The Government Accountability Office (GAO) has publicly released its recommendation sustaining the protest by ASM Research of a task order award by the Department of Veterans Affairs (VA) to Booz Allen Hamilton.
GAO determined that the VA failed to adequately consider a potential organizational conflict of interest (OCI) of the awardee based on the awardee’s performance of related task orders under the same overall program. The ASM Research decision demonstrates that, even after the Federal Circuit’s decision in Turner Construction, GAO will sustain an OCI protest where the agency’s evaluation fails to consider key facts or is otherwise not meaningful.
The ASM Research protest concerned a task order award for Mobile Infrastructure Services (MIS) under the VA’s Transformational Twenty-One Total Technology contract program. Through the MIS Task Order, the VA sought to procure hosting and maintenance of infrastructure, platforms, and tools for development, testing, and production of mobile applications related to healthcare.