Can a COR function in a dual role as the Program Manager?
We answered an almost identical question at the end of April 2015; it was posted under Program Management. You can see the answer at this link: https://dap.dau.mil/aap/pages/qdetails.aspx?cgiSubjectAreaID=9&cgiQuestionID=122400
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Unfortunately, if you are “trying to justify separation of duties”… you may have come to the wrong place.
There are many examples of agencies and organizations within the federal government where personnel serve as both PM and COR. This actually serves both the requiring activity and the contracting office very, very well. The contract is put into place in order to help the requiring activity meet its mission. The more the COR knows about the mission and contract requirement (PM type role) the more they will know if contract performance is adequately helping to meet the mission needs. In the event it is not, corrective action and changes can be discussed with the contracting officer sooner, rather than later.
The role of the PM is to represent the requiring activity, normally this authority is tied to budget execution responsibility. The COR is the “eyes and ears” of the contracting officer and they receive their authority from the contracting officer, in fact the contracting officer is delegating some of the authority (contract administration) they have from their warrant to the COR. But that does not mean there should be any conflicts of interest, so long as COR duties are performed in full accordance and compliance with the Letter of Designation.
All that said, if you want separate duties and your leadership agrees, there is nothing preventing you from doing it.