation scheme prior to the deadline for proposals.

What if K-MAR had timely protested the RFP's best value evaluation process, do you think the GAO would have sustained that protest?

Is it wise to use this AF approach that past performance is more important than price but then not consider other offerors' past performance?

http://www.gao.gov/products/B-411262,B-411262.2#_ftnref5

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For certain acquisitions, the method is expressly permitted:

FAR 13.106-2 ( b ) (4) For acquisitions conducted using a method that permits electronic response to the solicitation, the contracting officer may

(i) After preliminary consideration of all quotations or offers, identify from all quotations or offers received one that is suitable to the user, such as the lowest priced brand name product, and quickly screen all lower priced quotations or offers based on readily discernible value indicators, such as past performance, warranty conditions, and maintenance availability; or

(ii) Where an evaluation is based only on price and past performance, make an award based on whether the lowest priced of the quotations or offers having the highest past performance rating possible represents the best value when compared to any lower priced quotation or offer.

Plus, the GAO appeard not to have any objections to the method.

Here is an earlier WIFCON thread concerning the same method:

http://www.wifcon.com/discussion/index.php?/topic/2910-can-agency-just-award-to-highest-rated-highest-priced-proposal-without-explaining-the-tradeoff-ppt-question/

If that situation, the government awarded to a higher priced proposer, which it had to do under that scheme. It had no opportunity to conduct discussions to obtain a lower price. Thus,past performance was the most important factor.

Is it wise? Perhaps for some simple, straightforward acquisitions, where one anticipates that there will be good competition..

If only done for the convenience of the government, then I'd question the wisdom when applied for such reason on a widespread scale.

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The Performance-Price Tradeoff (PPT) method raises practical issues. When agencies try to use PPT for "FAR Part 15" solicitations, PPT does not allow for compliance with FAR 15.306(c ) (it requires evaluation "against all evaluation criteria"). In PPT, usually the solicitation will say that Price is evaluated first, then only those proposals found to have F&R price move on to be evaluated for Technical, then only those proposals found Technically Acceptable move on to be evaluated for Past Performance. If an agency intends to hold discussions, and they want to do a Competitive Range, it looks like the agency could just do the Competitive Range "cut-off" by including in discussions only those offerors with technically acceptable proposals. In other words, an agency does not have to evaluate on "all" evaluation criteria, as the agency does not even get to evaluating Past Performance until after the Competitive Range has been made.

But I can see how a disgruntled offeror might see this as the agency failing to comply with FAR 15.306©. As far as I know, GAO has not addressed this specific question.

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All the Air Force did in the linked protest procurement (K-MAR) was conduct an LPTA source selection. "Technical acceptability" was based on past performance. Here's how the RFP described the process:

If the lowest priced evaluated offer is judged to have a Substantial Confidence performance assessment, that offer represents the best value for the government and the evaluation process stops at this point. Award shall be made to that offeror without further consideration of any other offers.

If the lowest priced offeror is not judged to have a Substantial Confidence performance assessment, the next lowest priced offeror will be evaluated and the process will continue (in order by price) until an offeror is judged to have a Substantial Confidence performance assessment or until all offerors are evaluated. The Source Selection Authority shall then make an integrated assessment best value award decision.

All the Air Force needed to say was that they would (1) identify the firm that proposed the lowest price, (2) determine if its price is reasonable, (3) if the price is reasonable, evaluate its past performance for "substantial confidence" (technical acceptability), and (4) if it passes that test, award it the contract. If the lowest priced offeror does not pass the technical acceptability test they will move on to the offeror with the second lowest price, and so forth. There is no prejudice to offerors not receiving further evaluation There is nothing new in this approach. No big deal.

​As for the Air Force statement that past performance was more important than price, it was confusing in the context of LPTA, in which price is always the deciding factor. Statements of relative importance don't make much sense in LPTA, but FAR appears to require them anyway, and the Air Force did the best it could. The best thing to say in an LPTA solicitation is that "technical acceptability is the threshold factor, but price will be the deciding factor." I suppose it's possible that technical acceptability could involve tradeoffs among non-price factors, but I haven't thought much about that.

govt2310, on what do you base your understanding of the USAF PPT method?

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