Yesterday, the US Government Accountability Office (GAO) published a decision denying the protest of Lockheed Martin Integrated Systems (LMIS) and holding that agencies should evaluate the risks associated with proposals from contractors in the middle of corporate reorganizations that are "imminent and essentially certain" when making their award decisions. LMIS had filed its protest after being excluded from a competition for high performance computing modernization program integrated technical services when the US Army Corps of Engineers (Army) concluded it could not determine the realism of LMIS's costs and identified additional risks associated with the pending corporate merger involving LMIS and Leidos Holdings, Inc. (Leidos). The Army instead awarded the $575 million task order to Science Applications International Corporation (SAIC) for offering the best value to the government.

The GAO's decision highlights that agencies have discretion to consider information outside the four corners of the proposal. To view the decision, please click here.