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Proposed Rule on Organizational Conflicts of Interest (from the Federal Register April 26, 2011)

Link to the notice:  Click Here.

 

I highly recommend any of you who may be involved in procurements with a potential for organizational conflict of interest (OCI) issues (and in the services world that is a lot of you) read this proposed rule in its entirety.  To save you a little aggravation, the rule begins on page 23236.  Of particular note are pages 23247-23248 where the linkage to task and delivery order contracts (including BPAs in this instance) is discussed.  Take a look at the new proposed language for FAR 3.1206-4(d) and 3.1206-5.

This is a very long document which has quite a bit of included analysis and regulatory language to slog through.  You will not be skimming through it in five minutes.  I did come across what I think is a fairly decent summary by the law firm of McKenna, Long & Aldridge here.  Please note this is an external site not affiliated with GSA.  The opinions expressed in this posting do not represent my views or the views of my agency.  OK, disclaimer over.

So what are your thoughts on this proposed rule?  Does anyone plan to submit comments and if so, would you like to share them?

 

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