False Claims And Whistleblowers

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No sensible person ever goes into a contract with the Government expecting to be prosecuted for contract fraud. However, many people and companies are prosecuted every year for selling non-TAA compliant products and for selling items at prices that do not comply with their Commercial Sales Practices (CSP) document. You might not know that these actions can make you subject to prosecution for contract fraud, but that is exactly what can happen if you are the signature authority for your company on a GSA or VA contract or a company manager who manages the performance of the contract.

What can you do?

  • Carefully control the prices at which items on your contract are sold to both Government and non-Government purchasers. Non-Government sales must be at or above the prices defined in your CSP-1 disclosure. Government prices must be at or below the prices on your current Authorized Price List. Note that this is not necessarily the same as ensuring that the Government price is less than your commercial price; your prices must comply with your CSP!
  • Establish a written policy that you and/or your suppliers will correctly identify the current country of origin for all products and services you supply to the Government through your contract. Generally you will be compliant if your price lists are updated for compliance at least once a calendar quarter. Document your quarterly compliance check.
  • Do not accept purchase orders referencing your contract number for any items that are non-compliant; sell these items as open market items on a separate purchase order. It is not the price list or the advertisement that triggers the penalty; it is the actual sale. The penalties can be substantial and apply to each invoice.
  • Modify your contract to remove all non-compliant items when you are notified by your suppliers or any other credible source that the items are no longer compliant.
  • Republish your GSA Advantage! price lists as soon as your contract modifications are approved by your Contracting Officers.

Please make sure you have read and understand the false claims and false statements laws as they apply to your contract. SenSoft can provide references to law firms if you have need.

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