CANCELLED BY PIC 09-05
06-05
Procurement Information Circular
March
7, 2006
CONTRACTOR SURVEILLANCE
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.
BACKGROUND: The 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@nasa.gov.
Lou
Becker
Acting
Director, Contract Management Division