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Overview

FAR 3.1106 prescribes the mandatory use of the clause at 52.203-16 to prevent personal conflicts of interest in service contracts where contractor employees perform acquisition functions closely associated with inherently governmental functions.

Key Rules

  • Threshold: The clause must be included in solicitations and contracts that exceed the simplified acquisition threshold (SAT).
  • Applicability: It applies specifically to contracts involving services where contractor employees perform acquisition functions closely associated with inherently governmental functions on behalf of a Federal agency.
  • Partial Performance: If only a specific portion of the contract involves these functions, the clause is still mandatory but its application is limited to that specific portion.
  • Self-Employed Exemption: The clause is not required for contracts with self-employed individuals if they are performing the acquisition functions entirely by themselves rather than through employees.

Practical Implications

  • Contractor Compliance: Firms winning these contracts must implement internal procedures to screen employees for financial interests or relationships that could bias their advice to the government.
  • Scope Identification: Contracting officers must carefully evaluate the Statement of Work (SOW) to determine if tasks (such as drafting specifications or evaluating proposals) trigger this requirement, even if those tasks are only a minor part of the overall contract.

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