GSA OIG Posts New Contractor Misconduct Reporting Form

In preparation for important new changes to the Federal Acquisition Regulation (FAR) that take effect this Friday, the General Services Administration Office of Inspector General (GSA OIG) has posted a new contractor disclosure form on its website.

Regular readers of this blog know about recent changes to the FAR that will require contractors to report certain contract-related misconduct or face possible suspension or debarment.  Contractors must report to the contracting officer and the relevant agency’s OIG whenever they have “credible evidence” of a violation of the civil False Claims Act or a violation of federal criminal law involving fraud, conflict of interest, bribery, gratuities, or significant overpayments in connection with the award, performance, or closeout of a federal contract or subcontract.

To make reporting as easy and convenient as possible for its own contractors, the GSA OIG has posted this online form.  Upon submitting the form, the contractor will receive a confirmation e-mail containing a tracking number and a copy of the form the contractor can forward to the contracting officer.  Contractors reporting violations over $2,500 automatically qualify for free super-saver shipping and other exciting deals.  (Just kidding.)

Ever since the new rule was finalized last month, the air in Washington has been thick with the dread and anxiety of the contractor community.  Today, POGO attended a contractor conference at George Washington University and noticed a somewhat less frantic mood.  Contractors, or at least the lawyers who represent them, still have many unanswered questions about the rule, but they seem to be accepting their fate.  One conference panelist, Air Force suspension and debarment official Steven Shaw, predicts the new rule will have minimal fallout.

-- Neil Gordon

Comments

[Bondo]

This self reporting rule appears to favor the contractors in that it will reduce false Claims act violations and thus save avoid big fines and heading off any whistle blowing.

[KSBR shocked]

Do we think that the GSA IG guy's comment (if he is genuine) is professional and proper? Even funny? Ask him if the GSA IG will establish, on its own authority, a parallel program for government employees? Just kidding, of course.

[Dave Farley]

Neil:

Thanks for the coverage of the new form. We hope that contractors will find it helpful. Also thought it might be worth mentioning that there have been discussions about entering those contractors reporting within the first week into a drawing for a delightful plush toy "junk yard dog" with our logo on a chain around its neck, just in time for the holidays.

Cheers,
Dave Farley
Special Asst. for Communications and Congressional Affairs
GSA Office of Inspector General