Photo of Zachary Schroeder

Zachary Schroeder

Subscribe to Zachary Schroeder's Posts

Zachary Schroeder is a counsel in Crowell & Moring’s Washington, D.C. office, where he practices in the Government Contracts Group.

Zach represents contractors in both litigation and counseling matters. His practice focuses on representing contractors in bid protests before the Government Accountability Office (GAO), the U.S. Court of Federal Claims, and the Federal Aviation Administration’s Office of Dispute Resolution for Acquisition. His practice also includes federal regulatory and ethics compliance, as well as various aspects of state and local procurement law, including representing contractors in size protests and affiliation matters. In the transactional context, Zach has performed government contracts diligence for government contractors in a range of industries.

While in law school, Zach served as a judicial intern for Judge Mary Ellen Coster Williams at the U.S. Court of Federal Claims. He also served as the chair of the 2017 Government Contracts Moot Court Competition and as an editorial staff member of the American Intellectual Property Law Association (AIPLA) Quarterly Journal.

Contact:Read more about Zachary Schroeder

Crowell & Moring’s “All Things Protest” podcast keeps you up to date on major trends in bid protest litigation, key developments in high-profile cases, and best practices in state and federal procurement. In this episode, Crowell attorneys cover impacts of the government shutdown on bid protests, GAO’s new pleading standards, and GAO’s dismissal of a…

On September 4, 2025, the Small Business Administration’s (SBA) Office of Hearings and Appeals (OHA) granted an appeal challenging SBA’s determination that a service-disabled veteran did not control an entity applying for Service-Disabled Veteran-Owned Small Business (SDVOSB) status based on a minority owner’s ability to block certain actions in the matter of VSBC Appeal of: Blue Skye Foods, LLC, SBA No. VSBC-442-A.Continue Reading SBA’s OHA Further Defines Extraordinary Action in SDVOSB Appeal

On August 7, 2025, the FAR Council issued a final rule amending FAR 52.204-7 to clarify that, effective immediately, an offeror’s failure to maintain continuous System for Award Management (SAM) registration between proposal submission and contract award does not render the offeror ineligible for award, so long as the offeror was registered in SAM at the time of proposal submission and is registered at the time of contract award. The final rule should address situations like TLS Joint Venture, LLC, B-422275, Apr. 1, 2024, 2024 CPD ¶ 74, where an offeror’s SAM registration lapsed for a single day between the proposal submission and award dates, and GAO found the offeror ineligible for award.Continue Reading The End of the Continuous SAM Registration Requirement …. Almost

The deadlines for filing a GAO protest are short and strictly enforced.  In post-award protests, the general rule is that a company must file its protest within ten days of when the protester knows, or should have known, of its basis of protest.  However, GAO’s regulations provide an exception to this rule for “protests challenging a procurement conducted on the basis of competitive proposals under which a debriefing is requested and, when requested, is required”—in such a situation, “[the] protest shall not be filed before the debriefing date offered to the protester, but shall be filed not later than 10 days after the date on which the debriefing is held.”  4 CFR §21.2(a)(2).Continue Reading GAO Moves the Goalposts: New Post-Debriefing Timeliness Trap for Protesters

On May 7, 2025, GAO issued a decision in Raven Investigations & Security Consulting, LLC, B-423447, warning the bid protest bar that artificial intelligence (“AI”)-based tools utilized without proper oversight may result in severe consequences, including dismissal of the protest and sanctions.Continue Reading “Confirm You’re Not a Robot”: AI-Written Briefs Could Lead to Sanctions

On May 12, 2025, the U.S. Small Business Administration (SBA) announced that it is holding a tribal consultation meeting and requesting comments and input on topics relating to the 8(a) and mentor-protégé programs. The tribal consultation will be held on June 13, 2025 in Anchorage, Alaska, and SBA is anticipating that the meeting will cover a range of topics relevant to 8(a) and mentor-protégé program participants.Continue Reading Tribal Consultation Meeting for 8(a) Business Development and Mentor-Protégé Programs Provides Insight Into SBA Priorities Under the New Administration

United States Attorneys’ Offices recently announced a number of False Claims Act (FCA) settlements arising out of the Paycheck Protection Program (PPP). These settlements reveal several trends that PPP loan recipients should be aware of.Continue Reading Recent Deluge of Paycheck Protection Program False Claims Act Settlements

On August 23, 2024, the Small Business Administration (SBA) posted a proposed rule to update and clarify aspects of various SBA small business programs, including but not limited to the HUBZone Program and 8(a) Business Development Program.  This proposed rule followed SBA’s July 22, 2024 notification of tribal consultation meeting and request for comments (which Crowell covered here). Continue Reading SBA Proposed Rule Would Enact Material Changes as Well as Promote Regulatory Uniformity Across Size and Status Programs

On July 22, 2024, the Small Business Administration (SBA) posted a notification of tribal consultation meeting and request for comments regarding updates to the HUBZone and 8(a) Business Development Programs.  Of critical importance for any contractors participating in the SBA’s Mentor-Protégé Program, SBA is also seeking comments on prospective policy changes addressing joint venture participation in SBA’s programs.  SBA has identified perceptions that:Continue Reading SBA Seeks Comment on Prospective Policy Change Regarding Mentor-Protégé Joint Venture Eligibility For Multiple Award Contracts

Generally, a GAO protest challenging the terms of a solicitation is timely if filed within 10 days after the denial of an agency-level protest, “even if filed after bid opening or the closing time for receipt of proposals.”  4 C.F.R. § 21.2(a)(3).  Accordingly, the salient consideration for determining when that 10-day clock begins to run is when the agency denies the agency-level protest.  But in Marathon Medical Corp., B-422168.2, February 14, 2024, GAO held that if an agency has not ruled on a pre-award agency-level protest as of the closing date for receipt of proposals, then the protest is deemed denied as of that date—and the protester’s clock for filing a GAO protest begins to run—even if the agency later issues an actual decision denying the protest. Continue Reading Yet Another Timeliness Trap for the Unsuspecting Protester: A Pre-Award Agency-Level Protest Is Functionally Denied as of the Closing Date for Receipt of Proposals, Even if the Agency Actually Denies it Later