Washington, DC 20548

441 G St. N.W.

Washington, DC 20548

Comptroller General

of the United States

DOCUMENT FOR PUBLIC RELEASE

Decision

The decision issued on the date below was subject to

a GAO Protective Order. This version has been

approved for public release.

Matter of:

DLH, LLC

File:

B-424528; B-424528.2; B-424528.3

Date:

August 31, 2026

Holly A. Roth, Esq., Terry L. Elling, Esq, Tanner N. Slaughter, Esq. and Ben R. Smith,

Esq., Holland & Knight LLP, for the protester.

William M. Jack, Esq., and David T. Hickey, Esq., Dickinson Wright, PLLC, for Dynanet

Corporation, the intervenor.

Brandon Dell’Aglio, Esq., and Karyne C. Akhtar, Esq., Department of Health and Human

Services, for the agency.

Christopher Alwood, Esq., and Alexander O. Levine, Esq., Office of the General

Counsel, GAO, participated in the preparation of the decision.

DIGEST

Protest of a sole-source bridge task order for critical information technology services,

placed against a federal supply schedule contract, is denied where the need for the

services was of such unusual urgency that following the federal supply schedule’s

competitive ordering procedures would result in unacceptable delay.

DECISION

DLH, LLC, of Bethesda, Maryland, protests the Department of Health and Human

Services (HHS), National Institutes of Health’s (NIH) issuance of a 3-month task order

on a sole-source basis to Dynanet Corporation, of Elkridge, Maryland, for information

technology (IT) and information security services in support of NIH’s Office of Innovation

and Information Technology (OIIT). DLH contends that the sole-source task order

lacks a legal basis and arises due to a lack of advanced planning by the agency.

We deny the protest.

BACKGROUND

NIH’s OIIT is responsible for providing IT support for more than 3000 employees in

NIH’s Office of Research Services (ORS) and Office of Research Facilities (ORF).

Agency Report (AR), Tab 1.12, Request for Quotations (RFQ) No. C-120673-SB,

Statement of Work (SOW) at 1. 1 This support includes project management, application

development and operations, application hosting services, desktop support, customer

care, network account administration, internet and intranet services, network resource

management, web development, and IT security. Id. As relevant here, OIIT provides

network application hosting, desktop support, and information security for two IT

environments, NIH’s Enterprise Network and its Facilities Network (FACNet). Id. at 2.

Support for NIH’s FACNet includes network and IT security engineering for ORS and

ORF’s industrial control systems. Id.

For more than a year, NIH has been attempting to issue a task order, on a competitive

basis, for IT services to assist OIIT in meeting its mission requirements to provide IT

support to ORS and ORF. Specifically, in May 2025, NIH issued RFQ

No. C-120673-SB to firms holding contracts under the NIH Information Technology

Acquisition and Assessment Center (NITAAC) Chief Information Officer-Solutions and

Partners 3 small business (CIO-SP3 SB) governmentwide acquisition contract (GWAC).

Contracting Officer’s Statement (COS) at 1. The RFQ contemplated the issuance of a

task order to provide application development, network services, end-user support, and

project management services for a 1-year base period and two 1-year option periods.

AR, Tab 1.12, RFQ No. C-120673-SB, SOW at 1, 3. On July 3, 2025, the agency

issued a task order to Dynanet. COS at 1. DLH and another disappointed vendor

protested the issuance of the task order and the agency promptly notified our Office that

it intended to take corrective action by reevaluating quotations and making a new

source selection decision. Emagine IT, Inc., B-423719, Aug. 8, 2025 (unpublished

decision); DLH, LLC, B-423719.2, B-423719.3, Aug. 8, 2025 (unpublished decision).

Our Office dismissed the protests as academic. Id.

The agency reevaluated quotations and, on May 4, 2026, again issued a task order to

Dynanet. COS at 1. DLH and the other disappointed vendor again protested the

issuance of the task order. Emagine IT, Inc., B-423719.4, June 4, 2026 (unpublished

decision); DLH, LLC, B-423719.5, June 4, 2026 (unpublished decision). In response to

these protests, the agency notified our Office that it intended to take corrective action by

cancelling the solicitation, reconsidering NIH’s requirements, and conducting a new

competitive procurement to meet the requirement. Req. for Dismissal, B-423719.5,

May 29, 2026.

DLH served as the incumbent contractor providing these IT services in support of ORS

and ORF. AR, Tab 1.5, DLH Incumbent Contract; see also Protest at 2; Memorandum

of Law (MOL) at 2. DLH’s incumbent task order supporting the instant requirement

expired on May 18. AR, Tab 1.5, DLH incumbent Task Order at 2. On May 19, NIH

executed a sole-source justification (SSJ) to issue a noncompetitive, federal supply

Some documents in the agency report do not contain a uniform set of page numbers.

For clarity, unless otherwise noted, all citations to the record are to the consecutive

numbering of the pages in the Adobe PDF documents provided by the agency.

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schedule (FSS) task order for a 3-month base period and three 1-month option periods.

AR, Tab 1.1, SSJ at 1.

The SSJ cited General Services Acquisition Regulation (GSAR) 538.7104-3(b)(1)(i) as

authority to issue an FSS sole-source order, explaining that the “need is of such

unusual urgency that following the procedures would result in unacceptable delays in

fulfilling that need.” 2 Id. at 2. On May 19, the same day the SSJ was executed, NIH

issued the sole-source task order at issue here to Dynanet. AR, Tab 1.4, Sole-Source

Task Order. The $3.6 million task order covers a 3-month base period with three

1-month option periods. Id. at 2; AR, Tab 1.11, Performance Work Statement at 2. On

May 26, DLH filed the instant protest challenging the sole-source task order. See

Protest. On June 4, DLH filed a supplemental protest after it had reviewed the agency’s

SSJ. See Supp. Protest.

DISCUSSION

The protester raises various challenges to the issuance of the short-term, sole-source

task order to Dynanet. While our decision does not address every argument, we have

reviewed all the arguments and, as explained below, find no merit to DLH’s objections

to the short-term, sole-source contract.

Interested Party

As an initial matter, NIH and the intervenor argue that DLH is not an interested party to

challenge the agency’s decision to issue the task order on a sole-source basis. Based

on the record and facts before us, we find that DLH is an interested party to challenge

the order.

Under the bid protest provisions of the Competition in Contracting Act of 1984 (CICA),

only an interested party may protest a federal procurement. That is, a protester must be

an actual or prospective bidder or offeror whose direct economic interest would be

affected by the award of a contract or the failure to award a contract. 4 C.F.R.

§ 21.0(a)(1). A protester is not an interested party where it would not be eligible to

receive a contract award were its protest to be sustained. See C3.ai, B-421337,

B-421337.2, Feb. 16, 2023, at 4. Determining whether a party is interested involves the

consideration of a variety of factors, including the nature of the issues raised, the benefit

of the relief sought by the protester, and the party’s status in relation to the

HHS adopted the updated version of Federal Acquisition Regulation (FAR) part 8,

issued as part of the Revolutionary Far Overhaul (RFO), through a class deviation.

HHS FAR Class Deviation 2025-09, amend. 1. For clarity in this decision, citations to

each set of regulations will use the abbreviations “FAR” and “RFO” as appropriate.

Under the RFO, when placing an FSS order, agencies are required to follow the

procedures set forth in GSAR subpart 538.71. RFO 8.401(b). Similar procedures had

previously been set forth in FAR subpart 8.4.

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procurement. RELM Wireless Corp., B-405358, Oct. 7, 2011, at 2. Whether a protester

is an interested party is determined by the nature of the issues raised and the direct or

indirect benefit or relief sought. Id.

The agency argues that DLH is not eligible to receive the task order because the order

was issued as a small business set-aside under FSS special item number (SIN) 54151,

and DLH is not a small business that holds an FSS contract with that SIN. Agency Req.

for Dismissal, June 2, 2026; Agency Resp. to Intervenor’s Req. for Dismissal at 1-2.

However, the agency did not explain why, if this protest were to be sustained, it would

be required to procure a replacement bridge task order from a small business under

FSS SIN 54151. 3 Further, the agency did not demonstrate that it would be prohibited

from issuing a task order to DLH to meet this requirement under the procurement

vehicle the agency used in the prior competitive solicitation for this requirement, the

CIO-SP3 SB GWAC. 4 In short, we see no basis to conclude that the agency could not

reprocure the requirement using a different acquisition strategy, and if the agency did

so, that DLH would necessarily be ineligible to receive the task order. 5

The agency does not explain how this non-competitive acquisition qualifies as a small

business set-aside rather than simply a sole-source order to a firm that happens to be a

small business concern. The agency also did not specifically represent that, if the

protest were sustained, it would seek to procure a task order set aside for that SIN.

3

NIH’s CIO-SP3 SB website states that the ordering period for the GWAC runs through

October 29, 2026, with an ordering period of performance through October 2031.

CIO-SP3 SB IT Services/Solutions, NITAAC, https://www.nitaac.nih.gov/gwacs/cio-sp3small-business (last accessed August 19, 2026).

4

In support of its arguments, the agency cites several of our decisions for the principle

that a protester is not an interested party to challenge an FSS procurement if it does not

hold an FSS contract with the required SIN. See, e.g., Agency Resp. to Intervenor’s

Req. for Dismissal at 2 (citing Manhattan Telecommunications Corp., LLC, B-423414,

B-423414.2, June 30, 2025; BAO Systems, LLC, B-421561.13 et al., Apr. 10, 2024).

However, the facts of those protests are distinguishable from the facts here.

Specifically, in both Manhattan Telecommunications and BAO Systems, the agency

conducted a competition to establish a blanket purchasing agreement under an FSS,

instead of, as here, where the agency conducted a sole-source procurement. In both

cases, we found that the protester was not an interested party to challenge the agency’s

source selection decision because it was not eligible for award under the terms of the

relevant competitive solicitation. Manhattan Telecommunications, supra at 5-6; BAO

Systems, supra, at 11. Accordingly, in each of these cases, there were other eligible

vendors that had participated in the competition such that, were the protests sustained,

the protesters would still not be next in line for award. Here, the protest does not

challenge a competitive procurement and there is no next-in-line vendor in place.

Rather, DLH’s protest challenges the agency’s decision to conduct a sole-source

procurement, meaning that a successful protest would necessarily result in the agency

having to use another acquisition strategy to fulfill the requirement. We further note that

(continued...)

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The intervenor also argues that DLH is not an interested party because it does not have

qualified staff available with the necessary personal identity verification (PIV) credentials

to perform the required services without interruption. Intervenor’s Req. for Dismissal

at 2-5. The intervenor bases this argument, in part, on NIH’s SSJ, which stated that

Dynanet was “uniquely positioned” to perform the bridge contract because it “has

technically qualified staff available immediately with the necessary [PIV] credentials” to

access NIH facilities and IT systems. Id. at 3 (quoting AR, Tab 1.1, SSJ at 2). Dynanet

contends that “NIH’s rationale that only Dynanet could meet these specific [bridge

contract] requirements” in the necessary timeframe meant that DLH is not a prospective

offeror eligible to compete for the bridge task order. Id.

In response to the request for dismissal, DLH argues that it can meet the requirements

of the bridge task order separate from its expired incumbent task order. Protester’s

Resp. to Intervenor’s Req. for Dismissal at 6. In this regard, DLH asserts that its

employees--through their work on a separate NIH task order--performed critical portions

of the bridge task order requirements on May 19 and 20 after DLH’s incumbent contract

had expired but before Dynanet began performance on the sole-source task order.

Protester’s Resp. to Intervenor’s Req. for Dismissal at 6. The protester explains that it

is currently performing an IT task order for NIH’s Office of the Director through which it

has qualified IT personnel with access to PIV credentials and NIH systems. Id.; Protest,

Exh. 4a, DLH Task Order.

Without more, we fail to see how the bridge task order requirements are so restrictive

that it would be impossible for DLH--which had been performing the services at issue

before the bridge task order was issued--to meet them. Based on the protester’s

representations regarding its other NIH IT contract, we find that the intervenor has failed

to demonstrate that DLH is incapable of providing qualified staff that can obtain PIV

credentials to access NIH IT systems and facilities. Further, we note that the SSJ did

not rely on the sole-source authority that only one source was capable of performing the

requirement. In this regard, while the agency stated Dynanet was “uniquely positioned

to provide urgent support[,]” we read this within the context of the SSJ as indicating that

Dynanet was best suited to meet the unusually urgent requirement. AR, Tab 1.1, SSJ

at 2. Had this statement been intended as a finding that other vendors could not

perform the sole-source task order’s services, the agency presumably would have said

so and potentially cited the only one responsible source justification for the use of

noncompetitive procedures.

On this record, we find that neither the agency nor the intervenor has demonstrated

that, if the protest were sustained, DLH would not be eligible to receive a bridge task

(...continued)

in BAO Systems, the protest grounds alleging that the agency had unreasonably limited

competition were resolved on the merits and not dismissed based on the protester’s

interested party status. BAO Systems, supra, at 8.

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order for the requirement at issue. Accordingly, we conclude that the protester is an

interested party to protest the sole-source task order to Dynanet.

Timeliness

In its comments and second supplemental protest, the protester argues, for the first

time, that the agency improperly permitted Dynanet access to DLH employees so as to

later justify the sole-source task order to Dynanet. Comments & Second Supp. Protest

at 11-16. In this regard, DLH contends that the agency permitted Dynanet to begin

performance immediately upon the issuance of the May 4 competitive task order,

thereby giving Dynanet access to nonpublic, competitively useful incumbent workforce

and performance information. Id. at 12. DLH asserts that the agency failed to consider

whether such access constituted an impermissible organizational conflict of interest. Id.

at 15; Protester’s Resp. to Agency’s July 7 Req. for Dismissal at 5.

Under our Bid Protest Regulations, protests based on other than solicitation

improprieties must be filed within 10 days of when the protester knew or should have

known their basis. 4 C.F.R. § 21.2(a)(2). Further, our regulations do not contemplate

the piecemeal presentation or development of protest issues; where a protester raises a

broad ground of protest in its initial submission but fails to provide details within its

knowledge until later, so that a further response from the agency would be needed to

adequately review the matter, these later issues will not be considered. 22nd Century

Techs., Inc., B-413210, B-413210.2, Sept. 2, 2016, at 9.

Here, DLH likely was aware of Dynanet’s allegedly improper transition and onboarding

of employees no later than May 11, 2026, when DLH sent an email to the agency

expressing concerns regarding Dynanet’s attempted employee transitions prior to the

expiration of DLH’s incumbent task order. 6 AR, Tab 1.16, DLH Email to NIH, May 11,

2026. However, the record is clear that by May 20, the protester was certainly aware

that Dynanet had transitioned DLH employees, that the agency had issued a stop work

order related to the competitive task order, that Dynanet was still performing the

requirement for the agency, and that “NIH personnel were less than forthcoming about

the contract vehicle that permitted Dynanet’s performance[.]” Protest at 3. Further, the

record demonstrates that by May 26, DLH knew that the agency had issued the

The protester contends that the language of the May 11 email demonstrates DLH was

not aware Dynanet was conducting these transition activities with the agency’s blessing.

Protester’s Resp. to Agency’s July 7 Req. for Dismissal at 3. Curiously, despite

complaining that the agency did not file a copy of the contracting officer’s reply to DLH’s

May 11 email as an exhibit to the agency’s July 7 request for dismissal, DLH also did

not include a copy of the contracting officer’s reply in its response to that dismissal

request. See id. Given our conclusion below that this protest ground is untimely

regardless of what DLH knew on May 11, we need not review the agency’s response to

DLH’s May 11 email to resolve the protest.

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sole-source task order to Dynanet. Id.; Protest, Exh. 3, SAM.gov Posting for

Sole-Source Task Order at 2.

In sum, we find that the protester had all the information it needed to raise these protest

grounds no later than May 26. 7 Accordingly, DLH was required to raise these protest

grounds by June 5. Since DLH failed to raise them until it filed its second supplemental

protest on July 6, we dismiss these protest grounds as untimely.

Sole-Source Task Order

DLH contends that the agency failed to meet the applicable requirements to award a

sole-source task order under GSAR 538.71. Supp. Protest at 9-13; Comments &

Second Supp. Protest at 2-11. In this regard, the protester argues that NIH failed to

satisfy its requirement to obtain competition to the maximum extent practicable before

moving forward with the sole-source order to Dynanet. Comments & Second Supp.

Protest at 2-5.

We will review an agency’s justification for sole-source FSS orders to ensure they are

reasonable and in compliance with applicable statutory and regulatory requirements.

See, e.g., Castro & Co., LLC, B-419366, Jan. 25, 2021, at 4 (reviewing the use of a

limited sources justification under FAR subpart 8.4); XTec, Inc., B-405505, Nov. 8,

2011, at 3; STG, Inc., B-405082, B-405082.2, July 27, 2011, at 2-3. As discussed

below, we find nothing unreasonable in the agency’s determination that issuance of a

short-term, sole-source task order on an urgent basis was justified.

The sole-source task order at issue was placed against Dynanet’s FSS contract relying

on GSAR 538.7104-3. Orders and blanket purchase agreements placed under the FSS

are exempt from the competitive requirements of CICA and its implementing regulations

in FAR part 6. GSAR 538.7104-3; cf. Noble Supply & Logistics, B-417269, Apr. 30,

2019, at 8 (the issuance of BPAs and orders under FAR subpart 8.4 are generally

exempt from the competition requirements of CICA and its implementing regulations).

Nevertheless, the GSAR requires that an ordering activity “justify its action when

awarding on a sole[-]source basis.” GSAR 538.7104-3. For FSS orders that exceed

the simplified acquisition threshold, sole-source justifications “must be made in writing

and include sufficient detail and supporting rationale to support” the statutory exception

relied upon by the agency. GSAR 538.7104-3(b)(2). The GSAR sets forth five statutory

The protester maintains that it was not aware of the full extent of the agency’s

involvement in Dynanet’s allegedly improper transition activities until the agency filed its

report on June 24. Protester’s Resp. to Agency’s July 7 Req. for Dismissal at 5.

However, our decisions have repeatedly concluded that a protester need not await

perfect knowledge before filing a protest. See, e.g., Valkyrie Enters., LLC, B-414516,

June 30, 2017, at 3-4 n.2. Here, as discussed above, we conclude that DLH had all the

information it needed to raise the supplemental protest grounds at issue no later than

May 26.

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exceptions that support the placement of an FSS order on a sole-source basis,

including, as relevant here, when the “need is of such unusual urgency that following

the procedures would result in unacceptable delays in fulfilling that need[.]”

GSAR 538.7104-3(b)(1)(i).

Here, the SSJ cited the “unusual urgency” exception as authority to issue an FSS

sole-source order. AR, Tab 1.1 at 2. The SSJ recited the procurement history and

explained that this “short-term award is needed to ensure continuity of critical services

while [] NIH reconsiders its requirements and prepares for a new competitive solicitation

to be issued.” Id. The SSJ explained that continuity of services is necessary because,

without this specialized support, NIH will be unable to “sustain facilities, research

infrastructure, and specialized cybersecurity functions” including support of biosafety

containment labs and “high-consequence research sites[.]” Id. The SSJ also stated

that any gap in services “poses a direct threat to NIH safety and operations” because

the services support “mission-critical physical security, emergency response, and

campus infrastructure.” Id. The contracting officer determined that the 3-month base

period was meant to cover “the minimum period reasonably necessary to ensure that a

competitive solicitation can be developed and issued[,]” while the option periods were

meant to be a contingency for unanticipated delays. Id.

We see nothing objectionable in NIH’s issuance of a short-term, sole-source order to

Dynanet in light of the agency’s findings that the services were needed immediately and

that conducting a competition would take months. We find the agency’s justification to

be in line with GSAR 538.7104-3(b)(1)(i), which specifically authorizes restricting

competition where, as here, there is an urgent need such that following the FSS

ordering procedures would result in unacceptable delays.

DLH objects to the agency’s justification, arguing that, on May 19 and 20, its employees

performed the requirements at issue though “a separate, active contract vehicle at the

[a]gency’s direction.” 8 Comments & Second Supp. Protest at 4. The protester avers

that, because the agency’s critical short-term needs were being met through these

alternative means, there was no urgent need to issue a sole-source bridge task order to

meet the requirement. Id. However, the protester does not contend that this separate

vehicle (the other NIH task order) had been modified to include the bridge task order

work, or that there was otherwise a contract or task order in place with a scope that

included the services at issue. Therefore, we view DLH’s arguments here not as

challenging the cited urgent basis to issue the sole-source task, but rather as arguing

that the agency should have issued the bridge task order to DLH instead. Such

arguments do not demonstrate that it was unreasonable or contrary to statute or

regulation for the agency to issue the order to Dynanet. See Systems Integration &

The agency disagrees with the protester’s characterization of events, arguing that DLH

was not performing the requirements at issue on May 19 and 20. MOL at 5. Given our

conclusion above, we need not address this factual dispute in order to resolve the

protest.

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Mgmt., Inc., B-402785.2, Aug. 10, 2010, at 3 (that an agency can issue a sole-source

bridge task order on an urgent basis to an incumbent protester does not render the

agency’s decision to issue the order to another vendor unreasonable).

We are also unpersuaded by the protester’s argument that the agency was required to

obtain competition to the maximum extent practicable here. As an initial matter, we

note that the protester does not identify any specific requirement in the GSAR’s ordering

procedures that agencies obtain competition to the maximum extent practicable when

using the unusual urgency basis to issue a sole-source FSS order. To the contrary, the

GSAR’s general requirement to open competitions above the simplified acquisition

threshold to as many FSS contractors as practicable does not apply when “a

justification is executed and approved in accordance with [GSAR] 538.7107-3(b)[.]”

GSAR 538.7103-3(a).

The protester’s only legal basis for this argument derives from two of our Office’s

decisions discussing the sole-source justification requirements of CICA and FAR part 6.

Protest at 7-8; Comments & Supp. Protest at 5-6 (citing WorldWide Language

Resources, Inc.; SOS International Ltd., B-296993 et al., Nov. 14, 2005; Career Sys.

Dev. Corp., B-411346.11 et al., May 18, 2018). 9 However, as noted above, orders and

blanket purchase agreements placed under the FSS are exempt from the competitive

requirements of CICA and its implementing regulations in FAR part 6. 10

GSAR 538.7104-3; cf. Noble Supply & Logistics, supra at 8. Without more, we fail to

see how this argument demonstrates that the agency’s sole-source justification was

unreasonable or not in compliance with the regulatory requirements of

GSAR 538.7104-3

The protester also argues that NIH improperly relied on the unusual urgency basis as a

result of a lack of advanced planning. Protest at 8-10; Comments & Second Supp.

Protest at 6-9. CICA specifically provides that noncompetitive procedures may not be

used as a result of a lack of advanced planning by contracting officials. 41 U.S.C.

§ 3304(e)(5)(A)(i); RFO 6.103(b)(1). While FSS orders are not subject to the specific

competition requirements of CICA and FAR part 6, our Office has recognized that an

Notably, the Career Systems decision cited by the protester concerns a sole-source

justification based on the “only one responsible source available” exception to

competition, not an unusual urgency exception. See Career Sys. Dev. Corp., supra

at 3, 8-10. The protester does not explain how this decision is relevant to the facts

presented here.

9

FAR section 6.301(d), and the corresponding RFO section 6.103(c), generally require

contracting officers to “solicit offers from as many potential sources as is practicable

under the circumstances” when they are not obtaining full and open competition for the

government’s requirements. The applicable GSAR provisions, however, do not include

a similar requirement when an agency issues orders under the FSS on a

noncompetitive basis.

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agency similarly may not utilize non-competitive FSS procedures as a result of a lack of

adequate advance planning. Noble Supply & Logistics, supra at 8 (citing XTec, Inc.,

B-410778.3, Oct. 1, 2015, at 12, n.18). However, we do not consider an immediate

need for services that arises as a result of an agency’s implementation of corrective

action in response to a protest to be the result of a lack of advanced planning. RCG of

N.C., LLC, B-419691, June 24, 2021, at 6-7 (citing Systems Integration & Mgmt., supra

at 3.)

As described above, the record reflects that NIH tried to issue a long-term task order

competitively for the IT support services in support of OIIT. The SSJ explained that the

short-term, sole-source task order is necessary to allow the agency to implement

corrective action in response to the multiple protests received in response to the two

previous competitive awards. AR, Tab 1.1, SSJ at 3. Given that the delays in awarding

the long-term task order are due primarily to the agency’s reasonable implementation of

corrective action, we do not consider the sole-source task order at issue here to be the

result of a lack of advanced planning.

The protest is denied.

Edda Emmanuelli Perez

General Counsel

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