Minimum thresholds can be informed by incumbent rates
The Air Force solicited proposals for "training intelligence plans and exercise support for cyber readiness operations and weapons and tactics network defensive operations" and made an award to Cherokee Nation Strategic Programs, LLC (CNSP). Protestor argued that the Air Force evaluation of its proposal was unreasonable, but GAO found that the record supported the agency's evaluation. Protestor also argued that CNSP's cost was unrealistic because the agency used an "arbitrary" floor of 15% below incumbent labor rates. GAO rejected the argument, finding credible the agency's explanation that the 15% floor was "based on the collective experience of the evaluation team to determine whether a proposed labor rate was unrealistic and could present a risk to program success." GAO also rejected protestor's claim of unequal discussions and found that the agency's best-value tradeoff was documented and reasonable. Protest denied.