Federal Contracting: Ethics Compliance and Enforcement Course

Module 1: Principles of Ethical Behavior in Federal Procurement

• Explore the historical evolution of ethical standards in federal procurement.
• Understand definitions and implications of fraud, waste, and abuse.
• Examine the role of Executive Orders and federal statutes on ethics in procurement.
• Learn about kickbacks, bribery laws, and standards of conduct for both government and contractor employees.
• Understand the impact of whistleblower protections and personal/organizational conflicts of interest.

Module 2: Roles of GAO, DOJ, IGs, Office of Government Ethics, OSC, DAEOs, and CCOs

• Understand the audit and bid protest functions of the GAO.
• Review DOJ's civil and criminal enforcement roles in procurement fraud.
• Examine the investigative powers and functions of Inspectors General.
• Study the regulatory and advisory role of the Office of Government Ethics.
• Learn how OSC investigates whistleblower complaints and Hatch Act violations.
• Explore the roles and responsibilities of Designated Agency Ethics Officials and Corporate Compliance Officers.

Module 3: Contractor Responsibility—Debarment and Suspension

• Define "responsible contractor" and understand FAR Part 9 requirements.
• Understand the causes, procedures, and consequences of debarment and suspension.
• Review tools like SAM, CPARS, PPIRS, and FAPIIS for evaluating contractor responsibility.
• Examine due process rights for contractors and subcontractor flowdown clauses.
• Study the U.S. Sentencing Guidelines related to corporate ethics compliance programs.

Module 4: The False Claims Act Whistleblower Provisions and Other Statutes

• Understand the Civil and Criminal False Claims Act and its qui tam provisions.
• Learn about whistleblower protections and enforcement actions under FAR 3.9.
• Review other statutes related to bribery, illegal gratuities, and financial conflicts of interest.
• Examine timelines for bringing whistleblower actions and protections against reprisal.

Module 5: Conflicts of Interest and Restrictions on Information

• Distinguish between personal and organizational conflicts of interest (PCI/OCI).
• Study FAR Subpart 3.1 and 9.5 standards on ethical conduct and conflict mitigation.
• Understand the Procurement Integrity Act and the rules around obtaining/disclosing source selection info.
• Learn about revolving door issues and post-employment restrictions under 18 U.S.C. §§ 207–209.
• Explore real-life enforcement cases related to violations of federal ethics standards.

Module 6: Contractor Performance Information and Other Databases

• Understand how contractor performance is tracked through CPARS and PPIRS.
• Explore the use of FAPIIS for integrity and performance-based decisions.
• Review the role of SAM, FPDS, and Performance.gov in procurement transparency.
• Understand reporting requirements for executive compensation and subcontract awards.
• Learn about default termination reporting and use of contractor report cards in award decisions.

Module 7: FAR Contractor Code of Business Ethics and Conduct Rule

• Understand FAR Subpart 3.10 requirements for contractor ethics programs.
• Review mandatory disclosure rules for reporting credible evidence of wrongdoing.
• Explore the implications of non-disclosure, including suspension and debarment.
• Examine the required elements of an effective compliance program and internal controls.
• Learn how ethics rules apply to subcontracts and non-U.S. performed contracts.