Thursday, May 12, 2016

DoD Wants to Help Contractors Remove Clutter

The Federal Acquisition Regulations (FAR) and individual agency FAR supplements, contain several provisions requiring Government contractors to display posters advising employees of their rights and duties in certain areas. One well-known poster requirement is the Hotline poster where anyone (contractor or Government employee) can call to report suspicions of fraud, waste and abuse (see DFARS 252.203-7004 for example).  We've discussed this requirement numerous times on these pages.

A more recent requirement for contractors is the need to inform employees in writing of their whistleblower rights. The most common way to inform employees in writing of their whistleblower rights has become the "poster".

An even more recent poster requirement has been the Combating Trafficking in Persons poster (see DFARS 252.203-7004(c)).

Regulations require that these posters be prominently displayed. However, when there are so many poster requirements, its easy to run out of prominent places. When you add these three posters to the myriad state and local "poster" requirements for workers compensation, unemployment and some additional Department of Labor poster requirements, you have a jumbled mess where posters become just part of the landscape. Recently, we were conducting floorchecks for a Government contractor and one of the questions was whether employees were aware of the Hotline poster. Less than 50 percent replied in the affirmative, even though, in many cases, we could see the poster from where we were interviewing the employee.

The Department of Defense is proposing to help de-clutter those "prominent places". The DoD Office of Inspector General has consolidated the three posters (i.e. fraud, waste, and abuse, whistleblower protections, and combating trafficking) into one. The DoD is revising its FAR Supplement to update the contract clauses that require displays, accordingly.

The new combined poster is not yet available but keep watching the DoD-IG Hotline Poster Site for the new poster. Incidentally, there is no requirement that contractors use the DoD-IG poster. Contractors are free to develop their own. But why go to the expense of doing so when the IG posters are free.

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