# Federal Contracting: Ethics Compliance and Enforcement Course Canonical URL: ## Overview Procurement fraud scandals have prompted a tightening as well as an expansion of the regulatory requirements concerning ethics and standards of conduct. Both government contracting personnel and industry personnel need to understand what is expected of them with respect to procurement integrity and conflicts of interest, including the FAR provisions on contractor ethics. This course explains the key procurement ethics laws and regulations, as well as the role of key government entities involved in overseeing and enforcing those laws and regulations. It includes the text of selected regulations and guidance as well as references to public and private sector sources of information. ## What you'll learn - Recognize and apply the principles of ethical behavior in Federal procurement. - Describe administrative debarment and suspension procedures and the administrative tools available to the Contracting Officer for ensuring contractor responsibility. - Differentiate between a personal and an organizational conflict of interest. - Identify and explain the requirements of the Procurement Integrity Act. - Explain the whistleblower (qui tam) provisions of the civil False Claims Act. - Describe the FAR rule regarding the contractor business ethics compliance program and mandatory disclosure requirements. ## Curriculum #### Module 1: Principles of Ethical Behavior in Federal Procurement - Explore the historical evolution of ethical standards in federal procurement. - Understand definitions and implications of fraud, waste, and abuse. - Examine the role of Executive Orders and federal statutes on ethics in procurement. - Learn about kickbacks, bribery laws, and standards of conduct for both government and contractor employees. - Understand the impact of whistleblower protections and personal/organizational conflicts of interest. #### Module 2: Roles of GAO, DOJ, IGs, Office of Government Ethics, OSC, DAEOs, and CCOs - Understand the audit and bid protest functions of the GAO. - Review DOJ's civil and criminal enforcement roles in procurement fraud. - Examine the investigative powers and functions of Inspectors General. - Study the regulatory and advisory role of the Office of Government Ethics. - Learn how OSC investigates whistleblower complaints and Hatch Act violations. - Explore the roles and responsibilities of Designated Agency Ethics Officials and Corporate Compliance Officers. #### Module 3: Contractor Responsibility—Debarment and Suspension - Define "responsible contractor" and understand FAR Part 9 requirements. - Understand the causes, procedures, and consequences of debarment and suspension. - Review tools like SAM, CPARS, PPIRS, and FAPIIS for evaluating contractor responsibility. - Examine due process rights for contractors and subcontractor flowdown clauses. - Study the U.S. Sentencing Guidelines related to corporate ethics compliance programs. #### Module 4: The False Claims Act Whistleblower Provisions and Other Statutes - Understand the Civil and Criminal False Claims Act and its qui tam provisions. - Learn about whistleblower protections and enforcement actions under FAR 3.9. - Review other statutes related to bribery, illegal gratuities, and financial conflicts of interest. - Examine timelines for bringing whistleblower actions and protections against reprisal. #### Module 5: Conflicts of Interest and Restrictions on Information - Distinguish between personal and organizational conflicts of interest (PCI/OCI). - Study FAR Subpart 3.1 and 9.5 standards on ethical conduct and conflict mitigation. - Understand the Procurement Integrity Act and the rules around obtaining/disclosing source selection info. - Learn about revolving door issues and post-employment restrictions under 18 U.S.C. §§ 207–209. - Explore real-life enforcement cases related to violations of federal ethics standards. #### Module 6: Contractor Performance Information and Other Databases - Understand how contractor performance is tracked through CPARS and PPIRS. - Explore the use of FAPIIS for integrity and performance-based decisions. - Review the role of SAM, FPDS, and Performance.gov in procurement transparency. - Understand reporting requirements for executive compensation and subcontract awards. - Learn about default termination reporting and use of contractor report cards in award decisions. #### Module 7: FAR Contractor Code of Business Ethics and Conduct Rule - Understand FAR Subpart 3.10 requirements for contractor ethics programs. - Review mandatory disclosure rules for reporting credible evidence of wrongdoing. - Explore the implications of non-disclosure, including suspension and debarment. - Examine the required elements of an effective compliance program and internal controls. - Learn how ethics rules apply to subcontracts and non-U.S. performed contracts. ## Schedule - Aug 11, 2026 – Aug 12, 2026 — Live Online - Oct 5, 2026 – Oct 6, 2026 — Live Online ## Instructors ### Anna Garcia-Durr — Instructor Ms. Garcia-Durr is a highly respected acquisition expert and retired U.S. Army officer with over 35 years of combined military and federal civilian service in logistics, contingency operations, and acquisition leadership. A former Contingency Contracting Officer, Anna brings operational insight from combat zones, austere environments, and disaster response operations directly into the training environment. She held senior leadership roles across the Department of State, Department of Homeland Security, and the Bureau of Alcohol, Tobacco, Firearms & Explosives—managing multi-billion dollar portfolios and overseeing mission-critical procurement in domestic and international settings. She is also a seasoned instructor and mentor, having trained hundreds of acquisition professionals, CORs, and program teams to exceed performance and compliance goals. She equips today’s acquisition professionals with the insight, precision, and mission-driven mindset needed to confidently lead and execute procurements in any acquisition environment. Anna holds a Juris Master in Corporate Compliance and Contracts and graduate certificates in Contract Management and Program/Project Management. Her certifications include Certified Federal Contract Manager (CFCM), DAWIA Level III (Contracting), and FAC-C / FAC-COR Level III. ### Jeff Hysen — Instructor Jeff Hysen has been with GSUSA since 2020, teaches numerous classes, and has received several awards for his work. Before joining Graduate School USA, Jeff was an Assistant Regional Counsel with the General Services Administration for 31 years. At GSUSA, Jeff served as the lead counsel on Ethics issues for the National Capital Region and worked on numerous projects across various fields. In addition to his work with GSUSA, Jeff is a podcast host and stand-up comedian. ### Melanie Dooley — Instructor Melanie Dooley is a seasoned expert in federal acquisition and contracting with more than three decades of experience spanning government, industry, and education. She has built a distinguished career as both a practitioner and educator, serving as a Vice President of Acquisition Policy for SAIC, a managing editor for the _Federal Contracts Report_ at Bloomberg BNA, and an instructor and curriculum developer for Graduate School USA. Her background includes deep knowledge of legislative and regulatory processes, the federal budget and appropriations cycle, and the intricacies of acquisition policy. She has also cultivated an exceptional ability to translate complex policy and contracting issues into practical guidance, having trained members of the defense and civilian acquisition workforce at all levels. In addition to her leadership roles, Melanie brings corporate strategy experience, extensive editorial expertise from her years in the trade press, and a strong record of shaping acquisition policy within a major defense contractor. She is a Certified Professional Contracts Manager (CPCM) and a Fellow of the National Contract Management Association, where she has held leadership roles including VP of Programs and Fellows Chair. With an MBA from Georgetown University and a reputation for clarity, rigor, and real-world insight, Melanie has become a trusted resource to federal professionals, corporate leaders, and students alike. ### Alan McCain — Curriculum Program Manager Alan McCain is a retired combat veteran who served as both an Air Force enlisted member and a Navy officer. He brings over 30 years of experience spanning federal and commercial budgeting, auditing, programming, operations, global logistics support, supply chain and inventory management, as well as major IT acquisition. He possesses extensive, hands-on budget and audit experience across Federal, State, and Local government operations, including work within the Executive Office of the President and the Departments of State, Defense, Homeland Security, Health and Human Services, Housing and Urban Development, and Education, as well as the Office of the Mayor of Washington, D.C., among others. Alan’s consulting background includes strategic planning and business development with the District of Columbia government, multiple federal agencies, Lockheed Martin, KPMG, and PricewaterhouseCoopers. He is a Certified Government/Defense Financial Manager (CGFM/DFM), holds a Teaching Certification from Harvard University’s Bok Center for Teaching and Learning, and earned an Executive MBA in International Business from The George Washington University. ## Pricing **Tuition:** $1050