Sandra G. Nugent, Esq.

Sandra G. Nugent has experience in the areas of government contracts, fraud remedies (including suspension and debarment) corporate compliance, federal auditing, and business management. She has more than thirty years of experience in the public and private sectors and is the founder and former director of the National Aeronautics and Space Administration (NASA) Acquisition Integrity Program (AIP) which has primary responsibility for legal issues regarding procurement fraud, other related irregularities, remedies coordination, and suspension and debarment. As the AIP Director and Coordination of Remedies Official, she led the day-to-day operations of the program. Under her leadership, a fraud awareness training and education program was established and more than 17,000 employees throughout the agency were trained. Ms. Nugent formally established the suspension and debarment program at NASA.

Ms. Nugent's legal career also includes positions with; Defense Logistics Agency (DLA), Defense Contract Management Command (DCMC), and Defense Contract Audit Agency (DCAA). She served as the Western District Fraud Counsel for the Defense Logistics Agency (DLA), Defense Contract Management Command (DCMC) prior to her position with NASA. In that capacity she managed the Fraud Program and was the inter/intra agency point of contact in cases of suspected fraud and other related irregularities, and the liaison with the investigative organizations, U.S. Attorney Offices, and the Department of Justice. Ms. Nugent has also represented contractors facing possible debarment as in-house corporate counsel in the private sector. Ms. Nugent's experience has given her a unique perspective and insight into how the government investigates and prosecutes procurement and non-procurement fraud cases; and how debarment cases are handled and resolved.

Ms. Nugent has played a critical role in some of the largest fraud cases in U.S. history. Under her leadership, NASA, and the Department of Defense, in conjunction with the civil division and two U.S. Attorney's Offices achieved the largest procurement settlement in history: $615 million (including $565 million in civil recoveries and $50 million in criminal penalties) to resolve allegations of fraud in the award of NASA's Launch Services Contract (the 19-Pack) and the Air Force's Evolved Expendable Launch Vehicle contracts.

She has years of experience as an Independent Monitor and is well suited to serve as a Monitor to assist contractors and the government in eliminating the risk of reoccurrence of the conduct in question.

Ms. Nugent also held positions as an auditor with the General Accounting Office (GAO), Department of Energy, and the Defense Contract Audit Agency (DCAA), respectively. In addition to holding these positions, she was a price/cost analyst, contract negotiator and led Overhead Cost reviews with the Department of the Air Force.

Ms. Nugent is a member of the Maryland State Bar; District of Columbia Bar; State Bar of California and the New Mexico State Bar; and the U.S. Supreme Court Bar. She has a Juris Doctorate Degree from Southwestern University, Los Angeles, California, and a Bachelor of Arts Degree in Business Administration from Dillard University, New Orleans, Louisiana. She is a Certified Procurement Professional Contracts Manager (C.P.C.M.) and is an active member of the American Bar Association, and the National Contract Management Association.

Ms. Nugent focuses on helping government contractors navigate through the complexities of the Federal Acquisition Regulations; assess and evaluate the effectiveness of compliance and integrity programs to reduce or minimize risk; assist the business in responding to a Notice of suspension or Proposed Debarment; and provide independent monitoring services in cases where a contractor or grantee facing a possible suspension or debarment has entered into an Administrative Agreement, allowing the business to continue doing business with the government while taking corrective actions and putting compliance measures in place to resolve the government's concerns and demonstrate responsibility.

Business Ethics and Compliance Program Consulting

• Compliance Program Design
• Review of policies and procedures related to ethics and compliance
• Evaluation and assessment of compliance programs
• Compliance Risk Assessments related to compliance with Federal Acquisition Regulation (FAR) based rules and related statutes
• Grant Compliance
• Ethics and Compliance Training

Suspension and Debarment

• Respond to Notice of Suspension or Proposed Debarment
• Review and evaluation services required under the terms of a debarment or suspension administrative agreement
• Independent Monitoring

Business Consulting

• Start or Update a Business
• Articles of Organization
• Operating Agreements
• Policies and Procedures Development
• Contract Review/Terms and Conditions
• Prime/Subcontractor Flow down Clauses
• Contract Negotiation
• Independent Contract Agreements
• Non-Disclosure Agreements