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CICA performance stay
GAO merits timeliness under 4 CFR 21.2 and the CICA performance-stay trigger under 31 U.S.C. § 3553(d) and FAR 33.104(c) are separate calculations. A stay generally depends on the agency’s receipt of notice from GAO within the statutory window measured from award or from the offered date of a required — not merely from when the protester presses submit. Build a dated chronology covering award, notice, debriefing, knowledge, filing, and expected GAO notice to the agency. If the business case depends on a stay, file early enough that GAO notice can reach the agency inside the statutory window.
Watch for
Don’t assume a timely protest invariably triggers a stay. An agency protest does not automatically preserve the later GAO stay window. Informal customer do not toll either clock.