Formatting Matters: A Closer Look at Horizons Youth Services’ GAO Protest

In the recent protest decision by the Government Accountability Office (GAO), Horizons Youth Services challenged its elimination from a competitive federal procurement conducted by the Department of Labor (DOL) for the operation of the Cascades Job Corps Center in Sedro Woolley, Washington. The GAO, however, denied the protest, emphasizing the importance of strictly adhering to solicitation requirements, including seemingly minor formatting instructions.

At the heart of the issue was the font type used by Horizons in its technical proposal. The solicitation specifically mandated that proposals be submitted in Times New Roman, Arial, Garamond, or Calibri fonts, sized 12 points or larger. Horizons opted for Arial Narrow—a more condensed variation of the allowed Arial font—thereby enabling it to present additional substantive information within the prescribed 50-page limit. The agency's evaluators quickly flagged this non-compliance, noting that using Arial Narrow allowed Horizons to effectively add three or more pages of content beyond the stated limit.

Horizons argued that Arial Narrow is simply a member of the broader Arial font family, thus falling within the solicitation’s specifications. However, GAO rejected this interpretation, concluding that the solicitation clearly identified only four permissible fonts and did not imply broader font families. GAO stressed that the solicitation language must be interpreted by its plain, common meaning, and Horizons’ choice constituted a material deviation.

The GAO further clarified that such formatting deviations are not trivial technicalities, particularly when they impact the length and substantive content of the proposal. Agencies establish specific formatting requirements to maintain fairness and a level playing field. Allowing Horizons’ proposal to proceed, despite the font deviation, would unfairly disadvantage other competitors who complied with the instructions.

Moreover, Horizons contended the deviation was minor and argued the agency should have reformatted its proposal using Garamond, the densest allowable font, to ascertain actual compliance with page limits. The GAO found no merit in this approach, stating clearly that agencies are not obligated to adapt their evaluations to correct offerors’ formatting errors. Instead, it emphasized that offerors carry the burden of ensuring their proposals strictly meet solicitation requirements.

This GAO decision underscores a crucial takeaway for government contractors: meticulous compliance with solicitation instructions—down to formatting nuances—is essential. Overlooking or misinterpreting requirements, no matter how minor they seem, can lead to proposal elimination. In government contracting, attention to detail is not just best practice—it’s mandatory.

(Source: Decision B-423202, Horizons Youth Services, GAO, March 7, 2025.)

Disclaimer: This summary is not guaranteed to be accurate and does not constitute legal advice.