DFARS Case 2010-D026, Display of DoD Inspector General Fraud Hotline Posters,Proposed rule
Friday, March 11th, 2011
The DoD IG has determined that FAR 52.203-14(c), which allows an exemption from posting agency hotline posters if the contractor already has an ethics and conduct awareness program, is not sufficient to protect potential whistleblowers when alleging fraud, waste and abuse by their company.
Under this propose rule the DoD IG wants to supplement the FAR with a DFARS Clause that would make it mandatory for all DoD contractors (regardless of size or adequacy of internal ethics and conduct programs) to display the DoD IG hotline posters.
Comments on the proposed rule should be submitted in writing to the address shown below on or before May 10, 2011, to be considered in the formation of the final rule.
My guess is that regardless of any comments against this propose rule, it will be implemented, so be prepared to post the additional posters and for DCAA to ensure such posters are posted during their audits.
Click here for a link to the Federal Register
DFARS Case 2009-D031, Government Support Contractor Access to Technical Data, Interim rule
Wednesday, March 2nd, 2011
I would recommend all contractors discuss with their outside counsel the impact and potential risk to the security of their technical data this interim rule poses. If any contractor needs a recommendation for counsel with expertise in this subject matter feel free to contact me via email or at the following number 814-242-2410
Click here for a link to the Federal Registor for DFARS Case 2009-D031
The changing landscape of Government contract compliance
Tuesday, April 20th, 2010
The attached PowerPoint presentation address the many changes in compliance requirement facing government contractors and the potential impact on their business
- High-Visibility Procurement & Audit Issues
- DCAA and Access to Contractor Records
- Proposed DFARS Rule – Withholding Payments to DoD Contractors
- Contractor Business Systems and Internal Controls
- Ensuring a Compliant Cost Accounting System
- Prime Contractor Management of Subcontractors
- Interim Rule to Increase Competition in Major Defense Acquisition Programs (MDAP)
- How to Survive a DCAA Audit
Click here for a copy of the PowerPoint document
