Organizational Conflict of Interest (OCI) Guide 2025: Types, Mitigation & Compliance

Quick Answer: What is OCI?

An Organizational Conflict of Interest occurs when a contractor has relationships or interests that could bias their work or give them unfair competitive advantage. FAR Subpart 9.5 requires agencies to identify, avoid, or mitigate OCIs. There are three main types: Biased Ground Rules, Impaired Objectivity, and Unequal Access to Information.

Biased

Ground Rules

Impaired

Objectivity

Unequal

Access

What is Organizational Conflict of Interest?

OCI exists when a contractor cannot render impartial advice or has an unfair competitive advantage due to prior or current work. It is about organizational relationships, not individual employee conflicts.

OCI Key Concepts

→Applies to the organization, not just individuals
→Includes parent companies, affiliates, and subcontractors
→Must be analyzed for each procurement
→Can arise from current or previous contracts

Types of OCI

Biased Ground Rules

When a contractor writes specifications or requirements they might later compete on:

→Writing RFP specifications then bidding on that RFP
→Developing system requirements then competing to build it
→Setting standards they are uniquely positioned to meet

Impaired Objectivity

When a contractor evaluates its own work or that of a competitor:

→Evaluating proposals including own or affiliates products
→Providing quality assurance on own deliverables
→Advising on decisions affecting own financial interests

Unequal Access to Information

When prior work provides competitive advantage through proprietary information:

→Access to government cost estimates
→Knowledge of future requirements before public
→Proprietary data from prior contracts

Identifying OCI

OCI Analysis Questions

1.Did we help develop the requirements for this solicitation?

2.Would we be evaluating our own work or a competitors?

3.Do we have information that competitors do not have?

4.Do our affiliates or subcontractors have conflicts?

5.Would winning this contract affect our objectivity on other work?

Mitigation Strategies

Common Mitigation Measures

Firewalls

Physical and electronic barriers preventing information flow between conflicted and non-conflicted work. Requires documented procedures.

Organizational Separation

Separate teams, management chains, or business units for conflicted work. May include physical separation of personnel.

Disclosure and Monitoring

Full transparency to government about potential conflicts with ongoing government oversight of mitigation effectiveness.

Exclusion from Competition

Voluntarily or by government direction, not competing on conflicted work. Sometimes unavoidable for severe conflicts.

Mitigation Plan Approval

Mitigation plans must be approved by the Contracting Officer. Submit plans with your proposal when potential OCI exists. Generic or boilerplate plans are typically rejected.

Disclosure Requirements

When to Disclose

→In proposal when solicitation requires OCI representation
→When you identify potential OCI during performance
→When circumstances change (acquisitions, new work)
→Proactively when pursuing opportunities that may conflict

What to Disclose

→Nature of the potential conflict
→Related contracts and work
→Proposed mitigation measures
→Why mitigation is sufficient

Consequences of OCI

Pre-Award

×Disqualification from competition
×Exclusion from future related work
×Negative past performance considerations

Post-Award

×Contract termination
×Suspension or debarment
×False Claims Act liability if undisclosed

Frequently Asked Questions

Can OCI be waived?

In rare cases, agency heads can waive OCI if in the government interest and mitigation is effective. Waivers are unusual and require high-level approval.

Do subcontractor conflicts affect primes?

Yes—primes are responsible for identifying and addressing subcontractor OCI. A subcontractor conflict can disqualify the entire team.

How long do OCI restrictions last?

It depends on the nature of the conflict. Some restrictions last through the contract period, others extend years afterward. The solicitation or contract will specify duration.

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