V. David Zvenyach

Nonproprietary success audits

The Army solicited leadership training and coaching services using the "Five Behaviors of a Cohesive Team” leadership training methodology. As part of that training, the Army required "success audits," which the protestor claims is their proprietary tool and that the other vendors should be eliminated from competition. The Army disagreed, claiming that "success audits" is "common nomenclature," not a proprietary tool. GAO agreed with the Army and protest denied.

GAO: Life Together Coaching, LLC, B-423989,B-423989.2,B-423989.3 (Jan 28, 2026)

No capability statement, no reconsideration

Protestor challenged a sole-source decision by the National Park Service but GAO dismissed because the vendor never submitted a "capability statement" and was, therefore, not an interested party. Protestor argued for reconsideration of decision that they did submit a capability statement as part of their protest. GAO denies reconsideration because "the declaration was not a capability statement directed to the agency requesting its procurement consideration."

GAO: Economic Systems, Inc.--Reconsideration, B-423747.3 (Jan 28, 2026)

Nothing to see here

Accenture argued that CACI had unmitigated organizational conflicts of interest concerns. The contracting officer, however, "methodically" considered potential OCI concerns during the award process and "conclud[ed] that these contracts either did not have the potential to present OCIs or were appropriately mitigated at this time." GAO found no reason to disagree. Similarly, Accenture argued that the government's evaluation of the proposals was unreasonable. And GAO found no reason to disagree. Protest denied.

GAO: Accenture Federal Services, LLC, B-423859,B-423859.2 (Jan 16, 2026)

Lower bid, but not enough

Protestor, which had equivalent adjective ratings and a lower price, argued that the Navy didn't evaluate the winning awardee's proposal harsh enough. For example, protestor argued that the technical proposal should have been dinged because the "proposed quality manager lacked relevant experience" and that the past performance was tainted by negative past performance of a teaming partner. GAO reviewed the record and found that the Navy "meticulously compared the strengths and disadvantages offered by the proposals" and, therefore, protest denied.

GAO: GKG Contractors, LLC, B-423941,B-423941.2 (Jan 22, 2026)

100% by two "tenants by the entirety" isn't a majority

SBA denied Service‑Disabled Veteran‑Owned Small Business (SDVOSB) status to Vialytics, because SBA found that the veteran‑owner didn't actually hold a majority stake. Specifically, the SBA found that the LLC was owned 100% by the owner and his wife as "tenants by the entirety with the right of survivorship." OHA agreed that ownership wasn't "direct and unconditional" because his wife "has equal rights in the ownership interest in Appellant." Appeal denied.

SBA OHA: VSBC APPEAL OF: VIALYTIX, LLC, APPELLANT, SBA No. VSBC-462-A (Jan. 22, 2026)

Oopsies about sharing that pricing information?

During procurement, CBP inadvertently disclosed the incumbent's pricing information in a hidden worksheet! Even though CBP's response to disclosure "was remiss in several fundamental respects," GAO found that the proposed remedies (requiring an signed affidavit from competitors, changing the contract vehicle with different pricing, and changing the evaluation criteria to remove price consideration) was sufficient to survive protest. Protest denied.

GAO: Federal Missions Solutions, LLC, B-423584,B-423584.2 (Sep 04, 2025)

Sometimes, buzzwords matter

Protestor did not identify key technologies in their resumes and agency dinged them for it. Protestor claimed that this was an unstated requirement. GAO disagreed, and held that the "plain language of the RFQ clearly advised vendors that the resume factor would be evaluated, in part, based on how experienced and proficient the key personnel was with the Azure and Intune technologies." Protest denied.

GAO: Technology Information Systems, LLC, B-424087,B-424088 (Jan 26, 2026)

No COC? No protest.

VA determined that Calvary was not a responsible bidder. SBA declined to issue Calvary a certificate of competency (COC), which is dispositive for responsibility determinations. Because Calvary's GAO protest did not raise any of the "limited prescribed circumstances" that GAO will review SBA COC decisions, GAO dismissed the protest.

GAO: Calvary Contracting, Inc., B-424024, (Jan 13, 2026)

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