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Talk Is Cheap, Time Is Not: GAO Denies NOAA Oral Presentation Protest

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In Manutek Inc., B-423476.2, et al. (Jan. 1, 2026), Manutek protested the National Oceanic and Atmospheric Administration’s decision not to award it an IDIQ contract for professional, scientific and technical services under the ProTech 2.0 Weather Domain. The protest focused largely on the agency’s evaluation of Manutek’s oral presentation, including alleged flaws in time management, documentation, evaluator judgments and the conduct of the post-presentation interactive dialogue.

Manutek argued that NOAA improperly downgraded its management approach based on an incomplete and insufficiently documented oral presentation, ignored information Manutek claims it presented, improperly credited oral presentation weaknesses based on a lack of “granular detail” not required by the RFP and unreasonably refused to ask clarifying questions during the interactive dialogue. GAO denied the protest in full, providing a detailed roadmap of common oral presentation pitfalls and explaining how it resolves credibility disputes and documentation challenges.

The Decision
GAO denied the protest, ruling that:

  1. Poor Time Management During an Oral Presentation Is the Offeror’s Risk: Manutek spent most of its allotted 45 minutes addressing the first two of four required scenarios, leaving little time to meaningfully address the third and fourth. GAO credited the evaluators’ contemporaneous conclusion that Manutek provided very little substantive information on the final two scenarios and rejected Manutek’s attempt to shift responsibility to the agency. GAO reiterated that it is the offeror’s obligation to plan and execute its presentation within the time provided.
  2. NOAA Reasonably Documented the Oral Presentation Evaluation: Manutek argued that NOAA’s evaluation was inadequately documented because the record lacked evaluator worksheets, transcripts, recordings or detailed contemporaneous notes. GAO rejected this argument, emphasizing that FAR 15.102(e) gives agencies discretion to choose how oral presentations are memorialized, including through “government notes,” which NOAA used here. The “on-the-spot” evaluation report contained contemporaneous observations identifying what was and was not presented and provided a sufficient basis for meaningful GAO review.
  3. GAO Rejected Manutek’s “He Said, She Said” Declaration Argument: Manutek submitted a declaration from one of its presenters asserting that the firm had, in fact, addressed all required elements during the oral presentation. NOAA countered with a declaration from an evaluator who attended the presentation and provided a detailed, sequential account explaining what Manutek failed to address. GAO credited the evaluator’s account and found no evidence that NOAA ignored information that was actually presented.
  4. Piecemeal Declarations Will Be Disregarded: GAO also declined to consider Manutek’s declaration because it was submitted in piecemeal fashion—after the initial protest—when responding to a dismissal request.
  5. Agency Did Not Require “Granular Detail” Beyond the RFP: Manutek argued that NOAA improperly required a level of detail not contemplated by the solicitation. GAO disagreed, holding that NOAA’s expectation that Manutek explain specific examples, metrics and outcomes was logically encompassed by the RFP’s stated evaluation criteria. GAO emphasized that requiring an offeror to substantiate claims is not the same as imposing unstated evaluation criteria.
  6. NOAA Reasonably Declined to Ask Clarifying Questions During the Interactive Dialogue: Manutek claimed NOAA acted unreasonably by refusing to ask clarifying questions that could have resolved perceived weaknesses. GAO dismissed this allegation as untimely because Manutek knew the basis for the claim at the conclusion of its oral presentation but did not raise it until months later. GAO also explained that even if timely, the allegation would fail because NOAA reasonably concluded that asking questions would have invited Manutek to provide new information, effectively changing its offer, which the RFP prohibited.
  7. Strong Past Performance Could Not Overcome Weaknesses in More Important Factors: Finally, GAO upheld NOAA’s selection decision, rejecting Manutek’s argument that its exceptional past performance should have compelled award. GAO confirmed that NOAA reasonably followed the solicitation’s stated weighting, under which demonstrated technical experience and management approach were more important than past performance.

Key Takeaways for Contractors

  1. Oral Presentations Are High-Risk, High-Reward: Running out of time is not a protest ground. If you do not address required scenarios in sufficient detail during the presentation, GAO will not rescue you later.
  2. You Don’t Control the Record, The Agency Does: Agencies have wide discretion in how they document oral presentations. The absence of transcripts or recordings does not make an evaluation unreasonable where contemporaneous notes explain what was presented or omitted.
  3. Dueling Declarations Rarely Favor Protesters: When GAO is faced with conflicting declarations, it will credit contemporaneous agency records and evaluator testimony absent evidence of bad faith.
  4. “Granular Detail” Arguments Are Hard to Win: If the RFP requires offerors to demonstrate understanding of the requirements, soundness of approach, and ability to perform the contract, agencies may reasonably expect specific examples and explanations.
  5. Interactive Dialogue Is Not a Safety Net: Agencies are not required to ask questions to fix incomplete presentations—and may properly decline to do so where questions would invite offerors to change their proposals.