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ARTICLE · 19 AUGUST 2025

Recent GAO Sustain Includes Valuable Lessons On Proposal Preparation And More

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GAO's recent sustain of the protest filed by emissary LLC provides valuable lessons for potential offerors with respect to organizational conflict of interest (OCI) mitigation plans...

United StatesGovernment, Public Sector
Amy Laderberg O'Sullivan
Amy Laderberg O'Sullivan
Cherie J. Owen
Cherie J. Owen
Issac D. Schabes
Issac D. Schabes

GAO's recent sustain of the protest filed by emissary LLC provides valuable lessons for potential offerors with respect to organizational conflict of interest (OCI) mitigation plans (and their impact on technical approach), as well as their descriptions of key personnel qualifications.

In response to two rounds of earlier protests challenging purported OCIs, the agency conducted two rounds of OCI investigations of the awardee, Gemini. In connection with these investigations, the agency found that Gemini's work providing subject matter expertise and knowledge-based services in support of the United States Special Operations command (USSOCOM) raised the potential for an OCI. The agency requested—and Gemini provided—an OCI mitigation plan, which Gemini subsequently amended at the agency's request. After the agency completed its second round of corrective action and again awarded to Gemini, emissary protested again.

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