Based on what seems to be a conflict, Background, what is a CORs GFP responsiblities?
Thanks for identifying this issue. The 2008 AAP answer says "If a PA and PLCO are not appointed, the Administrative Contracting Officer (ACO) is responsible for performing these functions (see FAR 42.302(a)(26) V (30)
). If the Procuring Contracting Officer is also administering the contract (ACO functions) and a PA and PLCO are not appointed, then the PCO is responsible for performing these functions. Since neither the ACO nor the PCO typically have specific training in these functions, this is not an optimal situation. These functions may not be passed to an individual who has been appointed as Contracting Officer Representative (COR) or Contracting Officer Technical Representative (COTR)."
These are the facts as I see them, so you can decide:
1, The FAR reference FAR 42.302
does not say the these functions may not be passed down to a COR. It might have said it in 2008, but those words are not currently in the FAR
2. The 29 March 2010 policy letter, Signed by Dr. Carter, "DOD Standard for Certification of Contracting Officer's Representatives (COR) for Service Acquisitions, identifies 14 compentencies that CORs muist have. Competency # 13 is "Monitor control/disposition of Government Furnished Assets"
3. I checked with our Government Property Expert at DAU. She says, "COR can be assigned, but must be qualified." You can contact her at Dale.Lippman@dau.mil if you wish to discuss further.
The truth is that we all wish we had trained Property Administrators to monitor all Gov't property. But sometimes this is not possible and the job is delegated down to a COR. Its important that the COR is trained well enough to do this job. In most cases, we are talking about comparitively low dollar, less complex servic contract, where DCMA is not involved and no ACO or PA is assigned. The PCO just needs help. Assigning a COR to help, is better than no monitoring at all.