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  • Question

    If awarded without a COR or if the COR's security clearance is lower than the DD-254, does the COR function remain with the Procuring Contracting Officer, delegated in its entirety to the Ordering Officer, or shared between the COR and Ordering Officer for those orders above the COR's security level?


    Answer

    For other readers, the Navy has a regulation which requires the COR to have the same or higher security clearance as what is specified in the DD Form 254.  Additionally, the term “Ordering Officer” in this question refers to a warranted contracting officer who has been given the authority to issue task orders against another Navy Command’s IDIQ contract; as opposed to the ordering officer defined in DFARS 201.603-3(b) for micro purchasing.
     
    Now, onto the answer:
     
    Based on your predicament, you have essentially only three (3) choices:
     
    1) You wait to issue task orders until the requiring activity, customer, etc. provides a COR who has all of the training, experience and security clearance requirements.
     
    2) You (and the other ordering officers) issue the task orders and maintain all of the contract administration duties you were going to delegate to the COR in the designation letter.  In this instance you will have to follow your local or SYSCOM procedures for deviations and waivers, because you are deviating from FAR 1.602-2(d) and 16.301-3(4)(i).  Note: we are assuming the contracting officer/ordering officers have the required security clearances to prevent what the submitter referred to as “gray contracting”, a scenario where the contracting officer doesn’t know what they are buying.
     
    3) Request relief from the Navy regulation requiring the security clearance to higher headquarters.  Note: your COR will still not be able to have access to any information that is classified above their actual security clearance.


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