GAO sustained Markon’s protest because CIA’s cost realism adjustment relied on oral “industry Q&A” instructions that were never incorporated into the final RFP. The decision reinforces a core rule for contractors: evaluation turns on the solicitation and the contemporaneous record, not informal guidance.

Solvere Technical Group (GAO B-423785) is a must-read staffing-plan decision: GAO sustained where Navy penalized an offeror for using “TBD” non-key personnel exactly as the solicitation directed and for relying on a six-month certification window the RFP expressly allowed. Key lessons for service contractors on unstated evaluation criteria and cost-risk “double counting.”

A 3-year synthesis of GAO’s Bid Protest Annual Reports (FY23–FY25): filings trends, sustain and effectiveness rates, the CIO-SP4 anomaly, and what recurring sustain grounds reveal about evaluation discipline, price/cost scrutiny, and proposal rejection risks—plus why protests still influence outcomes.

GAO’s Tiger Natural Gas (B-423744 et al., Dec. 10, 2025) sustained a protest because DLA’s heavily redacted record prevented GAO from confirming awardees’ technical acceptability under LDC authorization/experience requirements, while denying challenges to discussions conducted alongside a reverse auction.

GAO’s FY2025 Bid Protest Annual Report to Congress shows a 14% sustain rate, 52% effectiveness rate, and recurring sustain grounds—unreasonable technical evaluations, cost/price errors, and improper proposal rejections. Learn what the Air Force non-implementation case teaches contractors about timing, remedies, and building protest-ready proposals.

GAO’s decision in Valiant Government Services, LLC (B-423740) clarifies three recurring themes in task-order protests: when “strengths” must be credited, what equal treatment really requires, and when changing FTE levels trigger a duty to amend the solicitation.

GAO sustained IPRO’s protest of CMS’s QIN-QIO Region 1 award because CMS failed to document how the awardee met a prime-only eligibility test. Technical and tradeoff challenges were denied. The ruling highlights that JV/subcontractor structures must be reconciled to solicitation language and that contemporaneous analysis—not post-hoc rationales—controls.

GAO sustained ESI’s protest in a best-value facilities maintenance award, finding improper attribution and documentation of the awardee’s past performance and an inadequately reasoned tradeoff despite a small price advantage. The case underscores strict prime-only past performance rules, JV/affiliate pitfalls, and the need for qualitative tradeoffs.

GAO’s August 25, 2025 decision in PSEI v. DCSA reaffirms three pre-award baselines: agencies need not restrict non-VA buys to SDVOSB set-asides, firm-fixed-price unit rates are permissible with adequate history despite variable demand, and phase-in may be funded via the first task order with specific prerequisites. Key guidance for capture, pricing, and transition.

GAO’s UCIG decision (B-423682) reinforces strict protest timeliness and clarifies that clearly drafted pre-submission approvals like JCCS can be treated as material solicitation requirements, not post-award responsibility checks. It also narrows hopes for the “significant issue” exception, distinguishing Pernix’s impossibility scenario from routine compliance terms.

GAO denied Warfighter Focused Logistics’ protest over a DLA tire cross chains award, reinforcing strict timeliness rules, reliance on past performance data, and a heightened pleading standard requiring credible, evidence-backed allegations under the FY2025 NDAA.

The GAO issued a rare sustained protest in emissary LLC v. WHS, criticizing serious flaws in the agency’s evaluation and award decision. This rare victory underscores the importance of strict compliance with solicitation terms in federal procurement—and the value of the protest process as an accountability tool.

GAO denies 1st SBC’s protest over an IRS IT task order award to Agovx. Key issues included discussions fairness, compliance with RFP instructions, price realism, and past performance. The ruling reinforces best-value discretion and the need for showing prejudice.

GAO’s response to Section 885 of the FY2025 NDAA rejects protest cost penalties, proposes new pleading standards, and warns Congress of unintended harm to small businesses and competition.

GAO denies Brandan Enterprises’ protest over a visitor services task order at Arlington Cemetery, citing reasonable evaluation and meaningful discussions over labor hour deficiencies.

GAO denies protest by Quantum Research International alleging misrepresentation and flawed evaluation in Army RCCTO SETA task order award to PeopleTec. Decision clarifies material misrepresentation standards and best-value tradeoff discretion.

GAO denies SOS International's protest over Army's cyber task order, affirming the reasonableness of the oral presentation evaluation and exclusion from award. The case underscores FAR 16.5’s streamlined process and importance of meeting solicitation thresholds.