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  • Question

    1. Is there a conflict of interest in appointing an individual as an ordering officer, if that individual is also performing functions as a budget technician for the contract in question? 2. I remember having read "somewhere" that it is generally not allowed that one of the following functions are being performed by the same individual: (1) payment (DFAS), (2) ordering, (3) acceptance, and (4) budget. Those four functions must be performed by separately. Is this a true assumption? What is the reference (FAR, DFARS, etc.) ? Thanks in advance, Karin Donner


    Answer

    The first problem that needs to solved is the incorrect assumption that a COR can delegate work to odering officers.  The COR CANNOT delegate their work to anyone else.  The Letter of Appointment or Delegation should say that very clearly.  Only the Contracting Officer can delegate contractor administration to another individual who is trained and certified in accordance with the March 29, 2010 Dr. Carter Policy Memo "DoD Standard for Certification of COR's for Service Acquisitions"

    Essentially the Government is set up with a balance of powers separating the warranted contracted officer from the Comptroller, but I am not aware of anything in the FAR/DFAR/PGI that addresses conflict of interest when assigning CORs or even assigning Contracting Officers. When the supervisor and Contracting Officer assign a COR, it must be with good judgement.  If the Contracting Officer believes that there is a conflict of interest, then don't do it.  But I wouldn't assume that a budget technician couldn't be a COR.  You need to look at the job itself and the power that individual has.  Are they in the position to cause harm to the Gov't?  If not, then I think you are OK.  

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