VA Reopens 60-Day Comment Period on Contractor Conflict-of-Interest Disclosure Rule
Extension without change would keep VAAR 852.209-70's disclosure requirement in place for management and consulting offerors
BLUF: The Department of Veterans Affairs (VA) is seeking public comment through November 2, 2026 on an unchanged extension of its rule requiring contractors bidding on management-support and consulting work to disclose organizational conflicts of interest.
The VA's Office of Procurement published the notice under the Paperwork Reduction Act of 1995, which requires 60 days of public comment before OMB can renew an existing information-collection approval. This request covers OMB Control No. 2900-0418, tied to Department of Veterans Affairs Acquisition Regulation (VAAR) provision 852.209-70, Organizational Conflicts of Interest.
Why it matters: VAAR 852.209-70 and its companion solicitation provision, VAAR 809.507-1, require offerors on VA management-support and consulting solicitations to state in their proposal whether award of the contract could create a conflict of interest and, if so, to disclose the relevant facts. Contracting officers use those disclosures to decide whether to make award as-is, add mitigating contract terms, or decline to award. Firms that pursue VA consulting or management-support work should expect the disclosure requirement to continue unchanged and should be prepared to identify potential conflicts, including work for other VA components or competitors, before submitting an offer.
By the numbers:
- 60-day comment period, closing November 2, 2026
- OMB Control No. 2900-0418
- Estimated annual burden: 102 hours
- Estimated respondents: 102, at 60 minutes each, once per solicitation
- Statutory basis: Section 8141 of the 1989 Department of Defense Appropriation Act (Pub. L. 100-463)
The collection is described as an "extension without change of a currently approved collection" — VA is not proposing to modify the disclosure requirement itself, only to renew OMB's approval to keep collecting it. Comments must be submitted through Regulations.gov. Program-specific questions go to Forrest Browne in VA's Office of Procurement; PRA-process questions go to VA's PRA clearance office.
Source: Federal Register
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