Booz got "retracted"

Hey y'all—Two preliminary business items: (1) I have been writing these GAO / SBA / GSA snippets for a couple weeks now (at the bottom of the posts) and I am trying to decide whether to keep doing them. If they are interesting / useful to you and whether you'd like to receive them more frequently (i.e., daily), please email me at dave@tandemgov.com to let me know; (2) if you are someone who uses or needs public-sector procurement data, you might want to check out my product Tango. We published our first blog post this week about how we think about contracts, IDV, and awards data. I encourage you to check it out. And with that, on to the main event. Thanks as always for reading the latest GovContrActually.

About a decade ago, Booz Allen Hamilton won a contract to build a modernized USASpending.gov. As it would turn out, that project would be, relatively speaking, a major victory for transparency and agile software delivery. Today, however, BAH is no longer responsible for the project.

In ordinary times, that fact might be surprising enough. Outbidding a 10-year incumbent on a contract — particularly one that has had a relatively strong track record on the project - is no small feat.

But we are not in ordinary times. Because it appears that BAH didn't lose the contract for failure to perform or because of a poorly executed recompete. BAH lost because the USASpending work because it got "retracted."

I use the term "retracted" here because that word doesn't actually have a meaning in govcon. You see, on January 26, the Treasury department issued a press release that said the following:

Today, U.S. Secretary of the Treasury Scott Bessent announced the cancelation of all contracts with consulting firm Booz Allen Hamilton.

For operational contracting folks, this is kind of a weird sentence. In government contracting, you don't cancel a contract, you "terminate" the contract. You can cancel a solicitation, but not a contract. During peak DOGE era, “canceling contracts” became popular shorthand, even though insiders understood the government was really terminating them.

In government contracting, you also don't see termination of all contracts with a particular vendor as a class. You "suspend" or "debar" a vendor when the government deems a vendor to be a "non-responsible" contractor. I've written about debarment before. It's not especially common, but it happens.

Now, before I go any further. I want to take a moment and appreciate what Treasury is trying to do here. The government far too rarely holds vendors accountable for subpar performance on contracts. So to the extent that BAH "failed to implement adequate safeguards to protect sensitive data," as the Secretary claims, I'm not going to shed a tear for terminating contracts.

And, you know, what's really weird about this case is that Treasury had done debarment work in this case. According to SAM.gov records, Charles Edward Littlejohn—the guy who actually "stole and leaked the confidential tax returns and return information of hundreds of thousands of taxpayers"—was actually debarred in 2024. So, Treasury clearly knows how to do this sort of thing according to the book.

But, as far as I am aware, no suspension or debarment proceedings have been completed with BAH? And despite that, Treasury claims that it will terminate all of the contracts for BAH—in essence, achieving the effect of suspension and debarment—without following any of the typical process that comes with a suspension or debarment.

Which is why I say that BAH appears to have been retracted.

Now, this all may feel a bit like semantics, but the fact that normal processes didn't seem to apply here triggered a memory for me.

You see, back when I was at GSA in 2017, I remember the US District Court for the District of Columbia issued an opinion in a case entitled Friedler v. GSA that really surprised me at the time.

Friedler, for those who may be unfamiliar, was the CEO of a company called Symplicity Corporation until 2014 or so, until he pleaded guilty to crimes:

Friedler conspired with two other Symplicity employees between 2007 and 2011 to hack into the computer systems of two companies that competed with Symplicity’s business. Friedler and others decrypted account passwords of former customers, and Friedler hid his IP address using TOR, a network of computers used to encrypt and anonymize online communications. Friedler then accessed customer contacts and viewed the proprietary and confidential software design and features of competitors Maxient LLC and a second company, identified in court documents as "Company A," to inform Symplicity's software development and sales strategy.

Why did this matter to GSA? Because Symplicity was the vendor that ran FedBizOpps.gov. Yikes!

So, GSA debarred Friedler in 2015. And Friedler challenged it and the District Court found that "GSA disregarded the applicable regulations that require the agency to provide notice and an opportunity to be heard—a procedural misstep that rendered GSA's final debarment decision arbitrary and capricious as a matter of law." Friedler won. It was wild!

Anyway, I thought of Friedler v. GSA as I read the Treasury statement and the press that followed and I can't help but wonder whether BAH is going to make the a similar argument in court. Sure, there was a criminally breach of public trust some years before but, because if agency failed to follow applicable regulatory procedures, the action was unlawful.

It's possible they won't bother suing. After all, several colleagues observed that the $21 million at stake at Treasury for BAH is peanuts compared to their ~$6B in trailing 12-month obligations. Maybe it's not worth it to them to rock the boat further and let the Treasury department take the win. Who knows?

And, as one particularly smart colleague I spoke with noted, what happened here isn't actually a de facto suspension or debarment because there doesn't appear to be any prospective applicable at stake here... yet! Unless the Treasury department finds BAH to be a nonresponsible vendor going forward, it's not really a constructive suspension or a debarment. But if Treasury does prevent BAH from winning future awards, they'd have fresh grounds to challenge that decision. Kind of a tough spot?

In the end, the outcome here might very well be the right outcome. Vendors should be held accountable for serious security failures. The harm to 406,000 taxpayers was real. I am going to assume there's evidence behind the claim that BAH failed to implement adequate safeguards. And while it's naive to ignore the prospect that political retribution is at play here, its presence shouldn't be the only consideration either.

Maybe it's time we had a quicker path to suspension and debarment, or to formalize retraction processes? I'd welcome such a reform. Having a remedy that puts more pressure on vendors to deliver effectively without resort to future punishment seems like good policy that the govcon community should embrace.

But we should also insist on clearer rules and processes, to differentiate between legitimate use of termination, suspension, and debarment procedures and the murky version of retraction that we saw this week. I'll even take a practitioner album.

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GAO Protest Snippets

• 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. T3i, Inc., B-423815 (Dec 30, 2025)
• 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. Strategic Resources, Inc., B-423597.2,B-423597.3 (Jan 14, 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. Calvary Contracting, Inc., B-424024, (Jan 13, 2026)
• 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. Technology Information Systems, LLC, B-424087,B-424088 (Jan 26, 2026)
• A reasonable basis to cancel. Agency canceled a solicitation because it identified "conflicting evaluation criteria." Protestor argued that an amendment to the solicitation would have been adequate and that cancelation was aimed at avoiding protest. But GAO won't overturn a decision to cancel if the agency has a "reasonable basis" to do so. Protest denied. Centurion Analytics, LLC, B-423727.3,B-423727.4 (Jan 23, 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. Federal Missions Solutions, LLC, B-423584,B-423584.2 (Sep 04, 2025
• 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. GKG Contractors, LLC, B-423941,B-423941.2 (Jan 22, 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. Accenture Federal Services, LLC, B-423859,B-423859.2 (Jan 16, 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." Economic Systems, Inc.--Reconsideration, B-423747.3 (Jan 28, 2026)
• 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. Life Together Coaching, LLC, B-423989,B-423989.2,B-423989.3 (Jan 28, 2026)
• You still have to check SAM.gov. Department of Veterans Affairs put out a solicitation on SAM.gov for "surgical instrument maintenance and repair". Incumbent never saw the solicitation and, obviously, never proposed. GAO said that posting on SAM.gov was all that was needed. Incumbent also claimed that VA was required to keep doing purchase-card transactions under a previously cancelled solicitations. The VA and GAO disagreed. Also, the protestor used a lot of AI and got citations wrong and GAO was unamused. Bramstedt Surgical Inc., B-424064 (Jan 28, 2026)

SBA OHA Decisions

• 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. VSBC APPEAL OF: VIALYTIX, LLC, APPELLANT, SBA No. VSBC-462-A (Jan. 22, 2026)
• Remand requested, remand motion granted. SBA determined that UNCOMN was an "other than small business" for a solicitation with USTRANSCOM and UNCOMN appealed. On appeal, two competitors moved to intervene. Then, SBA requested remand because it "may have incorrectly calculated the firm's annual revenue." And OHA granted a remand over intervenor objections. SIZE APPEAL OF: UNCOMN, LLC, APPELLANT, SBA No. SIZ-6374 (Jan 22, 2026)

Other GovCon updates

• GSA has a new Star Mark. GSA has a "GSA 250 Commemorative Star Mark". You can see what it looks like. According to GSA's Logo Policy, "GSA Schedule vendors and contract holders are encouraged to use the commemorative Star Mark as well, to reinforce your important role in providing products and services to the federal government." Introducing the GSA 250 Commemorative Star Mark (Jan. 28, 2026)