If I have a training service requirement ($850,000.00) , do I need a COR and QASP? Where in the FAR/DFAR are the exceptions/exemptions? I looked in FAR Part 37 and DFAR 201.602, any help would be greatly appreciated. Please reply thru email, thanks.
In order to determine if the contracting officer should require the designation of a COR, please refer to FAR 1.602-2(d), DFARS 201.602-2 and more importantly PGI 201.602-2 (in its entirety). Note, this DFARS PGI will soon be updated to replace the reference to the DoD COR HDBK with a reference to DoDI 5000.72 - DoD Standard for Contracting Officer’s Representative (COR) Certification
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In your situation, you will need to justify/document any decision not to designate a COR. If that is the case, the contracting officer retains ALL contract administration responsibilities.
When is a QASP needed? The DFARS recently deleted guidance specifying PWS and QASP requirements because the FAR was updated to clarify this for all Federal Agencies. See FAR 37.102, this is the policy mandating performance based service contracts. In your case, you would need to justify not using a performance based contract. FAR 37.102 will direct you to 37.600 and you’ll notice that 37.602 mandates a PWS when using performance based service contracts and 37.604 provides guidance on the QASP and a reference to FAR 46.4. DFARS 246.401 will also clarify your need to have a QASP.
Should you need help in developing your PWS and QASP, the Automated Requirements Roadmap Tool (ARRT) Suite is a Best Practice and available for free at: http://sam.dau.mil/Content.aspx?currentContentID=arrt