Oci Mitigation Plan

Draft FAR 9.5 OCI Mitigation Plans in Minutes

12 minutes with CaseMark

Run this workflow

Run it in CaseMark

Upload your documents and get a finished work product in minutes. New accounts get $5 free to run their first skill.

12 minutes with CaseMark

What you'll need

Solicitation & Statement of Work
Corporate Structure Documentation
Prior Contract History

SOC 2 Type II · HIPAA compliant · $5 free credit

Workflow

Overview

CaseMark's OCI Mitigation Plan skill automates the complex process of drafting FAR Subpart 9.5-compliant organizational conflict of interest mitigation plans for federal government contractors. It analyzes your corporate structure, procurement details, and prior contract history to identify material conflicts and generate tailored mitigation strategies. The result is a submission-ready plan complete with firewalls, recusals, compliance monitoring frameworks, and binding corporate certifications.

Drafting OCI mitigation plans is one of the most complex and time-sensitive tasks in federal contracting. Attorneys and compliance professionals must manually analyze intricate corporate relationships, map them against three distinct FAR 9.5 conflict categories, and craft tailored mitigation measures—all under tight proposal deadlines. Missing a conflict or proposing inadequate mitigation can result in disqualification from competition or contract termination.

CaseMark automates the end-to-end OCI mitigation plan drafting process by analyzing your uploaded solicitation documents, corporate structure, and prior contract history against FAR 9.5 requirements. The AI identifies material conflicts across all three categories, generates proportionate mitigation strategies, and produces a complete plan with compliance architecture and binding certifications—transforming a multi-day effort into a streamlined workflow.

How it works

1. Upload your solicitation documents, corporate structure details, and prior contract history
2. AI analyzes each FAR 9.5 conflict category for materiality and risk exposure
3. Review the generated mitigation plan with tailored firewalls, recusals, and compliance frameworks
4. Export the finalized OCI mitigation plan in your preferred format (DOCX, PDF)

What you get

Executive Summary with Conflict-to-Mitigation Table
Conflict Identification & Materiality Analysis
Tailored Mitigation Measures
Compliance & Monitoring Architecture
Binding Corporate Certifications

What it handles

Automated FAR 9.5 conflict category analysis across unequal access, impaired objectivity, and biased ground rules
Tailored mitigation strategies including firewalls, recusals, and information barriers
Compliance architecture with monitoring frameworks and reporting protocols
Binding certification language for authorized corporate officers
Executive summary with conflict-to-mitigation mapping table
Prior OCI correspondence integration and timeline tracking

Required documents

Solicitation & Statement of Work
The solicitation package including the statement of work, performance work statement, or requirements document for the target procurement
.pdf, .docx
Corporate Structure Documentation
Organizational charts, parent-subsidiary relationships, UEI/CAGE codes, teaming agreements, and equity interest disclosures
.pdf, .docx
Prior Contract History
List of relevant prior and current government contracts, advisory roles, and any non-public information accessed
.pdf, .docx, .xlsx

Supporting documents

Prior OCI Correspondence
Any prior communications with the contracting officer regarding OCI concerns or disclosures
.pdf, .docx, .eml
Teaming & Subcontractor Agreements
Executed or draft teaming agreements, subcontract arrangements, and consulting agreements relevant to the procurement
.pdf, .docx
Existing Compliance Policies
Current corporate OCI policies, ethics programs, or firewall procedures already in place
.pdf, .docx

Why teams use it

Reduce OCI mitigation plan drafting time from days to minutes while maintaining FAR 9.5 compliance

Ensure comprehensive conflict analysis across all three FAR categories with no gaps in coverage

Generate professionally structured plans that address contracting officer expectations and agency standards

Minimize proposal risk by producing thorough OCI disclosures that demonstrate proactive compliance

Questions

What types of OCI conflicts does this tool analyze?

CaseMark analyzes all three FAR 9.5 conflict categories: unequal access to information (9.505-4), impaired objectivity (9.505-3), and biased ground rules (9.505-1, 9.505-2). Each category is assessed for materiality based on your specific procurement and organizational facts.

Can this be used for voluntary OCI disclosures or only CO-requested plans?

CaseMark generates OCI mitigation plans for all scenarios—contracting officer requests, proposal requirements mandating OCI disclosure, and voluntary disclosures. The output adapts its framing and legal basis section accordingly.

Does the tool account for corporate parent-subsidiary relationships?

Yes. CaseMark analyzes your full corporate family structure, including parent companies, subsidiaries, affiliates, teaming partners, and subcontractors to identify potential conflicts that extend beyond the prime contractor entity.

How does CaseMark ensure the mitigation measures are appropriately tailored?

Rather than applying generic templates, CaseMark maps each identified conflict to specific mitigation strategies—information firewalls, personnel recusals, organizational separations, or divestiture recommendations—based on the nature and severity of the conflict and relevant FAR guidance.

Can I include prior OCI correspondence with the contracting officer?

Absolutely. CaseMark integrates prior OCI communications into the plan, creating a chronological record and ensuring your mitigation measures directly address any concerns previously raised by the contracting officer.

Is the output ready to submit to the contracting officer?

CaseMark produces a comprehensive, professionally structured OCI mitigation plan that follows FAR 9.5 conventions. While we recommend legal review before submission, the output provides a thorough foundation that significantly reduces drafting time.