Quick Takes

Similar to a decision a few weeks ago (Preference Pecking Order), with very minor factual differences, GAO reaffirms that Javits-Wagner-O'Day (JWOD) has preference over Rule of Two.

GAO: Magellan Solutions USA, Inc., B-424079 (Jan 29, 2026)

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."

GSA: Introducing the GSA 250 Commemorative Star Mark (Jan. 28, 2026)

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.

GAO: Bramstedt Surgical Inc., B-424064 (Jan 28, 2026)

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)

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)

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)

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)

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.

SBA OHA: SIZE APPEAL OF: UNCOMN, LLC, APPELLANT, SBA No. SIZ-6374 (Jan 22, 2026)

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)

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)