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  • Question

    Do all construction contracts require a COR? If the contracting officer is only going to require the inspectors to sigh on WAWF do we need to be a COR?


    Answer

    In this instance, the final determining guidance is at DFARS PGI 201.602-2(v)(A).

    The answer is “yes”, UNLESS:

    (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, with the specific reasons why the appointment of a COR is unnecessary.

    Both 1 and 2 have to be affirmed, not either or.

    However, if in your case the contracting officer has delegated contract administration functions including inspection and acceptance to a contract administration office (CAO, e.g. DCMA).  Then you cannot delegate any functions to a COR that have been delegated to the CAO [see FAR 1.602-2(d)(4)].

    If inspection, or inspection and acceptance have not been delegated to a CAO and all the inspector is doing is “sign on WAWF” in PIEE… it begs the question: “Who is doing inspection for the government?”

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