ORGANIZATIONAL CONFLICT OF INTEREST AND THE AIR FORCE CONTRACT AUGMENTATION PROGRAM: A PATTERNED APPROACH TO RISK IDENTIFICATION
AIR COMMAND AND STAFF COLLEGE MAXWELL AFB United States
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The Air Force Contract Augmentation Program AFCAP provides contracted support to sustain operations in the deployed environment. Fraud, waste, and abuse violations in this environment are well documented and costly. A type of fraud, organizational conflict of interest OCI is the subject of greater scrutiny in the acquisition community. AFCAP contracting officers lack management controls to identify OCI as required by regulation. Conditions suggest AFCAP is predisposed to OCI occurrence and contractors are not incentivized to devote necessary resources to identify OCI. One hundred thirty eight OCI protest cases adjudicated by the Government Accountability Office were reviewed to collect data from the protest outcomes. This data was charted to determine elevated accusation of OCI type, frequency, and disposition in the GAO protests. The patterns the data presented were applied to the AFCAP program to evaluate its OCI susceptibility in conjunction with conditions inherent in the program. This evaluation concludes that AFCAP is at increased risk to two types of OCI unequal access to information and impaired objectivity. To counter this, three recommended process improvements include increased accountability from the customer, demanding transparency from the contractor, and the exploration of flexible reporting through existing systems by the DoD.
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