Over the past four and a half years, the Defense Department has faced at least four separate rounds of bid protest litigation challenging its multi-billion dollar overhaul of the military’s household goods moving system. It’s now gearing up for a fifth.

The latest legal challenge is highly unusual in that it comes more than two years after DoD made the award the protesters are challenging. But the plaintiffs argue the circumstances surrounding the military’s $17.9 billion Global Household Goods contract (GHC) are unusual too, and justify the sort of late-in-the-day legal claim that courts typically frown on.

The challengers, all of whom are moving companies who conduct large numbers of military moves under DoD’s legacy contract structure, claim the department made “cardinal” changes to its contract with HomeSafe, the winning bidder, long after it was awarded — changes so significant that GHC itself is now fundamentally different than what DoD contemplated when it first solicited bids for the contract in 2018.

Suit alleges CICA violations

The suit asks the Court of Federal Claims to terminate the GHC contract and order U.S. Transportation Command to start a new full and open competition to handle the military’s moving needs.

“TRANSCOM’s non-competitive cardinal change to GHC was a violation of law and regulation, including the Competition in Contracting Act and related federal acquisition regulations … TRANSCOM’s actual requirement for household goods moving services are vastly different from what was stated in the solicitation against which all offerors had to compete,” attorneys for Suddath Companies, the first firm to file the current challenge, wrote in a Nov. 8 complaint.

Two other moving companies joined the lawsuit this month: Total Military Management on Dec. 13 and National Van Lines on Dec. 26.

The lawsuit claims DoD made significant changes involving both time and money that prospective bidders couldn’t have factored into their bid-no bid decisions. Among them, the plaintiffs claim HomeSafe was given three years to fully phase in the new contract instead of the nine months contemplated in the contract award, and that DoD gave the company an unexpected $60 million to fund a software development effort that was supposed to have been done at the contractor’s expense.

“The transition/phase-in, as modified, is nearly unrecognizable from the requirement under the original solicitation — a quintessential cardinal change. TRANSCOM thus has violated CICA by procuring services through other than full and open competition and preventing qualified bidders from participating in the procurement,” Total Military Management alleged in its similar Dec. 13 complaint. “TMM has been wrongfully deprived of the opportunity to fully and fairly compete for TRANSCOM’s actual GHC needs.”

The government has until Jan. 7 to file its first response to the lawsuit, and a more fully detailed motion laying out DoD’s case for why the contract should be upheld is expected by Feb. 12.

GHC implementation continues

DoD, meanwhile, is pressing ahead with its GHC implementation. Earlier in December, TRANSCOM announced it had added 20 more domestic military installations to the list of bases where GHC is “live.” That brings the total to 94 U.S. bases, about half of all the installations in the continental U.S.

However, the rollout so far has been relatively slow, and DoD has continued to contract for moving services under its legacy system alongside the GHC moves at each base. As of Dec. 4, DoD had placed fewer than 800 orders for military moves under GHC compared to the several hundred thousand that occur under the legacy “tender for service” system each year.

TRANSCOM officials have consistently said that the GHC rollout would be “conditions-based,” but they currently expect a significant ramp-up of the contract over the next several months. HomeSafe is expected to take over all domestic moves by May 2025.

“First and foremost, the service member experience is at the forefront of all the decisions that we make. Whether that’s IT or business processes, how that impacts the relocation experience is factored into every decision we’re currently making,” Andy Dawson, the director of TRANSCOM’s Defense Personal Property Management Office, told reporters in September. “As we move forward, we expect HomeSafe to have the capacity required to support the program. For those in industry that have participated in the [current] program, we’re very grateful for their participation. We’re very grateful for the feedback that they’re providing HomeSafe to make the program better, but at the same time, I think we recognize the size, magnitude and scale of this program, which is why we adopted a gradual phase-in over time, instead of a flip-the-switch approach.”

Escalation of moving companies’ concerns

The latest lawsuit is far from the first time DoD’s incumbent moving companies have raised concerns about the new contract.

Prior to the legal challenge, many of the large incumbents had publicly warned that moving companies would struggle to operate as subcontractors on the GHC contract because of what they said were rates that were too low to make a profit.

They also claim compliance with the Service Contract Act — a new requirement for movers under GHC — will be impossible because the SCA’s hourly wage requirements are largely incompatible with the moving industry’s business model. DoD and HomeSafe have largely denied that the SCA will cause difficulty and say they have been helping movers make the adjustment to the new wage model.

Also this year, many of the companies that have raised complaints about the GHC model formed a new coalition called Movers for America. One of the group’s largest priorities has been to convince Congress to mandate a Government Accountability Office review of the contract. Before that, the American Trucking Association’s Moving and Storage Conference had also been pressing lawmakers since 2023 to require a GAO study.

In its version of the 2025 defense authorization bill, the House agreed to language that would have ordered that review, but the final version negotiated with the Senate omitted the mandate. Instead, lawmakers ordered TRANSCOM to brief Congress by November on HomeSafe’s performance during the 2025 summer peak moving season, service members’ feedback on those moves, an update on the GHC rollout schedule, and DoD’s plans for continuing to operate the current “tender” program.

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