L7. OCI Mitigation Plan Checklist.pdf
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- Solicitation number
- FA881923R1000DRAFT
About this file
This document contains an organizational conflicts of interest (OCI) mitigation plan checklist for a Space and Missile Systems Center contract opportunity. The checklist outlines general considerations, definitions, management processes, training requirements, reviews, descriptions of actual and potential OCI situations for offerors, and techniques for avoiding or mitigating identified OCI risks. It requires statements of corporate commitment to OCI compliance, organizational charts, letters of commitment from teammates and subcontractors, and descriptions of training, documentation, auditing, and disciplinary policies. For potential OCI situations, offerors must explain contributing factors and propose avoidance or mitigation techniques involving more than just firewalls for biased ground rules or impaired objectivity issues.
The related federal contract opportunity is a draft request for proposal for professional services to support Space Systems Command's Space Domain Awareness and Combat Power/Battle Management Command Control and Communications program. It seeks industry feedback on draft documents by July 19, 2023 to ensure requirements are clear before release of the formal RFP. Offerors must identify any potential organizational conflicts of interest and submit comments using an attached matrix.
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SPACE AND MISSILE SYSTEMS CENTER
ORGANIZATIONAL CONFLICTS OF INTEREST (OCI)
MITIGATION PLAN CHECKLIST
October 2018
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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