Attachment_L-8_OCI_Plan.docx

ATTACHMENT L-8 – OCI Plan

|X| Administrative

|_| SR&QA

FAR Subpart 9.5, Organizational and Consultant Conflicts of Interest NFS 1852.209-71, Limitation of Future Contracting NFS 1852.237-72, Access to Sensitive Information NFS 1852.237-73, Release of Sensitive Information NASA Guide on Organizational Conflicts of Interest (March 2010)

8. Preparation Information (Include complete instructions for document preparation)

a. Data Type: 1

b. Scope: The OCI Plan describes the Contractor’s comprehensive management approach and implementation methods for avoiding, neutralizing, or mitigating organizational conflicts of interest. After approval, the OCI Plan will become part of the contract.

c. Content: The OCI Plan shall discuss the following:

(1) Purpose: A summary of the Contractor’s rationale for instituting and applying the OCI Plan;

(2) Update Criteria: A description of the criteria and process for determining when an update to the plan is required;

(3) Contractor’s OCI Assessment Methodology: A summary of the general methodology used to identify, avoid, neutralize, or mitigate OCI issues. Define company roles, responsibilities, and procedures for screening (i.e., identifying/recognizing, analyzing/evaluating, resolving, and reporting) existing and new business opportunities for actual/potential OCIs. Include any Contractor policies defining organizational or employee sanctions for violations of Contractor’s OCI procedures or requirements. Identify any Contractor recordkeeping or self-audit requirements related to Contractor’s OCI program. Identify any affiliated companies/entities (e.g., a parent company or a wholly-owned subsidiary) and procedures for coordinating OCIs with such affiliated companies/entities. Explain how the Contractor will flow down the provisions of this mitigation plan to any subContractor that may have a conflict with regard to performing the requirements of this contract;

(4) Contractor’s OCI Response Procedures: A summary of the steps that the Contractor will take when an OCI has been identified of when circumstances have changed such that an OCI issue is probable. Include Contractor procedures for the reporting of all potential/actual OCIs during performance of the contract and the contact of OCI reports;

(5) Identified OCI Risks: A description of identified potential OCI risks, due to the Contractor’s relationships or potential relationships with the Government, other companies, and other contracts. The description shall characterize the risk and measures to avoid, neutralize, or mitigate each OCI threat. If using a firewall, explain how these actions will operate to successfully address the conflict without adversely affecting performance of the contract. Additionally, Contractor shall identify any potential OCIs created by the requirements of this RFP which the Contractor intended to resolve using methods other than mitigation ;

(6) Personnel Clearance Procedures: A description of the procedures the Contractor will use if needed to identify and partition Contractor personnel requiring access to or participation in activities that would otherwise create an OCI issue; and

(7) OCI Training: A description of the training to be provided to a Contractor personnel regarding potential OCIs on this contract.

d. Format: Contractor format is acceptable. The product shall be in a Microsoft Office compatible format.

e. Distribution:

(1) BH4/Contracting Officer (Electronic copy)

(2) EG4/Contracting Officer’s Representative (Electronic copy)

f. Submission:

(1) Initial: Due with proposal

(2) Final: By the end of the contract phase-in period

(3) Approval: Within 30 days of an acceptable OCI Plan

(4) Update Frequency: As required

g. Maintenance: Revisions to this DRD shall be incorporated by change page or complete reissue. The Contractor shall review the OCI Plan on an annual basis or as directed by the Contracting Officer to revise the OCI Plan if necessary. Revisions are subject to Contracting Officer approval.