GAO Bid Protests
Here's a look at news stories involving federal bid protest decisions issued by the GAO General Counsel
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GAO Dismisses Metro East Protest Over CDC Sole-Source Extension to Chenega Global Protection
By Marlyn T. Vitin
WASHINGTON, April 23 -- The Government Accountability Office has dismissed a protest filed by Metro East Joint Venture LLC, Chattanooga, Tennessee, challenging a sole-source contract extension issued by the U.S. Department of Health and Human Services Centers for Disease Control and Prevention to Chenega Global Protection LLC, Chantilly, Virginia.
The dispute involved security guard services at CDC facilities in Atlanta, Georgia, and Fort Collins, Colorado. Metro East argued that the agency improperly extended Chenega's contract through a sole-source modification, failed to address alleged conflicts
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WASHINGTON, April 23 -- The Government Accountability Office has dismissed a protest filed by Metro East Joint Venture LLC, Chattanooga, Tennessee, challenging a sole-source contract extension issued by the U.S. Department of Health and Human Services Centers for Disease Control and Prevention to Chenega Global Protection LLC, Chantilly, Virginia.
The dispute involved security guard services at CDC facilities in Atlanta, Georgia, and Fort Collins, Colorado. Metro East argued that the agency improperly extended Chenega's contract through a sole-source modification, failed to address alleged conflictsof interest, and delayed implementing corrective action promised in response to an earlier protest.
The GAO, however, did not reach the merits of those claims. Instead, it dismissed the protest as untimely, finding that Metro East waited too long to challenge the agency's actions.
According to the decision, the CDC publicly posted a notice on January 27, 2026, outlining its intent to extend Chenega's contract. That notice included a justification explaining that the extension could run through June 30, 2026, including the use of option periods. Under GAO bid protest rules, any challenge based on such information must be filed within 10 days of when the protester knew or should have known its basis.
Metro East did not file its protest until April 6, more than two months after the notice was posted. The GAO concluded that all of the protester's arguments--including allegations of conflicts of interest, improper sole-source justification, and delays in corrective action--were based on information available as of the January notice.
The watchdog rejected Metro East's argument that a protest would have been premature earlier in the process. It found that the agency's notice clearly indicated the potential duration of the extension and the continued reliance on sole-source contracting, providing sufficient grounds for a timely challenge at that point.
The GAO emphasized that its timeliness rules are designed to ensure both fairness and the efficient resolution of procurement disputes, and that waiting to see how events unfold does not extend filing deadlines when the basis for protest is already known.
Because Metro East failed to meet those deadlines, the GAO dismissed the protest without further review, leaving the CDC's extension of Chenega's contract in place.
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Primary source of information - GAO: https://www.gao.gov/products/b-424392
Publicly Released on: April 22, 2026 Published: April 21, 2026
Jonathan D. Shaffer, Esq., and John M. Tanner, Esq., Haynes and Boone, LLP, for the protester.
William J. Shim, Esq., and Jon J. Gottschalk, Esq., Department of Health and Human Services, 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 Denies SupplyCore Protest of GSA Award to Amentum for Japan Logistics Contract
By Marlyn T. Vitin
WASHINGTON, April 23 -- The U.S. Government Accountability Office has denied a protest by SupplyCore Inc., Rockford, Illinois, challenging the General Services Administration's award of a logistics support contract to Amentum Services Inc., Chantilly, Virginia, for operations in Japan.
The procurement sought a contractor to provide supply chain services for federal and Defense Department customers across the Indo-Pacific region, including sourcing, warehousing, and delivery of goods such as tools, office supplies, and cleaning products. The contract was structured as a fixed-price, indefinite-delivery,
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WASHINGTON, April 23 -- The U.S. Government Accountability Office has denied a protest by SupplyCore Inc., Rockford, Illinois, challenging the General Services Administration's award of a logistics support contract to Amentum Services Inc., Chantilly, Virginia, for operations in Japan.
The procurement sought a contractor to provide supply chain services for federal and Defense Department customers across the Indo-Pacific region, including sourcing, warehousing, and delivery of goods such as tools, office supplies, and cleaning products. The contract was structured as a fixed-price, indefinite-delivery,indefinite-quantity award with a one-year base period and four option years.
GSA evaluated proposals from three offerors using a best-value tradeoff that placed greater importance on non-price factors, though price became more significant as proposals were rated more closely. Both SupplyCore and Amentum received similar ratings across most technical factors, but Amentum was rated significantly higher in operational quality assurance and proposed a lower price--approximately $77.8 million compared to SupplyCore's $81.4 million.
SupplyCore argued that the agency unreasonably evaluated its proposal, particularly by failing to assign strengths under the operational quality assurance factor and by assigning a weakness related to its warehouse documentation. The company also challenged the overall tradeoff decision.
The GAO rejected these arguments, finding that GSA's evaluation was reasonable, adequately documented, and consistent with the solicitation. The decision emphasized that agencies are not required to explain why particular aspects of a proposal do not warrant strengths, so long as the evaluation record shows that the proposal was considered against the stated criteria.
On the warehouse issue, the GAO agreed with GSA that SupplyCore's submission of a lease agreement written entirely in Japanese prevented evaluators from verifying key details, such as the lease term and compliance with solicitation requirements. Although the solicitation did not explicitly require English-language documents, the GAO found it reasonable to expect submissions to be in English or accompanied by translations in a procurement conducted in English.
The GAO also dismissed as untimely a separate challenge regarding alleged deficiencies in warehouse blueprints, noting that SupplyCore raised the issue more than 10 days after learning of it during debriefing.
Finally, the GAO concluded that even if some evaluation aspects were debatable, SupplyCore failed to demonstrate competitive prejudice. The agency had already considered the firm's proposal strengths in its tradeoff analysis, and Amentum's lower price and stronger rating in a key factor supported the award decision.
The protest was denied on April 9, 2026.
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Primary source of information - GAO: https://www.gao.gov/products/b-424243%2Cb-424243.2
Publicly Released on: April 22, 2026 Published: April 9, 2026
Marlena Ewald, Esq., Michael T. Patterson, Esq., and Amanda Z. Sin, Esq., Fluet & Associates, PLLC, for the protester.
Luke W. Meier, Esq., and Oliver Jury, Esq., Blank Rome LLP, for Amentum Services, Inc., the intervenor.
Michael C. Evans, Esq., General Services Administration, for the agency.
Todd C. Culliton, Esq., and Tania Calhoun, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Logmet LLC Protest Over Air Force Maintenance Contract Evaluation
By Marlyn T. Vitin
WASHINGTON, April 23 -- The Government Accountability Office has denied a protest filed by LOGMET LLC of Round Rock, Texas, challenging its exclusion from a U.S. Air Force competition for maintenance services contracts.
The protest concerned LOGMET's non-selection for a multiple-award indefinite-delivery, indefinite-quantity contract issued under a 2024 solicitation seeking contractor support for maintenance operations under the Air Force's Contractor Field Team program. The procurement anticipated multiple awards with a five-year base period and an additional five-year option.
LOGMET argued
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WASHINGTON, April 23 -- The Government Accountability Office has denied a protest filed by LOGMET LLC of Round Rock, Texas, challenging its exclusion from a U.S. Air Force competition for maintenance services contracts.
The protest concerned LOGMET's non-selection for a multiple-award indefinite-delivery, indefinite-quantity contract issued under a 2024 solicitation seeking contractor support for maintenance operations under the Air Force's Contractor Field Team program. The procurement anticipated multiple awards with a five-year base period and an additional five-year option.
LOGMET arguedthat the Air Force unreasonably evaluated its proposal, asserting that the agency should have used information in its submission--such as work samples and narratives--to assess its qualifications, even though a required self-scoring matrix was not included. The company also contended that the agency should have opened discussions to allow it to correct the omission.
The GAO rejected both arguments, finding that the Air Force acted reasonably and in accordance with the solicitation's terms. The decision emphasized that the solicitation explicitly required offerors to submit a self-scoring matrix as part of the technical evaluation process. This matrix was central to determining whether proposals met the minimum technical threshold score of 40,000 points required for further consideration.
Because LOGMET failed to include the matrix, the Air Force determined it could not validate a score and deemed the proposal technically unacceptable. The GAO agreed, noting that agencies are not obligated to infer or reconstruct required elements of a proposal from other materials. It reiterated that offerors bear the responsibility for submitting complete and adequately written proposals.
The GAO also found no fault in the Air Force's decision not to conduct discussions. The solicitation clearly stated the agency's intent to award contracts without discussions, and under such circumstances, agencies have broad discretion in deciding whether to engage offerors. Moreover, the GAO noted that even if discussions had been held, LOGMET's proposal would have remained ineligible because it failed to meet the minimum technical requirements.
The decision underscores the importance of strictly adhering to solicitation instructions, particularly in procurements using structured evaluation methods where missing required components can result in automatic disqualification.
The protest was denied on April 15, 2026.
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Primary source of information - GAO: https://www.gao.gov/products/b-423066.2
Publicly Released on: April 16, 2026 Published: April 15, 2026
Wayne Rankin for the protester.
Kevin P. Connelly, Esq., Kelly E. Buroker, Esq., Jeffrey M. Lowry, Esq., and Michael P. Ols, Esq., Vedder Price P.C., for Amentum Services, Inc., the intervenor.
Colonel Justin A. Silverman, Geoffrey R. Townsend, Esq., Major Princess Gaye, and Alexander S. Hall, Esq., Department of the Air Force, for the agency.
Hannah G. Barnes, Esq., and April Y. Shields, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Harper Construction Reconsideration Bid in Navy Housing Contract Dispute With Clark Construction
By Marlyn T. Vitin
WASHINGTON, April 23 -- The Government Accountability Office has denied a request for reconsideration filed by Harper Construction Co. Inc., San Diego, California, reaffirming its earlier decision rejecting the firm's protest over a U.S. Navy construction contract awarded to Clark Construction Group-California LP, Irvine, California.
The dispute stems from a U.S. Navy procurement for repairs and upgrades to five bachelor enlisted quarters at Marine Corps Base Camp Pendleton in California. The solicitation, issued in July 2025, sought proposals under an existing pool of contractors and called for
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WASHINGTON, April 23 -- The Government Accountability Office has denied a request for reconsideration filed by Harper Construction Co. Inc., San Diego, California, reaffirming its earlier decision rejecting the firm's protest over a U.S. Navy construction contract awarded to Clark Construction Group-California LP, Irvine, California.
The dispute stems from a U.S. Navy procurement for repairs and upgrades to five bachelor enlisted quarters at Marine Corps Base Camp Pendleton in California. The solicitation, issued in July 2025, sought proposals under an existing pool of contractors and called foraward on a lowest-priced, technically acceptable basis.
In its original protest, Harper argued that the Navy improperly found its proposal technically unacceptable. Evaluators had concluded that one of Harper's proposed unit designs failed to meet minimum space requirements, particularly for required living areas such as kitchenettes. The Navy determined that the design could not realistically accommodate all required spaces within the prescribed square footage.
The GAO denied that protest in March 2026, finding the agency's evaluation reasonable and consistent with the solicitation. Harper then sought reconsideration, claiming the decision contained factual and legal errors, including misinterpretation of its position on space requirements and improper reliance on the Navy's explanations.
In its April 15, 2026 decision, the GAO rejected those arguments, concluding that Harper failed to meet the high bar required for reconsideration. Under GAO rules, a requester must show that a prior decision contained a clear error of fact or law, or present new information that would warrant changing the outcome.
The GAO found that Harper largely repeated arguments already raised and addressed in the initial protest. It also determined that the firm mischaracterized portions of the prior decision, including statements about whether its proposal met minimum net square footage requirements. According to the GAO, the earlier decision accurately reflected that Harper's design fell below certain thresholds, even as the firm disputed whether those thresholds applied.
The decision also dismissed Harper's contention that the Navy's explanations were inconsistent or improperly introduced after the protest. The GAO reiterated that it may consider post-protest explanations so long as they are credible and consistent with the record.
Finding no error in its earlier ruling, the GAO denied the reconsideration request, leaving the Navy's award to Clark Construction intact.
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Primary source of information - GAO: https://www.gao.gov/products/b-419947.4
Publicly Released on: April 21, 2026 Published: Aprril 15, 2026
Dirk Haire, Esq., Jessica Haire, Esq., A. Michelle West, Esq., Michael J. Brewer, Esq., and Isabella S. Capanna, Esq., Burr & Forman LLP, for the requester.
Kristopher M. Cronin, Esq., Department of the Navy, for the agency.
Michelle Litteken, Esq., and April Y. Shields, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Highland Engineering Protest Over Air Force Contract Award to SelectTech Services
By Marlyn T. Vitin
WASHINGTON, April 15 -- The Government Accountability Office has denied a protest filed by Highland Engineering Inc., a small business based in Howell, Michigan, challenging the U.S. Air Force's award of a sustainment contract to SelectTech Services Corp., Dayton, Ohio.
The dispute concerned a solicitation issued by the Air Force for the sustainment of air transportable galley and lavatory units, which include maintenance, repair, and logistical support services. The competition was conducted as a small business set-aside and contemplated a long-term contract with multiple pricing structures.
Highland
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WASHINGTON, April 15 -- The Government Accountability Office has denied a protest filed by Highland Engineering Inc., a small business based in Howell, Michigan, challenging the U.S. Air Force's award of a sustainment contract to SelectTech Services Corp., Dayton, Ohio.
The dispute concerned a solicitation issued by the Air Force for the sustainment of air transportable galley and lavatory units, which include maintenance, repair, and logistical support services. The competition was conducted as a small business set-aside and contemplated a long-term contract with multiple pricing structures.
HighlandEngineering argued that the Air Force unreasonably evaluated past performance and made a flawed best-value tradeoff in selecting SelectTech's higher-priced proposal. Highland's total evaluated price was approximately $84.2 million, compared with SelectTech's $115.4 million.
In its decision dated April 6, 2026, the GAO found that the Air Force reasonably evaluated proposals in accordance with the terms of the solicitation, which placed greater importance on past performance than on price.
A central issue in the protest was Highland's past performance rating. The Air Force assigned Highland a "neutral confidence" rating after determining that the company's submitted references were not relevant because Highland had performed the work as a subcontractor rather than as a prime contractor, as required by the solicitation. The GAO agreed with the agency's interpretation, finding it consistent with the plain language of the solicitation and rejecting Highland's argument that subcontractor experience should qualify if it mirrored prime contractor responsibilities.
By contrast, SelectTech received a "substantial confidence" rating based on its record as a prime contractor on relevant Air Force work. The GAO also found that the Air Force reasonably considered and weighed past performance information for SelectTech and its subcontractors, including any negative findings.
In reviewing the award decision, the GAO concluded that the Air Force conducted a proper best-value tradeoff. The source selection authority reasonably determined that SelectTech's stronger, more relevant past performance justified paying a price premium of about $31 million.
The GAO emphasized that agencies have broad discretion in evaluating past performance and making tradeoff decisions, so long as they are reasonable and consistent with the solicitation.
Finding no basis to sustain the protest, the GAO denied Highland Engineering's challenge in full.
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Primary source of information - GAO: https://www.gao.gov/products/b-424183%2Cb-424183.2
Publicly Released on: April 9, 2026 Published: April 6, 2026
Frank S. Murray, Esq., Foley & Lardner LLP, for the protester.
Suzanne Sumner, Esq., Brandon E. Dobyns, Esq., and Celeste M. Friel, Esq., Taft Stettinus & Hollister LLP, for SelectTech Services Corporation, the intervenor.
Colonel Justin A. Silverman, Walker J. Gray, Esq., Isabelle P. Cutting, Esq., James M. Peeler, Esq., and Erik T. Fuqua, Esq., Department of the Air Force, for the agency.
Uri R. Yoo, Esq., and Alexander O. Levine, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies CSlope Solutions Request to Reconsider Protest Over Army Award to JCS Solutions
By Marlyn T. Vitin
WASHINGTON, April 15 -- The Government Accountability Office has denied a request for reconsideration filed by CSlope Solutions LLC, a small business based in Arlington, Virginia, seeking to overturn an earlier decision involving an Army contract award to JCS Solutions LLC, Fairfax, Virginia.
The dispute stems from a task order issued by the U.S. Army for customer care support services at Arlington National Cemetery. In a prior decision issued in December 2025, the GAO rejected CSlope's protest, which alleged that the Army unreasonably evaluated proposals and made a flawed source selection.
CSlope
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WASHINGTON, April 15 -- The Government Accountability Office has denied a request for reconsideration filed by CSlope Solutions LLC, a small business based in Arlington, Virginia, seeking to overturn an earlier decision involving an Army contract award to JCS Solutions LLC, Fairfax, Virginia.
The dispute stems from a task order issued by the U.S. Army for customer care support services at Arlington National Cemetery. In a prior decision issued in December 2025, the GAO rejected CSlope's protest, which alleged that the Army unreasonably evaluated proposals and made a flawed source selection.
CSlopesubsequently requested reconsideration, arguing that the GAO's earlier ruling contained errors of fact and law--particularly in its interpretation of Small Business Administration regulations related to responsibility determinations and referrals for a certificate of competency.
In its April 8, 2026 decision, the GAO found that CSlope failed to meet the high standard required for reconsideration, which demands a showing of material errors or previously unavailable information that would warrant reversing the original outcome.
A key issue raised by CSlope was whether the Army's evaluation of past performance effectively amounted to a nonresponsibility determination, which would have required referral to the Small Business Administration. CSlope, supported by the SBA's views during the protest, argued that the solicitation created a "binary" evaluation scheme because only offerors with a "substantial confidence" rating were eligible for award.
The GAO disagreed, reaffirming its earlier conclusion that the Army's evaluation was comparative rather than pass/fail. The solicitation allowed for multiple past performance ratings--ranging from "no confidence" to "substantial confidence"--and required an assessment of relevance and performance quality. According to the GAO, this structure did not constitute a non-comparative evaluation that would trigger a mandatory referral to the SBA.
The GAO also rejected CSlope's argument that it failed to properly consider or defer to the SBA's interpretation of its own regulations. The decision emphasized that where regulatory language is clear, the GAO relies on its plain meaning and is not required to adopt an alternative interpretation.
Additionally, the GAO found that CSlope largely repeated arguments already raised and addressed in the initial protest, which does not satisfy the standard for reconsideration.
Concluding that no errors of fact or law were demonstrated, the GAO denied the request and left its prior decision in place, upholding the Army's award to JCS Solutions.
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Primary source of information - GAO: https://www.gao.gov/products/b-422249.5
Publicly Released on: April 13, 2026 Published: April 8, 2026
Jeremy D. Burkhart, Esq., Tanner N. Slaughter, Esq., and Ben R. Smith, Esq., Holland & Knight LLP, for the protester.
Jonathan A. Hardage, Esq., Department of the Army, for the agency.
Kasia Dourney, Esq., and Alexander O. Levine, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
