Is there a minimum dollar value on a contract below which no COR is required?
It’s been a while since we’ve answered this in the COR section of Ask-A-Professor, so a reminder and refresher to all is merited.
At the DoD level, the guidance for when a COR is required to be designated is not tied to a dollar threshold. It requires a more subjective analysis surrounding the risk of contract performance and oversight the government wishes to have. That said, there is guidance for use in making this decision. Unless you have local or agency level policy we are unaware of, the guidance you need can be found at DFARS PGI 201.602-2(iv)(A), which states:
“Contracting officers shall designate a COR for all service contracts, including both firm fixed price and other than firm fixed price contracts, awarded by a DoD component or by any other Federal agency on behalf of DoD. The surveillance activities performed by CORs should be tailored to the dollar value/complexity of the specific contract for which they are designated. Contracting officers may exempt service contracts from this requirement when (each of) the following three conditions are met:
(1) The contract will be awarded using simplified acquisition procedures;
(2) The requirement is not complex; and
(3) The contracting officer documents the file, in writing, why the appointment of a COR is unnecessary.
For cost reimbursement contracts that are not service contracts, contracting officers shall either retain or delegate surveillance activities to a COR or DCMA.”
If there is no COR assigned; then ultimately the contracting officer is responsible for monitoring contractor performance. This makes sense considering that when a COR is appointed it is some of the contracting officer’s authority/responsibility they are being delegated.
Note: the above is also codified in DoDI 5000.72 - DoD Standard for Contracting Officer’s Representative (COR) Certification
Open full Question Details