COR Regulatory Compliance & Documentation 3 — Questions and Answers
Question 1: A contractor submits an invoice for work that the COR believes was not fully completed. What is the correct COR action?
- Reject the invoice directly in the payment system
- Approve partial payment without notifying the CO
- Document the discrepancy and notify the CO before invoice certification (Correct answer)
- Tell the contractor to resubmit after completing the work
Correct answer: Document the discrepancy and notify the CO before invoice certification
The COR should document the discrepancy and bring it to the CO's attention; the COR recommends but does not unilaterally reject invoices without proper authority.
Question 2: What does 'constructive change' mean in government contracting?
- A beneficial modification formally approved by the CO
- An informal government action that effectively changes contract requirements and may entitle the contractor to additional compensation (Correct answer)
- A contractor-initiated improvement to the deliverable
- A change order that reduces the contract price
Correct answer: An informal government action that effectively changes contract requirements and may entitle the contractor to additional compensation
A constructive change occurs when government actions or omissions effectively alter contract requirements without a formal modification, potentially creating contractor entitlement to additional costs.
Question 3: Under FAR 52.232-25, the Prompt Payment Act requires that contractors be paid within how many days of a proper invoice?
- 14 days
- 21 days
- 30 days (Correct answer)
- 45 days
Correct answer: 30 days
The Prompt Payment Act generally requires payment within 30 days of receipt of a proper invoice or acceptance of goods/services, whichever is later.
Question 4: Which document formally delegates authority to a COR and defines the limits of that authority?
- The statement of work
- The COR appointment letter (or designation letter) from the Contracting Officer (Correct answer)
- The contractor's quality control plan
- The agency's acquisition plan
Correct answer: The COR appointment letter (or designation letter) from the Contracting Officer
The COR appointment/designation letter from the CO is the official document that delegates authority and specifies what the COR can and cannot do.
Question 5: When a contractor requests a meeting to discuss a potential claim, what should the COR do?
- Negotiate directly with the contractor to resolve the claim
- Attend and participate but ensure the CO is informed and involved in any substantive discussions (Correct answer)
- Decline to meet until the claim is submitted in writing
- Approve or deny the claim based on COR judgment
Correct answer: Attend and participate but ensure the CO is informed and involved in any substantive discussions
The COR may attend technical meetings but must keep the CO informed; only the CO has authority to settle or deny contract claims.
Question 6: What is the significance of the 'Period of Performance' in a contract, and why must the COR monitor it?
- It determines the contractor's billing rate
- It establishes the timeframe within which work must be completed; work or payments outside this period may be unallowable (Correct answer)
- It specifies when the COR must submit CPARS evaluations only
- It sets the government's fiscal year for budget purposes
Correct answer: It establishes the timeframe within which work must be completed; work or payments outside this period may be unallowable
Work performed or costs incurred outside the period of performance are generally not allowable, making it essential for the COR to track completion dates.
Question 7: Which of the following best describes a 'quality assurance surveillance plan' (QASP)?
- A contractor-prepared document outlining internal quality control procedures
- A government document defining how the COR will monitor and evaluate contractor performance against contract requirements (Correct answer)
- A plan required only for construction contracts exceeding $1 million
- A GAO audit tool for reviewing past contract awards
Correct answer: A government document defining how the COR will monitor and evaluate contractor performance against contract requirements
A QASP is a government-developed surveillance plan that guides the COR in monitoring contractor performance and documenting whether standards are being met.
A contractor submits an invoice for work that the COR believes was not fully completed.
What is the correct COR action?