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Good afternoon Wifcon,

Customer is requesting we delegated COR authority to another agency's personnel due to staffing shortages within our own agency.

My concern is this individual is not learned in our agency's regulations/instructions/supplements and that delegating them CO authority may be worse than not having a COR at all.  Also, do we owe this organization funding to cover the time spent performing COR duties on our behalf, or can they donate those to us?

I've considered an IAA, but others in my office say I'm overthinking it, so I figured I'd consult the brain trust.

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What are your agency’s and higher level  (e.g., Army, DoD, Etc.) policy and procedures for qualifications and appointing COR’s?  Is the other agency co-located or near the customer? Is your office in the same organization as your customer? The scenario isn’t clear…

My other question is, if you haven’t planned for and can’t provide a COR or otherwise actively administer a contract, why are you awarding a contract?  FAR Part 42 may address resources available for contract administration duties. It discusses the requesting organization’s responsibility to fund CA functions provided by other organizations. 

Depending upon the circumstances, I think that not assigning a COR is inappropriate. 

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31 minutes ago, Krimz said:

Also, do we owe this organization funding to cover the time spent performing COR duties on our behalf, or can they donate those to us?

IAA is a must in my view.    The matter is "exercise of authority"     CO from the agency who was delegated by the agency head (or designee) who has authority to delegate their CO duties to a COR delegate must have the other agency authority to delegate the COR duties.    Your agency FAR supplement or policy may provide the opening.   I have seen it so and I have also seen it done by those that do not want to "overthink" but I sincerely question it.  

As I was writing another stated this....

7 minutes ago, joel hoffman said:

if you haven’t planned for and can’t provide a COR, why are you awarding a contract?

If you are in contracting then the question is a good one to direct to the understaffed "customer" based on what ever your agency policy is for the requirement for having a COR (when, what kind of contracts etc etc).  If they are understaff and want to supplement their staffing they need to consult with HR first in my view.   The IAA would be up to them, HR and your agreements group to forge.    Its kind of like a "color of money" thing in my view.   The other agency staff person needs to become your agency to avoid things like supplementing the agency's appropriation.   

Bottomline it is up to the CO but if I were in the CO's shoes I would only do it if the "customer" came to me with an IAA in hand.

 

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Ah,  so the customer is too short handed to provide a COR and wants to hire another agency to provide one, correct? If so, that is clearer. 

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3 hours ago, Krimz said:

Also, do we owe this organization funding to cover the time spent performing COR duties on our behalf, or can they donate those to us?

FAR  42.002 Interagency agreements.

 “(a) Agencies shall avoid duplicate audits, reviews, inspections, and examinations of contractors or subcontractors, by more than one agency, through the use of interagency agreements.

       (b) Subject to the fiscal regulations of the agencies and applicable interagency agreements, the requesting agency shall reimburse the servicing agency for rendered services in accordance with the Economy Act (  31 U.S.C.1535).”

 

Plus, see applicable supplements thereto. 

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