Earlier this week, the Air Force issued a Notice of Proposed Debarment to Booz Allen Hamilton, Inc. The basis for the debarment is set forth in a memorandum attached to the notice (contact me if you would like a copy). …
Organizational Conflicts of Interest (“OCI”) has been a “hot topic” in government contracts ever since new DoD OCI regulations for Major Defense Acquisition Programs were published in December of 2010. While the final regulations were far narrower than anticipated, the …
In my earlier blog post on the GAO’s decision in VSE Corporation  (B-404833.4, November 21, 2011), I commented on GAO case law holding that “an appearance of impropriety” can justify the disqualification of a contractor from a procurement. In the …
In 2010, the Government implemented the Federal Awardee Performance and Integrity Information System (FAPIIS). FAPIIS consolidates information from various federal databases such as the Excluded Parties List System (EPLS), the Past Performance Information Retrieval System (PPIRS) and the Contractor Performance …
Yesterday, the GAO issued a decision in Kingdomware Technologies, B-405727, in which it found that the Department of Veterans Affairs improperly sought to fulfill a requirement for subscription and support services from a non-mandatory FSS contract rather than conducting market …
‘Tis the season and Aldevra is the case that keeps on giving. Last we heard (October 11), GAO decided that the VA should have set aside one solicitation and done market research to determine whether there was a reasonable expectation …
On November 18, DoD issued a final rule requiring offerors in DoD procurements to represent that former DoD officials employed by the contractor are complying with post-employment restrictions applicable to that contractor. Such post-employment restrictions are found in the Procurement …
In August 2011, the General Accounting Office (GAO) issued a report which concluded that many agency suspension and debarment programs were inadequate. The report took a look at the suspension and debarment activity of ten agencies with contract obligations in …
In September, I blogged on the importance of ensuring that a service-disabled veteran “controls” the company if the company holds itself out as a service-disabled veteran owned business (SDVOSB). Lack of “control” is the single number one reason a SDVOSB …
Last month I posted a bit on the Government Accountability Office’s decision in Aldevra.  The case raised an interesting issue: do the Veterans First Contracting Program rules trump the “required sources of supply” rules? Specifically, Aldevra argued that before …