OCI

OCIs arise most frequently in advisory and assistance contracts, systems engineering work, and situations where a contractor helped define the requirements for a procurement they then want to bid on. Agencies take OCIs seriously — an unresolved OCI can disqualify a contractor from an entire competition.

The three types of OCI (per FAR 9.505):

• Biased Ground Rules — The contractor helped write the SOW, requirements, or evaluation criteria that now favor their own solution. The fix is typically recusal from the follow-on competition.
• Impaired Objectivity — The contractor is asked to evaluate solutions (including competitors' products) but has a financial interest in a particular outcome. Common in advisory contracts and source selection support roles.
• Unequal Access to Information — The contractor has access to non-public, competitively useful information (e.g., proprietary data from a prior contract) that competitors do not have.

OCI mitigation strategies:

• Mitigation plans — Agencies may accept a written plan describing firewalls, personnel restrictions, or other controls to neutralize the conflict
• Waiver — In limited cases, agencies can waive an OCI if it's in the government's best interest
• Recusal — The contractor withdraws from part or all of the procurement

OCI should be a factor in your bid/no-bid decision. If your company holds a systems engineering contract, a program management support contract, or has done prior work defining the requirements — assess your OCI exposure before investing in a proposal. Failing to disclose a known OCI is a serious compliance risk.