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Better Late Than Never: FAR Council Finally Addresses OCI Rules

On January 15, 2025, the Federal Acquisition Regulation (FAR) Council published a proposed rule overhauling the FAR’s Organizational Conflict of Interest (OCI) provisions. The proposed rule follows a December 2022 law that...more

FY25 NDAA: Promoting Nontraditional Acquisition While Securing the Supply Chain, and More

On December 23, 2024, President Biden signed into law the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2025. The annual bill authorizes spending for the Department of Defense (DOD) while setting other...more

Less Oversight and Undefined Penalties: The NDAA’s Proposed Protest Reforms

Buried in Section 885 of the current draft of the National Defense Authorization Action (NDAA) for Fiscal Year 2025 is a new attempt to figure out how to make unsuccessful bid protesters pay. As of this posting, the NDAA has...more

Bid Protest Spotlight: Debriefings, Timeliness, Documentation

This article is part of a monthly column that provides takeaways from recent bid protest cases. In this installment, we highlight decisions from the U.S. Court of Appeals for the Federal Circuit, the U.S. Government...more

OMB Says Agencies “Should” Perform A Rule Of Two Analysis And Set Aside Requirements For Task Orders Under Multiple-Award...

The U.S. Office of Management and Budget (OMB) has issued a policy memorandum with a goal of promoting small business participation under multiple-award indefinite delivery/indefinite quantity contracts (MACs). One of the...more

GAO Finds Company's BPA Bid Remains Eligible For Award Despite A Transaction, Recertification, And Change In Size Status In...

Small business regulations create one of the stickier wickets in bid protest litigation. Although the Small Business Administration (SBA) has exclusive authority to determine a company’s size and socioeconomic status, the...more

November 2023 Bid Protest Roundup

This month's protest spotlight highlights three decisions by the U.S. Government Accountability Office. The decisions feature arguments that unsuccessful offerors often want to make, but that are rarely successful, as well as...more

Timeliness Traps: Adverse Action Before Receipt Of A Written Agency-Level Protest Decision

In the right circumstances, an agency-level protest can be a quick and efficient way to address certain procurement errors, as we discussed a few years ago. One downside of agency‑level protests, however, is their potential...more

August 2023 Bid Protest Roundup: Former Government Employees; Buy American Act Waivers

This month’s bid protest roundup looks at two GAO protests from August. One examines the risks of using former federal employees to assist with proposal development when their prior access to non-public information might...more

Hard Validations And Cutlines: What Happened On CIO-SP4?

If you’ve been following the saga of the National Institutes of Health Information Technology Acquisition and Assessment Center’s (NITAAC) Chief Information Officer-Solutions and Partners (CIO-SP4) procurement, you likely...more

Clarifying Minor Errors: The Court Makes An Agency Seek A Clarification

Offerors whose proposals are disqualified for immaterial typographical and data input errors will want to read an interesting new protest decision from the Court of Federal Claims. In Aspire Therapy Services & Consultants,...more

Joint Venture Member Experience: “Considering Each Member” Vs. “Considering Either Member”

The Government Accountability Office (GAO) has issued an important new decision in the protest of AttainX,Inc ., B-421216, B-421216.2, Jan. 23, 2023, 2023 WL 1860802. The decision addresses how agencies must evaluate the...more

A Bluer Shade Of Blue: All “Outstandings” Are Not Created Equal

A common mistake in competitive procurements is a mechanical fixation on the adjectival ratings, color ratings, or numerical “scores” a procuring agency assigns a proposal under a particular evaluation factor. In best value...more

Deciphering The GAO’S Bid Protest Statistics For FY 2022

Each year around this time, the U.S. Government Accountability Office (GAO) publishes its annual report to Congress on bid protests. Earlier this week, the GAO published the report for Fiscal Year (FY) 2022....more

Congress Passes Bill To Reauthorize SBIR/STTR Programs

As most experts expected, Congress has passed the bill to reauthorize the SBIR and STTR programs until September 30, 2025. The bill is now headed for the White House, where the President is expected to sign it into law....more

August 2022 Bid Protest Roundup: Affiliate Experience, JV Registration

In this month’s bid protest roundup, we consider: (1) an exception to the normal rule governing reliance on affiliate experience and past performance; and (2) two different bid protests of very similar solicitation terms that...more

“I Get By With A Little Help From My Friends”: Relying On Affiliate Past Performance And Experience

For evaluation purposes in a federal procurement, may an offeror rely upon the past performance and experience of its affiliates? The answer generally is a qualified yes, but the answer and the qualifications may change...more

SEKRI, INC. V. United States: Are Pre-Proposal-Submission Email Exchanges Now Enough To Avoid Blue & Gold Waiver?

In the seminal decision Blue & Gold Fleet, L.P. v. United States, the U.S. Court of Appeals for the Federal Circuit held that “a party who has the opportunity to object to the terms of a government solicitation containing a...more

February 2022 Bid Protest Roundup: Key Personnel Changes, Agency Computer Glitches, And Ambiguous Solicitations

This month’s roundup considers three recent protests: (1) an important decision by the Court of Federal Claims rejecting controversial precedents of the U.S. Government Accountability Office (GAO) concerning key personnel...more

Unavailable Key Personnel: Differing Legal Standards At The GAO And Court Of Federal Claims

An interesting new bid protest decision from the U.S. Court of Federal Claims articulates a rule for pre-award key personnel unavailability that is very different from the one employed by the U.S. Government Accountability...more

Five Peculiarities Of Protests Of Federal Supply Schedule Protests

The General Services Administration’s Federal Supply Schedule contracts are an efficient method for agencies across the Government to meet their needs for many commercially available supplies and services. For requirements...more

Harmonia Holdings: Denied Pre-Award Protest Rises From The Dead Five Months Later As A Post-Award Protest

The U.S. Court of Appeals for the Federal Circuit has issued its long-awaited decision in Harmonia Holdings Group, LLC v. United States, vacating a bid protest decision the U.S. Court of Federal Claims rendered nearly two...more

GAO Finds CIO-SP4 Solicitation Is Unduly Restrictive Of Competition

The Chief Information Officer-Solutions and Partners 4 (CIO-SP4) procurement of the National Institutes of Health’s Information Technology Acquisition and Assessment Center (NITAAC) has garnered a great deal of attention....more

February 2021 Bid Protest Roundup (Law360 Spotlight)

This installment of our monthly Law360 bid protest spotlight considers: (1) a company’s successful challenge to an agency’s decision to take corrective action and reopen a competition the company had already won; (2) a...more

Stays Of Performance During A Gao Bid Protest: Federal Circuit Says That Five Days After The Debriefing Date Means Five Days After...

The Court of Appeals for the Federal Circuit has issued a precedential decision in NIKA Technologies, Inc. v. United States, reversing a decision by the Court of Federal Claims on the timelines for securing a stay of contract...more

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