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“SMALLTOFEDS” By Ken Larson
“If a potential for a conflict of interest is real, it is best to make that fact a principal factor in your bid/no bid decision. Be open and honest in your presentation of the facts to the government. Your past performance rating will take a major hit if OCI is uncovered after award and you have not made full and open disclosure previously.”
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“While planning, marketing, teaming, proposing or performing under federal government programs (particularly service contracts) the small business will encounter the term, “Organizational Conflicts of Interest” or “OCI”. The term has been established by the government as part of the process to control procurement integrity.
OCI clauses in solicitations and contracts require that companies certify their organizations and personnel do not have a procurement integrity issue with regard to a pending contract award or disclose what may be deemed an issue and provide mitigating factors to still be considered.
“Smalltofeds” has discussed procurement integrity and the law at the following article:
Procurement Integrity and the Law Meeting OCI requirements involves strategic planning to avoid situations where your company, your management and/or your personnel are placed in potentially compromising positions while government contracting in your industry.
An apparent win can be delayed indefinitely by a competitor protest claiming OCI. Government actions after the fact if an OCI violation is uncovered will be annotated to a contractor’s past performance history and in severe cases result in disbarment from government contracting.
This article will define Organizational Conflict of Interest (OCI), discuss situations under which OCI issue are likely to occur and recommend strategic planning and processes to manage the requirement.”
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