PROMOTING INTEGRITY FROM WITHOUT: A CALL FOR THE MILITARY TO CONDUCT OUTSIDE, INDEPENDENT INVESTIGATIONS OF ALLEGED PROCUREMENT INTEGRITY ACT VIOLATIONS

摘要

The comment of a procurement law author more than a decade ago still rings true today: "The susceptibility of federal contracts to fraud is not the recent invention of Congress or the Inspectors General, but an historic and unfortunately continuing reality." Because of this reality, the procurement system's integrity may suffer when violations of the Procurement Integrity Act occur. It is therefore vital that executive agencies such as the military services set forth clear guidance for HCAs to resolve alleged Procurement Integrity Act violations. An internal investigation, while appropriate in some circumstances, may not be the best course of action concerning Procurement Integrity Act violations. Such investigations may be plagued by biases such that the results of those investigations undermine the public's confidence in the procurement system and contractors' desire to participate in it.