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No Match, No Deal In FSS Buy

Client Alert | 1 min read | 01.05.05

Reiterating once again that the exemption from full and open competition for orders placed under GSA’s Federal Supply Schedule contracts applies only to items and services in fact listed and priced in the FSS contracts, in American Sys. Consulting, Inc. (Dec. 13, 2004), GAO sustained a protest because the awardee’s Schedule contract description of education/experience and functional requirements for a particular job title did not match those for the RFQ position proposed to be filled. Neither the fact that the background of the individual proposed met the RFQ requirements nor the fact that the RFQ called for quotations citing the FSS job title that “mostly nearly equated” to the RFQ position cured the legal flaw, because the exemption from the competition requirements applies only to the items/services offered by the explicit terms of the Schedule contract.

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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....