COR for Service Contract

[WinterMute]

Issue: Is a COR required for a service contract if it is a full delegation to DCMA?

Background: A new service contract (FFP w/ O&A) was awarded and delegated to DCMA and the procurement office wants to appoint a COR IAW PGI 201.602-2 to be onsite at the contractor's facility with DCMA. The contract does not meet the requirements for exemption. However, since the contract is a full delegation to DCMA and FAR 1.602-2(a)(4) preventing duplication of duties, the COR's authority is extremely limited.

[napolik]

PGI 201.602-2 Responsibilities

(v) A COR assists in the technical monitoring or administration of a contract.

(A) Contracting officers shall designate a COR for all service contracts, including both firm-fixed-price and other than firm-fixed-price contracts, awarded by a DoD component or by any other Federal agency on behalf of DoD. The surveillance activities performed by CORs should be tailored to the dollar value/complexity of the specific contract for which they are designated. For geographically dispersed large contracts with multiple task orders, contracting officers should consider appointing multiple or alternate CORs to assist with surveillance duties. These CORs should have specific duties based on criteria, such as geographic region or distinct task areas, to avoid conflicting or duplicative direction. Contracting officers may exempt service contracts from this requirement when the following three conditions are met:

(1) The contract will be awarded using simplified acquisition procedures;

(2) The requirement is not complex; and

(3) The contracting officer documents the file, in writing, with the specific reasons why the appointment of a COR is unnecessary.

If the PCO needs the assistance of a COR, why would not the ACO?