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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 Active Deployment Systems, LLC v. United States, U.S. Court of Federal Claims, No. 25-968C (Oct. 30, 2025), Active Deployment Systems (ADS) challenged several aspects of the Department of Homeland Security’s (DHS) award of 42 indefinite delivery /indefinite quantity (IDIQ) contracts for detention related services under a solicitation issued by Immigration and Customs Enforcement (ICE). ADS alleged that ICE violated the terms of the solicitation by awarding far more contracts than advertised, and that the solicitation’s pricing structure—which included fixed price caps—was irrational and arbitrary. ADS sought to halt the award of any task orders and urged the Court to find that it had been competitively harmed by the agency’s actions. But the Court disagreed, finding no violation of the solicitation and, most notably, no prejudice, even assuming ADS’ complaints about the competition had merit.

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In Protection Strategies Etc. International, LLC, B-423539 (Aug. 25, 2025), Protection Strategies, a service-disabled veteran-owned small business (SDVOSB), filed a pre-award protest challenging the terms of a solicitation issued by the Defense Counterintelligence and Security Agency (DCSA) for background investigation support services. The protester objected to the agency’s decision to issue the solicitation as a general small business set-aside, rather than reserving it for SDVOSBs or another small business subcategory. It also raised concerns about the solicitation’s risk structure, particularly the use of a fixed-price contract model and the alleged lack of guaranteed funding for phase-in activities.

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In System Studies & Simulation, Inc. v. United States, U.S. Court of Federal Claims, Nos. 24-1429, et al. (March 4, 2025)​, three disappointed offerors, including System Studies & Simulation (S3), protested the U.S. Army’s decision not to conduct discussions before awarding a contract for Advanced Helicopter Flight Training Support (AHFTS) services. The protesters argued that the Army violated Defense Federal Acquisition Regulation Supplement (DFARS) § 215.306(c), which states that discussions “should” be held for procurements over $100 million​.

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