1. Could the CORs use the PMs' email approval as the proof for their invoice verification work?
2. Is there a conflict of interest in designate the PM to be the COR for the program/project he/she manages, such in the designation of Task Lead cases?
I’ll address the second half of your question “2.”, first as we’ve answered almost identical questions recently, these are the links:
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Bottom Line: There is nothing which prohibits PMs from being CORs. That said, Agencies and CO’s have the latitude to make this determination.
Now, on to the first part of your question regarding “invoice verification”. There is nothing inherently wrong with the process you described per se; here’s how it would work:
Accepting an invoice is ultimately the contracting officer’s responsibility. But, it is one that is most often delegated/designated to a COR. If the Agency and the CO do not want the PMs to be designated CORs, but it is the PM who has the knowledge to know if the invoice is accurate and complete; then I can see where this is ok. The COR is relying on the expertise of the PM to finalize acceptance. This is similar to when a contractor submits a technical report to the government. The COR may not have the expertise to know if the report meets the contracts terms and conditions regarding quality, so they rely on the subject matter expert to read the report. If the SME says the report is good, then the COR accepts it.
This assumes that everyone (CO, PM and COR) are equally responsible and motivated to make sure the government is only paying for the goods and services it has received and accepted and at the price/cost agreed to in the contract or task order. This also assumes that the PM knows they are not the COR and therefore not allowed/authorized to do any of the other tasks the CO may have delegated to the COR. Often times CORs are nothing more than information conduits.
In your case, we hope that these “PM E-Mails that approve the invoice” are backed up with the documentation as to how they ensured verification. If not, there very well could be an issue. In other words, the focus should be on how the invoices are being verified, how is that being documented and supported and less on who is actually doing it.
CAVEAT: The above is based on current Department of Defense policy, procedures and regulations. Your agency may have other policy, procedures or regulations that dictate a certain process or procedure. You should ask the CO if they are comfortable with how the invoices are being verified as accurate and complete.