Office of Inspector General (OIG). Federal Acquisition Regulation (FAR) Disclosure Requirements and the American Recovery and Reinvestment Act (ARRA). Richard P. Levi Counsel to the Inspector General General Services Administration. May 6, 2010. AGENDA. Value to the Customer
Federal Acquisition Regulation (FAR) Disclosure Requirements and the American Recovery and Reinvestment Act (ARRA)
Richard P. LeviCounsel to the Inspector GeneralGeneral Services Administration
May 6, 2010
Value to the Customer
Issue 1: What does in connection with the award, performance, or closeout of a contract mean?
Issue 2: What types of criminal conduct are covered?
Issue 3: What constitutes a reportable violation of the False Claim Act (FCA)?
Consider FCA Amendments - May 20, 2009
Issue 4: What is a significant overpayment?
Issue 5: What is credible evidence?
Issue 6: Who is a principal?
Why definition of principal matters
Issue 7: What are requirements regarding subcontractors?
Issue 8: What is a “timely” disclosure?
Issue 9: What are the “look back” requirements?
Issue 10: What should be the form and content of disclosures?
Issue 11: Who should disclosures be made to?
Issue 12: Are there still voluntary disclosures?
Issue 13: How to preserve confidential and privileged information?
ARRA and FAR Rule comparison