Discussions with an agency prior to submitting a final proposal can lead to a more well-informed submission by an offeror; however, such is not always the case. The Government Accountability Office (GAO) decision in Quality Control International, LLC (QCI), B-417984 (December 20, 2019) provides guidance as to how offerors should rely on information supplied by
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2019
New Year, New Voluntary Self-Disclosure Policy for Export Controls and Sanctions
By Eric Whytsell on
Several years ago, the head of the State Department’s Director of Defense Trade Controls (DDTC) explained that, when a company engaged in substantial exporting makes no voluntary disclosures of export control violations, something is wrong. He reasoned that every company is made up of human beings—and human beings make mistakes, so every company doing lots…
Bribery, Gratuities, and Kickbacks, Oh My!
By Judith Araujo on
On December 12, 2019, the Department of Justice (DOJ) announced that a former civilian employee of the U.S. Army is being prosecuted by the DOJ’s Criminal Division’s Fraud Section. The former employee, Ephraim Garcia, worked in the Army’s Directorate of Public Works, where his job duties related to the solicitation, award and management of government …
Tiered Evaluations: A Lesson in Reasonably Applying Different Rules
By Judith Araujo on
It’s not always clear where the applicability of one law or rule should stop and the applicability of another should begin. Recently, the Government Accountability Office (GAO) decision in Becton, Dickinson and Company, B-417854 (November 15, 2019) helped clarify the interplay between the Buy American Act (BAA) and the Trade Agreements Act (TAA) when it…
Regulation Recap: SBA Publishes Proposed Rule Consolidating Mentor Protégé Programs
By Judith Araujo on
Lovers of consistency, rejoice! After a few years of administering two separate, yet substantially similar mentor-protégé programs, the Small Business Administration (SBA) has proposed a rulemaking to consolidate the 8(a) Business Development (BD) Mentor-Protégé Program and the All Small Mentor-Protégé Program. On November 8, 2019, SBA published the Consolidation of Mentor Protégé Programs and Other …