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GAO Denies Accura Reconsideration Request Over Protest Cost Reimbursement
By Marlyn T. Vitin
WASHINGTON, Aug. 18 -- The Government Accountability Office has denied a reconsideration request from Accura Engineering and Consulting Services Inc., a small business based in Atlanta, Georgia, concerning reimbursement of costs incurred in a bid protest over a U.S. Army Corps of Engineers contract.
Accura sought reconsideration of a June 23 GAO decision that declined to recommend reimbursement of costs associated with its challenges to the Army's technical evaluation in a competition for quality assurance services. The contract was awarded to Radise International L.C., Barranquitas, Puerto Rico.
The
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WASHINGTON, Aug. 18 -- The Government Accountability Office has denied a reconsideration request from Accura Engineering and Consulting Services Inc., a small business based in Atlanta, Georgia, concerning reimbursement of costs incurred in a bid protest over a U.S. Army Corps of Engineers contract.
Accura sought reconsideration of a June 23 GAO decision that declined to recommend reimbursement of costs associated with its challenges to the Army's technical evaluation in a competition for quality assurance services. The contract was awarded to Radise International L.C., Barranquitas, Puerto Rico.
Theprocurement, conducted as a small-business set-aside, sought quality assurance services to monitor and oversee construction contractors building facilities in Puerto Rico and the U.S. Virgin Islands. The solicitation called for a best-value tradeoff based on technical approach, past performance and price.
In its original protest, Accura challenged several aspects of the Army's evaluation, including the technical approach, past performance, price evaluation and best-value decision. During an outcome-prediction alternative dispute resolution conference in February, GAO advised that it would likely sustain Accura's challenges to the price evaluation and best-value tradeoff because the Army failed to consider option-year prices and did not perform a required price-realism analysis for the seed task order.
The Army subsequently took corrective action, and GAO dismissed the protest as academic. The Corps agreed to reimburse Accura's costs associated with the price evaluation and best-value challenges but declined to reimburse costs related to the technical evaluation.
In June, GAO ruled that the technical evaluation challenges were sufficiently separate from the successful price-related grounds to be considered severable. Accura argued in its reconsideration request that GAO had overlooked portions of its protest connecting the price-realism issue to potential technical risks.
GAO rejected that argument, finding that Accura had not demonstrated a material error of fact or law. While Accura had briefly argued that a price-realism analysis could have affected the technical evaluation, GAO said the primary focus of its technical challenges was the Army's decision to rate Radise's proposal outstanding despite identifying a risk involving key personnel.
GAO concluded that the technical and price challenges involved different core facts and legal theories. The request for reconsideration was therefore denied.
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Primary source of information - GAO: https://www.gao.gov/products/b-424049.5
Publicly Released on: Aug. 11, 2026. Published: Aug. 5, 2026.
Evan C. Williams, Esq., and Nick Feldstern, Esq., Fox Rothschild LLP, for the requester.
Rachel D. Gray, Esq., Department of the Army, 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 American Correctional Healthcare Protest Over Medical Services Pricing Terms
By Marlyn T. Vitin
WASHINGTON, Aug. 18 -- The Government Accountability Office (GAO) denied a protest by American Correctional Healthcare Inc., a small business in Fort Worth, Texas, challenging the pricing terms of a solicitation issued by the U.S. Department of Justice Federal Bureau of Prisons for comprehensive medical services at the federal correctional institution in Cumberland, Maryland.
The July 6 decision, which sought a single contract for specialized medical services that cannot be provided on site. American Correctional Healthcare, the incumbent contractor, argued that the agency unreasonably selected
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WASHINGTON, Aug. 18 -- The Government Accountability Office (GAO) denied a protest by American Correctional Healthcare Inc., a small business in Fort Worth, Texas, challenging the pricing terms of a solicitation issued by the U.S. Department of Justice Federal Bureau of Prisons for comprehensive medical services at the federal correctional institution in Cumberland, Maryland.
The July 6 decision, which sought a single contract for specialized medical services that cannot be provided on site. American Correctional Healthcare, the incumbent contractor, argued that the agency unreasonably selectedMedicare rates for CBSA 51, covering rural West Virginia, as the pricing benchmark.
The company said the benchmark was inappropriate because about 90% of the services it provides under the incumbent contract are performed at Maryland hospitals, which use a different Medicare rate-setting methodology. It also noted that its West Virginia services were provided at a hospital in Morgantown, which is in a different CBSA.
The Bureau of Prisons said it selected CBSA 51 because Maryland uses an unusual Medicare reimbursement formula that differs from other states, while West Virginia uses a conventional rate-setting process. The agency also noted that Cumberland is located on the West Virginia border and that medical services under the incumbent contract have been provided by hospitals in Maryland, Pennsylvania and West Virginia.
GAO found the agency's use of CBSA 51 reasonable for establishing a common pricing benchmark. The solicitation did not require offerors to use the same hospitals or providers as the incumbent and allowed them to propose their own provider networks.
GAO also found that the benchmark did not restrict offerors' actual pricing. Instead, offerors were required to express proposed prices as a discount from or premium to the CBSA 51 Medicare rates. The rates were to serve as a common basis for comparing proposals, not as contractual reimbursement rates.
The decision also rejected the protester's argument that differences between Maryland and West Virginia Medicare rates could create unfair pricing risks. GAO said agencies are not required to eliminate all pricing risk and found that all offerors faced the same potential risks and had sufficient information to compete intelligently.
"Competitive prejudice is an essential element of every viable protest," GAO said, concluding that American Correctional Healthcare had not shown that it was uniquely or unfairly prejudiced by the agency's choice of benchmark.
GAO denied the protest.
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Primary source of information - GAO: https://www.gao.gov/products/b-424391
Publicly Released on: July 14, 2026. Published: July 6, 2026
H. Todd Whay, Esq., and Ian Cronogue, Esq., Baker, Cronogue, Tolle & Werfel, LLP, for the protester.
Loneryl Burns, Esq., William D. Robinson, Esq., Kristina Sullivan, Esq., Clint Gerdine, Esq., and David M. Tatarsky, Esq., Department of Justice, 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 AOC Applied Solutions Protest Over Navy Engineering Task Order
By Marlyn T. Vitin
WASHINGTON, Aug. 18 -- The Government Accountability Office has denied a protest by AOC Applied Solutions LLC, Ashburn, Virginia, challenging the U.S. Navy's decision to exclude the company's proposal from competition for an engineering services task order.
The Navy issued the solicitation in October 2025 under its SeaPort Next Generation contract vehicle, seeking engineering services through a cost-reimbursable task order with a one-year base period and four one-year options. The solicitation required proposals to be submitted in four volumes, including a contract documentation volume containing
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WASHINGTON, Aug. 18 -- The Government Accountability Office has denied a protest by AOC Applied Solutions LLC, Ashburn, Virginia, challenging the U.S. Navy's decision to exclude the company's proposal from competition for an engineering services task order.
The Navy issued the solicitation in October 2025 under its SeaPort Next Generation contract vehicle, seeking engineering services through a cost-reimbursable task order with a one-year base period and four one-year options. The solicitation required proposals to be submitted in four volumes, including a contract documentation volume containinga Contract Data Requirements List.
The solicitation stated that the contract documentation volume would be evaluated on a pass-or-fail basis and that proposals failing any of its requirements would be eliminated from further consideration.
AOC submitted a proposal but did not include the required Contract Data Requirements List in its contract documentation volume. The Navy consequently rated the volume as a failure and excluded AOC's proposal from the competition.
AOC argued that the omission should have been treated as a minor informality because its cost proposal contained information related to the data deliverables listed in the required document. The company also argued that the omitted information did not affect its price or evaluation.
The Navy disagreed, saying AOC had not provided all the information required by the document. Specifically, the Contract Data Requirements List required offerors to provide both a price group and an estimated total price for each data item, while AOC's cost proposal included only the estimated prices.
In a July 14 decision, GAO found that the Navy reasonably declined to waive the omission. The solicitation permitted, but did not require, the agency to waive minor oversights in contract documentation.
GAO said the missing document was a required and material contract document and that AOC had failed to provide all of the information it was required to submit. The office also rejected AOC's argument that the Navy had acted inconsistently by waiving a separate omission involving a fee table. GAO noted that the complete fee-table information had been included elsewhere in AOC's proposal, unlike the information required by the Contract Data Requirements List.
GAO concluded that the Navy acted within its discretion in refusing to waive AOC's omission and properly eliminated the proposal from the competition. The protest was denied.
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Primary source of information - GAO:
Publicly Released on: July 21, 2026. Published: July 14, 2026.
Katherine B. Burrows, Esq., Eric A. Valle, Esq., Caitlin E. Trevillyan, Esq., and Adel K.H. Mansour, Esq., Piliero Mazza, PLLC, for the protester.
Theresa Cortese-Fusaro, Esq., and Stephanie Kearney-Quilling, Esq., Department of the Navy, Naval Surface Warfare Center, for the agency.
Mary G. Curcio, Esq., and John Sorrenti, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
Adel Mansour, Piliero Mazza, PLLC, for the protester.
GAO Denies Crowley Protest Against Navy Ship Procurement Solicitation
By Marlyn T. Vitin
WASHINGTON, Aug. 18 -- The Government Accountability Office has denied a protest by Crowley Government Services Inc., Jacksonville, Florida, challenging the terms of a U.S. Navy solicitation for a vehicle construction manager to procure up to eight ships for the Navy's medium landing ship program. GAO issued its decision June 30, 2026.
Crowley argued that the solicitation imposed unreasonable risks, departed from customary commercial practices and did not give companies enough time to prepare proposals. The Navy disputed the allegations and asked GAO to deny the protest.
At issue was a requirement
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WASHINGTON, Aug. 18 -- The Government Accountability Office has denied a protest by Crowley Government Services Inc., Jacksonville, Florida, challenging the terms of a U.S. Navy solicitation for a vehicle construction manager to procure up to eight ships for the Navy's medium landing ship program. GAO issued its decision June 30, 2026.
Crowley argued that the solicitation imposed unreasonable risks, departed from customary commercial practices and did not give companies enough time to prepare proposals. The Navy disputed the allegations and asked GAO to deny the protest.
At issue was a requirementthat the vehicle construction manager negotiate and award shipbuilding subcontracts to designated shipyards, including Bollinger and FMM. Crowley argued that successful performance would depend on reaching agreements with third parties that it could not control. The company also contended that the solicitation did not adequately protect it if the designated shipyards refused to negotiate in good faith.
GAO found that the solicitation provided sufficient information for companies to compete intelligently and on an equal basis. The decision noted that the solicitation included mechanisms for relief if a designated source refused to negotiate in good faith and limited the vehicle construction manager's liability in certain circumstances involving subcontractor default.
Crowley also challenged the requirement as inconsistent with customary commercial practices. The Navy acknowledged that directed-source subcontracting was not customary commercial practice but had obtained a waiver allowing the agency to depart from that practice. GAO concluded that the waiver met regulatory requirements and reasonably supported the Navy's decision to direct work to FMM and Bollinger.
The Navy's waiver cited its interest in maintaining FMM as a capable source in the industrial base and Bollinger's unique experience, which GAO said would help the Navy begin construction quickly to support critical Marine Corps requirements.
GAO also rejected Crowley's challenge to the amount of time provided to submit proposals, finding that the Navy gave offerors sufficient time to prepare and submit their proposals.
GAO therefore denied Crowley's protest.
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Primary source of information - GAO: https://www.gao.gov/products/b-424373
Publicly Released on: July 10, 2026. Published: June 30, 2026
James Y. Boland, Esq., Lindsay M. Reed, Esq., and Allison M. Siegel, Esq., Venable LLP, for the protester.
Alex L. Sheppard Esq., and Patrick Sheehan, Esq., Department of the Navy, for the agency.
Raymond Richards, Esq., and John Sorrenti, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Ardmore Consulting Protest of Homeland Security Contract Award to T47 International
By Marlyn T. Vitin
WASHINGTON, Aug. 18 -- The Government Accountability Office has denied in part and dismissed in part a protest by Ardmore Consulting Group Inc., Atlanta, Georgia, challenging the U.S. Department of Homeland Security's award of a contract to T47 International Inc., Bowie, Maryland, for uniform and equipment issuance and laundry services at the Federal Law Enforcement Training Centers in Glynco, Georgia.
Ardmore argued that the agency failed to conduct meaningful discussions, improperly evaluated its proposal and made an unreasonable best-value determination.
In its July 23 decision, GAO found
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WASHINGTON, Aug. 18 -- The Government Accountability Office has denied in part and dismissed in part a protest by Ardmore Consulting Group Inc., Atlanta, Georgia, challenging the U.S. Department of Homeland Security's award of a contract to T47 International Inc., Bowie, Maryland, for uniform and equipment issuance and laundry services at the Federal Law Enforcement Training Centers in Glynco, Georgia.
Ardmore argued that the agency failed to conduct meaningful discussions, improperly evaluated its proposal and made an unreasonable best-value determination.
In its July 23 decision, GAO foundthat the agency's communications with Ardmore after issuing a revised wage determination constituted clarifications rather than discussions. The agency had asked Ardmore to provide a teaming agreement, identify the division of work with its subcontractor and update its pricing to reflect the revised wage determination.
GAO said the communications did not involve bargaining, persuasion, negotiations or attempts to alter the company's position. Therefore, the agency was not required to advise Ardmore that its price proposal was unacceptable.
GAO also rejected Ardmore's challenge to the evaluation of its price proposal. The solicitation required offerors to provide a detailed breakdown of costs, including other direct costs and overhead, and warned that failure to comply could result in a proposal being deemed unacceptable.
Ardmore's proposal did not provide all of the required cost information. The agency determined that the omissions created uncertainty about whether the proposed price accounted for indirect business expenses and future cost increases and concluded that the proposal was unacceptable for award.
GAO found the agency's evaluation reasonable and consistent with the solicitation. Because Ardmore's proposal was properly determined to be unacceptable, GAO also dismissed the company's remaining challenges to the evaluation of its non-price factors and the best-value tradeoff, finding that Ardmore was no longer an interested party eligible to pursue those allegations.
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Primary source of information - GAO: https://www.gao.gov/products/b-423916.2%2Cb-423916.3
Publicly Released on: Aug. 4, 2026. Published: July 23, 2026.
Aron C. Beezley, Esq., Patrick R. Quigley, Esq., Elizabeth A. Brown, Esq., and Winni Zhang, Esq., Bradley Arant Boult Cummings LLP, for the protester.
Maxwell S. Smart, Esq., Department of Homeland Security, for the agency.
Glenn G. Wolcott, Esq., and April Y. Shields, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Absolute Strategic Technologies Protest Over Air Force REMIS Task Order Award
By Marlyn T. Vitin
WASHINGTON, Aug. 18 -- WASHINGTON -- The Government Accountability Office has denied in part and dismissed in part a protest filed by Absolute Strategic Technologies (AST) LLC, Southlake, Texas, challenging the U.S. Air Force's award of a task order for Reliability and Maintainability Information System (REMIS) support services to Concept Plus LLC, Fairfax, Virginia.
In a decision issued June 18, GAO found that the Air Force reasonably evaluated proposals and properly selected Concept Plus under a best-value competition conducted through the Small Business Enterprise Applications Solutions (SBEAS)
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WASHINGTON, Aug. 18 -- WASHINGTON -- The Government Accountability Office has denied in part and dismissed in part a protest filed by Absolute Strategic Technologies (AST) LLC, Southlake, Texas, challenging the U.S. Air Force's award of a task order for Reliability and Maintainability Information System (REMIS) support services to Concept Plus LLC, Fairfax, Virginia.
In a decision issued June 18, GAO found that the Air Force reasonably evaluated proposals and properly selected Concept Plus under a best-value competition conducted through the Small Business Enterprise Applications Solutions (SBEAS)contract vehicle.
The REMIS contract supports a web-based system used to collect and manage maintenance and operational data for Air Force weapon systems.
AST argued that the Air Force failed to credit its proposal with additional technical strengths, improperly evaluated Concept Plus's proposal, failed to conduct a price realism analysis of fixed-price contract line items, treated offerors unequally, and conducted an unreasonable best-value tradeoff.
GAO rejected those arguments.
The decision found that the solicitation did not require the agency to perform a price realism analysis for firm-fixed-price portions of the contract, noting that cost realism reviews applied only to cost-plus-fixed-fee line items. GAO also concluded that the Air Force reasonably assessed Concept Plus's costs as realistic using government estimates and labor-rate comparisons.
Both AST and Concept Plus received "outstanding" ratings under the staffing approach subfactor. AST earned a strength for proposing a workforce with a high proportion of senior personnel, while Concept Plus received a strength for proposing a dedicated team focused on addressing "technical debt," or deferred software and system maintenance issues.
GAO agreed with the Air Force that Concept Plus's dedicated technical debt team provided a unique benefit not matched by AST's proposal, rejecting claims of unequal treatment.
The watchdog also found no merit in AST's contention that its status as part of the incumbent team warranted additional strengths, reiterating that agencies are not required to give incumbents extra credit.
Finally, GAO upheld the Air Force's best-value determination, concluding that Concept Plus's lower evaluated price of $54.4 million offered greater value than AST's $62.5 million proposal when combined with its technical approach.
The protest was denied in part and dismissed in part.
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Primary source of information - GAO: https://www.gao.gov/products/b-424321.2%2Cb-424321.3
Publicly Released on: July 13, 2026. Published: June 18, 2026.
Gregory S. Jacobs, Esq., Erin L. Felix, Esq., Daniel H. Petkoff, Esq., and Eyasu Yirdaw, Esq., Polsinelli PC, for the protester.
Olivia L. Lynch, Esq., Cherie J. Owen, Esq., William B. O'Reilly, Esq., and Adina B. Nelson, Esq., Crowell & Moring LLP, for Concept Plus, LLC, the intervenor.
Col. Justin A. Silverman, Michael J. Farr, Esq., Matney E. Rolfe, Esq., Geoffrey R. Townsend, Esq., Lindsey A. Rasmussen, Esq., and Erika Whelan Retta, Esq., Department of the Air Force, for the agency.
Glenn G. Wolcott, Esq., and April Y. Shields, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies GSINA-Pacific Protest Against Army Corps Construction Contract Competition
By Marlyn T. Vitin
WASHINGTON, July 27 -- The Government Accountability Office has denied a protest filed by GSINA-Pacific JV II LLC, Flemington, New Jersey, challenging the U.S. Army Corps of Engineers' evaluation of its proposal and exclusion from the next phase of a major construction contract competition.
The procurement sought up to six multiple-award indefinite-delivery contracts with a combined value of as much as $699 million for design-build and design-bid-build construction services supporting military petroleum, oil and lubricants infrastructure projects across the United States, Alaska, Hawaii and other
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WASHINGTON, July 27 -- The Government Accountability Office has denied a protest filed by GSINA-Pacific JV II LLC, Flemington, New Jersey, challenging the U.S. Army Corps of Engineers' evaluation of its proposal and exclusion from the next phase of a major construction contract competition.
The procurement sought up to six multiple-award indefinite-delivery contracts with a combined value of as much as $699 million for design-build and design-bid-build construction services supporting military petroleum, oil and lubricants infrastructure projects across the United States, Alaska, Hawaii and otheroutlying areas.
GSINA-Pacific, a joint venture between GSI North America Inc. and GSI Pacific Inc., alleged that the Army Corps arbitrarily evaluated its phase-one proposal, improperly assessed the relevance of its past performance projects, and treated its proposal differently from those of competing offerors.
The GAO found that the agency's evaluation was reasonable and consistent with the solicitation. Evaluators reviewed four past performance references submitted by GSINA-Pacific and determined that one project was "very relevant," two were "relevant," and one was "somewhat relevant." The agency ultimately assigned the proposal a "limited confidence" rating, indicating a low expectation that the company would successfully perform the required work.
A central dispute involved whether several of GSINA-Pacific's prior projects demonstrated experience in tank rehabilitation and tank cleaning. The watchdog concluded that while the company's proposal identified those capabilities, the underlying project descriptions did not adequately show that such work had actually been performed. The decision emphasized that offerors bear the responsibility for submitting proposals with sufficient detail for agencies to evaluate compliance with solicitation requirements.
The GAO also rejected claims that the Army Corps used unstated evaluation criteria or engaged in disparate treatment when comparing GSINA-Pacific's proposal with those submitted by Dawson Federal Inc. and Goshawk LLC. According to the decision, the competing projects were not substantively indistinguishable, and the agency documented meaningful differences in scope, complexity and prior performance.
Under the program management and technical approach factor, GSINA-Pacific received an "acceptable" rating based on one identified strength and one weakness. The watchdog found no competitive prejudice even if the challenged weakness had been removed, because the selected offerors received stronger overall ratings.
The Army Corps invited seven firms to submit phase-two proposals, while GSINA-Pacific was excluded from further consideration. The protest was denied in full.
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Primary source of information - GAO: https://www.gao.gov/products/b-424314.2
Publicly Released on: July 8, 2026. Published: June 18, 2026.
Kate H. Kennedy, Esq., Jonathan A. DeMella, Esq., and Matthew Gurr, Esq., Davis Wright Tremaine LLP, for the protester.
Matthew R. Keiser, Esq., and Stacy K. Birkel, Esq., Department of the Army, for the agency.
Paula A. Williams, Esq., and Evan D. Wesser, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Weston Solutions, Tetra Tech Protests Over Army Corps Contract Award to Pond Constructors
By Marlyn T. Vitin
WASHINGTON, July 15 -- The Government Accountability Office has denied protests by Weston Solutions Inc., West Chester, Pennsylvania, and Tetra Tech Inc., Collinsville, Illinois, challenging the U.S. Army Corps of Engineers' award of a maintenance services contract to Pond Constructors Inc., Peachtree Corners, Georgia, in support of the Defense Logistics Agency.
The contract covers preventive and corrective maintenance for fuel program facilities throughout the Corps' South Atlantic Division, including sites in North Carolina, South Carolina, Georgia, Florida, Alabama, Mississippi, Puerto Rico
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WASHINGTON, July 15 -- The Government Accountability Office has denied protests by Weston Solutions Inc., West Chester, Pennsylvania, and Tetra Tech Inc., Collinsville, Illinois, challenging the U.S. Army Corps of Engineers' award of a maintenance services contract to Pond Constructors Inc., Peachtree Corners, Georgia, in support of the Defense Logistics Agency.
The contract covers preventive and corrective maintenance for fuel program facilities throughout the Corps' South Atlantic Division, including sites in North Carolina, South Carolina, Georgia, Florida, Alabama, Mississippi, Puerto Ricoand the U.S. Virgin Islands. The procurement called for a fixed-price contract with a one-year base period and two one-year option periods.
Four companies submitted proposals. Pond received ratings of "good" for technical approach, "substantial confidence" for past performance and "outstanding" for small business participation, with a proposed price of about $49.99 million. Weston earned an "acceptable" technical rating and proposed approximately $50.28 million, while Tetra Tech received an "outstanding" technical rating, a "satisfactory confidence" past performance rating and proposed about $50.46 million.
Weston challenged the Corps' assessment of a technical weakness and argued that evaluators failed to credit several strengths in its proposal, including its incumbent workforce. Tetra Tech argued that Pond's technical proposal and past performance were improperly evaluated and that the agency made an unreasonable best-value determination.
GAO rejected all of the allegations.
The decision found that the Corps reasonably assigned Weston a weakness after concluding its proposal appeared to rely on an incorrect service-order process for certain corrective maintenance work. GAO also agreed that the agency was not required to award additional strengths simply because Weston proposed experienced incumbent personnel, noting that proposals must clearly demonstrate features exceeding solicitation requirements.
GAO also upheld the evaluation of Pond's proposal, concluding the agency reasonably credited the firm's network of nine branch offices and other technical advantages. The watchdog found no evidence that the Corps improperly evaluated Pond's past performance or overlooked relevant information.
The decision further upheld the source selection authority's independent assessment that Pond's proposal offered the best overall value. Although Tetra Tech received a higher adjectival technical rating, the source selection authority reasonably determined that Pond's technical strengths were more valuable to the government, while Pond also offered stronger past performance, an equivalent small business participation rating and the lowest overall price.
Finding the evaluation and best-value tradeoff consistent with the solicitation and procurement regulations, GAO denied both protests.
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Primary source of information - GAO: https://www.gao.gov/products/b-424322%2Cb-424322.3%2Cb-424322.2%2Cb-424322.4
Publicly Released on: July 7, 2026 Published: June 18, 2026
John G. Horan, Esq., Faegre Drinker Biddle & Reath LLP, for Weston Solutions, Inc.; and Holly A. Roth, Esq., John M. McAdams III, Esq., and Ben R. Smith, Esq., Holland & Knight LLP, for Tetra Tech, Inc., the protesters.
Damien C. Specht, Esq., James A. Tucker, Esq., and Victoria Dalcourt Angle, Esq., Morrison & Foerster LLP, for Pond Constructors, Inc., the intervenor.
Allen Scott Black, Esq., United States Army, 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 Denies Strategic Alliance Business Group Protest Over NASA Contract Competition
By Marlyn T. Vitin
WASHINGTON, July 15 -- The Government Accountability Office has denied a protest by Strategic Alliance Business Group LLC, Fairfax, Virginia, challenging its elimination from a NASA competition for a government-wide information technology services contract valued at up to $20 billion.
The protest involved NASA's sixth-generation Solutions for Enterprise-Wide Procurement (SEWP VI) contract vehicle, which will provide information technology products, cloud solutions, cybersecurity, audiovisual services and related support through multiple indefinite-delivery, indefinite-quantity contracts with a
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WASHINGTON, July 15 -- The Government Accountability Office has denied a protest by Strategic Alliance Business Group LLC, Fairfax, Virginia, challenging its elimination from a NASA competition for a government-wide information technology services contract valued at up to $20 billion.
The protest involved NASA's sixth-generation Solutions for Enterprise-Wide Procurement (SEWP VI) contract vehicle, which will provide information technology products, cloud solutions, cybersecurity, audiovisual services and related support through multiple indefinite-delivery, indefinite-quantity contracts with a10-year ordering period.
Strategic Alliance Business Group submitted proposals for two contract categories covering enterprise-wide and mission-based IT services. NASA removed both proposals from consideration after determining that the company failed to include either a required Cybersecurity Supply Chain Risk Management (C-SCRM) attestation form or an Open Trusted Technology Provider Standard certification, both of which the solicitation identified as mandatory.
The company argued that its management approach narrative sufficiently demonstrated its cybersecurity supply chain capabilities and that NASA should have sought clarifications regarding the omitted documentation rather than eliminating its proposals.
GAO rejected both arguments.
The decision found that the solicitation expressly required offerors to submit either the C-SCRM attestation form or the certification and warned that failure to respond to all required proposal elements would render an offeror ineligible for award. GAO noted that Strategic acknowledged it had inadvertently failed to include the required attestation form.
According to GAO, while the company's proposal discussed its corporate cybersecurity processes, it did not provide the specific attestations required by the solicitation regarding compliance with 15 supply chain risk management and information security controls.
GAO emphasized that offerors bear the responsibility for submitting proposals that contain all information required by a solicitation and that agencies may reasonably reject proposals that omit mandatory documentation.
The watchdog also concluded that NASA was not obligated to request clarifications. Under federal procurement rules, clarifications are discretionary and may not be used to remedy material proposal omissions or deficiencies. Allowing Strategic to submit the missing attestation after proposals were received would have constituted a material revision rather than a permissible clarification, GAO said.
Finding NASA's evaluation consistent with the solicitation and procurement regulations, GAO denied the protest.
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Primary source of information - GAO: https://www.gao.gov/products/b-423306.19
Publicly Released on: July 2, 2026 Published: July 2, 2026
Christopher R. Shiplett, Esq., Randolph Law, PLLC, for the protester.
Jennifer L. Howard, Esq., and Stephen T. O'Neal, Esq., National Aeronautics and Space Administration, 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 Denies Rockville's FCN Reconsideration Request in IRS Procurement Protest
By Marlyn T. Vitin
WASHINGTON, July 15 -- The Government Accountability Office has denied a request by FCN Inc., Rockville, Maryland, to reconsider a prior decision rejecting the company's protest over a U.S. Department of the Treasury Internal Revenue Service solicitation for enterprise virtualization and cloud platform services.
The reconsideration request stemmed from GAO's May 13 decision, which upheld the terms of a request for quotations seeking a contractor to replace the Internal Revenue Service's existing VMware-based virtualization environment with the Nutanix Cloud Platform or an equivalent alternative.
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WASHINGTON, July 15 -- The Government Accountability Office has denied a request by FCN Inc., Rockville, Maryland, to reconsider a prior decision rejecting the company's protest over a U.S. Department of the Treasury Internal Revenue Service solicitation for enterprise virtualization and cloud platform services.
The reconsideration request stemmed from GAO's May 13 decision, which upheld the terms of a request for quotations seeking a contractor to replace the Internal Revenue Service's existing VMware-based virtualization environment with the Nutanix Cloud Platform or an equivalent alternative.The contract covers the migration of about 10,000 virtual machines and ongoing platform support.
FCN argued that GAO had improperly dismissed one of its protest allegations as untimely. Specifically, the company contended that the solicitation failed to provide sufficient technical or salient characteristics for certain Nutanix products listed in the bill of materials, making it unclear what would qualify as an equivalent product.
GAO rejected that argument, concluding that FCN had not raised the alleged ambiguity in its original protest before the solicitation deadline, as required by the agency's bid protest regulations.
According to the decision, FCN's initial protest focused on claims that the solicitation was unduly restrictive because it favored Nutanix products and effectively created a sole-source procurement. While the company referenced the listing of Nutanix model numbers without detailed specifications, GAO found that those references supported its competition-related arguments rather than constituting a separate challenge that the solicitation itself was ambiguous.
GAO also rejected FCN's assertion that the Internal Revenue Service had understood and responded to the alleged ambiguity during the original protest. Instead, the agency's report addressed only FCN's claims that the solicitation was overly restrictive and improperly favored Nutanix, GAO said.
The decision emphasized that bid protesters must clearly identify each protest ground in their initial filings and cannot introduce new solicitation challenges later through comments. Allowing otherwise would undermine the requirement that challenges to apparent solicitation defects be filed before proposals are due and would hinder the efficient resolution of bid protests.
GAO therefore found no factual or legal error in its earlier decision and denied FCN's request for reconsideration.
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Primary source of information - GAO: https://www.gao.gov/products/b-424249.2
Publicly Released on: June 26, 2026 Published: June 15, 2026
Paul F. Khoury, Esq., George E. Petel, Esq., W. Benjamin Phillips III, Esq., and Nicholas T. Iliff, Jr., Esq., Wiley Rein LLP, for the protester.
Nickolas S. Card, Esq., Justin M. Wakefield, Esq., and Richard L. Hatfield, Esq., Department of the Treasury, 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 Stondoh LLC Protest Over Labor Dept. Award to WINTrio
By Marlyn T. Vitin
WASHINGTON, July 15 -- The Government Accountability Office has denied a protest by Stondoh LLC, Baltimore, Maryland, challenging the U.S. Department of Labor's decision to award a task order to WINTrio LLC, Leesburg, Virginia, for security assessment and validation services supporting federal information systems.
The procurement sought professional security control assessor and plan of action and milestones validation services under a small business set-aside solicitation. The contract includes a one-year base period and four one-year option periods and was competed under the Federal Supply Schedule.
The
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WASHINGTON, July 15 -- The Government Accountability Office has denied a protest by Stondoh LLC, Baltimore, Maryland, challenging the U.S. Department of Labor's decision to award a task order to WINTrio LLC, Leesburg, Virginia, for security assessment and validation services supporting federal information systems.
The procurement sought professional security control assessor and plan of action and milestones validation services under a small business set-aside solicitation. The contract includes a one-year base period and four one-year option periods and was competed under the Federal Supply Schedule.
TheDepartment of Labor received 26 quotations and evaluated them based on technical merit and price, with technical factors carrying significantly greater weight.
Stondoh received an "outstanding" technical rating and proposed a price of $979,800. WINTrio earned a "good" technical rating but submitted a substantially lower price of $550,276, slightly below the government's independent cost estimate of about $560,000.
Stondoh argued that the agency's best-value determination improperly discounted the advantages of its technically superior quotation and relied almost entirely on the significant price difference between the two vendors.
GAO disagreed, finding that the record showed the contracting officer, who also served as the source selection authority, thoroughly considered the strengths and weaknesses of both quotations before concluding that WINTrio offered the best value.
The decision noted that evaluators identified nine significant strengths and no weaknesses in Stondoh's quotation, while WINTrio received nine strengths but also six weaknesses. Despite recognizing Stondoh's superior technical approach, the source selection authority determined that its technical advantages did not justify paying a price approximately 75 percent higher than WINTrio's offer and the government's cost estimate.
GAO said the source selection authority documented the comparison in detail, including Stondoh's willingness to exceed solicitation requirements and WINTrio's mature management approach, while also acknowledging weaknesses in WINTrio's continuous monitoring and risk prioritization.
The watchdog concluded that the Department of Labor reasonably balanced technical merit against price in accordance with the solicitation's evaluation criteria. It emphasized that agencies may properly select a lower-priced, lower-rated quotation when they reasonably determine that the higher-rated proposal's additional technical benefits are not worth the price premium.
Finding the best-value tradeoff rational, well documented and consistent with procurement regulations, GAO denied Stondoh's protest.
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Primary source of information - GAO: https://www.gao.gov/products/b-424439
Publicly Released on: July 7, 2026 Published: July 6, 2026
LaTonya Hall for the protester.
Jonathan Heinz, Esq., Department of Labor, 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 Denies Oready Protest Over GPO Printing Contract
By Marlyn T. Vitin
WASHINGTON, July 15 -- The Government Accountability Office has denied a protest by Oready LLC, Las Vegas, Nevada, challenging the Government Publishing Office's determination that the company was not responsible to perform a contract for printing U.S. Department of the Treasury Internal Revenue Service manuals.
The procurement sought a single-award contract with a base period through May 31, 2027, and four one-year option periods. The work required the contractor to print IRS internal revenue manuals and perform related publishing, printing, binding, packing and distribution services. Because
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WASHINGTON, July 15 -- The Government Accountability Office has denied a protest by Oready LLC, Las Vegas, Nevada, challenging the Government Publishing Office's determination that the company was not responsible to perform a contract for printing U.S. Department of the Treasury Internal Revenue Service manuals.
The procurement sought a single-award contract with a base period through May 31, 2027, and four one-year option periods. The work required the contractor to print IRS internal revenue manuals and perform related publishing, printing, binding, packing and distribution services. Becausethe manuals contain sensitive but unclassified and personally identifiable information, the solicitation required detailed pre-award plans covering quality control, security and waste disposal.
After determining that Oready had submitted the lowest-priced bid, the Government Publishing Office requested the firm's pre-award production plans to assess its responsibility. Following reviews by both the IRS and the agency's quality control staff, officials identified multiple concerns, including incomplete security measures, insufficient production details and questions about whether the company's equipment could meet the contract's quality requirements.
The agency requested additional information and revised plans, but concluded that Oready still failed to provide adequate documentation. The contracting officer also found that the company had not demonstrated its ability to meet the required Quality Level IV printing standard because it neither submitted printing samples for evaluation nor provided evidence of comparable past performance.
Oready argued that it had submitted all plans required by the solicitation and contended that the Government Publishing Office improperly imposed additional, unstated requirements during the responsibility review.
GAO rejected those arguments, finding that the contracting officer reasonably exercised broad discretion in evaluating the firm's responsibility. The decision noted that agencies may request additional evidence of a bidder's technical and production capabilities when determining responsibility, as expressly permitted by the solicitation.
GAO also found that the agency repeatedly informed Oready of deficiencies in its submissions and gave the company an opportunity to provide additional information. However, the record showed that Oready declined to furnish some requested documentation, including certain facility and production details, while agency evaluators continued to question whether its proposed equipment could perform the required work.
The watchdog concluded that the Government Publishing Office's nonresponsibility determination was supported by the record and had a reasonable basis. Finding no evidence that the contracting officer abused her discretion or acted in bad faith, GAO denied the protest.
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Primary source of information - GAO: https://www.gao.gov/products/b-424375
Publicly Released on: July 7, 2026 Published: July 6, 2026
Mike Farro for the protester.
Nicole Goldstein, Esq., and James Goodman III, Esq., Government Publishing Office, for the agency.
Kasia Dourney, Esq., and Alexander O. Levine, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
DarkStar Intelligence Protest Against Air Force Award to Starlo Innovation Denied by GAO
By Marlyn T. Vitin
WASHINGTON, June 27 -- The Government Accountability Office has denied a protest filed by DarkStar Intelligence LLC, Woodbridge, Virginia, challenging the U.S. Air Force's award of a task order to Starlo Innovation LLC for intelligence and operational support services.
The procurement, issued as a small business set-aside under the General Services Administration's OASIS+ contract vehicle, sought contractor support for the Narcotics and Transnational Crime Support Center, which assists the Department of Defense and law enforcement agencies in combating drug trafficking, terrorism and transnational
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WASHINGTON, June 27 -- The Government Accountability Office has denied a protest filed by DarkStar Intelligence LLC, Woodbridge, Virginia, challenging the U.S. Air Force's award of a task order to Starlo Innovation LLC for intelligence and operational support services.
The procurement, issued as a small business set-aside under the General Services Administration's OASIS+ contract vehicle, sought contractor support for the Narcotics and Transnational Crime Support Center, which assists the Department of Defense and law enforcement agencies in combating drug trafficking, terrorism and transnationalorganized crime.
DarkStar argued that the Air Force unreasonably evaluated its proposal, relied on unstated evaluation criteria, and failed to properly consider price in its best-value tradeoff decision.
GAO rejected those claims, finding the agency's evaluation was reasonable and consistent with the solicitation. The watchdog concluded the Air Force reasonably assigned DarkStar's proposal a "good" rating under the technical approach and mission understanding factor because evaluators found its proposal demonstrated a thorough understanding of the requirements but lacked the deeper, partner-focused understanding of law enforcement organizations sought by the solicitation. That shortcoming led evaluators to identify a low-to-moderate performance risk stemming from the potential need for additional government oversight.
GAO also dismissed DarkStar's claim that the agency applied unstated evaluation criteria. The decision found that the solicitation explicitly required offerors to demonstrate detailed knowledge of how law enforcement agencies' missions, structures and cultures interact with the Department of Defense. As a result, the agency's assessment of DarkStar's proposal as insufficiently partner-centric was logically encompassed within the stated evaluation criteria.
Finally, GAO rejected DarkStar's argument that the Air Force ignored price in selecting the higher-priced proposal from Starlo. DarkStar proposed a price of about $73 million, while Starlo's proposal totaled roughly $80.4 million, a premium of approximately 9%.
GAO found that the Air Force documented its consideration of both technical merit and price, concluding that Starlo's superior technical proposal and lower performance risk justified the additional cost. The decision held that the best-value tradeoff was rational, adequately documented and consistent with the solicitation's evaluation scheme.
As a result, GAO denied the protest.
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Primary source of information - GAO: https://www.gao.gov/products/b-424306
Publicly Released on: June 18, 2026 Published: June 3, 2026
Edward J. Tolchin, Esq., Offit Kurman, for the protester.
Olivia L. Lynch, Esq., Cherie J. Owen, Esq., and Adina B. Nelson, Esq., Crowell & Moring LLP, for Starlo Innovation, LLC, the intervenor.
Siobhan K. Donahue, Esq., Beatrice K. Foster, Esq., Autumn Hazy, Esq., and Erika Whelan Retta, 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.
