FAC Risk & Compliance 2 — Questions and Answers
Question 1: Which risk management framework is most commonly referenced in federal acquisition for assessing information system security risks?
- COSO ERM
- NIST RMF (SP 800-37) (Correct answer)
- ISO 31000
- PMBOK Risk Register
Correct answer: NIST RMF (SP 800-37)
NIST SP 800-37 provides the Risk Management Framework (RMF) used governmentwide for managing information system security risks.
Question 2: A contracting officer discovers a contractor submitted falsified cost data during negotiations. Under the False Claims Act, who may bring a qui tam lawsuit on behalf of the government?
- Only the Inspector General
- Only the Department of Justice
- A private citizen (relator) (Correct answer)
- Only the contracting agency head
Correct answer: A private citizen (relator)
The False Claims Act allows private citizens, called relators or whistleblowers, to file qui tam suits on the government's behalf and share in any recovery.
Question 3: Under FAR 9.405, what is the immediate consequence when a contractor is debarred?
- The contractor must pay a civil penalty
- Agencies are prohibited from awarding contracts to the contractor (Correct answer)
- The contractor's existing contracts are terminated immediately
- The contractor is placed on a performance improvement plan
Correct answer: Agencies are prohibited from awarding contracts to the contractor
FAR 9.405 prohibits agencies from soliciting offers from, awarding contracts to, or consenting to subcontracts with debarred contractors.
Question 4: Which clause requires contractors to disclose credible evidence of a violation of federal criminal law involving fraud, conflicts of interest, bribery, or gratuity?
- FAR 52.203-13 (Correct answer)
- FAR 52.215-10
- FAR 52.227-14
- FAR 52.246-25
Correct answer: FAR 52.203-13
FAR 52.203-13 (Contractor Code of Business Ethics and Conduct) mandates timely disclosure of credible evidence of certain criminal violations.
Question 5: A program manager wants to transfer all risk of cost overruns to the contractor. Which contract type best accomplishes this?
- Cost-Plus-Fixed-Fee (CPFF)
- Time-and-Materials (T&M)
- Firm-Fixed-Price (FFP) (Correct answer)
- Cost-Plus-Incentive-Fee (CPIF)
Correct answer: Firm-Fixed-Price (FFP)
A Firm-Fixed-Price contract places maximum risk on the contractor because the price does not change regardless of the contractor's actual costs.
Question 6: What is the primary purpose of a Contractor Purchasing System Review (CPSR)?
- To audit the contractor's financial statements
- To evaluate the efficiency and effectiveness of the contractor's purchasing system (Correct answer)
- To approve all subcontracts above $150,000
- To verify contractor compliance with Buy American requirements
Correct answer: To evaluate the efficiency and effectiveness of the contractor's purchasing system
A CPSR evaluates whether the contractor's purchasing system provides adequate policies, procedures, and internal controls for subcontracting.
Question 7: Under the Anti-Kickback Act (41 U.S.C. 8702), which action is specifically prohibited?
- Offering volume discounts to the government
- Providing anything of value to obtain or reward favorable treatment in subcontracting (Correct answer)
- Negotiating lower prices through competitive bidding
- Paying bonuses to employees for cost savings
Correct answer: Providing anything of value to obtain or reward favorable treatment in subcontracting
The Anti-Kickback Act prohibits providing, attempting to provide, or offering anything of value to improperly obtain or reward favorable treatment in the subcontracting process.
FAC Risk & Compliance 2
Which risk management framework is most commonly referenced in federal acquisition for assessing information system security risks?