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Posted on May 15, 2008 by Sheppard Mullin
- Negotiate a Basis of Award you can live with - the time to figure out what you can live with is before, not after, award.
- Adopt a centrally controlled and monitored standard pricing structure - memorialize it in writing and enforce it.
- Institute redundant internal compliance safeguards.
- Limit the number of your people dealing with Government customers.
- Assign qualified people - and train them on your policies.
- Do not incentivize non-compliance - use a carrot and a stick.
- Be proactive in responding to non-federal concerns so the Schedule rules do not become a hindrance that folks try to circumvent.
- Conduct periodic, independent compliance reviews Sanction significant misconduct - don't have rules that are "winked at."
- Inform your counsel immediately of non-routine communications (e.g., audit letters, show cause letters, subpoenas etc.)
