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MEMORANDUM

TO: John Quinlan 

FEC Chief Financial Officer

Pamela Jones

Procurement Director/Contracting Officer

THROUGH: Christopher Skinner 

Inspector General

FROM: Shellie Purnell-Brown

Senior Auditor 

SUBJECT: SR-22-01: Management Letter for OIG Special Review of the Federal 

Election Commission (FEC) Contracting Officers Representative (COR) 

Program 

DATE: May 26, 2022 

Purpose

This letter transmits the results of the Federal Election Commission (FEC) Office of 

Inspector General’s (OIG) Special Review of the Contracting Officers Representative (COR) 

Program. This special review was selected based on several factors, including risks identified 

during the FEC OIG FY 2022 Risk Assessment. 

Objective 

The primary objective of this special review is to assess FEC policies and procedures around 

COR management to ensure that current internal controls are adequate and that the program 

complies with relevant federal laws and regulations, including the Federal Acquisition 

Regulation (FAR), Office of Management and Budget (OMB) guidance, and FEC policies 

and procedures. For more information about the FEC COR program, see the Background 

section below.
 

Criteria

• FAR Parts 1.602-2 and 2.101 

• OMB Office of Federal Procurement Policy’s (OFPP) “Revisions to the Federal 

Acquisition Certification for Contracting Officer’s Representatives (FAC-COR)” 

• OFPP’s Federal Acquisition Institutes (FAI) Continuous Learning Requirements 

Scope 

Our review concentrated on the COR certification process and COR training. We selected a 

random sample of 10 (22%) active employees serving as CORs during the period of FY 2019 

to FY 2021. 

Work Performed 

We reviewed applicable FEC related policies and procedures to determine if they were 

aligned with the FAC-COR. We then selected a random sample of 10 (22% of the 

population) active CORs during the review period. For the CORs selected, we obtained and 

reviewed supporting documentation to ensure each COR: 

• Had an authorized COR Designation Letter, 

• Had the proper COR Certification, and 

• Obtained the required number of Continuous Learning (CL) points.

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Observations

1. The Procurement Office maintains COR certification and CL tracking processes but 

those processes are not memorialized

CORs are required to complete applicable training and CL points based on their COR level 

to obtain initial COR certification and semi-annual recertification. The Procurement Office 

reported that it captures each CORs certification/recertification dates and tracks training with 

a COR tracker spreadsheet. Monitoring compliance with COR regulations and applicable 

guidance is a key internal control which reduces the risk that management would fail to 

identify a COR who did not meet applicable CL requirements. According to the Government 

Accountability Office’s Green Book, internal control procedures should be included in 

formal written policies and/or procedures. Memorializing Procurement’s COR certification 

and CL tracking processes also increases the likelihood that this control process will continue 

to operate effectively in the event of employee turnover. 

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One classroom hour is equal to one CL point. 
2. The OFPP highly recommends that COR responsibilities be incorporated as a critical 

element in the annual performance plans of employees with COR responsibilities at 

Levels II and III 

The OFPP does not require COR responsibilities to be included as a critical element in 

employee annual performance plans. However, the OFPP recommends this as a best practice 

to ensure COR activities and expectations are achieved. 

3. The OFPP has implemented a standard biennial COR recertification reporting period

During this review, it came to our attention that OFPP has transitioned to a common biennial 

COR recertification reporting period for all FAC-CORs. The new standard reporting period 

became effective on May 1, 2022. The OIG acknowledges that the FEC issued an agencywide email on May 10, 2022, confirming that the FEC has implemented the common COR 

recertification reporting period. Consolidating all CORs to the same recertification reporting 

period should improve the efficiency of the COR certification monitoring process. 

Conclusion 

Based on the work performed, all CORs selected for testing had an approved COR 

Designation Letter, obtained the proper COR certification level and required CL points. We 

conclude that the FEC has implemented applicable FAC-COR requirements. However, the 

FEC OIG is proposing two recommendations to enhance alignment with the FAC-COR and

improve the operating effectiveness of COR monitoring controls. 

Recommendations

1. The Procurement Office should memorialize the COR certification tracking procedures it 

has implemented. 

2. In the course of certifying CORs, the Procurement Officer should encourage supervisors to 

include COR activities in performance plans for employees with COR responsibilities at 

Level II and III. In addition, the Procurement Officer should consider including related 

language in the standard COR designation letters. 

Management Response

The Office of the Office of the Chief Financial Officer (OCFO) recognizes the importance of 

an effective Contracting Officers Representative (COR) program in supporting the agency’s 

mission. We are pleased that the Office of Inspector’s (OIG) special review found that the 

agency had implemented applicable FAC-COR requirements and that tested CORs were 

appropriately certified and maintained necessary continuous learning points. These 

conclusions show growth in the program and confirm the program’s ability to support 

important FEC functions. 
OCFO also agrees with OIG’s recommendation to “memorialize the COR certification 

tracking procedures it [the Procurement Office] has implemented.” The Procurement Office 

intends to update the relevant procedures to reflect its current tracking processes. 

We also support supervisors incorporating COR duties under existing critical elements in 

performance plans, where appropriate. To implement this recommendation, we intend to 

include language in COR designation letters encouraging supervisors to incorporate COR 

duties into performance plans where warranted. We note, however, that the inclusion of 

COR duties is ultimately up to each individual supervisor, as the procurement office does not 

control employee performance plans and most underlying contract management functions 

reside at the program level. This is one reason why most CORs are subject-matter-experts on 

the contracts that they oversee and reside in appropriate expert areas of the agency. Also, the 

proportion of COR duties to overall duties will vary by employee.Given that, the supervisors 

will require some flexibility in determining the appropriate level or way to incorporate COR 

duties into performance plans, if warranted. 

We thank the OIG for its work on the COR special review and look forward to working with 

it to promote an effective COR program. 

Background

On September 6, 2011, OMB issued a memorandum communicating the revisions to the 

FAC-COR requirements. The purpose of the FAC-COR is to “establish general training, 

experience and development requirements for CORS...” The new requirements became 

effective on January 1, 2012. The previous COR requirements (FAC-COTR) required only

one level of certification for all CORs, and the new FAC-COR requires three levels of 

certification. 

During the transition to define FAC-COR levels, agencies had the discretion to grandfather 

existing CORs in at Level I, Level II, and/or reassign to level III after validating their 

experience and competency. Upon being grandfathered in or reassigned, CORs are required 

to follow the CL requirements for their new COR level as follows: 

FAC-COR Requirements

Requirements for: Level I Level II Level III

Experience* None 1 year of COR 

experience 

2+ years of COR 

experience

Initial COR 

Training 8 hours 40 hours 60 hours 

Continuous 

Learning 8 CL points 40 CL points 60 CL points 

*Experiences includes work performed on a job that relates directly to COR responsibilities.

Before an employee can be certified as a COR, they must complete the applicable COR 

specific training requirements per the table above. 
FEC OIG 2022-05-013

Once the appropriate training is completed, OCFO will review and confirm the employees 

COR certification level. After a COR’s initial certification is granted, they are required to 

earn a minimum number of CL points every 2 years based on their COR Level to maintain 

their FAC-COR certification. CORs are ultimately responsible for ensuring they comply with 

the CL requirements to maintain COR certification, and for maintaining supporting 

documentation. 

The Contracting Officer (CO) determines who is most appropriate to be assigned as a COR 

on a particular contract/agreement and that is generally determined during the acquisition 

planning phase of the contract/agreement. FEC COR appointments are memorialized in a 

COR Designation Letter that is approved by the CO and signed by the COR, and the COR’s 

supervisor. Before a COR Designation Letter is finalized, OCFO ensures that the COR has 

the appropriate COR Certification and has met the applicable training requirements. CORs 

along with their certification dates are entered into the Procurement system and tracked via 

the COR Certification Tracker Excel spreadsheet. 

Procurement also tracks COR recertification dates and CL training requirements via the COR 

Certification Tracker. The COR certification tracker is used by Procurement to monitor 

whether CORs are obtaining the necessary training for COR recertification in a timely 

manner. In early 2022, the OFPP announced that they were moving to a common bi-annual 

recertification reporting period for all FAC-CORs which became effective on May 1, 2022. 

Prior to May 2022, all FEC CORs’ recertification reporting periods were based on individual 

COR certification dates. 

If I can provide you with any further information, please do not hesitate to contact me at 

(202) 694-1019 or via email at spurnell-brown@fec.gov

cc: The Commission 

Alec Palmer, Staff Director/Chief Information Officer

Lisa Stevenson, Acting General Counsel