These rules propose that contractors receiving awards worth more than $5 million and involving work in excess of 120 days soon could be required to put in place a written code of ethics and business conduct and to display fraud hotline posters provided by the Office of Inspector General (OIG) of the contracting agency.The rules would require a contractor receiving an award in excess of $5 million, within 90 days of the award, to establish an employee ethics and compliance training program and an internal control system.
 
With respect to the display of fraud hotline posters, the proposed rules would require contractors to prominently display and make available electronically agencies' OIG fraud hotline posters. The rule also provides that failure to do so may render the contractor subject to withholding of contract payments or the loss of award fees.

Author: Prior to forming his own Firm in 1991,  Darrell Oyer was a partner with Deloitte & Touche, a Big Five accounting firm.  Before that he served nearly 20 years in the Defense Contract Audit Agency (DCAA) in various capacities. Mr. Oyer is highly experienced in the application and interpretation of the Federal Acquisition Regulation (FAR) and department FAR Supplements, Financial Accounting Standards Board (FASB) pronouncements and Cost Accounting Standards Board (CASB) promulgations, and has testified in about twenty-five Board of Contract Appeals and court cases involving cost and government procurement issues. Mr. Oyer received a Bachelor of Science degree in accountancy from the University of Illinois and a Master of Business Administration degree from American University.  He is a Certified Public Accountant (CPA) in Virginia.

Mr. Oyer is editor of the texts "Accounting for Government Contracts﷓﷓Federal Acquisition Regulation" and “Accounting for Government Contracts—Cost Accounting Standards and author of “Pricing and Cost Accounting--A Handbook for Government Contractors.” He is a frequent speaker and lecturer on contracting subjects and has taught graduate level accounting courses for the University of Houston--Clear Lake and Central Michigan University. 

Contact Information
Darell J. Oyer & Company
Government Contract Specialists
PO Box 11116
McLean, VA 22102
Telephone: 703-438-3041
Fax: 240-465-0540
DarrellOyerCo.com
doyerco@aol.com