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Less Risk, More Reward: DoD Proposed Rule on Operational Contract Support Expands Overseas Contracting Opportunities

Client Alert | 1 min read | 01.22.21

On the heels of a 2019 Government Accountability Office report that recognized the Department of Defense’s (DoD) efforts in reducing risks associated with overseas operational contract support (OCS), DoD issued a proposed rule updating its OCS policies and procedures. The proposed rule continues DoD’s focus on enhancing its ability to effectively oversee, manage, and account for contractors supporting U.S. military operations to reduce the risk of fraud, waste, and abuse. This proposed rule seeks to:

  • Broaden the types of overseas operations for which contracted support may be used, to include non-contingency operations, such as humanitarian assistance or peace operations, or overseas military exercises;
  • Clarifies contractors’ responsibilities for deploying personnel in support of overseas operations, including medical and dental fitness standards;
  • Details the services that DoD is authorized to provide contractors; and
  • Promotes efficiency and transparency by removing internally-facing information requirements.

If adopted, this proposed rule will broaden the scope of military operations for which contractor support could be deployed. It would also provide clarity and consistency to other OCS procedures to allow contractors to better plan for compliance and the DoD to more effectively oversee contractors’ OCS performance. Comments on the proposed rule are due March 8, 2021.

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New Developments in DOJ Whistleblower Policies and HHS Disclosures: Key Takeaways for General Counsel, Chief Compliance Officers, and Boards

On October 20, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division announced a new whistleblower rewards initiative, the Fraud Whistleblower Incentive Program (WHIP). Assistant Attorney General Colin M. McDonald issued a directive earlier this month directing Division leadership to design and implement policies and programs that incentivize whistleblowers to bring forward credible information pertaining to fraud. The new WHIP incentive pays awards of $10,000 to $30,000 for qualifying tips at or around the time criminal charges are filed or unsealed, rather than years later at case resolution....