# Washington, DC 20548

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URL: https://www.frixlaw.com/law-library/documents/agency%3Agao%3A20b44ce1ac0e2ef0

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

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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B-423877.4

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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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Agao%3A20b44ce1ac0e2ef0. Public record. Not legal advice.