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GAO Dismisses Oready Protests Over Bureau of Indian Education Therapy Services Solicitations
By Marlyn T. Vitin
WASHINGTON, June 27 -- The Government Accountability Office has dismissed three bid protests filed by Oready LLC, Las Vegas, Nevada, challenging the terms of solicitations issued by the U.S. Department of the Interior Bureau of Indian Education for therapy services at two schools in New Mexico.
The protests involved requests for quotations seeking commercial occupational therapist and certified occupational therapist assistant services at T'iis Ts'ozi Bi'Olta'/Crownpoint Community School in Crownpoint, New Mexico, speech-language therapy services at Tohaali Community School in Newcomb, New Mexico,
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WASHINGTON, June 27 -- The Government Accountability Office has dismissed three bid protests filed by Oready LLC, Las Vegas, Nevada, challenging the terms of solicitations issued by the U.S. Department of the Interior Bureau of Indian Education for therapy services at two schools in New Mexico.
The protests involved requests for quotations seeking commercial occupational therapist and certified occupational therapist assistant services at T'iis Ts'ozi Bi'Olta'/Crownpoint Community School in Crownpoint, New Mexico, speech-language therapy services at Tohaali Community School in Newcomb, New Mexico,and occupational therapy services at the same Tohaali school.
Oready argued that each solicitation contained requirements that unnecessarily restricted competition.
GAO dismissed all three protests as untimely, finding that although Oready submitted its protests electronically on May 15, they were filed after GAO's 5:30 p.m. Eastern Time filing deadline. Under GAO's bid protest regulations, filings received after that time are considered filed on the next business day, which in this case was May 18--after the May 15 deadline for receipt of quotations established by the solicitations.
The protester acknowledged that its filings would ordinarily be untimely but argued that it had effectively filed timely agency-level protests by emailing copies of its GAO protests to the contracting officer before the solicitation closing time. Oready contended that this qualified its later GAO filings for an exception allowing protests filed after an agency-level protest.
GAO rejected that argument, concluding that the emails did not constitute agency-level protests under the Federal Acquisition Regulation. The decision noted that the emails merely transmitted copies of protests addressed to GAO, invoked GAO's bid protest regulations, and requested relief from GAO rather than from the Department of the Interior. The submissions also failed to request an agency ruling, a required element of a valid agency-level protest.
Because the communications to the contracting officer did not meet the requirements for agency-level protests, GAO ruled that the exception to its timeliness rules did not apply.
As a result, GAO dismissed all three protests, allowing the Bureau of Indian Education's procurements for therapy services at the Crownpoint and Tohaali community schools to proceed.
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Primary source of information - GAO: https://www.gao.gov/products/b-424508%2Cb-424509%2Cb-424510
Publicly Released on: June 8, 2026 Published: Jun 8, 2026
Michael Faro, for the protester.
William B. Blake, Esq., Department of the Interior, for the agency.
Paul N. Wengert, Esq., and Todd Culliton, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Dismisses BCCG JV Protest Over $641 Million Border Barrier Task Order Award to Cochrane USA
By Marlyn T. Vitin
WASHINGTON, June 27 -- The Government Accountability Office dismissed a protest by BCCG JV, Montgomery, Alabama, challenging the Customs and Border Protection's issuance of a sole-source task order valued at up to $641.3 million to Cochrane USA Inc., Fredericksburg, Virginia, for the design and construction of waterborne barriers along the U.S.-Mexico border.
The protest challenged the Department of Homeland Security's decision to award the task order without competition under a multiple-award indefinite-delivery, indefinite-quantity contract. BCCG argued that the agency improperly relied on a
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WASHINGTON, June 27 -- The Government Accountability Office dismissed a protest by BCCG JV, Montgomery, Alabama, challenging the Customs and Border Protection's issuance of a sole-source task order valued at up to $641.3 million to Cochrane USA Inc., Fredericksburg, Virginia, for the design and construction of waterborne barriers along the U.S.-Mexico border.
The protest challenged the Department of Homeland Security's decision to award the task order without competition under a multiple-award indefinite-delivery, indefinite-quantity contract. BCCG argued that the agency improperly relied on awaiver issued under the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA), contending that the waiver did not apply to waterborne barriers and that the award violated federal procurement rules requiring fair opportunity among contract holders.
GAO dismissed those claims, finding that it lacked jurisdiction because the task order was issued pursuant to an IIRIRA waiver published by the Secretary of Homeland Security in October 2025. Under the statute, exclusive jurisdiction over challenges arising from actions taken under such waivers rests with U.S. district courts, not GAO.
The decision noted that the waiver expressly exempted the procurement from numerous contracting statutes and regulations, including fair opportunity requirements for task orders under multiple-award contracts. GAO also found that the waiver's reference to "physical barriers" was broad enough to encompass waterborne barriers, rejecting BCCG's argument that the waiver applied only to land-based projects.
BCCG also alleged that the award created an improper conflict of interest because Cochrane employed a former CBP acquisition official who had previously overseen border barrier projects. The protester argued that the former official likely had access to nonpublic information that could have benefited Cochrane.
GAO dismissed that allegation as legally and factually insufficient. The decision found that BCCG offered only speculation, not the "hard facts" required to establish an actual or potential conflict of interest. It also noted that because the task order was awarded on a sole-source basis, BCCG failed to explain how any nonpublic information could have provided a competitive advantage.
The protest additionally suggested that the former official may have violated federal post-government employment restrictions. GAO declined to consider that claim, explaining that enforcement of criminal conflict-of-interest statutes falls within the jurisdiction of the procuring agency and the Department of Justice, not GAO.
As a result, GAO dismissed the protest in its entirety.
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Primary source of information - GAO: https://www.gao.gov/products/b-424377
Publicly Released on: June 26, 2026 Published: June 22, 2026
Robert J. Symon, Esq., Nathaniel J. Greeson, Esq., Erik M. Coon, Esq., and Elizabeth A. Brown, Esq., Bradley Arant Boult Cummings LLP, for the protester.
Kimberly L. Cohen, Esq., and Adam Struble, Esq., Department of Homeland Security, 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 Highlight Technologies Protest of FedTec Contract Award
By Marlyn T. Vitin
WASHINGTON, June 27 -- The Government Accountability Office has denied a protest by Highlight Technologies Inc., Fairfax, Virginia, challenging the award of a task order to FedTec LLC, Reston, Virginia, for enterprise data analytics shared services operations and maintenance support for the General Services Administration Office of the Chief Information Officer.
The procurement, conducted under a request for quotations issued in August 2025, sought a best-value contractor to provide professional support services for the agency's enterprise data analytics portfolio. The contract includes a one-year
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WASHINGTON, June 27 -- The Government Accountability Office has denied a protest by Highlight Technologies Inc., Fairfax, Virginia, challenging the award of a task order to FedTec LLC, Reston, Virginia, for enterprise data analytics shared services operations and maintenance support for the General Services Administration Office of the Chief Information Officer.
The procurement, conducted under a request for quotations issued in August 2025, sought a best-value contractor to provide professional support services for the agency's enterprise data analytics portfolio. The contract includes a one-yearbase period, four one-year option periods, and an optional six-month extension.
Following corrective action after an earlier protest, the General Services Administration reevaluated quotations from Highlight and FedTec. Highlight received higher technical ratings, earning "Excellent" in technical capability, staffing, and past performance, while FedTec received "Good" ratings across those categories. However, FedTec submitted a significantly lower evaluated price of about $33.9 million, compared with Highlight's roughly $42.9 million.
The source selection authority concluded that Highlight's technical advantages did not justify paying an additional $8.95 million, selecting FedTec as offering the best overall value.
Highlight argued that the agency improperly evaluated pricing after adding a $2 million annual ceiling for optional labor line items that had not been expressly included in the solicitation's pricing schedule. The company contended this change misled it into submitting a higher-priced quotation.
GAO acknowledged that the agency's addition of the ceiling price during evaluation was inconsistent with the solicitation's language. However, the watchdog found Highlight failed to demonstrate it suffered competitive prejudice or that it would have had a substantial chance of winning the award absent the error. GAO concluded that all vendors had received the same information and were free to develop their own pricing strategies based on business judgment.
The decision also rejected Highlight's challenge to the best-value tradeoff, finding the agency reasonably documented why FedTec's lower-priced proposal represented the better value despite its lower technical ratings.
Finally, GAO dismissed Highlight's allegation that FedTec violated the Procurement Integrity Act. The decision found the protester's claims--that FedTec contacted Highlight employees before award while representing itself as the likely winner--did not credibly establish that any government official improperly disclosed protected procurement information or otherwise violated federal law.
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Primary source of information - GAO: https://www.gao.gov/products/b-424060.2
Publicly Released on: June 18, 2026 Published: May 22, 2026
C. Peter Dungan, Esq., Lyle F. Hedgecock, Esq., Lauren S. Fleming, Esq., and Cash W. Carter, Esq., Miles & Stockbridge P.C., for the protester.
Taylor R. Holt, Esq., Maynard Nexsen PC, for FedTec, LLC, the intervenor.
Shirin Ahlhauser, Esq., General Services Administration, for the agency.
Christopher Alwood, Esq., and Alexander O. Levine, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
GAO Denies Octave Technologies Protest Over CMS Award to C-HIT
By Marlyn T. Vitin
WASHINGTON, June 27 -- The Government Accountability Office has denied a bid protest filed by Octave Technologies Corp., Baltimore, Maryland, challenging the award of a task order to Chags Health Information Technology LLC dba C-HIT, Columbia, Maryland, for application programming interface gateway support services for the U.S. Department of Health and Human Services Centers for Medicare and Medicaid Services.
The task order, issued under the General Services Administration's Federal Supply Schedule, covers commercial services supporting CMS's API gateway through a hybrid firm-fixed-price and
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WASHINGTON, June 27 -- The Government Accountability Office has denied a bid protest filed by Octave Technologies Corp., Baltimore, Maryland, challenging the award of a task order to Chags Health Information Technology LLC dba C-HIT, Columbia, Maryland, for application programming interface gateway support services for the U.S. Department of Health and Human Services Centers for Medicare and Medicaid Services.
The task order, issued under the General Services Administration's Federal Supply Schedule, covers commercial services supporting CMS's API gateway through a hybrid firm-fixed-price andtime-and-materials contract with a one-year base period and four option years.
Octave argued that CMS improperly evaluated vendors' quotations, treated offerors unequally, conducted discussions only with C-HIT, and made an unreasonable best-value determination.
GAO rejected all of the protester's arguments, finding that the agency's evaluation was reasonable, consistent with the solicitation, and supported by the record.
According to the decision, CMS reasonably assigned Octave lower confidence ratings after identifying several weaknesses in its proposal. The agency found inaccuracies in the corporate experience submitted for a contractor teaming arrangement partner, concerns with Octave's proposed application rationalization approach, and shortcomings in its oral presentation, including what evaluators viewed as an overreliance on a technique that could undermine the agency's objective of expanding data access.
GAO also dismissed Octave's claims of disparate treatment, concluding that the differences in the evaluations reflected meaningful differences between the competing proposals rather than unequal treatment. In contrast to Octave's proposal, C-HIT's quotation received high confidence ratings under all three non-price evaluation factors and contained no negative findings.
Although C-HIT's proposed price of approximately $33.66 million exceeded Octave's price of about $25.87 million, GAO agreed that the awardee's superior technical proposal justified the additional cost. The contracting officer reasonably concluded that C-HIT's quotation represented the best value to the government, the decision said.
GAO further upheld CMS's decision to conduct discussions only with C-HIT after determining it was the apparent best-suited vendor. The solicitation expressly permitted the agency to limit exchanges to the vendor most likely to receive the award, and GAO found that CMS acted in accordance with the solicitation and applicable procurement rules.
The protest was denied, leaving the award to C-HIT in place.
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Primary source of information - GAO: https://www.gao.gov/products/b-424253%2Cb-424253.4
Publicly Released on: June 8, 2026 Published: May 15, 2026
Alexander B. Ginsberg, Esq., Michael J. Anstett, Esq., Robert C. Starling, Esq., and Morgan E. Kurst, Esq., Fried, Frank, Harris, Shriver & Jacobson LLP, for the protester.
J. Ryan Frazee, Esq., and John. R. Prairie, Esq., Mayer Brown LLP, for Chags Health Information Technology LLC, the intervenor.
Brandon Dell'Aglio, Esq., and William Shim, Esq., Department of Health and Human Services, for the agency.
Paul N. Wengert, Esq., and Tania Calhoun, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
FedWriters Protest Over National Science Foundation Communications BPA Dismissed by GAO
By Marlyn T. Vitin
WASHINGTON, June 27 -- The Government Accountability Office has dismissed a protest by FedWriters Inc., Fairfax, Virginia, challenging a National Science Foundation solicitation for a multiple-award blanket purchase agreement covering comprehensive communications support services.
The procurement, valued at an estimated $62.6 million, seeks multiple BPA holders to provide communications services across six functional areas, including digital communications, writing, event support, video and audio production, administrative support, and communications metrics. The solicitation was issued as a woman-owned
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WASHINGTON, June 27 -- The Government Accountability Office has dismissed a protest by FedWriters Inc., Fairfax, Virginia, challenging a National Science Foundation solicitation for a multiple-award blanket purchase agreement covering comprehensive communications support services.
The procurement, valued at an estimated $62.6 million, seeks multiple BPA holders to provide communications services across six functional areas, including digital communications, writing, event support, video and audio production, administrative support, and communications metrics. The solicitation was issued as a woman-ownedsmall business set-aside through the General Services Administration eBuy system.
FedWriters argued that NSF improperly consolidated work previously performed under seven separate contract vehicles without demonstrating that the benefits of consolidation outweighed alternative contracting approaches, as required by section 7.107-2 of the Revolutionary Federal Acquisition Regulation Overhaul (RFO).
GAO dismissed the protest, finding that the cited consolidation requirements do not apply to BPAs. The decision explained that the plain language of the RFO provision covers solicitations for contracts and certain orders, but not BPAs. GAO noted that its earlier decisions had consistently reached the same conclusion because BPAs are not considered contracts under the applicable acquisition regulations.
The decision acknowledged that the U.S. Small Business Administration amended its regulations in 2023 to apply consolidation requirements to BPAs. However, GAO found that FedWriters did not raise arguments based on those SBA regulations until supplemental briefing, more than 50 days after filing its initial protest. Because the arguments could have been presented earlier, GAO dismissed them as an untimely piecemeal presentation of protest grounds.
GAO also rejected FedWriters's later argument that the consolidation rules should apply because the solicitation contemplated issuing six call orders simultaneously with the BPAs. The office found that the protest had challenged only the BPA-level consolidation analysis, not the consolidation of individual call orders, making the new argument untimely.
Although NSF prepared a detailed consolidation justification during corrective action following an earlier protest, GAO ruled that the agency's voluntary preparation of such a memorandum did not create a legal obligation to comply with RFO section 7.107-2 where the regulation itself did not apply.
As a result, GAO dismissed the protest in its entirety, leaving NSF's procurement for the communications support BPA to proceed.
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Primary source of information - GAO: https://www.gao.gov/products/b-424376
Publicly Released on: June 25, 2026 Published: June 23, 2026
Devon E. Hewitt, Esq., and Matthew L. Nicholson, Esq., Potomac Law Group, for the protester.
John Cho, Esq., National Science Foundation, for the agency.
Michelle Litteken, Esq., and April Y. Shields, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision.
Altus Technology Solutions Protest Against Air Force Contract Award to VetPride-EMI Denied
By Marlyn T. Vitin
WASHINGTON, June 27 -- The Government Accountability Office has denied a protest by Altus Technology Solutions, Hanover, Maryland, challenging the U.S. Air Force's award of a contract for operations, maintenance and support services at primary training ranges to VetPride-EMI Maintenance Solutions LLC, Raleigh, North Carolina.
The procurement, issued as a small business set-aside, sought a fixed-price contract with a nine-month base period and four one-year option periods. Award was to be made on a best-value tradeoff basis, with program management weighted significantly more heavily than price.
Altus
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WASHINGTON, June 27 -- The Government Accountability Office has denied a protest by Altus Technology Solutions, Hanover, Maryland, challenging the U.S. Air Force's award of a contract for operations, maintenance and support services at primary training ranges to VetPride-EMI Maintenance Solutions LLC, Raleigh, North Carolina.
The procurement, issued as a small business set-aside, sought a fixed-price contract with a nine-month base period and four one-year option periods. Award was to be made on a best-value tradeoff basis, with program management weighted significantly more heavily than price.
Altusreceived a "Good" rating under the program management factor and proposed a price of about $106.8 million. VetPride-EMI received an "Acceptable" rating but submitted the lower-priced proposal at approximately $91.1 million. The Air Force determined that VetPride-EMI's proposal represented the best value because Altus's technical advantages did not justify its roughly 17 percent price premium.
GAO rejected Altus's claims that the Air Force improperly evaluated proposals under the program management factor. Altus argued that the agency overlooked weaknesses in VetPride-EMI's quality control approach and failed to recognize additional strengths in Altus's proposal, including its use of incumbent personnel. GAO found that the Air Force reasonably evaluated both proposals in accordance with the solicitation and that Altus's arguments largely reflected disagreement with the agency's judgment rather than evidence of an unreasonable evaluation.
The watchdog also denied Altus's challenge to the Air Force's price evaluation. Altus contended that VetPride-EMI's labor rates and equipment pricing were inconsistent with solicitation requirements. GAO concluded that the solicitation required the agency to evaluate only each offeror's total overall evaluated price rather than underlying labor rates or pricing details. Because the procurement did not call for a price realism analysis, the Air Force was not required to examine those cost breakdowns.
Finally, GAO rejected Altus's argument that VetPride-EMI was ineligible for award because of alleged errors in its System for Award Management registration. The decision found that the joint venture maintained an active SAM registration throughout the procurement and that any inaccuracies concerning ownership information or mentor-protege representations were, at most, minor informalities that did not invalidate the award or prejudice other offerors.
As a result, GAO denied the protest in its entirety, allowing the Air Force's contract award to VetPride-EMI Maintenance Solutions to stand.
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Primary source of information - GAO: https://www.gao.gov/products/b-424316%2Cb-424316.2
Publicly Released on: June 18, 2026 Published: June 12, 2026
Craig A. Holman, Esq., Amanda J. Sherwood, Esq., Thomas A. Pettit, Esq., and Adrienne Jackson, Esq., Arnold & Porter Kaye Scholer LLP, for the protester.
J. Alex Ward, Esq., James A. Tucker, Esq., and Jillian I. Stern, Esq., Morrison & Foerster LLP, for VetPride-EMI Maintenance Solutions, LLC, the intervenor.
Colonel Justin A. Silverman, Michael J. Farr, Esq., W. Jacob Worthan, Esq., Beatrice K. Foster, Esq., Department of the Air Force, 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.