Defense contractors and subcontractors (those covered by hotline poster requirements) will soon be able to consolidate several required hotline posters into a single poster, per a Final Rule published in the Federal Register on October 21, 2016.
The rule revises the Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.203-7004, Display of Hotline Posters, to reduce the number of fraud, waste, and abuse hotline posters required to be displayed and to remove the United States-only restriction for use of the poster. It also requires contractors and subcontractors that employ significant numbers of people who do not speak English to have the poster translated into the languages that a significant number of people speak.
It keeps the requirement for a separate Homeland Security hotline poster if a contract is funded, in whole or in part, by DHS disaster relief funds. And it requires contractors that have company websites used to provide information to employees to display an electronic version of the required poster on the websites.
Prior to the change, the DFARS rule required the covered contractors to prominently display three posters: the DoD’s fraud hotline poster, the combating trafficking in persons hotline poster, and the whistleblower protection hotline poster (Koprince, 2016). The new poster, when it becomes available, will incorporate aspects of the “trafficking in persons” and “whistleblower protection” poster content into the fraud hotline poster.
The DFARS rule points contractors to the Department of Defense’s (DoD’s) Office of the Inspector General website to obtain posters, but the new poster has not yet been published on the site. Posters can also be ordered directly from: Defense Hotline, The Pentagon, Washington, D.C. 20301-1900.
The DoD hotline posters offer a minimum required method “to publicize the DoD Hotline Program and encourage the DOD community to identify and report suspected fraud, waste, and mismanagement in DoD programs and operations,” per the DoD IG website. With the introduction of a new, required poster, contractors and subcontractors will have an opportunity to refresh the message for all employees and to reinforce ethics and compliance values.
Ethical Advocate assists companies of all sizes in creating a culture of ethics and accountability by providing ethics and compliance training, confidential and anonymous hotlines, and assistance in meeting regulatory and reporting needs. Contact us for more information.
DFARS 252.203-7004, Display of Hotline Posters, October 2016. http://www.acq.osd.mil/dpap/dars/dfars/html/current/252203.htm#252.203-7004
DoD IG (Office of the Inspector General). The Department of Defense Hotline—Posters (website). http://www.dodig.mil/Hotline/posters.cfm
Koprince, Steven. “DoD Proposes Hotline Poster Consolidation.” SmallGovCon blog, May 10, 2016. http://smallgovcon.com/statutes-and-regulations/dod-proposes-hotline-poster-consolidation/