Castro & Company, LLC (9531BP25Q0010)

B-423689 Nov 13, 2025 Jump To FULL REPORT VIEW DECISION RELATED PAGES GAO CONTACTS Highlights Castro & Company, LLC, a small business of Alexandria, Virginia, protests the establishment of a blanket purchase agreement (BPA) with Contracts Management Enterprises, LLC (CME), a small business of Leesburg, Virginia, under request for quotations (RFQ) No. 9531BP25Q0010, issued by the Federal Election Commission (FEC) for financial management and accounting support services. The protester alleges that the awardee has an unmitigable organizational conflict of interest (OCI) that precludes it from award. The protester also challenges the agency's evaluation of the protester's technical quotation and the best-value tradeoff decision. We sustain the protest. View Decision Decision Matter of: Castro & Company, LLC File: B-423689 Date: November 13, 2025 Gabriel Fry, Castro & Company, LLC, for the protester. Amber N. Smith, Esq., Steve N. Hajjar, Esq., Jean Mauss, Esq., and Raeed N. Tayeh, Esq., Federal Election Commission, for the agency. Uri R. Yoo, Esq., and Alexander O. Levine, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision. DIGEST 1. Protest alleging that agency failed to consider unmitigable organizational conflict of interest (OCI) is sustained where the agency failed to document its consideration of an apparent OCI arising from the awardee's role providing a contract specialist in the agency's procurement office. 2. Protest challenging reasonableness of agency's technical evaluation is sustained where the evaluation of the protester's quotation under the technical approach factor was unsupported by the record and inadequately documented. 3. Protest challenging agency's best-value tradeoff decision is sustained where the agency's tradeoff analysis did not include any documented rationale for not considering the protester's lowest-priced quotation. DECISION Castro & Company, LLC, a small business of Alexandria, Virginia, protests the establishment of a blanket purchase agreement (BPA) with Contracts Management Enterprises, LLC (CME), a small business of Leesburg, Virginia, under request for quotations (RFQ) No. 9531BP25Q0010, issued by the Federal Election Commission (FEC) for financial management and accounting support services. The protester alleges that the awardee has an unmitigable organizational conflict of interest (OCI) that precludes it from award. The protester also challenges the agency's evaluation of the protester's technical quotation and the best‑value tradeoff decision. We sustain the protest. BACKGROUND The FEC is charged with preventing corruption in the federal election campaign process by administering, enforcing, and formulating policy with respect to the Federal Election Campaign Act of 1971. Contracting Officer's Statement (COS) at 1. In support of this statutory mandate, the finance division of the agency's Office of the Chief Financial Officer (OCFO) provides budgetary, accounting, and financial reporting support. Id. To accomplish its mission, the OCFO requires financial management and accounting support services, which were previously provided under a predecessor BPA that expired in June 2025. Id. The agency issued the solicitation on April 25, 2025, by providing the RFQ via email to seven potential vendors.[1] Id. The solicitation was issued as a total set-aside for small businesses and anticipated the establishment of a single award BPA for a 1-year base period with four 1‑year option periods. Agency Report (AR), Exh. 3, RFQ at 7, 15.[2] The solicitation provided for award on a best‑value tradeoff basis considering three factors: (1) technical approach; (2) price; and (3) past performance. Id. at 33. For tradeoff purposes, technical approach would be significantly more important than price, and price would be more important than past performance. Id. The solicitation informed vendors that the agency may “accept other than the lowest priced or highest technically rated offer and may reasonably determine that the [o]fferor with the highest rated in non-price factors is the best value.” Id. at 36. Under the technical approach factor, vendors were required to submit a quotation that addresses section 3 of the statement of work (SOW) and “effectively demonstrates the [o]fferor's clear understanding of all the tasks and how the approach is likely to yield the required results.” Id. at 32. In this regard, vendors were directed to demonstrate their understanding of the tasks to be performed, “as well as the technical approach and methodology and flexibility that will be utilized” in accomplishing the requirement. Id. The proposed methodology was to include: technical expertise as it related to the requested service; application of government standards; quality control process; timeliness; and business relations.