Joel, the specific contract is in the 4th iteration of a sole source USACE SATOC (4 different contracts over 7 years). Over the years the CO's (there have been at least 3 different ones) have failed to include the specific insurance requirements, even at my request to provide them. That said, the Task Order Contracting Specialists (of course) require that I provide a COI, which of course includes standard Auto Liability coverage. My requirement to the Sub is based on the other USACE contracts we hold which do require "Auto Liability Insurance. This insurance shall be required on the comprehensive form of policy and shall provide bodily injury liability and property damage liability covering the operations of all automobiles used in connections with the performance of the subcontract......" . I know that ultimately the failure of the Gov to provide me with the specific requirements (on the contract in question), is no excuse for not flowing down contract requirements.
Other than the fact that I can't evidence the specific contract requirements to the Sub, it sounds like my interpretation of the Regs, in general, is accurate.