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Consulting for Prime and Subcontractor


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Guest Vern Edwards
If a consulting firm manages (includes pricing) the same contract for a prime contractor and a subcontractor are there any potential OCI issues?

No. There are no OCI issues.

I understand you to be talking about contracts between private entities. FAR 2.101 defines Organizational Conflict of Interest as follows:

“Organizational conflict of interest” means that because of other activities or relationships with other persons, a person is unable or potentially unable to render impartial assistance or advice to the Government, or the person’s objectivity in performing the contract work is or might be otherwise impaired, or a person has an unfair competitive advantage.

OCI is a concept and term of art applicable to contracts between private entities and the government. As covered in the Federal Acquisition Regulation, it does not apply to contracts between private entities.

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Yes Vern is right and I should have clued-in that "OCI" is a term of art applicable only to government contracting officers. I was thinking about "conflicts of interest" ("COI") as addressed by the policies found at many government contractors. I suspect that the situation initially described would be the cause of some concern for the contractors but, as Vern correctly noted, not for the government.

H2H

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