Strict Application Of Micro-Purchase Exception Sinks Award
Client Alert | less than 1 min read | 04.15.10
In Rapiscan Sys., Inc. (Mar. 15, 2009), a case handled by C&M, GAO sustained a protest of the award of a purchase order under a Federal Supply Schedule ("FSS") solicitation when the awardee's FSS contract did not include one of the solicitation's required line items. Although the awardee priced the non-FSS item at $0, GAO concluded that the micro-purchase exception did not apply, because the vendor's quotation also stated that the non-FSS item's price (which exceeded the $3,000 micro-purchase threshold) was included in the price of an FSS item.
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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.
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2025 GAO Bid Protest Annual Report: Where Have All the Protests Gone?
