Organizational Conflict of Interest (OCI)

FAR 9.505 rests on two principles: prevent conflicting roles that might bias a contractor's judgment, and prevent unfair competitive advantage, including advantage from access to proprietary or source selection information. Sections 9.505-1 through 9.505-4 apply those principles to the recurring fact patterns — systems engineering and technical direction, preparing specifications or work statements, providing evaluation services, and access to other companies' proprietary information.

The analysis belongs to the contracting officer. FAR 9.504 requires identifying potential conflicts as early as possible and resolving them before award, whether by restricting future work, accepting a mitigation plan, or excluding the offeror. An agency head or designee can waive the requirement in writing under 9.503 when applying it is not in the government's interest.

OCIs tend to surface as postaward protests: the winner helped write the specification, or will be grading its own work. A mitigation plan accepted without analysis is nearly as vulnerable as no plan, so document the OCI review even when the conclusion is that no conflict exists.