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 Ambulance Management Services Protest Against VA Award, Citing Lack of Interested Party Status
By Marlyn T. Vitin
WASHINGTON, Dec. 5 -- The Government Accountability Office has dismissed a protest filed by Ambulance Management Services Ltd. dba Trans-Care Ambulance, a small business in Terra Haute, Indiana, challenging the U.S. Department of Veterans Affairs award of a contract to Heartland Ambulance Service LLC, a small business IN Muncie, Indiana. The contract is for non-emergency ambulance transportation services under an invitation for bids.
Trans-Care's primary allegation was that the VA made an improper affirmative responsibility determination for Heartland. The protester claimed that a VA official
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WASHINGTON, Dec. 5 -- The Government Accountability Office has dismissed a protest filed by Ambulance Management Services Ltd. dba Trans-Care Ambulance, a small business in Terra Haute, Indiana, challenging the U.S. Department of Veterans Affairs award of a contract to Heartland Ambulance Service LLC, a small business IN Muncie, Indiana. The contract is for non-emergency ambulance transportation services under an invitation for bids.
Trans-Care's primary allegation was that the VA made an improper affirmative responsibility determination for Heartland. The protester claimed that a VA officialhad told a Trans-Care employee that Heartland attempted to bribe the official on a different contract, which, if true, should have led the contracting officer to find Heartland non-responsible and ineligible for award.
The VA made the award to Heartland as the lowest bidder, with a total price of $18,452,800. Trans-Care was the fifth-lowest bidder, with a price of $31,049,618.
The GAO dismissed the protest because Trans-Care is not an interested party under the Competition in Contracting Act (CICA) and the GAO's bid protest regulations. The record showed there were three other bidders with lower prices than Trans-Care that the protester did not challenge.
The GAO determined that even if it were to sustain Trans-Care's protest and Heartland were found ineligible, Trans-Care would not be next in line for the award, as these three intervening bidders would be considered first. The GAO also explicitly rejected Trans-Care's argument that its "sufficiently grave" allegations of attempted bribery should merit consideration regardless of its interested party status, confirming that CICA and GAO regulations do not provide such an exception. Because the protester's interest in the procurement was too remote, the protest was dismissed.
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Primary source of information - GAO: https://www.gao.gov/products/b-423804
Publicly Released on: Dec. 4, 2025 Published: Dec. 2, 2025
Shane J. McCall, Esq., Nicole D. Pottroff, Esq., John L. Holtz, Esq., Stephanie L. Ellis, Esq., Gregory P. Weber, Esq., and Annie E. Birney, Esq., Koprince McCall Pottroff, LLC, for the protester.
Katherine B. Burrows, Esq., Kristine Cralle, Esq., Jacqueline K. Unger, Esq., and Eric A. Valle, Esq., Piliero Mazza, PLLC, for Heartland Ambulance Service, LLC, the intervenor.
Jared M. Levin, Esq., Department of Veterans Affairs, 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 Valiant Government Services Protest of Army Linguist Contract Award to Mission Essential Group
By Marlyn T. Vitin
WASHINGTON, Dec. 5 -- The Government Accountability Office has denied a protest filed by Valiant Government Services LLC, Fayetteville, North Carolina, challenging the U.S. Army's issuance of a task order for linguist services. The order was awarded to The Mission Essential Group LLC, New Albany, Ohio, combining requirements previously performed separately by the two firms.
The new task order, known as EUCOM III, consolidates work in support of U.S. European Command (EUCOM) and U.S. Army Intelligence and Security Command. The Army issued the Request for Task Order Proposals (RTOP) under a multiple-award
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WASHINGTON, Dec. 5 -- The Government Accountability Office has denied a protest filed by Valiant Government Services LLC, Fayetteville, North Carolina, challenging the U.S. Army's issuance of a task order for linguist services. The order was awarded to The Mission Essential Group LLC, New Albany, Ohio, combining requirements previously performed separately by the two firms.
The new task order, known as EUCOM III, consolidates work in support of U.S. European Command (EUCOM) and U.S. Army Intelligence and Security Command. The Army issued the Request for Task Order Proposals (RTOP) under a multiple-awardcontract, using a best-value tradeoff approach where the Continuity and Transition Plan and Past Performance factors were significantly more important than Cost/Price.
The evaluation resulted in the following key findings: both firms received a "GOOD" rating for the Continuity and Transition Plan factor. For Past Performance, Mission Essential received "SUBSTANTIAL CONFIDENCE," while Valiant received "SATISFACTORY CONFIDENCE." Mission Essential's proposed Cost/Price was $208,264,440, significantly lower than Valiant's $234,039,382. The Army concluded that the proposals were approximately equal in the technical factors, but Mission Essential was superior in Past Performance and offered a lower cost, justifying the award.
The GAO addressed and denied Valiant's main protest grounds. Valiant argued the Army failed to assign strengths for its low attrition rate and rapid mobilization team. The GAO found the Army reasonably concluded Valiant's retention plan used "typical industry practices" and that attrition data was appropriately considered historical past performance, not a strength under the continuity plan's focus on replacement processes.
The GAO also denied the claim of unequal treatment regarding the linguist pipeline size, finding the Army applied the same evaluation standard to both firms. Finally, Valiant contended the Army failed to amend the RTOP after the required number of Full-Time Equivalents (FTEs) decreased on the incumbent task order.
The GAO denied this, concluding that the original solicitation contemplated the ongoing fluctuation of requirements for linguist services, and thus, this fluctuation did not constitute a material change that would necessitate amending the RTOP and restarting the competition. The GAO upheld the Army's selection of Mission Essential as the best value.
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Primary source of information - GAO: https://www.gao.gov/products/b-423740%2Cb-423740.2
Publicly Released on: Dec. 4, 2025 Published: Nov. 26, 2025
Daniel R. Forman, Esq., Cherie J. Owen, Esq., and Roxanne N. Cassidy, Esq., Crowell & Moring LLP, for the protester.
Craig A. Holman, Esq., Stuart W. Turner, Esq., Amanda J. Sherwood, Esq., Nicole A. Williamson, Esq., and Samantha C. Smith, Esq., Arnold & Porter Kaye Scholer LLP, for The Mission Essential Group, LLC, the intervenor.
Captain Sana H. Daniell, and Captain Lindsay M. DeFer, Department of the Army, for the agency.
Nathaniel S. Canfield, Esq., and Evan D. Wesser, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Protest by AAA General Contractors Against VA Over Missing Subcontracting Certification
By Marlyn T. Vitin
WASHINGTON, Dec. 5 -- The Government Accountability Office General Counsel has denied a bid protest filed by AAA General Contractors LLC, an eligible service-disabled veteran-owned small business in El Paso, Texas. The protest challenged the U.S. Department of Veterans Affairs rejection of its proposal for indefinite-delivery, indefinite-quantity contracts.
The contract was for construction and design-build services for VA medical facilities across the Veterans Integrated Service Network 17, covering portions of Texas, New Mexico, and Oklahoma.
The VA rejected the proposal because it failed to
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WASHINGTON, Dec. 5 -- The Government Accountability Office General Counsel has denied a bid protest filed by AAA General Contractors LLC, an eligible service-disabled veteran-owned small business in El Paso, Texas. The protest challenged the U.S. Department of Veterans Affairs rejection of its proposal for indefinite-delivery, indefinite-quantity contracts.
The contract was for construction and design-build services for VA medical facilities across the Veterans Integrated Service Network 17, covering portions of Texas, New Mexico, and Oklahoma.
The VA rejected the proposal because it failed toinclude the formal certification required by VA Acquisition Regulation Supplement (VAAR) clause 852.219-75. This clause mandates that an offeror certify its compliance with the statutory limitation on subcontracting required by law for SDVOSB contracts.
Crucially, the Request for Proposals (RFP) specifically included the text of the VAAR clause, which warned: "The Government will not consider offers for award from offerors that do not provide the certification, and all such responses will be deemed ineligible for evaluation and award."
AAA General Contractors argued that the certification was an immaterial administrative formality because the terms of the eventual contract would require compliance with subcontracting limits anyway. It also contended that the VA should have allowed the firm to submit the missing document as a minor clarification.
The GAO rejected all of the protester's arguments, finding the VA's rejection proper.
The GAO affirmed that the requirement to submit the signed certification is a material term of the solicitation, not a minor formality. By failing to include the certificate with its proposal, AAA General Contractors failed to meet a material proposal submission requirement and rendered its proposal ineligible for award under the RFP's express terms.
Furthermore, the GAO ruled that allowing the firm to submit the certificate after the proposal deadline would have constituted discussions--a step the RFP clearly advised the agency did not intend to hold. Correcting a material defect, such as the omission of this specific, required certification, cannot be remedied under the label of an allowed "clarification."
Therefore, the GAO concluded that the contracting officer acted appropriately by following the RFP's instructions and rejecting the proposal without holding discussions.
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Primary source of information - GAO: https://www.gao.gov/products/b-423842
Publicly Released on: Nov. 18, 2025 Published: Nov. 18, 2025
Edgar Skertchly for the protester.
Natica C. Neely, Esq., Department of Veterans Affairs, for the agency.
Paul N. Wengert, Esq., and Tania Calhoun, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Protest, Upholding Army Contract Award to BryMak Over SRM Group
By Marlyn T. Vitin
WASHINGTON, Dec. 5 -- The Government Accountability Office has denied a protest filed by SRM Group LLC, Virginia Beach, Virginia, regarding a U.S. Army contract for lodging and transportation services at the National Guard Professional Education Center in North Little Rock, Arkansas. The decision, released on Sept. 25, 2025, affirms the Army's selection of BryMak Associates Inc., Clarksville, Tennessee.
The procurement was a set-aside for service-disabled veteran-owned small businesses (SDVOSB) for a fixed-price contract. The Army evaluated proposals based on a best-value tradeoff, prioritizing
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WASHINGTON, Dec. 5 -- The Government Accountability Office has denied a protest filed by SRM Group LLC, Virginia Beach, Virginia, regarding a U.S. Army contract for lodging and transportation services at the National Guard Professional Education Center in North Little Rock, Arkansas. The decision, released on Sept. 25, 2025, affirms the Army's selection of BryMak Associates Inc., Clarksville, Tennessee.
The procurement was a set-aside for service-disabled veteran-owned small businesses (SDVOSB) for a fixed-price contract. The Army evaluated proposals based on a best-value tradeoff, prioritizingTechnical, then Past Performance, then Cost.
SRM Group, the incumbent contractor, challenged the Army's evaluation of BryMak's past performance, arguing it was unreasonable and led to a flawed best-value decision. Both firms received equivalent ratings: "Purple/Good" for Technical and "Substantial Confidence" for Past Performance. However, BryMak's total evaluated price of $22,303,146 was approximately 7.8 percent lower than SRM Group's price of $24,059,013.
The GAO found the Army's evaluation to be reasonable and consistent with the solicitation. The contracting officer determined that the proposals were essentially equivalent under the non-price factors. Since BryMak offered the same high level of technical merit and confidence at a lower cost to the government, the Army's decision to award the contract to BryMak was upheld.
The GAO specifically found no fault in the Army's assessment of BryMak's relevant past performance, which included work similar in scope and complexity to the required services, even when performed under different industry codes.
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Primary source of information - GAO: https://www.gao.gov/products/b-423695
Publicly Released on: Nov. 20, 2025 Published: Sept. 25, 2025
Thomas K. David, Esq., and Lewis Rhodes, Esq., Reston Law Group, LLP, for the protester.
Richard W. Arnholt, Esq., Sylvia Yi, Esq., and Adam R. Briscoe, Esq., Bass Berry & Sims, PLC, for BryMak & Associates, Inc., the intervenor.
Robert B. Neill, Esq., Major Joseph A. Seaton, Jr., and Lieutenant Colonel Anthony V. Lenze, Department of the Army, for the agency.
Suresh S. Boodram, Esq., and Evan D. Wesser, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Protest by SOFIS-TRG, Upholds Air Force Award to MilTrain for MQ-9 Training
By Marlyn T. Vitin
WASHINGTON, Dec. 5 -- The Government Accountability Office has denied a protest filed by SOFIS-TRG LLC, Alexandria, Virginia, challenging a U.S. Air Force contract award. The contract, for training services related to the MQ-9 remotely piloted aircraft, was granted to MilTrain JV II LLC, North Las Vegas, Nevada.
SOFIS-TRG asserted that the Air Force unreasonably assigned both proposals the same Substantial Confidence rating under the Past Performance factor, despite SOFIS-TRG having a numerically higher number of "Very Relevant" contracts. The protester also argued that this flawed evaluation
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WASHINGTON, Dec. 5 -- The Government Accountability Office has denied a protest filed by SOFIS-TRG LLC, Alexandria, Virginia, challenging a U.S. Air Force contract award. The contract, for training services related to the MQ-9 remotely piloted aircraft, was granted to MilTrain JV II LLC, North Las Vegas, Nevada.
SOFIS-TRG asserted that the Air Force unreasonably assigned both proposals the same Substantial Confidence rating under the Past Performance factor, despite SOFIS-TRG having a numerically higher number of "Very Relevant" contracts. The protester also argued that this flawed evaluationled to an unreasonable best-value tradeoff decision.
The solicitation provided for a fixed-price contract, where the Past Performance factor was significantly more important than the Technical factor and Price. Both SOFIS-TRG and MilTrain received identical ratings: "Acceptable" for Technical and "Substantial Confidence" for Past Performance. MilTrain's total proposed price was $84,647,510, while SOFIS-TRG's price was slightly higher at $86,045,416.
The GAO found the Air Force's evaluation to be reasonable. While SOFIS-TRG had one more "Very Relevant" past performance rating, the Source Selection Authority (SSA) looked behind the adjectival ratings and conducted an integrated assessment of both firms' records. The SSA concluded that both companies demonstrated a strong record of recent, relevant, and high-quality work, with performance showing ample experience managing the Air Force's remotely piloted aircraft program.
The SSA determined that the difference in individual relevancy ratings was not a substantial difference that made one offeror superior to the other under the overall Past Performance factor. The GAO affirmed that the agency's methodology correctly assessed each proposal against the solicitation criteria rather than simply relying on a numerical comparison between the two firms.
Since both proposals were rated equally high in Past Performance and Acceptable in Technical, the SSA determined that neither offeror was superior based on non-price factors.
In this scenario of equivalent technical and past performance merit, the SSA relied on the lower price to select the awardee. The SSA explicitly concluded that paying an additional $1,397,906--the difference between the two prices--to SOFIS-TRG for the same level of expected performance was not warranted and was not in the Government's best interest. The GAO found this tradeoff analysis to be rational and consistent with the solicitation requirements, leading to the denial of the protest.
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Primary source of information - GAO: https://www.gao.gov/products/b-423667
Publicly Released on: Nov. 25, 2025 Published: Sept. 16, 2025
Shomari B. Wade, Esq., Timothy M. McLister, Esq., Christopher M. O'Brien, Esq., Jordan N. Malone, Esq., and Olivia C. Bellini, Esq., Greenberg Traurig, LLP, for the protester.
J. Bradley Reaves, Esq., Kenneth M. Hyde, Esq., and Jacob D. Noe, Esq., Reaves GovCon Group, for MilTrain JV II, LLC, the intervenor.
Colonel Nina R. Padalino, Hector Rivera-Hernandez, Esq., and W. Jacob Worthan, Esq., Department of the Air Force, for the agency.
Kenneth Kilgour, Esq., and Jennifer D. Westfall-McGrail, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Protest by QA Engineering Over Army Corps of Engineers Construction Contract
By Marlyn T. Vitin
WASHINGTON, Dec. 5 -- The Government Accountability Office denied a protest by QA Engineering LLC, Albuquerque, New Mexico, challenging the U.S. Army Corps of Engineers' contract award to Koman Advantage LLC, Chandler, Arizona, for a small arms storage facility at Kirtland Air Force Base, New Mexico. The contract was awarded on a lowest-priced technically acceptable basis.
The GAO upheld the Army's finding that QA Engineering's proposal was technically unacceptable, making it ineligible for award. The request for proposals required proposals to be acceptable across three factors, including management
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WASHINGTON, Dec. 5 -- The Government Accountability Office denied a protest by QA Engineering LLC, Albuquerque, New Mexico, challenging the U.S. Army Corps of Engineers' contract award to Koman Advantage LLC, Chandler, Arizona, for a small arms storage facility at Kirtland Air Force Base, New Mexico. The contract was awarded on a lowest-priced technically acceptable basis.
The GAO upheld the Army's finding that QA Engineering's proposal was technically unacceptable, making it ineligible for award. The request for proposals required proposals to be acceptable across three factors, including managementapproach.
The Army found QA Engineering failed to discuss quality control for off-site fabrication of the pre-engineered metal building (PEMB), a requirement explicitly stated in the solicitation. QA Engineering argued the agency created an unstated criterion, but the GAO disagreed, noting the term "PEMB" was a reasonable description of the required offsite fabrication component. QA Engineering's proposal, which focused only on the "On-Site Construction Team" and made only a vague reference to off-site inspections, failed to meaningfully address this key requirement.
Because QA Engineering's proposal was unacceptable, the company could not prove it was prejudiced by any other alleged evaluation errors. The GAO also rejected the firm's claim of disparate treatment, noting the awardee, Koman, and three other acceptable offerors did address offsite fabrication quality control elsewhere in their submissions, unlike QA Engineering. Since at least three other proposals were clearly acceptable, QA Engineering would not be in line for the award even if Koman's evaluation were flawed.
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Primary source of information - GAO: https://www.gao.gov/products/b-423716%2Cb-423716.2
Publicly Released on: Nov. 14, 2025 Published: Sept. 30, 2025
Jon W. Burd, Esq., and Vaibhavi Patria, Esq., Wiley Rein LLP, for the protester.
Maureen E. Rudolph, Esq., Matthew R. Keiser, Esq., Trevor Stevens, Esq., Joseph Turner, Esq., and Randall C. Merchant, Esq., Department of the Army, for the agency.
Michael Willems, Esq., and Evan D. Wesser, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Protest by AtechGov Against USDA IT Services Procurement
By Marlyn T. Vitin
WASHINGTON, Dec. 5 -- The Government Accountability Office General Counsel has denied a protest filed by AtechGov LLC, Bethesda, Maryland, challenging actions taken by the U.S. Department of Agriculture regarding a request for quotations for information technology support services for the USDA's Rural Development division.
AtechGov raised two main issues: first, that the USDA improperly limited competition by issuing the RFQ only to a select group of vendors, and second, that the agency unreasonably refused to extend the deadline for submitting quotations.
The GAO found the USDA's actions were
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WASHINGTON, Dec. 5 -- The Government Accountability Office General Counsel has denied a protest filed by AtechGov LLC, Bethesda, Maryland, challenging actions taken by the U.S. Department of Agriculture regarding a request for quotations for information technology support services for the USDA's Rural Development division.
AtechGov raised two main issues: first, that the USDA improperly limited competition by issuing the RFQ only to a select group of vendors, and second, that the agency unreasonably refused to extend the deadline for submitting quotations.
The GAO found the USDA's actions wereconsistent with procurement regulations. The agency's strategy was to establish a blanket purchase agreement (BPA) with Federal Supply Schedule (FSS) contractors under the section 8(a) small business set-aside program. Since the acquisition value exceeded the simplified acquisition threshold and included a statement of work, Federal Acquisition Regulation (FAR) subsection 8.405-3(b)(2)(v)(B) governed the process. This regulation gives the agency discretion to either post the RFQ on the General Services Administration's eBuy system or to send it directly to "as many schedule contractors as practicable," provided it's consistent with market research and reasonably ensures quotes are received from at least three contractors.
The USDA conducted market research which identified at least five eligible small businesses and, acting under its discretion, chose to issue the RFQ directly to four vendors it believed could meet the requirements. The GAO determined that sending the RFQ to four vendors, which was consistent with the market research and ensured competition from at least three, complied with the plain and unambiguous meaning of the FAR. Therefore, the GAO concluded the agency did not illegally limit competition.
Regarding the deadline extension, the GAO found the protester's argument unpersuasive. AtechGov learned of the RFQ on July 16 and requested a copy and an extension on July 17, just four days before the July 21 deadline. The agency was under no obligation to extend the due date simply because AtechGov became aware of the RFQ late. The other four solicited vendors were given one month to respond, a reasonable time for a quotation. The protester provided no legal support requiring an extension for a vendor not initially solicited, nor did it offer a specific reason why submitting a quotation in four days was impossible. The GAO concluded the protester failed to demonstrate the USDA acted unreasonably.
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Primary source of information - GAO: https://www.gao.gov/products/b-423738
Publicly Released on: Nov. 18, 2025 Published: Nov. 17, 2025
W. Brad English, Esq., Hunter M. Drake, Esq., Taylor R. Holt, Esq., and Emily J. Chancey, Esq., Maynard Nexsen, PC, for the protester.
Adam Humphries, Esq., U.S. Department of Agriculture, for the agency.
Christine Martin, Esq., and Tania Calhoun, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
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.
