Organizational Conflict of Interest (OCI) Mitigation Planning

The contract requires the development and implementation of an Organizational Conflict of Interest (OCI) Mitigation Plan to ensure that subcontractor performance does not compromise fairness or integrity, particularly when the subcontractor has prior involvement with U.S. Army data systems. The plan must identify potential conflicts arising from existing knowledge, access, or relationships with Army systems and outline specific, enforceable measures to neutralize those risks throughout the duration of the subcontract. These measures may include structural separation, information firewalls, personnel restrictions, or independent oversight to safeguard the impartiality of system development, maintenance, or support activities. The subcontract is tied to the Department of Defense’s Software Sector under the W6QK Acc-apg Cont Ct Software Sector and is performance-based at Fort Huachuca, Arizona, with a strict response deadline of May 1, 2026. It falls under NAICS code 541611, indicating primary focus on management consulting services, specifically those involving technical and operational support for defense systems. The subcontractor is expected to demonstrate a clear understanding of the Army’s operational environment and regulatory requirements to prevent any actual, perceived, or potential bias in system design or data handling. Full compliance with OCI mitigation standards is mandatory for award and ongoing contract execution.