Last fall, the Federal Acquisition Regulation (FAR) Council and Department of Defense (DoD) published proposed rules to implement requirements in President Obama’s Executive Order 13627 and the National Defense Authorization Act (NDAA) of FY 2013 intended to combat human trafficking in the Government’s supply chain. These implementing rules, which have drawn extensive comments from a broad array of stakeholders, likely will take effect in 2014, and for the reasons discussed below, the interim or final…

The following discussion provides several general pointers for contractors seeking advice on surviving the current government shutdown. Initially, it is important to understand that in many instances a contractor’s compliance obligations do not cease simply because the government has shuttered.  For example, reporting websites, including the System for Award Management (SAM), the Electronic Subcontracting Reporting System (eSRS), the EEO-1 online filing system, and the VETS 100/100A reporting system remain active and must be updated…

Earlier this week, the Senate-House Conference Committee Report on the National Defense Authorization Act for Fiscal Year 2013 (NDAA) was released.  As we reported here, the Senate’s original version of the NDAA [1] would expressly permit access to contractor internal audit reports by the Defense Contract Audit Agency (DCAA).  The House’s original version of the NDAA which passed in May did not include a similar provision.[2] The Conference Report now includes a revised…

On September 25, President Obama unveiled a new executive order which requires changes to the Federal Acquisition Regulation (“FAR”) to prohibit federal contractors, contractor employees, subcontractors, and their employees from engaging in activities related to human trafficking, as defined in the Trafficking Victims Protection Act of 2000 (“TVPA”). The order states that “[a]s the largest single purchaser of goods and services in the world, the United States Government bears a responsibility to ensure that taxpayer…