GAO decisions/Denied/Decided 16 Sep 2025
QED Systems, LLC
Offeror's burden to submit a complete, adequately written proposal
The procurement
The Army competed a support services task order under FAR subpart 16.5 among small business holders of its Responsive Strategic Sourcing for Services (RS3) multiple-award IDIQ, with an anticipated value over $35 million. Offerors had to submit a Volume III, Small Business Participation and Subcontracting Plan, and the plans were evaluated on an acceptable/unacceptable basis in part 1 of the evaluation.
The protest
QED did not submit a separate Volume III plan, but argued that its small business participation information appeared in multiple clearly marked places in its proposal, including its cost narrative. QED contended that eliminating its proposal over the missing volume elevated form over substance.
The agency’s answer
The Army said the Volume III plan was a material solicitation requirement, and the solicitation warned that if a complete proposal was not submitted by the closing time, it would not be considered for award. The agency rated QED's proposal unacceptable, making it ineligible for award, and eliminated it from the competition.
What decided it
Offerors bear the burden of submitting an adequately written proposal; evaluators need not hunt elsewhere for omitted material.
GAO denied the protest. A proposal must conform to the solicitation's material terms, and an offeror bears the burden of submitting an adequately written proposal. Because QED did not submit the required Volume III plan, the Army reasonably rated its proposal unacceptable and was not required to hunt through the cost narrative for the missing information.
“Our Office has consistently explained that offerors bear the burden of submitting an adequately written proposal, and 'contracting agencies evaluating one section of a proposal are not required to go in search of additional information that an offeror has omitted or failed to adequately present.'”
GAO, B-423634
For the file: If the RFP says a separate volume is required and incomplete proposals won't be considered, an offeror who scatters that content elsewhere risks elimination, and the contracting officer can enforce the requirement as written.
Authorities: FAR subpart 16.5. Read the decision at GAO →
Facts are condensed from the published decision and the quote is verbatim; the takeaway is ours. Where GAO decided several grounds, only this one is described.
Could you have called it?
Protest! is the daily game: three real GAO decisions, both sides laid out. Rule sustain, deny or dismiss, then pick what decided it.
Play today’s Protest!