JOINT BASE SAN ANTONIO-FORT SAM HOUSTON, Texas (April 12, 2021) -- Performance audits of contracting officer representative documentation for high- and moderate-risk contracts and task orders are reinforcing process standardization and contract administration oversight throughout the Mission and Installation Contracting Command.
MICC officials from the contracting operations directorate deployed the audit in early February to review 336 contracts across its two contracting support brigades and two field directorate offices by June 9.
Approximately 120 of those audits have been accomplished using the Army Contracting Command Contractor Performance and Non-conformance Report tracking database. Audits provide oversight and surveillance of contracting officer representative, or COR, documentation related to contractor performance.
Karl Fischer, the quality assurance functional manager for the MICC at Joint Base San Antonio-Fort Sam Houston, Texas, said the requirement for performance audits is not anything new as they are required by acquisition instructions; however, the use of the Contract Performance Tracking Tool offers a deliberate approach in standardizing those audits for CORs.
“Our offices have been complying before these documents were created, but each office had different audit questions that skewed the data. Now we have a standardized process and database to store all the information,” he said. “The database can filter the data many ways, so you can filter for a particular unit, location, date, COR and contracting officer just to name a few. It’s a quality assurance specialist’s dream, and now we can provide data sets for most COR questions asked.”
Fischer explained that high-risk contracts are high dollar value, high complexity or very large geographically such as base operations and the Enhanced Army Global Logistics Enterprise Program while moderate-risk contracts and orders are those of moderate complexity. He added the average time to complete an audit varies depending on complexity and quality assurance specialist experience, but most take approximately 45 minutes to an hour.
“COR performance audits provide MICC leadership and contracting officers insight of the COR’s contract oversight and surveillance documentation. This insight is in the form of data sets related to each COR’s surveillance and performance monitoring file in accordance with regulation and policy,” he said. “The reports generated show stakeholders how well the COR is maintaining their files and the level of performance.”
He said audit questions are go-no-go, and the Contract Performance Tracking Tool provides a detailed report showing both go and no-go items rolled up for all audits performed. Trends midway through the audit have identified a deficiency in the use of surveillance schedules and checklists.
“It will eliminate the guessing game of ‘is the COR performing at the required level’ and provide the COR supervisor and contracting officer with a detailed report complete with quality assurance specialist recommendations for improvement and evaluation input for the CORs rating,” Fischer said. “The goal is to identify no-goes that effect contractor oversight and surveillance, then provide the CORs assistance and help in improving their scores and focus our COR training on these identified no-goes, while providing all stakeholders reports showing improvement on predetermined cycles,” Fischer said.
Karen Edwards, the MICC COR Program manager at JBSA-Fort Sam Houston, said contracting officers designate a COR for all service contracts, including construction, unless the contracting officer retains and executes the contract oversight. Upon designation in writing, CORs perform specific technical or administrative contract functions. CORs are responsible for appropriately addressing nonconforming supplies and services, and documenting all government-discovered nonconformance. She added that this documentation must be maintained to support objective contractor performance ratings and used when analyzing data for performance trends.
About the MICC
Headquartered at Joint Base San Antonio-Fort Sam Houston, Texas, the Mission and Installation Contracting Command consists of about 1,500 military and civilian members who are responsible for contracting goods and services in support of Soldiers as well as readying trained contracting units for the operating force and contingency environment when called upon. As part of its mission, MICC contracts are vital in feeding more than 200,000 Soldiers every day, providing many daily base operations support services at installations, facilitate training in the preparation of more than 100,000 conventional force members annually, training more than 500,000 students each year, and maintaining more than 14.4 million acres of land and 170,000 structures.