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Procurement Integrity

Procurement integrity regulations mandated by the Federal government prohibit certain actions by government officials, employees, consultants and advisers, and those of competing contractors during the conduct of any Federal agency procurement of property or services. There are provisions of the Procurement Policy Act covering four areas of concern to the University. The four areas are:

  1. Past employment - For two years after covered participation in a federal agency procurement has ceased, an officer or employee may not: Participate on behalf of a competing contractor in any negotiations leading to award; modification or extension of the contract; or participate personally on behalf of a competing contractor in the performance of the contract.
  2. Seeking employment - During the conduct of a federal agency procurement of property or services, an agency procurement official may not: Solicit, accept or engage in discussion of future employment or business opportunity with an officer, employee, representative, agency or consultant of a competing contractor.
  3. Gratuities - During the conduct of an agency procurement, a procurement official may not: Seek or receive any money, gratuities or other thing of value from an officer, employee, representative, agency or consultant of a competing contractor.

    A parallel provision prohibits competing contractors from offering, giving or promising such gratuities.

  4. Disclosure of Information - During the conduct of an agency procurement, a procurement official or anyone else who properly or improperly receives such information may not: Disclose any proprietary or source selection information regarding the procurement to any person not authorized to receive such information. Competing contractors cannot solicit or obtain such information from any agency officer or employee prior to the award of the contract.

Reference:

Federal Procurement Policy Act, 41 U.S.C. 401-20, as amended by P.L. 100-679 including the requirement of Section 6.

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