V. David Zvenyach

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)

Protestor argued that agency's assessment of technical approach was flawed. GAO's view was that the protest was just "disagreement with the agency's evaluation judgment" and that the protestor's slides weren't sufficiently clear ("We likewise see no basis to fault the agency for not connecting various arrows and unlabeled graphics on one slide to various statements on subsequent slides"). Ergo, protest denied.

GAO: H2 Technology Group, LLC, B-423777,B-423777.2 (Dec 15, 2025)

Protestor filed a protest more than 10 days after a post-award brief explanation. Because the acquisition followed Part 13 procedures, not Part 15, no debrief was required and the protest was untimely.

Also, in the govcon-time-is-a-flat-circle category: the solicitation was marked "urgent" with proposals due in 4 days, with "boots on ground" within 40 days. Curiously, the award notice came 6 months later, 211 days after the solicitation release.

GAO: ASG Solutions Corporation d/b/a American Systems Group, B-424053 (Jan 16, 2026)

Protest window closed at 5:30 pm. Protest came in at 5:31 pm. Dismissed.

GAO: Mission Analytics, LLC, B-423980 (Jan 14, 2026)

The VA noticed intent to sole source "switchboard services" under the AbilityOne program to the Central Association for the Blind under the Javits-Wagner-O'Day (JWOD) Act. Protestor claimed that this violated the Veterans First Contracting Program's Rule of Two for SDVOSBs or VOSBs. GAO explained that the Department of Veterans Affairs Contracting Preference Consistency Act addresses the conflict and JWOD has priority. Protest denied.

GAO: Magellan Solutions USA, Inc., B-423857 (Jan 12, 2026)

Solicitation required four key personnel that each had "a minimum two years' experience with five years preferred in supervising warehouse logistical operations." But 2 of the protestor's key personnel did not meet the 2-year minimum. Agency considered that a material deficiency and GAO upheld the agency's decision. Protest denied.

GAO: Hurricane Consulting, Inc., B-423839,B-423839.3,B-423839.4,B-423839.5 (Jan 02, 2026)

Protestor's claim that a Navy IDIQ didn't cover AI/ML was tossed because the contract covered "technical tasks, including those that involve the optimal utilization of IT tools and software development." Why wasn't AI/ML included explicitly five years ago? "At the time the [IDIQ] was issued nearly five years ago, utilization of AI/ML was not sufficiently widespread to be included in the performance work statement." But a broad scope covered the new tech and the $35 million threshold applied, so the protest was dismissed.

GAO: JDSAT, Inc., B-423868 (Jan 12, 2026)

Protestor was assigned a significant weakness because the solicitation required "80dB RF attenuation" for the facility and two doors and the protestor only offered "a minimum of 60dB of attenuation." Despite a sizable cost difference, agency determined that the failure to meet 80dB RF attenuation was enough to go a different direction. GAO denies protest.

GAO: Assisted Building Solutions, LLC, B-423895,B-423895.2 (Jan 08, 2026)

GSA's solicitation documents for the "next generation of Best-in-Class multi-agency contracts for complex non-IT services" are now live. Of note: even though it's a "continuously open model," it's mostly going to be first in, first out...

GSA: GSA Releases OASIS+ Phase II Open Continuous Request for Proposal Amendments with Additional Domains (Jan. 13, 2026)