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Overview

On November 12, the FAR Council issued a final rule establishing The New Contractor Business Ethics Compliance Program and Disclosure Requirements. The new rule is broad in scope, burdensome in application, and – in some respects at least – almost immediate in its effect. This new, one-day seminar by Federal Publications will examine the requirements of the new rule, which will result in significant changes for all government contractors and subcontractors.

The New Contractor Business Ethics Compliance Program and Disclosure Requirements is an accelerated one-day briefing on what contractors must know about the new rules on:

  • Internal Control Systems to Detect and Prevent Improper Conduct
  • Codes of Business Ethics and Conduct
  • Mandatory Disclosure Obligations
  • Requirements for Reporting Violation and Significant Overpayments
  • …and more

Since the rule went into effect on December 12, 2008, and because elements of the new rule apply to all federal contractors, this course is essential to educate and protect your entire organization.

The new rule has four primary elements:

  • First, it requires all contractors (including commercial items contractors and small businesses) to establish and promote awareness of a Code of Conduct.
  • Second, it requires all contractors to disclose to the Government any “credible evidence” of (i) certain crimes, (ii) a violation of the civil False Claims Act (FCA), or (iii) a significant overpayment by the Government.
  • Third, it provides for suspension/debarment for a contractor’s failure to “timely disclose” those same events if there is "credible evidence" to support a violation – even where the event occurred prior to the effective date of the new rule.
  • Fourth, it mandates that large companies with non-commercial items contracts implement a comprehensive “internal control system.”
Agenda
9:00 AM - 4:00 PM

Contractor Business Ethics Compliance Program and Disclosure Requirements: Course Curriculum

  1. Understanding the new rule and its scope
    1. What is required?
      1. How does it differ from what exists now?
      2. To whom does the rule apply?
      3. When must you begin complying?
  2. Understanding the risks of non-compliance
    1. Suspension and debarment?
      1. Criminal prosecution?
      2. Breach of contract?
      3. Termination?
  3. Complying with the new disclosure obligations
    1. Understanding the company’s retroactive disclosure obligations
      1. Understanding the company’s “go-forward” disclosure obligations
      2. Understanding key terms
    2. What is "credible evidence?"
      1. What is a “timely” disclosure?
      2. Who is a “principal”?
      3. What is a reportable crime?
  4. Conducting internal investigations in the post-Dec 12 environment
    1. Understanding what must be investigated
      1. Understanding how investigations must be conducted
      2. Understanding implications of investigation results
      3. Issues regarding the Attorney Client Privilege
  5. Special M&A / due diligence considerations brought about by the new rule
    1. Implications of the rule’s retroactive, “look-back” provisions
      1. Reviewing a company’sprior disclosures
      2. Reviewing target company compliance program
      3. New reps and warranties
  6. Drafting a Code of Conduct
    1. "Must have" provisions
      1. Tailored provisions
      2. What do you do with it?
      3. How do you prove employee awareness?
  7. Implementing a compliant Internal Control System
    1. Understanding the new minimum mandatory requirements
      1. Discussion of industry best practices
Accreditation
See Individual Courses For Available Credits
Certificates of Completion are provided to all seminar participants who attend Federal Publications Seminars courses following the event, upon request.
CPE: Continuing Professional Education
Field of Study: Specialized Knowledge
Delivery Method: Group-Live Classroom
Federal Publications Seminars is affiliated with West Professional Development and is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.
For more information regarding administrative policies such as refunds, cancellations and complaints, please contact Federal Publications Seminars at 888.494.3696.
CPE Hours
This program is eligible for: 6 (CPE) hours of credit
Program Level: Basic
Program Prerequisite: None
Advance Preparation: None
Method: Group-Live
CLP: Continuous Learning Points
Approved for CLP by Defense Acquisition University
Defense Acquisition Workforce members must acquire 80 Continuous Learning Points (CLP) every two years from the date of entry into the acquisition workforce for as long as the member remains in an acquisition position per DoD Instruction 5000.66. We will provide you with documentation of points awarded for completing the event.
CLP Hours
This program is eligible for: (CLP) hours of credit
CLE: Continuing Legal Education
States have widely varying regulations regarding MCLE credit. LegalEdcenter is an approved provider in AL, AK, AR, CA, GA, IL, ME, MO, MS, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, PA, RI, SC, TN, TX, UT, VA, VI, VT, WA, WI, and WV. Credit may be applied for in other jurisdictions on request and in accordance with state MCLE rules.
Please note that because some states are changing their policy on CLE reporting, you will need to fill out the request for credit from Federal Publications Seminars within 10 business days, or we may not be able to issue credits for the program.
CLE Hours
This program is eligible for: 5.5 (60 minutes), (50 minutes)