More issues

40 more strengths, please?

Incumbent protestor lost a proposal to a lower bidder, though both had good technical factor ratings. Agency assigned 2 strengths but felt that wasn't enough to overcome the price factor. Protestor claimed that the agency should have given the proposal 40 more strengths. Agency disagreed, GAO said that decision was within agency's discretion. Other protest grounds included Unequal Treatment, Service Contract Act noncompliance, and failure to conduct a responsibility determination. But on each front, GAO said allegations weren't supported and agency's record was sufficient. Protest denied.

GAO: Strategic Resources, Inc., B-423597.2,B-423597.3 (Jan 14, 2026)

The Labor Rates Were Too Low

Air Force's cost-realism analysis showed that ~20% of a proposal's unburdened hourly labor rates were unrealistic based on ERI and Salary.com benchmarks. Protestor argued that agency's analysis was flawed and should have looked at its pricing narrative, but the agency and GAO were unpersuaded, with GAO saying that the narrative was "overly general." Protest denied.

GAO: T3i, Inc., B-423815 (Dec 30, 2025)

Lack of experience, even if not a weakness, can be dispositive

The Air Force solicited proposals for "fuel transportation services." After reviewing proposals, the Air Force picked the vendor with better experience with "aviation fuel" even though the solicitation required other fuels, too. GAO found that the protestor's lack of experience with aviation fuel was enough to make the award even if it wasn't considered a significant weakness or deficiency. And because it wasn't a weakness, Air Force wasn't required to raise it during discussions. Protest denied.

GAO: Centerline Logistics Corporation, B-423838,B-423838.2 (Jan 07, 2026)

Misevaluated? Nah

Protestor argued that GSA "misevaluated" the awardee's proposal. GAO reviewed the record and found that, based on that record, GSA's evaluation was reasonable and consistent with the solicitation. Protest denied.

Also, a case where the incumbent's past performance was determined to be "high risk" based on its failure to meet SLAs. Ouch.

GAO: CWTSatoTravel, B-423181.2,B-423181.3,B-423181.4 (Dec 19, 2025)

Halves and Halves Not

DLA planned to procure "423 coupling halves" using a "special emergency procurement authority" and set the procurement aside for small businesses. After a pre-award protest by Chase, DLA canceled the solicitation, and issued a second solicitation with a smaller request for 176 coupling halves. After DLA made an award, Chase protested again. DLA took corrective action to cancel the solicitation and award. GAO dismissed the protest of the second solicitation as academic. GAO also reaffirmed that "an agency may cancel a solicitation during the course of a protest," rejecting Chase's claims related to the first cancellation.

GAO: Chase Supply, Inc., d/b/a Chase Defense Partners, B-424032 (Jan 20, 2026)

If the RFP wants escalation rates, you need to include them or the agency will include them for you

Solicitation required that labor rates escalate each year in the period of performance. Protestor didn't include an escalation rate and agency applied a default rate. Protestor claimed this was unreasonable but GAO disagreed, noting that the solicitation required it. Also, protestor claimed a "bait and switch" in the awardee's staffing plan, but GAO found that the agency never took the bait.

GAO: Imagine One Technology & Management, Ltd., B-422875.3,B-422875.4 (Jan 02, 2026)

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