Agency Failure to Consider Proposal Differences Invalidates Award
Client Alert | less than 1 min read | 07.06.11
In One Largo Metro LLC (June 20, 2011), GAO sustained three protests to a best value procurement for office space for HHS when GSA evaluated one of the technical subfactors in a manner inconsistent with the solicitation and failed to consider meaningfully the evaluated differences in the proposals. Regarding the latter protest ground, the source selection official, by disregarding the recommendations of the lower-level evaluators without explanation, did not conduct a well documented, meaningful consideration of the identified technical differences between the proposals and instead based her decision on a mechanical comparison of the subfactor ratings assigned by the lower-level evaluators.
Insights
Client Alert | 7 min read | 11.02.26
DOL Finalizes PBM Fee Disclosure Requirements
On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time.
Client Alert | 4 min read | 10.30.26
Client Alert | 3 min read | 10.29.26
What University Licensors Should Learn From TexasLDPC v. Broadcom
