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    Question is: I have COR's who are apointed by a letter and also they have 1910 QA's who conduct their surveillance fthem. Are the 1910's still required to be on an apointment letter with the COR and still meet the same training? This AR states so: AR 70-13 2-2. Requiring activities g. Provide other surveillance support personnel, when needed. Requiring activities shall provide other surveillance support personnel, as necessary, to support CORs in monitoring and documenting the contractor's performance. These other surveillance support personnel may serve as on-site representatives of the COR in performance of actual contract surveillance if they meet all COR requirements and have been appointed by the contracting officer as alternate CORs. But the KO states he does not have to according to this paragraph in the same AR. section 2.6(a), states, "The contracting officer may appoint an individual to assist the COR in monitoring a contractor's performance. This individual may be called a quality assurance evaluator, quality assurance representative, quality assurance specialist, or government technical monitor. The requiring activity should designate other surveillance support personnel necessary to aid the COR in the monitoring and evaluation of a contractor's performance." Since the QA personnel in question are already hired by the Government to perform these functions, I do not have to appoint them in writing. So my question is if a COR has 1910's doing surveillance for them are they required to have the same training and be on an apointment letter or not?? Billy D Wilkerson MICC-QAS


    Answer

    This is a question I receive (and have answered in the AAP forum) very often, albeit in different forms, functional career fields, etc.
     
    We are going to assume that the GS-1910 in your question background is not a Defense Contract Management Agency (DCMA) GS-1910 Quality Assurance Representative.  Because… if that were the case, the following guidance would apply IAW the Defense Federal Acquisition Regulation Supplement (DFARs):

     
    201.602-2 Responsibilities.
    (2) A COR—
    (iii) May not be delegated responsibility to perform functions at a contractor's location that have been delegated under FAR 42.202(a) to a contract administration office;
     
    A DCMA GS-1910 is already authorized to perform in plant related QA duties by virtue of the contract being formally delegated from the Contracting Officer to a Contract Administration Office.  But judging from your question background, the scenario does not involve DCMA or in-plant inspection.
     

    It is extremely common for CORs to rely on subject matter experts (SMEs) to help them do contract surveillance/performance monitoring; especially for contracts that require complex inspection efforts (much like AR 70-13 2-2 describes).  In these cases, the SMEs report their findings, observations, recommendations, etc. to the COR or other government official but they have absolutely NO authority to provide technical direction directly to the contractor or formally accept contractor work on behalf of the gov’t.  In these instances the COR is often nothing more than a “communication conduit” between various subject matter experts (GS-1910 in your instance), the contractor and the Contracting Officer and have few if any direct surveillance or inspection duties delegated to them, but they have many “communication” related duties delegated to them.
     
    However, if the 1910 is “accepting” work by signing a DD250 or approving invoices in WAWF or authorized to provide technical direction to the contractor; then they need to be designated as a COR.  If they are designated a COR by the Contracting Officer they need to meet all COR training requirements; 1910s are not relieved of COR training requirements in this scenario.
     
    Minimal COR training requirements can be found in the DoD COR HDBK Appendix C.  A web enabled version of the HDBK can be found at: www.acc.dau/mil/cor  or a PDF version of the HDBK at http://www.acq.osd.mil/dpap/cpic/cp/panel_on_contracting_integrity.html

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