Managing OCI Risk

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Managing OCI for 30 Years

Management Systems International (MSI) recognizes the importance of fairness and objectivity in government contracting and holds these values as central to our own corporate culture and philosophy. As one of a number of contractors that provide both implementation and monitoring and evaluation (M&E) services to the US government, this corporate perspective is evidenced in a robust set of MSI policies and procedures that allow us to proactively manage potential Organizational Conflicts of Interest (OCI).

MSI has developed its deep expertise on OCI by working extensively with industry experts, legal counsel and the US Agency for International Development (USAID). This collaboration has produced an OCI management system that is fully consistent with the requirements of the US government and provides a comprehensive approach to identifying and addressing any OCI concerns as they arise. Using a range of OCI mitigation measures long accepted by the US government, such as firewalls and the use of non-conflicted subcontractors, MSI ensures that the principles of fairness and objectivity are upheld while fully meeting the technical needs of our clients – needs that include the delivery of highly rigorous M&E services that are designed and implemented to be fully independent.

A recent decision of the Government Accountability Office (GAO) confirms that our OCI policies and procedures meet the standards and expectations of our clients and the US government. In its denial of a protest of our award on a M&E contact for USAID/Indonesia, the GAO repeatedly throughout the decision validated MSI’s approach to managing OCI. After noting the in-depth review conducted by the USAID Contracting Officer prior to approving the MSI OCI plan, the GAO panel wrote that:

“the record reflects that the contracting officer reviewed the [MSI OCI] plan and… reasonably determined that its procedures–including the use of firewalls and subcontractors–adequately avoided, neutralized, or mitigated potential conflicts of interest.”Read full GAO decision here

Conflict of interest is a serious procurement issue that all USG contractors must understand and address. Our ability to identify OCIs early, the fact that we maintain full transparency with our clients, and our tested OCI procedures, make it easy for government Contracting Officers to mitigate or neutralize any OCIs that might arise under MSI’s M&E and implementation projects.

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