# GAO Clarifies Conflict of Interest Investigation Requirements

The U.S. Government Accountability Office (GAO) has clarified in the Viderity Inc. protest case that agencies must conduct a reasonable conflict of interest investigation by directly inquiring with the involved firm rather than relying solely on representations from individuals allegedly involved. This decision highlights the necessity for federal agencies, such as the Department of the Interior (DOI) acting on behalf of the Department of Health and Human Services (HHS), to perform thorough and independent conflict of interest inquiries to avoid legal deficiencies and potential protest cost reimbursements.

- **Why this matters:** Procurement officials must ensure conflict of interest investigations include direct engagement with implicated firms to meet GAO standards and reduce protest risks.
- Agencies awarding contracts, including communications infrastructure support contracts like the one awarded by DOI for HHS, should review and potentially revise their investigation protocols.
- Contractors and bidders should be prepared for direct inquiries during conflict of interest assessments, impacting proposal preparation and compliance.
- This ruling underscores the importance of rigorous due diligence in procurement processes to safeguard contract awards and minimize protest vulnerabilities.

**Jurisdictions:** federal
**Industries:** Information Technology
**Topics:** Regulatory Compliance
**Published:** September 24, 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
- Bixal Solutions, Inc. (awardee)
- Viderity Inc. (protester)

### Sources
- [GAO Indicates Reasonable Conflict of Interest Investigation Must Include Inquiry of Involved Firm | Government Contracts Legal Forum](https://www.governmentcontractslegalforum.com/2026/09/articles/bid-protest/gao-indicates-reasonable-conflict-of-interest-investigation-must-include-inquiry-of-involved-firm) - Government Contracts Legal Forum