Use LEFT and RIGHT arrow keys to navigate between flashcards;
Use UP and DOWN arrow keys to flip the card;
H to show hint;
A reads text to speech;
10 Cards in this Set
- Front
- Back
|
OCI Definitions |
Unfair competitive advantage over others in an acquisition Because of other activities or relationships with other persons, a person is unable or potentially unable to render impartial assistance or advice to the government, or the person’s objectivity in performing the contract work is or might be otherwise impaired, or a person has an unfair competitive advantage |
|
|
Work situations that cause OCI? |
Based on ground rules—unfair competitive advantage-ktr writes SOW -exception:if more than 1 contractor involved in developing the SOW, the developing work is not considered unfair, if enough time has elapsed, supervised and controlled by Government reps or if the Government requested the specs/data of a product they provide Impaired objectivity - evaluating own information (A&AS) Unequal access - access to nonpublic info as part of its performance of a government contract I.e. access to IGE) must sign NDAs |
|
|
PCO responsibilities |
Identify and evaluate To avoid, neutralize, and mitigate a potential or apparent OCI before award Comply w/ OCI review process Early mitigation Use common sense, good judgment, and sound discretion Identify and evaluate potential OCIs as soon as possible Get advice from JA/Tech Team Avoid unnecessary delays |
|
|
JA will brief at industry day |
Common OCI issues so the can be resolved |
|
|
If OCI identified |
Obtain OCI plan from prime ktr Review: JA, PMO, and PCO. Issues can be discussed early and the ktr can revise Summit plan to OCI review panel -findings are advisory -JA -AQ -PK -PCO If not mitigated = exclude from competition and prepare D&F as a letter to the ktr |
|
|
Elements of OCI Plan |
Description of OCI Approach to mitigating OCI Organization Chart Controlled access to sensitive information - any organization, physical, or financial firewalls Company oversight Employee training -awareness and compliance training programs Non-disclosure agreement Movement of personnel -physical separation: management or organizational Mitigation plan updates |
|
|
OCI remedies |
Exclusion from conflicted work (if OCI cannot be mitigated) Mitigation -should be done before the fact -establish “firewalls” -disclosure of sensitive info to all -removal of a conflicted sub -Gov’t performs conflicted work Waiver -benefit to Gov’t outweighs OCI -HCA approval (Holt) |
|
|
AFLCMC Policy |
All industry days must have OCI brief from legal All acquisition strategy panels will address OCI issues to assure resolves early Electronic bulletin board will be a resource OCI Review Board will consist of Senior representative from PK, AFLCMC and JA |
|
|
OCI review process |
Industry submits plan PCO makes determination JA reviews Formalize decision and submit to AFLCMC AFLCMC schedules review panel Panel approves and finalized with industry |
|
|
OCI FAR Part |
FAR 9.5 HCA is waiver authority |
