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I'd be interested to know how Operational DoD offices have been handling the surveillance requirements for construction contracts. Under FAR 46.4, - Quality assurance surveillance plans should be prepared in conjunction with the preparation of the statement of work. Under DFARS 246-401 - For contracts for services, the contracting officer should prepare a quality assurance surveillance plan to facilitate assessment of contractor performance, see 237.172. ... (this seems to imply FAR 37 Service contracting - does FAR 37 Service contracting include construction? Under Subpart 37.3 - it discusses Demolition and Construction Wage Rates - it seems the argument on whether Construction contracting can be considered a Service is becoming more obscure, instead of clear). DoDi 5000.72 - Table 2 (Minimum requirements for Types A, B, and C training are described in Tables 2, 3, and 4, respectively.) infers that a Surveillance Plan is required. Perform technical and administrative contract surveillance and reporting responsibilities in accordance with the letter of designation and surveillance plan. However in DoDi 5000.72 - Table 1 it suggests a QASP only under performance-based services (not mentioning a QASP anywhere else in the DoDi). 24. For a performance-based services contract, order, or agreement, perform on-site surveillance in accordance with the QASP Otherwise, the DoDi is silent on surveillance. Does this mean the agency should determine their own surveillance requirements for construction? There doesn't seem to be anything written that says we shouldn't build a QASP in conjunction with construction Statement of Works. But for those that do construction contracting, it seems redundant to do so. In fact, the entire COR designation requirement for construction seems redundant since the majority of Program Managers already perform inspection (blue books, daily inspection logs, etc IAW with their own internal Civil Engineering procedures... which are ultimately handed over to contracting as part of the close-out file). How do your office handle surveillance?
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Can an agency contract out the COR/COTR job? Or is that considered inherently governmental?
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I am at a base level operational contracting office. A new DoDi came out 26 Mar 15 - number 500.72 - titled DoD Standard for Contracting Officer's Representative Certification. Apparently this new instruction mandates COR's for construction contracts and the inclusion of these COR's in the CORT tool. Am I missing something, but haven't COR's always been required for construction contracts? The reason I am curious is anyone else trying to come up with a plan to comply with this requirement? Does anyone else within DoD use CORT tool for their construction CORs ? This office has had 'inspectors' but never full fledged CORs.....just posting for a little discussion.