"The preponderance have been related to single employee misconduct, say where someone was found not to have shown up to work or to have erroneously billed to one contract instead of another or the employee was found surfing the Internet for three or four hours a day for the last three months, or something like that.  So they have to adjust the billing in order to credit the government back for that employee's labor time."

Because of the volume of the disclosures, the DOD IG has had to add staff in order to ensure that Government stakeholders, including Department of Justice Attorneys as well as the various DOD buying agencies and contract administration offices, are properly briefed and agree to the proposed disposition of each disclosure.

In sum, the first six months seem to indicate a trend where contractors are erring on the side of caution by disclosing every small transgression, even those that would normally be handled administratively.  The IGs are receiving the disclosures and adjudicating each one through coordination with numerous Government stakeholders.  The vast majority of disclosed matters is being handled administratively, just as they would have been before the new rule took effect.  The only difference is, now the contractors are spending more to disclose the issues and DOD IG is spending more to process them.  As is often the case, the only winners seem to be the attorneys involved in the process.