Robert K Tompkins is Partner in Holland &
Knight's
Washington D.C. office
Mary Beth Bosco is Partner in Holland & Knight's
Washington D.C. office
Vijaya S Surampudi is Associate in Holland &
Knight's
Washington D.C. office
Contractors with corporate structures involving more than one
entity, such as parent and subsidiary, utilize multiple Commercial
and Government Entity (CAGE) Codes. A recent Government
Accountability Office (GAO) ruling is a caution to these
organizations. In the decision, GAO upheld an agency's
rejection of a proposal that used a CAGE Code of a subsidiary,
which differed from the offeror's CAGE Code, to satisfy the
RFQ's Facility Clearance (FCL) requirements. This case presents
yet another instance of GAO focusing on the precise legal identity
of offerors in its decisions.