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ARTICLE · 03 OCTOBER 2018

GAO Upholds Proposal Rejection Over Conflicting Cage Codes

Contractors with corporate structures involving more than one entity, such as parent and subsidiary, utilize multiple Commercial and Government Entity (CAGE) Codes.

United StatesGovernment, Public Sector

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.

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