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  • Question

    Can a contractor perform Contracting Officer Representative (COR) file reviews or assist in any form with COR file reviews?


    Answer

    The situation you describe is a scenario where the contractor would be conducting some type of audit to determine if a COR’s files are timely, accurate, complete, etc.  These individuals would NOT be acting as CORs on contracts or delivery orders (i.e. providing technical direction to a contractor or accomplishing inspection and acceptance, etc.).  There is NO FAR prohibition on contracting out this effort.  A good source for seeing if a task, action or activity may be inherently governmental is FAR 7.503.
     
    That said, it sounds like the work has the potential to fall into the category described at FAR 37.114 or within the Advisory and Assistance Services area (FAR 37.2).  Most Federal Agencies have review and approval procedures above the contracting officer level prior to executing these types of contract actions; therefore we highly suggest you review your Agency specific FAR Supplement and policy and procedures.  A COR’s file often contains proprietary information and as such OCI issues and the need for Non-Disclosure Agreements should be thoroughly researched.

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