# Federal Contracting: Ethics Compliance and Enforcement Course (Self-Paced)

Canonical URL: <https://www.graduateschool.edu/courses/federal-contracting-ethics-compliance-and-enforcement-course-self-paced>

## Overview

Procurement fraud scandals have prompted a tightening as well as an expansion of the regulatory requirements concerning ethics and standards of conduct. Both government contracting personnel and industry personnel need to understand what is expected of them with respect to procurement integrity and conflicts of interest, including the FAR provisions on contractor ethics. This course explains the key procurement ethics laws and regulations, as well as the role of key government entities involved in overseeing and enforcing those laws and regulations. It includes the text of selected regulations and guidance as well as references to public and private sector sources of information.

## What you'll learn

- Recognize and apply the principles of ethical behavior in Federal procurement.
- Describe administrative debarment and suspension procedures and the administrative tools available to the Contracting Officer for ensuring contractor responsibility.
- Differentiate between a personal and an organizational conflict of interest.
- Identify and explain the requirements of the Procurement Integrity Act.
- Explain the whistleblower (qui tam) provisions of the civil False Claims Act.
- Describe the FAR rule regarding the contractor business ethics compliance program and mandatory disclosure requirements.

## Curriculum

#### Module 1: Principles of Ethical Behavior in Federal Procurement

- Explore the historical evolution of ethical standards in federal procurement.
- Understand definitions and implications of fraud, waste, and abuse.
- Examine the role of Executive Orders and federal statutes on ethics in procurement.
- Learn about kickbacks, bribery laws, and standards of conduct for both government and contractor employees.
- Understand the impact of whistleblower protections and personal/organizational conflicts of interest.

#### Module 2: Roles of GAO, DOJ, IGs, Office of Government Ethics, OSC, DAEOs, and CCOs

- Understand the audit and bid protest functions of the GAO.
- Review DOJ's civil and criminal enforcement roles in procurement fraud.
- Examine the investigative powers and functions of Inspectors General.
- Study the regulatory and advisory role of the Office of Government Ethics.
- Learn how OSC investigates whistleblower complaints and Hatch Act violations.
- Explore the roles and responsibilities of Designated Agency Ethics Officials and Corporate Compliance Officers.

#### Module 3: Contractor Responsibility—Debarment and Suspension

- Define "responsible contractor" and understand FAR Part 9 requirements.
- Understand the causes, procedures, and consequences of debarment and suspension.
- Review tools like SAM, CPARS, PPIRS, and FAPIIS for evaluating contractor responsibility.
- Examine due process rights for contractors and subcontractor flowdown clauses.
- Study the U.S. Sentencing Guidelines related to corporate ethics compliance programs.

#### Module 4: The False Claims Act Whistleblower Provisions and Other Statutes

- Understand the Civil and Criminal False Claims Act and its qui tam provisions.
- Learn about whistleblower protections and enforcement actions under FAR 3.9.
- Review other statutes related to bribery, illegal gratuities, and financial conflicts of interest.
- Examine timelines for bringing whistleblower actions and protections against reprisal.

#### Module 5: Conflicts of Interest and Restrictions on Information

- Distinguish between personal and organizational conflicts of interest (PCI/OCI).
- Study FAR Subpart 3.1 and 9.5 standards on ethical conduct and conflict mitigation.
- Understand the Procurement Integrity Act and the rules around obtaining/disclosing source selection info.
- Learn about revolving door issues and post-employment restrictions under 18 U.S.C. §§ 207–209.
- Explore real-life enforcement cases related to violations of federal ethics standards.

#### Module 6: Contractor Performance Information and Other Databases

- Understand how contractor performance is tracked through CPARS and PPIRS.
- Explore the use of FAPIIS for integrity and performance-based decisions.
- Review the role of SAM, FPDS, and Performance.gov in procurement transparency.
- Understand reporting requirements for executive compensation and subcontract awards.
- Learn about default termination reporting and use of contractor report cards in award decisions.

#### Module 7: FAR Contractor Code of Business Ethics and Conduct Rule

- Understand FAR Subpart 3.10 requirements for contractor ethics programs.
- Review mandatory disclosure rules for reporting credible evidence of wrongdoing.
- Explore the implications of non-disclosure, including suspension and debarment.
- Examine the required elements of an effective compliance program and internal controls.
- Learn how ethics rules apply to subcontracts and non-U.S. performed contracts.

## Pricing

**Tuition:** $1050