Good afternoon FUN with the FAR Friends!
Thank you for joining us for our second episode of Season 11! Steve and our guest instructor Fred Geldon covered FAR Part 3 for our second episode of 2024: FAR Part 3 (Improper Business and Personal Conflicts of Interest)
As a follow-up to Wednesday’s session, here are a few facts to ponder:
DID YOU KNOW?
Simply requesting a gift, gratuity, or anything of monetary value from a contractor who has or is seeking “Government business” with the employee’s agency will constitute a violation of the FAR’s gift regulations. FAR 3.101-2
DID YOU KNOW?
The person signing a contractor’s Certificate of Independent Pricing must be the person within the contractor’s organization who is “responsible for determining the prices being offered.” FAR 52.203- 2(b)(1).
DID YOU KNOW?
Complying with the terms of a designated agency ethics officer (DAEO) post-Government employee opinion letter protects both the former Government employee and the government contractor from liability under Procurement Integrity Act. FAR 3.104-6(d)(3).
DID YOU KNOW?
The FAR has recently established a “pilot program for enhancement of contractor employee whistleblower protections.” The pilot program includes the policies and procedures for filing complaints, as well as enforcement mechanisms and remedies. The entirety of the program can be found at FAR 3.908.
DID YOU KNOW?
Small businesses are explicitly exempt from having to establish a “Business ethics awareness and compliance program and internal control system.” FAR 52.203-13(c).
DID YOU KNOW?
A “personal conflict of interest” means a situation in which a “covered employee” has a financial interest, personal activity or relationship that could impair the employee’s ability to be impartial and not act in the best interest in the Government when performing under a Government contract. FAR 3.11 and FAR 52.203-16. Personal conflicts of interest issues could arise for both Government employee and contractor employees who perform services that require the use of discretion, such as “acquisition support” services.