Attachment K.9 DRD 6 - OCI Plan

1. DRD Title: Organizational Conflicts of Interest (OCI) Plan

2. DRD No.: 6

3. Data Type: 1

5. Solicitation No.: 80GSFC27R0018

6. Contract No.: TBD

7. Date Issued: March 23, 2026

8. Date Revised: N/A

4.OPR: OP

9. DRD Category:

Technical
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Administrative ☒
S&MA
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10. Description/Use: The Plan will communicate the contractor’s approach to identify and resolve OCIs. The contractor will be held accountable for identifying, dispositioning, and reporting OCIs during contract performance. 11. Distribution: Distribution must be as instructed by the contracting officer. Initial Submission: Plan must be submitted with the initial proposal. Submission Frequency: As needed.
Format: As specified in Contract Attachment L, Non-Technical Data Requirements List. Interrelationship: NASA Federal Acquisition Regulation (FAR) Supplement (NFS) 1852.237-72, Access to Sensitive Information, NFS 1852.237-73, Release of Sensitive Information. Applicable Documents: FAR Subpart 9.5, Organizational and Consultant Conflicts of Interest, NFS 1809.5, Organizational and Consultant Conflicts of Interest, NASA Guide on Organizational Conflicts of Interest. Scope: The OCI Plan describes the contractor’s comprehensive approach to identify, avoid, mitigate, neutralize, and report potential OCI issues, including conflicts described in the solicitation and those discovered during contract performance.
Contents: The OCI Plan must meet the requirements of FAR 9.5 and include the following: 1. Point of contact for OCI issues and reports.
2. Demonstrate an understanding of (1) OCI principles and (2) the full breadth of OCI issues and the types of harm that can result. The Plan at a minimum addresses the three primary types of OCIs (i.e., biased ground rules, unequal access to information, and impaired objectivity). 3. Define company roles, responsibilities, and procedures for (1) screening (i.e., identifying/recognizing, analyzing/evaluating, resolving, and reporting) existing and new business opportunities for actual/potential OCIs and (2) monitoring and reporting all potential/actual OCIs that arise, resolving conflicts, and reporting previously unidentified OCIs or potential OCIs to the Government. 4. Describe how employees are notified of the Plan’s requirements and how this notification will be documented. Establish and require entrance training for new employees, refresher training for existing employees, and exit training for departing employees. Describe how completion of this training will be documented, including a