Most people know that the Office of Management and Budget plays
a leadership role in the development of the President's budget.
However, too often advocates solely focus their federal funding
advocacy efforts on the Congress and the members of the House and
Senate Appropriations Committees. While clearly, those who control
the purse-strings are essential to the federal funding process and
outcomes, the staff – both political and career
– at OMB maintain significant expertise in –
and authority over - federal departments, agencies, and programs.
OMB maintains responsibility for five core functions, only one
which relates to the development of the annual budget proposal. It
is important to note that OMB:
provides "oversight of agency performance, federal
procurement, financial management";
coordinates and reviews "all Federal regulations by
engages in "legislative clearance and coordination (review
and clearance of all agency communications with Congress, including
testimony and draft bills)"; and
is involved in "Executive Orders and Presidential
Memoranda to agency heads and officials."
Given this significant role and associated authority, OMB and
its staff are in an unique position to influence policies,
programs, and funding across the entire spectrum of the federal
government. In my experience, visiting with the OMB staffer whose
portfolio includes the program or agency of concern of interest
will prove time well spent.
To read the 2014 Budget Guidance released by OMB on May 18th,
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A recent federal court decision makes a company's internal investigation documents fair game in litigation, particularly when federal regulations, such as the Federal Acquisition Regulation (FAR), require the company to maintain a compliance program and to investigate potential misconduct.
On March 6, 2014, the District Court for the District of Columbia issued an opinion in United States ex rel. Barko v. Halliburton Company et al. that should serve as a wake-up call for all companies conducting internal compliance investigations to evaluate whether those investigations are structured in a manner to maximize the protections of the attorney-client privilege and work product doctrines.