The business of government is complex, highly demanding, and the direction of many projects can change without so much as a moment’s notice – effective government contract management can help ensure projects stay on track. With several years combined experience as a contracting officer’s representative (COR), I’ve learned a lot along the way: facing an audit and living to tell the tale, working with agency attorneys during a heated award protest, and helping identify and resolve costly mistakes before it’s too late.
Here are some tips that should make your life a lot easier, especially if that catch-all “other duties as assigned” category applies to you and your role as a COR.
Good Recordkeeping is Paramount
It’s no secret that keeping good records comes with the COR territory, so to speak. Having complete, detailed records of all communications and transactions between the contractor, designated project manager and COR is not just a legal requirement for federal entities – these records can also potentially serve as your first line of defense should you be identified for an audit or formal investigation. Remember, emails are considered official records and should also be treated as such. File them away in a safe location before deleting them from your inbox.
Acquisition-Specific Data is Sensitive Information
From an ethical perspective, CORs are responsible for protecting the integrity of the information for which they often have privileged access to. It’s okay for your supervisor not to see all of the details of your transactions with a contractor – there’s some information that is simply “for your eyes only.” Take extra precautions by encrypting email messages and saving sensitive, financial data to a secure place. Many agencies use two-factor authentication systems to store contract-specific information. Check with your contracting office to see what’s available to you.
Actual vs. Perceived Authority: There is a Difference
Many front line managers and supervisors often inflate the perceived authority of a COR. It’s easy to assume that a COR might have carte blanche access to “make things happen” but there are legal limitations to what we can do. If you ever feel uneasy about a request from the project manager on your contract or supervisor, give your contracting officer (CO) a call and verify first before taking any action you might regret later. Your official COR designation letter should outline your roles, responsibilities and limitations as a COR.
Beware of Scope Creep
We’ve all heard this before, but scope creep is very real and can sometimes occur without being noticed. Scope creep happens when the COR or project manager tasks the contractor with work that is outside the original scope of the contract, statement of work (SOW), or performance work statement (PWS). It’s essentially asking them to do extra work they weren’t initially brought on to do. The good news is that you can get ahead of it. If you see or suspect scope creep, reach out to your CO for advice. If the extra work is deemed necessary, you can work with your contracting office to draft a modification (MOD). If your leadership team or project manager absolutely insists that the work be done “under the table,” you absolutely have the authority to work with your CO to issue a stop work order until these issues can be properly sorted out.
Developing a Project Tracker is a Must
In most cases, a simple spreadsheet will suffice. Be sure to include fields for a unique ID number for each task assigned to your contractor with a title, brief description, due date, delivery date and status. This will be helpful for you to stay organized and on track but also to report out progress during monthly and annual contract performance reviews.
Know Your SOW or PWS Inside and Out
As noted in the previous tip, scope changes can creep up on you at any time. Having a strong understanding of the SOW or PWS specifics will help you to quickly identify any issues and head off any potentiality of scope creep before it happens. Think of the SOW or PWS as your blinders in the race. They help keep your eyes from drifting off the course.
Always Review Invoices for Accuracy
Most contractors are well intentioned, but it’s important to catch simple things such as the submission of a duplicate invoice or incorrectly listed period of performance. With competing priorities, it’s tempting to just sign and submit an invoice to get it out of the way but that can land you in hot water. For example, I once received an invoice from my contracting team for work completed on a contract that was not mine to manage. Had I signed that invoice, I would have authorized payment to a vendor for work I didn’t have the legal authority to oversee.
Don’t Let Your Contract Go On Cruise Control
One of the primary duties of a COR is to be the CO’s eyes on the contract at all times. It’s your responsibility to ensure proper surveillance and monitoring tools are in place throughout the contract lifecycle. While requirements may differ by department or agency, I would recommend keeping a monthly report of the contractor’s performance and quality of completed work products/services. As a COR, you may not be the subject matter expert (SME), but you should be copied on all requests for new tasks to ensure they’re in scope. “If you see something, say something” applies here too.
Plan Ahead If Exercising Option Year(s)
If you’re managing a multi-year contract and have been given the green light to move forward with exercising an option period of your contract, start planning early – as in at least 6 months before the current period of performance ends. This often includes checking to see if funding is available, or in some cases, petitioning for funding. It also generally involves a multilayered approvals process and completion of paperwork by the COR and CO. I cannot stress enough to plan ahead here. If your period of performance expires before your option period is formally exercised, that means a complete stop in services and halt to any projects you might have in the hopper.
Always Be Prepared for an Audit
Remember, you can be audited at any time and your records as a COR may be requested for review. As long as you’ve faithfully and ethically executed your duties, kept detailed, accurate records of all communications, invoices, and work completed – you have nothing to worry about. These aren’t as painful as you might think. Just be calm and contract on!
Blake Scates is part of the GovLoop Featured Contributor program, where we feature articles by government voices from all across the country (and world!). To see more Featured Contributor posts, click here.