- 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.)