Welcome back to our second installment of OIG Shorts. In this post, we focus on the difference between Checking Boxes and Solving Problems from an Ethics & Compliance (E&C) perspective. We all know what attributes an E&C program should have. Combine the elements of DOJ’s Corporate Charging Guidelines, the federal Suspension/Debarment rules, and FAR 52.203‐13, and you’ll have a pretty good checklist. But we contend thinking about an E&C program as a check‐the‐box exercise is a mistake. Nonetheless, it’s what many of us do because that’s how the Government evaluates our programs.
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