Hurricane Consulting Inc (36C79125R0001)

B-423839,B-423839.3,B-423839.4,B-423839.5 Jan 02, 2026 Jump To FULL REPORT VIEW DECISION RELATED PAGES GAO CONTACTS Highlights Hurricane Consulting, Inc. (HCI), a service-disabled veteran-owned small business of Tampa, Florida, protests the elimination of its proposal from the competition under request for proposals (RFP) No. 36C79125R0001, issued by the Department of Veterans Affairs, for warehouse logistics support services. The protester argues that the agency's evaluation of HCI's technical proposal was unreasonable and tainted by various procurement improprieties. We deny the protest. View Decision DOCUMENT FOR PUBLIC RELEASE The decision issued on the date below was subject to a GAO Protective Order. This version has been approved for public release. Decision Matter of: Hurricane Consulting, Inc. File: B-423839; B-423839.3; B-423839.4; B-423839.5 Date: January 2, 2026 Jerry A. Miles, Esq., Deale Services, LLC, for the protester. Vanessa L. Calabrese, Esq., and Shawn Larson, Esq., Department of Veterans Affairs, 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 challenging agency's evaluation of protester's proposal as unacceptable is denied where the agency reasonably assessed a deficiency to the protester's proposed key personnel for failing to satisfy the solicitation's minimum requirements. 2. Protester is not an interested party to challenge agency's past performance evaluation where the agency reasonably assessed a deficiency under the organizational management factor, rendering the proposal unacceptable and unawardable. DECISION Hurricane Consulting, Inc. (HCI), a service-disabled veteran-owned small business of Tampa, Florida, protests the elimination of its proposal from the competition under request for proposals (RFP) No. 36C79125R0001, issued by the Department of Veterans Affairs, for warehouse logistics support services. The protester argues that the agency's evaluation of HCI's technical proposal was unreasonable and tainted by various procurement improprieties. We deny the protest. BACKGROUND On April 2, 2025, the agency issued the solicitation pursuant to Federal Acquisition Regulation (FAR) part 15, as a set-aside for service‑disabled veteran‑owned small businesses. Contracting Officer's Statement (COS) at 3; Agency Report (AR), Tab 5, Amended RFP at 1.[1] The RFP included a detailed performance work statement (PWS) describing a broad range of facility support and material handling responsibilities to support the agency's three service distribution warehouse locations: two Denver logistics service centers in Golden, Colorado, and Lakewood, Colorado; and one service distribution center (SDC) in Hines, Illinois. See RFP at 6‑41. The solicitation contemplated the award of up to two fixed-price with economic price adjustment, indefinite‑delivery, indefinite-quantity contracts for a 1‑month phase‑in period, an 11‑month base period, four 1‑year option periods, and a 6‑month option to extend services. Id. at 11‑12, 109. The solicitation provided for evaluations in three phases. In phase 1, proposals would be screened for completeness and evaluated under the two non-price factors: (1) past performance; and (2) organizational management. Id. at 108‑109. The organizational management factor encompassed three subfactors of equal importance: (1) program management plan; (2) staffing plan; and (3) quality control plan. Id. at 110. Only offerors whose proposals receive ratings of acceptable or better for both factors would proceed to phase 2 for price evaluation. Id. at 109. As relevant here, the solicitation advised that a rating of unacceptable for any factor or subfactor would render the entire proposal technically unacceptable, removing it from further consideration for award. Id. at 109, 111. In phase 3, the agency would conduct a best‑value tradeoff considering price and non‑price factors, where non‑price factors, when combined, would be more important than price. Id. at 110, 111. To demonstrate past performance, offerors were instructed to provide a comprehensive written narrative describing up to 10 examples of experience on current or previous contracts over the past five years that are relevant to the solicited work in terms of complexity, size, type, and scope as described in the PWS. Id. at 103. The solicitation provided that offerors would be evaluated to determine the “extent to which [their] recent and relevant past performance demonstrates the likelihood of successful performance in providing requirements similar in size and complexity to th[e] solicitation,” and “reflects performance which is satisfactory or better.” Id.