Events

The Latest FAR Rule on Business Ethics and Mandatory Disclosure of Violations Lunch Seminar

Tuesday, December 9 , 2008

Date:	Tuesday, December 9, 2008
Time:	11:00 AM - 1:00 PM
Cost:	$35 per attendee (Lunch is provided)
Credits:	2 hours of CPE credits
Location:	Beason & Nalley, Inc. Monroe Street Huntsville, AL 35801
Speakers:	Michael Steen Senior Managing Consultant, Beason & Nalley, Inc.
Registration:	Register Online or using FAX/Email Registration Form (PDF)
Registration Deadline:	Monday, December 8, 2008

Synopsis

On November 12, 2008, the FAR Council issued the final rule on "COBEC" or Code of Business Ethics and Conduct including the controversial requirement for mandatory disclosure (of certain violations) to an agency OIG (Office of Inspector General). This final rule, effective December 12, 2008, incorporated most of the "suggestions" from the Department of Justics as well as the demands of Congress (dissatisfaction with the inital rule) and brings with it severe penalties for noncompliance (potential suspension and/or debarment from government contracting). In conjunction with the initial rule (effective December 24, 2007), the FAR (3.1003 and 3.1004) now has a number of requirements which simply cannot be overlooked by any contractor in government contracting.

This presentation is designed to assist contracts and accounting professionals in understanding the COBEC requirements which are a combination of the December 2007 rule and the December 2008 final rule. In this case, gaining an understanding involves not only the wording of the final rule, but also certain public comments (relative to the proposed rules) and FAR Council responses. Key points to be discussed will be:

Contract applicability including provisions of the final rule that are retroactive.
Applicability (limited) to small businesses and contractors with commercial item government contracts as well as contracts performed outside the United States.
COBEC training requirements and Requirements to Post Hotline Posters.
Requirements for Internal Controls.
Mandatory Disclosure of certain violations, civil false claims act violations and significant government overpayments including the requirement to fully cooperate with audit, investigations or corrective actions.
Subcontract flow-down requirements and Prime contractor responsibilities.
The substantial penalties for noncompliance with the Final Rule.
Agency policy and/or guidance applicable to the Final Rule.

Speaker

Mr. Michael E. Steen, Senior Managing Consultant

Mr. Steen is a Senior Managing Consultant with Beason & Nalley, Inc. He provides government contracts consulting services to our government contractors primarily related to cost accounting, financial compliance and DCAA audit expectations. Prior to joining Beason & Nalley, Mr. Steen served in a number of capacities with DCAA for over thirty years. Upon his retirement, Mr. Steen was one of the top seven senior executives with DCAA.

We look forward to seeing you at the Lunch Seminar, Tuesday, December 9th! Be sure to register.

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