Bid Protest (GAO)

A GAO bid protest is a written objection by an interested party to a solicitation or award, filed with the Government Accountability Office under CICA, 31 U.S.C. 3551-3557. Timely filing triggers an automatic stay, and GAO must decide within 100 days.

GAO hears protests under CICA on its regulations at 4 CFR part 21; FAR 33.104 covers the agency side. Timeliness is unforgiving: solicitation defects must be protested before the proposal due date, everything else within 10 days of when the protester knew or should have known the basis. Where a required debriefing is requested, the protester waits for it, then files within 10 days.

The stay is the leverage. Pre-award, the agency may not award while the protest is pending. Post-award, the contracting officer must suspend performance when GAO notice arrives within 10 days of award or 5 days after the offered debriefing date, whichever is later (31 U.S.C. 3553(d)). An override takes a written head-of-contracting-activity finding of urgent and compelling circumstances or the government's best interests, with GAO notified.

Two clocks run at once: a protest can reach GAO timely on day 10 and still miss the stay window, leaving the protester arguing while the awardee performs. Decisions issue within 100 days of filing, 65 under the express option.

Regulatory Reference

31 U.S.C. 3551-3557; 4 CFR Part 21; FAR 33.104

RFO Status

The Part 33 model deviation rebuilds agency protests at 33.104-4 with a 35-day best-effort resolution target and restates the stay at 33.105-3, and Part 33 is in the June 23, 2026 first-batch proposed rules, which drop the FAR's restatement of GAO procedure in favor of a pointer to 4 CFR part 21.

Category

Processes & Methods

How AcqBot Helps

AcqBot tracks the stay window on every award — 10 days from award, 5 from the offered debriefing date — flags protests that arrive inside it, and drafts the override determination and findings when the program cannot wait.