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CMS Is “Not Intercepted.”

by Fred W. Geldon, Senior Counsel, Steptoe & Johnson, LLP | Mar 26, 2013 | Offers/Protests

“When you know what you’re doing, you’re not intercepted.” – Johnny Unitas Johnny U. famously uttered those words in 1958, after leading the Baltimore Colts to victory in “The Greatest Game Ever Played.” Fifty-five years later the Baltimore-based Center for Medicare...

A Steady Drumbeat?

by Fred W. Geldon, Senior Counsel, Steptoe & Johnson, LLP | Nov 5, 2012 | Uncategorized

In every Organizational Conflict of Interest (OCI) bid protest decision, the Government Accountability Office (GAO) says that it will defer to the Contracting Officer (CO) – i.e., that it “will review the reasonableness of a contracting officer’s OCI investigation...

Should the Kimono be Opened? – Organizational Conflicts of Interest (OCI) Best Practices

by Fred W. Geldon, Senior Counsel, Steptoe & Johnson, LLP | Aug 31, 2012 | FAR, Government Contracts Education

FAR Part 9.504 requires contracting officers (CO’s) to identify and evaluate potential OCI’s early in the process, but puts no time pressure (other than the award deadline) on the need to resolve (i.e., avoid, neutralize, or mitigate) significant organizational...

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This blog does not provide any legal advice regarding any particular transaction.

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