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Really good article, thank you. I had twenty years in AF Contracting and I did worry about going to jail before I signed a contract each and every time. The whole point of a FAR based contract is to hold both the contractor and the government accountable. Sure it is a pain in the butt to manage but if you don't have all those checks and balances you end up with this sort of nightmare. Thankfully I was only directed to use OTA once in my career but I hated it. "Here contractor, have a suitcase full of money and give us something, maybe". The guidance on OTAs is so darn vague and, as Col Mills stated, they were never meant for this type of procurement. Doubt if the misuse was criminal though but only because the guidance governing OTAs is so vague.

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