News & Analysis as of

Rule of Two Government Accountability Office Department of Veterans Affairs

Pillsbury - Bid Protest Debrief

Risk Too High? GAO Says You Don’t Have to Bid

In Protection Strategies Etc. International, LLC, B-423539 (Aug. 25, 2025), Protection Strategies, a service-disabled veteran-owned small business (SDVOSB), filed a pre-award protest challenging the terms of a solicitation...more

Holland & Knight LLP

GAO Rules That Kingdomware "Rule of Two" Does Not Govern Leasehold Acquisitions Conducted by GSA on Behalf of VA

Holland & Knight LLP on

The U.S. Government Accountability Office (GAO) ruled on Dec. 20, 2019, that the "Rule of Two" of the Veterans Benefits, Health Care, and Information Technology Act of 2006 (VBA) does not require the U.S. General Services...more

Bradley Arant Boult Cummings LLP

The 3 Most Important Bid Protest Decisions Of 2018 - Law360

In 2018, three particularly important decisions were issued that will have a significant impact on bid protest law for years to come: Dell Federal Systems LP v. United States, PDS Consultants Inc. v. United States, and Oracle...more

Pillsbury Winthrop Shaw Pittman LLP

Kingdomware Revisited: VA’s “Rule of Two” Takes Priority Over AbilityOne

The U.S. Court of Appeals for the Federal Circuit finds the Department of Veterans Affairs’ (VA) Rule of Two takes priority over older and less specific statutory procurement mandates. The Federal Circuit found that the VA...more

Smith Anderson

Supreme Court Requires Many More VOSB Set-Asides

Smith Anderson on

On June 16, 2016, the United States Supreme Court ruled that the Department of Veterans Affairs (VA) must apply the “Rule of Two” in all contracting decisions in Kingdomware Technologies, Inc. v. United States, 136 S.Ct. 1969...more

Kilpatrick

Supreme Court Finds The Department of Veterans Affairs Violated Procurement Law – Are There Broader Implications for Government...

Kilpatrick on

On June 16, 2016 the Supreme Court of the United States (“SCOTUS”) issued its much anticipated decision in the Kingdomware Technologies, Inc. v. United States case (“Kingdomware”). One of two important cases, both decided on...more

Morgan Lewis

Supreme Court Requires the VA to Expand Use of Mandatory Set-Asides for VOSBs

Morgan Lewis on

The Department of Veterans Affairs will be required to implement mandatory set-aside requirements for procurements at all levels, including FSS orders, if two or more VOSBs reasonably can be expected to submit offers that...more

PilieroMazza PLLC

Kingdomware Vs. the VA: Supreme Court Case to be Dismissed?

PilieroMazza PLLC on

If you are already aware of the Kingdomware case, you will likely be surprised to hear that on November 4, 2015, the U.S. Supreme Court issued an order to the parties in the Kingdomware case to submit briefs on whether the...more

Sheppard Mullin Richter & Hampton LLP

Supreme Court to Hear VA Procurement Controversy This Fall

In a matter of keen interest to the small business community, last month the Supreme Court, granted certiorari in Kingdomware Technologies, Inc. v. United States. The Court’s decision will hopefully bring some closure to the...more

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