Section 1.3 of the Operational Procedures for Enforcement, published in June 1998, provides the opportunity for the Office of Enforcement and Investigation (EHEnforcement) to periodically issue clarifying guidance regarding the processes used in its enforcement activities.
During 1999, EH-Enforcement began an initiative to conduct formal reviews of contractor programs for identifying, reporting, tracking and closing PAAA noncompliances. Four main objectives were associated with this initiative:
- Encourage the establishment of effective programs for noncompliance identification and reporting across the complex;
- Enhance the uniformity of PAAA noncompliance identification and reporting among contractors;
- Provide EH-Enforcement with first-hand information on program effectiveness for those contractors with little previous enforcement interaction (i.e., low-reporters); and
- Establish a mechanism for the feedback of program implementation lessons-learned into existing EH-Enforcement guidance.