Joe Jordan, recently appointed Administrator of the Office of Federal Procurement Policy wrote in his blog that “It is critical that the government take a hard line against those who would defraud taxpayers.” This is much more than rhetoric because Mr. Jordan went on to cite statistics released by the Interagency Suspension and Debarment Committee indicating the suspensions and debarments have increased from approximately 1,900 in GFY 2009 to more than 3,000 in GFY 2011. Rather than a substantial increase in “bad actors” these statistics reflect the Administration’s greater emphasis on suspensions and debarments. As Mr. Jordan further pointed out, each major executive agency now has a senior official in place to assess their suspension and debarment programs. Also, most agencies have developed formal suspension and debarment programs and have dedicated resources to managing them.
Of course many contractor groups complain that suspensions and debarments are now being used to punish contractors in lieu of their original purpose of protecting the Government from contractors that lack responsibility. As one speaker noted at the recent NCMA World Congress, the Federal procurement system was not designed to divvy out punishment, that is the job of the criminal justice system. However, the increase in suspensions and debarments seems to play well to the average American who may not fully appreciate the difference between protection and punishment.
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What We Are Writing
- 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)