CPCM Certified Professional Contract Manager: Ethics and Compliance 3 — Questions and Answers
Question 1: During source selection, a contracting officer shares a competitor's proposal price with a preferred vendor. This action is BEST described as:
- Acceptable market research
- A violation of procurement integrity laws (Correct answer)
- Standard negotiation practice
- A required disclosure under the Freedom of Information Act
Correct answer: A violation of procurement integrity laws
Sharing proprietary proposal information violates the Procurement Integrity Act, which prohibits disclosure of contractor bid or proposal information.
Question 2: The False Claims Act imposes liability on any person who:
- Fails to submit a contract on time
- Knowingly submits a false or fraudulent claim for payment to the government (Correct answer)
- Disagrees with a contracting officer's decision
- Requests a contract modification
Correct answer: Knowingly submits a false or fraudulent claim for payment to the government
The False Claims Act imposes treble damages and civil penalties on those who knowingly submit false claims for payment to the federal government.
Question 3: A contract manager recognizes that a contract clause conflicts with her company's ethics policy. The BEST course of action is to:
- Sign the contract and ignore the ethics policy
- Seek legal and ethics counsel to reconcile the conflict before signing (Correct answer)
- Strike out the clause without telling the other party
- Proceed since the contract supersedes internal policy
Correct answer: Seek legal and ethics counsel to reconcile the conflict before signing
Consulting legal and ethics counsel ensures the organization addresses the conflict properly and avoids committing to terms that violate its own policies.
Question 4: What is the PRIMARY purpose of a compliance hotline in a government contractor's ethics program?
- To track employee attendance
- To provide an anonymous channel for reporting suspected misconduct (Correct answer)
- To communicate contract milestones to the government
- To record all vendor communications
Correct answer: To provide an anonymous channel for reporting suspected misconduct
A compliance hotline gives employees a confidential or anonymous way to report potential violations without fear of retaliation.
Question 5: A contract manager's former employer is bidding on a contract she is now evaluating. She should:
- Evaluate the bid objectively since she no longer works there
- Recuse herself and disclose the potential conflict to her ethics officer (Correct answer)
- Reject the former employer's bid automatically
- Seek additional technical help but remain lead evaluator
Correct answer: Recuse herself and disclose the potential conflict to her ethics officer
A personal financial or employment relationship with a bidder creates a conflict of interest requiring recusal and disclosure.
Question 6: Which of the following BEST defines 'gratuity' in the context of federal contracting ethics rules?
- A bonus paid to government employees for overtime
- Anything of value given to influence the award or administration of a contract (Correct answer)
- A contractually required payment for early delivery
- A tip given to a delivery driver
Correct answer: Anything of value given to influence the award or administration of a contract
In federal contracting, gratuities are items of value offered to officials to influence contracting decisions, which is prohibited under FAR Subpart 3.2.
Question 7: Under the NCMA Standards of Conduct, a contract manager's PRIMARY obligation when facing an ethical dilemma is to:
- Protect the financial interests of the employer above all else
- Act with honesty and integrity even when it is personally costly (Correct answer)
- Follow the client's instructions regardless of ethical concerns
- Defer the decision to a more senior manager without taking a position
Correct answer: Act with honesty and integrity even when it is personally costly
The NCMA Standards of Conduct require members to uphold honesty and integrity as foundational professional obligations.
CPCM Certified Professional Contract Manager: Ethics and Compliance 3
During source selection, a contracting officer shares a competitor's proposal price with a preferred vendor.
This action is BEST described as: