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LOGCAP Oversight Lacking?

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Deja_vuThe proximate cause for many of DCAA’s audit-related problems are the audits of the LOGCAP (Logistics Civil Augmentation Program) contracts in 2007 and 2008. DCAA showed up late to the party and made up for it by taking a hard line with LOGCAP contractors (primarily KBR but also others), questioning millions (if not hundreds of millions) of costs incurred and also asserting that the majority of those contractors’ business systems were inadequate—allegedly leading to fraud, waste, and abuse.

More than a decade later, we still feel the ripples from those stones thrown in the government contracting pond. The Contractor Business Systems oversight regime sprung from that source. The backlog of unaudited contractor final billing rate proposals sprung from that source. DCAA’s relative lack of CAS-related audits and post-award (defective pricing) audits sprung from that source. DCAA’s “risk-based” audit approach (designed to “risk away” small dollar value audits in favor of larger dollar value audits) sprung from that source. Putting DCMA in charge of reviewing contractor Disclosure Statements sprung from that source.

It all started with LOGCAP contractors and it continues to this day.

The DoD Office of Inspector General (DoD OIG) released an audit report on May 11, 2018 that reminded us of the old days of DCAA LOGCAP audits. In audit report DODIG-2018-119, the DoD OIG reported several headline-worthy assertions, including:

  • Army Contracting Command and Defense Contract Audit Agency (DCAA) officials did not adequately monitor all 128 LOGCAP IV vouchers submitted from 2015 to 2017 for questionable and potentially unallowable costs

  • DoD policy established DCAA prepayment reviews as the sole method of voucher oversight prior to payment; however, prepayment reviews are cursory reviews not sufficient for preventing reimbursement to the contractor for all potentially unallowable costs

  • The Army paid all 128 LOGCAP vouchers the LOGCAP contractors submitted from 2015 to 2017, valued at $2.4 billion, with little or no examination of the supporting documentation. We [DoD OIG] identified at least $536 million of the $2.4 billion billed on vouchers that were supported by questionable documentation that warranted further analysis

  • We also identified $422,825 in costs that, based on the description of the costs in contractor’s accounting data, may not be allowable

Wow. That’s a whole lot of assertions, right?

Well, not really. Much like the DCAA assertions from a decade ago, when examined more closely the DoD OIG audit findings are more headline material than anything else. Let’s look closer:

  1. Worst case: contractors submitted $2,400,000,000 in costs for reimbursement, of which $536,000,000 “warranted further analysis.” Not that the costs were improper or unallowable, just that somebody should have looked harder at them. That’s about 22 percent of all costs incurred—a very high number.

  2. When looking at the $536,000,000 value, DoD OIG admits the truth: the value is comprised of 2,531 individual transactions that “did not contain sufficient detail for us to determine how the contractor calculated the costs.”

  3. In fact, DCAA had already reviewed those costs and understood them, even though the DoD OIG auditors did not. The report stated “According to DCAA officials, the contractor did not intend these line items to be literal representations of the costs claimed in the contractor’s voucher. DCAA officials stated that the contractor clustered these line items, and thousands of similar line items in the contractor’s billing support, under one employee identification number. DCAA officials explained that the contractor billed in this manner to reduce the number of files attached to the vouchers. However, the contractor’s presentation of cost data in such a manner lacks transparency and reduces contracting and auditing officials’ ability to determine whether costs are allowable.” So the 2,531 transactions were in fact summaries of thousands upon thousands of other accounting transactions, summarized for ease of reviewing.

  4. As readers likely know, contracts contain billing instructions. Indeed, DCAA has an entire audit program (17390) dedicated to “contractor compliance with billing instructions.” Had the contracting activity wanted the contractors to provide additional detail for certain contractor costs, it had ample opportunity to do so. If those contractors were now to be asked to comply with modified billing instructions, in our view those contractors would be entitled to an equitable adjustment of the contract price (including fee) for doing so.

  5. But modifying the contracts is exactly what the DoD OIG recommended be done. The report stated, “To ensure that future vouchers include supporting documentation that accurately represents the nature of the claimed cost, ACC-RI should modify the LOGCAP IV contract to require contractors to submit transaction-level accounting data that accurately represents the costs billed on vouchers in iRAPT.”

  6. With respect to the $422,825 in potentially unallowable costs, the report stated, “The Defense Contract Audit Agency Director … stated that the Defense Contract Audit Agency did not find any significant unallowable costs during its review of the $422,825 in costs we identified as potentially unallowable.”

Thus, much like the DCAA audit reports and testimony of a decade ago, the DoD OIG audit report is full of attention-grabbing headlines, but not much else.

Left unstated in the report is the fact that these were all interim payment vouchers. In other words, they were not final payments; they were interim payments and subject to subsequent review. In fact, in addition to the 17390 audit mentioned above, DCAA has the 10100 (audit of incurred costs) and the 10180 (Iraq direct cost testing) and the 11015 (testing of paid vouchers) audit programs available to be used on these contractor vouchers.

The DoD OIG didn’t mention the additional controls available to the contracting officer and contracting activity, possibly because doing so would have detracted from the headline-worthiness of the findings.

It feels like déjà vu all over again.

Last Updated on Monday, 21 May 2018 12:27

The Map is Not the Territory

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I’m working on this theory about compliance. I’m not saying it’s fully baked yet, but I thought I’d share some thoughts. Your feedback is welcome.

First, the title of this article. It comes from “General Semantics”—an early-to-mid-century philosophical movement. Although General Semantics aimed at changing human thoughts and behaviors, what interests me about it was how it later impacted research into human perceptions and communication. The Institute of General Semantics continues to probe these areas. Although I’m in no way any kind of expert in the area, my layperson’s understanding is that a foundational precept was the notion of abstraction. The title is based on a General Semantics axiom that the description of a thing is not the thing itself. You can describe an object or a feeling, but that description is limited by your language and my internal language (how I process what you are describing). Neither of us is actually sensing the true object (or feeling). Another General Semantics saying is “the word is not the thing.” You get the idea.

Anybody who has ever relied solely on GPS directions and, as a result, has made a wrong turn or gotten lost, understands this concept. The GPS model on which the directions are based may not, in fact, be an accurate representation of the environment in which you are driving.

How does this all relate to compliance?

It seems to me that a compliance plan is like a map. It is the abstraction of compliance. It is not compliance. It’s useful—as maps are useful—as a guide or limited description; but it is subject to limitations (like our GPS directions) and thus should not be relied upon as being the entire compliance universe.

Compliance is the thing. Compliance is people—individual people—complying with rules and guidelines. Those people are making decisions in the moment. Those decisions lead to actions that are (or are not) compliant with the rules and guidance the organization has determined it wants to follow.

Right away it becomes apparent that there are abstract rules and regulations and laws. The “organization” (another abstraction) reviews those abstract things and decides, based on the review, what behaviors and actions constitute “compliance.” The first step (and the most abstract step) is having knowledgeable people within the organization review the various rules, regulations, and laws in order to determine which ones are applicable to the organization and then what compliant behavior and actions look like. The result of this review is a set of parameters that guide individual behavior.

Another complication is that the laws, regulations, and rules change—so the review must be performed fairly frequently.

The review output is a set of parameters. Individual actions and behaviors that fall within the parameters are “compliant;” whereas those that fall outside the parameters are non-compliant and require correction.

The next step is to translate the parameters into written guidance. Policies, procedures, practices. Command media, each piece of which has a topic and an associated behavioral parameter. This is compliant behavior, this is not compliant behavior. The documents are another abstraction. Somebody has to decide what to communicate and how to communicate. The end goal is to effectively communicate in such a way that an individual faced with a decision—a choice—can use the document as an aid. The better the document, the more likely the individual will be to make a decision that leads to behavior within the desired parameters—compliant behavior and compliant actions.

When complete, the command media must be explained. Individuals must be trained. People need to understand (1) where to find the guidance, and (2) where to find within the guidance the decision aid they are seeking. Many times, organizations opt to create Computer Based Training (CBT) for such interaction; but note that the creation of CBT itself involves choices and decisions about what content to teach and want content not to teach. Even if the training is instructor-led, the communication is almost wholly dependent on the instructor’s competence—not only in the subject matter but also in effectively communicating the subject matter. Finally, regardless of the training modality, the student’s mindset is critical. Students on the phone listening (on mute) to a conference call while simultaneously watching a CBT are likely not paying sufficient attention to either task. (As we’ve asserted before, multi-tasking is a detrimental myth.) Accordingly, effective communication is not being achieved, regardless of the effort put into the training by those who created the CBT or the instructor.

At this point, to create a decision that leads to compliant behavior or action, we have had to navigate multiple levels of abstraction. Each level has required choices, and those choices have reduced the full and complete “reality” of the thing. We don’t use the full text of an applicable statute; we abstract it and summarize. We don’t publish the full summary; we piece it into parts and create documents that explain it and apply it to organizational functions and activities. That step involves many choices. Finally, we train individuals; but we don’t train them in the entire command media document(s); we pick and choose the parts we think are important for the individuals to know.

It’s conventional wisdom that when you have communicated expectations to employees and trained them in those expectations, you are now positioned to enforce discipline. You may in fairness reward compliant behavior and penalize noncompliant behavior. But in order to get here you have had to make so many abstractions, so many choices, so many compromises! Can you truly be said to have effectively communicated both the parameter and the consequences?

I’m not sure you have. But the conundrum is that communicating the actual thing--the compliance driver--is literally impossible. The map is not the territory. If you made a map that was 100 percent in fidelity with the territory, then you would be recreating the territory. You would have a map that had a 1:1 scale: one mile would equal one mile. It would be accurate; but it would also be unusable. If you drafted a a policy or procedure that was 100 percent the law or regulation or rule itself, then you would be simply recreating the statute or regulation or rule, instead of creating a useful aid for individual decision-making.

Some thoughts for you to consider as you create your compliance plans.

Last Updated on Monday, 14 May 2018 18:56

Long-Term Travel

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We’ve noticed that, for a while now, the Department of Energy (DOE) has been moving forward on clarifying and streamlining existing acquisition rules and regulations. Good for them! We believe that DoD might learn a thing or two from following the lead of DOE.

Thus, we were interested to see DOE issue Acquisition Letter 2018-08 on May 3, 2018. The Acquisition Letter addresses a topic in which we have long been interested – “long-term travel” (or, as DOE terms it “domestic extended personnel assignments").

Most contractors’ travel policies address the costs of normal business travel, which is sometimes called “TDY travel.” The policies tell employees what costs will be reimbursable and at what amounts. The policies are (usually) aligned somewhat with the FAR cost principle at 31.205-46. Most contractors understand that there are also government travel rules, which apply to government travelers—and some (but not all!) of those government travel rules are incorporated into the FAR travel cost principle. As the DOE Acquisition Letter explains, “the travel cost principle does not incorporate the entirety of the FTR, JTR or SR. Absent specific contract language to the contrary, only the maximum per diem rates, the definitions of lodging, meals, and incidental expenses, and the regulatory coverage dealing with special or unusual situations are incorporated.”

Even though most contractors understand the interplay between the FAR travel cost principle, the Federal Travel Regulations, the Joint Travel Regulations, and the Standardized Regulations, many of those same contractors have not extended their travel policies to address long-term travel. Long-term travel is the situation where an employee is assigned to a single location for an extended period of time. The employee’s permanent work location has not changed, but they are going to be somewhere else for 60 or 90 days, or perhaps as much as a year. (You don’t want to go over a year in duration unless you want to deal with some complicated tax issues.)

When an employee is on long-term travel (or, as DOE calls it “a domestic extended personnel assignment”), it’s not reasonable to have them keep incurring the same amounts of travel costs they would incur on normal business travel. For example, if they are going to be at a single location for six months, why can’t they lease an apartment, or (at least) start renting their hotel room by the month instead of by the day? Why can’t they buy food and cook it in their own kitchen, instead of going out to eat three meals a day?

In other words, reasonable people would expect the employee’s daily travel costs to drop significantly while on long-term travel. Lodging costs should drop. The Meals & Incidentals allowance should drop. Too many contractors’ travel policies don’t take this into account.

The DOE Acquisition Letter addresses this issue and establishes DOE policy on cost allowability associated with long-term assignments. The AL starts with a clear, concise definition: “Contractor domestic extended personnel assignments are defined as any assignment of contractor personnel to a domestic location different than (and more than 50 miles from) their normal duty station for a period expected to exceed 30 consecutive calendar days.” In other words, you can be on TDY travel for the first 30 days, but on day 31 the employee’s travel costs are supposed to come down. That sounds very reasonable to us.

The DOE AL lists a number of allowability rules. We won’t recap them all here (we provided a link to the AL in the 2nd paragraph). Here are some significant policy positions:

  • For the first 60 days and last 30 days of the assignment, DOE/NNSA will reimburse costs associated with lodging at the lesser of actual cost or 100% of the Federal per diem rate at the assignment location. The intervening days will be reimbursed at the lesser of actual cost or 55% of Federal per diem.

  • For the first 30 days and last 30 days of the assignment, DOE/NNSA will reimburse costs associated with meals and incidental expenses (M&IE) at a rate not to exceed 100% of the Federal per diem rate at the assignment location. The intervening days will be reimbursed at a reduced rate, not to exceed 55% of Federal per diem.

Contractors whose travel policies do not currently address long-term travel would do well to review this DOE Acquisition Letter in some detail and consider adopting the DOE cost allowability standards as the company’s reimbursement policy positions when their employees are on an extended assignment that does not involve a permanent change in work location. In particular, we advise paying attention to the portion of the AL that discusses the cost analysis that should be performed when considering putting an employee into a long-term travel situation. The AL recommends that a full-up relocation be considered and costed. If the relocation is less expensive than the costs of the extended assignment, it would seem reasonable and prudent to relocate the employee—and that’s what the DOE AL suggests.

In other words, there is more to this particular topic than simply complying with applicable regulations. There is a certain level of analysis expected. We agree. And we recommend that contractors structure their travel policies accordingly.

Last Updated on Wednesday, 09 May 2018 20:00

Generating Profits Through Foreign Military Sales

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Historically defense contractors have had two primary customers for their goods and services: the U.S. Department of Defense and the rest of the world. As U.S. defense budgets wax and wane (which is dependent on various factors including the global security situation, Congressional mood, and Presidential intent), contractors either focus on their domestic customer or else look for international sales channels. (Many do both!) For example, take a look at this Raytheon “global presence” webpage. In recent years, nearly one-third of Raytheon’s revenue has been from international sales.

Contractors have two avenues for international sales of defense products. They can contract directly with the buying government (commonly called “direct commercial sales” or DCS) or they can use the U.S. DoD as an intermediary (commonly called “Foreign Military Sales” or FMS). Choosing one avenue over the other is not an easy decision; there are pros and cons with both approaches. Often, the decision is made for the contractor. For example, if a foreign government wants U.S. financial assistance with paying for the weapons it wants, the U.S. Government may insist that FMS be used. (See our article on security assistance here. Further, we have uploaded a 2013 DoD presentation on the topic, intended for DCMA contracting officers, on this site’s knowledge resources page.) Even when the choice is available, the decision can be a tough one to make.

As the Government Accountability Office (GAO) recently wrote: “According to DOD and State officials, FMS provides multiple benefits to foreign governments and the U.S. government. Foreign governments that choose to use FMS rather than direct commercial sales receive greater assurances of a reliable product, benefit from DOD’s economies of scale, improve interoperability with the U.S. military, and build a stronger relationship with the U.S. government … although using FMS is generally not the quickest or least expensive option for foreign governments.”

We want to unpack that last point a bit. Why should FMS transactions be any more expensive than DCS transactions?

One answer to that question is that the Defense Security Cooperation Agency (DSCA)—the DoD component that administers FMS transactions---charges governments a transaction fee for their services. As GAO recently noted, “DSCA charges purchasers certain overhead fees to cover the U.S. government’s costs for operating the FMS program. These fees include the administrative fee, which covers costs such as civilian employee salaries, facilities, and information systems, and the contract administration services (CAS) fee, which covers the costs of quality assurance and inspection, contract management, and contract audits. These fees are collected in separate accounts in the FMS trust fund, which is used for payments received from purchasers and disbursements made to implement FMS.”

In other words, foreign governments that directly contract with U.S. defense contractors are responsible for administrating and managing their contracts; whereas governments that contract through DSCA via the FMS program have those services provided by DoD entities—for a price. That price covers the listed services, and within those listed services one finds contract administration and quality assurance (DCMA) and contract audit (DCAA). Presumably, CAS provides assurance that the foreign customers are getting what they are paying for, and that the price they are paying is considered to be fair and reasonable. GAO reported that “The base CAS fee has three subcomponents, which are currently set at (1) 0.5 percent for quality assurance and inspection, (2) 0.5 percent for contract management, and (3) 0.2 percent for contract audits.”

The U.S. government intends that its FMS administration fee—currently 3.5% of the FMS agreement (or case) value—is a break-even fee. It is not intending to profit from the fee. In fact, GAO reports that the Standard FMS Terms and Conditions “indicates that the U.S. government will not profit from the FMS program.”

The problem is that the U.S. Government is profiting to the tune of billions of dollars.

GAO report GAO-18-401, published May 10, 2018, told Congress and the public that “The FMS administrative account balance grew by over 950 percent from fiscal years 2007 to 2017—from $391 million to $4.1 billion—due in part to insufficient management controls, including the lack of timely rate reviews.” (Emphasis added.) Further, GAO reported that “The FMS CAS account grew from fiscal years 2007 to 2015 from $69 million to $981 million, due in part to insufficient management controls …”

So when DSCA and other DoD officials blithely note that FMS transactions are neither the quickest nor the least expensive option for foreign customers, what they are really saying is that FMS sales do not represent good value for money. FMS transactions take longer than they should and they cost more than they should. FMS transactions do not represent the optimum sales channel, nor do they lead to fair and reasonable prices. It’s not the contractors’ fault: it’s the DoD’s fault. When using the FMS program, DoD expects its foreign partners to pay for the privilege of slowing down weapon system delivery. And DoD is profiting from the situation.

DSCA describes this situation as “building a stronger relationship with the U.S. Government.”

How much profit is DoD making on these transactions? GAO reported “Our analysis indicates that even if the administrative fee rate were reduced to as low as 2.9 percent and administrative expenditures were to increase 15 percent above expected growth, the administrative account balance would likely remain sufficient to pay for projected expenditures while maintaining a reserve balance through at least fiscal year 2024.”

GAO says the excess balance (profit) generated by the excessively high administrative fees could be used to pay for additional expenditures. Sure. That is certainly one possibility.

Or perhaps the U.S. Government could build stronger relationships with its international partners by refunding the excess costs—costs that it was prohibited by contract terms and conditions from collecting—back to the entities that overpaid in the first place.

You think that might generate some goodwill? We certainly do.

Meanwhile, DSCA and DoD continue to charge international customers the excessively high transaction fees that add costs while admittedly slowing down the entire process.

Last Updated on Monday, 14 May 2018 18:48

TINA Threshold Can Be Raised Across All Agencies

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The story continues.

It started with the 2018 National Defense Authorization Act (NDAA), a piece of legislation focused on the Department of Defense and NASA. The 2018 NDAA directed DoD (and NASA) to make a number of changes to the acquisition regulations. We told you about many of those changes. Notably, the 2018 NDAA changed the threshold at which contracting officers (and contractors) must obtain certified cost or pricing data—commonly known as “the TINA threshold” (referring to the Truth-in-Negotiations Act). The 2018 NDAA raised the TINA threshold from $750,000 to $2 million.

Again, the NDAA language was focused on DoD and NASA, but that focus created a problem. The problem is that the TINA language—e.g., FAR 15.403-4(a)(1)—applies to all Federal agencies, not just to DoD and NASA. Essentially, then, Congress was telling the DAR Council (one of the two FAR Councils who writes the acquisition regulations) to make special language in the Defense Federal Acquisition Regulation Supplement (DFARS). That would be an enormous undertaking, since the DAR Council would not only have to create regulatory language that paralleled the existing FAR language, but would also have to create new solicitation provisions and contract clauses that paralleled existing FAR provisions and clauses. That would be hard and take a long time, a duration perhaps measured in years. In the meantime, DCMA contracting officers would be stuck, forced to choose between complying with statute and complying with the existing FAR regulatory language. We wrote about that challenge in this article.

We followed-up that article with another one, one that discussed how the Civilian Agency Acquisition Council (CAAC)—the sister entity to the DAR Council—had issued a Class Deviation that authorized civilian agencies to adopt some of the 2018 NDAA acquisition thresholds. This was a significant step because it was a strong indication that the 2018 NDAA changes were going to be adopted across the entire FAR, and not just adopted within the DFARS. However, we noted that the CAAC Class Deviation was silent with respect to the TINA threshold. We speculated that it might be the subject of a future CAAC communication.

In yet another article on the topic, we discussed in some detail the quandary faced by both DCMA contracting officers and contractors, because the existing FAR language and associated solicitation provisions and contract clauses all referenced a specific dollar value ($750,000) as the TINA threshold, rather than the value in the statute. Thus, if the statute changed but the regulatory language did not, then there was going to be a conflict between the two. Further, the CAS threshold (which is the contract value at which CAS is applied, unless an exemption is available) is tied to the TINA statute rather than to the regulation. That created yet another compliance quandary for people. We wrote—

By ‘slow-rolling’ the implementation of the 2018 NDAA threshold changes into the acquisition regulations, the FAR Councils have created a problem for contractors. If the contractors wait for the regulatory implementation, then they must disconnect CAS coverage from TINA coverage. They will end up requesting certified cost or pricing data from subcontractors that are, by statute, exempt from CAS. This helps nobody and may well lead to increased procurement costs.

In our view, the only rational approach is to apply the statutory threshold changes now. The FAR Councils should immediately issue a Class Deviation to FAR 15.403-4(a)(1) to implement the new TINA threshold, even if formal rule-making takes a bit longer. If you are a contractor, you should discuss this quandary with your cognizant contracting officer and try to get some relief.

Then, in two other (brief) articles, we noted that the DoD had issued Class Deviations to implement the 2018 NDAA acquisition threshold changes in advance of formal rulemaking. (See here.)

Just to recap, by this point the CAAC had issued a Class Deviation to permit civilian agencies to implement some of the 2018 NDAA threshold changes—in particular, those associated with the Simplified Acquisition Threshold (SAT) and the Micro-Purchase threshold—but they had not addressed changes to the TINA threshold. The Department of Energy (DOE) had jumped on that permission and had issued its own Class Deviation. But of course DOE could not address the TINA threshold, because the CAAC had not addressed it in its Class Deviation. The DoD had issued two Class Deviations addressing the SAT, the Micro-Purchase threshold, and the TINA threshold.

Now we are all up to date.

And you should not be surprised to learn that on May 3, 2018, the CAAC issued a Class Deviation via CAAC Letter 18-003, that addressed the TINA threshold. The CAAC Class Deviation authorizes civilian agencies to “raise[ ] the threshold for requiring Certified Cost or Pricing Data from $750,000 to $2,000,000.” So there you go.

Importantly, the CAAC Letter also addressed how the threshold increase is to be implemented on existing contracts. The CAAC Letter stated “contracts entered into on or before June 30, 2018 are excluded from this threshold increase.” That sounds like another problem, doesn’t it? Contractors are supposed to have one Purchasing System, with a single set of requirements and thresholds, and not two separate ones (one for old contracts and another for new contracts).

Fortunately, the CAAC Letter also offered a way out of the problem. It stated “contractors for those [old] contracts can request to modify such contracts, without consideration, to use the new threshold.” Note the key phrase – “without consideration.”

At this point, contractors should be moving briskly to revise their Purchasing/Subcontracting procedures to implement the new 2018 NDAA thresholds. They should also be preparing letters to their procuring contracting officers to have their existing contracts modified to adopt the new acquisition thresholds. Contractors with DoD and/or NASA contracts should have already sent those requests, and contractors with civilian agency contracts should be looking to do the same.

Last Updated on Tuesday, 08 May 2018 19:34

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In March 2009, Nick Sanders’ article “Surviving Government Audits: Have the Rules of Engagement Changed?” was published in Government Contract Costs, Pricing & Accounting Reports (4 No. 2 GCCPAR P. 11). Apogee Consulting, Inc. is proud to announce that Mr. Sanders’ article was selected for reprint and publication in Thomson West’s The New Landscape of Government Contracting.  Mr. Sanders, Apogee Consulting’s Principal Consultant, joins such distinguished contributors as Professors Steven Schooner and Christopher Yukins, Luis Victorino and John Chierachella, Joseph West and Karen Manos, Joseph Barsalona and Philip Koos and Richard Meene, and several others.  The text covers a lot of ground, ranging from the American Recovery and Reinvestment Act (ARRA) to Business Ethics and Corporate Compliance, and includes several articles on the False Claim Act and the Foreign Corrupt Practices Act.  In addition, the text includes the full text of many statutory and regulatory matters affecting Government contract compliance.


The book may be found here.