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While OCI “requirements are applicable to most procurements, acquisitions below the simplified acquisition threshold (SAT) and those for commercial products are exempt, as well as subcontracts for commercial products or commercial services.” ” Use of “structural or behavioral barriers, internalcontrols, or both.”
The Final Rule also makes many changes to 2 CFR Parts 180 and 200, including, but not limited to, increasing the threshold for audits, clarifying the requirements for fixed amount awards, and implementing a mandatory disclosure rule.
31] Thus, implementing and documenting adequate internalcontrols for determining compensation can significantly reduce audit risk. 36] This guidance affords contractors considerable leeway to try to influence the appropriate level at which to define the relevant geographic area.
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