The Government Accountability Office has ordered the Army to reopen a solicitation for its Marketplace for Acquisition of Professional Services program after ruling the agency illegally barred small businesses from forming teaming arrangements. In a decision posted August 11, 2026, GAO sustained a protest filed by Intelligence Consulting Enterprise Solutions, Inc. (ICES), an Alexandria, Virginia small business, against the terms of Army solicitation W15P7T26RA006.
Background
ICES challenged the terms of the MAPS solicitation on four separate grounds before GAO issued its decision under case numbers B-424433.3 and B-424433.7. MAPS is designed to consolidate two existing Army services multiple-award task-order contract (MATOC) IDIQ vehicles into a single acquisition vehicle. That consolidation already narrows the field for firms that previously held a position on only one of the two predecessor contracts, since those firms would otherwise have competed for a smaller slice of the combined scope.
Layered on top of that narrower base of eligible small businesses, the solicitation as drafted permitted small businesses to pursue joint ventures but prohibited them from forming teaming arrangements — a distinct contracting structure under the Small Business Act in which a prime and one or more subcontractors combine capabilities without forming a new joint entity. ICES argued that barring one of the two statutorily recognized structures was unlawful and that the Army lacked discretion to make that call on offerors' behalf.
The distinction between the two structures matters to small businesses competing for large task-order vehicles because each carries different formation and compliance burdens. A joint venture typically requires the participating firms to establish a new legal entity, often registered separately with the Small Business Administration, before a proposal can be submitted. A teaming arrangement, by contrast, lets a prime contractor and its subcontractors pursue an award under a set of pre-negotiated agreements without creating a new entity. By eliminating the teaming option, the MAPS solicitation would have forced every small business that wanted to combine capabilities with another firm to absorb the additional overhead of forming a joint venture, regardless of whether that structure fit the firm's actual business arrangement.
ICES filed its protest challenging these terms before proposals were due, and GAO's bid-protest forum required the Army to respond to each of the four grounds raised. GAO's docket lists the case under two linked numbers, B-424433.3 and B-424433.7, reflecting supplemental protest filings tied to the same underlying solicitation.
GAO issues bid-protest decisions after each side files an agency report and comments, and it may sustain some grounds while denying others in the same decision — which is what happened here.
Key Details
GAO's decision addressed four grounds ICES raised and sustained only one of them. The agency denied ICES's arguments concerning the Army's solicitation-numbering and amendment-posting practices, denied a challenge to the solicitation's prohibition on using classified contracts as past-performance references, and denied a challenge to the adequacy of the Army's responses to more than 2,500 pre-proposal questions submitted by industry.
On the teaming-arrangement ground, GAO sustained the protest. The Army had defended the teaming prohibition by arguing that the Small Business Act's provisions at 15 U.S.C. §§ 644(e)(4)(A) and 644(q)(1)(A) — which reference small-business teaming and joint ventures using the word "or" — gave the agency discretion to permit one structure while excluding the other. GAO rejected that reading. The decision found that the statute places the choice between forming a team and forming a joint venture with the small business offeror, not with the contracting agency, and that nothing in the cited provisions authorizes an agency to eliminate one of the two options outright.
GAO also tied the teaming ban to the practical effect of MAPS' consolidation of the two predecessor MATOC-IDIQ vehicles. Because that consolidation already reduces competitive opportunities for small businesses that previously served only part of the combined scope, GAO found that layering a teaming prohibition on top of the consolidation ran contrary to the Small Business Act's underlying purpose of maximizing small-business participation in federal contracting. The decision separately noted that historical data in the record showed only 3 of 338 prior task-order awards under one of the two predecessor MATOC-IDIQ vehicles required classified performance, context GAO cited in denying the separate challenge to the classified past-performance restriction.
GAO's recommendation directs the Army to amend the MAPS solicitation to permit small-business offerors to submit as teams alongside the joint-venture option already allowed, and to reopen the procurement so that firms can submit revised proposals under the corrected terms. GAO also recommended that the Army reimburse ICES for the costs of pursuing the protest.
What It Means for Contractors
The decision reopens the MAPS competition to any small business that intends to pursue a teaming arrangement rather than a joint venture, giving firms that had structured — or were preparing to structure — their approach around a joint venture a chance to reconsider their teaming strategy once the Army issues the amendment. Firms that had already begun assembling joint ventures because the solicitation left them no other option should watch for the amended terms before finalizing partnership agreements, since a team arrangement may now be a viable and potentially less complex alternative.
More broadly, the decision reinforces a clear limit on how agencies structure competitions that combine multiple prior contract vehicles into one. Consolidating separate IDIQs into a single procurement is common practice, but GAO's reasoning here signals that agencies cannot pair that consolidation with additional restrictions on small-business teaming structures without running into the Small Business Act's participation-maximizing purpose. Contracting officers drafting similar consolidated solicitations elsewhere in the Army — or at other agencies pursuing comparable strategic-sourcing consolidations — should expect renewed scrutiny of any clause that forecloses either teaming or joint-venture options for small businesses, since GAO has now stated plainly that the choice belongs to the offeror.
For firms currently registered as interested offerors on MAPS, the practical next step is monitoring the solicitation for the Army's amendment implementing GAO's recommendation and the associated reopened proposal window. Firms that submitted proposals under the original teaming-restricted terms should anticipate an opportunity to revise their proposed team structure once the amendment is issued, rather than assuming their original submission stands unchanged.
