Mandatory Disclosure Rule

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The 12/08 Mandatory Disclosure rule make it necessary for you to have business processes and automated systems that can help you: prevent Contract price violations, and manage TAA compliance issues. You must disclose:

to the Agency Office of the Inspector General, with a copy to the Contracting Officer. It doesn't matter whether you're the prime contractor or a subcontractor...if there is credible evidence of such violations, disclosure is required.

The rule also adds to the causes for suspension or debarment, knowing failure by a principal (officer, director, owner, partner, or person having primary management or supervisory responsibilities within the business entity), until three years after final payment on any Government Contract awarded to the Contractor, to timely disclose. See Mandatory Disclosure Rule

Contractors have to report Trade Agreements Act and Price Change violations to the Inspector General and the Contracting Officer on credible evidence that they happened. But here's the rub...Whistle Blowers or the Department of Justice investigators can bring cases against Contractors for an occurrence that the Contractor did not report. There is even a web page to the hot line.

You are now in a regulatory environment which requires disclosure of violations and encourages more people to report violations and share in the substantial penalties. Ask us if you need help with business processes and automated systems that can minimize the chance of Contract Price Violations and TAA compliance issues.

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