GAO Bid Protests
Here's a look at news stories involving federal bid protest decisions issued by the GAO General Counsel
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GAO Denies Rockville Firm's Protest Over TSA Audit Support Task Order Award to Leesburg Contractor
By Marlyn T. Vitin
WASHINGTON, May 22 -- The Government Accountability Office has denied a bid protest filed by TFC Consulting Inc., Rockville, Maryland, challenging the award of a U.S. Department of Homeland Security Transportation Security Administration task order to Centennial Technologies Inc., Leesburg, Virginia, for financial statement audit liaison and internal control support services.
The procurement was conducted by the Transportation Security Administration under a small business set-aside using the General Services Administration's Federal Supply Schedule program. The task order covers risk management,
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WASHINGTON, May 22 -- The Government Accountability Office has denied a bid protest filed by TFC Consulting Inc., Rockville, Maryland, challenging the award of a U.S. Department of Homeland Security Transportation Security Administration task order to Centennial Technologies Inc., Leesburg, Virginia, for financial statement audit liaison and internal control support services.
The procurement was conducted by the Transportation Security Administration under a small business set-aside using the General Services Administration's Federal Supply Schedule program. The task order covers risk management,audit oversight and internal control support services for TSA business processes and information technology systems.
According to the decision released by the Government Accountability Office, TSA evaluated quotations in two phases and ultimately concluded that Centennial offered the best overall value, combining stronger technical advantages with a lower price.
Centennial submitted a quotation priced at about $8.26 million, while TFC's proposal totaled roughly $9.89 million. Both firms received "high confidence" ratings for technical scenarios and project management plans, along with "acceptable" past performance ratings.
TFC argued that TSA improperly assigned Centennial the highest technical rating despite the company not being the incumbent contractor. The protester contended that a non-incumbent vendor would require greater government intervention during transition and management control implementation activities.
GAO rejected those arguments, finding the agency reasonably concluded Centennial proposed a detailed transition plan and innovative approaches that demonstrated a strong understanding of TSA requirements. The decision noted evaluators credited Centennial for proposing scalable management control processes, automation tools and emerging technology solutions intended to reduce redundancy and improve efficiency.
TFC also challenged TSA's evaluation of past performance, arguing the agency ignored stronger and more relevant contractor performance records. GAO found the agency reasonably relied on selected Contractor Performance Assessment Reporting System reports that reflected highly rated work similar in scope to the solicitation requirements.
In addition, GAO dismissed claims that the agency's best-value tradeoff was flawed or involved disparate treatment. The watchdog concluded TSA reasonably determined Centennial's quotation offered greater technical benefits at a significantly lower cost to the government.
The protest was denied in full.
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Primary source of information - GAO: https://www.gao.gov/products/b-423996
Publicly Released on: May 19, 2026 Published: Feb. 6, 2026
Victor A. Kubli, Esq., Law Office of Victor A. Kubli, P.C., for the protester.
Matthew R. Keller, Esq., Praemia Law, PLLC, for Centennial Technologies, Inc., the intervenor.
Christopher J. Curry, Esq., and Michael D. Kiffney, Esq., Department of Homeland Security, for the agency.
Uri R. Yoo, Esq., and Alexander O. Levine, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies E-Logic Protest Over NASA SEWP VI Proposal Elimination
By Marlyn T. Vitin
WASHINGTON, May 22 -- The Government Accountability Office denied a protest filed by E-Logic Inc. challenging its removal from a major NASA procurement for government-wide information technology products and services.
The protest concerned NASA's sixth-generation Solutions for Enterprise-Wide Procurement contract vehicle, known as SEWP VI, a multiple-award indefinite-delivery, indefinite-quantity program with a maximum ordering value of $20 billion. The procurement covers IT products, cloud solutions, cybersecurity, and related services.
E-Logic argued that NASA improperly eliminated its proposal
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WASHINGTON, May 22 -- The Government Accountability Office denied a protest filed by E-Logic Inc. challenging its removal from a major NASA procurement for government-wide information technology products and services.
The protest concerned NASA's sixth-generation Solutions for Enterprise-Wide Procurement contract vehicle, known as SEWP VI, a multiple-award indefinite-delivery, indefinite-quantity program with a maximum ordering value of $20 billion. The procurement covers IT products, cloud solutions, cybersecurity, and related services.
E-Logic argued that NASA improperly eliminated its proposalduring the first phase of the evaluation for category A, which covers IT, communications, and audiovisual service solutions. NASA determined that the company failed to satisfy solicitation requirements requiring offerors to submit at least 100 contract line item numbers, or CLINs, from an approved designated provider for each non-primary technical area.
According to the decision, E-Logic identified HP Inc. as its designated provider for two non-primary technical areas and submitted letters of authorization from HP. However, NASA found that many of the products listed in E-Logic's proposal were actually manufactured by Hewlett Packard Enterprise, a separate company.
NASA discovered the discrepancy after reviewing E-Logic's spreadsheet submissions, which identified HP in the OEM/service provider column while referencing HPE products in the description field and through product part numbers. Agency officials conducted internet research to verify the manufacturers and concluded that HPE and HP are distinct publicly traded companies.
Based on that review, NASA determined that E-Logic proposed only 97 qualifying CLINs for one technical area and only 10 for another, falling short of the solicitation's 100-CLIN minimum requirement.
E-Logic argued that NASA improperly relied on information outside the OEM/service provider column and applied an unstated evaluation criterion by reviewing descriptions and conducting internet research. The company also argued that HP and HPE products were commercially interconnected and should have been treated as reasonably attributable to HP.
GAO rejected those arguments, finding NASA's evaluation reasonable and consistent with the solicitation. The decision stated that the solicitation expressly allowed NASA to verify information contained in proposal spreadsheets and did not limit the agency's review to a single spreadsheet column.
GAO further agreed with NASA that HP and HPE are separate entities and concluded the agency reasonably eliminated E-Logic's proposal from the competition after determining it failed to meet mandatory CLIN requirements.
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Primary source of information - GAO: https://www.gao.gov/products/b-423306.13%2Cb-423306.21
Publicly Released on: May 18, 2026 Published: May 15, 2026
Luis Padilla 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 Rejects FCN Protest Over IRS Virtualization Procurement Favoring Nutanix-Based Platform
By Marlyn T. Vitin
WASHINGTON, May 22 -- The Government Accountability Office denied in part and dismissed in part a protest filed by FCN Inc., Rockville, Maryland, challenging a virtualization modernization procurement issued by the U.S. Department of the Treasury Internal Revenue Service under NASA's Solutions for Enterprise-Wide Procurement contract vehicle.
The protest involved a small business set-aside procurement for vendors holding NASA SEWP indefinite-delivery, indefinite-quantity contracts. The solicitation seeks a contractor to help the IRS migrate roughly 10,000 virtual machines from its existing VMware
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WASHINGTON, May 22 -- The Government Accountability Office denied in part and dismissed in part a protest filed by FCN Inc., Rockville, Maryland, challenging a virtualization modernization procurement issued by the U.S. Department of the Treasury Internal Revenue Service under NASA's Solutions for Enterprise-Wide Procurement contract vehicle.
The protest involved a small business set-aside procurement for vendors holding NASA SEWP indefinite-delivery, indefinite-quantity contracts. The solicitation seeks a contractor to help the IRS migrate roughly 10,000 virtual machines from its existing VMwareinfrastructure to what the agency described as a more scalable enterprise virtualization platform.
FCN argued that several solicitation requirements were overly restrictive and effectively favored products made by Nutanix, creating what the company characterized as a "de facto sole-source procurement." The Rockville-based contractor specifically challenged requirements involving shared storage pools, live hypervisor conversion without data movement, integrated disaster recovery capabilities and installation timelines requiring software configuration within seven business days of hardware delivery.
GAO rejected those arguments, finding the IRS reasonably justified each requirement as necessary to meet operational and technical needs. The decision noted the agency explained that shared storage pools would allow more flexible expansion of storage and computing resources, while live migration capabilities would minimize downtime during the virtualization transition.
GAO also accepted the IRS explanation that integrated disaster recovery software reduced compatibility risks and simplified system management during migration. In addition, the watchdog found the seven-day installation requirement aligned with the agency's need to accelerate modernization efforts and reduce costs associated with maintaining its existing virtualization environment.
The protester further contended that the solicitation improperly favored Nutanix products by referencing specific Nutanix hardware and software items in the bill of materials. GAO denied that claim as well, concluding the procurement was properly structured as a "brand name or equal" competition because vendors were permitted to propose equivalent alternatives.
However, GAO dismissed as untimely FCN's later argument that the solicitation failed to adequately explain the salient characteristics required for products proposed as equivalents to Nutanix offerings. The decision found any ambiguity regarding those characteristics was apparent from the face of the solicitation and should have been challenged before the quotation deadline.
The protest decision leaves the IRS free to proceed with the procurement for the virtualization modernization initiative.
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Primary source of information - GAO: https://www.gao.gov/products/b-424249
Publicly Released on: May 18, 2026 Published: May 13, 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.
Glenn G. Wolcott, Esq., and April Y. Shields, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Sustains N&S Property Services Protest Over ICE Contract Award to KCorp Reliance
By Marlyn T. Vitin
WASHINGTON, May 22 -- The Government Accountability Office sustained a bid protest filed by N&S Property Services LLC, Atlanta, Georgia, challenging the award of a facilities operations and maintenance contract to KCorp Reliance Co. Inc., Wasilla, Alaska, under a procurement issued by U.S. Department of Homeland Security Immigration and Customs Enforcement for services at Fort Benning.
In a March 10, 2026, decision, the GAO found that ICE improperly evaluated both companies' technical proposals and relied on unsupported conclusions in selecting KCorp for award.
The procurement, issued as an 8(a)
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WASHINGTON, May 22 -- The Government Accountability Office sustained a bid protest filed by N&S Property Services LLC, Atlanta, Georgia, challenging the award of a facilities operations and maintenance contract to KCorp Reliance Co. Inc., Wasilla, Alaska, under a procurement issued by U.S. Department of Homeland Security Immigration and Customs Enforcement for services at Fort Benning.
In a March 10, 2026, decision, the GAO found that ICE improperly evaluated both companies' technical proposals and relied on unsupported conclusions in selecting KCorp for award.
The procurement, issued as an 8(a)small business set-aside, sought facility operations and maintenance support for ICE's Office of Firearms and Training Program at Fort Benning. The contract included fixed-price and time-and-material components with a one-year base period and four option years.
After reevaluating proposals during corrective action from an earlier protest, ICE rated N&S's proposal "low confidence" under the technical capability factor, while KCorp received a "some confidence" rating. N&S proposed a lower total evaluated price of about $25.7 million compared with KCorp's roughly $26.6 million offer.
GAO concluded that several weaknesses assigned to N&S's proposal were unreasonable and based on unstated evaluation criteria. In particular, the watchdog found flaws in ICE's criticism of N&S's proposed building operating plan approach.
The agency had faulted N&S for allegedly submitting vague information, using terms such as "coordination" and "would," and appearing to provide a draft document because of redline markings. GAO rejected those conclusions, noting that the solicitation itself required coordination with the contracting officer's representative and that the redlines reflected revisions required by solicitation amendments rather than unfinished drafting.
GAO also found unreasonable the agency's suggestion that N&S should have provided more "implementation history," ruling that the solicitation did not require offerors to demonstrate past experience in that manner.
The decision additionally criticized ICE's evaluation of KCorp's proposal. GAO said the agency failed to adequately explain why two aspects of KCorp's technical approach suddenly "raised confidence" during the reevaluation when they previously had not. The record also contained inconsistencies involving KCorp's proposed computerized maintenance management system.
Because the source selection authority relied heavily on the criticized findings in determining that KCorp's higher-priced proposal represented the best value, GAO found that N&S was competitively prejudiced.
GAO recommended that ICE reevaluate proposals, make a new source selection decision, and reimburse N&S for its protest costs and attorneys' fees.
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Primary source of information - GAO: https://www.gao.gov/products/b-423852.2%2Cb-423852.3
Publicly Released on: May 19, 2026 Published: May 19, 2026
Aron C. Beezley, Esq., Nathaniel J. Greeson, Esq., and Elizabeth A. Brown, Esq., Bradley Arant Boult Cummings LLP, for the protester.
Andrea A. Nwachukwu, Esq., Department of Homeland Security, for the agency.
Uri R. Yoo, Esq., and Alexander O. Levine, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies TRAX Protest Over White Sands Missile Range Support Contract
By Marlyn T. Vitin
WASHINGTON, May 22 -- The Government Accountability Office denied a protest filed by TRAX International Corp., Las Vegas, Nevada, challenging the award of a U.S. Army mission support services contract at White Sands Missile Range to Southwest Range Services LLC, Las Cruces, New Mexico.
The procurement, issued by the Department of the Army under request for proposals No. W51EW725RA003, sought engineering and operational support services for the White Sands Test Center, which conducts testing and evaluation of missile systems, countermeasures, unmanned systems and other defense technologies.
GAO
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WASHINGTON, May 22 -- The Government Accountability Office denied a protest filed by TRAX International Corp., Las Vegas, Nevada, challenging the award of a U.S. Army mission support services contract at White Sands Missile Range to Southwest Range Services LLC, Las Cruces, New Mexico.
The procurement, issued by the Department of the Army under request for proposals No. W51EW725RA003, sought engineering and operational support services for the White Sands Test Center, which conducts testing and evaluation of missile systems, countermeasures, unmanned systems and other defense technologies.
GAOrejected TRAX's allegations that the Army failed to adequately investigate an organizational conflict of interest involving Southwest Range. TRAX argued that one of Southwest Range's joint venture members was affiliated with companies producing electronic warfare and communications technologies that could potentially be tested under the contract.
GAO found the Army reasonably investigated the allegations by obtaining sworn declarations from company officials and consulting personnel at White Sands Missile Range and the Army Test and Evaluation Command. The investigation concluded that the products identified by TRAX were not tested under the incumbent contract and were unlikely to fall within the scope of the White Sands Test Center mission.
The decision stated that "the record does not contain clear evidence showing that the investigation was unreasonable."
GAO also denied TRAX's claims that the Army improperly evaluated proposals under the mission capability and past performance factors.
The Army rated both offerors "Outstanding" under mission capability and "Substantial Confidence" for past performance. Southwest Range received higher ratings under the continuity of operations subfactor and was found technically superior overall despite proposing a higher evaluated cost.
According to the source selection decision, Southwest Range proposed a total evaluated cost of about $449.4 million, compared with approximately $420 million for TRAX. The Army concluded the technical advantages justified the 6.5 percent price premium.
GAO acknowledged the Army mistakenly assigned one weakness to TRAX's proposal under the continuity of operations subfactor, but found the error non-prejudicial because the source selection authority did not rely on that weakness in making the award decision.
The protest decision was issued May 14, 2026, under docket numbers B-424271, B-424271.2 and B-424271.3.
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Primary source of information - GAO: https://www.gao.gov/products/b-424271%2Cb-424271.2%2Cb-424271.3
Publicly Released on: May 20, 2026 Published: May 14, 2026
Daniel P. Graham, Esq., Tara L. Ward, Esq., and Emily Fallin, Esq., McDermott Will & Schulte LLP, for the protester.
Craig A. Holman, Esq., Stuart W. Turner, Esq., Thomas A. Pettit, Esq., and Kristina Lorch, Esq., Arnold & Porter Kaye Scholer LLP, for Southwest Range Services, LLC, the intervenor.
Major Joshua A. Reyes, Lieutenant Colonel Susan Kim, and Robert B. Neill, Esq., 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.
