Washington, DC 20548

441 G St. N.W.

Washington, DC 20548

Comptroller General

of the United States

Decision

DOCUMENT FOR

PUBLIC RELEASE

Matter of:

CSA Global LLC d/b/a Client Solution Architects

The decision issued on the

File:

B-423877.4

GAO Protective Order. This

Date:

August 28, 2026

approved for public release.

date below was subject to a

redacted version has been

Lee Dougherty, Esq., Esna Mihail, Esq., and Bryan Short, Esq., Effectus PLLC, for the

protester.

Daniel R. Forman, Esq., William B. O’Reilly, Esq., and Lilliam Drenth, Esq., Crowell &

Moring LLP, for Valiant Global Defense Services Inc., the intervenor.

Paula S. Klotzback, Esq., Alexzina Taylor Wilks, Esq., and Wade L. Browen, Esq.,

Department of the Army, for the agency.

Heather Self, Esq., and Peter H. Tran, Esq., Office of the General Counsel, GAO,

participated in the preparation of the decision.

DIGEST

Protest challenging evaluation of protester’s proposal and best-value tradeoff is denied

where the record shows both were reasonable and consistent with the solicitation.

DECISION

CSA Global LLC d/b/a Client Solution Architects (CSA), of Virginia Beach, Virginia,

protests the issuance of a task order to Valiant Global Defense Services Inc. (Valiant),

of Herndon, Virginia, under task order request for proposals (RFP) No. W900KK-25-RARNG, issued by the Department of the Army for training services. The protester

challenges the evaluation of its proposal and the agency’s best-value tradeoff.

We deny the protest.

BACKGROUND

On July 2, 2025, using the procedures of Federal Acquisition Regulation part 16, the

agency issued the solicitation to the large business pool of vendors holding indefinitedelivery, indefinite-quantity (IDIQ) contracts under the Army’s Mission Training Complex

Capabilities Support multiple award contract. Agency Report (AR), Tab 3, RFP at 1-3;

Tab 27, Source Selection Decision (SSD) at 1. 1 The solicitation sought proposals for

“individual, leader, small unit, battle staff, and simulation-driven collective MISSION

1

Our citations use the PDF pagination of documents in the record.

Command (MC) training, technical, exercise, simulation, and organizational support for

the ARNG [Army National Guard] MCTSP [Mission Command Training Support

Program].” RFP at 1. The selected contractor will be required to “provide in-person or

distributed ARNG MCTSP training support emanating from all six ARNG MTCs [mission

training complexes] to include Live, Virtual, Constructive, and Gaming environments in

order to train Soldiers, leaders and military units throughout the United States, its

territories, and the District of Columbia via Mobile Training Teams.” Id.

The solicitation contemplated issuance of a single task order with both fixed-price and

cost-reimbursable contract line item numbers (CLINs), a 1-month phase-in period, an

11-month base period, four 1-year option periods, and one 6-month option to extend

services. RFP at 2, 8. The solicitation established award would be made on a

best-value tradeoff basis considering three evaluation factors: (1) technical; (2) small

business commitment; and (3) price. Id. at 8-9. The technical factor was more

important than the small business factor, and the two non-price factors combined were

more important than price. Id. at 9. The technical factor was composed of the following

three subfactors, listed in descending order of importance: (1.1) staffing plan;

(1.2) recruitment and retention strategy; and (1.3) phase-in plan. Id.

The solicitation provided the agency would assign proposals one of the following

adjectival ratings under each of the technical subfactors as well as for the technical

factor overall: outstanding, good, acceptable, marginal, or unacceptable. RFP at 5.

The small business factor would be rated on an acceptable/unacceptable basis. Id.

at 7. For price, the agency would evaluate an offeror’s fixed-price CLINs for

“reasonableness, completeness, comprehensiveness,” and balance. Id. at 8. Then, the

agency would derive an offeror’s total evaluated price (TEP) by adding the proposed

fixed-price CLINs to the “Government provided Cost CLIN values” and the six-month

option to extend services value. Id.

The agency received six timely proposals, including those submitted by CSA and

Valiant. AR, Tab 27, SSD at 3. In August of 2025, the Army selected General

Dynamics Information Technology, Inc.’s (GDIT) proposal as offering the best value to

the agency. Id. at 1. Two unsuccessful offerors protested the initial source selection of

GDIT to our Office. In response to those protests, the agency notified our Office that it

intended to take corrective action by reevaluating proposals and making a new source

selection decision; as a result, we dismissed the protests as academic. Valiant Global

Def. Servs., Inc., B-423877, Sept. 26, 2025, at 1 (unpublished decision); CSA Global

LLC d/b/a Client Solution Architects, B-423877.2, Sept. 30, 2025, at 1-2 (unpublished

decision).

In implementing its corrective action, the Army reevaluated proposals under the

technical factor and its three subfactors, but the agency did not reevaluate under the

small business commitment or price factors. AR, Tab 27, SSD at 3-5. The final

evaluation of CSA’s and Valiant’s proposals was as follows:

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Factor 1--Technical--OVERALL

Subfactor 1.1--Staffing Plan

Subfactor 1.2--Recruitment and

Retention

Subfactor 1.3--Phase-In Plan

Factor 2--Small Business

Commitment

Factor 3--Price (TEP)

CSA

ACCEPTABLE

Acceptable

Valiant

GOOD

Good

Acceptable

Good

Good

Good

Acceptable

$288,601,921

Acceptable

$299,177,674

Id. at 5. In April of 2026, based upon the evaluations and a comparative assessment of

proposals, the source selection authority (SSA) selected Valiant’s proposal as providing

the best value to the agency. 2 Id. at 1, 18, 21. After being notified of the source

selection decision and receiving a debriefing, CSA filed this protest with our Office. 3

DISCUSSION

The protester challenges the evaluation of CSA’s proposal under the staffing plan

subfactor. Further, the protester contends the underlying evaluation flaws resulted in an

unreasonable best-value tradeoff, and alleges that the agency has failed to justify

payment of the approximately $10.5 million price premium associated with Valiant’s

proposal. Although we do not specifically address every argument, or permutation

thereof, raised by the protester, we fully considered them all and find none provides a

basis to sustain the protest. 4

Valiant is the incumbent contractor currently providing the solicited training services.

RFP at 1. GDIT also protested the issuance of the task order to Valiant, but later

withdrew its protest. See B-423877.3.

2

As the value of the protested task order exceeds $35 million, this protest is within our

jurisdiction to hear protests of task orders placed under defense agency IDIQ contracts.

10 U.S.C. § 3406(f)(1)(B).

3

For example, we do not discuss in detail the protester’s argument that the agency

applied an inconsistent rating methodology across subfactors. Relevant here, the

evaluators called the strengths and weaknesses assessed in proposals “merits” and

“risks.” See RFP at 5 (defining a rating of outstanding as indicating a proposal “contains

multiple merits” and has a low risk); AR, Tab 27, SSD at 14-15 (noting “Merit 1.1” and

“Risk 1.1” assessed in CSA’s proposal). In this connection, CSA was assessed one

merit each under the recruitment and retention subfactor (1.2) and the phase-in

subfactor (1.3), but the firm’s proposal was assigned a adjectival ratings of acceptable

and good for the respective subfactors. According to the protester, it was unreasonable

for the Army to assign different adjectival ratings to subfactors when each subfactor was

assessed one merit. Protest at 16-17. The protester maintains CSA is not contending

that the assessment of one merit automatically corresponds to the assignment of a

(continued...)

4

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Staffing Plan Evaluation

The record reflects that during the original evaluation, prior to the agency’s August 2025

source selection decision, the evaluators assessed one merit and zero risks in CSA’s

proposal under the staffing plan subfactor which resulted in the assignment of an

adjectival rating of acceptable for the subfactor. AR, Tab 18, CSA Original Technical

(Tech.) Evaluation (Eval.) at 2. During the reevaluation, the evaluators assessed one

merit and one risk in CSA's proposal under the staffing plan subfactor, and, again,

assigned it an adjectival rating of acceptable. AR, Tab 24, CSA Tech. Eval. at 2.

The protester argues the agency unreasonably assessed the new “risk based on a

characterization of CSA’s proposal that is directly contradicted by multiple sections of

the proposal itself.” Protest at 14. According to the protester, it is unreasonable that

“[t]he same evaluation team examined the same proposal and reached a different, more

adverse conclusion, not because new information came to light, but because [CSA’s

prior] protest prompted the evaluators to apply a deeper level of scrutiny than they had

originally applied.” Id. at 15. The protester disclaims that it is suggesting the agency

acted in bad faith, but instead contends only that the Army applied a stricter level of

scrutiny to CSA’s proposal upon reevaluation than it applied during the original

evaluation. Id. at 16. The agency responds “that the evaluation team’s assessment of

a risk in CSA’s Sub-factor 1.1 (Staffing Plan) was reasonable and consistent with the

evaluation criteria,” and that the Army “exercised sound and reasonable judgment in the

performance of its corrective action.” Contracting Officer’s Statement and

Memorandum of Law (COS/MOL) at 12, 18.

When reviewing protests alleging improper evaluations we do not reevaluate proposals;

rather, we examine the record to determine whether the agency’s judgments were

(...continued)

rating of good, nor asking our Office to “mechanically tally strengths across subfactors."

Comments at 3-4. Rather, the protester asserts the record does not “identify the

qualitative distinction that made one merit sufficient to support ‘Good” and the other

insufficient.” Id. at 3. We disagree.

The record here reflects the evaluators’ documented basis for the single merit assessed

under the phase-in subfactor had several more subcomponents than the basis for the

single merit assessed under the recruitment and retention subfactor, and that the

evaluators considered this qualitative difference in the assessed merits when

concluding that the assignment of a higher rating was warranted on the basis of the

multi-faceted single merit assessed for CSA’s phase-in plan. Compare AR, Tab 24,

CSA Tech. Eval. at 12-13 with id. at 16-17. Accordingly, we find the protester’s claim of

an internally inconsistent rating methodology is not supported by the record and, thus,

provides no basis to sustain the protest. See e.g., Perspecta Eng’g, Inc., B-420501.2,

B-420501.3, Dec. 13, 2022, at 9 (denying allegation that evaluation was internally

inconsistent where allegation was not supported by the record).

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reasonable and in accordance with the solicitation’s evaluation criteria and applicable

procurement statutes and regulations. Battelle Memorial Inst., B-418047.5, B-418047.6,

Nov. 18, 2020, at 5. The evaluation of proposals is a matter within the agency’s

discretion, and a protester’s disagreement with the agency’s judgment about the relative

merits of competing proposals, without more, does not establish that the evaluation was

unreasonable. Id.; CACI, Inc.--Fed., B-420729.2, Mar. 2, 2023, at 7.

Assessment of Risk

In addressing the protester’s challenge to the evaluation of its proposal under the

staffing plan subfactor, we review, first, the reasonableness of the assessed risk in

CSA’s staffing plan. Relevant here, the solicitation requires the successful contractor to

provide a simulation support team (SST) composed of a sufficient number and type of

qualified personnel to “ensure each MTC can conduct one large (multi-echelon) and one

medium scale (single echelon) JLCCTC [joint land component constructive training

capability] supported exercise simultaneously.” AR, Tab 4, RFP attach. 1, Performance

Work Statement (PWS) at 23. The solicitation explains the “JLCCTC is the Army’s

constructive simulation toolkit, supporting institutional and operation unit training for the

Active Component, Reserve Component and National Guard units providing capabilities

across the range of warfighting functions.” Id. at 9.

The evaluators concluded CSA’s proposal “demonstrates risk to performance under the

JLCCTC/MRF 5 capabilities and system processes for conducting two simultaneous

simulation exercises (Large and Medium) per MTC.” AR, Tab 24, CSA Tech. Eval. at 7,

10 (citing AR, Tab 15, CSA Tech. Proposal at §§ 2.1.6.4, 2.1.6.5, 2.1.6.6.1,

Figure 2.1-13, Table 2.1-14). They found CSA proposed [DELETED] personnel to staff

the SST, and that the proposal indicated a large scale event would require the services

of all [DELETED] of these personnel; thus, leaving no SST personnel available to

conduct a simultaneous medium scale event, as required by the solicitation. Id. The

evaluators noted that CSA included in its proposal a “[DELETED] approach” whereby

personnel from [DELETED] could be [DELETED] on an as needed basis. Id. The

evaluators expressed concern, however, that the [DELETED] approach did “not include

additional [DELETED], which could increase the staffing required to conduct the two

simultaneous events.” Id. at 10.

The protester contends the evaluators’ “characterization is factually inaccurate,”

because “CSA’s proposal addresses simulation support for concurrent events in

multiple sections, through [DELETED] that [DELETED] the SST team and through an

approach to medium events that does not require the [DELETED].” Protest at 11-13

(citing AR, Tab 15, CSA Tech. Proposal at Table 2.1-14, Table 2.1-1, §§ 2.1.6.3,

2.1.6.4, 2.1.8). The protester asserts: “CSA’s proposal thus provides a concrete staffing

Many of the acronyms used by the parties are defined in either the PWS or CSA’s

proposal. See PWS at 84-90; AR, Tab 15, CSA Tech. Proposal at 5-7, 39. The

acronym MRF, however, is not defined in either document.

5

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solution for simultaneous Large and Medium events.” Protest at 13 (citing AR, Tab 15,

CSA Tech. Proposal at internal pages 27-28, 36). This explanation is not supported by

the record, which shows instead that CSA has not proposed sufficient personnel to

simultaneously run both a medium scale and large scale event utilizing the JLCCTC

simulation tool, as required by the solicitation.

In this regard, the protester’s proposal explains that CSA plans to provide [DELETED]

with a [DELETED] team (TST) consisting of a [DELETED]--with the [DELETED]

“focused on [DELETED], [DELETED], and [DELETED],” and the [DELETED] “focused

on [DELETED], and [DELETED].” AR, Tab 15, CSA Tech. Proposal at 39. The

[DELETED] will be responsible for “[DELETED] to support Large and Medium Event

Training.” Id. CSA’s proposed organizational charts show that, at [DELETED] MTCs,

the TSTs will be staffed by a total of [DELETED] personnel--[DELETED]. Id. at 15-16.

At [DELETED] MTCs, CSA proposes to staff the TSTs with a total of [DELETED]

personnel--[DELETED]. Id. at 14, 18. For the [DELETED] MTCs, CSA proposes

staffing the TSTs with a total of [DELETED] personnel--[DELETED]. Id. at 17, 19.

The protester’s proposal states “[t]he JLCCTC/MRF-Brigade” simulation tool requires 9

SST personnel--an SST lead and 8 constructive simulation engineers--plus a system

engineer from the T/NST “to operate and administer in support of its full up use for

Medium and Large Unit exercises.” Id. at 39. In other words, 10 personnel from the

TSTs proposed by CSA are required to run a training event that uses the JLCCTC

simulation tool. Thus, depending on which of the six MTCs one looks at, having 10 TST

personnel engaged with one JLCCTC training event would leave [DELETED],

[DELETED], or [DELETED] remaining TST personnel to operate a second (medium or

large unit) JLCCTC training event. Based on the protester’s own proposed requirement

of 10 TST personnel to operate one JLCCTC training event, this would leave the

second event short-staffed by [DELETED], [DELETED], or [DELETED] personnel,

respectively.

The protester attempts to overcome this personnel deficiency in staffing by referencing

CSA’s proposed approach to [DELETED]. Protest at 13; Comments at 7. In this

connection, CSA’s proposal discusses [DELETED] of personnel as “central to the

[DELETED]” and identifies [DELETED] as “needed to [DELETED].” AR, Tab 15, CSA

Tech. Proposal at 42-43. Even if we assume, for the sake of argument, that every one

of the [DELETED], [DELETED], or [DELETED] personnel proposed by CSA to staff

each MTC’s technical support teams is [DELETED], there still simply are not enough

personnel to simultaneously run a medium scale and a large scale--i.e. two--JLCCTC

training events, which by the protester’s own stated staffing requirements would take 20

personnel to operate--10 personnel per JLCCTC event.

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Based on the record here, we find the evaluators reasonably assessed a risk in the

protester’s proposal related to CSA’s ability to simultaneously conduct medium and

large scale JLCCTC events, as required by the solicitation. While the protester

disagrees with the evaluators’ judgment, it has not shown that the agency’s reading or

evaluation of CSA’s proposal was unreasonable or inconsistent with the solicitation.

Accordingly, we deny this basis of protest. See e.g., Brandan Enterprises, Inc.,

B-423385, June 16, 2025, at 14-15 (denying protest challenging assessment of

significant weakness related to offering insufficient labor hours where protester

disagreed with evaluators’ judgment but did not show it was unreasonable or

inconsistent with solicitation).

Difference Between Original Evaluation and Reevaluation

Having found the evaluators reasonably assessed a risk in CSA’s staffing plan, we next

address the protester’s contention that it was unreasonable for the risk to be assessed

during the reevaluation when it was not assessed during the original evaluation. The

gravamen of the CSA’s contention is perhaps best summarized in the rhetorical

question posed by the protester, “if the original evaluation was thorough enough to

support an award decision, why did a second look at the same proposal by the same

team produce a materially different risk assessment?” Protest at 15.

Our Office has stated consistently, the fact that a reevaluation of proposals varies from

the original evaluation does not constitute evidence that the reevaluation was

unreasonable, because it is implicit that a reevaluation can result in different findings

and conclusions. Battelle Memorial Inst., supra at 11; CACI, Inc.--Fed., supra at 5; IAP

World Servs., Inc., B-406339.2, Oct. 9, 2012, at 3. Here, CSA’s suggestion that the

agency’s initial evaluation constitutes a touchstone against which its final evaluation

must compare presents a false premise; instead, the overriding concern in our review of

a reevaluation following corrective action is not whether the final evaluation is consistent

with an earlier evaluation, but whether it is reasonable and consistent with the

solicitation. CACI, Inc.--Fed., supra at 5; HeiTech-PAE, LLC, B-420049.9,

B-420049.10, June 8, 2022, at 11-12.

On rare occasions and in unique circumstances, our Office has found that when an SSA

reviewed “starkly different” evaluation conclusions of essentially the same proposal

under the same solicitation it was incumbent upon the SSA to reconcile or explain the

different evaluation conclusions. eAlliant, LLC, B-407332.6, B-407332.10, Jan. 14,

2015, at 11-12. In reaching this finding, our Office also noted, however, that an agency

is not prohibited “in its corrective action from revising its evaluations of the offerors’

proposals, or from reaching different evaluation results or ratings.” Id. at 12.

Here, the record does not reflect the sort of starkly different evaluation results that

would require the SSA to explain or reconcile the differences between the original

evaluation--which assessed one merit, zero risks, and assigned a rating of acceptable-and the reevaluation--which assessed one merit, one risk, and assigned a rating of

acceptable. Rather, the record shows that, upon “further examination” of CSA’s

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proposal through an additional round of evaluation, the agency noticed a risk it had not

previously identified. AR, Tab 26, Corrective Action Memorandum at 2; see also

Tab 24, CSA Tech. Eval. at 11. Notably, despite the assessment of this risk, the

evaluators determined that it did not warrant a decrease in CSA’s rating of acceptable

under the staffing plan subfactor. Id.

We find no basis to question the reasonableness of the agency’s reevaluation where, as

here, the record indicates the evaluators simply noticed something they previously had

not upon rereading CSA’s proposal--similar to the way in which a person can notice a

new facet of a character or story line upon rereading a novel. See e.g., AttainX, Inc.,

B-422141.2, June 20, 2024, at 4 n.4 (denying protest argument that it was improper for

SSA not to reconcile different pre-and post-corrective action evaluations where removal

of a strength originally assessed in protester’s proposal related to a key person was due

to the evaluators noticing they had already counted that strength elsewhere).

Best-Value Tradeoff

The protester insists the Army’s best-value tradeoff is unreasonable because it is based

on a flawed evaluation. Protest at 19. This allegation is based on the protester’s

challenges to the agency’s evaluation of proposals, which as discussed above, we find

to be without merit. Accordingly, we also find this challenge to be without merit.

CSA further argues the agency has not adequately justified paying the “significant price

premium” associated with Valiant’s proposal, and that the tradeoff “failed to look behind

the adjectival ratings and compare the qualitative substance of the competing

proposals.” Protest at 19; Comments at 11. The agency responds that the SSA

performed a comparative analysis in which “the specific merits identified in each

proposal” were reviewed and formed the basis of the source selection decision.

COS/MOL at 22. Based on our review of the record, we agree with the agency.

Where, as here, a solicitation provides for issuance of a task order on a best-value

tradeoff basis, it is the function of the SSA to perform a price/technical tradeoff. Alliant

Enter. JV, LLC, B-410352.5, B-410352.6, July 1, 2015, at 13. Source selection officials

have broad discretion in deciding the manner and extent to which they will make use of

technical and price evaluation results, and the extent to which one may be sacrificed for

the other is governed only by the test of rationality and consistency with the evaluation

criteria. Cognosante MVH, LLC; ProSphere-Tek, Inc., B-421150 et al., Jan. 10, 2023,

at 22. A protester’s disagreement with an agency’s judgments about the relative merit

of competing proposals does not establish that the judgments were unreasonable. Id.;

Battelle Memorial Inst., supra at 13.

The record here shows the SSA conducted a comparative analysis of proposals. AR,

Tab 27, SSD, at 18-21. With respect to the comparison between CSA’s and Valiant’s

proposals, the SSA noted CSA’s price advantage and merits assessed in CSA’s

proposal, but also noted that CSA’s proposal introduced some risks. Id. at 19-20. In

contrast, the SSA found Valiant’s proposal offered “additional benefits related to Key

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Personnel, Knowledge Management and JLCCTC staffing approaches” that were

stronger than CSA’s proposal under the staffing plan subfactor, which was the most

important of the three subfactors under the technical factor, which, in turn, was the most

important overall evaluation factor. Id. at 20; see also RFP at 9. Similarly, the SSA

found Valiant’s proposal offered a more robust plan than CSA’s proposal to provide risk

mitigation for recruitment and retention, the second most important technical subfactor.

Id. For phase-in, the third and least important technical subfactor, and the small

business factor the SSA found CSA’s and Valiant’s proposals “about equal.” Id.

Overall, the SSA concluded Valiant’s proposal was technically superior to CSA’s

proposal under the two most important technical subfactors, and that CSA’s “Technical

Approach is not the best value to the Government despite its lower proposed price due

to the higher performance risk and fewer technical merits identified in the comparative

analysis.” AR, Tab 27, SSD at 20. Based on this record, we have no basis to question

the Army’s selection of Valiant’s higher-rated, higher-priced proposal as offering the

best value to the agency, nor does the protester’s disagreement provide such a basis.

See e.g., Cognosante MVH, LLC; ProSphere-Tek, Inc., supra at 23 (denying challenge

to selection of higher-rated, higher-priced proposal where SSA’s tradeoff noted multiple

technical benefits that warranted payment of price premium).

The protest is denied.

Edda Emmanuelli Perez

General Counsel

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