Holding Contractors Accountable
In a recent OMB blog posting by Dan Gordon, Office of Federal Procurement Policy Administrator, he noted the Federal Government, as part of the Campaign to Cut Waste, will ensure all agencies are “fully equipped to suspend or debar contractors and other recipients whenever necessary to protect the government’s interest.” Agencies must assess their current suspension and a debarment program to ensure the Excluded Parties List System (“EPLS”) is checked prior to the award of contracts, along with other processes.
In addition to the EPLS, agencies must also participate on the Interagency Suspension and Debarment Committee, and create other processes to ensure their suspension and debarment processes are well-established.
Historically, tax dollars have been put at risk for waste, fraud, and abuse with contractors who:
- Provide nonconforming parts (vehicle, aircraft, etc.)
- Submit falsified documentation (timesheets, billings, etc.)
- Are delinquent with paying their taxes
- Willfully fail to perform in accordance with the terms of their contract
- Are already in the EPLS with a history of issues
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- A Marriage of Inconvenience: GSA Schedule Contracts & The Contractor Code of Business Ethics & Conduct Clause
- Emerging Small Businesses: To Grow Your Business, You Must Plan For Growth
- Government Contracting: Look Before You Leap!
- GSA Schedules – Strategies for Success
- New Employee vs. Independent Contractor Considerations
- Pay on Display – Understanding the Executive Compensation and Subcontractor Data Reporting Requirements & Ramifications
- The GSA Schedule: Your Ticket to the Federal Market (May 2010)
- The New FAR Codes of Conduct and Compliance Program Provisions
- The Seven Deadly Sins (of contract compliance)
None of this will work unless you have qualified and knowledgeable Feds to perform diligent oversight and contract management.