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GSA Transactional Rule Pilot Program – Understanding the Seismic Shift

Client Alert | less than 1 min read | 08.29.16

The GSA’s Transactional Data Rule Pilot Program has been rolled out for certain schedules, but many questions remain for contractors, including the logistical challenges related to the monthly compilation of data, the ability of GSA contracting officers to compare products and services accurately as the agency moves from commercial pricing to horizontal pricing analysis, and the areas of potential liability under this new program. This article by C&M attorneys, published in Bloomberg BNA, provides a detailed explanation of the new rule and practical considerations for government contractors.

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Client Alert | 3 min read | 07.10.26

Federal Circuit Clarifies Application of Blue & Gold: Proposal Submission Deadline, Not Award, is the Operative Time for Filing

In Utech, Inc. v. United States, No. 24-1586 (Fed. Cir. June 24, 2026), the U.S. Court of Appeals for the Federal Circuit clarified that in most cases, a pre-award protest must be filed before the proposal submission deadline to avoid the Blue & Gold waiver rule.  This decision, while nonprecedential, is in line with U.S. Government Accountability Office (GAO) precedent, which has long held that pre-award protests must be filed before the proposal submission deadline....