Is there any guidance that clearly states whether or not a contracting officer must use military rank in their signature block when signing as a contracting officer?
This is a fantastic question! Like you, I was taught the same thing early in my career (my first USAF issued warrant was 1996).
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I could not find any definitive guidance, policy, or procedure that either expressly prohibits including military rank (or civilian grade) on either the SF 1402 or in a contracting officer’s signature block on correspondence (I’ll get to Forms shortly) OR expressly requires rank/grade to be included.
- FAR 1.602 and 1.603
- DFARS 201.602 and 201.603
- AFFARS 5301.602, 5301.603, and MP5301.603 (plus a few of the embedded links).
- 10 U.S.C 1724
- DoDI 5000.66
AFARS 5101.602 and 5101.603 (because the Army does a great job at explaining things like this)
Forms: I also checked the FAR and all of the supplements referenced above Parts 53. Again, nowhere did they say rank/grade in a contracting officer’s signature block should be included; but they also do not state that it is prohibited to be included. However, it should be noted that almost all DoD Agency FAR Supplements mandate that rank/grade be included when designating CORs and/or Ordering Officers. I find the difference to be telling.
Back to Forms… if you look closely at ANY form that has a block for a Contracting Officer (e.g. SF33, SF30, SF26, SF1442, DD1155, etc., etc.) notice that they all have the same thing which is “Name of Contracting Officer” and “Contracting Officer Signature”. The Title of "Contracting Officer" stands on its own!!
Intuitively you were absolutely correct, the authority you have as a contracting officer is given to you through the warrant (SF 1402) you have and any limitations it may state. It has nothing to do with the rank or grade you hold.
We think it is good form not to include rank or grade. That said, there are acquisition related positions which do have minimum rank/grade requirements, but Contracting Officer is not one of them. Again, while the research done to answer this question was exhaustive, that does not mean it was all encompassing, I could have missed something somewhere. If I have, hopefully a reader will let us know!