It’s not enough for everyone in your organization to “know” what the processes are to maintain compliance with your government contracts.  Roles change over time and, believe us, it is absolutely amazing how differently people interpret their responsibilities when speaking candidly.  The bottom line:  Your people may not know what you think you taught them. Your company’s policies should be written down and updated as needed. This leads us to a discussion of internal vs. external training.  While both can be important, contractors too often rely exclusively on in-house training. 

Anyone who has children, though, will tell you that they tune their parents out when mom and dad are delivering instructions.  Internal training can follow this pattern.  Plus, it makes it too easy for people to get distracted and get back to their regular work.  External training provides your team with a fresh voice and a dedicated real or virtual training space.  It also shows any auditor or investigator that your company takes compliance seriously enough to invest in outside classes. 

This can be an important factor in assessing any fines or penalties stemming from a noncompliance issue.  Yes, we realize that writing down policies takes time and that external training costs money.  So does dealing with and paying lawyers, expert witnesses, forensic accountants, and others that are routinely part of any significant compliance action.  Guess which one costs less in the long run?  Proceed accordingly.