With a rebid for the Prime contract getting ready to take place this year does the scenario above constitute a conflict of interest.
The answer to your question is highly dependent on ALL the specific facts and circumstances of the situation.
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That said, normally there is no automatic conflict of interest when someone comes from the private sector and then starts to work for the government. However, if this COR still has a financial interest in the company or is not able to accomplish COR related duties in an objective and impartial manner because of relationships with contractor employees and management… then yes, there could be an issue or at least the “perception” of an issue.
If you’re with the Department of Defense, DoDI 5000.72 - DoD Standard for Contracting Officer’s Representative (COR) Certification mandates a pre-screening be done when nominating CORs to determine if there are any actual or potential conflicts of interest (see Enclosure 3, page 10).