Contractors cannot perform tasks on service contracts that are considered inherently governmental functions IAW FAR subpart 7.5, DFARS subpart 207.5 and agency supplements to the DFARS. FAR 7.503(e) says that a written determination is required to determine if the tasks on the service contract are inherently governmental. Additionally, DoD policy mandates the written determination be prepared using DoD Instruction 1100.22, Guidance for Determining Workforce Mix. Ultimately, the written determination would require an interpretation of all of the regulatory information.

So to answer your question, we would have to review that written determination for that service contract. This is an interesting question though, as the Army Form 4856 refers to the counselor as a "leader".