GAO Ups the Ante on Biased Ground Rules OCIs
Client Alert | 1 min read | 03.15.10
In Energy Systems Group (Feb. 26, 2010), GAO found that the agency had acted reasonably in excluding the protester from the competition because of concerns about a biased ground rules organizational conflict of interest ("OCI") when protester had previously prepared a feasibility study in anticipation of a potential sole-source award upon which the agency relied to develop approximately 80% of the requirements for the competitive procurement at issue. GAO rejected protester's arguments that (i) at the time protester prepared the feasibility study, a competitive procurement was not anticipated and, therefore, the study could not affect an unanticipated competition; (ii) protester was unaware that the feasibility study might be incorporated into the requirements for the competitive procurement; and (iii) the feasibility study was released to all prospective offerors.
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Client Alert | 5 min read | 06.05.26
The Office of Management and Budget issued on May 29, 2026 a Proposed Rule that would significantly revise the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 C.F.R. Part 200, potentially impacting the full lifecycle of federal grants, cooperative agreements and other forms of financial assistance, from pre-award merit review through post-award administration and termination. These proposed changes are designed to implement the President’s policy priorities, executive actions related to diversity, equity and inclusion (DEI) activities, and Executive Order No. 14332, Improving Oversight of Federal Grantmaking (EO 14332).
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