OCI Mitigation Plan Checklist.pdf
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- Attached to
- HADES (Hybrid Architecture and Development for Experimental Systems) Draft Request for Proposal
- Solicitation number
- FA8809-26-R-B002
- Issued by
-
Department of the Air Force
About this file
This is a Space Systems Command Organizational Conflicts of Interest (OCI) Mitigation Plan Checklist dated March 2026, serving as a template and guidance document for contractors to develop comprehensive OCI plans for federal contract opportunities.
The checklist establishes seven major requirement categories. General Considerations require a signed corporate commitment statement from senior leadership, organizational charts, and letters of commitment from all teammates and subcontractors. The Management of OCI Plan section mandates identification of responsible personnel, documentation location accessible to contracting officers, attachment of corporate OCI policies, description of execution processes, and procedures for notifying the Contracting Officer of subcontractor changes, new OCI situations, and plan violations. OCI Training requirements include training plans for all program personnel (at minimum annually), documentation procedures, personnel conflict identification processes, employee transfer policies to prevent sensitive information flow, nondisclosure agreements with specified protection periods, and documented disciplinary actions for non-compliance. OCI Plan Reviews require corporate oversight and audit descriptions with stated frequency. The Description of OCI Situation section requires detailed identification of actual and potential conflicts classified as biased ground rules, impaired objectivity, or unequal access to non-public information, with applicable contract numbers. OCI Mitigation requires description of avoidance or mitigation techniques for each identified situation, identification of responsible personnel, and specification that biased ground rules or impaired objectivity situations must involve mitigation techniques beyond firewalls alone. Additional requirements include definitions of terms and acronyms used throughout the plan.
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SPACE SYSTEMS COMMAND
ORGANIZATIONAL CONFLICTS OF INTEREST
(OCI) MITIGATION PLAN CHECKLIST
March 2026
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 Contractor’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.
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