Last week we reported on the Government's program to enhance its contractor integrity databases. The main problem with the information in the databases is the inability to link different operating segments that happen to fall under the same corporation. Thus there is the real possibility that the Government could award contracts to operating segments that are affiliated with segments that have been suspended or debarred. Such information could be relevant to responsibility determinations.
DoD is getting a jump on things by proposing to amend the DFARS (DoD FAR Supplement) to provide a provision that any offeror, if owned or controlled by another business entity, must identify the CAGE code (Commercial and Government Entity code) and legal name of that business entity. This information, will, after time, allow the Government visibility into who really owns or controls the entity bidding on a particular contract. It should also help the Government in its responsibility determinations.
There may be some implementation issues however. One issue that comes to mind is the term "owned and controlled" Under GAAP (generally accepted accounting procedures), "owned" and "controlled" have different meanings. Another issue that comes to mind involves joint ventures. Which of the partners are the owner? Which of the partners has the "controlling" interest.
If you care to comment on this DoD proposal, instructions for doing so are contained in this announcement.
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