GAO Denies Protest Alleging Misrepresentation and Unreasonable Past Performance Evaluation in RCCTO SETA Task Order Award
In its June 17, 2025, decision in Quantum Research International, Inc., B-423237.2; B-423237.3, the Government Accountability Office (GAO) denied a protest filed by Quantum Research International challenging the Department of the Army’s award of a cost-plus-fixed-fee task order to PeopleTec, Inc. under the GSA’s OASIS SB Pool 4 vehicle. The task order supports the Army’s Rapid Capabilities and Critical Technologies Office (RCCTO) through Systems Engineering and Technical Assistance (SETA) services. The protest raised multiple allegations, including that allegedly PeopleTec had materially misrepresented its past performance, that the Army’s evaluation of proposals was flawed, and that the agency’s best-value tradeoff was improperly conducted.
Quantum’s central argument revolved around PeopleTec’s past performance submission involving a joint venture contract known as MATCH SEC. Quantum claimed that PeopleTec falsely portrayed itself as having led the task order, managing multiple subcontractors and projects across different military and federal agencies. Quantum contended that because it—not PeopleTec—was the managing member of the CybEx joint venture that performed the work, any such representations by PeopleTec constituted material misstatements and should have led to disqualification. GAO, however, concluded that even if PeopleTec’s statements were exaggerated, they were not material because they had no significant impact on the Army’s evaluation or award decision.
During the agency’s corrective action, triggered by a prior protest from Quantum, the Army requested clarifying information from PeopleTec about its role in MATCH SEC. PeopleTec affirmed that it was a JV member during execution, led elements of the work, and managed subcontractors. GAO determined that the Army reasonably accepted these representations and that even without considering MATCH SEC, PeopleTec’s proposal still demonstrated sufficient past performance to warrant a “Satisfactory Confidence” rating. Importantly, GAO noted that the contested MATCH SEC reference was only rated “somewhat relevant,” and its exclusion would not have changed the overall past performance evaluation outcome.
GAO also rejected Quantum’s claim that the Army failed to follow the stated evaluation criteria. The solicitation provided a sliding scale of past performance relevance, ranging from “very relevant” to “not relevant,” based on factors such as scope, magnitude, and complexity. GAO found that the Army reasonably assessed PeopleTec’s submissions against these criteria, appropriately rating them as “somewhat relevant” or “relevant” based on total dollar value, subcontractor complexity, and mission alignment. Contrary to Quantum’s argument, GAO clarified that the evaluation criteria did not impose hard minimums for relevance but permitted a nuanced evaluation of similarity and significance.
Further, GAO rejected the assertion that the Army had improperly bolstered PeopleTec’s proposal by reviewing additional CPARS records not tied to the five submitted references. Instead, the Army simply checked those additional records to confirm there was no adverse performance information, which did not meaningfully affect the proposal's rating or the fairness of the process.
On the question of best value, GAO concluded that the Army appropriately considered both technical merit and cost. While the protester’s proposal was deemed technically superior—particularly in qualifications and experience—it carried a substantial price premium of nearly $38 million. The Army rationally determined that PeopleTec’s proposal, with an “Outstanding” rating under the most important factor (task execution) and a much lower probable cost, represented the best value. GAO found the tradeoff decision was adequately documented and did not improperly elevate cost above the stated non-price evaluation factors.
Ultimately, GAO found no basis to sustain any part of Quantum’s protest. The case highlights several important procurement principles, including the standard for material misrepresentation, the agency’s broad discretion in evaluating past performance relevance and quality, and the necessity for protestors to demonstrate not only agency error but also competitive prejudice resulting from that error. In a complex technical procurement such as this, the burden remains on the protestor to prove that alleged flaws materially affected the award decision. Here, GAO concluded that burden was not met.
Disclaimer: This blog post is a summary of a GAO decision and is provided for informational purposes only. It does not constitute legal advice or guarantee the accuracy or completeness of the decision’s interpretation. Readers should consult the original GAO ruling or a qualified attorney for legal guidance.
