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SBA’s OHA Finds Initial Offer To Be Of Consequence, Not Final Proposal Revision, for the “180-Day Rule”

On February 19, the Office of Hearings and Appeals (OHA) denied an appeal from an unsuccessful bidder who argued the awardee was large due to an acquisition that occurred while the award was pending. OHA found that Small...more

Bid Protest Minute: Bidders Beware – Clearly Stated Solicitation Requirements Control

On November 15, the Government Accountability Office (GAO) denied a protest from AtVentures, LLC, a mentor-protégé joint venture, who challenged its exclusion from consideration for award on the basis that it was able to use...more

SBA Seeks to Make Changes to Recertification Requirements for Multiple-Award Contracts

On August 23, the U.S. Small Business Administration (SBA) issued a proposed rule that would make significant changes to SBA’s recertification requirements. Most notably, the rule would change when size and socioeconomic...more

Bid Protest Minute: COFC Makes It Clear; SAM Registration Can Sink a Proposal

On September 10, the Court of Federal Claims (COFC) issued an opinion in Zolon PCS II, LLC v. United States, holding that the National Geospatial-Intelligence Agency (NGA or Agency) unreasonably issued a deviation from FAR...more

Bid Protest Minute:  GAO Clarifies Certain “De Facto” Joint Venture Eligibility Issues

On March 22, the Government Accountability Office (GAO) sustained a protest challenging an agency decision finding the protester ineligible for award under both the Omnibus Diplomatic Security and Antiterrorism Act of 1986...more

GAO’s 2023 Bid Protest Report: More Than Meets the Eye

On October 26, the Government Accountability Office (GAO) sent its annual bid protest report to Congress, which reflected a dramatic increase in protests filed following four straight years of decline. The report provides...more

Bid Protest Win for AM General on Multi-Billion Dollar Contract

We represented AM General (AMG), an automotive manufacturer that builds military vehicles for government customers, including the Humvee, in a successful bid protest involving a $9.7 billion contract for the U.S. Army to...more

Joint Venture Past Performance Can Be Gleaned from Previous Prime-Sub Relationships

Over the last few years, the government has shifted away from lowest price technically acceptable valuations placing a larger importance on past performance. The past performance requirement can sometimes create obstacles for...more

Responsibility vs. Responsiveness: A Critical Difference Saves Flawed Initial Bid

As a general matter, an agency should reject a bid out of hand if it is deemed defective due to problems with bidder responsiveness. However, flawed bids determined on account of issues with bidder responsibility can be...more

Broad Agency Discretion to Cancel Bid Solicitations Curtailed with Recent Court Decision – “The Tribe has Spoken”

Generally, government agencies are given broad discretion to define their needs; however, last month, the United States Court of Federal Claims chose to curtail an agency’s authority to cancel and amend bid solicitations in...more

Not Quite Good Enough: COFC Finds Agencies OCI Investigations Fall Short

Organizational conflicts of interest (OCI) are troubling for both the government and contractors. Under FAR 2.101, an OCI is a situation where “a person is unable or potentially unable to render impartial assistance or advice...more

Size Recertification Prior to Award – When is it Required?

The U.S. Court of Federal Claims (COFC) decision in HWI Gear, Inc. v. United States highlights the importance of reviewing a solicitation to determine if the text of Federal Acquisition Regulation (FAR) 52.219-28 is included...more

How Do Mergers & Acquisitions Impact Pending Bids?

Given the continued high volume of mergers and acquisitions (M&A) transactions in the federal marketplace, buyers and sellers need to be aware of the developing body of case law at Government Accountability Office (GAO) and...more

New GAO Bid Protest Procedures Take Effect on May 1

In early April, the GAO issued a final rule revising the existing bid protest process—the major revisions being the introduction of an Electronic Protest Docketing System (EPDS) and a protest filing fee. When the rule takes...more

Learning from Bid Protests: Price “Credits” for IP Rights

On January 24, 2018, the Government Accountability Office (GAO) denied a bid protest that in part, focused on the issue of price credit. VT Halter Marine, Inc. (VT) protested the award of a Department of the Army contract—for...more

U.S. Court of Federal Claims Reports on Busy and Productive FY17

The U.S. Court of Federal Claims recently issued a 2017 statistical report—covering the government’s fiscal year October 1, 2016 to September 30, 2017. During this time, 652 suits filed were filed at the Court and 1,035 suits...more

Mentor Protégé Joint Venture Allowed to Proceed with Contract Even Though Ineligible to Bid

In an unsealed opinion on October 30, 2017, U.S. Court of Federal Claims Judge Nancy Firestone held that a company, which should have been deemed ineligible from bidding, was allowed to proceed with a contract award because...more

GAO Upholds Waiver(s) of OCI Allegations

On January 30, the U.S. Government Accountability Office (GAO) issued its decision denying Concurrent Technologies Corp.’s (CTC) protest of the U.S. Navy’s award of a support contract for the Navy Manufacturing Technology...more

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