System Studies & Simulation, Inc. v. United States

CourtUnited States Court of Federal Claims
DecidedMarch 4, 2025
Docket24-1429
StatusPublished

This text of System Studies & Simulation, Inc. v. United States (System Studies & Simulation, Inc. v. United States) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
System Studies & Simulation, Inc. v. United States, (uscfc 2025).

Opinion

OPINION AND ORDER HADJI, Judge. This is a post-award bid protest arising from the U.S. Army’s handling of an Advanced Helicopter Flight Training Support (AHFTS) Services Acquisition. Plaintiffs, three disappointed offerors, challenge the Army’s alleged failure to conduct discussions, evaluation of proposals, and ultimate decision to award the AHFTS contract to CAE, Inc. (CAE or Intervenor). Before the Court are motions for judgment on the administrative record (MJAR) filed by Plaintiffs DigiFlight, Inc. (DigiFlight) (ECF 36), Amentum Services, Inc. (Amentum) (ECF 37), and System Studies & Simulation, Inc. (S3) (ECF 39). Also before the Court are Defendant’s Cross-Motion for Judgment on the Administrative Record (Def.’s MJAR) (ECF 46), and Intervenor’s Cross-Motion for Judgment on the Administrative Record and Motion for Partial Dismissal (Int.’s MJAR and MTD) (ECF 47). For the reasons stated below, the Court DENIES DigiFlight’s Motion for Judgment on the Administrative Record (ECF 36), DENIES Amentum’s Motion for Judgment on the Administrative Record (ECF 37), DENIES S3’s Motion for Judgment on the Administrative Record (ECF 39), GRANTS Defendant’s Cross-Motion for Judgment on the Administrative Record (ECF 46), and GRANTS Intervenor’s Cross-Motion for Judgment on the Administrative Record and Motion for Partial Dismissal (ECF 47).1 BACKGROUND I. Procurement History The procurement at issue involves the provision of flight training support services to the United States Army Aviation Center of Excellence (USAACE) at Fort Novosel, Alabama. AR 655. In May 2020, the Army awarded Contract No. W9124G-20-C-0008, a firm-fixed-price contract to CAE to provide flight instructors to train Army pilots operating the AH-64 Apache Longbow Helicopter, the UH-60 Black Hawk Helicopter, and the CH- 47 Chinook Helicopter. AR 6, 192. The contract was valued at approximately $88 million, with an initial base period and option periods extending through December 9, 2027 (the 2020 CAE Contract). See AR 6-7, 192. In September 2022, the Army increased the total value of the 2020 CAE Contract by $29 million to approximately $117 million; the increased amount was added to Option Periods 2, 3, and 4. AR 6-7. The Army explained that the contract modification was necessary because “[s]ince contract award, multiple global and macroeconomic events like the COVID-19 pandemic, airline pilot shortages, proliferation of the AH-64 platform to allied nations, missed Army retention goals, and overseas conflicts reduced the labor 1 This Opinion was originally filed under seal on February 12, 2025. The Court provided the parties an opportunity to review the decision for any proprietary, confidential, or other protected information and submit proposed redactions. The proposed redactions were filed on February 26, 2025, ECF 68-1, and are accepted by the Court. The sealed and public versions of this Opinion differ only to the extent of those redactions, the publication date, the corrected spelling of an attorney's name, and this footnote.

2 market to where this contract can no longer meet Government requirements.” AR 7. Due to CAE’s “difficulties recruiting and retaining qualified personnel at the labor rates provided for under the contract,” the Army declined to exercise the final three option periods of the 2020 CAE Contract and instead elected to re-compete the requirement “to allow for additional flight instructors to be hired at potentially higher salaries to increase retention, maintain flight safety, and prevent having to reduce the number of students in flight instruction courses or potentially cancel entire sessions due to instructor shortages.” AR 192. The Independent Government Cost Estimate (IGCE) for this effort estimated a total contract price of approximately . AR 148. II. The Solicitation On March 4, 2024, the Army issued Solicitation No. W9124G-24-R-0001 (the Solicitation). AR 461-632. The Army twice amended the Solicitation. See generally AR 633-703; AR 704-20. The Solicitation contemplated award of a firm-fixed-price contract with a one-year base period (including a one-month phase in period) and four one-year option periods. AR 467-84. A. Evaluation Criteria and Basis for Award The Solicitation advised offerors that proposals would be evaluated on a best value trade-off basis using four evaluation factors: Factor 1 – Technical Capability; Factor 2 – Past Performance; Factor 3 – Small Business Participation; and Factor 4 – Price. AR 650. Factor 1 (Technical Capability) was to assess “the offeror’s Technical Capability to determine the offeror’s understanding of and ability to perform the requirements of the Solicitation.” Id. Factor 2 (Past Performance) was designed to “assess[] the degree of confidence the Government has in an offeror’s ability to supply the services that meet the users’ needs based on a demonstrated record of performance.” AR 652. Factor 3 (Small Business Participation) evaluated the “level of proposed participation of small businesses” in each offeror’s proposal. AR 653. For Factor 4 (Price), the Army would evaluate the total price (total evaluated price), which included all Contract Line Item Numbers (CLINs) for the base period and all options. AR 654. Additionally, the Army would determine if a proposed price was “fair and reasonable, balanced, and complete using price analysis techniques at FAR 15.404-1(b) and FAR 15.404-1(g).” Id. The Solicitation provided that the Army would evaluate proposals under Factor 1 and Factor 3 using the following adjectival ratings: Outstanding, Good, Acceptable, Marginal, and Unacceptable. AR 650-51, 654. The Factor 1 ratings were to include consideration of risk in conjunction with offerors’ strengths, weaknesses, and deficiencies. AR 650. An “Unacceptable” rating for Factor 1 was described as one in which the “[p]roposal does not meet requirements of the solicitation and, thus, contains one or more deficiencies and is unawardable, and/or risk of performance is unacceptably high.” AR 651. The Solicitation defined a deficiency as follows: “[a] material failure of a proposal to meet a Government requirement or a combination of significant weaknesses in a proposal that increases the risk of unsuccessful contract performance to an unacceptable level (See

3 FAR 15.001).” Id. For Factor 2 (Past Performance), the Solicitation provided the following adjectival ratings: Substantial Confidence, Satisfactory Confidence, Neutral Confidence, Limited Confidence, and No Confidence. AR 652. The Solicitation explained the four factors would be weighed as follows: Factor 1 is significantly more important than Factors 2 and 3 (all other non-price factors). Factor 2 is significantly more important than Factor 3. Factors 1 through 3 (all non-price factors), when combined, are significantly more important than Factor 4 (Price). The greater the equality of proposals within the non-price factors, the more important price becomes in selecting the best value to the Government. AR 650. To be eligible for award, an offer must be rated “Acceptable” or higher for Factor 1 and Factor 3, and a rating of “Neutral Confidence” or higher for Factor 2. See AR 649- 652. The Solicitation further explained: An offeror shall be ineligible for award if (i) its proposal fails to comply with the material requirements of the solicitation … (ii) it proposes prices that are determined to be unreasonably high, unbalanced, incomplete, or inaccurate; (iii) its proposal receives a rating of ‘Marginal’ or ‘Unacceptable’ in Factor 1 or Factor 3; or (iv) its proposal receives a rating of ‘Limited Confidence’ or ‘No Confidence’ in Factor 2. AR 649-50. The Solicitation further advised that “[t]he Government intends to conduct discussions in accordance with DFARS § 215.306(c)(1).” AR 649. However, in the next immediate sentence, the Solicitation cautioned: “[h]owever, the Government may choose to award without discussions.

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System Studies & Simulation, Inc. v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/system-studies-simulation-inc-v-united-states-uscfc-2025.