Two recent news stories regarding organizational conflicts of interest should catch the attention of leadership teams at federal government contractors. As reported by Bob Brewin at Nextgov (“VA abruptly cancels key software contract for joint health record“), the Department of Veterans Affairs has terminated the $102.6 million contract awarded to ASM Research because of two employees who worked for the Military Health System when the contract went out for bid and are now ASM Research employees. Alysha Sideman of Washington Technology reported on the debarment of Booz Allen’s San Antonio office by the Air Force (“Booz Allen’s San Antonio office faces AF debarment“), citing that at least one former government official who shared sensitive information about a coming Air Force procurement after being employed by Booz Allen. Booz Allen took proactive action after discovering the conflict of interest. They terminated the employee, withdrew from the procurement and alerted the government.
Are the efforts of your recruiting department, general counsel’s office and business development teams integrated and working together to avoid real or perceived institutional conflicts of interest? Are the costs of even the appearance of a conflict known to your employees? Public embarrassment, debarment of an office and $100 million dollars are steep prices to pay for an avoidable conflict. Practicing due diligence in the recruiting process by asking probing questions of candidates about conflicts from prior roles (either in government or at a competitor) are critical. Training your team to ask the right questions before the employee is hired and to structure the role properly after the hire to avoid problems is a great investment. Making certain that external recruiters are also sensitive to the adverse effects of conflicts is also important. While no one wants to impede former government employees from joining the private sector, it is in the best interest of everyone involved that no surprises await the employer.
TMG’s Take is a regular e-mail advisory produced by The McCormick Group. The company’s Government Contracting group combines the expertise of our knowledgeable consultants to help government contractors fulfill all of their recruiting needs. TMG’s Take covers topics across the spectrum of the government contracting industry, including business development, proposals, contract management, cyber security, compliance, R&D, technology, and finance. Please direct all inquiries to Brian McCormick, Executive Vice President at (703) 841-1700 or bmccormi@tmg-dc.com.
