Impaired Objectivity

Examples

• 1.A contractor evaluating proposals for a program on which it is also a competitor or subcontractor to a competitor
• 2.A systems integrator assessing the technical performance of its own subsystem as part of a broader system evaluation
• 3.A contractor providing independent testing and evaluation services for a system it also helped design or build
• 4.An advisory firm recommending contract extensions or modifications that would directly benefit its own affiliated companies

Mitigation Strategies

• +Separate the advisory/evaluation function from any business unit with a financial interest in the outcome
• +Use government personnel or an independent third party for evaluations involving the contractor's own products
• +Implement rigorous disclosure requirements and recusal procedures
• +Prohibit the contractor from evaluating its own work or competing products in which it has a financial interest
• +Require supervisory review of all evaluations and recommendations by government personnel

Consequences

• !Invalidation of the contractor's evaluations or recommendations
• !Exclusion from advisory and evaluation roles on affected programs
• !Contract termination and potential debarment for repeated or egregious impaired objectivity violations
• !Bid protests challenging the integrity of source selections influenced by conflicted advisors
• !Loss of credibility in the advisory and professional services market

Other Impairment-Based Conflicts

Other OCI Types