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Overview

In November of 2008, Mandatory Disclosure Rule (MDR) became effective in the FAR requiring disclosure of certain violations of federal criminal law and civil False Claims Act.  It also mandates contractors to create business ethics awareness and compliance programs and an internal control system.   

This rule impacts, among other things, contract breach, past performance ratings, Suspension and Debarment, False Claims Act, loss of business and personal risk. 
This one day program discusses overlapping rules fin FAR Parts 9 and 52, reportable categories including FCA challenges. It requires a written code of Business Ethics and Conduct including an internal controls procedure. It also requires ‘timely’ disclosures of ‘credible evidence.

Learn how disclosures are being made through the DOD and GSA as well as best practices.  You will learn about how the government handles disclosures as not to allow for release of sensitive information to the public.  You will receive guidance on the government’s ability to have access to your employees and how best to handle.

By using examples and scenarios, you will learn how to better protect you and your organization from MDR violations. 

Learning Objectives:
Upon completion of this course you will be able to

  • Evaluate disclosure statements and implement industry best practices
  • Quickly find rules on disclosure statements in the FAR and understand their meanings
  • Receive guidance on what the government can and cannot access
  • Determine what may need to be disclosed to the government and what does not
Dates/Locations
No upcoming dates/locations at this time
Agenda
8:00 AM - 3:00 PM
Las Vegas, NV
9:00 AM - 4:00 PM
All Other Locations
  • Identifying Reportable Conduct
    • Meaning of In Connection With the Award, Performance, or Closeout of a Government Contract or Subcontract
    • Reportable Criminal Conduct
    • Reportable Violations of the Civil False Claims Act
    • Significant Overpayments
 
  • The “Credible Evidence” Standard
  • Contractor Obligations with Respect to Principals
  • Disclosures Regarding Subcontractors and Agents
  • Obtaining Information Regarding Potentially Reportable Events
  • Timely Disclosure and Look-Back Requirements
  • The Form, Content, and Recipients of Disclosures
  • Voluntary Disclosures
  • Full Cooperation
  • Preserving Confidentiality and Privilege and Preventing Disclosures to Third Parties
  • Dealing with Company Employees and Officers
  • Past Performance and Contractor Responsibility Determination Requirements
  • Structuring Ethics Awareness Programs and Internal Control Systems
  • Non-procurement Transactions
Experts
  • Jonathan S. Aronie
    Partner, Sheppard Mullin
    Jonathan S. Aronie is a partner in Sheppard Mullin's Government Contracts practice group, focusing on litigation, internal investigations, and Government Contracts. Jonathan is the co-author of Multiple Award Schedule Contracing (Xlibris 2002), and has extensive experience r...
    See Full Bio
  • Keith R. Szeliga
    Partner, Sheppard Mullin Richter & Hampton LLP
    Keith R. Szeliga is a partner and Co-Practice Group Leader in the Government Contracts, Investigations, and International Trade Group in Sheppard Mullin’s Washington, D.C. office. Mr. Szeliga represents clients ranging from small businesses to the nation's largest defense contractor...
    See Full Bio
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: 6.5 (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: 6.0 (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: 5.50 (60 minutes), 6.5 (50 minutes)
Travel
No travel information is available at this time
Level
  • 100
    Basic or fundamental subject matter is covered. Courses are geared to general knowledge or can be taken as a refresher.
  • 200
    Specific topics or issues within a topic area are covered. Students should be familiar with terms of art and general concepts concerning the course topic.
  • 300
    Workshops and class discussions cover specific subject matter in-depth, and participation is strongly encouraged. Attendees should have at least 2-3 years' experience in the area of study.
  • 400
    Courses build upon students' knowledge and experience, and cover complex issues within the subject matter. Should have 4-5 years' mastery of subject for in-depth analysis.
  • 500
    Masters-level programs designed for professionals with 5+ years' experience. Courses cover in-depth and technical analysis on specific subjects and updates on current issues.