GAO bid protests sometimes involve allegations that a particular contracting officer and/or other government personnel were biased against the protester.

However, as a recent GAO bid protest decision demonstrates, without “convincing proof,” which can be very difficult to obtain, the GAO will not sustain a protest allegation of bias or bad faith on the part of government employees.  In other words, without a “smoking gun,” making an allegation of bias or bad faith may simply be a waste of time.