Overview
FAR Subpart 42.4 establishes the protocols for communication and physical site visits between the government and contractors. It focuses on maintaining a unified government front by ensuring that all interactions are coordinated through the cognizant Contract Administration Office (CAO) to prevent administrative redundancy and conflicting instructions.
Key Rules
- Routing of Correspondence: All correspondence related to contract administration must normally be forwarded to the contractor through the CAO.
- Urgency Exception: If correspondence must be sent directly to a contractor due to urgency, a copy must be provided to the CAO at the same time.
- Mandatory Notification for Visits: Government personnel must notify the CAO "sufficiently in advance" before visiting a contractor’s facility to allow for proper coordination.
- Anti-Duplication Measure: Visitors must identify the information they seek before a visit. If that information is already available within the government or was recently reviewed, the CAO will discourage the visit to prevent "audit fatigue" and duplicative effort.
- Reporting Requirements: Following a visit, personnel must inform the CAO of any agreements reached or results that might impact contract administration.
- Internal Evaluations: Onsite evaluations of a CAO's performance can only be conducted by the specific agency to which that CAO belongs.
Responsibilities
- Contracting Officer (CO) / Purchasing Office: Responsible for keeping the CAO in the loop on all contractor communications and providing copies of all direct correspondence.
- Contract Administration Office (CAO):
- Acts as the primary liaison between the government and the contractor.
- Maintains the official contract administration file.
- Has the final authority to decide if a CAO representative will accompany visitors to the facility.
- Verifies if requested data is already available before authorizing administrative visits.
- Government Visitors (Program Managers, Auditors, etc.):
- Required to provide the CAO with visitor names, security clearances, and the specific purpose of the visit.
- Must debrief the CAO on any outcomes or agreements made during the visit.
- Cognizant Audit Office: Consults with the CAO to determine if previous audits satisfy the visitor's information needs.
Practical Implications
- The "One Voice" Policy: This subpart prevents contractors from receiving conflicting directions from different government entities (e.g., a Program Manager saying one thing and a Contracting Officer saying another). By funneling communications through the CAO, the government maintains a consistent legal and administrative stance.
- Efficiency for Contractors: Contractors are protected from "death by a thousand cuts" regarding oversight. The rule against duplicative reviews means a contractor shouldn't have to provide the same financial or technical data to three different agencies in the same month.
- Site Visit Gatekeeping: For contractors, the CAO acts as a gatekeeper. If a government official shows up unannounced or without CAO coordination, the contractor has a basis (via FAR 42.402) to request that proper protocols be followed.
- Documentation Trail: For the CAO, receiving copies of all correspondence is critical for the "Contract File," which serves as the official record in the event of disputes, claims, or terminations.