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 Strategic Communications Protest Over NASA Information Technology Contract Competition
By Marlyn T. Vitin
WASHINGTON, June 3 -- The Government Accountability Office has denied a protest filed by Strategic Communications LLC, Louisville, Kentucky, challenging its exclusion from a major NASA competition for information technology products, cloud services, cybersecurity solutions and related support.
The procurement involves NASA's sixth-generation Solutions for Enterprise-Wide Procurement contract vehicle, a governmentwide acquisition program with a maximum ordering value of $20 billion over a 10-year period. NASA planned to award multiple contracts without discussions to qualifying offerors.
Strategic
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WASHINGTON, June 3 -- The Government Accountability Office has denied a protest filed by Strategic Communications LLC, Louisville, Kentucky, challenging its exclusion from a major NASA competition for information technology products, cloud services, cybersecurity solutions and related support.
The procurement involves NASA's sixth-generation Solutions for Enterprise-Wide Procurement contract vehicle, a governmentwide acquisition program with a maximum ordering value of $20 billion over a 10-year period. NASA planned to award multiple contracts without discussions to qualifying offerors.
StrategicCommunications was competing for a category covering enterprise-wide information technology, communications and audiovisual service solutions. During the first phase of evaluations, offerors were required to demonstrate qualifying past performance by submitting four relevant experience projects. Each project had to be ongoing or completed within three years of the solicitation's release and have a value of at least $30 million.
NASA found that one of Strategic's four submitted projects failed to meet the minimum value requirement. The company's proposal identified a project for the Defense Health Agency and described it as a task order valued at $250 million. However, when contracting officials reviewed publicly available contract data to verify what appeared to be an error in the project's performance dates, they found the listed order carried a value of approximately $5 million rather than $250 million.
Because the order fell below the solicitation's $30 million threshold, NASA concluded that Strategic had submitted only three qualifying projects instead of the required four and removed the proposal from further consideration.
After receiving notice of its elimination, Strategic argued that the project was not merely a task order but part of a Defense Health Agency catalog with a ceiling value of $250 million. The company maintained that the catalog functioned similarly to a single-award blanket purchase agreement and therefore satisfied the solicitation's requirements.
The GAO rejected that argument, finding that the proposal itself repeatedly identified the project as a task order and contained no indication that it was part of a larger catalog vehicle. The decision noted that the term "catalog" did not appear anywhere in the submission and that the additional explanation was provided only after NASA had completed its evaluation.
The watchdog concluded that offerors bear the responsibility for submitting adequately written proposals containing all required information. Finding NASA's evaluation reasonable and consistent with the solicitation, the GAO denied the protest.
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Primary source of information - GAO: https://www.gao.gov/products/b-423306.18
Publicly Released on: May 28, 2026 Published: May 12, 2026
John L. Holtz, Esq., Shane J. McCall, Esq., Nicole D. Pottroff, Esq., Gregory P. Weber, Esq., and Annie E. Birney, Esq., Koprince Mccall Pottroff LLC, for the protester.
Jennifer L. Howard, Esq., and Stephen T. O'Neal, Esq., National Aeronautics and Space Administration, for the agency.
Sarah T. Zaffina, Esq., and Heather Weiner, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Soft Tech Consulting Protest Over Homeland Security Contract Evaluation
By Marlyn T. Vitin
WASHINGTON, June 3 -- The Government Accountability Office has denied a protest filed by Soft Tech Consulting Inc., Chantilly, Virginia, which challenged its elimination from a U.S. Department of Homeland Security competition for information technology support services.
The procurement, conducted by the U.S. Citizenship and Immigration Services, sought outcome-based delivery, development, and security operations services for the agency's Office of Information Technology. The solicitation was reserved for small businesses holding contracts under the General Services Administration's federal supply
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WASHINGTON, June 3 -- The Government Accountability Office has denied a protest filed by Soft Tech Consulting Inc., Chantilly, Virginia, which challenged its elimination from a U.S. Department of Homeland Security competition for information technology support services.
The procurement, conducted by the U.S. Citizenship and Immigration Services, sought outcome-based delivery, development, and security operations services for the agency's Office of Information Technology. The solicitation was reserved for small businesses holding contracts under the General Services Administration's federal supplyschedule program.
Soft Tech argued that the agency improperly rejected its quotation because of what it described as a minor clerical mistake in its pricing workbook. The company contended that officials should have sought clarification before removing it from the competition.
According to the decision, vendors were required to identify labor categories from their federal schedule contracts and ensure that quoted rates did not exceed approved schedule rates. The solicitation warned that vendors quoting rates above their schedule prices would be deemed noncompliant and ineligible for award.
The agency found that Soft Tech listed labor rates for a project manager position that exceeded the rate associated with the labor category identified in its schedule contract. As a result, the company's quotation was excluded before it could advance to the next phase of the competition.
Soft Tech acknowledged the discrepancy but said it stemmed from an administrative error. The company explained that it intended to propose a higher-level project manager category, which carried a higher approved schedule rate, but mistakenly referenced a lower-level category in the pricing workbook. Correcting the error, Soft Tech argued, would have required changing only a single letter designation.
The GAO rejected that argument, concluding that the agency was not required to seek clarifications. The decision noted that procurements conducted under federal supply schedule procedures do not obligate agencies to hold discussions or request clarifications from vendors regarding quotation contents.
While the solicitation stated that the government "may" engage in clarifications, the watchdog emphasized that the language granted discretion rather than creating a requirement. The office found no evidence that the agency acted unreasonably in choosing not to seek clarification from Soft Tech before excluding its quotation.
As a result, the GAO denied the protest, allowing the procurement to proceed without reinstating Soft Tech's bid.
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Primary source of information - GAO: https://www.gao.gov/products/b-424323
Publicly Released on: May 22, 2026 Published: May 15, 2026
Aron C. Beezley, Esq., Patrick R. Quigley, Esq., and Gabrielle A. Spiro, Esq., Bradley Arant Boult Cummings LLP, for the protester.
Richard W. Postma, Esq., and Jessica Easton, Esq., Department of Homeland Security, United States Citizenship and Immigration Services, for the agency.
Mary G. Curcio, Esq., and John Sorrenti, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies San Antonio Joint Venture's Bid for Protest Cost Reimbursement in Air Force Contract Dispute
By Marlyn T. Vitin
WASHINGTON, June 3 -- The Government Accountability Office has denied a request by JBW FEDITC II JV LLC, San Antonio, Texas, seeking reimbursement for the costs of pursuing protests against the U.S. Air Force over cybersecurity support work previously performed under a federal small-business contracting program.
The dispute centered on the Air Force's handling of its Information Security Support Services requirement, which had been performed under the U.S. Small Business Administration's 8(a) program. JBW alleged that portions of the work were being shifted outside the program to larger contractors,
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WASHINGTON, June 3 -- The Government Accountability Office has denied a request by JBW FEDITC II JV LLC, San Antonio, Texas, seeking reimbursement for the costs of pursuing protests against the U.S. Air Force over cybersecurity support work previously performed under a federal small-business contracting program.
The dispute centered on the Air Force's handling of its Information Security Support Services requirement, which had been performed under the U.S. Small Business Administration's 8(a) program. JBW alleged that portions of the work were being shifted outside the program to larger contractors,including Booz Allen Hamilton and Leidos.
According to the decision, JBW filed protests after learning the Air Force did not intend to pursue a direct follow-on contract for the work. The company argued that some of the services had instead been transferred through modifications to contracts held by Booz Allen Hamilton and Leidos.
The Air Force initially sought dismissal of the protests, maintaining that no follow-on contract existed and that the allegations were based on speculation. After additional document production and discussions with the Government Accountability Office, the agency announced corrective action before a revised deadline for its formal protest report.
The corrective action included terminating modifications to a Leidos contract that allegedly involved the disputed work, confirming that planned modifications to a Booz Allen Hamilton contract had not been implemented, and committing not to place the work on those contracts or any other contract without complying with 8(a) program requirements. The Air Force also pledged to determine whether the work remained necessary and, if so, either procure it through the 8(a) program or seek formal approval to remove it from that program.
The GAO dismissed the underlying protests as academic in February after concluding that the corrective measures addressed the concerns raised.
JBW later sought reimbursement of its protest costs, arguing that the Air Force delayed corrective action and forced the company to expend unnecessary resources. However, the watchdog concluded that the agency acted promptly because corrective action was initiated before the revised deadline for the agency report.
As a result, the GAO denied JBW's request for reimbursement, finding that payment of protest costs was not warranted.
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Primary source of information - GAO: https://www.gao.gov/products/b-424191.3
Publicly Released on: May 22, 2026 Published: May 15, 2026
Lucas T. Hanback, Esq., Neil H. O'Donnell, Esq., and Timothy A. Wieroniey, Esq., Rogers Joseph O'Donnell, for the protester.
Colonel Justin A. Silverman, and Siobhan K. Donahue, Esq., Department of the Air Force, for the agency.
Heather Self, Esq., and Peter H. Tran, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Metro Accounting Protest Over Air Force Task Order Award to Vector CSP
By Marlyn T. Vitin
WASHINGTON, June 3 -- The Government Accountability Office has denied a protest filed by Metro Accounting and Professional Services LLC, Goodyear, Arizona, challenging the U.S. Air Force's award of a task order to Vector CSP LLC, Elizabeth City, North Carolina, for support services related to air combat command operations.
The procurement sought specialized non-personal, knowledge-based services covering duties typically performed by military aviation personnel, including pilots and weapons systems officers. The task order was competed among small-business holders of the General Services Administration's
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WASHINGTON, June 3 -- The Government Accountability Office has denied a protest filed by Metro Accounting and Professional Services LLC, Goodyear, Arizona, challenging the U.S. Air Force's award of a task order to Vector CSP LLC, Elizabeth City, North Carolina, for support services related to air combat command operations.
The procurement sought specialized non-personal, knowledge-based services covering duties typically performed by military aviation personnel, including pilots and weapons systems officers. The task order was competed among small-business holders of the General Services Administration'sOASIS Plus contract vehicle and carried a one-year base period with four option years.
Metro argued that the Air Force improperly found its proposal ineligible for award after determining that the company failed to provide required pricing information. The Arizona firm also contended that Vector was not eligible for award because of issues related to its business status under North Carolina law.
According to the decision, offerors were required to submit a detailed price proposal, including a basis of estimate and a narrative explaining how pricing was developed. The solicitation specifically required vendors to identify the sources of pricing data, explain mathematical factors such as indirect rates, and justify any judgment-based pricing adjustments.
During its review, the Air Force concluded that Metro's proposal did not adequately explain key aspects of subcontractor pricing. The agency found that Metro failed to provide sufficient information regarding the source and rationale for one subcontractor's labor rates and did not adequately explain how subcontractors would use Metro's indirect rates.
After issuing an interchange notice seeking clarification, the Air Force determined that Metro's response still failed to satisfy the solicitation's requirements. The agency assigned the proposal a failing rating under the price factor, making it ineligible for further consideration.
The GAO agreed with the Air Force, finding that the solicitation clearly required offerors to explain the methodology supporting all pricing included in their proposals, including subcontractor pricing. The watchdog rejected Metro's argument that the requirement applied only to the prime contractor's pricing and found no ambiguity in the solicitation language.
Because Metro's proposal was properly deemed ineligible for award, the office also ruled that the company lacked standing to challenge Vector's eligibility. Even if Metro's allegations against Vector were correct, the decision noted, Metro would not have been next in line for award.
As a result, the GAO denied the protest and left the award to Vector CSP in place.
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Primary source of information - GAO: https://www.gao.gov/products/b-424317
Publicly Released on: May 26, 2026 Published: May 15, 2026
Michelle F. Kantor, Esq., and Daniel E. Schoeni, Esq., McDonald Hopkins LLC, for the protester.
J. Bradley Reaves, Esq., Kenneth M. Hyde, Esq., Jacob D. Noe, Esq., and Tariq Abdel-Wakil, Esq., Reaves GovCon Group, for Vector CSP, LLC, the intervenor.
Colonel Justin A. Silverman and Walker J. Gray, Esq., Department of the Air Force, 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 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.
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 Modifies Remedy in Effective Communication Strategies Protest Over Army Appliance Contract
By Marlyn T. Vitin
WASHINGTON, May 15 -- The Government Accountability Office has modified its recommended corrective action in a bid protest involving Effective Communication Strategies LLC, Rapid City, Michigan, and the U.S. Army after determining that the disputed contract had already been substantially completed.
The case stems from a protest filed by Effective Communication Strategies, known as ECS, challenging the Army Corps of Engineers' award of a contract to Export 220 Volt, Inc. for replacement appliances at multiple U.S. Navy installations.
In a February 2026 decision, GAO sustained ECS's protest, finding
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WASHINGTON, May 15 -- The Government Accountability Office has modified its recommended corrective action in a bid protest involving Effective Communication Strategies LLC, Rapid City, Michigan, and the U.S. Army after determining that the disputed contract had already been substantially completed.
The case stems from a protest filed by Effective Communication Strategies, known as ECS, challenging the Army Corps of Engineers' award of a contract to Export 220 Volt, Inc. for replacement appliances at multiple U.S. Navy installations.
In a February 2026 decision, GAO sustained ECS's protest, findingthat the Army failed to provide vendors sufficient time to respond to solicitation amendments and technical evaluation notices issued during the procurement process. GAO initially recommended that the agency reopen the competition, allow revised quotations, reevaluate proposals and make a new award decision.
However, both ECS and the Army later asked GAO to modify that remedy after contract performance progressed substantially. The Army said roughly 75% to 80% of the contract work had already been completed, making reopening the procurement impractical.
GAO agreed that the original corrective action was no longer feasible and granted the requests to modify the remedy.
Instead of reopening the competition, GAO recommended that the Army reimburse ECS for its quotation preparation costs in addition to the company's protest costs and attorney fees.
The watchdog agency said reimbursement was appropriate because ECS was deprived of a fair opportunity to compete due to what GAO described as the agency's "unlawful and unreasonable conduct" during the procurement.
The Army opposed reimbursing quotation preparation costs, arguing that ECS did not have a substantial chance of receiving the award and that the company should have known performance would continue because the protest was not filed within the statutory 10-day stay period.
GAO rejected those arguments, noting that the protest filing was delayed by a federal government shutdown that temporarily suspended GAO operations and disabled access to its Electronic Protest Docketing System. ECS filed its protest on the first day GAO resumed operations in November 2025.
GAO concluded that ECS demonstrated sufficient competitive prejudice because the agency's rapid issuance of amendments and revised requirements over a weekend prevented vendors from competing fairly for the Army's actual requirements.
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Primary source of information - GAO: https://www.gao.gov/products/b-423993.4%2Cb-423993.5
Publicly Released on: May 13, 2026 Published: May 13, 2026
Sarah S. Reida, Esq., Legal Meets Practical, LLC, for the protester.
Robert I. Moore, Esq., 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.
