Cover Letter #2

The current FAR 9.5 has been in place for decades. While it has worked well to date, the nature and scope of contracting has changed significantly over the past seven years. As a result, PSC recommended that FAR 9.5 should be simplified, updated, and restructured to more effectively address current issues relating to organizational conflicts of interest (OCIs), to update the terminology for current situations, and to baseline the duties, timing and roles and responsibilities of agencies, contracting officers and contractors. PSC also recommended restructuring FAR 9.5 to address only OCI issues. However, PSC strongly opposed the need for or use of a single standard FAR clause, or set of standard clauses. The full text of the PSC comments are attached. Alan Chvotkin, Executive Vice President and Counsel, Professional Services Council