Good morning thanks for the great question.
Since this is a relatively complicated scenario, I want to start with what the FAR and DFARS say about the issue, but it is also important to caveat that your organization or agency may have additional requirements which I do not cover here. FAR 1.602-2(d) says that the contracting officer must designate and authorize a COR on "all contracts AND (emphasis added) orders other than those that are firm-fixed price, and for firm-fixed price contracts AND (emphasis added) orders as appropriate, unless the contracting officer retains and executes the COR duties." Additionally DFARS PGI 201.602-2(d)(v)(A) states that contracting officers should appoint CORS for all service contracts whether they are firm fixed price contracts or not, but also mention that contracting officers can exempt service contracts from requiring a COR if they meet the following requirements, “(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.” There are other instructions at the DoD level that give some further guidance, but none that specifically say whether or not every order needs a COR or if having one appointment letter is sufficient, with the exception of orders that take place at different locations.
To tie all this information together, Contracting Officers are responsible for ensuring that adequate contract administration oversight is provided for the contracts and associated task orders for which they are responsible. The structure of the coverage, number and geographic location, duties and responsibilities of the CORs are up to the responsible Contracting Officer. COR responsibilities and duties vary based on the work being provided and the terms and conditions of the contract and any related task orders. The Contracting Officer specifies the duties and responsibilities delegated to the COR in the appointment letter of authority and the COR acknowledges these duties and responsibilities in writing. Additionally, the authorities delegated by the Contracting officer may not be further delegated or passed on by the COR. If you do think that one COR can adequately monitor all of the orders on the contract and the orders meet the two requirements previously listed, you could mention that in the COR appointment letter and also document why doing individual COR appointments is not necessary. When it comes to the regs, as often is the case, there’s no one “right” answer, but hopefully the references provided here will help you determine the course of action to choose and the necessary documentation that may be required.
Required fields marked with *
Please note that you should expect to receive a response from our team, regarding your inquiry, within 2 business days.