CFCM Legal Compliance 2 — Questions and Answers
Question 1: Under the False Claims Act, what is the minimum civil penalty per false claim submitted to the government?
- $5,000
- $11,803 (Correct answer)
- $25,000
- $50,000
Correct answer: $11,803
The False Claims Act imposes civil penalties (adjusted for inflation) currently around $11,803 to $23,607 per false claim, plus treble damages.
Question 2: Which regulation requires federal contractors to implement a written ethics and compliance program if they hold contracts valued at $5 million or more with a performance period of 120 days or more?
- FAR 52.203-13 (Correct answer)
- FAR 52.222-26
- FAR 52.215-2
- FAR 52.204-9
Correct answer: FAR 52.203-13
FAR 52.203-13 (Contractor Code of Business Ethics and Conduct) mandates written compliance programs for qualifying large contracts.
Question 3: The Anti-Kickback Act of 1986 prohibits subcontractor employees from providing what to prime contractor personnel in exchange for favorable treatment?
- Unsolicited proposals
- Kickbacks of any form of compensation (Correct answer)
- Teaming agreements
- Cost-sharing arrangements
Correct answer: Kickbacks of any form of compensation
The Anti-Kickback Act prohibits any money, fee, commission, credit, gift, or gratuity given to influence subcontract awards or administration.
Question 4: A contractor discovers a significant overpayment on a cost-reimbursement contract. Under FAR 52.215-2, within how many days must the contractor notify the contracting officer?
- 30 days (Correct answer)
- 60 days
- 90 days
- There is no notification requirement
Correct answer: 30 days
FAR requires prompt disclosure; audit and records clauses generally require contractors to report known overpayments within 30 days of discovery.
Question 5: Which statute prohibits federal contractors from discriminating in employment based on race, color, religion, sex, or national origin, and applies to contracts over $10,000?
- Davis-Bacon Act
- Executive Order 11246 (Correct answer)
- Service Contract Act
- Walsh-Healey Act
Correct answer: Executive Order 11246
Executive Order 11246 requires nondiscrimination and affirmative action in employment for federal contractors and subcontractors meeting the $10,000 threshold.
Question 6: Under the Procurement Integrity Act, what is the cooling-off period before a former federal official involved in a procurement may accept employment with the winning contractor?
- 6 months
- 1 year (Correct answer)
- 2 years
- 5 years
Correct answer: 1 year
The Procurement Integrity Act (41 U.S.C. § 2104) imposes a one-year bar on accepting employment from a contractor whose contract the official was personally and substantially involved in.
Question 7: Which legal doctrine holds that a contractor is bound by the government's interpretation of a solicitation if the contractor knew or should have known of the ambiguity but failed to seek clarification?
- Contra proferentem
- Patent ambiguity doctrine (Correct answer)
- Quantum meruit
- Unjust enrichment
Correct answer: Patent ambiguity doctrine
Under the patent ambiguity doctrine, contractors must seek clarification before bid submission when an ambiguity is obvious on the face of the solicitation.
CFCM Legal Compliance 2
Under the False Claims Act, what is the minimum civil penalty per false claim submitted to the government?