GAO Bid Protests
Here's a look at news stories involving federal bid protest decisions issued by the GAO General Counsel
Featured Stories
GAO Upholds Air Force Award Decision, Denying Protest From Alexandria's DCS Corp.
By Marlyn Vitin
WASHINGTON, Oct. 14 -- The General Accountability Office has denied a protest from DCS Corp., an information technology and engineering firm based in Alexandria, Virginia, regarding a contract for global mobility and special mission planning systems. The decision affirms the U.S. Air Force's selection of three other companies, including MORSECORP Inc., Boeing Co. and Jacobs Engineering Group Inc. for the work.
DCS Corp. had challenged its non-selection for the task orders, arguing that the Air Force unfairly evaluated its quotation and conducted a flawed best-value analysis. The Air Force's solicitation
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WASHINGTON, Oct. 14 -- The General Accountability Office has denied a protest from DCS Corp., an information technology and engineering firm based in Alexandria, Virginia, regarding a contract for global mobility and special mission planning systems. The decision affirms the U.S. Air Force's selection of three other companies, including MORSECORP Inc., Boeing Co. and Jacobs Engineering Group Inc. for the work.
DCS Corp. had challenged its non-selection for the task orders, arguing that the Air Force unfairly evaluated its quotation and conducted a flawed best-value analysis. The Air Force's solicitationsought agile software development, sustainment, and systems engineering services under a federal supply schedule contract. The agency's evaluation weighted technical capability "significantly more important than price."
The GAO's review found the Air Force's evaluation of DCS's quotation to be reasonable and consistent with the solicitation terms. A key factor in the denial was the Air Force's assessment of negative attributes under the highly important data exchange technical subfactor.
The evaluators found that DCS failed to discuss the "full range of impacts" of proposed augmented communications for combat search and rescue, discussing only the beneficial impacts and omitting any negative consequences or risks. DCS's proposal received a "marginal/yellow" rating with a "moderate risk" under this crucial factor.
The GAO rejected DCS's argument that the solicitation only required discussion of positive impacts, concluding that the plain meaning of "full range of impacts" necessarily includes both positive and negative aspects. The protest was denied on September 12, 2025.
The three awarded companies are: MORSECORP, Inc., of Cambridge, Massachusetts; The Boeing Company, of Berkeley, Missouri; and Jacobs Engineering Group, Inc., of Arlington, Virginia.
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Primary source of information - GAO: https://www.gao.gov/products/b-423482.2
Publicly Released on: Sept. 23, 2025 Published: Sept. 12, 2025
Ambika J. Biggs, Esq., William L. Walsh, Esq., and Allison P. Klena, Esq., Hirschler Fleischer, P.C., for the protester.
Clayton S. Marsh, Esq., for MORSECORP Inc.; Scott M. McCaleb, Esq., Jon W. Burd, Esq., J. Ryan Frazee, Esq., and W. Benjamin Phillips, III, Esq., Wiley Rein LLP, and Jade C. Totman, Esq., and Sarah B. Hansen, Esq., for the Boeing Company; and Robert J. Symon, Esq., Nathaniel J. Greeson, Esq., Eugene Benick, Esq., and Owen E. Salyers, Esq., Bradley Arant Boult Cummings, LLP, for Jacobs Engineering Group, Inc., the intervenors.
Matney E. Rolfe, Esq., Colonel Nina R. Padalino, and Catherine J. McSwain, Esq., Department of the Air Force, for the agency.
Michael P. Grogan, Esq., and Evan D. Wesser, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Rejects Bid Protest From Chicago's Richard Group, Upholds VA Contract for Alabama's Jarrett Construction
By Marlyn Vitin
WASHINGTON, Oct. 14 -- The General Accountability Office has denied a contract bid protest filed by Richard Group LLC, of Chicago, Illinois, upholding the U.S. Department of Veterans Affairs decision to award a construction contract to Billy W. Jarrett Construction Co. Inc., of Prattville, Alabama.
The dispute centered on the VA's contract for the construction of a replacement outpatient clinic at the Coast Guard Air Station Cape Cod, Massachusetts. The procurement, initially issued as a full and open solicitation, was later revised to be a set-aside for Service-Disabled Veteran-Owned Small Businesses
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WASHINGTON, Oct. 14 -- The General Accountability Office has denied a contract bid protest filed by Richard Group LLC, of Chicago, Illinois, upholding the U.S. Department of Veterans Affairs decision to award a construction contract to Billy W. Jarrett Construction Co. Inc., of Prattville, Alabama.
The dispute centered on the VA's contract for the construction of a replacement outpatient clinic at the Coast Guard Air Station Cape Cod, Massachusetts. The procurement, initially issued as a full and open solicitation, was later revised to be a set-aside for Service-Disabled Veteran-Owned Small Businesses(SDVOSBs) following an earlier protest from another firm.
Chicago-based Richard Group was excluded from the competition after the VA found the firm was no longer a certified SDVOSB at the time of the contract award, which was made to Jarrett for $21.8 million on June 12, 2025. Richard Group conceded it was a large business starting in 2025 but argued its eligibility should have been based on its small business status at the time it submitted its initial proposal in 2024.
The GAO, however, found that the relevant VA acquisition regulation clause unambiguously requires an offeror to be an eligible, certified SDVOSB both at the time of proposal submission and at the time of award.
The decision, issued on September 18, 2025, noted that Richard Group had conceded its SDVOSB status expired as of January 1, 2025. Consequently, the GAO found no basis to challenge the VA's determination that the firm was ineligible for the contract award, denying the protest. The award to Prattville-based Jarrett Construction remains in effect.
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Primary source of information - GAO: https://www.gao.gov/products/b-422701.2
Publicly Released on: Sept. 23, 2025 Published: Sept. 18, 2025
Thomas O. Crist, Esq., Benesch, Friedlander, Coplan & Aronoff LLP, for the protester.
Aron C. Beezley, Esq., Nathaniel J. Greeson, Esq., Eugene J. Benick, Esq., and Winni Zhang, Esq., Bradley Arant Boult Cummings LLP, for Billy W. Jarrett Construction Company, Inc., the intervenor.
Natica Chapman Neely, Esq., Department of Veterans Affairs, for the agency.
Samantha S. Lee, Esq., and Peter H. Tran, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Dismisses Reconsideration Bid Protest by Amentum Parsons, Upholding Army Award to KBR
By Marlyn Vitin
WASHINGTON, Oct. 14 -- The U.S. Government Accountability Office has dismissed a request for reconsideration filed by Amentum Parsons Logistics Services LLC, Arlington, Virginia, effectively upholding the U.S. Army's decision to award a major task order to KBR Services LLC, Houston, Texas, for military support services.
The dispute centered on a task order for Army prepositioned stock (APS) support services across locations in Europe. Amentum Parsons, based in Arlington, Virginia, had challenged the Army's selection of Houston, Texas-based KBR, arguing the Army's evaluation of both proposals was
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WASHINGTON, Oct. 14 -- The U.S. Government Accountability Office has dismissed a request for reconsideration filed by Amentum Parsons Logistics Services LLC, Arlington, Virginia, effectively upholding the U.S. Army's decision to award a major task order to KBR Services LLC, Houston, Texas, for military support services.
The dispute centered on a task order for Army prepositioned stock (APS) support services across locations in Europe. Amentum Parsons, based in Arlington, Virginia, had challenged the Army's selection of Houston, Texas-based KBR, arguing the Army's evaluation of both proposals wasflawed.
However, the case was initially dismissed in October 2024, not on the merits of the Army's evaluation, but because the GAO found Amentum Parsons was not an interested party with legal standing to protest. This finding was based on an argument raised by KBR during the protest proceedings. The GAO concluded that Amentum Parsons' own proposal contained internal inconsistencies regarding its commitment to material small business subcontracting requirements, which made the proposal ineligible for the award.
Amentum Parsons subsequently asked the GAO to reconsider the decision, asserting that the prior dismissal was based on a clear error of law. They argued that if their proposal was indeed flawed, the Army should have been required to reopen discussions to allow them to correct the small business participation conflict before being excluded from the competition.
In a September 2025 decision, the GAO's Office of the General Counsel dismissed the request for reconsideration. The key reason was that Amentum Parsons failed to address KBR's "interested party" arguments when they were first raised during the original protest proceedings. The GAO reiterated its policy that arguments available to a party in the initial protest must be asserted at that time; failing to do so is not a valid basis for a request for reconsideration.
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Primary source of information - GAO: https://www.gao.gov/products/b-422697.14
Publicly Released on: Sept. 25, 2025 Published: Sept. 18, 2025
Kevin P. Connelly, Esq., Kelly E. Buroker, Esq., Jeffrey M. Lowry, Esq., and Michael P. Ols, Esq., Vedder Price P.C., for the requester.
Seth H. Locke, Esq., Wilmer Cutler Pickering Hale and Dorr LLP, for KBR Services LLC, the intervenor.
Wade L. Brown, Esq., Department of the Army, for the agency.
Edward Goldstein, Esq., and Kenneth E. Patton, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Dismisses Modesto Management Protest Against VA Elevator Contract, Citing Lack of 'Interested Party' Status
By Marlyn Vitin
WASHINGTON, Oct. 14 -- The General Accountability Office has dismissed a protest filed by Modesto Management LLC, of Oak Park, Illinois, against the award of an elevator maintenance services contract by the U.S. Department of Veterans Affairs. The contract, awarded to Eleven Bravo Group LLC, of Plantation, Florida, was issued under a request for quotations set aside for service-disabled veteran-owned small businesses for the Minneapolis VA Health Care System facility.
The GAO dismissed the protest because Modesto Management failed to qualify as an interested party, a mandatory requirement for
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WASHINGTON, Oct. 14 -- The General Accountability Office has dismissed a protest filed by Modesto Management LLC, of Oak Park, Illinois, against the award of an elevator maintenance services contract by the U.S. Department of Veterans Affairs. The contract, awarded to Eleven Bravo Group LLC, of Plantation, Florida, was issued under a request for quotations set aside for service-disabled veteran-owned small businesses for the Minneapolis VA Health Care System facility.
The GAO dismissed the protest because Modesto Management failed to qualify as an interested party, a mandatory requirement formaintaining a protest. Modesto challenged the agency's technical evaluation of its own quotation and raised issues with the awardee's eligibility, arguing that Eleven Bravo Group would violate limitations on subcontracting.
However, the agency received a total of 17 quotations. After evaluating them, the VA found three other vendors submitted technically acceptable quotations with prices lower than Modesto's, even if the award to Eleven Bravo Group were overturned. Eleven Bravo Group, with the lowest price of $2,173,301, was determined to be technically acceptable.
General Counsel Edda Emmanuelli Perez stated in the September 30, 2025 decision that in an lowest-price, technically acceptable procurement, a protester must demonstrate a reasonable possibility of being next in line for the award if its protest is sustained. Since three other vendors were found technically acceptable and priced below Modesto, those firms had a greater interest in the procurement.
Modesto attempted to challenge the intervening vendors' eligibility by making broad, unsupported assertions that they could not meet the subcontracting requirements without being licensed elevator companies. The GAO rejected this, finding that such speculation, unsupported by evidence, failed to meet the required standard for a detailed protest. Consequently, Modesto's interest was deemed too remote to sustain the protest. The protest was therefore dismissed.
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Primary source of information - GAO: https://www.gao.gov/products/b-423728
Publicly Released on: Sept. 30, 2025 Published: Sept. 30, 2025
Eric Dobyne for the protester.
Jared Levin, Esq., Department of Veterans Affairs, for the agency.
Alexa J. Young, Esq., and April Y. Shields, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Protest by Guardian D.B. Services Against Forest Service
By Marlyn Vitin
WASHINGTON, Oct. 14 -- The General Accountability Office has denied a bid protest filed by Guardian D.B. Services LLC, a small business based in Mobile, Alabama, challenging the U.S. Department of Agriculture Forest Service's decision to reject its contract proposal.
The protest centered on a request for proposals for road, bridge and related civil construction projects in the Forest Service's Rocky Mountain Region 2. The Forest Service found Guardian's proposal lacked required information, specifically under the "Organization and Management" evaluation factor.
Guardian DB Services argued that
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WASHINGTON, Oct. 14 -- The General Accountability Office has denied a bid protest filed by Guardian D.B. Services LLC, a small business based in Mobile, Alabama, challenging the U.S. Department of Agriculture Forest Service's decision to reject its contract proposal.
The protest centered on a request for proposals for road, bridge and related civil construction projects in the Forest Service's Rocky Mountain Region 2. The Forest Service found Guardian's proposal lacked required information, specifically under the "Organization and Management" evaluation factor.
Guardian DB Services argued thatits proposal contained sufficient information to meet the solicitation's requirements for key personnel. However, the GAO's General Counsel, Edda Emmanuelli Perez, concluded in a decision dated September 24, 2025, that the agency's evaluation was reasonable and consistent with the stated criteria.
The Forest Service had rated Guardian's proposal as "Low Confidence" for the organization and management factor because it failed to provide the mandated resumes for key positions--Project Manager, Site Superintendent, Quality Control Manager, and Safety Officer. The agency noted that Guardian's submission included only a general summary of background experience and did not clearly identify individuals for the Quality Control Manager or Safety Officer roles.
The GAO decision underscores that an offeror must submit a clearly written proposal that contains all required information, and disagreement with a reasonable evaluation does not justify overturning an award decision. The Forest Service ultimately selected 26 firms for the multiple award task order contracts.
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Primary source of information - GAO: https://www.gao.gov/products/b-423692
Publicly Released on: Sept. 25, 2025 Published: Sept. 24, 2025
Johnny Johnson for the protester.
Adam Humphries, Esq., Department of Agriculture, for the agency.
Sarah T. Zaffina, Esq., and Jennifer D. Westfall-McGrail, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Peraton Protest Against GDIT Task Order for IT Services
By Marlyn Vitin
WASHINGTON, Oct. 14 -- The General Accountability Office has denied a protest filed by Peraton Inc. of Herndon, Virginia, challenging the award of an information technology lifecycle support services task order to General Dynamics Information Technology Inc. of Falls Church, Virginia. The task order, issued by the General Services Administration, is for IT services supporting the U.S. Strategic Command, primarily at Offut Air Force Base, Nebraska, and Davis-Monthan Air Force Base, Arizona.
Peraton's protest raised three main arguments: the agency improperly evaluated its proposal, the agency failed
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WASHINGTON, Oct. 14 -- The General Accountability Office has denied a protest filed by Peraton Inc. of Herndon, Virginia, challenging the award of an information technology lifecycle support services task order to General Dynamics Information Technology Inc. of Falls Church, Virginia. The task order, issued by the General Services Administration, is for IT services supporting the U.S. Strategic Command, primarily at Offut Air Force Base, Nebraska, and Davis-Monthan Air Force Base, Arizona.
Peraton's protest raised three main arguments: the agency improperly evaluated its proposal, the agency failedto conduct clarifications on its proposal's weaknesses, and GDIT had a disqualifying organizational conflict of interest related to hiring former government employees.
Peraton challenged the General Services Administration's evaluation, which assigned its proposal an "Acceptable" rating for the most important "Technical Approach" factor and assessed two significant weaknesses related to the Global Operations Center audio/visual engineering requirements. The GAO upheld the evaluation, finding that the requirement for A/V engineering was clearly stated in the solicitation and reasonably related to the evaluation criteria. The agency was therefore justified in assessing weaknesses against Peraton for failing to adequately address this critical area in both its technical approach and proposed staffing. The GAO also ruled that the agency was not required to seek clarifications on the assessed weaknesses, as the solicitation did not mandate such actions.
Peraton also alleged that GDIT had an unfair competitive advantage by hiring two former senior government employees who had access to non-public information from the incumbent contract. The GAO denied this claim, concluding that the contracting officer conducted a reasonable investigation. The agency's inquiry found that due to "myriad changes" in requirements since the prior contract, and the age of any non-public information (four to seven years old), the former employees did not have access to non-public, competitively useful information that created an OCI or an unfair competitive advantage for GDIT.
Ultimately, the GAO found the GSA's decision to award the contract to GDIT, despite Peraton's lower evaluated cost, was reasonable, as GDIT's proposal was rated technically superior under the most important factors. The protest was denied on all grounds.
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Primary source of information - GAO: https://www.gao.gov/products/b-423639%2Cb-423639.2%2Cb-423639.3
Publicly Released on: Sept. 26, 2025 Published: Sept. 17, 2025
Kevin P. Connelly, Esq., Kelly E. Buroker, Esq., Jeffrey M. Lowry, Esq., and Michael P. Ols, Esq., Vedder Price P.C., for the protester.
Noah B. Bleicher, Esq., Moshe B. Broder, Esq., Jennifer Eve Retener, Esq., Aime J. Joo, Esq., Ginsey V. Kramarczyk, Esq., and Sierra A. Paskins, Esq., Jenner & Block, LLP, for General Dynamics Information Technology, Inc., the intervenor.
Barbara Behn Ayala, Esq., General Services Administration, for the agency.
Christopher Alwood, Esq., and Evan D. Wesser, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
