# GAO Strengthens Conflict of Interest Investigations

The U.S. Government Accountability Office (GAO) has clarified in its recent Viderity Inc. decision that federal agencies must conduct conflict of interest investigations by directly inquiring with the involved firm, rather than relying solely on statements from individuals alleged to have conflicts. This ruling, arising from a protest involving a communications infrastructure support contract awarded by the Department of the Interior (DOI) on behalf of the Department of Health and Human Services (HHS), emphasizes the necessity for thorough and independent agency investigations to avoid unreasonable conclusions and potential protest cost reimbursements.

- **Why this matters:** Procurement officials must ensure conflict of interest investigations include direct firm-level inquiries to meet GAO standards and reduce protest risks.
- Agencies should review and potentially revise their investigation protocols to incorporate this requirement, enhancing transparency and defensibility.
- Contractors and vendors should be prepared for more rigorous conflict of interest scrutiny during federal procurements.
- Legal counsel supporting procurement activities can leverage this decision to advise agencies on compliant investigation practices and protest mitigation strategies.

**Jurisdictions:** federal
**Industries:** Professional Services
**Topics:** Regulatory Compliance
**Published:** September 16, 2026

### Government Entities
- U.S. Government Accountability Office (GAO)
- U.S. Department of the Interior (DOI)
- U.S. Department of Health and Human Services (HHS)

### Vendors
- Viderity Inc. (Protester)
- Bixal Solutions, Inc. (Awardee/Intervenor)

### Key Quotes
> GAO may view such an inquiry as a necessary, not optional, component of a conflict of interest investigation.
> — Daniel R. Forman, Partner, Crowell & Moring LLP

### Sources
- [GAO's Viderity Decision: Agency Conflict of Interest Investigations Must Include Inquiry of the Involved Firm | Crowell & Moring LLP](https://www.crowell.com/en/insights/client-alerts/GAO-Indicates-Reasonable-Conflict-of-Interest-Investigation-Must-Include-Inquiry-of-Involved-Firm) - Crowell & Moring LLP