GAO Sustains DIA Task Order Award: Oral Presentation Evaluations Must Be Documented, Supported, and Evenhanded
In Amentum Technology Inc.; SOS International LLC, GAO sustained protests challenging the Defense Intelligence Agency’s evaluation and source selection for a time-and-materials task order supporting USCENTCOM’s Joint Intelligence Operations Center. The procurement was conducted under FAR subpart 16.5 and contemplated a one-year base period with four one-year options. Award was to be made to the highest technically evaluated proposal with a fair and reasonable price, based on a single technical factor (with subfactors) and a price reasonableness review.
A central feature of the acquisition was that technical proposals were delivered through oral presentations, consisting of common questions provided in advance and a scenario delivered at the time of the presentation. The agency assessed a “confidence level” (high/some/low) reflecting the government’s confidence in the offeror’s ability to perform with varying degrees of government intervention. The evaluation produced “High Confidence” ratings for GDIT and SOSi and “Some Confidence” for Amentum, with evaluated prices clustered in a narrow band relative to the overall acquisition value.
GAO sustained for two core reasons that matter to contractors competing in oral-presentation-heavy competitions. First, GAO found the record did not support DIA’s negative finding against SOSi tied to an alleged reference—during a specific question response—to a legacy CENTRIXS variant viewed as obsolete. DIA had audio-recorded the oral presentations, yet did not point to any portion of the recording substantiating the asserted reference, and GAO’s own review of the audio for that segment found no mention of the system as alleged. GAO reiterated a long-standing principle: when an agency cannot provide documentary support for an evaluation conclusion, it “bears the risk” that the determination will be deemed unsupported.
Second, GAO sustained Amentum’s disparate treatment challenge concerning how DIA credited “upskilling” of the incumbent workforce. GAO rejected the theory that the agency relied on an unstated evaluation criterion or improperly “double/triple counted” upskilling, reasoning that workforce development, hiring rigor, training, and transition were logically encompassed by the solicitation’s questions and the stated technical evaluation framework. However, GAO agreed that the contemporaneous record did not support DIA’s sharp distinction between GDIT and Amentum on training and workforce development. Notably, GAO pointed to audio evidence indicating both offerors described comprehensive training approaches and that Amentum explicitly used the term “upskilling,” undercutting the agency’s negative conclusion.
For federal contractors, the decision underscores three operational lessons. Oral presentations should be treated as a record-building exercise: structure answers to map cleanly to evaluation prompts, and—when permitted—ensure the presentation is internally consistent and readily “citable” if recordings or transcripts become the determinative record. Second, where agencies record orals, offerors should be prepared to challenge evaluation findings that are not anchored to the recording or contemporaneous notes. Third, the case illustrates how GAO will distinguish between (i) an agency permissibly considering an issue “logically encompassed” by stated criteria and (ii) an agency applying unequal scrutiny across offerors—a fertile ground for protest when the record shows comparable content treated differently.
GAO recommended reevaluation consistent with the solicitation, adequate documentation, and termination for convenience if a different offeror is selected, and awarded protest costs.
GAO Decision: Amentum Technology Inc.; SOS International LLC, B-423898; B-423898.2; B-423898.3; B-423898.4 (Jan. 27, 2026).
Disclaimer: This article is for general informational purposes only and does not constitute legal advice. It does not create an attorney-client relationship. Readers should consult qualified counsel for advice regarding any specific procurement, proposal, or protest strategy.