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Inadequate Documentation Dooms Cost Realism Evaluation

Client Alert | less than 1 min read | 02.14.12

In TriCenturion, Inc.; SafeGuard Services, LLC (Jan. 25, 2012), a case in which C&M represented one of the protesters, GAO sustained challenges to the agency’s determination that the awardee’s proposed labor costs were realistic in light of its technical approach, finding that the “inadequate” and “apparently incomplete” evaluation record, which the agency was unable to bolster through hearing testimony, failed to support the agency’s conclusions.  GAO also sustained challenges to the agency’s technical and past performance evaluations.

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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....