Training & Resources > Key Issues & Documents

Key Issues & Documents

Memorandums from the Department of Defense

1. Memorandum from the Department of Defense on Ethics, Integrity, and Accountability dated Dec. 21, 2010 (sent by Laura Kennedy)
2. Memorandum from the Department of Defense on the Split of Responsibilities between DCAA and DCMA dated Jan 4, 2011 (sent by Terry Albertson)

Personal Conflicts of Interest

On April 2, 2010, the DoD Standards of Conduct Office issued a new Advisory. Topics include:

1. New DoD Policy on Social Networking.
2. Defense Procurement and Acquisition Policy Survey on the Ethical Climate at DoD.
3. Military Balls.
4. Updated $25,000 Defense Contractor listing.

On November 24, 2009, Ashton Carter, the Under Secretary of Defense for Acquisition, Technology and Logistics, issued this memo titled “Personal Conflicts of Interest (PCIs) of Contractors’ Employees.”

The Civilian Agency Acquisition Council and the Defense Acquisition Regulations Council (Councils) are proposing to amend the Federal Acquisition Regulation (FAR) to address personal conflicts of interest by employees of government contractors. Read the Proposed Rules in the Federal Register, from November 13, 2009.

Organizational Conflicts of Interest

On December 8, 2009, the Department of Defense hosted a public forum regarding Organizational Conflicts of Interest and Section 207 of the Weapon Systems Acquisition Reform Act of 2009. Presentations by AIA, Lockheed Martin, PSC and other participants are included in this document.

Mandatory Disclosures

Read the Defense Contract Audit Agency’s (DCAA) form letter regarding Mandatory Disclosures.

In January 2010, the American Bar Association published a useful, 400-page guide to Mandatory Disclosure rules. To order the ABA’s “Guide to the Mandatory Disclosure Rule,” click on this link. The cost is $55 per copy.

Revolving-Door Policies

Defense Secretary Robert Gates released a Memo in April 2010 on the use of retired officers, or “senior mentors,” by the Department of Defense. USA Today ran an article on the new policy and included the Memo from Secretary Gates, which states that retired officers must abide by “certain ethics laws and regulations that apply to Federal employees to avoid any perception of impropriety.”

DCAA Compliance

Click here for the DCAA Memorandum on Significant Deficiencies/Material Weaknesses on Internal Control Systems, dated December 19, 2008.

Click here for an Analysis by Wiley Rein of the December 2008 DCAA Memo on Internal Control Systems.

Click here for GAO Congressional Testimony on DCAA Audits, titled “Widespread Problems with Audit Quality Require Significant Reform.” Date: September 23, 2009

Click here for the GAO report on DCAA Audits, titled: “Widespread Problems with Audit Quality Require Significant Reform.” Date: September 2009

Other Developments

On March 23, 2010, the House Armed Services Committee Panel on Defense Acquisition Reform issued a 53-page report that found that the nation’s defense acquisition system is outmoded. “The system remains structured primarily for the acquisition of weapon systems at a time when services represent a much larger share of the Department’s acquisitions,” the report concluded.