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Is It Time to Professionalize DOD’s CORs?

Denise A. Tatum and E. Cory Yoder • Jan 2019

CM0119_Yoder

In fiscal year 2015, the Department of Defense (DOD) applied 33% — over $90 billion — of its $273.6 billion in contract obligations to cost-reimbursement and time and materials/labor hour type contracts.[1]

These contract types require surveillance by a contracting officer’s representative (COR) and/or a contract administration office, such as the Defense Contract Management Agency (DCMA).[2] However, ensuring adequate contract surveillance is challenging due to several factors, including—

  • DOD budget constraints and reductions in personnel levels across the department,
  • Insufficient COR training,[3] and
  • Low DCMA staffing levels[4] that have left defense agencies with minimal assistance with day-to-day contract surveillance duties.

These resource constraints and training gaps leave contracts potentially under‐managed and at risk for waste, fraud, and abuse.

One solution to this problem is to make improvements to COR competencies, training, and certification requirements—and to develop more full‐time CORs versus relying on part‐time CORs to improve contract surveillance. These changes may improve overall contract outcomes in terms of ensuring a fair and reasonable price for the goods and services procured by DOD while minimizing the risk of contract waste, fraud, and abuse.

The Evolving Role of the COR

CORs play an important role in the acquisition process by performing surveillance duties upon contract award to ensure the contractor meets the cost, schedule, quality, and delivery requirements of the contract.[6]—as well as myriad other duties not specifically designated as “COR duties.” However, competency development guidance and training have not kept pace with the evolving role of the COR.

Yoder_Figure1

Weak COR Competency Requirements

The Federal Acquisition Institute (FAI) recognizes the increased role of the COR in its detailed COR competency structure.[7] The FAI supports non-DOD federal agencies and provides COR certification based on a competency model known as the “Federal Acquisition Certification for Contracting Officer’s Representatives” (FAC-COR).

FAC-COR certification revolves around 49 technical competencies and 5 professional competencies, and certification requires completion of a combination of FAI and Defense Acquisition University (DAU) courses.[9] which only identifies assisting with acquisition planning and assisting in the contract award process as expanded COR duties,[10] revolves around 19 competencies and training requirements and consists of:

  • One online or in-class DAU COR training course,
  • Contingency environment COR training (if required), and
  • Any agency specific training that may be required.

DAU does offer certification in 14 Defense Acquisition Workforce Improvement Act (DAWIA)[12] provides no specific requirements for COR training, DAWIA career field certification, or the use of CORs on a part- or full-time basis.

The DOD approach appears to assume that CORs are performing contract surveillance as an additional duty to their primary duties, and that their DAWIA career field would be associated with their primary field of work or education. For example, an engineer performing COR duties in addition to his or her engineering duties should maintain a DAWIA certification in the engineering career field; however, there are a growing number of full-time CORs with a variety of educational backgrounds working in positions that do not necessarily align with an appropriate DAWIA career field. This has led to a fragmented approach where full-time CORs performing contract oversight and other acquisition functions are assigned to DAWIA career fields that are only partially relevant to COR duties—and in some cases, CORs do not have any DAWIA career field designation at all.

Simply put, the lack of a formal acquisition career path and training for the expanding role of the DOD COR leaves the potential for a large volume of contracts managed by inexperienced, unprepared personnel.

Is There a Benefit to Developing Full-Time Career CORs Versus Assigning Contract Oversight Duties to Part-Time CORs?

To answer this question, extensive research was conducted.[13] The areas examined included the following:

  • Potential areas of COR capability gaps;
  • COR guidance alignment or misalignment with actual COR duties;
  • COR training, including new mandates for service contracting quality assurance surveillance plan (QASP) development and management;
  • Career development and progression; and
  • Examination and analysis of interviews conducted with executive acquisition leadership and CORs within DOD.

Surprisingly, the research shows that workload from part-time CORs actually took significantly more time and effort than the part-time ad-hoc appointments indicate. Of those interviewed, actual time spent in oversight and surveillance functions were significant, as indicated in FIGURE 1

COR Functional Mandates Require More Professionalized Skill Sets   

More Robust Training

Recently, U.S. Army CORs identified the online COR training as insufficient preparation for realistic execution of COR duties.[14] As such, CORs are taking their own initiative to find the right training and are relying on resources other than the introductory online CLC 222 COR training and agency provided in-class training once assigned to a contract. This indicates a need for improving the robustness of the existing training.

Key areas identified for improvement include invoice review and approval, as well as QASP development and utilization. 

Critical Issues and Weaknesses

Research[15] has also identified several critical issues and weaknesses. Of note are the following.

  • COR Guidance Is Not Aligned with Actual COR Duties

    All CORs interviewed reported being overloaded with contract surveillance duties. Further, some part-time CORs indicated that their COR duties were taking time away from their primary duties. It is unclear whether this is an organizational COR assignment problem or acquisition workforce training problem. In either case, the heavy workload may be preventing individual CORs from performing adequate contract oversight, which may be exacerbated by insufficient training.

  • Insufficient COR Training

    Introductory training for becoming a COR is not sufficient to ensure proper contract oversight and does not cover all the tasks a COR may perform. Two COR contract surveillance duties that were reported by the interviewed CORs to be particularly difficult to learn include:

    Currently, no formal training exists for either.

    CORs also reported seeking out continuous learning opportunities—despite not being mandated by any COR guidance—to improve their skill sets. This indicates that a formal COR continuous learning requirement would be beneficial for COR competency improvement and expansion.

    CORs also expressed a need for a COR community of practice that would provide a means to share ideas, methods, and experiences, which would improve contract surveillance and contract outcomes across organizations.

     

  • Inadequate COR Career Development and Continuous Learning
  • Invoice review, and
  • QASP development and use.

There is no established, organized, and consistent continuous learning training for CORs at the agency level and no established COR career field or career path at the DOD level. Generally, both part-time and full-time CORs are well-educated with a majority reporting holding a bachelor’s degree and some reporting a master’s degree or other professional certifications and 10 CORs reported currently belonging to a DAWIA career field. In most cases, the assigned career fields were not necessarily related to the COR’s educational background, and part-time CORs assigned with specific technical contract oversight duties were not necessarily assigned to DAWIA career fields pertaining to that area of technical expertise.

This DAWIA career field inconsistency indicates the particular career field is not critical to COR success. However, none of the DAWIA career field certifications provide the specific training required to perform COR surveillance duties, suggesting that there is a benefit to establishing a COR career field or career path.

Is There a Benefit to Developing Full-Time Career CORs Versus Assigning Contract Oversight Duties to Part-Time CORs?

Ideally, organizations should develop both full-time and part-time CORs to ensure a mix of well-developed technical and acquisition-specific skills that can be applied to the variety of contracting scenarios the organization encounters. The question of whether to develop full-time CORs or rely on part-time CORs depends on the complexity and dollar value of the contracting effort. Although there are likely exceptions, in cases where a COR is required to possess specific technical skills or certifications to perform contract surveillance and when contracts will be of short duration, it makes sense to select an expert from a technical domain who will perform COR duties on a part-time basis. In cases where COR oversight is required for long-term, recurring efforts, such as maintenance and support services contracts, a full-time COR provides consistency and allows the COR to develop a more comprehensive acquisition skill set. Additionally, the full-time COR has a historical knowledge of the contracting effort that can contribute to improvements in future contracting efforts from lessons learned.

What Professional Competencies Are Really Necessary for CORs?

The COR competencies defined in DODI 5000.72 do not accurately or thoroughly represent the work CORs are performing within DOD. Whether full-time or part-time, all CORs interviewed during this research were performing additional duties similar to those that might be performed by a COR according to DOD and agency level COR guidance, although few CORs received any training in these areas. In addition, current COR guidance does not specify or mandate what training would be beneficial for CORs performing these additional duties, nor does the guidance outline a requirement for continuous COR learning.

As a first step in improving COR training and, ultimately, COR performance, DOD should adopt a more comprehensive COR competency structure, such as the FAI FAC-COR competency structure, which incorporates specific technical and professional competencies related to acquisition with performance outcomes aligned to the performance level of the COR.

The FAC-COR competency model focuses on a broader spectrum of acquisition duties performed by CORs than the DODI 5000.72 model. The FAC-COR competency model identifies 12 units of competence, which include, but not limited to:

  • Acquisition planning;
  • Market research;
  • Defining government requirements;
  • Effective pre-award communication;
  • Proposal evaluation;
  • Contract negotiation;
  • Contract administration management;
  • Effective inspection and acceptance;
  • Contract quality assurance and evaluation;
  • Contract closeout, contract reporting; and
  • Business acumen and communication skill sets.[16]

Regardless of COR performance level, contract complexity, and contract dollar value, all CORs should develop competency in these areas to ensure they are able to perform effective contract oversight.

Are the Existing COR Training and Competency Requirements Sufficient to Ensure Acceptable COR Performance and Effective Contract Oversight?

Literature review and interviews conducted during this research show that existing DOD COR training and competency requirements are not sufficient to ensure acceptable COR performance and effective contract oversight. The COR competencies identified in DODI 5000.72 focus on soft skills—such as attention to detail, flexibility, and self-management and initiative—and some general technical competencies—such as business ethics, effective communication, and effective contract performance management.[17] DODI 5000.72 does include a long list of examples of COR responsibilities; however, it does not group them into a logical and complete competency structure, nor does it recommend the training required to master all of those responsibilities.

In addition, the existing initial COR training of 12 to 60 hours of instruction followed by annual ethics and combatting trafficking in persons (CTIP) training and a COR refresher course every three years is insufficient and leaves CORs unprepared to perform effective contract surveillance. The training recommended by DODI 5000.72 does not cover all of the most basic COR duties—e.g., invoice review and QASP development and use—and does not provide a foundational understanding of DOD acquisition and the FAR. Additionally, there is no continuous learning requirement beyond the previously mentioned annual ethics and CTIP training and triennial COR refresher training.

Continuous Learning

Training Applicable to Defined Competencies

First, DOD and DAU should identify a comprehensive list of training courses that apply to its defined competencies within each COR performance level. DAU provides many continuous learning modules that would be beneficial for COR competency development. For example, CLC 051, “Managing Government Property in the Possession of Contractors,” would be helpful to CORs performing asset management duties. In addition, there are training opportunities outside of DAU, such as the automated and instructor-led training available through the Contractor Performance Assessment Reporting System (CPARS) website that not only provides general information on how to use the data collection system, but also includes a specific module on writing effective performance assessments.[18]

Continuous Learning Addressing Training Gaps

Second, DOD and DAU should develop training for topics that currently have no associated training course. For example, no training exists through DAU for invoice review. Although invoices may vary between contractors, there are elements that are common to all contractor invoices that CORs should understand, such as the separation of labor and materials, overhead, general and administrative expenses, other direct charges, fringe benefits, cost pools, and fees.

Another example is Contract Data Requirements List (CDRL) creation or CDRL deliverable review. Although it would be difficult to capture the technically specific attributes of CDRL review for every acquisition scenario, there are some key CDRL requirements that could be included in a training module for CORs developing CDRLs and reviewing the resulting deliverables, including CDRL form completion, the appropriate use of data item descriptions in CDRLs, CDRL delivery dates for review and approval, corrections to deliverables, who should receive CDRLs, and the associated contractual cost of data that should be considered when determining what data is needed.

A training course covering general security topics would also be beneficial for CORs. CORs’ use of systems—e.g., the tactical automated security system (TASS) for security clearance processing—requires user training that is provided at the agency level; however, there is no existing training focused on contractor employee security issues in general.

CORs would also benefit from formalized training in preparing and using a QASP—particularly in the area of developing meaningful performance measures.

Make the Continuous Learning a Requirement

Third, DOD should establish a continuous learning requirement for CORs and provide suggested continuous learning training courses for CORs.

Are There Gaps in COR Training that Could Be Filled by DAWIA Career Fields?

Yes—and such training gaps could be filled by DAWIA career fields that would ensure CORs receive comprehensive acquisition training. (However, assignment to a DAWIA career field does not necessarily ensure CORs receive training related to the performance of contract surveillance duties.)

In the absence of a specific COR career path, CORs would benefit from placement in the “Program Management” or “Contracting” DAWIA career fields. Placing full-time CORs in the “Program Management” career field would ensure CORs receive training associated with integrated product teams (IPTs), financial/status reporting, logistics, acquisition planning, pre-award contract planning and tasking, contract tracking, risk management, systems engineering activities, and configuration control[19]—all of which are skill sets required to perform, or closely related to the performance of, COR duties.

Alternately, placing full-time CORs in the “Contracting” career field would ensure CORs get training related to the FAR, contract planning/execution/management, cost and price analysis, working with small businesses, source selection, analyzing contract costs, managing government property, and understanding acquisition law[20]—all of which are beneficial to CORs who perform in the role of acquisition developer in addition to performing contract surveillance.

What DAWIA Career Field Would Be Appropriate for CORs?

CORs are not necessarily placed in DAWIA career fields related to the duties they perform or their educational background, and DAWIA career field designation varies from COR to COR. Ideally, full-time CORs would be assigned to a COR-specific DAWIA career path similar the small business administrator’s career path currently under development by DAU. A properly structured career path would provide CORs with consistent training for:

  • The right competencies required to perform contract surveillance,
  • An adequate understanding of DOD acquisition, and
  • A working knowledge of the FAR.

This would ensure CORs are prepared to perform contract surveillance and all the other acquisition tasks that are becoming commonly associated with COR duties.

Alternatively, existing DAWIA career fields could suffice for CORs. For example, if the COR is a technical expert or part-time COR, his or her DAWIA career field should be related to that area of expertise. For a full-time COR performing contract surveillance duties, and assuming a DAWIA COR career path does not exist, the “Program Management” or “Contracting” career fields may be appropriate, depending on the complexity and dollar value of the contracts managed by the COR.

Clear Requirement for COR Professionalization is Needed! 

The authors recommend clear and unequivocal mandates for creating a career track with requisite training and certification for those CORs that are assigned complex, high-value, and high-risk contracts. Where this initiative should originate may lie in congressional authorization and appropriation and/or within the language of a National Defense Authorization Act. It’s long overdue. CM

Denise Tatum

  • Contracting Officer’s Representative (COR), NAVSEA, Naval Undersea Warfare Center (NUWC) Division, Keyport
  • Has experience in acquisition project development and management, writing performance-based and material requirements, and providing COR oversight for DOD service, material, and research and development contracts

E. Cory Yoder

  • Senior lecturer, Naval Postgraduate School
  • Specialties include contingency and expeditionary contracting, cost and price analysis and negotiations, and advanced business protocols for DOD contracting

The views presented in this article are those of the authors and do not represent the views of the organizations with which they are affiliated.

Endnotes

[1] W.T. Woods, U.S. Government Accountability Office (GAO), GAO-17-244SP, “Contracting Data Analysis: Assessment of Government-wide Trends” (Washington, DC: GAO, 2017), available at https://www.gao.gov/assets/690/683273.pdf.

[2] See, generally, Federal Acquisition Regulation (FAR) §§ 1.604, 1.602-2, 42.202, 42.302, 16.301-3(a)(4)(i), and 16.601.

[3] DOD Inspector General, “Top DOD Management Challenges Fiscal Year 2018” (2017), available at https://media.defense.gov/2017/Dec/01/2001850837/-1/-1/1/FY%202018%20MANAGEMENT%20CHALLENGES_508.PDF.

[4] See J. Hutton, GAO, “Defense Contract Management Agency: Amid ongoing efforts to rebuild capacity, several factors present challenges in meeting its missions” (Washington, DC: GAO, 2012), available at https://www.gao.gov/assets/590/586078.pdf.

[5] Acquisition Encyclopedia: “contracting officer’s representative,” available at https://www.dau.mil/acquipedia/Pages/ArticleDetails.aspx?aid=b019cf97-6963-4c6b-aa91-76592ffd3067.

[6] FAC-COR competency model, available at https://www.fai.gov/drupal/sites/default/files/2013-1-23-COR-Competency-Model.pdf.

[7] Ibid.

[8] FAC-COR certification, available at https://www.fai.gov/drupal/certification/fac-cor.

[9] DOD Instruction (DODI) 5000.72, “DOD Standard for Contracting Officer’s Representative (COR) Certification” (Washington, DC: DOD, 2015), available at http://iac.dtic.mil/support_docs/acor_memo_500072p.pdf.

[10] Ibid.

[11] 10 USC Chapter 87.

[12] DODI 5000.72, see note 9.

[13] Denise A. Tatum, “Contracting Officer’s Representative (COR): An Analysis of Part-Time and Full-Time COR Roles, Competency Requirements, And Effectiveness” (Monterey, CA: Naval Postgraduate School, Master’s Joint Applied Project (Thesis): 2018).

[14] T.V. Peel and A.R. Acevedo, “An Analysis of Army Contract Administration With Regard to Contracting Officer’s Representatives” (Joint Applied Project: 2016), available at https://calhoun.nps.edu/bitstream/handle/10945/50466.

[15] Tatum, see note 13.

[16] FAC-COR competency model, see note 6.

[17] DODI 5000.72, see note 9.

[18] See CPARS Training, available at https://www.cpars.gov/webtrain.htm.

[19] See, generally, Defense Acquisition University iCatalog, available at http://icatalog.dau.mil/onlinecatalog/courses.aspx?crs_id=1731.

[20] See ibid.