GSH of Alabama, LLC (70FB8025R000000010)

B-424012 Feb 18, 2026 Jump To VIEW DECISION DOWNLOADS RELATED PAGES GAO CONTACTS Highlights GSH of Alabama, LLC, a women-owned small business of Huntsville, Alabama, protests the issuance of a delivery order to Gibbco, LLC, a small business of Winter Park, Florida, under delivery order proposal request (DOPR) No. 70FB8025R000000010, issued by the Department of Homeland Security, Federal Emergency Management Agency (FEMA) for the production and delivery of various types and amounts of manufactured housing units (MHU). The protester argues that the agency applied an unstated evaluation criterion, the agency failed to notify offerors of material changes to its requirements and request revised proposals, and the price analysis and best-value tradeoff determination were flawed. 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: GSH of Alabama, LLC File: B-424012 Date: February 18, 2026 Casey J. McKinnon, Esq., and Anam Abid, Esq., Cohen Seglias Pallas Greenhall & Furman PC, for the protester. Jonathan Gibb, for Gibbco LLC, the intervenor. Sean Grafton, Esq., and Katlyn Har, Esq., Department of Homeland Security, for the agency. Janis R. Millete, Esq., and John Sorrenti, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision. DIGEST 1. Protest that agency applied unstated evaluation criterion is denied, where the agency's evaluation was reasonable and consistent with the solicitation. 2. Protest that agency improperly failed to amend the solicitation because it knew or should have known that its requirements had changed prior to award is denied where changes were not material. 3. Protest challenging agency's price analysis and best-value tradeoff is denied where the record shows that the price evaluation and best-value tradeoff were reasonable and consistent with the solicitation. DECISION GSH of Alabama, LLC, a women-owned small business of Huntsville, Alabama, protests the issuance of a delivery order to Gibbco, LLC, a small business of Winter Park, Florida, under delivery order proposal request (DOPR) No. 70FB8025R000000010, issued by the Department of Homeland Security, Federal Emergency Management Agency (FEMA) for the production and delivery of various types and amounts of manufactured housing units (MHU). The protester argues that the agency applied an unstated evaluation criterion, the agency failed to notify offerors of material changes to its requirements and request revised proposals, and the price analysis and best-value tradeoff determination were flawed. We deny the protest. BACKGROUND On March 3, 2025, FEMA issued the DOPR to firms holding contracts under its MHU indefinite-delivery, indefinite-quantity (IDIQ) contract, pursuant to the procedures of Federal Acquisition Regulation (FAR) subpart 16.5. Agency Report (AR), Tab 3, DOPR at 5.[1] The solicitation contemplated purchase of a base quantity of one-bedroom, two-bedroom, and three-bedroom NextGen MHUs, and two-bedroom and three-bedroom California Wildlands-Urban Interface MHUs; and an option for various quantities of one-bedroom, two-bedroom, and three-bedroom NextGen MHUs. Id. at 3. The DOPR expected the issuance of one or more fixed-price delivery order(s) with selection on a best-value tradeoff basis considering technical approach, past performance, and price. Id. at 5. The DOPR further stated: all non-cost evaluation criteria, when combined are significantly more important than cost or price. The Government will conduct a detailed evaluation of the contractors' approach and capability to meet the Government's objectives against the following evaluation factors in order of importance[]: Factor 1 (Technical Approach), Factor 2 (Past Performance), Factor 3 (Price). As the technical merit of competing proposals became more equal, the price factor increases in importance in the award decision. Id. Relevant here, the DOPR advised that the agency would evaluate technical approach by considering an offeror's ability to demonstrate production of MHUs within three weeks of award, to complete production within 45 to 70 days from award, and to initiate delivery of MHUs within 50 days of production start for both base and optional units. Id. Furthermore, the agency would evaluate the degree to which the offeror “demonstrates the ability to meet the requirements outlined in the [statement of work] and th[e] DOPR's instructions.” Id. The agency received proposals from six offerors, including GSH and Gibbco. Contracting Officer Statement (COS) at 6. Following the initial evaluation of proposals, the agency established a competitive range to conduct discussions with four offerors, including GSH and Gibbco. Id. at 6.