Government Contracts Monitor

Short Take: Final Rule Consolidates Hotline Posters

November 2, 2016

Effective October 21, the Department of Defense (DOD) allows federal contractors to consolidate several Hotline Posters required for contracts exceeding $5.5 million that are not procured as commercial items under FAR part 12. The requirement also flows down to subcontractors. The Final Rule modifies DFARS Clause 252.203-7004 (Display of Hotline Posters). Before the Rule was published, this clause required contractors to display a number of posters to make their employees aware of federal government policies. These included a DOD fraud hotline poster, a poster about combatting human trafficking, and a poster informing employees of the FAR’s whistleblower protection program. This rule consolidates these requirements into a single poster.

Additionally, the previous hotline poster requirement applied only to work areas in the United States; the new rule expands that requirement to include sites outside of the United States, because the whistleblower and human trafficking notifications are required to be displayed worldwide. The new rule also clarifies that, where a significant portion of the contractor’s workforce does not speak English, the contractor bears the costs of translating the poster to the appropriate foreign language or languages. The current DoD Hotline posters can be accessed here, although the consolidated poster has not yet been published on the site.