ATCH 8_ NITE-STAR CD IDIQ_OCI Mitigation Plan Checklist_FINAL.pdf
PDF 125 KB Posted
- Solicitation number
- FA2553-26-R-B001
- Issued by
-
Department of the Air Force
About this file
This is an Organizational Conflicts of Interest (OCI) Mitigation Plan Checklist for Solicitation FA255326RB001, NITE-STAR Capability Development IDIQ. The checklist is a template that offerors must use to assess and document any actual or potential OCI situations in accordance with FAR 9.5, DFARS 209.5, and DAFFARS 5309.5. Offerors are required to propose an OCI mitigation plan as an attachment to any resulting contract if they identify OCI issues with their performance or that of their teammates or subcontractors under any federal agency or other entity contracts.
The checklist comprises seven major sections with specific requirements: General Considerations (corporate commitment statement signed by Vice President or above, business unit positioning, organizational charts, and teammate/subcontractor commitments); Definitions (terms and acronyms); Management of OCI Plan (designated responsible individuals, documentation location and accessibility, corporate policies and procedures, execution processes, flow-down requirements to subcontractors and teammates, notification procedures for changes and violations); OCI Training (training plans, frequency requirements, documentation procedures, personal conflict identification processes, employee transfer policies, nondisclosure agreements, and disciplinary actions); OCI Plan Reviews (oversight and audit procedures with specified frequency); Description of OCI Situation (identification of actual and potential conflicts with classification as biased ground rules, impaired objectivity, or unequal access to non-public information); and OCI Mitigation (detailed avoidance or mitigation techniques with identification of responsible individuals, noting that biased ground rules or impaired objectivity situations require mitigation beyond firewalls alone). The completed checklist must be included as an appendix to the OCI mitigation plan, with subcontractors and teammates also providing completed checklists if submitting individual plans.
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Solicitation # FA255326RB001, NITE-STAR Capability Development IDIQ
Attachment 8 OCI Checklist
ORGANIZATIONAL CONFLICTS OF INTEREST (OCI)
MITIGATION PLAN CHECKLIST
Offerors shall assess if they have any OCI issues in accordance with FAR 9.5, DFARS 209.5 and
DAFFARS 5309.5. If the Offeror identifies an actual or potential OCI situation associated with its or any of its teammate’s or subcontractor’s performance under any contract it or any of its teammates or subcontractors has been or may be awarded by any federal agency or other entity, the Offeror shall propose an OCI mitigation plan to be included as an attachment in any contract resulting from this solicitation. At a minimum, the plan shall address all of the items in the checklist below.
The OCI mitigation plan shall include this completed checklist as an appendix to the plan. The Offeror shall enter the page and paragraph numbers from its OCI mitigation plan that corresponds to each requirement listed below. If subcontractors or other teammates submit individual OCI mitigation plans, each subcontractor or teammate OCI mitigation plan shall also include a completed checklist. Mark items that are not applicable “N/A.”
1 General Considerations Page/Para
1.1 A clear statement of corporate commitment to continuously identify and avoid or mitigate OCI situations for this acquisition signed by senior corporate official
(Vice President or above).
1.2 Description of the position of the business unit performing this contract effort within the overall corporate structure.
1.3 Organizational charts for the parent organization and the performing business unit (e.g., division, sector, subsidiary, affiliate).
1.4 Letters of commitment to the prime contractor’s OCI Plan from all teammates and subcontractors or individual OCI Plans from all teammates and subcontractors attached to prime contractor’s OCI Plan.
2 Definitions
2.1 Definition of terms used in the OCI Plan.
2.2 Definitions of acronyms used in the OCI Plan.
3 Management of OCI Plan
3.1 Identification of individual responsible for oversight and administration of the
OCI Plan by position and place in company/business unit organizational structure.
3.2 Identification of individual responsible for maintaining documentation related to
OCI Plan by position and place in company/business unit organizational structure.
3.3 Location where OCI Plan documentation will be maintained and commitment that the location will be easily accessible by Contracting Officer or Government auditor.
3.4 Identification of corporate OCI-related policies and procedures (policies and procedures shall be attached to the OCI Plan).
3.5 Description of processes and procedures implemented to execute the OCI Plan.
3.6 Commitment to flow OCI Plan requirements down to all teammates and subcontractors. Only those teammates and subcontractors who have committed to the Offeror’s OCI Plan in writing or provided an OCI Plan of their own shall be allowed to commence work on this contract.
3.7 Description of process for advance notification to Contracting Officer of addition, deletion, or changes to subcontractors and teammates. Notification shall include sufficient information for the Contracting Officer to determine whether or not the
OCI situation has changed. Notification shall also include any proposed changes to the OCI Plan.
3.8 Description of process for timely notification to Contracting Officer of newly identified OCI situations, OCI Plan violations, or appearance of violation.
Notification shall include a description of the violation or appearance of violation and the actions taken or proposed to be taken to mitigate or avoid repetition of the violation. After conducting further inquiries and discussions as may be necessary, the Contracting Officer and the contractor shall agree on appropriate corrective action, if any.
4 OCI Training
4.1 Plan for OCI training of all personnel working on the program.
4.2 Identification of persons or classes of persons working on the program not subject to OCI training, including rationale and description of alternate OCI mitigation techniques.
4.3 Statement of frequency of training (not less than annually).
4.4 Description of how training completion is documented and where training documentation is maintained.
4.5 Description of process for determining personal (individual) conflicts of interest.
4.6 Description of personnel policies to limit employee transfers that might result in the inadvertent flow of sensitive information to other parts of the company where information could be used inappropriately.
4.7 Statement that requirement is in place for program personnel to execute non-disclosure agreements (NDA) to protect proprietary and other sensitive information.
4.8 Statement that requirement is in place for debriefing personnel who executed
NDAs upon their transfer, reassignment, resignation, or retirement.
4.9 Statement of the length of time that NDAs require protection of information.
4.10 Description disciplinary actions for non-compliance with the OCI Plan.
4.11 Description of how and where disciplinary actions are documented.
5 OCI Plan Reviews
5.1 Description of how OCI processes and procedures are overseen and audited by the corporate organization.
5.2 Statement of the frequency of corporate audits.
6 Description of OCI Situation
6.1 Description of actual and potential OCI situations for prime contractor, subcontractors, or teammates, including classification of OCI situations as biased ground rules, impaired objectivity or unequal access to non-public information.
Description identifies applicable contract numbers and customers.
6.2 Explanation of factors that place the prime contractor, subcontractors, or teammates in an OCI situation.
7 OCI Mitigation
7.1 Description of avoidance or mitigation technique(s) proposed for each identified
OCI situation in sufficient detail to evaluate efficacy of proposed technique.
7.2 Identification of individuals (by position and place in company/business unit organizational structure) responsible for executing proposed technique(s).
7.3 If OCI situation is one of biased ground rules or impaired objectivity, avoidance or mitigation techniques shall involve more than firewalls.
| PageParaA clear statement of corporate commitment to continuously identify and avoid or mitigate OCI situations for this acquisition signed by senior corporate official Vice President or above: |
| PageParaDescription of the position of the business unit performing this contract effort within the overall corporate structure: |
| PageParaOrganizational charts for the parent organization and the performing business unit eg division sector subsidiary affiliate: |
| PageParaLetters of commitment to the prime contractors OCI Plan from all teammates and subcontractors or individual OCI Plans from all teammates and subcontractors attached to prime contractors OCI Plan: |
| PageParaDefinitions: |
| PageParaDefinition of terms used in the OCI Plan: |
| PageParaDefinitions of acronyms used in the OCI Plan: |
| PageParaManagement of OCI Plan: |
| PageParaIdentification of individual responsible for oversight and administration of the OCI Plan by position and place in companybusiness unit organizational structure: |
| PageParaIdentification of individual responsible for maintaining documentation related to OCI Plan by position and place in companybusiness unit organizational structure: |
| Location where OCI Plan documentation will be maintained and commitment that the location will be easily accessible by Contracting Officer or Government auditor: |
| Identification of corporate OCIrelated policies and procedures policies and procedures shall be attached to the OCI Plan: |
| Description of processes and procedures implemented to execute the OCI Plan: |
| Commitment to flow OCI Plan requirements down to all teammates and subcontractors Only those teammates and subcontractors who have committed to: |
| the Offerors OCI Plan in writing or provided an OCI Plan of their own shall be allowed to commence work on this contract: |
| Description of process for advance notification to Contracting Officer of addition deletion or changes to subcontractors and teammates Notification shall include sufficient information for the Contracting Officer to determine whether or not the OCI situation has changed Notification shall also include any proposed changes to the OCI Plan: |
| Description of process for timely notification to Contracting Officer of newly identified OCI situations OCI Plan violations or appearance of violation Notification shall include a description of the violation or appearance of violation and the actions taken or proposed to be taken to mitigate or avoid repetition of the violation After conducting further inquiries and discussions as may be necessary the Contracting Officer and the contractor shall agree on appropriate corrective action if any: |
| OCI Training: |
| Plan for OCI training of all personnel working on the program: |
| Identification of persons or classes of persons working on the program not subject to OCI training including rationale and description of alternate OCI mitigation techniques: |
| Statement of frequency of training not less than annually: |
| Description of how training completion is documented and where training documentation is maintained: |
| Description of process for determining personal individual conflicts of interest: |
| Description of personnel policies to limit employee transfers that might result in the inadvertent flow of sensitive information to other parts of the company where information could be used inappropriately: |
| Statement that requirement is in place for program personnel to execute non disclosure agreements NDA to protect proprietary and other sensitive information: |
| Statement that requirement is in place for debriefing personnel who executed NDAs upon their transfer reassignment resignation or retirement: |
| Statement of the length of time that NDAs require protection of information: |
| Description disciplinary actions for noncompliance with the OCI Plan: |
| Description of how and where disciplinary actions are documented: |
| OCI Plan Reviews: |
| Description of how OCI processes and procedures are overseen and audited by the corporate organization: |
| Statement of the frequency of corporate audits: |
| Description of OCI Situation: |
| Description of actual and potential OCI situations for prime contractor subcontractors or teammates including classification of OCI situations as biased ground rules impaired objectivity or unequal access to nonpublic information Description identifies applicable contract numbers and customers: |
| Explanation of factors that place the prime contractor subcontractors or teammates in an OCI situation: |
| OCI Mitigation: |
| Description of avoidance or mitigation techniques proposed for each identified OCI situation in sufficient detail to evaluate efficacy of proposed technique: |
| Identification of individuals by position and place in companybusiness unit organizational structure responsible for executing proposed techniques: |
| If OCI situation is one of biased ground rules or impaired objectivity avoidance or mitigation techniques shall involve more than firewalls: |
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