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August 2023 Bid Protest Roundup: Former Government Employees; Buy American Act Waivers

This month’s bid protest roundup looks at two GAO protests from August. One examines the risks of using former federal employees to assist with proposal development when their prior access to non-public information might...more

Subcontracting To A Mentor-Protégé Joint Venture: Changes To How Small Business Subcontracting Goals Are Calculated

Recent changes to the U.S. Small Business Administration (SBA) regulations affect how large businesses can take small business credit for subcontracting to their own mentor-protégé joint ventures (MPJVs). SBA’s final rule...more

GSA Issues Multiple Award Schedule Solicitation Refresh 16: What It Means For Joint Ventures, Good And Bad

On May 19, 2023, the General Services Administration (GSA) issued Multiple Award Schedule (MAS) solicitation refresh 16, which introduced a formal offer process for joint ventures. To provide guidance on navigating those...more

Hard Validations And Cutlines: What Happened On CIO-SP4?

If you’ve been following the saga of the National Institutes of Health Information Technology Acquisition and Assessment Center’s (NITAAC) Chief Information Officer-Solutions and Partners (CIO-SP4) procurement, you likely...more

Clarifying Minor Errors: The Court Makes An Agency Seek A Clarification

Offerors whose proposals are disqualified for immaterial typographical and data input errors will want to read an interesting new protest decision from the Court of Federal Claims. In Aspire Therapy Services & Consultants,...more

When Does The So-Called TikTok Ban Really Apply To Contractors And Their Employees?

In the extensive chatter since the Federal Acquisition Regulatory Council (“FAR Council”) published an interim rule on the new Federal Acquisition Regulation (FAR) 52.204-27, “Prohibition on a ByteDance Covered Application,”...more

Challenging Unilateral Definitizations Of Undefinitized Contract Actions: What Is A Claim?

Forty-five years after enactment of the Contract Disputes Act of 1978 (CDA), contractors and agencies still often struggle to identify what is and isn’t a CDA claim—a term the CDA itself does not define. Until the CDA’s...more

Back To The Drawing Board: FAR Councils Withdraw Long-Delayed Proposed Rule For Lower-Tier Small Business Subcontracting Credit

Some of you may recall the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2014 from nearly a decade ago. It amended the Small Business Act (SBA) to allow a contractor, under certain circumstances, to receive...more

Joint Venture Member Experience: “Considering Each Member” Vs. “Considering Either Member”

The Government Accountability Office (GAO) has issued an important new decision in the protest of AttainX,Inc ., B-421216, B-421216.2, Jan. 23, 2023, 2023 WL 1860802. The decision addresses how agencies must evaluate the...more

Is Your Joint Venture Agreement Compliant With Current SBA Regulations And Current Case Law?

The Small Business Administration’s (SBA) popular shields from affiliation for all-small and mentor-protégé joint ventures are powerful tools for helping small businesses succeed in the federal procurement marketplace. These...more

A Bluer Shade Of Blue: All “Outstandings” Are Not Created Equal

A common mistake in competitive procurements is a mechanical fixation on the adjectival ratings, color ratings, or numerical “scores” a procuring agency assigns a proposal under a particular evaluation factor. In best value...more

Deciphering The GAO’S Bid Protest Statistics For FY 2022

Each year around this time, the U.S. Government Accountability Office (GAO) publishes its annual report to Congress on bid protests. Earlier this week, the GAO published the report for Fiscal Year (FY) 2022....more

Congress Passes Bill To Reauthorize SBIR/STTR Programs

As most experts expected, Congress has passed the bill to reauthorize the SBIR and STTR programs until September 30, 2025. The bill is now headed for the White House, where the President is expected to sign it into law....more

DOD Issues Guidance In Advance Of Possible Failure To Reauthorize The SBIR/STTR Program

As of this posting, Congress has not yet reauthorized the popular Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs. Given the broad bipartisan support for these programs, most...more

August 2022 Bid Protest Roundup: Affiliate Experience, JV Registration

In this month’s bid protest roundup, we consider: (1) an exception to the normal rule governing reliance on affiliate experience and past performance; and (2) two different bid protests of very similar solicitation terms that...more

“I Get By With A Little Help From My Friends”: Relying On Affiliate Past Performance And Experience

For evaluation purposes in a federal procurement, may an offeror rely upon the past performance and experience of its affiliates? The answer generally is a qualified yes, but the answer and the qualifications may change...more

New Small Business Regulation: Reliance On Past Performance Gained As A Subcontractor Or Joint Venture Member

The U.S. Small Business Administration (SBA) recently promulgated a final rule addressing past performance ratings for small business joint venture members and small business first-tier subcontractors. The rule, which will go...more

SBA Finalizes Changes In How To Calculate Size For Various Programs

Earlier this week, the U.S. Small Business Administration (SBA) issued a Final Rule adopting changes to how a concern calculates its number of employees for eligibility purposes in all of SBA’s programs, as well as how a...more

SEKRI, INC. V. United States: Are Pre-Proposal-Submission Email Exchanges Now Enough To Avoid Blue & Gold Waiver?

In the seminal decision Blue & Gold Fleet, L.P. v. United States, the U.S. Court of Appeals for the Federal Circuit held that “a party who has the opportunity to object to the terms of a government solicitation containing a...more

Five Million Reasons For Government Contracts Lawyers To Assist With The Acquisition Of Companies That Perform Government...

Due diligence is an important preliminary step before one company acquires another or an investor puts millions behind an existing firm. When a target company performs government contracts or subcontracts, it is critical that...more

DOD Adds Enhanced Post-Award Debriefing To The DFARS

Earlier this month, the U.S. Department of Defense (DOD) issued a final rule to add the 2018 National Defense Authorization Act’s enhanced post-award debriefing rights to the Defense Federal Acquisition Regulation Supplement...more

February 2022 Bid Protest Roundup: Key Personnel Changes, Agency Computer Glitches, And Ambiguous Solicitations

This month’s roundup considers three recent protests: (1) an important decision by the Court of Federal Claims rejecting controversial precedents of the U.S. Government Accountability Office (GAO) concerning key personnel...more

Unavailable Key Personnel: Differing Legal Standards At The GAO And Court Of Federal Claims

An interesting new bid protest decision from the U.S. Court of Federal Claims articulates a rule for pre-award key personnel unavailability that is very different from the one employed by the U.S. Government Accountability...more

Five Peculiarities Of Protests Of Federal Supply Schedule Protests

The General Services Administration’s Federal Supply Schedule contracts are an efficient method for agencies across the Government to meet their needs for many commercially available supplies and services. For requirements...more

Harmonia Holdings: Denied Pre-Award Protest Rises From The Dead Five Months Later As A Post-Award Protest

The U.S. Court of Appeals for the Federal Circuit has issued its long-awaited decision in Harmonia Holdings Group, LLC v. United States, vacating a bid protest decision the U.S. Court of Federal Claims rendered nearly two...more

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