**FAQs: Contracting Officer**

**Certificate of Appointment (COA) Program**

1.  ***What is the Contracting Officer Certificate of Appointment (COA)
    Program?***

> The Contracting Officer Certificate of Appointment (COA) Program
> replaces DOI's former warrant system, popularly known as the COWS
> Manual. It was originally issued as DIAPR 1997-4, and revised by DIAPR
> 2006-1. The new COA Program Manual (dated October 2, 2006) replaced
> both.

2.  ***Why was the warrant system changed to the COA Program?***

> The new COA Program was written to bring DOI in line with the OFPP
> [Policy Letter
> 05-01](http://www.whitehouse.gov/omb/procurement/policy_letters/05-01_041505.html)
> and OMB
> [Memorandum](http://www.whitehouse.gov/omb/procurement/acq_wk/fac_contracting_program.pdf),
> the Federal Acquisition Certification in Contracting Program, dated
> January 20, 2006.
>
> The intent of the FAC-C program is to ensure that all contracting
> professionals throughout the Government are properly trained and
> qualified to effectively conduct the acquisition business of the
> Government. A similar program has existed in the Department of Defense
> for over a decade and is now being implemented in the civilian
> agencies, as required by the Clinger-Cohen Act. Contracting staff must
> be FAC-C certified in order to be appointed as a Contracting Officer.
> The FAC-C program establishes the minimum education, training, and
> experience requirements for contracting professionals in civilian
> agencies.

***3. Do I need a FAC-C certification to get a Certificate of
Appointment (COA)?***

> Effective October 1, 2006, all *new* COA applicants must be FAC-C
> certified. New COAs are those issued by a Bureau to an employee for
> the first time, and any increases in COA authority.

***4. What will happen to existing warrants at DOI after October 1,
2006?***

> The warrant structure will change slightly based on the OFPP
> requirement for agencies to align their COA structure with the FAC-C
> Program. Current warrant holders will be issued a transition COA
> sometime between October 1, 2006, and December 31, 2006, based on the
> new three-level COA structure. If you do not achieve a FAC-C
> certification by the sunset date on your transition COA, it will
> expire.

***5. How do the new COA levels compare to the existing warrant
levels?***

> There are three COA levels as opposed to the four COWS warrant levels.
> The [COWS-COA comparison chart]{.underline} provides more detail.

***6. I currently am an 1102 and have a warrant, but do not have a
degree or 24 hours of business-related courses. Can I still be a
contracting officer?***

> COA is based on FAC-C certification, which in turn has a three-part
> qualification standard, one of which is education. There are two
> education exceptions for 1102s, sometimes called "grandfathering
> provisions":
>
> a\. If you were an 1102 at the GS 5 - 12 level on January 1, 2000, you
> are assumed to have met the education requirement of a bachelor's
> degree or 24 hours of business-related courses.
>
> b\. If you were an 1102 at the GS 13 or higher level on January 2,
> 2000, you are assumed to have met the education requirement of a
> bachelor's degree and 24 hours of business-related courses.

***7. Is there any grandfathering of the education requirement for
non-1102 warranted individuals?***

> Yes, if you are any other series and held a warrant on January 1, 2000
> and have continuously held that warrant since then with no break
> longer than 90 days, you are assumed to have met the education
> requirement of a bachelor's degree or 24 hours of business-related
> courses needed for Level I certification.

***8. If I only have a warrant for space leasing, do I need to meet the
FAC-C requirements?***

> No, space leasing COAs are exempt from FAC-C certification
> requirements.

***9. How do I apply for a transition COA?***

> Your Bureau Procurement Chief will implement procedures for your
> bureau's transition COAs.

***10. How do I qualify and apply for a permanent COA?***

-   You must be FAC-C certified at a level commensurate with the COA
    level being requested

-   Your office must demonstrate a need for contracting authority at
    your location (i.e., sufficient volume of procurement actions to
    support IDEAS/FBMS, validated by FPDS reporting, etc.)

-   Must apply to and be appointed by the Bureau Procurement Chief

***11. What about maintenance training under the new system?***

> Refer to the FAC-C Program Manual for training requirements for each
> level of
>
> FAC-C certification.

***12. What is ACMIS?***

> The Acquisition Career Management Information System (ACMIS) is the
> mandatory source to track acquisition workforce training, FAC-C
> certification, and COAs. Each executive agency is required to collect,
> maintain and use this information to ensure effective management of
> the acquisition workforce. Bureaus are required to have complete,
> current records in ACMIS for COs regardless of classification series.

***14. Is there any way to issue a COA after October 1, 2006 to an
employee if he or she is not FAC-C certified?***

> Yes. The Senior Procurement Executive (SPE) can waive the requirement
> for a person to have a certification on a case-by-case basis, if
> granting a waiver is in the best interest of the Department. Then the
> bureau can grant COA authority, if otherwise justified. The FAC-C
> waiver is not transferable to another agency or to subsequent COA
> increases.

***15. If I don't apply for the FAC-C, what will happen to my current
job?***

You can continue to perform contract specialist duties but without the
ability to sign and obligate actions as a CO. If you are a
procurement/policy analyst at Grade 13 or above, your duties will need
to be re-evaluated by your supervisor.

***16. I don't have a warrant/COA now, but I want to make sure I am
eligible in the future. What should I do?***

> All members of the 1102 series are encouraged to work toward FAC-C
> certification. Refer to the requirements in the FAC-C Program Manual
> and work with your supervisor to meet the education, training and
> experience requirements.