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    Can a COR approve invoices on fixed price contracts? Can a COR approve vouchers on cost-reimbursement, T&M, and labor hour contracts? Is there a FAR reference for this?


    We have answered this question on many (repeat – many) occasions before in this section of Ask-A-Professor.  Not only does AAP have a search feature, AAP answers will often show up during internet search engines queries (e.g. Google, Bing, Yahoo, etc.).
    You are going to have to ask your USDA Comptroller what the rules are for your agency.  But we believe the rules/policy is probably very similar to the Department of Defense (DoD).  In short, CORs cannot “approve” vouchers on CR contracts or invoices on T&M or Labor Hour contracts.  They can review them for accuracy though.
    The DoD rule and policy is clearly stated in DoDI 5000.72 and it comes directly from the DOD Financial Management Regulation Volume 10, Chapter 10 paragraph 100302, which reads:
    �� 100302. Cost Reimbursement Type Contracts. Cost reimbursement type contracts provide for payment of allowable incurred costs, to the extent prescribed in the contract. These contracts establish an estimate of total cost for the purpose of obligating funds and establishing a ceiling that the contractor may not exceed (except at its own risk) without the approval of the contracting officer.
    A. The Defense Contract Audit Agency (DCAA) has sole authority for verifying claimed costs and approving interim payment costs under cost-reimbursement, time and materials, and labor-hour contracts. Contracting Officer’s Representatives (COR’s) shall not be delegated authority to approve these types of payments. The COR’s may review contractor billings, but are expected to coordinate with DCAA when any cost verification of data is necessary in support of their surveillance responsibilities. Therefore, DCAA approves interim payment requests, the Administrative Contracting Officer (ACO) approves the final payment request, and the COR’s coordinate with DCAA if any cost verification is needed.
    B. Contractors will submit payment requests and receiving reports in electronic form in accordance with Defense Federal Acquisition Regulation Supplement 232.7002 with noted exceptions. When payment requests and receiving reports are not submitted in electronic form, the contracting officer will consult with the payment office and the ACO regarding the preferred method for submitting payment requests. The entitlement office ensures proper approval of all invoices prior to payment.
    The word "invoice" is often used universally to describe a request for payment under any type of contract (FFP, CR, T&M, etc.).  We are going to assume you mean a Public Voucher (SF 1034) on a CR contract.  The word "voucher" has a strict meaning and connotation and are requests for payments on Cost Reimbursement (CR) type contracts.  COR's are only allowed to view vouchers for CR contracts for accuracy (e.g. skill mix, labor hours, bill of materials, travel, etc.) they are NOT allowed to approve vouchers.  The same holds true for invoices on T&M and Labor Hour contracts, the COR can view for accuracy but NOT approve.

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