Government Contracts Quarterly Update - July 2014


The Government Contracts Quarterly Update is published by BakerHostetler’s Government Contracts Practice team to inform our clients and friends of the latest developments in federal government contracting.

Topics will include:

- Proposed Rule Focuses on Audit of Business Systems, May Expedite and Streamline Process

- D.C. Circuit Extends Attorney-Client Privilege to Internal Compliance Investigations

- Executive Order 13665 Allows Agencies to Terminate Contracts If Contractors Retaliate Against Employees Who Disclose Compensation

- Proposed DOD Rule Expands Contractors’ Risk of Personal Conflicts of Interest

- DOD’s Restrictions on Counterfeit Parts Rule Is Limited to Electronic Parts, but More Changes Are Expected

- DOD’s New FOCI Rules Present New Challenges to Contractors with Foreign Connections

- Would-Be Service Contractors Face Exposure of up to $10,000 Penalty per Day under HHS Contracts

- GAO Decides That Small Business Joint Venture Proposals Do Not Require SBA Pre-Approval

- Baker Team Secures Arbitration Award for Wrongful Termination of Subcontract

- Legislative and Regulatory Updates.

- Excerpt from Proposed Rule Focuses on Audit of Business Systems, May Expedite and Streamline Process:

On July 15, the Department of Defense (“DOD”) released a proposed rule, 79 Fed. Reg. 41172, that will allow contractors that are subject to the requirement for audit of key business systems (more than $50 million annually of contracts requiring cost or pricing data) to self-certify that their key business systems are adequate and to elect to use DOD-approved third-party auditors to periodically validate those same systems. The comment period ends on September 15, 2014.

Please see full update below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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