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New DoD Poster Requirements — September 20, 2011

You may have heard the news that effective 9/16/11, the DoD is now requiring their contractors to post DoD fraud posters.  There is concern in the contracting community that this move by the DoD will overtly or covertly encourage your employees to report anything to the DoD rather than you.

 

While you must have the DoD poster, you should still have a poster promoting your hotline (whom do you want your employees to call, your hotline or the DoD IG?).  The DoD responds to such concerns with the following:  “The posting of the DoD IG fraud hotline poster supplements the existing reporting mechanisms.  A contractor’s existing duty to self-report or voluntarily disclose violations to the Government is not preempted by posting the DoD IG fraud hotline poster.” 


If employees know about your hotline and hotline reports are actively managed, your organization is more likely to receive and be able to manage a report before it is reported to the DoD.  


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