A-76 Mix And Match Faulted By GAO
Client Alert | less than 1 min read | 08.16.04
In Career Quest (Aug. 2, 2004), GAO sustained a protest of the GSA's decision under OMB Circular A-76 that it was more economical to continue performance of services in-house at the National Customer Support Center, as the agency evaluated the in-house offeror's technical performance plan based on a higher level of staffing than the same offeror included in its cost of performance. Inconsistencies between in-house offerors' staffing levels for compliance with work requirements and those it uses for calculating the cost of performance remain a persistent problem in A-76 competitions, and this decision sends the message that GAO will be alert to such shell games.
Insights
Client Alert | 3 min read | 08.18.25
FCPA Enforcement Continues to Evolve with Newly Unsealed Indictment
On August 11, 2025, the U.S. Department of Justice (“DOJ”) announced that it had unsealed an indictment against two Mexican businessmen for alleged violations of the Foreign Corrupt Practices Act (“FCPA”). DOJ asserts that the defendants, both Mexican nationals living in Texas, paid bribes to officials at Petróleos Mexicanos (“PEMEX”), and its subsidiary, PEMEX Exploración y Producción (“PEP”) to secure contracts worth an estimated $2.5 million. These charges come amidst a period of uncertainty regarding FCPA enforcement following the Trump administration’s temporary pause on FCPA enforcement and the subsequent issuance of new investigation and enforcement guidelines.
Client Alert | 3 min read | 08.18.25
Recent GAO Sustain Includes Valuable Lessons on Proposal Preparation and More
Client Alert | 6 min read | 08.14.25
Changes in Sunscreen Regulation & Litigation are Heating Up: Updates from Congress to the Courts
Client Alert | 3 min read | 08.14.25
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