Drafting Organizational Conflict of Interest mitigation plans manually requires extensive regulatory knowledge, careful analysis of FAR requirements, and hours of documentation to identify conflicts and develop acceptable mitigation strategies. Government contracts attorneys spend 4-6 hours per plan researching precedents, analyzing relationships, and ensuring compliance with complex OCI regulations, all while facing tight proposal deadlines.
Federal contractors face complex regulatory requirements when addressing organizational conflicts of interest under FAR Subpart 9.5. Manually drafting comprehensive OCI mitigation plans requires extensive legal analysis, detailed conflict identification across multiple categories, and precise documentation of enforceable mitigation strategies—a process that typically takes 12+ hours and risks missing critical compliance elements.
CaseMark automates the creation of legally sound, FAR-compliant OCI mitigation plans by analyzing your contract documents and organizational information to identify potential conflicts, assess materiality, and generate tailored mitigation strategies with robust implementation frameworks. Our AI produces comprehensive plans in minutes that meet the rigorous standards expected by contracting officers and agency legal counsel.
This workflow is applicable across multiple practice areas and use cases
Corporate counsel for government contractors need OCI mitigation plans when pursuing federal contracts to ensure compliance with procurement regulations and protect corporate interests.
Government contractors require corporate legal support for conflict analysis and compliance documentation as part of their business development and risk management processes.
Corporate governance teams at government contractors need OCI mitigation frameworks to establish internal controls, compliance policies, and conflict management procedures for ongoing federal contract work.
Effective governance of government contracting entities requires systematic OCI identification and mitigation processes as part of compliance infrastructure and board-level risk oversight.
M&A transactions involving government contractors require OCI analysis to assess regulatory compliance risks and identify conflicts that could impact contract portfolios and deal valuation.
Due diligence in acquisitions of government contractors must evaluate existing OCIs and potential conflicts arising from combined operations, making OCI mitigation plans critical transaction documents.
Commercial litigation involving contract disputes with government agencies often requires analysis of OCI compliance and mitigation efforts as evidence of good faith performance and regulatory adherence.
OCI-related disputes and bid protests frequently result in litigation where documented mitigation plans serve as key evidence of contractor compliance with FAR requirements.
An OCI mitigation plan is a formal regulatory document required under FAR Subpart 9.5 that identifies potential organizational conflicts of interest in federal contracting and proposes specific, enforceable measures to neutralize those conflicts. The plan addresses three conflict categories: biased ground rules, impaired objectivity, and unequal access to information. It becomes a binding contract term once accepted by the government and must include detailed implementation, monitoring, and enforcement mechanisms.
You need an OCI mitigation plan when a contracting officer identifies potential conflicts, when solicitation instructions require one as part of your proposal, or when you voluntarily disclose conflicts that could affect your ability to compete fairly or perform objectively. Common scenarios include contracts involving advisory services, technical evaluation support, requirements development, or situations where you possess non-public information from prior government work. Early submission demonstrates good faith and can prevent disqualification from competition.
You'll need the solicitation or contract documents describing the procurement scope, your complete corporate structure including parent companies and subsidiaries, details of any prior contracts with the procuring agency, and information about personnel who may have access to competitively sensitive information. Optional but helpful documents include prior OCI-related correspondence with the government, teaming agreements, and records of access to non-public information. CaseMark analyzes these materials to identify conflicts and generate appropriate mitigation strategies.
CaseMark's AI is trained on FAR Subpart 9.5 requirements, agency-specific supplements, and best practices for federal procurement compliance. The system conducts comprehensive conflict analysis across all three regulatory categories, generates tailored mitigation strategies specific to your situation rather than generic boilerplate, and structures the plan with legally binding certifications and enforcement mechanisms that meet contracting officer expectations. Every plan includes detailed implementation frameworks with governance, monitoring, and compliance architecture required by federal regulations.
Yes, the generated plan serves as a comprehensive foundation that you can review and customize as needed. You may want to refine specific mitigation strategies based on internal capabilities, adjust personnel assignments, or add details about your organization's unique compliance infrastructure. The AI-generated structure ensures you don't miss critical regulatory elements while giving you flexibility to tailor the final document to your specific circumstances and the contracting officer's requirements.