Articles Posted in Government Accountability Office (GAO)

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In Marvin Test Solutions, Inc., B-423928; B-423928.2 (Jan. 28, 2026), Marvin Test Solutions filed a pre-award protest challenging the Department of the Air Force’s RFP for a common armament tester (CAT-F) system for F-15, F-16 and A-10 fighter aircraft. Marvin argued that the agency was required to conduct the procurement as a commercial item acquisition under FAR Part 12 and that the solicitation was unduly restrictive of competition, particularly with respect to a minimum screen size requirement for the handheld operational-level (O-level) tester.

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In Centerline Logistics Corporation, B-423838, et al. (Jan. 7, 2026), Centerline Logistics Corp. protested the Air Force’s award of a roughly $200 million fuel transportation services contract to Vane Line Bunkering. Centerline challenged multiple aspects of the evaluation and source selection decision, arguing that the agency applied unstated evaluation criteria, treated offerors disparately, failed to consider negative information “too close at hand,” and did not conduct meaningful discussions regarding the relevance of Centerline’s past performance. GAO denied the protest in its entirety. In doing so, the decision serves as a useful refresher on several important protest doctrines—and the high bar protesters must clear to prevail in a GAO protest.

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Twice in one week, GAO dismissed bid protests as untimely, with each case highlighting a different but equally unforgiving timeliness trap. In ASG Solutions Corp., B-424053 (Jan. 16, 2026), the protester mistakenly assumed it was entitled to a FAR Part 15 debriefing in a FAR Part 13 procurement, incorrectly believing that its protest clock had been tolled. In Mission Analytics, LLC, B-423980 (Jan. 14, 2026), the protester miscalculated the deadline for filing a follow-on GAO protest after initial adverse agency action, and missed the filing deadline by one minute. Together, the decisions underscore GAO’s strict enforcement of its timeliness rules and serve as a reminder that misunderstandings about debriefings, agency-level protests and filing deadlines are often fatal to otherwise potentially successful protest challenges.

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In Manutek Inc., B-423476.2, et al. (Jan. 1, 2026), Manutek protested the National Oceanic and Atmospheric Administration’s decision not to award it an IDIQ contract for professional, scientific and technical services under the ProTech 2.0 Weather Domain. The protest focused largely on the agency’s evaluation of Manutek’s oral presentation, including alleged flaws in time management, documentation, evaluator judgments and the conduct of the post-presentation interactive dialogue.

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In Markon LLC, B-423767, et al. (Dec. 12, 2025), Markon protested the Central Intelligence Agency’s award to Arcfield for business operations, IT engineering and business enterprise modernization support. Markon challenged the CIA’s cost realism evaluation, arguing that the agency improperly relied on oral instructions given during pre-solicitation industry one-on-one sessions, instructions that were never incorporated into the final RFP. According to Markon, the CIA used those oral statements to reject Markon’s proposed efficiencies and imposed a significant upward cost adjustment instead of evaluating whether Markon’s proposed costs were realistic for its unique technical approach. GAO sustained the protest, finding that the CIA evaluated proposals using unstated criteria and failed to conduct the cost realism analysis required by the solicitation and procurement regulations.

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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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