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Tiffani Lee Named Diversity Partner for Holland & Knight

MIAMI – Tiffani Lee, a litigation partner in the firm's Miami office, has been appointed Diversity Partner for the firm. Lee previously served as Chair of the firm's African-American Affinity Group and led its external diversity marketing efforts. In her new role, she will work closely with the firm's senior management and Chief Diversity Officer to advance Holland & Knight's diversity initiatives, internally and externally.

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Dan Coffman Joins Holland & Knight's National Labor, Employment and Benefits Practice Group in Jacksonville

JACKSONVILLE, Fla. – Highly respected Jacksonville labor and employment attorney Dan Coffman has joined Holland & Knight's Jacksonville office as Of Counsel in the firm's national Labor, Employment and Benefits Practice Group. Prior to joining the firm, he was a founding partner at Coffman, Coleman, Andrews & Grogan in Jacksonville.

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Government Contracts
Alert - July 23, 2008
 
In this Issue...
 
FAR Case 2007-006, Contractor Compliance Program and Integrity Reporting – 2nd Proposed Rule
 
 July 23, 2008
 
Alan Dickson- Los Angeles
Richard O. Duvall- Northern Virginia
Steven Gordon - Washington
Christopher Myers- Northern Virginia

Holland & Knight partners in the Government Contracts and Compliance Services practice groups submitted comments to the General Services Administration (GSA) and FAR Councils in response to the proposed rule set forth in FAR Case 2007-006, “Contractor Compliance Program and Integrity Reporting – 2nd Proposed Rule.” The Proposed Rule would add new requirements to the recent final rule in FAR Case 2006-007, Contractor Code of Business Ethics and Conduct, 72 Fed. Reg. 65873
(Nov. 23, 2007) (the “Code of Ethics Rule”).

The Code of Ethics Rule requires many government contractors to develop and adopt a Code of Ethics, internal controls to promote compliance with the Code of Ethics and training programs to help implement the code. The Proposed Rule would mandate self-reporting of overpayments, criminal violations and civil False Claims Act violations, and would make a failure to self-report a cause for suspension or debarment from government contracting.

Holland & Knight’s comments identify a number of significant concerns with the Proposed Rule as currently structured and highlight certain unintended and adverse consequences of the Proposed Rule. One especially troubling consequence is that the Proposed Rule will likely generate large numbers of “defensive” self-disclosures of minor or non-existent issues, which will then have to be investigated by the government. We believe that the Proposed Rule will prove to be very costly and counter-productive to the government’s interest in promoting honest, efficient and cost-effective contracting procedures.

Please Click Here to view the comments.

For more information, contact:

Alan Dickson
213.896.2415
alan.dickson@hklaw.com

Richard O. Duvall
703.720.8620
richard.duvall@hklaw.com

Steven Gordon
202.457.7038
steven.gordon@hklaw.com

Christopher Myers
703.720.8038
chris.myers@hklaw.com

toll free: 1.888.688.8500