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    What are the regulatory and policy requirements for performing contract surveillance? I understand anyone performing contract surveillance should now be a COR. Is anyone that reviews a contractor deliverable performing contract surveillance? If so, our entire organization could require COR training and designation, which would be a significant requirement. I'm looking to meet the intent of regulations and policy while ensuring the quality of contractor performance.


    Answer

    The current policy can be found here: https://acc.dau.mil/adl/en-US/380459/file/51353/Carter USA005569-09_Signed.pdf
    A new Dept of Defense Instruction on the COR program should be released in January 2014 that will clarify and mandate the policy across DoD.
     
    This is a question we see (and answer) often in the COR section of Ask-A-Professor and below is how I’ve answered this question in the past:
     
    Until the COR DoDI is published, this memorandum (that I provided in the link above) is the primary source for determining if an employee (based on their duties) should accomplish COR Training, as well as other possible training requirements which may apply.  In addition, this guidance has been incorporated into the DOD COR HDBK dated 22 Mar 2012 which provides more clarity than the Memorandum above.  You can find a copy of the DoD COR HDBK at the following two links:
    http://www.acq.osd.mil/dpap/cpic/cp/panel_on_contracting_integrity.html
    https://acc.dau.mil/cor
     
     
    Back to your specific question; there is no mandate at the DoD level that specifies anyone and everyone helping with contract surveillance requires COR training.  The key thing a contracting officer has to ask themself is “will the individual(s) who is/are helping with contract surveillance need to communicate technical direction or guidance directly to the contractor or will they be responsible for being the government person who will conduct official inspection/acceptance (e.g. sign a DD 250 or press a button in WAWF, etc.)”?
     
    We have many scenarios where subject matter expert (SME) or QAEs/QAS’ review contractor provided documents or conduct inspections because of their training and knowledge in the subject area; but they do not necessarily communicate directly to or with the contractor and do not act as the voice of the government for providing technical direction and/or guidance.  Rather they forward their input to someone else (another COR or KO?) who is actually documenting the formal acceptance in WAWF and providing feedback, direction, guidance to the contractor.
     
    If that is the situation, there is no policy mandating the QAE/QAS be a trained COR.  However, the final decision rests with the contracting officer (KO).  We recognize having these individuals receive COR training to be a “Best Practice” as it may ensure roles and responsibilities and general contracting knowledge and contract oversight are significantly improved.
     
    In your scenario, the government encourages multiple or assistant CORs be assigned when the contractor is working at multiple geographic locations.
     

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