Mandatory Display of Fraud Posters
Client Alert | less than 1 min read | 09.16.11
On September 16, 2011, DoD issued a final rule that requires contractors to prominently display in common work areas -- within business segments performing work on DoD contracts -- fraud hotline posters prepared by the DoD Office of the Inspector General, unless the contract is for the acquisition of a commercial item, will be performed entirely outside the United States, or does not exceed $5 million. This requirement must be flowed down to all subcontracts that similarly qualify.
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On February 24, 2025, in Raytheon Company v. United States, Judge Bonilla of the Court of Federal Claims (CFC) submitted the latest—and perhaps most definitive—entry in a growing body of jurisprudence confirming the CFC’s Tucker Act bid protest jurisdiction encompasses challenges to awards made under the Department of Defense’s Other Transaction Agreement (OTA) authority. Upon establishing a framework for considering its ability to review OTA awards, the CFC declared itself “the de facto forum for bid protests involving ‘other transactions’ and ‘other transaction agreements.’”
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