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

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 conflicts.   Following this timeline, CO’s will often require that proposals include relevant OCI-related information, including mitigation plans, and then defer consideration and resolution of an offeror’s potential OCI until (and unless) the offeror’s proposal is found to offer the “best value.” There are understandable reasons for this procrastination.  First, the facts may not be known initially (and may evolve, especially if the statement of work is amended).  Second, a CO’s plate is always full; where will they find the time to address potential OCI’s that won’t … Continue reading