GAO Bid Protests
Here's a look at news stories involving federal bid protest decisions issued by the GAO General Counsel
Featured Stories
GAO Dismisses East Coast Flight Services Protest Over Air Force Flight Contract
By Marlyn T. Vitin
WASHINGTON, Feb. 12 -- The U.S. Government Accountability Office has dismissed a bid protest by East Coast Flight Services Inc., Easton, Maryland. The decision, which was issued on Jan. 7, 2026, clears the way for CSI Aviation Inc., Killeen, Texas, to proceed with a $20 million contract for fixed-wing flight services issued by the U.S. Transportation Command.
The protest was dismissed because ECFS failed to establish a valid legal or factual basis for challenging the agency's decision. The ruling serves as a reminder that simply being the lowest bidder or having extensive history does not automatically
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WASHINGTON, Feb. 12 -- The U.S. Government Accountability Office has dismissed a bid protest by East Coast Flight Services Inc., Easton, Maryland. The decision, which was issued on Jan. 7, 2026, clears the way for CSI Aviation Inc., Killeen, Texas, to proceed with a $20 million contract for fixed-wing flight services issued by the U.S. Transportation Command.
The protest was dismissed because ECFS failed to establish a valid legal or factual basis for challenging the agency's decision. The ruling serves as a reminder that simply being the lowest bidder or having extensive history does not automaticallymake an agency's choice improper.
ECFS's primary argument was that awarding the contract to a more expensive competitor constituted "government waste." CSI Aviation's winning bid was valued at over $20 million, which ECFS claimed was significantly higher than its own proposal.
The GAO rejected this claim, noting that the solicitation was based on a best-value tradeoff process. This common procurement method allows an agency to choose a higher-priced proposal if it offers superior technical capabilities or lower risk. Because the solicitation explicitly stated that the Air Force could award to a "higher rated, higher priced offeror," the GAO ruled that the price difference alone was not proof of improper action.
A significant portion of the dismissal focused on ECFS's past performance. The firm argued it had successfully operated the same contract for five years, from 2015 to 2020.
However, the solicitation contained a strict "recency" requirement: only work performed within three years of the proposal submission (April 2025) would be considered. Because ECFS's cited experience ended in December 2020, it fell outside this window. The GAO ruled that the Air Force was legally prohibited from considering that older experience, making ECFS's argument factually irrelevant to the evaluation.
The GAO also addressed ECFS's claim that the Air Force's "Unsuccessful Offeror Notice" contained incorrect information. The ruling clarified that the adequacy of post-award notices is a procedural matter. Even if a notice contains minor errors, it does not affect the legal validity of the contract award itself.
Because ECFS provided only conclusory assertions rather than specific evidence of agency error, General Counsel Edda Emmanuelli Perez concluded that the protest was "legally insufficient."
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Primary source of information - GAO: https://www.gao.gov/products/b-423977
Publicly Released on: Jan. 8, 2026 Published: Jan. 2, 2026
Edward C. Ambler for the protester.
Jennifer S. Zucker, Esq., and Christopher O'Brien, Esq., Greenberg Traurig, LLP, for CSI Aviation, Inc., the intervenor.
Colonel Justin A. Silverman, and Kelsi Pilcher, Esq., Department of the Air Force; and Todd P. Federici, Esq. and Adam J. Koudelka, Esq., United States Transportation Command, for the agency.
Jacob M. Talcott, Esq., and Heather Weiner, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Dismisses American Systems Group Protest Over Navy Administrative Support Contract
By Marlyn T. Vitin
WASHINGTON, Feb. 12 -- The Government Accountability Office has dismissed a bid protest by ASG Solutions Corp. dba American Systems Group, San Diego, California. The decision, which was issued on Jan. 16, 2026, affirms the U.S. Navy's award of an administrative support contract to WWC Global, Mashantucket, Connecticut.
The case centered on a misunderstanding of federal procurement rules regarding "debriefings"--formal explanations agencies provide to losing bidders. The protest failed because ASG relied on a deadline extension that did not legally apply to this type of contract.
The Navy issued
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WASHINGTON, Feb. 12 -- The Government Accountability Office has dismissed a bid protest by ASG Solutions Corp. dba American Systems Group, San Diego, California. The decision, which was issued on Jan. 16, 2026, affirms the U.S. Navy's award of an administrative support contract to WWC Global, Mashantucket, Connecticut.
The case centered on a misunderstanding of federal procurement rules regarding "debriefings"--formal explanations agencies provide to losing bidders. The protest failed because ASG relied on a deadline extension that did not legally apply to this type of contract.
The Navy issuedthe contract for overseas support services in Bahrain using "Simplified Acquisition Procedures." Under these specific rules, agencies are not required to provide the formal, detailed debriefings typical of larger, more complex procurements. Instead, they are only required to provide a "brief explanation" of the award.
While the Navy initially told ASG that a "debrief is forthcoming," it later corrected itself, noting that the information already provided in an email on September 18 satisfied the legal requirements for a brief explanation. ASG argued that the clock for filing a protest should have stayed paused (tolled) until they received a full debriefing. The Government Accountability Office disagreed, ruling that an agency's "erroneous references" to a forthcoming debriefing do not create a legal right to one if the law doesn't require it.
Because a formal debriefing was not legally required, ASG was bound by the standard rule: a protest must be filed within 10 days of learning the basis for the challenge. ASG learned of the award to WWC Global on September 18, meaning their deadline to file was September 29.
ASG did not file its protest until November 13. Even accounting for a temporary government shutdown in October, the GAO determined the filing was weeks late. General Counsel Edda Emmanuelli Perez noted that "a required debriefing has the effect of tolling the filing period in limited circumstances," but those circumstances were not present here.
The ruling also highlighted ASG's failure to track the contract's status. The Navy's request for quotations was marked "urgent," with work scheduled to begin in March 2025. However, ASG did not contact the Navy to ask about the award status until September 3--more than five months after the work was supposed to have started.
The Accountability Office found that ASG failed to "diligently pursue" information. Waiting 157 days to check on an urgent contract does not meet the legal standard for a timely protest. The dismissal concludes the matter, allowing the Navy to continue its administrative operations in the Kingdom of Bahrain with WWC Global.
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Primary source of information - GAO: https://www.gao.gov/products/b-424053
Publicly Released on: Jan. 16, 2026 Published: Jan. 16, 2026
Ritobrata Banerjee for the protester.
Lori K. Stibb, Esq., and Sara L. Thompson, Esq., Department of the Navy, for the agency.
Sarah T. Zaffina, Esq., and Heather Weiner, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Think Tank Inc. Reconsideration Request Over Dismissed NOAA Protest
By Marlyn T. Vitin
WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a request for reconsideration from Think Tank Inc., a Silver Spring, Maryland-based firm, regarding the dismissal of its protest against the U.S. Department of Commerce National Oceanic and Atmospheric Administration. The original protest concerned an information technology support services contract but was dismissed after the company failed to meet a strict filing deadline.
The central issue in the case was the timing of Think Tank's response to the agency's report. Under GAO regulations, protesters must file comments within
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WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a request for reconsideration from Think Tank Inc., a Silver Spring, Maryland-based firm, regarding the dismissal of its protest against the U.S. Department of Commerce National Oceanic and Atmospheric Administration. The original protest concerned an information technology support services contract but was dismissed after the company failed to meet a strict filing deadline.
The central issue in the case was the timing of Think Tank's response to the agency's report. Under GAO regulations, protesters must file comments within10 days of receiving the agency's report unless an extension is granted. In this instance, the GAO had already extended the deadline to May 16 at 5:30 p.m. Eastern Time. Think Tank's counsel did not successfully upload the comments until after that cutoff.
Think Tank argued that the delay should be excused for "good cause," claiming they attempted to upload the documents at 5:28 p.m. but were blocked by technical issues, including a file-naming error and a required password reset. The company also argued that because certain documents were kept under a protective order until May 8, they were not given the full statutory time to respond.
The GAO rejected these arguments, noting that the firm's counsel had access to the documents since April 30, providing a total of 16 days to prepare a response. Furthermore, the GAO verified its electronic system records, which showed no technical glitches at the time of the deadline. The GAO characterized the delay as the result of a "last-minute" attempt to log in rather than a system failure, emphasizing that it must resolve protests expeditiously to comply with federal law.
Because Think Tank failed to demonstrate a material error of fact or law in the original dismissal, the GAO maintained that the protest remains closed without a review of the company's underlying claims against the NOAA award.
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Primary source of information - GAO: https://www.gao.gov/products/b-423427.2
Publicly Released on: Jan. 12, 2025 Published: July 25, 2025
Wanda Sanchez Day, Esq., Wanda Sanchez Day Attorney At Law, for the requester.
Jillian Stern, Esq., Department of Commerce, for the agency.
Michael P. Price, Esq., and John Sorrenti, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Salient CRGT Protest Over $472 Million Defense Cloud Contract Award to Omni Fed
By Marlyn T. Vitin
WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a bid protest filed by Salient CRGT Inc., Fairfax, Virginia, challenging a major information technology contract awarded by the Defense Counterintelligence and Security Agency. The contract, valued at approximately $472 million, was awarded to Omni Fed LLC, Gainesville, Virginia.
The dispute centered on a Department of Defense initiative to modernize the National Background Investigation System. The project aims to transform a legacy, "monolithic" on-premises system into a secure, modular, cloud-based environment using development,
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WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a bid protest filed by Salient CRGT Inc., Fairfax, Virginia, challenging a major information technology contract awarded by the Defense Counterintelligence and Security Agency. The contract, valued at approximately $472 million, was awarded to Omni Fed LLC, Gainesville, Virginia.
The dispute centered on a Department of Defense initiative to modernize the National Background Investigation System. The project aims to transform a legacy, "monolithic" on-premises system into a secure, modular, cloud-based environment using development,security, and operations--commonly known as DevSecOps--managed services.
Salient CRGT argued that the agency's evaluation was flawed, claiming Omni Fed lacked the necessary experience to handle a project of this magnitude. A primary point of contention was the definition of "scale." Salient contended that because Omni Fed's previous federal contracts were significantly smaller in dollar value than the $472 million award, the agency should not have assigned Omni Fed a "high confidence" rating.
However, the Government Accountability Office found that the solicitation did not require the agency to consider dollar value when assessing the scale of past work. Instead, the agency focused on the technical complexity and the number of developers supported in previous roles. For example, Omni Fed's work on the Air Force "Party Bus" contract--which supported 600 developers--was found to be directly comparable to the requirements of the new defense system.
Salient also challenged the adequacy of Omni Fed's price, alleging that the awardee proposed an insufficient level of effort. While the government's internal estimate suggested approximately 917,000 labor hours, Omni Fed proposed significantly fewer.
The GAO ruled that because the solicitation did not mandate a specific number of hours, Omni Fed was free to propose a labor mix based on its unique technical approach. The agency concluded that Omni Fed's staffing plan was "balanced" and sufficient to meet the government's needs without the "risk of overestimation" and wasted resources seen in higher bids.
In the final best-value tradeoff, the Defense Counterintelligence and Security Agency determined that Omni Fed offered a higher-rated technical approach at a lower price than Salient CRGT. The GAO upheld this decision, stating the evaluation was reasonable and consistent with the solicitation's terms.
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Primary source of information - GAO: https://www.gao.gov/products/b-423640.2%2Cb-423640.4
Publicly Released on: Jan. 12, 2026 Published: Jan. 5, 2026
J. Andrew Jackson, Esq., Ryan P. McGovern, Esq., and Alexandra K. Heyl, Esq., Jones Day, for the protester.
Damien C. Specht, Esq., James A. Tucker, Esq., and Victoria Dalcourt Angle, Morrison Foerster, LLP for Omni Fed, LLC, the intervenor.
Matthew T. Donahue, Esq., Katie L. Oyler, Esq., Tiffany J. Williams, Esq., and Cathryn F. Beaman, Esq, Defense Counterintelligence and Security Agency, for the agency.
Heather Self, Esq., and Peter H. Tran, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Salient CRGT Protest Over $134 Million Information Technology Task Order
By Marlyn T. Vitin
WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a bid protest filed by Salient CRGT Inc., Fairfax, Virginia, regarding a technology information services task order awarded to Science Applications International Corp., Reston, Virginia.
The task order, issued by the GAO's own technology division, is a hybrid fixed-price and time-and-materials contract featuring a one-year base period and four one-year options. The dispute arose after SAIC was selected as the best-value provider with a total evaluated price of approximately $95.4 million, significantly lower than CRGT's $134.3
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WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a bid protest filed by Salient CRGT Inc., Fairfax, Virginia, regarding a technology information services task order awarded to Science Applications International Corp., Reston, Virginia.
The task order, issued by the GAO's own technology division, is a hybrid fixed-price and time-and-materials contract featuring a one-year base period and four one-year options. The dispute arose after SAIC was selected as the best-value provider with a total evaluated price of approximately $95.4 million, significantly lower than CRGT's $134.3million proposal.
A central pillar of CRGT's protest was the claim that SAIC's price was "unrealistically low." CRGT argued that SAIC's proposed cost was only 51% of the Independent Government Cost Estimate (IGCE), creating a "substantial performance risk." The protester contended that SAIC could not possibly meet the complex requirements of the contract with such a drastically reduced budget and workforce.
However, the GAO ruled that the solicitation did not require a "price realism" analysis. In government contracting, a price realism review--determining if a price is too low--is only required if explicitly stated in the request for proposals. The GAO found that while the agency had the right to reject proposals that showed a "lack of understanding," it was not mandated to throw out a bid simply because the price was low.
CRGT further alleged that the agency failed to properly evaluate SAIC's labor mix and level of effort. The agency's evaluators, however, noted that SAIC's use of artificial intelligence and cross-tasking of employees justified their staffing levels. The record showed that the agency compared SAIC's pricing worksheets directly against their technical approach and found them sufficient to perform the work.
The protest also challenged the evaluation of "key personnel" and "past performance." CRGT argued that the agency waived certain certification requirements for SAIC. The GAO found that the agency had effectively relaxed these standards for both companies, ensuring equal treatment. Regarding past performance, SAIC received a "Substantial Confidence" rating compared to CRGT's "Satisfactory Confidence," a judgment the GAO deemed reasonable and well-documented.
Ultimately, the Source Selection Authority concluded that SAIC was both the highest-rated technical offeror and the lowest-priced. Because SAIC led in both categories, a complex "tradeoff" analysis was not required. The GAO concluded that the agency's decision-making process was consistent with the law and the solicitation's criteria.
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Primary source of information - GAO: https://www.gao.gov/products/b-423283.3
Publicly Released on: Jan. 12, 2026 Published: Dec. 5, 2025
J. Andrew Jackson, Esq., Ryan P. McGovern, Esq., Robyn B. Celestino, Esq., and Jonathan E. DeWitt, Esq., Jones Day, for the protester.
Daniel R. Forman, Esq., William B. O'Reilly, Esq., and Jasmine L. Masri, Esq., Crowell & Moring LLP, for Science Applications International Corporation, the intervenor.
Lauren Jenrich, Esq. and Nuha Hamid, Esq., Government Accountability Office, for the agency.
Charmaine A. Stevenson, Esq., and John Sorrenti, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies PCI Bhate J.V. Protest Over Air Force Construction Contract
By Marlyn T. Vitin
WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a bid protest by PCI Bhate JV LLC, Reston, Virginia. The decision that was issued on Jan. 2, 2026, reinforces the strict importance of following page limits in federal proposals. The protest challenged the U.S. Air Force's decision to disqualify the firm from a major construction and design-build contract after its proposal exceeded the mandatory page count.
The dispute arose from a solicitation for a multi-year, small business set-aside contract to support projects at Offutt Air Force Base. The Air Force had established a
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WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a bid protest by PCI Bhate JV LLC, Reston, Virginia. The decision that was issued on Jan. 2, 2026, reinforces the strict importance of following page limits in federal proposals. The protest challenged the U.S. Air Force's decision to disqualify the firm from a major construction and design-build contract after its proposal exceeded the mandatory page count.
The dispute arose from a solicitation for a multi-year, small business set-aside contract to support projects at Offutt Air Force Base. The Air Force had established aclear limit of 100 pages for all proposal volumes combined. PCI Bhate JV submitted a proposal totaling 112 pages.
In accordance with the solicitation's instructions--which explicitly warned that excess pages would not be read--the Air Force evaluators removed the final 12 pages of the firm's technical volume before beginning their review. Because the firm had placed its "seed project" plans and experience information at the very end of the document, the removal of those 12 pages left the proposal incomplete.
The Air Force subsequently rated the proposal as "technically unacceptable" because the remaining 88 pages lacked the required management plans and schedules for the specific construction projects.
PCI Bhate JV argued that the agency acted unreasonably by cutting pages from the technical section. The firm suggested that since it was already identified as one of the lowest-priced bidders, the Air Force should have counted the "first several pages" of its price volume and then cut pages from the price volume instead to save the technical content.
The GAO rejected this logic, ruling that an agency is not obligated to "sort through" a non-compliant proposal to decide which pages the bidder would prefer to keep. General Counsel Edda Emmanuelli Perez noted that by exceeding the limit, the firm "assumed the risk" that vital information would be discarded.
The firm also argued that the Air Force should have used its discretion to waive the page limit, noting that it offered a lower price than several of the eventual winners and that the government could have simply awarded a ninth contract.
The GAO dismissed this argument, stating that the Air Force applied the limit consistently to all 24 bidders. The agency was able to meet its needs and achieve healthy competition while enforcing the rules as written. The GAO concluded that there was no legal error in the agency's refusal to grant a special exception for a firm that failed to follow basic formatting instructions.
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Primary source of information - GAO: https://www.gao.gov/products/b-423853
Publicly Released on: Jan. 8, 2026 Published: Jan. 2, 2026
Joseph G. Martinez, Esq., Dentons US LLP, for the protester.
Colonel Justin A. Silverman, Lieutenant Colonel Jeffrey J. Hannon, Isabelle P. Cutting,
Esq., and Lyric L. Clark, Esq., Department of the Air Force, 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 PCI Bhate J.V. Protest Over Air Force Construction Contract
By Marlyn T. Vitin
WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a bid protest by PCI Bhate JV LLC, Reston, Virginia. The decision that was issued on Jan. 2, 2026, reinforces the strict importance of following page limits in federal proposals. The protest challenged the U.S. Air Force's decision to disqualify the firm from a major construction and design-build contract after its proposal exceeded the mandatory page count.
The dispute arose from a solicitation for a multi-year, small business set-aside contract to support projects at Offutt Air Force Base. The Air Force had established a
... Show Full Article
WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a bid protest by PCI Bhate JV LLC, Reston, Virginia. The decision that was issued on Jan. 2, 2026, reinforces the strict importance of following page limits in federal proposals. The protest challenged the U.S. Air Force's decision to disqualify the firm from a major construction and design-build contract after its proposal exceeded the mandatory page count.
The dispute arose from a solicitation for a multi-year, small business set-aside contract to support projects at Offutt Air Force Base. The Air Force had established aclear limit of 100 pages for all proposal volumes combined. PCI Bhate JV submitted a proposal totaling 112 pages.
In accordance with the solicitation's instructions--which explicitly warned that excess pages would not be read--the Air Force evaluators removed the final 12 pages of the firm's technical volume before beginning their review. Because the firm had placed its "seed project" plans and experience information at the very end of the document, the removal of those 12 pages left the proposal incomplete.
The Air Force subsequently rated the proposal as "technically unacceptable" because the remaining 88 pages lacked the required management plans and schedules for the specific construction projects.
PCI Bhate JV argued that the agency acted unreasonably by cutting pages from the technical section. The firm suggested that since it was already identified as one of the lowest-priced bidders, the Air Force should have counted the "first several pages" of its price volume and then cut pages from the price volume instead to save the technical content.
The GAO rejected this logic, ruling that an agency is not obligated to "sort through" a non-compliant proposal to decide which pages the bidder would prefer to keep. General Counsel Edda Emmanuelli Perez noted that by exceeding the limit, the firm "assumed the risk" that vital information would be discarded.
The firm also argued that the Air Force should have used its discretion to waive the page limit, noting that it offered a lower price than several of the eventual winners and that the government could have simply awarded a ninth contract.
The GAO dismissed this argument, stating that the Air Force applied the limit consistently to all 24 bidders. The agency was able to meet its needs and achieve healthy competition while enforcing the rules as written. The GAO concluded that there was no legal error in the agency's refusal to grant a special exception for a firm that failed to follow basic formatting instructions.
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Primary source of information - GAO: https://www.gao.gov/products/b-423853
Publicly Released on: Jan. 8, 2026 Published: Jan. 2, 2026
Joseph G. Martinez, Esq., Dentons US LLP, for the protester.
Colonel Justin A. Silverman, Lieutenant Colonel Jeffrey J. Hannon, Isabelle P. Cutting,
Esq., and Lyric L. Clark, Esq., Department of the Air Force, 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 Oready LLC Protest Over BLM Warehouse Services Contract
By Marlyn T. Vitin
WASHINGTON, Feb. 12 -- The Government Accountability Office upheld the U.S. Department of the Interior Bureau of Land Management's decision to disqualify Oready LLC, Las Vegas, Nevada, from a contract for warehouse services at the Ely Regional Seed Warehouse. The ruling, which was issued on Jan. 9, 2026, clarifies that contractors must adhere strictly to specified pricing formats, even when general contract terminology like "fixed-price" is used elsewhere in the solicitation.
Oready, LLC of Las Vegas, Nevada, argued that its proposal was unfairly excluded. The firm claimed that because the request
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WASHINGTON, Feb. 12 -- The Government Accountability Office upheld the U.S. Department of the Interior Bureau of Land Management's decision to disqualify Oready LLC, Las Vegas, Nevada, from a contract for warehouse services at the Ely Regional Seed Warehouse. The ruling, which was issued on Jan. 9, 2026, clarifies that contractors must adhere strictly to specified pricing formats, even when general contract terminology like "fixed-price" is used elsewhere in the solicitation.
Oready, LLC of Las Vegas, Nevada, argued that its proposal was unfairly excluded. The firm claimed that because the requestfor proposals (RFP) described the project as a "firm-fixed-price" contract, it was appropriate to submit its bid as a total annual lump sum for each labor category. However, the BLM rejected the proposal because the solicitation specifically required "Quoted Hourly Rates" for material handling laborers and warehouse specialists.
The GAO found that the instructions were clear and not "latently ambiguous" as the firm suggested. Although the RFP used the term "fixed-price," it repeatedly directed offerors to provide hourly rates that included minimum wages, benefits, overhead, and profit. The GAO noted that the requirement for hourly rates appeared multiple times in the schedule of services and the bid schedule sheet. Consequently, Oready LLC, could not reasonably claim the requirement was hidden or confusing.
The ruling also addressed the firm's argument that the agency should have allowed it to "clarify" its pricing after the submission deadline. The GAO determined that submitting a lump sum instead of an hourly rate is a material non-conformity rather than a minor clerical error. Agencies are not required to seek clarifications for proposals that fail to meet fundamental solicitation requirements.
Because Oready LLC, failed to challenge the pricing format before the proposal due date, its later objections were deemed untimely. The GAO concluded that the BLM acted reasonably by following the solicitation's explicit terms and disqualifying the non-compliant bid.
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Primary source of information - GAO: https://www.gao.gov/products/b-423934
Publicly Released on: Jan. 12, 2026 Published: Jan. 9, 2026
Mike Farro for the protester.
William B. Blake, Esq., Department of the Interior, for the agency.
Christine Martin, Esq., and Tania Calhoun, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Manutek Inc. Protest Over NOAA ProTech 2.0 Weather Domain Award
By Marlyn T. Vitin
WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a bid protest by Manutek Inc., Canton, Michigan. The decision, issued on Jan. 8, 2026, upholds the U.S. Department of Commerce National Oceanic and Atmospheric Administration's decision not to award the firm a contract under the ProTech 2.0 Weather Domain program, which is an $8 billion initiative for professional, scientific and technical services. The ruling highlights the critical necessity for contractors to provide specific, detailed evidence of their roles in past projects and to manage their time effectively during high-stakes
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WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a bid protest by Manutek Inc., Canton, Michigan. The decision, issued on Jan. 8, 2026, upholds the U.S. Department of Commerce National Oceanic and Atmospheric Administration's decision not to award the firm a contract under the ProTech 2.0 Weather Domain program, which is an $8 billion initiative for professional, scientific and technical services. The ruling highlights the critical necessity for contractors to provide specific, detailed evidence of their roles in past projects and to manage their time effectively during high-stakesoral presentations.
Manutek's protest primarily targeted how NOAA evaluated its technical experience. While Manutek claimed extensive experience in sophisticated weather modeling, such as pre-processing and numerical prediction, NOAA rated the firm as only having some confidence. The agency found that Manutek often listed impressive project outcomes but failed to explain the material role the company actually played in those achievements. For example, in environmental numerical prediction modeling, Manutek's proposal did not specify how it developed or maintained the models. The GAO ruled that it is an offeror's responsibility to prove their experience, and "mixed bag" results naturally lead to lower confidence ratings.
A critical turning point in the competition was the Phase Two Oral Presentation, where offerors were given exactly 45 minutes to answer four specific management scenarios. According to the record, Manutek spent the vast majority of its time on the first two scenarios. By the time it reached the final topics regarding niche teaming partners and large-scale problem solving, it had only 10 minutes remaining and struggled to provide complete answers. Because Manutek ran out of time, it failed to explain how it solved significant implementation problems or how it utilized internal quality controls.
The GAO found that NOAA acted reasonably by not asking follow-up questions during the interactive dialogue, as doing so would have essentially allowed Manutek to change its offer by providing information it missed during the timed session. NOAA used a "Highest Technically Rated Offeror" (HTRO) methodology, initially selecting 15 firms with high confidence ratings and no negative findings. Manutek fell into the bottom tier of bidders because of significant negative findings in its management approach. The GAO concluded that even though Manutek had an exceptional past performance record, this could not overcome the technical and management weaknesses identified in its proposal.
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Primary source of information - GAO: https://www.gao.gov/products/b-423476.2%2Cb-423476.4
Publicly Released on: Jan. 9, 2026 Published: Jan. 8, 2026
Manohar Gaddam for the protester.
Jillian Stern, Esq., Andrew Parker Frank, Esq., and Lauren Williams, Esq., Department of Commerce, 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 Guidehouse Digital Protest Over $162 Million Task Order
By Marlyn T. Vitin
WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a protest by Guidehouse Digital LLC, McLean, Virginia, regarding a high-stakes information technology contract. The decision released on Jan. 5, 2026, solidifies the award of a $162 million task order to IBM, Armonk, New York.
The contract, issued by the U.S. Department of Homeland Security's U.S. Citizenship and Immigration Services, sought specialized architecture and engineering services. The dispute centered on how the agency evaluated staffing plans. Under the rules of the solicitation, any company receiving a "no confidence"
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WASHINGTON, Feb. 12 -- The Government Accountability Office has denied a protest by Guidehouse Digital LLC, McLean, Virginia, regarding a high-stakes information technology contract. The decision released on Jan. 5, 2026, solidifies the award of a $162 million task order to IBM, Armonk, New York.
The contract, issued by the U.S. Department of Homeland Security's U.S. Citizenship and Immigration Services, sought specialized architecture and engineering services. The dispute centered on how the agency evaluated staffing plans. Under the rules of the solicitation, any company receiving a "no confidence"rating in any evaluation category--such as staffing--would be automatically disqualified from winning the contract.
The government provided a standard staffing matrix as a guide for what it expected. While bidders were permitted to propose alternative staffing models, they were required to explain the specific benefits the government would receive from those changes. Guidehouse proposed an alternative plan that included various staffing reductions.
Government evaluators assigned Guidehouse a "no confidence" rating, concluding that the company failed to clearly explain the advantages of its personnel changes. The evaluators also found that Guidehouse relied on unsupported assumptions, specifically claiming the agency would move to a fully cloud-based infrastructure within five years. The agency noted that this assumption was not part of its strategic plan and that cutting staff based on that premise created an unacceptable risk to contract performance.
Guidehouse argued that the benefits of its plan, primarily cost savings, should have been self-evident and accused the agency of essentially treating the government's guide as a mandatory requirement. However, the Accountability Office ruled that the agency acted reasonably. The decision noted that IBM followed the provided matrix--offering a "safe harbor" approach - while Guidehouse's alternative plan was rejected not because it was different, but because it was poorly justified and technically risky.
The ruling also touched on a procedural dispute involving the inadvertent release of unredacted documents during the litigation. While the agency accused Guidehouse's attorneys of misconduct for reading the leaked files, the Accountability Office cleared the lawyers of any abusive practices, finding they had acted in good faith. Despite this, the underlying technical evaluation remained valid, and the $162 million award to IBM was upheld.
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Primary source of information - GAO: https://www.gao.gov/products/b-423833%2Cb-423833.2
Publicly Released on: Jan. 13, 2026 Published: Jan. 5, 2026
Brian G. Walsh, Esq., Tracye Winfrey Howard, Esq., and W. Benjamin Phillips, III, Esq., Wiley Rein LLP, for the protester.
Sylvia Yi, Esq., and Adam R. Briscoe, Esq., Bass Berry & Sims, PLC, for International Business Machines Corporation, the intervenor.
Jessica Easton, Esq., Richard Postma, Esq., Dana-Marie Akpan, Esq., and Clarine Allen, Esq., Department of Homeland Security, for the agency.
Michael Willems, Esq., and Evan D. Wesser, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
