GW Law Faculty Publications & Other Works
Document Type
Testimony
Publication Date
2024
Status
Accepted
Abstract
This testimony, presented before the U.S. Senate Committee on Homeland Security & Governmental Affairs, examines longstanding deficiencies in the regulatory framework governing organizational conflicts of interest (OCIs) in federal contracting. While acknowledging recent legislative progress, including the enactment of the Preventing Organizational Conflicts of Interest in Federal Acquisition Act, the testimony highlights how current Federal Acquisition Regulation (FAR) provisions are outdated, inconsistently applied, and ill-suited to modern procurement practices—particularly in advisory and consulting services with national security implications. The testimony argues for a balanced and modernized approach to OCI reform that enhances clarity, strengthens compliance and disclosure obligations, and provides more uniform guidance across agencies, while avoiding overcorrections that risk discouraging competition and innovation in the federal marketplace.
GW Paper Series
2025-38
SSRN Link
https://ssrn.com/abstract=5313204
Recommended Citation
Jessica Tillipman, Testimony of Jessica Tillipman, Associate Dean for Government Procurement Law Studies, The George Washington University Law School, before the Senate Committee on Homeland Security & Governmental Affairs, Safeguarding the Homeland: Examining Conflicts of Interest in Federal Contracting to Protect America’s Future, S. Hrg. 118‑437 (Sept. 24, 2024), https://www.congress.gov/event/118th-congress/senate-event/LC73534/text
Comments
https://blogs.gwu.edu/law-govpro/associate-dean-tillipman-testifies-before-the-senate-about-organizational-conflicts-of-interest/