U.S. AbilityOne Program

 

At Glotfelty PLLC, we are proud to be the only law firm with a primary focus on the AbilityOne Program and its participating nonprofits. Our attorneys combine deep knowledge of federal procurement law with firsthand experience in the AbilityOne community. We understand that federal contracting is complex on its own – to include bidding, pricing, compliance, and risk management. The AbilityOne Program adds another layer of unique requirements, exceptions, and mission considerations. Our firm provides practical, proactive, and cost-effective legal counsel to help AbilityOne nonprofits navigate this specialized landscape with clarity and make informed strategic decisions for long-term success.  

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Federal Contracting & AbilityOne Procurement List Counsel 

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Federal contracting is a constantly evolving environment shaped by new rules, policies, oversight priorities, and economic considerations. Our firm closely monitors developments within the federal procurement space, including the Revolutionary Overhaul of Federal Acquisition Regulation (FAR) and ongoing modernization efforts within the U.S. AbilityOne Commission. We help our clients stay ahead of and adapt to these changes while maintaining compliance.

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We assist a wide range of stakeholders, from participating nonprofits seeking to protect and grow their Procurement List work, nonprofits interested in exploring new and diversified business ventures, or businesses seeking to explore AbilityOne partnerships.

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Our firm offers highly specialized counsel surrounding the AbilityOne Program and its intersection with federal procurement laws, including:

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• AbilityOne Program’s Intersection with Federal Procurement Laws: counseling on whether proposed and existing business practices comply with federal contracting laws and, as needed, developing risk mitigation strategies or internal controls to ensure readiness for federal audits, evaluations, or investigations.

• AbilityOne Procurement List Actions and Disputes: advising on Opportunity Notice responses, contractor impact assessments, assignment and allocation appeals, and disputes involving PL additions, removals, or reassignments.

• AbilityOne Program Entry & Reentry: guiding nonprofits through the AbilityOne Program entry or reentry process in full compliance with Commission Policy 51.401. Our services include evaluating governance and related-entity structures, ensuring financial and operational independence, addressing prior compliance issues, preparing qualification documentation, and supporting required training.

• AbilityOne Partnerships & Business Development: assisting businesses and nonprofits on exploring and structuring partnerships under the AbilityOne Program, including subcontracting, co-branding, and other collaborations.
   

Compliance, Risk Assessment, and Strategic Mitigation Services

 

How prepared is your nonprofit to face government scrutiny? We offer tailored consulting services to help AbilityOne nonprofits strengthen compliance and prepare executives for government oversight, audits, and investigations. Our services include training sessions on the False Claims Act (FCA) and government enforcement priorities, how to prepare for investigative interviews, and the role and powers of different government agencies operating within the AbilityOne enforcement space. 

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We help AbilityOne nonprofits identify and mitigate vulnerabilities before they escalate into costly criminal, civil, or administrative exposure. Our services include targeted assessments focused on high-risk areas, including compliance with the AbilityOne direct labor ratio, medical documentation and Individual Eligibility Evaluations (IEEs), Procurement List product and service integrity, pricing practices, contractual obligations, the use of affiliated healthcare providers, privacy matters, sourcing and supply chain management, conflicts of interests, and federal procurement laws.

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Internal Investigations Under Commission Compliance Policy 406

 

Federal contractors, including AbilityOne nonprofits, which meet certain thresholds have an affirmative obligation under FAR 52.2023-13 Contractor Code of Business Ethics and Conduct to exercise reasonable due diligence to prevent and detect criminal conduct, including establishing and maintaining an effective compliance program and sufficient internal controls to timely detect and mitigate risks. Similarly, the AbilityOne Commission Policy 51.406(5)(c)(ii) requires participating nonprofits to establish and maintain “an effective system for receiving and investigating complaints from participating employees.” These systems are essential for protecting your organization’s integrity, protecting program beneficiaries, and reducing the risk of costly compliance failures.

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Glotfelty PLLC assists AbilityOne nonprofits in designing and implementing comprehensive internal reporting systems that meet both federal contracting and Commission requirements. Our approach strengthens compliance culture, enhances transparency, and provides a legally defensible framework to help address issues before they escalate.  

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In the event your nonprofit receives a complaint, our firm offers discreet, professional, and privileged investigative support. Our services include: conducting privileged internal investigations, performing credibility assessments, managing disclosure obligations to agency OIGs and contracting officers, and advising on risk mitigation strategies to lower liability exposure. 

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