If contract administration of aircraft maintenance (services) contracts is delegated to DCMA pursuant to FAR 42.202, what COR duties would be required without overlapping with the duties that DCMA is responsible to perform?
Is it acceptable to think in this scenario that the COR duties would only include inspection/acceptance, base access badging, CPARS input, and being the technical liaison btwn Contractor & Government?
Is it necessary for this to be an actual trained COR, or is it acceptabe for this role to be a TPOC instead? Our intent is to reduce the complexity of communication and direction to the Contractor.
Correct, DFARS PGI 201.602-2(i)(A) does not contain an exception for designating a COR due to the contract being delegated to DCMA for contract administration and surveillance. And DFARS 201.602-2(2)(iii) states that a COR “May not be delegated responsibility to perform functions at a contractor's location that have been delegated under FAR 42.202(a) to a contract administration office;” See also FAR 1.604(b). In addition, DFARS 201.602-2(2)(v)(B) requires the limitations of the CORs authority be designated in writing.
Depending on the terms and conditions of your specific contract, you could limit the duties of the COR to any functions not being delegated to DCMA or surveillance activities not being done at the contractor’s location.
FAR 1.602-2(d) discusses options for who could act as the COR. Due to the items being delegated to DCMA, the contracting officer has the responsibility to determine what type (A, B, or C) the contract should be considered and thus the training requirements needed of a designated COR.
Please note that a new DoD Instruction for CORs is currently being coordinated for publication. We anticipate that this will address some of the scenarios.
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