Articles Posted in Government Accountability Office (GAO)

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In Island Creek Associates, LLC, B-423301.3 (Dec. 5, 2025), Island Creek Associates protested the Department of the Navy’s award to StraCon Services Group for program management contractor support services. Island Creek did not challenge any aspect of the Navy’s evaluation of proposals. Instead, its protest focused solely on alleged organizational and personal conflicts of interest related to StraCon’s subcontractor, Precise Systems, Inc., who was the incumbent contractor. Island Creek claimed that Precise gained an unfair competitive advantage from access to proprietary information and due to the involvement of a senior Navy official whose wife worked for Precise. GAO denied the protest in its entirety and provided a detailed analysis of conflict of interest law.

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In Chugach Logistics and Facility Services JV, LLC, B-423690 (Nov. 20, 2025​), CLFS protested an $80 million award by the Department of the Navy to CCS King George 2 LLC (CCS KG) for base operations support at Naval Base Coronado. CLFS alleged that the Navy unreasonably evaluated proposals under the corporate experience, past performance and price factors, and improperly failed to consider certain performance data that it claimed was “too close at hand.” GAO rejected all of CLFS’ challenges, finding that the Navy acted within its discretion and in accordance with the solicitation.​

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In Ernst & Young, LLP, B-423491.2 (Sept. 26, 2025), Ernst & Young (EY) protested the scope of corrective action taken by the Department of the Army following EY’s earlier protest of the Army’s award to Guidehouse for support of the Army Financial Improvement program. EY’s initial protest resulted in a voluntary corrective action, during which the agency announced it would reevaluate proposals and make a new award decision. However, during implementation of that corrective action, Guidehouse informed the Army that one of its proposed key personnel was no longer available. That development led the Army to open limited discussions focused on key personnel substitution, which in turn became the focus of EY’s follow-on protest.

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In SRM Group, LLC, B-423695 (Sept. 25, 2025​), SRM Group, the incumbent contractor, protested the Army’s award of a contract for lodging and transportation services at Camp Robinson to BryMak & Associates. SRM argued that the agency’s past performance evaluation was flawed and that the resulting best-value tradeoff was unreasonable. At the heart of the protest was SRM’s claim that BryMak’s past performance references did not merit the same “substantial confidence” rating that SRM received. SRM challenged the relevance of BryMak’s references, the inclusion of a subcontractor’s limited experience and the agency’s treatment of SRM’s own incumbent performance. GAO rejected each of these arguments, finding the evaluation well-documented and consistent with the solicitation.

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In QA Engineering, LLC, B-423716, B-423716.2 (Sept. 30, 2025​), QA Engineering protested the U.S. Army Corps of Engineers’ decision to award a contract for the construction of a pre-engineered metal building (PEMB) to Koman Advantage. QA argued that the agency improperly found its proposal technically unacceptable because it did not address quality control for off-site fabrication, a requirement it claimed was not clearly stated in the solicitation. QA also contended that its proposal did meet this requirement and that other offerors were treated more favorably despite submitting similar responses. GAO rejected all of these claims, finding that the solicitation clearly required an off-site fabrication quality control discussion, that QA failed to provide one, and that other offerors met the requirement. The protest also raised additional arguments regarding inconsistent evaluator scoring and consensus ratings, but GAO found no merit in those claims.

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In Castro & Company, LLC, B-423689, (Nov. 13, 2025), ​Castro & Company protested the Federal Election Commission’s (FEC) decision to award a blanket purchase agreement (BPA) to Contracts Management Enterprises (CME) for financial management and accounting support services. Castro argued that CME had an unmitigable impaired objectivity organizational conflict of interest (OCI) because one of CME’s employees worked as a contract specialist on a separate FEC contract where she was in close proximity to the source selection authority for the protested procurement. The protester also challenged multiple aspects of the agency’s technical evaluation, including findings that its proposal lacked “timeline details” and a “structured response,” both of which Castro contended were not supported by the solicitation or adequately explained by the agency. Finally, Castro asserted that the agency’s best-value tradeoff was flawed because the FEC failed to consider Castro’s lower-priced quotation when selecting among technically acceptable offerors. GAO sustained the protest, finding that the agency failed to meaningfully investigate or document the alleged OCI, that the technical evaluation was unsupported, and that the tradeoff analysis improperly omitted consideration of Castro’s quotation.

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In Peraton Inc., B-423639 (September 17, 2025), Peraton Inc. protested the General Services Administration’s award of a task order to General Dynamics Information Technology (GDIT) for IT lifecycle support services at U.S. Strategic Command. Peraton challenged several aspects of the agency’s evaluation and award decision. It argued that the agency had applied unstated evaluation criteria by placing excessive emphasis on audiovisual (A/V) engineering support requirements that were not clearly highlighted as evaluation factors. Peraton also claimed that the agency improperly double-counted weaknesses, penalizing the same alleged deficiency in both the technical and staffing evaluation areas.

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In Noblis MSD, LLC, B-423599 (September 11, 2025), Noblis MSD, the incumbent contractor, protested the Navy’s award of a technical support services contract to Solute, Inc. Noblis raised several arguments, including that Solute’s proposal was noncompliant because it lacked a signed Standard Form (SF) 33, that the agency unreasonably evaluated past performance and that the award decision ignored known negative performance information. GAO denied the protest in full, finding that the agency’s evaluation and award decision were reasonable and supported by the record, and offering helpful reminders about intent to be bound, evaluators’ discretion, the “too close at hand” doctrine, and the use of sworn declarations.

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In Enviremedial Services, Inc., B-423552 (August 28, 2025), Enviremedial Services, Inc. (ESI) protested the Army Corps of Engineers’ award of a facilities maintenance contract to BryMak & Associates, Inc., alleging flaws in the agency’s price evaluation, past performance analysis and best-value tradeoff. While GAO dismissed ESI’s unbalanced pricing claim, it sustained the protest based on multiple errors and omissions in the past performance evaluation and the agency’s failure to meaningfully document its source selection rationale.

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In Advanced Computer Learning Company, LLC, B-423267.2 (September 2, 2025), Advanced Computer Learning Company (ACLC), the incumbent contractor, protested the Navy’s award of a support services and data link training contract to Linchpin Solutions, Inc., challenging the agency’s evaluation of past performance and the resulting best-value tradeoff. ACLC argued that it was irrational for the Navy to assign Linchpin the same “Substantial Confidence” rating it received, despite ACLC’s strong performance as the incumbent on the exact requirement.

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