Procurement Information Circular

March 7, 2006


PURPOSE:  To provide guidance to contracting officers and contracting officer’s technical representatives regarding contractor monitoring and surveillance in a consistent and coordinated manner across the Agency for multiple contracts supporting the same program or projects. 

BACKGROUNDThe Office of Inspector General recently conducted an audit of NASA’s oversight of its Integrated Enterprise Management Program (IEMP) contracts as part of an overall assessment of the IEMP.  The results of the audit revealed that in some cases surveillance plans were not properly developed and that contractor oversight was not always conducted appropriately.  The results further revealed that the appropriate contracting officer technical representative (COTR) delegations were not issued or that COTRs and technical monitors did not adequately document key oversight activities.

FAR Part 46.401 stipulates that contract quality assurance be performed as necessary to determine that supplies or services conform to contract requirements.  NASA FAR Supplement (NFS) 1846.000 states that “surveillance must be conducted whether or not the contract effort has been structured as performance-based.”

GUIDANCE:  Contracting officers shall ensure that the appropriate level of contract surveillance is conducted on all contracts and that the appointed contracting officer technical representative (COTR) possesses the training, qualification and experience necessary to perform the delegated duties and responsibilities.  Prior to appointment, the contracting officer shall verify that the mandatory training and/or refresher course was completed in accordance with NFS 1842.270(f).


Contracting officers shall work with program and project managers to ensure that oversight practices are consistent for all contracts related to the specific programs and projects.  Further, contracting officers shall work with program and project managers to the maximum extent practicable to ensure that surveillance plans are adequately developed, prepared and updated as appropriate.


Oversight practices such as surveillance approaches, plans and contract monitoring methods should be coordinated among Centers administering contracts for the same program or project.  Consistent and coordinated oversight practices across contracts for the same program or project increases the potential for creating and capturing standard performance measures for contractors on a program/project wide basis.


Contracting officer technical representatives shall document and maintain information necessary to support contract oversight activities as appropriate.  Adequate documentation of oversight activities assists both the COTR and contracting officer in measuring contractor performance.

EFFECTIVE DATE:  This PIC is effective as dated and shall remain in effect until cancelled or superseded.

HEADQUARTERS CONTACT:  Lou Becker, Contract Management Division, (202) 358-4593, email:


Lou Becker

Acting Director, Contract Management Division