How are the Defense Acts’ Requirements Implemented on Contractors?

This question has come up often (but insert prior year for 2012) in the past and with recent passage of the 2012 Act, I thought I would clarify the process as it impacts a government contractor.    Although an Act can be signed, it does not immediately flow to a government contractor.

Nothing in the 2012 Act has actually been placed into rule.  There are many things that are in the 2009-2011 Acts that are just now being implemented.   What the DoD will do, is to issue interim rules to implement sections of the Act, then the interim rule will be out for comment, the final rule will come into place, then the final rule is determined, publicized in the Federal Register and translates into the DFARS (this of course all happens for those sections that are at the high level of the FAR too).  So as you can imagine, the process takes time, so we’re just now seeing changes coming in that were from prior years’ Acts.

We will probably see implementation of the 2012 Act sections in the next year or so. Some will come faster than others.

Some items from various Acts have just recently been placed into effect (actually a couple yesterday).  Things to watch for in updating your policies and procedures are topics of contractor responsibility, past performance, and conflicts of interest.  A great place to watch regulations move through is

This is a perfect time to review and update your policies and procedures.  Remember, you can’t be in compliance if those are just collecting dust!


About Stephanie Amend

Stephanie is the Principal and CEO of Arrowhead Solutions, LLC, a solutions firm specializing in assisting established small businesses be successful government contractors.

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