What are the COR surveillance requirements for NASA or any agency outside of DOD when they receive a MIPR from a DOD agency? Are they required to adhere to the DOD COR Handbook? Do they have to develop a QASP? Is it possible for DCMA to perform surveillance?
Another question from one of our “regulars” here at AAP.
This is a fantastic question, but it actually goes way beyond COR surveillance requirements outside of DoD. It’s really a question about “Interagency Acquisitions” and possibly the Economy Act (31 U.S.C. 1535).
Luckily there is very straightforward guidance found at FAR 17.5 and DFARS 217.5 and associated PGI. Basically, unless using FSS or a GWAC, the Economy Act will apply. What this essentially means is that if another agency is acting as your contracting officer, they still must follow any applicable DoD or Service Component rules.
Will your organization be providing the COR? If yes, then the COR needs to be trained, certified and appointed in accordance with DoD procedures; see DFARS 201.602-2 and DoDI 5000.72.
If the other Agency (NASA) is appointing the COR, they are authorized to use their own procedures, see DoDI 5000.72, paragraph 3.c. on page 2.
Do they have to develop a QASP? This has nothing to do with assignment of CORs, the guidance is found at FAR 37.604. However, normally the requiring activity (you) is tasked to write the QASP. If one is required IAW the FAR, OR… you want one, the Contracting Officer is going to ask you to write it. If they will be using an existing NASA contract and a QASP is required, they probably already have one-NASA is very good when it comes to compliance with acquisition and procurement regulations.
Yes, contracts awarded by NASA may be delegated to DCMA (if it makes sense), see NASA FAR Supplement 1842.202. Remember, any surveillance delegated to DCMA may NOT also be delegated to a COR.
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