Single Contract for Several New Services Does Not Violate Small Business Act’s Prohibition Against Unjustified Bundling The Government Accountability

Single Contract for Several New Services Does Not Violate Small Business Act’s Prohibition Against Unjustified Bundling The Government Accountability

Office denied a protest by Warrior Service Company based on the terms of an RFP issued by the Department of

Veterans Affairs. Warrior argued that the RFP impermissibly bundled several requirements that could be performed by small businesses, without proper justification and authorization.

The GAO disagreed, noting that bundling, for purposes of the Small Business Act, means “consolidating 2 or more procurement requirements for goods or services previously provided or performed under separate smaller contracts into a solicitation of offers for a single contract that is likely to be unsuitable for award to a small business.” Since Warrior did not identify two or more specific separate smaller contracts that have been combined, the GAO concluded that Warrior failed to allege sufficient facts that would constitute impermissible bundling under the Small Business Act.