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Fifteen GAO Decisions, One Clear Message: Precision Wins Protests
Over the last three weeks, the Government Accountability Office (“GAO”) issued fifteen bid protest decisions spanning agencies as varied as the Air Force, NASA, GSA, the VA, DHS, and even USASOC's live-goat training program. Taken individually, each decision resolves a narrow dispute over a specific solicitation. Taken together, they reveal a consistent pattern in how GAO evaluates protests and a clear roadmap for contractors who want to protest effectively, or avoid giving competitors grounds to protest against them. In the last two weeks, GAO issued a series of bid protest decisions that—taken together—highlight how contractors can win (or lose) based on things like how strictly agencies apply stated thresholds, how persuasive the proposal record is against the solicitation’s evaluation criteria, and whether protests survive timeliness and “abandonment” rules. Below are the 10 most contractor-relevant takeaways, each tied to a specific GAO case, and distilled into practical guidance you can use to improve proposal strategy, reduce risk in submissions, and understand what GAO looks for when deciding whether an agency’s evaluation and award decision will stand.
Last week (May 25-29, 2026), the GAO issued another five bid protest decisions, in which it reinforced several recurring procurement themes:
This report provides comprehensive analysis of seven Government Accountability Office (GAO) bid protest decisions issued between February 6 and May 21, 2026. These decisions collectively addressed procurements valued at approximately $1.4 billion and covered diverse sectors including information technology, professional services, facilities management, and defense operations.
The decisions reflect GAO's continued emphasis on strict procedural compliance, thorough evaluation documentation, and adherence to solicitation terms. Notably, the period saw a 29% sustain rate (2 of 7 decisions), slightly higher than GAO's typical 15-20% average, indicating particular agency vulnerabilities in evaluation consistency and documentation. By: Jake Noe and Brad Reaves
As we turn the calendar to a new year, now is the perfect moment to take stock of the GAO’s bid protest activity from 2025—and, more importantly, what it may signal for contractors heading into 2026. Below, we break down the numbers, highlight the most common grounds on which protests were sustained, and offer practical, nonlegal observations about how these trends could affect your business strategy. By: Brad Reaves and Jake Noe
The Department of Transportation (DOT) has issued a major interim final rule (IFR), effective October 3, 2025, that could significantly reshape both current and prospective Disadvantaged Business Enterprise (DBE) and Airport Concessions DBE (ACDBE) participants. This update highlights the key revisions and what they mean for your business. By: Jake Noe and Brad Reaves
If you’ve been following the Revolutionary FAR Overhaul, you’ve probably heard about the major rewrite of FAR Part 19. But if this update slipped under your radar, here’s what you need to know: on September 26, 2025, the Federal Acquisition Regulatory Council officially issued an overhaul to FAR Part 19 — a move with real implications for small business government contractors. By: Jake Noe and Brad Reaves
If you are a certified HUBZone small business — or a large business considering a joint venture with a HUBZone — the SBA has just made a significant regulatory change you need to know about. by: Paul Hawkins and Jake Noe On December 17, 2024, the SBA published a final rule that will likely have a major impact on HUBZone businesses. This final rule implemented four (4) major categories of changes that HUBZone business will have to need to comply with. Specifically, these four (4) changes related to the following topics: (1) definition of principal office; (2) definition of employee; (3)
By: Paul Hawkins and Jake Noe
To protest or not? This is a question many government contractors face frequently whether because they were not chosen for award of a contract or because they are facing unfair or unreasonable solicitation terms. This article is the first in a short series on protests where we will cover how and when a contractor can and should use available, formal protest/appeal processes to challenge an agency’s actions in connection with a procurement. We will cover pre- and post-award bid protests, how the procurement Q&A process and debriefings play into protests, where and how to file bid protests, differences in the available bid protest forums, and last, size and status related protests with the SBA (including NAICS appeals). |