Offeror Gets Booted For Not Using Mandatory Spreadsheet
An offeror for a federal government contract didn't use the solicitation's required format to submit its pricing--and got kicked to the curb.
An offeror for a small business set-aside competition did not use the Microsoft Excel pricing spreadsheet required by the solicitation—and got booted out of the competition as a result.
In a recent bid protest decision, the GAO suggested that the offeror’s failure to use the mandatory spreadsheet, by itself, was enough to justify the offeror’s exclusion, regardless of whether the offeror provided the same information in another format. In this article, I examine the GAO’s decision and offer some takeaways for federal government contractors.
The Solicitation, Proposal & Evaluation
The GAO’s decision in Supplying Demand, LLC, B-423810; B-423810.2 (2025) involved an FBI solicitation seeking contractors to provide various types of tactical equipment and related incidental services. The FBI issued the solicitation as a small business set-aside and intended to award multiple IDIQ contracts, referred to as the agency’s strategic tactical equipment acquisition and logistics (STEAL) contracts.1
The solicitation stated that award would be made on a best-value tradeoff basis considering three factors: technical merit, past performance, and price. With respect to the price factor, the solicitation instructed offerors to use a Microsoft Excel spreadsheet, which was attached to the solicitation as Attachment 1, to prepare their price proposals.
The solicitation cautioned offerors that “[t]he pre-formatted spreadsheet(s) is the ONLY acceptable method of returning the Price Proposal(s)” and that “[v]endors should not change the format in the spreadsheet(s), as any vendor changes to the spreadsheet format may adversely impact the evaluation of their price proposals.” Elsewhere, the solicitation warned offerors that, with respect to all aspects of their submissions, “[p]roposals that do not provide the required information in the prescribed format as outlined in this [RFP] could be considered non-compliant and ineligible for award.”
Supplying Demand, LLC, a service-disabled veteran-owned small business, submitted a proposal. Supplying Demand did not use Attachment 1 to prepare its price proposal. Instead, in the words of the GAO, Supplying Demand “submitted a spreadsheet with three tabs: tab 1 labelled STEAL RFQ (from attachment 3, STEAL RFQ), tab 2 labelled incidental service (from attachment 1, price proposal spreadsheet), and tab 3 labelled vendor monthly report (also from attachment 3, STEAL RFQ).”2
The FBI informed Supplying Demand that its proposal had been eliminated from the competition because Supplying Demand had failed to comply with the terms of the solicitation. In an email notifying Supplying Demand of its elimination, the Contracting Officer explained:
Your submission is not on the correct form which prohibits any price comparison. . . The submission is not on the correct attachment which I have also included. The form you submitted appears to be a mix of all the attachments.
Supplying Demand filed an agency-level protest, arguing that its proposal had been complete and responsive. Supplying Demand requested that the agency resolve its protest within three days. When the FBI informed Supplying Demand that it would not resolve the agency-level protest within this time frame, Supplying Demand filed a bid protest with the GAO.
The GAO’s Decision
In its GAO bid protest, Supplying Demand argued, in part, that its proposal had been compliant with the solicitation. Supplying Demand did not allege that it had used Attachment 1 but contended that its proposal contained the same information as would have been provided on Attachment 1.
The GAO began its analysis by restating its longstanding position that:
It is an offeror’s responsibility to submit a well-written proposal, with adequately detailed information that clearly demonstrates compliance with the solicitation requirements and allows a meaningful review by the procuring agency.
In this case, the GAO wrote, the solicitation “required offerors to use attachment 1, price proposal spreadsheet, to prepare price proposals,” and stated that Attachment 1 was the “ONLY” acceptable method of returning price proposals. Additionally, the solicitation cautioned offerors that failing to follow the prescribed proposal format could result in the proposal’s exclusion.
The GAO reiterated that Supplying Demand had not used Attachment 1, then continued:
While the protester contends that the FBI should have accepted Supplying Demand’s proposal because “[e]very [price evaluation list] field is accounted for [in its proposal],” the protester’s position disregards the terms of the RFP. For one, the solicitation required offerors to use attachment 1, price proposal spreadsheet. In addition, the RFP provided that failing to submit information in the prescribed format could result in the proposal being rejected.
To me, this is perhaps the most important statement in the GAO’s decision. It suggests that the FBI was justified in excluding Supplying Demand solely for failing to follow the mandatory formatting requirements—regardless of whether Supplying Demand’s price proposal provided the same substantive information that would have been provided on Attachment 1.
However, the GAO also determined that Supplying Demand did not, in fact, provide the same information required by Attachment 1. In this regard, the GAO quoted the FBI Contracting Officer, who stated:
By not using the supplied form and creating its own, Supplying Demand made a price evaluation impossible. Price columns were added that were not included in Attachment 1 with no description on what these columns were intended to depict.
The GAO wrote that, in sum, “the record reflects that Supplying Demand’s proposal failed to comply with the solicitation’s requirements.” The GAO denied Supplying Demand’s bid protest and upheld the FBI’s decision to exclude Supplying Demand’s proposal.
Takeaways for Government Contractors
The Supplying Demand case offers some helpful lessons for federal government contractors:
When a government solicitation requires offers to be formatted in a particular manner, contractors may risk exclusion from the competition for not following the formatting requirements.
Even if a contractor provides all the information required by the solicitation, it’s possible that its proposal could be excluded for failing to follow the solicitation’s formatting instructions.
The Supplying Demand case is another reminder—and there are plenty of them in the GAO’s bid protest library—that government contractors must implement effective processes to ensure that their proposals cross every T and dot every I required by the solicitation.
Failing to do so could get the proposal booted.
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You probably should read these very exciting disclaimers: The information in this article is not, nor is it intended to be, legal advice. You should consult an attorney for individual advice regarding your own situation. The opinions expressed in this article, especially, but not limited to, any in which the author may extol his own good looks, intellect, charm and/or inherent modesty, are solely those of the author.
I’m sure someone at the FBI thought it was delightfully ironic to name a crime-fighting agency’s IDIQ after an actual crime, but STEAL seems like a particularly odd choice since government contractors are sometimes accused of doing just that with government funds. What’s next, an FBI services contract for Forensics, Reasarch and Undercover Detectives (FRAUD)?
I’m an ‘80s kid, so theft sometimes makes me think of the Hamburglar, who was all over television screens 40 years ago, teaching kids about the deliciousness of McDonald’s burgers and the potential to acquire them via illegal means.