DoD Proposes Hotline Poster Consolidation

Defense contractors looking for a little more wall space to hang inspirational cat posters may be in luck.  Today, the DoD issued a proposal to consolidate the various hotline poster requirements under DFARS 252.203-7004 (Display of Hotline Posters).

The DoD proposal certainly doesn’t fall under the category of major contracting news, but will be a welcome change for contractors feeling a little overburdened with mandatory government posters.

In its current form (which has only been in place since last year), DFARS 252.203-7004 requires subject defense contractors to “display prominently” three posters: the DoD’s fraud hotline poster, the combating trafficking in persons hotline poster, and the whistleblower protection hotline poster.  The clause also requires a separate Homeland Security hotline poster if the contract is funded, in whole or in part, by DHS disaster relief funds.  Under the current clause, the posters must only be displayed “within business segments performing work in the United States under [DoD] contracts.”

The DoD now states that it has “consolidated the posters into one poster to reduce the number of posters required to be displayed and proposes updating the clause accordingly.”  The proposed new clause will eliminate the separate trafficking in persons and whistleblower protection posters, which will be rolled into the DoD fraud hotline poster.  The separate DHS poster will still be required when DHS disaster relief funds are used.

While the consolidation is good news for domestic contractors, the new rule will actually increase requirements for business segments located in other countries.  As the DoD explains, “[t]his rule also removes the United States-only restriction for use of the DoD poster, because the human trafficking poster requires display outside the United States, even though the fraud hotline poster did not.”

The DoD is accepting comments on the proposed rule before July 11.  Perhaps sometime later this year, defense contractors can replace a couple of government posters with something better calculated to inspire employees.