GAO sustained ECS' protest of an Army Corps of Engineers RFQ on February 18, 2026 in B-423993, B-423993.2 — finding the Corps failed the reasonable-time standard. Per the GAO case page, Government Contracts Law, and National Law Review.
What the RFQ asked for
The Corps issued the RFQ on July 28, 2025 under FAR Part 13 simplified-acquisition procedures, seeking the lowest-price technically acceptable solution for replacement appliances at multiple Navy installations: microwaves, dehumidifiers, refrigerators.
What went wrong
Across the procurement, the Corps issued 10 amendments. Many contained material changes and unrealistic timelines. Amendment 0007 added refrigerator specs with a tight deadline. Amendments 0008–0010 went out late Friday evenings, Saturdays, and a Sunday — requiring revised quotes within a single hour in some cases.
GAO's holding
In its decision, GAO held that even in simplified acquisitions, agencies cannot sacrifice fair competition for speed — particularly where amendments are consequential enough to affect offeror eligibility. The Corps failed the reasonable-time standard because vendors had less than an hour to respond to substantive amendments and stringent product specs significantly altered the universe of compliant suppliers.
Remedy
- Amend the solicitation to provide vendors a reasonable response opportunity
- Evaluate revised quotations
- Make a new award decision
- Reimburse the protester for protest costs and reasonable attorneys' fees
What this means for COs
- "Simplified acquisition" doesn't suspend the reasonableness requirement
- Weekend amendments with sub-day response windows are now formally a sustainable protest ground
- Document why a tight window is necessary — bare-record CONOPS won't survive GAO scrutiny
