GAO decisions/Dismissed/Decided 1 Aug 2025
Integral Federal, Inc.
DoD task order below the $35 million jurisdictional threshold
The procurement
The Army competed a research and development services task order under its Responsive Strategic Sourcing for Services (RS3) multiple-award IDIQ. The SURVICE Engineering Company, LLC proposed $39,166,805, but before award the Army determined certain labor categories were no longer required and issued the order at $28,551,706.
The protest
Integral challenged the evaluation and argued the Army violated FAR 15.206(a) by dropping labor categories without amending the solicitation. On jurisdiction, Integral argued that SURVICE's $39,166,805 proposed price exceeded GAO's threshold and, given the alleged FAR 15.206(a) violation, was the amount GAO should use.
The agency’s answer
The Army requested dismissal for lack of jurisdiction. It argued that the task order's awarded value of $28,551,706, not the awardee's proposed price, controls, and that value falls below the $35 million threshold for task orders under DoD IDIQ contracts.
What decided it
Jurisdiction turns on the order's awarded value; a protester can't bootstrap it by arguing the price should have been higher.
GAO dismissed the protest for lack of jurisdiction. For task orders under DoD IDIQ contracts, GAO has jurisdiction only if the protester alleges the order increases the IDIQ's scope, period or maximum value, or if the order is valued in excess of $35 million, and the default rule is that value is the amount of the award. Integral could not use its FAR 15.206(a) merits argument to substitute the awardee's higher proposed price.
“In sum, the protester cannot 'bootstrap' the task order jurisdiction threshold to the merits of its protest based on an alleged regulatory violation. The awarded value of the task order here is below the $35 million threshold; accordingly, our Office does not have jurisdiction to consider the protest.”
GAO, B-423672
For the file: For DoD orders, GAO measures jurisdiction by the value of the issued order, not the awardee's proposed price, so a descoped award under $35 million puts the protest outside GAO no matter how strong the merits argument.
Authorities: 10 U.S.C. § 3406(f)(1). 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!