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A GSA Schedule Buy Must Be All Schedule

Client Alert | less than 1 min read | 02.07.05

In KEI Pearson, Inc. (Jan. 10, 2005), the GAO reaffirmed the rule "Non-FSS products may not be purchased using FSS procedures." There, GAO sustained the protest of a GSA schedule procurement because the awardee proposed to acquire certain commercial off-the-shelf software through a lower cost, non-schedule “alliance agreement” between the awardee and the software vendor, rather that proposing to use a more expensive GSA schedule vendor, of which there were many.

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Client Alert | 2 min read | 12.19.25

GAO Cautions Agencies—Over-Redact at Your Own Peril

Bid protest practitioners in recent years have witnessed agencies’ increasing efforts to limit the production of documents and information in response to Government Accountability Office (GAO) bid protests—often will little pushback from GAO. This practice has underscored the notable difference in the scope of bid protest records before GAO versus the Court of Federal Claims. However, in Tiger Natural Gas, Inc., B-423744, Dec. 10, 2025, 2025 CPD ¶ __, GAO made clear that there are limits to the scope of redactions, and GAO will sustain a protest where there is insufficient evidence that the agency’s actions were reasonable....