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Case: B-424421 Agency: Department of Veterans Affairs : Department of Veterans Affairs Date: 2026-06-10 Dismissed
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B-424421,B-424421.2 Jun 10, 2026 Jump To FULL REPORT VIEW DECISION RELATED PAGES GAO CONTACTS Highlights The Gilchrist Law Firm, P.A. (GLF), a service-disabled, veteran-owned small business (SDVOSB) of Coral Gables, Florida, protests the rejection of the vendor's quotation under request for quotations (RFQ) No. 36C10B26Q0022, issued by the Department of Veterans Affairs (VA) for the provision of Freedom of Information Act (FOIA) compliance services. The agency rejected GLF's quotation because it was submitted past the time set for receipt of quotations and in a manner other than that prescribed by the solicitation. The protester challenges the agency's decision to reject its quotation. We dismiss the protest. View Decision Decision Matter of: The Gilchrist Law Firm, P.A. File: B-424421; B-424421.2 Date: June10, 2026 Jacquin P. Gilchrist, Esq., for the protester. Lolitha K. McKinney, Esq., and Mellany Alio, Esq., Department of Veterans Affairs, for the agency. Heather Self, Esq., and Peter H. Tran, Esq., Office of the General Counsel, GAO, participated in the preparation of the decision. DIGEST Protest challenging rejection of protester's quotation as late is dismissed as abandoned. DECISION The Gilchrist Law Firm, P.A. (GLF), a service-disabled, veteran-owned small business (SDVOSB) of Coral Gables, Florida, protests the rejection of the vendor's quotation under request for quotations (RFQ) No. 36C10B26Q0022,[1] issued by the Department of Veterans Affairs (VA) for the provision of Freedom of Information Act (FOIA) compliance services. The agency rejected GLF's quotation because it was submitted past the time set for receipt of quotations and in a manner other than that prescribed by the solicitation. The protester challenges the agency's decision to reject its quotation. We dismiss the protest. BACKGROUND On February 2, 2026, the agency issued the solicitation as an SDVSOB set-aside on the General Services Administration's (GSA) eBuy website to holders of federal supply schedule (FSS)[2] contracts under special item number 541611 seeking quotations for the provision of FOIA compliance services. AR, Tab 4a, Initial RFQ at 1; Tab 4e, RFQ amend. 4 at 35, 93, 104.[3] The solicitation contemplated issuance of a fixed-price FSS purchase order with a 1-year base period and three 1‑year option periods. AR, Tab 4e, RFQ amend. 4 at 37, 103. The solicitation established that award would be made on a best-value tradeoff basis considering two factors--technical and price--with the technical factor being significantly more important than price. Id. at 103. Relevant here, the solicitation provided the following instructions for submission of quotations: The Offeror's proposal[[4]] shall be submitted electronically by the date and time indicated in the Solicitation via the GSA website for GSA MAS in the files set forth below. Proposals submitted by any other method will not be considered. The URL is https://www.ebuy.gsa.gov. The Offeror's proposal shall consist of three (3) volumes. The Volumes are I--Technical, II--Price[,] III--Solicitation, Offeror and Award Documents. The use of hyperlinks or embedded attachments in proposals is prohibited. AR, Tab 4e, RFQ amend. 4 at 104. Additionally, the solicitation used bold typeface to caution vendors that late quotations would not be accepted for evaluation. Id. at 105. Specifically, the solicitation stated: WARNING: Please do not wait until the last minute to submit your proposals! Late proposals will not be accepted for evaluation. To avoid submission of late proposals, we recommend the transmission of your proposal file 24 hours prior to the required proposal due date and time. Please be advised that timeliness is determined by the date and time an Offeror's proposal is received by the Government not when an Offeror attempted transmission. Offerors are encouraged to review and ensure that sufficient bandwidth is available on their end of the transmission. Id. Vendor quotations in response to the solicitation were due by 3 p.m. Eastern Time on March 27, 2026. AR, Tab 4f, RFQ amend. 5 at 1. On March 27, at 3:05 p.m., GLF emailed the VA asking: “CO [Contracting officer], is there any way to extend the proposal deadline by an hour? We had a computer malfunction issue and couldn't upload the proposal to eBuy 4 minutes ago.” AR, Tab 6, Email Chain Between GLF and VA at 4; Protest at 2. At 4:49 p.m., still on March 27, GLF emailed again stating: “Ma'am, this is still in the draft section on eBuy as of 3:03PM.” Id. This statement was accompanied by a screenshot showing three files--Vol. I GLF; Vol. II Price-GLF; Vol. III--with associated “Uploaded” times of 3:06 p.m., 3:06 p.m., and 3:03 p.m., respectively. Id. The March 27 (4:49 p.m.) email also included three attachments, which the agency did not open, though the contracting officer expresses his “belief that they contained the proposal.” COS at 2-3.

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