Department of Homeland Security 

Office of Inspector General 

FEMA’s Contracting Officer’s 
 

Technical Representative Program 
 

OIG-11-106 September 2011 
Office Offce of a/Inspector Inspector General General 

u.s. U.S. Department of Department of Homeland Homeland Security Security 

Washington Washington, DC 20528 , DC 20528 

Homeland

Security

Preface

The Department of Homeland Security (DHS) Offce of Inspector General (OIG) was

established by the Homeland Security Act 0/2002 (Public Law 107-296) by amendment

to the Inspector General Act 0/1978. This is one of a series of audit, inspection, and

special reports prepared as part of our oversight responsibilities to promote economy,

efficiency, and effectiveness within the department.

This report addresses the strengths and weaknesses of the Federal Emergency

Management Agency's contracting officer's technical representative program. It is based

on interviews with employees and officials of relevant agencies and institutions, direct

observations, and a review of applicable documents.

The recommendations herein have been developed to the best knowledge available to our

office, and have been discussed in draft with those responsible for implementation. We

trust this report will result in more effective, efficient, and economical operations. We

express our appreciation to all of those who contributed to the preparation of this report.

Matt Jadacki ~ ~-

Assistant Insp~~~

Offce of Emergency Management Oversight

Homeland 

Security 

SEP 022011 

Preface 

The Department of Homeland Security (DHS) Office ofInspector General (OIG) was 

established by the Homeland Security Act of2002 (Public Law 107-296) by amendment 

to the Inspector General Act of1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the department. 

This report addresses the strengths and weaknesses of the Federal Emergency 

Management Agency's contracting officer's technical representative program. It is based 

on interviews with employees and officials of relevant agencies and institutions, direct 

observations, and a review of applicable documents. 

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust this report will result in more effective, efficient, and economical operations. We 

express our appreciation to all of those who contributed to the preparation of this report. 

Matt ladacki -..------ ­


Assistant Insp~~~ Office of Emergency Management Oversight 

Table of Contents/Abbreviations 
 

Executive Summary.............................................................................................................1 
 

Background..........................................................................................................................2 
 

Results of Audit ...................................................................................................................7 
 

COTRs Would Benefit From Hands-on Training ........................................................... 7



Recommendation ........................................................................................................ 8



Management Comments and OIG Analysis ............................................................... 9 
 

COTRs Can Be Influenced by Program Offices and Contractors .................................. 9



Recommendation ...................................................................................................... 10



Management Comments and OIG Analysis ............................................................. 10 
 

Record Maintenance Policies Need Reinforcement ..................................................... 11



Recommendations..................................................................................................... 12



Management Comments and OIG Analysis ............................................................. 13 
 

Formal Surge Strategy Is Needed ................................................................................. 13



Recommendations..................................................................................................... 16



Management Comments and OIG Analysis ............................................................. 17 
 

Task Monitors Need Training....................................................................................... 17



Recommendation ...................................................................................................... 18



Management Comments and OIG Analysis ............................................................. 19



Appendices 

Appendix A: Purpose, Scope, and Methodology.......................................................20 
 

Appendix B: Management Comments to the Draft Report .......................................21 
 

Appendix C: COTR Training Requirements.............................................................24 
 

Appendix D: Primary COTR Appointment Letter ....................................................27 
 

Appendix E: COTR Locations ..................................................................................35 
 

Appendix F: Survey Results .....................................................................................36 
 

Appendix G: List of Related Reports ........................................................................43 
 

Appendix H: Major Contributors to this Report ........................................................45 
 

Appendix I: Report Distribution ..............................................................................46 
 
Abbreviations 

CAO Chief Acquisition Officer 

CLM continuous learning module 

CLP continuous learning point 

CORE Cadre of On-Call Response Employees 

COTR contracting officer’s technical representative 

CPARS Contractor Performance Assessment Reporting System 

DAE Disaster Assistance Employee 

DHS Department of Homeland Security 

FEMA Federal Emergency Management Agency 

GAO Government Accountability Office 

IA-TAC Individual Assistance-Technical Assistance Contracts 

IPT Integrated Project Team 

OCPO Office of Chief Procurement Officer 

OFPP Office of Federal Procurement Policy 

OIG Office of Inspector General 

OMB Office of Management and Budget 

PA-TAC Public Assistance-Technical Assistance Contracts 
OIG



Department of Homeland Security 

Office of Inspector General 

Executive Summary 

In the aftermath of Hurricane Katrina, the Federal Emergency 

Management Agency dedicated significant resources to improve its 

contracting officer’s technical representative program. Its Office 

of the Chief Procurement Officer (1) dedicated staff to oversee the 

program, (2) developed a tiered system, which ties training 

requirements to dollar values of contracts that a contracting officer’s 

technical representative can monitor, and (3) developed an intranet 

site containing contracting officer’s technical representative tools 

and news. The program office verifies that contracting officer’s 

technical representatives are meeting training requirements and 

notifies them when their certification status needs to be updated. 

The agency has made great strides in improving the program, but 

challenges remain. Many certified contracting officer’s technical 

representatives have never served on a contract and are unsure of 

their ability to be effective during a disaster. Although they 

represent contracting officers, program office officials complete 

their appraisals, leading to divided loyalties. Contracting officer’s 

technical representatives do not always follow file maintenance 

policies established agency-wide or complete contractor 

evaluations timely. The agency does not have a surge strategy for 

the program, instead relying on the sheer number of certified staff 

to handle large disasters. Also, some large contracts are monitored 

by untrained task monitors rather than contracting officer’s 

technical representatives. 

During this review, the agency was unable to identify its 

contracting officers. Furthermore, the agency does not target job 

announcements to attract contracting officers for its disaster reserve 

cadre, thus not taking advantage of programs being offered to attract 

and retain these skilled individuals. Should a major disaster strike, 

the agency will be unable to quickly deploy experienced and trained 

contracting officers, leaving itself at risk to the same type of contract 

problems it experienced in the aftermath of Hurricane Katrina. 

Our report contains eight recommendations to improve the 

program and to better sustain agency operations during a disaster. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 1 
 

 

Background 

Each year, the Federal Emergency Management Agency (FEMA) 

spends hundreds of millions of dollars on contracts for goods and 

services—$1.8 billion in 2009 and almost $500 million in 2010.1 

More than two-thirds of all contracting dollars were spent in 

headquarters, Region IV, and Region VI. These contracts are 

overseen by contracting officials, including contracting officer’s 

technical representatives (COTRs). 

The COTR plays a critical role in the outcome of the contract 

administration process and functions as the “eyes and ears” of the 

contracting officer, monitoring technical performance and 

reporting any potential or actual problems to the contracting 

officer. The COTR must stay in close communication with the 

contracting officer, relaying any information that may affect 

contractual commitments and requirements. The COTR’s contract 

administration duties may be simple or complex and timeconsuming, depending on the type of contract, contractor 

performance, and the nature of the work. The COTR is selected by 

the program office needing the contracted goods and services. 

Figure 1 shows the share of COTRs by program office. 

Figure 1. FEMA COTRs by Program Office 

Source: OIG analysis of FEMA data. 

Successful acquisitions take a team to complete. Table 1 provides 

descriptions of the key personnel needed in the acquisition process. 

1

 www.usaspending.gov. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 2 
 

Table 1. Key FEMA Acquisition Personnel 

Title Roles/Responsibilities 

Contracting Officer The contracting officer functions as the business manager 

and advisor to the program office throughout the acquisition 

process. The contracting officer is an employee of FEMA 

with the delegated authority to negotiate, enter into, 

administer, modify, and terminate contracts on behalf of the 

government. Contracting officer involvement includes 

making determinations and findings on matters such as the 

appropriate contract type, method of procurement, and the 

fairness and reasonableness of prices. The contracting 

officer is the subject matter expert with technical expertise 

and knowledge of the rules and regulations governing 

federal procurement. 

Contracting Specialist The contracting specialist supports the contracting officer 

and is responsible for the processes leading to the 

procurement of services and supplies, including proper 

development of procurement package documents and the 

contract file. 

Contracting Officer’s 

Technical 

Representative 

(COTR) 

The principal role of the COTR is to support the contracting 

officer in managing the contract. The COTR administers 

and directs the agreement within the confines of the 

contract, monitors performance, ensures that requirements 

meet the terms of the contract, and maintains a strong 

partnership with the contracting officer. Together, the 

COTR and the contracting officer must ensure that program 

requirements are clearly communicated and the agreement is 

performed to meet those requirements. 

Task Monitor Task monitors are responsible for observing contractor 

performance and providing technical feedback to the COTR. 

They have no contract execution oversight authority, nor are 

they able to accept deliverables. Task monitors only provide 

recommendations to the COTR. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 3 
 

Contracting Officer’s Technical Representatives 

The program office acquiring the contracted goods and services 

selects a COTR from its staff. The selection is sent to the 

contracting officer, who verifies that the nominee has the 

prerequisite training for the contract. The COTR is then appointed 

to the contract by the contracting officer and is authorized to 

monitor the contract on behalf of the contracting officer. However, 

the COTR is not authorized to make any contractual commitments 

or changes that may affect the contract price, terms, or conditions 

without the approval of the contracting officer. Some COTRs are 

assisted by task monitors (also known as project or technical 

monitors), who review and report on the technical aspects of the 

contractor’s performance, such as compliance with specific 

contract terms. The COTR role can be either part time or full time, 

and is often a collateral duty.2 As of March 2011, FEMA 

employed 1,430 certified COTRs. 

The Office of Management and Budget (OMB), through its Office 

of Federal Procurement Policy (OFPP), issues guidance for COTR 

training and programs. Government-wide COTR training was 

addressed in OMB Policy Letter 05-01.3 This letter states that the 

Chief Acquisition Officer (CAO) of the agency is “responsible for 

assessing the current skills inventory of the workforce, identifying 

short- and long-term agency needs, and establishing plans, 

including recruitment and retention strategies, for obtaining the 

acquisition workforce resources and skills required to meet future 

agency mission needs.” 

The agency’s CAO4

 is responsible for developing basic and 

refresher training requirements to ensure that COTRs are 

adequately trained. Agency COTRs are required to earn at least 40 

continuous learning points5

 every 2 years. Additionally, the OFPP 

Administrator prescribes specific continuous learning courses to 

ensure that training is provided on topics such as ethics, 

performance-based contracting, and strategic sourcing. 

2

 The Office of Personnel Management does not recognize COTR as a full-time position, and therefore 

does not provide a job series for full-time COTRs. 3 The purpose of the policy letter is to establish a “government-wide framework for creating a federal 

acquisition workforce with skills necessary to deliver best value supplies and services,” allowing COTRs to 

“be trained and developed using common standards.”

4

 In FEMA, the Chief Acquisition Officer is the Chief Procurement Officer. 5

 One continuous learning point is earned for each hour of training. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 4 
Training 

o	 Documentation of COTR certification and training was 

lacking.6  

o	 Instruction manuals and guides intended for the acquisition 

workforce had not been updated to reflect current federal 

acquisition regulations.7  

Communications 

o	 COTRs were unaware of the basic contract requirements 

they were supposed to be monitoring.8 

 

o	 There was an overall lack of communication between 

COTRs and program officials.9 

 

File Maintenance 

o	 COTRs failed to maintain quality assurance information on 

the contracts they were monitoring.10 

o	 Contract file policies and procedures, organization and 

maintenance regulations, and contract closeout 

requirements were infrequently monitored.11 

COTR Performance Feedback 

o	 No process was in place for the contracting officer to 

provide performance feedback to the COTR’s supervisor.12 

o	 COTR monitoring reports lacked required signatures, or 

evidence that different offices had reviewed the 

contractor’s responses.13 

 

COTR Program Weaknesses Previously Reported 

COTRs have an important role in contract oversight. Along with 

the Government Accountability Office (GAO), we have conducted 

numerous audits and have noted weaknesses in FEMA’s COTR 

program that have led to waste and abuse. Some of our previous 

recommendations have been addressed and have strengthened the 

program, whereas others remain outstanding. 

6 Acquisition Workforce Training and Qualifications (OIG-08-56), May 2008.
 7 An Audit of FEMA’s Acquisition Workforce (OIG-04-12), March 2004.
 8 Hurricane Katrina Temporary Housing Technical Assistance Contracts (OIG-08-88), August 2008.
 9 National Flood Insurance Program: Continued Actions Needed to Address Financial and Operational
 


Issues (GAO-10-631T), April 2010. 
 10 Ineffective FEMA Oversight of Housing Maintenance Contracts in Mississippi Resulted in Millions of 
 

Dollars of Waste and Potential Fraud (GAO-08-106), November 2007. 
 11 Internal Controls in the FEMA Disaster Acquisition Process (OIG-09-32), February 2009. 
 12 Ibid. 
 

13 National Flood Insurance Program: Financial Challenges Underscore Need for Improved Oversight of 
 

Mitigation Programs and Key Contracts (GAO-08-437), June 2008. 
 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 5 
 

 

FEMA’s COTR Website 

To assist its COTRs, FEMA has established a COTR intranet 

website. The site includes a COTR “Toolkit” containing forms 

and templates commonly used by COTRs, as well as updated 

policy information. 

According to the data on the site, FEMA currently has 1,430 

certified COTRs.14 They are categorized by tier level, reflecting 

their training and experience. This categorization matches COTR 

competency with contract complexity. Table 2 represents the 

COTR tiered certification requirements. 

Table 2. COTR Training Requirements for Tier Designation 

Source: FEMA’s COTR website, accessed March 15, 2011. 

14 FEMA intranet as of March 15, 2011. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 6 
 

Results of Audit 

Although FEMA has enhanced its COTR program, the following areas require 

additional attention: enhancing COTR training, reducing program office pressure, 

following records management guidance, developing a strategy to handle 

disasters, and training task monitors. 

As part of our fieldwork, we conducted a survey on FEMA’s COTR program. 

The survey was forwarded to 1,710 individuals, including COTRs, warranted 

contracting officers,15 and unwarranted contracting officers. We received greater 

than a 50% response rate from COTRs and an 85% response rate from warranted 

contracting officers. Appendix F contains the survey questions and a summary of 

the answers. 

COTRs Would Benefit From Hands-on Training 

FEMA COTR training requirements are mandated by DHS Acquisition 

Workforce Policy Number 064-04-003, Contracting Officer Technical 

Representative Certification, Appointment and Termination. To assume 

COTR responsibilities, an employee must complete 40 hours of initial 

training either in a classroom or online. Thereafter, 40 hours of training 

must be completed biennially to maintain COTR certification. Most 

COTRs found the initial certification training to be effective and useful, 

but several areas need improvement. 

COTRs said that they would benefit from training that is more technical 

and focuses on the “how-to” of contracting. For example, COTRs would 

like detailed guidance on what steps to take when they are appointed to a 

contract and instruction on the review and approval of invoices. A 

contract specialist suggested that COTRs also receive business process 

training, including how to compile financial data and document problems. 

One COTR said that the training simply outlines the laws and regulations, 

but does not prepare them for the actual experience of performing COTR 

duties. In addition, many of the followup training courses are offered only 

through the Defense Acquisition University, with examples specific to the 

Department of Defense. COTRs find it hard to apply these examples to 

FEMA’s work. 

Some of the COTRs we spoke to felt they would be uncomfortable 

performing their duties without a supervisor or mentor. One COTR said 

that he was not sure he was prepared to function as a COTR if a disaster 

were declared. One reason for this is that program offices repeatedly 

15 A warranted contracting officer carries a warrant allowing him or her to bind the government in 

contracts; an unwarranted contracting officer is employed as an 1102 job series, might have kept his or her 

education requirements current, but does not currently have a contract warrant. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 7 
appoint the same COTRs instead of taking full advantage of the entire 

pool of certified COTRs, leaving many COTRs with no contract oversight 

experience. Many COTRs said they need more real-world opportunities 

soon after training to remember what they have learned. A regional 

COTR said that she is sure she has forgotten everything she learned and 

would need to be recertified in order to perform effectively as a COTR. 

Several COTRs stated that on-the-job training was much more helpful 

than the classroom training. 

Many COTRs agreed that a mentoring program is needed to supplement 

what they learn in training. A supervisor agreed that the quality of 

certification training varies; simply passing a course does not mean that 

someone can function as a COTR. Providing newly certified COTRs with 

an opportunity to shadow more experienced COTRs would enable them to 

perform COTR duties more effectively, such as identifying illegitimate 

invoices, holding contractors accountable, and knowing which FEMA 

forms and processes to use—topics that are not always covered in training. 

A mentoring program would also help COTRs understand what actions 

they can and cannot take against a contract or contractor. A regional 

COTR said that the best training she received was the mentoring provided 

by her coworker. She is now comfortable mentoring others. Other 

COTRs said their duties are not something that can be done right away 

without supervision; they require guidance and mentoring. Training alone 

is not enough to enable COTRs to oversee large contracts. 

COTRs are taking the prescribed training and finding it useful. However, 

they would benefit from more hands-on experience before taking on full 

COTR responsibilities. This hands-on experience should familiarize the 

COTRs with FEMA’s business processes and help them develop the 

confidence needed for larger and more complex contracting actions. 

Recommendation 

We recommend that the Chief Procurement Officer, Federal 

Emergency Management Agency: 

Recommendation #1: Develop and implement a contracting 

officer’s technical representative mentoring program led by the 

contracting officer’s technical representatives’ contracting officers 

and contract specialists; and, where practical, ensure that program 

offices nominate certified contracting officer’s technical 

representatives with appropriate skill sets for consideration for 

appointment by the contracting officer to gain on-the-job 

experience. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 8 
 

 

Management Comments and OIG Analysis 

FEMA concurs with this recommendation. The Office of Chief 

Procurement Officer (OCPO) will develop a pilot program to 

evaluate the feasibility of having a COTR mentoring program, and 

has established an implementation date of September 30, 2011. 

We consider this to be an appropriate start to developing a worldclass COTR cadre. However, we are concerned that a pilot 

program to evaluate the feasibility of having a COTR mentoring 

program is not the same as having a mentoring program. By 

having a pilot program to evaluate the feasibility of such a 

program, FEMA is delaying the opportunity to strengthen its 

current cadre. 

COTRs Can Be Influenced by Program Offices and Contractors 

COTRs are selected by the program office in which they work, and the 

selection is submitted to the contracting officer for approval. A COTR’s 

duties are overseen by a contracting officer; however, the contracting 

officer is not required to provide formal input into the COTR’s annual 

performance appraisal. DHS Acquisition Workforce Policy16 states that 

when requested by a COTR’s supervisor, a contracting officer is to 

provide input for the COTR’s midpoint or annual appraisal. However, 

during our review, we learned that the part-time COTR’s performance 

appraisal was generally completed by the COTR’s direct supervisor or 

manager in the program office and did not include measures of success for 

COTR duties, unless the program office reached out and initiated a 

request. COTRs, contracting officers, and contracting specialists agree 

that it would be helpful if formal input were provided by the contracting 

officer or contracting specialist. 

Because COTRs are ultimately evaluated by their program office 

supervisor, COTRs may be influenced into meeting the program office’s 

needs and making contracting decisions that go against their better 

judgment. For example, in one instance involving the National Flood 

Insurance Program office, a contractor was hired to develop a new 

information technology system and manage the transition from the legacy 

system. The person appointed as COTR was a former employee of the 

contractor; many of the program office managers were former employees 

of the contractor that had developed the legacy system. The program 

office managers were unable to break allegiances to their former 

16 Contracting Officer Technical Representative Certification, Appointment and Termination, DHS 

Acquisition Workforce Policy Number 064-04-003, September 30, 2010. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 9 
 

 

 

employer, fueling favoritism for the legacy contractor, which impeded the 

completion of contract services. This ultimately resulted in the 

termination of the contract and removal of the COTR from his duties.17 

During our survey, we asked COTRs about challenges they faced, and 

about 16% replied that they felt excessive pressure from their program 

office.18 COTRs also reported instances in which contractors asked them 

to sign invoices or approve contract modifications, a clear violation of 

contracting regulations. One COTR recommended shifting the COTRs’ 

chain of command to fall under the FEMA OCPO, thereby preventing 

undue influence from program officials who persist in omitting the 

contracting officer from contract-related discussions. 

Recommendation 

We recommend that the Chief Procurement Officer, Federal 

Emergency Management Agency: 

Recommendation #2: 

Recognize contracting officer’s technical representative 

duties and ensure contracting officer input into the 

contracting officer’s technical representative’s annual 

appraisal. 

Issue a memorandum annually from the Federal Emergency 

Management Agency Administrator reminding supervisors 

that exerting undue pressure on contracting officer’s 

technical representatives to perform duties outside the 

contract scope of work is an ethics violation and may be 

subject to adverse action. 

Management Comments and OIG Analysis 

FEMA partially concurs with this recommendation. FEMA’s 

OCPO does not have supervisory authority over COTRs. In 

accordance with FEMA Directive 228-1, supervisors may solicit 

the feedback of the contracting officer for the COTR’s annual 

appraisal. 

We understand that the OCPO does not have supervisory authority 

over COTRs, as COTRs are placed in the directorates that are 

17 Improvement Needed in FEMA’s Management of the National Flood Insurance Program’s Information 
 

Technology Transition (OIG-10-76), March 2010. 
 18 See appendix F for the complete COTR survey results. 
 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 10 
 

receiving the benefits of the contracts they oversee. However, we 

do not believe that FEMA Directive 228-1 goes far enough in 

protecting the government’s interests. This directive is dated 

September 28, 2009. However, during the course of our audit, 

which occurred in late 2010 and early 2011, COTRs still expressed 

concerns regarding undue supervisory influence. The directive 

requires the COTR’s supervisor to request the contracting officer’s 

input. Until FEMA develops a way to ensure that COTRs are 

evaluated for their contract oversight, we believe that contracts will 

continue to be subject to program office interference. 

FEMA concurs with the second part of this recommendation. In 

coordination with the FEMA Office of Chief Counsel, the OCPO 

will, at the start of each fiscal year, prepare a memorandum 

reminding supervisors that exerting undue pressure on COTRs to 

perform duties inconsistent with their appointment or the contract 

scope of work is an ethics violation and may be subject to adverse 

action. 

Record Maintenance Policies Need Reinforcement 

Contract record maintenance and retention improved after we reported that 

FEMA needed internal controls for records management and 

maintenance.19 However, record retention policies are still not effectively 

communicated or widely followed. Adherence to policies varies by 

contracting officer and COTR, as many are unaware of what the formal 

contract file maintenance processes entail. 

The COTR website provides a checklist for COTRs to use to ensure that 

contract files are properly maintained. FEMA Directive 228-1, 

Contracting Officer’s Technical Representatives, requires that contract 

files be properly maintained. However, contract files are not always 

complete, as (1) not all COTRs are aware that the checklist exists and 

(2) there has been inadequate discipline in contract file management. 

Some COTRs have developed their own methods for maintaining files. 

For example, one COTR maintains a complete file, including the 

checklist, COTR appointment letter, a list of responsibilities, the contract 

and contract modifications, and copies of invoices. On the other hand, 

another COTR claimed that document management was discussed in 

training but once she was assigned to a contract, there was no push by 

management to maintain files. 

19 Improvements Needed in FEMA’s Disaster Contract Management (OIG-10-53), February 2010; and 

Challenges Facing FEMA’s Disaster Contract Management (OIG-09-70), May 2009. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 11 
COTRs are also unsure of what to do with files once contract terms are 

completed. COTRs are supposed to submit contract files to the 

contracting officers. The contracting officer reviews the files for 

completeness, packs them in boxes, and forwards them for storage. 

COTRs told us that files are— 

Not forwarded to the contracting officer “over 90% of the time”; 

Taken home in case there are issues later on with the contractor; and 

Personally maintained “for a long time.” 

FEMA has policies and methodologies for documenting problems with 

contractors. The OCPO instructs employees to use the Contractor 

Performance Assessment Reporting System (CPARS) to capture 

contractor performance evaluations. However, not all COTRs are using 

this system. This makes it difficult for contracting officers to determine 

whether a contractor has had a record of performance problems when 

deciding whether to renew a contract. A few contracting officers request 

informal feedback from COTRs regarding contractor performance. Only 

in one office did the contracting officers ask COTRs to rate contractor 

performance and document it in the contract file. Some COTRs claim that 

there is no need for formal contractor performance documentation because 

they work closely with their contracting officers on a daily basis and can 

communicate any contractor issue to them in person. In September 2009, 

FEMA’s Chief Procurement Officer issued a memorandum defining the 

various roles in CPARS preparation and use. The Chief Procurement 

Officer also expressed his expectation for “everyone having a role in 

CPARS to perform those roles as required.” 

The Federal Acquisition Regulation contains requirements for proper file 

maintenance. Records are necessary to support decisions made and 

actions taken. A standardized storage method is necessary so that 

documents are available if there is a change in personnel or if there is any 

disagreement over contract performance. Further, contractors deserve a 

fair and accurate evaluation of their performance. This evaluation should 

be captured in CPARS, where it is available for contracting officers to 

consider in future awards. 

Recommendations 

We recommend that the Chief Procurement Officer, Federal 

Emergency Management Agency: 

Recommendation #3: Enforce Federal Emergency Management 

Agency Directive 228-1, Contracting Officer’s Technical 

Representatives, and provide periodic training on the use of the 

contracting officer’s technical representative file checklist. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 12 
Recommendation #4: Implement mechanisms to enforce 

established policies for oversight in the use of the Contractor 

Performance Assessment Reporting System. 

Management Comments and OIG Analysis 

FEMA concurs with recommendation #3. FEMA stated that the 

“OCPO conducted a pilot program for COTR file technical review. 

Program Offices were selected at random to ensure COTR file 

compliance with FEMA Directive 228-1 and the COTR 

appointment letter. Non-compliance of the directive and 

appointment letter may result in termination of the COTR 

appointment. Periodic training and communication to COTRs 

regarding COTR file maintenance is continuous.” FEMA’s 

response is silent as to what happened to the pilot program, 

whether it was found to be effective, or whether the OCPO 

determined that there was a better way to ensure proper COTR file 

maintenance. However, during the course of our audit, we became 

aware that the COTR technical file review was curtailed because of 

funding limitations. We look forward to learning more about 

FEMA’s plan to ensure COTR compliance with Federal 

Acquisition Regulation file maintenance requirements. 

FEMA concurs with recommendation #4. FEMA’s OCPO will 

develop policy regarding the use of CPARS by January 1, 2012. 

We agree that policy is needed for better CPARS compliance. We 

also request that FEMA not only develop policy but strengthen its 

internal oversight of CPARS use. 

Formal Surge Strategy Is Needed 

FEMA currently has no system in place to quickly call up COTRs in the 

event of a disaster. The COTR Program Lead indicated that, at this time, 

the best way to handle a situation in which COTRs need to be deployed 

immediately would be to look at the list of COTRs based on location and 

then provide that information to the FEMA program office. 

FEMA maintains a database listing DHS-certified COTRs, and the list is 

also available via FEMA’s COTR community website. However, when 

we administered our survey to all COTRs and contracting officers, a 

number of the email addresses provided were incorrect. Furthermore, the 

OCPO did not have a current list of its warranted contracting officers. 

When FEMA finally compiled a contracting officer list for us, many of the 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 13 
 

 

addresses were incorrect; the OCPO was unable to provide an accurate list 

even after numerous conversations. Without an accurate list of names and 

contact information, it would be extremely difficult for FEMA to contact 

these contracting officers and COTRs in the event of a disaster. To ensure 

quick and efficient contracting activity during a disaster, FEMA needs to 

maintain an accurate list of its contracting officers and COTRs. 

In 2008, we reported that FEMA needed to enhance its plans and policies 

to develop a well-prepared acquisition workforce that can respond to 

disasters that result in extraordinary levels of casualties, damage, or 

disruptions. Specifically, we recommended that FEMA— 

Develop and implement a strategic acquisition workforce plan; 

Coordinate with other FEMA components and federal acquisition 

organizations that have responsibilities to prepare for and respond 

to such disasters; 

Develop and implement detailed acquisition workforce policies 

and procedures; 

Complete a staffing analysis to determine the appropriate size of 

the Disaster Assistance Employee (DAE) contracting cadre; 

Develop a succession plan for FEMA’s Office of Acquisition 

Management20 acquisition staff; 

Initiate a formal mentoring program; 

Design a rotation program for headquarters and regional office 

acquisition personnel to obtain disaster contracting experience; and 

Provide training and guidance to the field office staff in 

conjunction with reassignment of contract administration 

responsibilities.21 

FEMA has made progress on some of these activities, but more should be 

done. 

As of January 2010, FEMA had 16,588 federal employees, of whom 4,169 

or approximately 25% were permanent. The remaining 75% of FEMA’s 

workforce is nonpermanent disaster-related employees. Section 306 of the 

Robert T. Stafford Disaster Relief and Emergency Assistance Act 

authorizes the “Appointment of temporary personnel, experts, and 

consultants” during a disaster. The largest group of temporary employees 

is classified as DAEs. DAEs are federal employees who work on an oncall, intermittent basis, forming the major FEMA workforce in times of 

emergency or disaster. DAEs help complete FEMA’s mission by staffing 

20 Now known as OCPO. 
 

21 Challenges Facing FEMA’s Acquisition Workforce (OIG-09-11), November 2008. 
 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 14 
 

joint field offices22 and disaster recovery centers; interviewing disaster 

survivors; conducting and verifying damage assessments; providing 

administrative, financial, acquisition, and logistical support; and 

performing a wide variety of other tasks as identified by staffing needs and 

operational requirements. 

In the federal government, the standard way to classify employees is the 

use of numeric coding that is assigned to an occupational series. It provides 

agencies a way to group similar jobs together. FEMA has more than 130 

occupational series, but regardless of their individual qualifications and 

experiences, all of FEMA’s DAEs are classified in the Generalist-301 

series. Most of FEMA’s 301 series employees are program specialists in 

mission-critical areas such as emergency preparedness, response, or 

emergency management. DAEs are not given specific job titles or job 

descriptions that identify those qualified as contracting officers, COTRs, 

or acquisition-related experts. 

According to FEMA officials, this legacy practice of classifying all DAEs 

in the 301 series has an adverse impact on the acquisition cadre and it is an 

impediment to recruitment, qualification, and readiness. For example, 

despite a government-wide increase of qualified retiring 1102 series 

contract specialists,23 FEMA is unable to attract these individuals to 

become part-time, intermittent DAE employees because FEMA advertises 

openings only for generalists in the 301 series. Also, because acquisition 

policies are crafted to limit the financial risk to the government posed by 

non-1102 acquisition personnel, FEMA has limited the warrant levels for 

301 series contracting officers to $150,000. Prior to retirement, those 

same personnel may have held multimillion-dollar or unlimited warrants. 

This constraint limits the new hires’ ability to contribute to the award of 

higher level acquisitions at disaster sites. Also, while the Office of 

Personnel Management provides certain waivers for retired annuitants 

who return to serve in 1102 series positions, it does not provide the same 

for 301 series positions. Consequently, the 301 series DAEs serving as 

contract specialists are not encouraged to be available after the first 120 

days of a disaster declaration,24 and according to FEMA, this results in 

more frequent turnover in deployments. 

22 A joint field office is a temporary federal multiagency coordination center established locally to facilitate 

field-level domestic incident management activities related to prevention, preparedness, response, and 

recovery. It provides a central location for coordination of federal, state, local, tribal, nongovernmental, 

and private-sector organizations with primary responsibility for activities associated with threat response 

and incident support. 

23 “Contract specialist” is the term used for those in the 1102 series; a contracting specialist, as defined in 

table 1, is a job title for those who support contracting officers. 24 The Office of Personnel Management states that within the first 120 days of a presidential disaster 

declaration, FEMA is authorized to waive the pay/retirement reduction for civilian retirees employed 

during presidentially declared disasters. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 15 
 

Readiness is also at risk as contract specialists, who as part of the Cadre of 

On-Call Response Employees (CORE) or permanent full-time employees 

are classified as 1102 series personnel, have an affirmative education and 

training requirement in law. These training and education requirements 

ensure that only qualified personnel are obligating funds for the government 

and are providing appropriate oversight. However, when 301 series DAEs 

perform these same tasks, they may do so without meeting the education, 

training, and continuing education requirements of their 1102 series 

counterparts. 

Although FEMA has succeeded in increasing the size of its COTR 

workforce, it has not yet developed a methodology to provide the contract 

oversight vital in large disasters. With the administration and Congress 

focused on performance outcomes, now is the time for agencies to invest 

in the acquisition workforce directly overseeing contract performance. 

The federal government must attract talented individuals into the 

acquisition workforce, whether as permanent employees or DAEs, to 

ensure cost savings, reduce risk in contracting practices, and improve 

acquisition and project management. Contracting officers and COTRs are 

critical to ensuring that contracts deliver expected outcomes. To support 

this process, the federal government has identified hiring flexibilities and 

strategies that agencies should consider to improve the visibility of 

acquisition jobs, target specific skill sets, and reduce the administrative 

burden on the agency and the applicant. 

Recommendations 

We recommend that the Chief Procurement Officer, Federal 

Emergency Management Agency: 

Recommendation #5: Develop a working group with the program 

offices to develop a surge strategy for deployment of contracting 

officer’s technical representatives during disasters. 

Recommendation #6: Develop and maintain, on a monthly basis, 

a database with essential information regarding warranted 

contracting officers. 

Recommendation #7: Work in concert with the Federal 

Emergency Management Agency Chief Component Human 

Capital Officer and the Federal Emergency Management Agency 

Chief Counsel to review the classification of Acquisition Cadre 

positions in an effort to improve the recruitment and optimize the 

training and utility of contracting specialists in the Acquisition 

Cadre within the constraints of the Disaster Assistance Employee 

program. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 16 
 

 

 

 

Management Comments and OIG Analysis 

FEMA concurs with recommendation #5. The OCPO will 

coordinate a working group with the program offices to assist in 

surge strategies for COTR deployment. We believe that having a 

surge strategy for disaster deployment will lessen some of the 

uncertainties that are bound to occur during a disaster and 

strengthen FEMA’s effectiveness during emergencies. 

FEMA concurs with recommendation #6. The OCPO Acquisition 

Career Manager maintains an accurate record of warranted 

contracting officers with their contact information. 

FEMA concurs with recommendation #7. FEMA’s Office of 

Human Capital has agreed with the change needed to have DAE 

reservists identified in the 1102 series. The OCPO is now working 

directly with the FEMA Response Directorate, within the Office of 

Response and Recovery, to form a pilot working group to develop 

a cadre of Acquisition reservists. 

Task Monitors Need Training 

In a recent report, we stated that FEMA was using untrained task monitors 

to oversee Public Assistance25-Technical Assistance Contracts 

(PA-TAC).26 These are often multimillion-dollar contracts, depending on 

the type and severity of the disaster. FEMA has contracts in place with 

three contractors to provide architectural and engineering expertise after a 

disaster. The contracting officer and COTR for these contracts are based 

at FEMA headquarters, yet the actual work is performed in the field. 

FEMA has assigned task monitors at disaster sites to provide contract 

oversight. However, these task monitors had no significant experience or 

training to prepare them for these duties; often they were assigned simply 

because they were available at the disaster site. 

Individual Assistance-Technical Assistance Contracts27 (IA-TAC) are 

used to assist individuals after a disaster with temporary housing and mass 

25 FEMA awards grants to assist state and local governments and certain private nonprofit entities with the 

response and recovery from disasters through the Public Assistance Program. 26 Improvements Needed in FEMA’s Management of Public Assistance-Technical Assistance Contracts 

(OIG-11-02), October 2010.


27 IA-TAC differ from PA-TAC in that all PA-TAC contractors may be activated for a disaster. IA-TAC 
 

contractors each have an assigned sector of the country; they are activated on the basis of the location of the 
 

disaster. 
 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 17 
 

 

 

care. The IA-TAC program office also uses task monitors to oversee 

contractors in the field. This program office has realized the weakness in 

having untrained task monitors, so it is starting to require its task monitors 

to become certified COTRs. By requiring this training, the IA-TAC office 

will improve the quality of its oversight of the disaster contractors.28 

FEMA is developing the Disaster Acquisition Response Team to perform 

disaster contract oversight, administration, and contract closeout. 

Although the staff will be located in regional offices, they are considered 

headquarters assets and can be used nationally. Their focus will be on the 

large task orders already issued against the pre-positioned contracts 

following disasters. These employees will assist joint field offices and 

regions in closing out those task orders issued in response to a disaster to 

allow for a more timely return of unobligated funds to the Disaster Relief 

Fund. The creation of this team is still in the planning stages. 

PA-TAC and IA-TAC are just a few of the large contracts issued by 

FEMA headquarters. Other large contracts are overseen by COTRs based 

in Washington, DC, even though the actual work is performed elsewhere. 

The actual work is monitored by regional staff with the technical 

knowledge, but possibly little or no contracting training. Although 

personnel must be assigned to provide onsite monitoring, those assigned 

need to be fully trained to perform their oversight, acquisition-related 

duties. The COTR program is one way to provide that training. 

FEMA spends millions of contract dollars annually for goods and services 

nationwide. COTRs cannot be at every location in which contractors are 

performing, so using task monitors is a reasonable method of ensuring 

contract monitoring. However, these task monitors need to be adequately 

trained and supported, so that the contractors are held to the appropriate 

standards and FEMA receives the goods and services it needs. 

Recommendation 

We recommend that the Chief Procurement Officer, Federal 

Emergency Management Agency: 

Recommendation #8: Implement policy that requires all technical 

monitors to be Department of Homeland Security certified 

contracting officer’s technical representatives, and appoint them as 

limited authority contracting officer’s technical representatives on 

a contract. 

28 We are completing an audit of FEMA’s IA-TAC. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 18 
Management Comments and OIG Analysis 

FEMA concurs with recommendation #8. The COTR Program has 

updated the COTR Handbook to address limited authority COTRs. 

FEMA plans on updating FEMA Directive 228-1 with the role and 

responsibilities of the limited authority COTRs. FEMA’s response 

is silent as to whether all who have functioned as technical 

monitors will be required to become limited authority COTRs; 

however, we believe that FEMA’s concurrence signifies its 

acceptance of this additional step. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 19 
 

Appendix A 

Purpose, Scope, and Methodology 

The objective of our audit was to determine whether FEMA has 

adequate controls, policies, and procedures in place to effectively 

manage its contracting officer’s technical representative program. 

We conducted interviews at FEMA headquarters, FEMA Regions 

II, III, IV, VI, and IX, the Louisiana Transitional Recovery Office, 

and the Texas National Processing Service Center. We examined 

documentation related to FEMA’s COTR program at each location 

visited. We also sent a survey to 1,710 COTRs and contracting 

officers. The response rate was 50% for COTRs and 85% for 

contracting officers. We used the information gathered from our 

survey throughout this report; the survey questions and summaries 

of the answers are included as appendix F. 

We conducted this performance audit between October 2010 and 

March 2011 pursuant to the Inspector General Act of 1978, as 

amended, and according to generally accepted government 

auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based 

upon our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based 

upon our audit objectives. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 20 
IIS. llt·p,,,·IIIU·III Of l l,,,,, .. I,uul SI.'t"urily 

'<;(1) (" Slr,·d. SW 

W",hinglon. DC JlI.tn 

AUG 0 4 2011 

MEMORANDUM FOR: Mati Jadacki 

Assistant Inspector General 

Offi ce of Emergency Management Oversight 

FROM: David J. K<lllfillUnfl::::;' 

Director ; 

Offi ce of Policy an Program Analysis 

SUBJECT: f-EMA OCPO Response to O[G Draft Report FEMA ·s Contracting 

OiJ"icer Technical Represelltatil'c Program, Project No.09-2 [4-EMOFEM A 

We thank you for the opportunity to provide comments to your draft report, FEMA 's COl1(raclillg 

qfficer Technical Representative Program. Your report explained the actions taken by your offi ce 

to review the Contracting Officer Technical Representative (COTR) Program and identified 

measures to enhance COT R training and mcntoring, reduce program office pressure, ensure 

programs follow records management guidance, develop a COTR disaster strategy, and train task 

monitors. 

Our responses to your eight recommendations follow' 

Recommendation #1: Develop and implement a contracting officel··s technical representative 

(COTR) meDtoring program led by the contracting officer's technical representatives' 

contracting officers and contract specialists; and, n·here practical, ensure that Program Offices 

Domin:,tc certified contracting officer's technical representatives with appropriate skill sets for 

consideration for appointment by the contracting officer to gain on-tlte-job experience. 

Response to Recommendation: FEMA l:oncur);; wit h this recommend ution. FEMA"s Office of the 

Chief Procurement Of/ker (OepO) will develop a pilot prob'l'am to evaluate the feasibi lity of 

implementing a COTR mcntori ng program by the end of this fiscal year, September, 30, 20l 1. 

Recommendation #2: Recognize contracting officer's technical representative duties and 

assure contracting officer input in the contl'acting officer's technic al representative's annual 

appraisal. Issue a mcmurnndum annually (rom the Federal Emergency Management Agency 

Administrator reminding supervisors that exerting undue pressure on contracting officer's 

technical representatives to perform duties outside the contract scope of ,,"'ark is an Ethics 

violation and may be subject to adverse action. 

W" ·'I.rema./.:()\· 

Appendix B 

Management Comments to the Draft Report 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 21 
Response to Besommendation: FEMA partially concW'S with this recommendation. FEMA's 

OCPO does not have supervisory authority over COTRs. In accordance with FEMA Directive 

228-I, supervisors may solicit the feedback of the Contracting Officer for the COTRs annua1 

appraisal. We will update our COTR nomination letter to notify Supervisors that the OCPO is 

available for feedback to the COTRs appraisal. 

In coordination with the FEMA Office of Chief Counsel, the OCPO will, at the start of each fiscal 

year, prepare a memorandum reminding supervisors that exerting undue pressure on COTRs to 

perfonn duties inconsistent with their appointment or the contract scope of work is an ethics 

violation and may be subject to adverse action. 

Recommepdatiog #3: Enforce the Federal Emer&ency Mana&ement A&enl:y Directive 228-1, 

ContractiDg Officer's Technical Representatives, and provide periodic training on the use of 

the contracting officer's technical representative file checklist. 

Response to R~mmeDd.tloD: FEMA concurs with this recommendation. FEMA's OCPO 

conducted a pilot program for COTR file technical review. Program Offices were selected at random 

to ensure COTR file compliance with FEMA Directive 228a l and the COTR appointment letter. 

Non-compliance of the directive and appointment letter may result in tennination of the COTR 

appointment Periodic training and communication to COTRs regarding COTR file maintenance is 

continuous. 

Recommendatiob #4: Implement mecbanisms to enforce established policles for oversl&ht In 

the use of the Contractor Performance Assessment Reportiog System. 

Response to Recommendation: FEMA concurs with this recommendation. FEMA's OCPO will 

develop policy regarding the use ofCPARS by January 1,2012. 

Recommendation #5: Develop a working group with the program offices to develop a surge 

sfratee' for deployment of c.ontractinc officer's technical representatives durin& disasters. 

Response to Recommendation: FEMA concurs with this recommendation. FEMA's OCPO will 

coordinate a working group with the program offices to assist in surge strategies for COTR. 

deployment. 

Recommendatiop #6: Develop and maintain, on a monthly basis, a database with essential 

information regardlng warranted contracting officers. 

Response to RecoDlDlendation: FEMA concurs with this recommendation. FEMA's OCPO 

Acquisition Career Manager maintains an accurate record of warranted contracting officers 

including their warrant levels, experience, training and education levels, branch loffice assignment, 

grade, series, and full performance level, and FAC-C certification level. FEMA's existing email 

distribution lists for all OCPO divisions and contracting personnel are adequate for the dissemination 

of contracting policy, guidance and contacting these individuals in the event of a disaster. The 

decision to notify the entire acquisition community of such changes has broadened the understanding 

of the OCPO function at large. In addition to the established email distribution lists in Outlook, 

FEMA maintains an emergency notification system that incorporates both the current email address 

2 

Appendix B 

Management Comments to the Draft Report 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 22 
and the home and work phone numbers for all OCPO personnel to contact them in the event of a 

disaster. 

Recommendation #7: Work in concert with the Federal Emergency Management Agency 

Chief Component Buman Capital OffICer and the Federal Emergency Management Agency 

Chief Counsel to review the classification of Acquisitioa Cadre posJtions in aD effort to 

improve the recruitment and opdmize the trai.ning aod utility of contractiDg speciaHsts in the 

Acquisition Cadre within the constraints ortbe Disaster AssJstance Employee proll'am. 

Response t9 RecommendatiQA: FEMA concurs with this recommendation. As of June 16, 2011, 

FEMA's Office ofHwnan Capital has concurred that change is needed to convert the DAE 

Reservists to the 1102 series and invited OCPO to work directly with the Office of Response and 

Recovery, Response Directorate, to form a pilot working group to accomplish the same for 

Acquisition reservists. Also, on that date, the FEMA Administrator transferred responsibility for the 

DAE Cadres to the Office of Response and Recovery, Response Directorate. 

Recommendation #8: Implement pollcy that requires all technical monitors to be Department 

of Homeland Security certified contracting officer's technical representatives, and appoints 

them as limlted authority contracting officer's technical representatives on a contract. 

FEMA concurs with this recommendation. The COTR Program has updated the COTR 

Handbook to address Limited Authority COTRs (fonnally known as Technical Moniton). Plans are 

being coordinated to update FEMA Directive 228·' with the role and responsibilities of the Limited 

Authority COTRs. 

Due to the scope or technical complexity of some business agreements, the Contracting Officer may 

also designate a Limited Authority COTR in addition to a COTR. Their role is to perfonn specific 

delegated duties or tasks within the limits specified by the Contracting Officer. The Limited 

'Authority COTR serves as the "eyes and ears" of the COTR relevant to their specified limits. These 

limits are stated in a letter of appointment signed by the Contracting Officer. Limited Authority 

COTRs are appointed to perfonn those functions only for that specific contract. Some duties may 

include, but are not limited to, acceptance of deliverables, monitoring of Contractor's perfonnance. 

providing support for the certification of invoices for payment and ensuring that Government 

property is being used. properly, At the end of the contract, the designation of duties automatically 

expires, unless terminated sooner by the Contracting Officer. The appointment process and training 

requirements for COTRs pertain equally to the Limited Authority COTR. 

Again, we thank you for the opportunity to review and provide comments on your draft report. 

Should you have any questions regarding this response, please feel free to contact Brad Shefka, 

Chief, FEMA GAO/OiG Liaison Office, 202·646·1308. 

3 

Appendix B 

Management Comments to the Draft Report 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 23 
 

Appendix C 

COTR Training Requirements 

Certification Requirements29 

To obtain initial DHS FEMA contracting officer’s technical representative 

certification, employees must complete 40 hours of initial COTR training and apply 

for COTR certification within 2 years of completing the required coursework. 22 

hours must cover essential COTR technical competencies, 18 hours must cover 

business competencies, and the remaining 2 hours must cover procurement ethics. 

DHS permits two exceptions to the requirements mentioned above: 

Applicants who have previously acquired a Contracting Level 1 Certification 

or higher are eligible for initial COTR certification. 

Project managers with Level II Certification or higher are eligible for initial 

COTR certification. 

Training can be obtained online or in the classroom. DHS offers free accredited 

classroom training for the initial training curriculum. Initial COTR training provided 

by vendors other than DHS-accredited vendors must be accompanied by a course 

description and 1 hour of ethics training. Program offices are responsible for the 

costs of training obtained through a training provider. Online training can be taken 

through the Federal Acquisition Institute. 

If the training is taken online via the Federal Acquisition Institute, COTR applicants 

may obtain their 40 credits using one of the following two options: 

Complete Contracting Officers Representatives Online Training (32 hours). 

To cover the remaining 8 hours, choose one of the following three Defense 

Acquisition University online courses: 

o Cost Estimating (8 hours) 

o Integrated Project Team (IPT) Management and Leadership (8 hours) 

o Risk Management (8 hours) 

Plus 1 hour of ethics: 

o Ethicsburg (ethics training via the Internet) 

o Ethics Training 

o	 Ethics Training for Acquisition Technology and Logistics (Defense 

Acquisition University) 

Or, the employee may complete all courses from list A and six continuous learning 

modules (CLMs) from list B from the table below. The remaining 10 continuous 

learning points (CLPs) must be from an approved CLM, which is available on FEMA’s 

COTR website. 

29 Information provided as found on FEMA’s COTR website. The website contains the training hour 

inconsistencies demonstrated above. The inconsistency is due to ethics training being required in addition 

to the 40 hours of technical training. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 24 
 

Appendix C 

COTR Training Requirements 

List A: Technical Courses List B: Business Courses 

Course 

Number 

Course Title CLPs Course 

Number 

Course Title CLPs 

CLM 024 Contracting Overview 8 CLM 012 Scheduling 12 

CLC30 106 Contracting Officer’s 

Representative with a 

Mission Focus 

8 CLM 014 IPT Management and 

Leadership 

8 

CLC 004 Market Research 3 CLM 016 Cost Estimating 8 

CLC 007 Contract Source Selection 3 CLM 017 Risk Management 8 

CLM 003 Ethics Training for 

Acquisition Technology 

and Logistics 

2 CLB 013 Work Breakdown 

Structure 

6 

TOTAL 24 CLB 016 Intro to Earned Value 

Management 

1 

CLB 018 Earned Value and 

Financial Management 

Reports 

Source: FEMA intranet. 

Once the training is complete, employees are instructed to fax or email scanned 

training certificates to COTR headquarters to be processed. After 48 hours, their 

updated status will be posted on the COTR list alphabetically. 

Biennial Training Requirements 

To maintain certification, COTRs are required to obtain 40 hours of continuous 

learning training every 2 years: 

Twenty-two hours must cover essential COTR technical competencies. 
 

Eighteen hours must cover business competencies. 
 

Two hours must cover procurement ethics.
 


30 CLC = continuous learning contracts. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 25 
Appendix C 

COTR Training Requirements 

Biennial Maintenance Training (Every 2 Years) 

Technical Competencies = 

22 hours 

Business Competencies = 

18 hours 

Ethics = 

2 hours 

Total = 

40 hours 

Source: FEMA intranet. 

COTRs have two options to complete their biennial requirement: 

Complete all 40 hours and submit as one package, or 

Submit the minimum requirement for the first year, 12 hours plus 1 hour 

of ethics, and remaining hours by the end of the biennial period for a total 

of 40 hours. 

COTRs may receive also CLPs for Technical Evaluation Panel participation, 

conferences, and brown-bag training. 

COTRs who fail to complete their biennial requirement by the biennial 

maintenance due date will be required to complete 40 hours of COTR training in 

order to be reinstated. Failure to meet this requirement may result in the 

revocation of COTR certification. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 26 
 

Appendix D 

Primary COTR Appointment Letter 

Primary COTR Appointment Letter 

COMPONENT 

Insert Component Name 

Program Office Employee 

Insert Program Office Name Insert Employee Name 

Telephone Location 

Insert telephone number Insert location 

Dear Insert employee name, 

You are hereby appointed as the Contracting Officer’s Technical Representative (COTR) for DHS Office of 

Procurement Operations Agreement/ Contract number: Insert Agreement/Contract number for the amount of 

Insert contract dollar amount, awarded to Insert name of contractor/awardee organization effective Insert effective 

date. 

Insert Agreement/Contract Number is a: (check one below) 

ᆕ Contract ᆕ Purchase Order ᆕTask Delivery Order 

ᆕ Cooperative Agreement ᆕGrant ᆕMemorandum of Understanding (MOU) 

ᆕ Interagency/Intra-agency Agreement 

Under this COTR appointment, you are assigned responsibilities to assist the Contracting 

Officer in the administration of the Agreement/ Contract referenced above. This appointment remains in effect for 

the duration of the business agreement, as long as your COTR certification remains current. This appointment can 

only be changed or rescinded in writing by the Contracting Officer. 

Please carefully review the explanation of COTR authority and responsibilities herein and sign the last page of 

this document acknowledging your understanding and acceptance of this COTR appointment. After signing the 

last page of the COTR appointment letter, please return it to the DHS OPO Division within ten (10) calendar 

days. 

SCOPE OF AUTHORITY 

I, Insert COTR Name, understand and agree that: 

1. 	 The DHS Office of Procurement Operations Contracting Officer is the only agent with authority to enter into 

and administer business agreements. I have been delegated the authority to monitor delivery and performance 

under the business agreement as the Contracting Officer’s Technical Representative. Other than the 

Contracting Officer, or the alternate COTR acting in my absence, I am the duly appointed Government 

employee assigned to provide technical direction for the business agreement between the Government and the 

Contractor. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 27 
 

 

 

Appendix D 

Primary COTR Appointment Letter 

2. 	 This appointment does not change or supersede the established line of authority and/or responsibility of any 

organization. 

3. 	 I shall notify the Contracting Officer immediately if I am unable to fulfill the responsibilities of this position 

for an extended period. 

4. 	 I shall protect the Government’s interests while performing my COTR duties. I must avoid any action that 

places me in a real or apparent conflict of interest that may compromise security or impair public confidence 

in the integrity of DHS. 

5. 	 I have read DHS Management Directive 0480.1, Ethics /Standards of Conduct, and discussed any questions I 

have regarding my understanding of the duties and obligations under this policy. 

COTR RESPONSIBILITIES 

1.		 PREPARATION 

a.		 The COTR must be knowledgeable of the terms and conditions, as well as the technical content in the 

business agreement. To understand the terms, the COTR must read the business agreement and discuss 

any unclear areas with the Contracting Officer. The following is a list of topics in the Agreement that the 

COTR is expected to understand and manage: 

Business Agreement Type Performance Standards 81 Metrics
 


Invoicing Procedures Security Requirements
 


Packaging and Markings Inspection, Acceptance, and Special Clauses
 


Quality Assurance Ordering Procedures
 


Reports & Deliverable Items Time, Place and Method of Delivery or Performance 
 

Government Furnished Assets and Information 
 

b. While the official contract/agreement file is maintained by the Contracting Officer, the COTR must create 

and maintain a file to document COTR actions under this business agreement. The file should include: 

A complete copy of the business agreement, a copy of the COTR Letter of Appointment; 

Copies of any related correspondence; 

Record of any significant telephone conversations or other communications with the 

Contractor; 

Signed invoices; 

All records of the Contractor’s performance, such a performance monitoring, inspection 

and service reports and other documents as applicable. 

c.		 In order to effectively monitor delivery and performance, the COTR must read and become very familiar 

with the business agreement’s schedule for performance standards and metrics, deliveries, completion 

dates, invoice due dates, option renewal dates and other report or data submission dates. The COTR must 

also establish a log or tracking system. 

2.		 GENERAL ADMINISTRATION INFORMATION 

a.		 Determine the need, and ensure all requirements are met for Contractor badges, background checks, and 

all other required clearances. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 28 
Appendix D 

Primary COTR Appointment Letter 

b. Plan and coordinate as necessary with the Insert local facilities managers, real estate personnel or 

appropriate points of contact for the component. 

c. Obtain and maintain a list of employees who will be working at the Insert appropriate information 

facility. Keep list current by making adjustments for new and terminated employees. This is important to 

the security of the facility. This list may be used to initiate background checks by the security office in the 

relevant location. 

d. Coordinate with the Contracting Officer to ensure all Contractors (and subcontractor as applicable) have 

signed nondisclosure forms, as prudent or required. 

e. Safeguard the Contractor’s confidential business and technical information. Confidential information may 

include proposal pricing, technical documentation, or personnel data. Do not release any information 

without first consulting with the Contracting Officer to determine if release of such information is 

permissible. 

f. Maintain communications with the Contractor and the Contracting Officer. Meet with the Contractor or 

his/her designated representative at the beginning of the business agreement period of performance to 

discuss working methods. Also, serve as the contact through which the Contractor can relay questions and 

problems to the Contracting Officer. 

g. Ensure all Contractor personnel identify themselves and their company affiliation in all communications 

(written, telephonic, and electronic) related to the business agreement. 

h. Monitor the Contractor’s compliance with safety, security, labor and environmental law requirements. 

i. Report any observed fraud, waste, or opportunities to improve performance or cost efficiency to the 

Contracting Officer. 

j. Provide independent government cost estimates (IGCEs) and other supporting information as required by 

the Contracting Officer when changes to the business agreement are required. 

k. Assist the Contracting Officer in negotiating supplemental agreements and coordinating with related 

Contractors on other business arrangements. 

l. Write an evaluation of the Contractor’s technical performance at least annually and at the end of 

performance or delivery. If a specific form is required, it will be provided by the Contracting Officer. 

m. Keep the Contracting Officer fully informed of any technical, administrative or contractual difficulties 

encountered during performance and make recommendations as appropriate. 

n. Seek guidance from the Contracting Officer for specific situations not covered in this delegation. 

3.		 MONITORING AND SURVEILLANCE 

a.		 Perform surveillance of the performance under the business agreement and conduct inspections necessary 

to assure performance and compliance with the terms and conditions of the agreement. Resolve day-today matters within the scope of your authority. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 29 
Appendix D 

Primary COTR Appointment Letter 

b.		 Assist the Contractor in interpreting the terms and conditions or performance requirements, provided that 

any interpretation or clarification is within the limitations prescribed within this delegation. 

c.		 Immediately bring to the Contractor’s attention, any potentially hazardous working conditions. The 

Contractor is always required to comply with Federal Occupational Safety and Health Administration 

(OSHA) guidelines, applicable labor and environmental laws, as well as any state or local requirements 

for workplace safety, whether in a Federal facility or other location. In addition, ensure that the 

Contractor adheres to any specific safety clauses and/or the safety plan in the business agreement. 

d.		 Immediately alert the Contracting Officer to any possible Contractor deficiencies or questionable 

practices so that corrections can be made before the problems become significant. Advise the Contracting 

Officer of the following situations: 

Possible changes in Contractor management and/or key personnel;
 


Potential labor disputes or workforce problems; 
 

Disagreements with the Contractor regarding performance of statement of work/objectives 
 

(SOW/SOO) requirements or other potential disputes with the Contractor about technical or other 
 

business matters; 
 

Lack of performance that may jeopardize the cost or required schedule of the business agreement.
 


e.		 Review Contractor requests for travel, overtime, Government assets, or subcontracting in a timely manner 

and forward to the Contracting Officer for approval. 

f. Review and analyze the Contractor’s deliverables, service, and management reports. 

g.		 Provide feedback on Contractor performance as input to the past performance data base or as otherwise 

requested by the Contracting Officer. 

4.		 INSPECTION AND ACCEPTANCE 

a.		 Inspect deliverables and monitor services for conformance to the performance standards, and accept or 

reject them. 

b.		 Follow the guidance within the business agreement regarding inspection and acceptance. 
 

If there are any questions, contact the Contracting Officer. 
 

FEMA’s Contracting Officer’s Technical Representative Program 

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Appendix D 

Primary COTR Appointment Letter 

5.		 INVOICES AND PAYMENT 

a.		 See clause Insert appropriate clause for processing of invoices and adhere to those conditions. 

b.		 Report any discrepancies in payment vouchers to the Contracting Officer. Provide documentation to 

support the representation. 

c.		 Evaluate progress payment requests based on costs incurred and actual work accomplished. 

d.		 Review Interim Cost Vouchers: If this is a cost reimbursable agreement, the Contractor is entitled to be 

reimbursed periodically for all reasonable costs incurred in performing the business agreement. You 

should review such vouchers to make sure charges are commensurate with observed performance. It is 

your responsibility to question or concur with direct charges such as labor, materials, travel, etc. Alert the 

Contracting Officer if the billing includes material or equipment charges for items that have not been 

delivered to the work site. The Contracting Officer is responsible for verifying correctness of indirect 

rates, fringe benefits and fee, if any. 

6.		 GOVERNMENT FURNISHED ASSETS: EQUIPMENT, MATERIALS AND FACILITIES 

a.		 Do not authorized to provide any Government-owned (or leased) equipment or supplies or use of 

Government space to the Contractor, other than those specifically identified in the business agreement 

and authorized by the Contracting Officer. 

b.		 Monitor the Contractor’s use and care of any Government-furnished assets. If you believe the Contractor 

is using the item for unauthorized purposes or is not providing adequate maintenance or security for the 

property, you are required to bring your concerns to the Contractor’s attention. If the Contractor does not 

agree to remedy the problem, or indicates that corrective action will impact the cost, performance or 

schedule, refer the matter to the Contracting Officer. 

c.		 Coordinate with the Insert POC Name regarding the completion of all required documentation for the 

acceptance, use and return of Government-furnished assets. 

d.		 Assist the Insert POC Name with the disposal of excess Government furnished assets and/or Contractor 

acquired assets. 

e.		 Assist the Insert POC Name with the valuation of lost, damaged and destroyed Government furnished 

assets and/or Contractor acquired assets. 

f.	 Alert the Insert POC Name and the Contracting Officer to any potential or existing Government asset 

issues. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 31 
 

Appendix D 

Primary COTR Appointment Letter 

7.		 CONFLICT OF INTEREST AND STANDARDS OF CONDUCT 

a.		 The COTR is required to complete an Office of General Counsel (OGC) ethics training course annually. 

Upon completion of the annual ethics training, the COTR shall submit documentation (e.g., certificate or 

e-mail) to the Contracting Officer indicating the annual ethics training requirement has been met. 

b.		 In order to maintain DHS COTR Certification, one (1) hour of procurement ethics training is required 

annually per MD 0780.1. 

c.		 If applicable, the COTR appointee must submit a disclosure, such as a Statement of Financial Interest and 

Outside Employment or Financial Disclosure Report, to the appropriate DHS confidential reporting 

system. 

d.		 COTR appointees must adhere to standards of conduct as prescribed in Federal statutes, laws, regulations, 

and Departmental guidelines. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 32 
 

Appendix D 

Primary COTR Appointment Letter 

8. EXCLUSIONS FROM COTR RESPONSIBILITIES 
 

The COTR is expressly excluded from performing or being responsible for the following. 
 

a. Making or giving the appearance of being able to make commitments, modifications, or any other action 

that would commit the Government to a change in price, performance quality, quantity, or the delivery 

schedule. 

b. Providing guidance to the Contractor, either orally or in writing, which might be interpreted as a change 

in the scope or terms of the business agreement. 

c. Signing any changes or modifications to business agreements and/or task or delivery orders. 

d. Specifying how the Contractor will accomplish performance. 

e. Imposing or placing a demand upon the Contractor to perform any task or permitting any substitution not 

specifically provided for in the business agreement. 

f. Increasing the dollar limit of the business agreement or authorizing expenditures not specified under the 

business agreement. 

g. Engaging in conduct prejudicial to the Government. 

h. Making a Government decision outside official channels. 

i. Discussing procurement plans or any 

preferential treatment to one firm. 

other advance acquisition information that might provide 

The responsibilities, and exclusions set forth in this document are not Intended to be a encompassing. As a COTR, 

you are required to consult with the Contracting Officer when there are questions on your authority. You are not 

authorized to re-delegate your authority. Violation or misuse of your authority could result in abuse of DHS 

policy and resources at a minimum or monetary loss to the COTR or firm involved, disciplinary actions, and 

other measures, depending on the extent of the offense. 

Contracting Officer Typed Name and Signature Date 

The undersigned acknowledges the COTR appointment on Agreement/Contract Number: Insert 

Agreement/Contract Number and accepts the duties, responsibilities and limitations described in the appointment 

letter. 

The Contracting Officer reserves the authority to cancel COTR appointments in accordance with HS AM, Chapter 

3001. 

COTR Acknowledgment: 

I, Insert COTR Name, have read the COTR appointment letter herein for Agreement/Contract Number Insert 

Agreement/Contract Number and fully understand my responsibilities and the limits of my authority. I further 

understand that my performance as a COTR will be evaluated and documented on an annual basis by the 

Contracting Officer. I certify that I have taken the required training to obtain the DHS Acquisition Certification 

FEMA’s Contracting Officer’s Technical Representative Program 

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_ ________________________ __ _ 

 

 

Appendix D 

Primary COTR Appointment Letter 

for COTRs or have received a waiver. In addition, I certify that I will take the mandatory skills currency training 

to maintain my certification during the duration of this appointment. 

_________________________ 

Signature 

__ _ 

Date 

Supervisor Acknowledgment: 

I, Insert COTR Supervisor’s Name, have read the COTR appointment letter herein and fully understand, support 

and approve my employee’s responsibilities and limitations as a COTR under the above referenced contract. 

Signature & Title Date 

Return no later than fill in date to: Include Fax Number, e-mail or mailing address 

U.S. Department of Homeland Security – Federal Emergency Management Agency – Acquisition Management Division 

COTR Program – 395 E Street SW – Washington, DC 20024 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 34 
 

Appendix E 

COTR Locations 

FEMA Regions 

Source: FEMA. 

COTRs in Each Region 

Region COTRs 

Headquarters 360 

Region I 16 

Region II 19 

Region III 30 

Region IV 47 

Region V 16 

Region VI 103 

Region VII 20 

Region VIII 28 

Region IX 16 

Region X 6 

Other 242 

Source: OIG survey results. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 35 
 

Appendix F 

Survey Results 

As a part of our audit, we forwarded a survey to all COTRs and contracting officers. We 

obtained a list of the names and email addresses of all COTRs and contracting officers 

from FEMA. Each individual was sent an email with information about the survey, and 

an individualized link for them to use for access to the survey. The initial invitation was 

sent out November 17, 2010, and the survey was closed in March 2011. Periodically 

after the initial invitation, reminders were sent to those who did not complete the survey. 

The results of the survey follow: 

Overall Results: Of the 1,710 people to whom the survey was initially forwarded: 

554 people received the survey and did not respond. 

7 people had undeliverable invitations. 

118 invitations bounced back. 

77 people opened the survey invitation but did not start the survey. 

82 people started the survey but did not submit it.31 

872 people completed the survey. 

Survey Questions: 

Question 1: Please select your primary work location 

Results: 

The four regions with the greatest number of COTRs and contracting officer s 

are as follows: 

360 individuals at headquarters 

242 individuals at other locations (i.e., Mt. Weather, Louisiana 

Transitional Recovery Office, National Processing Service Centers) 

103 individuals in Region VI 

47 individuals in Region IV 

Region X, with six individuals, has the smallest number of COTRs and 

contracting officers. 

Question 2: Which of the following best describes your role within FEMA’s COTR 

Program? 

Results: 

469 answered active DHS-certified COTRs. 

296 answered DHS-certified COTRs but have not been active in the last 2 

years. 

60 answered active contracting officers. 

26 answered not active contracting officers. 

8 answered both DHS-certified COTRs and contracting officers. 

39 answered neither DHS-certified COTRs nor contracting officers. 

31 For the purposes of this analysis, we included answers provided by respondents who started the survey 

but did not submit it. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 36 
 

 

Appendix F 

Survey Results 

Question 3: How many years of experience do you have as a contracting officer? 

Results: 
 

25 had 10 years of contracting officer experience. 
 

10 had 6 to 9 years of contracting officer experience. 

8 had 3 to 6 years of contracting officer experience. 

12 had fewer than 3 years of contracting officer experience. 

Question 4: What level warrant do you hold? 

Results: 

53% hold a level III warrant. 

15% hold a level II warrant. 

7% hold a level I warrant. 

12% were unaware of their warrant levels. 

Question 5: As a contracting officer, how many contracts are you currently 

responsible for? 

Results: 

56% of respondents oversaw anywhere from 1 to 25 contracts. 

30% of respondents oversaw 25 or more contracts. 

13% of respondents oversaw no contracts. 

Question 6: Are you aware of the process for appointing COTRs to contracts? 

Results: 

5% indicated that contracting officers select their own COTRs. 

69% indicated that their program office nominates the COTRs. 

12% indicated that it is just their program office that does the selecting 

and approving. 

5% were completely unaware of the COTR selection process. 

Question 7: As a contracting officer, how frequently do you use each of the following 

forms of communication? 

Results: 

The majority of contracting officers indicated that they use email and the 

phone. 

The form of communication least used was postal service. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 37 
 

 

 

Appendix F 

Survey Results 

Question 8: When a COTR has committed an infraction against their roles and 

responsibilities, what corrective action(s) is taken to address the 

infraction? 

Results: 

62% said they would utilize options outlined in the 

Revocation/Termination of COTR Certification Standard Operating 

Procedure. 

52% said they would reach out to the program office to nominate a 

replacement COTR. 

48% said they would seek assistance from the COTR program. 

23% said they would immediately terminate the appointment. 

2% said they would do nothing. 

18% said they would do something other than the options provided. 

Question 9: How many of your contracts currently have COTRs appointed? 

Results: 

40% of the contracting officers said that all of their contracts currently 

have COTRs appointed to them. 

28% said that most of their contracts have COTRs. 

12% said that half of their contracts have COTRs. 

12% said that only some of their contracts have COTRs. 

7% said that none of their contracts have COTRs. 

Question 10: On any single contract, do you have more than one COTR appointed 

at the same time? 

Results: 

63% have only one COTR per contract. 

Question 11: How many years of experience do you have as a Contracting Officer’s 

Technical Representative? 

Results: 

180 COTRs had fewer than 3 years of experience as a COTR.
 


150 had 3 to 6 years of experience. 
 

45 had 6 to 9 years of experience. 
 

75 had more than 9 years of experience.
 


FEMA’s Contracting Officer’s Technical Representative Program 

Page 38 
 

 

Appendix F 

Survey Results 

Question 12: What level of certification have you achieved and are currently certified? 

Results: 

Tier I: 211 people 

Tier II: 51 people 

Tier III: 73 people 

125 COTRs did not know what certification level they were. 

Question 13: When questions arise while performing my COTR duties, I use the 

following sources as guidance: 

Results: 
 

86% go to the contracting officer. 
 

43% use hard copies of guidance at their desks. 
 

41% go to their supervisors in their program office.
 


8% go to the contractor (the least used resource). 
 

Question 14: As a COTR, how many contracts are you currently responsible for? 

Results: 
 

75% are currently responsible for 1 to 5 contracts.



1.73% are responsible for 25 or more contracts. 
 

15.55% are not responsible for any contracts. 
 

Question 15: How many of your contracts currently have task monitors assigned? 

Results: 

70% of respondents did not have any contracts with task monitors 

assigned. 

14% stated that all of their contracts have task monitors assigned. 

16% fell somewhere in between the two and had anywhere from some to 

most of their contracts assigned task monitors. 

Question 16: On any single contract, do you have more than one task monitor 

assigned? 

Results: 

85% of COTR respondents indicated that they do not have more than one 

task monitor assigned to their contracts. 

15% said they do have more than one task monitor on a single contract. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 39 
 

 

 

 

 

Appendix F 

Survey Results 

Question 17: When contacting your contracting officer, how frequently do you use 

the following forms of communication? 

Results: 

About 240 COTRs indicated that they use email most often to 

communicate with their contracting officer. 

About 75 COTRs use the telephone. 

The least used form of communication was the postal service. 

Question 18: How would you rate your contracting officer’s responsiveness to emails? 

Results: 

About 225 COTRs found their contracting officers to be extremely 

responsive to their emails. 

Almost 200 found the contracting officers to be responsive to emails. 

Fewer than 50 said their contracting officers are nonresponsive to emails. 

Question 19: How often do you meet (telephone or in person) with your contracting 

officer to discuss the progress of your contract? 

Results: 

Only about 9%, or 43 COTRs, stated that they meet with their contracting 

officer via telephone or in person very often to discuss the progress of 

their contract. 

Almost 50% stated that they meet sometimes via telephone or in person 

with their contracting officer to discuss progress. 

About 19% stated that they never meet with their contracting officer to 

discuss the progress of their contract. 

Question 20: Have you received a copy of your COTR appointment letter from the 

contracting office? 

Results: 

85% of respondents indicated that they did receive a copy of their COTR 

appointment letter from their contracting officer. 

15% indicated that they had not received an appointment letter. 

Question 21: Were you involved in the pre-award phase of the contract? 

Results: 

59.8% of COTRs were involved in the pre-award phase of the contract. 

40% were not involved. 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 40 
 

 

 

Appendix F 

Survey Results 

Question 22: How effective do you find each of the following areas of FEMA’s 

COTR Program? 

Results: 

FEMA COTR Program Training 

About 250 people found it to be effective. 

100 people found it to be not very effective. 

100 people found it to be very effective. 

About 20 people found it to be not effective at all. 

FEMA COTR Program Policy and Procedure 
 

More than 250 people found it to be effective. 
 

About 100 found it to be not very effective. 
 

Close to 90 found it to be very effective. 
 

Fewer than 20 found it to be not effective at all. 
 

Overall FEMA COTR Program 
 

Close to 300 people found it to be effective.



About 100 said it was not very effective.
 


Fewer than 100 said it was very effective. 
 

About 10 said it was not effective at all. 
 

Question 23: In the last 2 years, have you experienced any of these challenges with 

FEMA’s COTR Program? 

Results: 

38% of all respondents (COTRs and contracting officers) experienced 

challenges with unclear policy and procedure. 

36% experienced challenges with a lack of communication. 

30% identified other challenges that were not presented as options. 

27% said conflict between COTR responsibilities and program office 

duties was a challenge. 

16% said they experienced excessive pressure from the program office. 

10% experienced conflict between new contractors and existing 

contractors who are proven performers (the least common challenge). 

Question 24: What improvements would you like to make to FEMA’s COTR 

Program? 

Results: 

Top three categories of responses: 

Training (i.e., more training, less training, more FEMA-related training) 

Communication 

Policy, procedure, and guidance 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 41 
Appendix F 

Survey Results 

Question 25: Please feel free to leave any additional comments or concerns: 

Results: 

A few of the topics shared included comments about or concerns with the 

following: 

Training 
 

Making COTRs a full-time position
 


The COTR website 
 

Policy and Procedure 
 

Consistency within the program 
 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 42 
Appendix G 

List of Related Reports 

Department of Homeland Security Office of Inspector General 

Improvement Needed in FEMA’s Management of Public Assistance-Technical 

Assistance Contracts, OIG-11-02, October 2010 

Improvement Needed in FEMA’s Management of the National Flood Insurance 

Program’s Information Technology Transition, OIG-10-76, March 2010 

Improvements Needed in FEMA’s Disaster Contract Management, OIG-10-53, 

February 2010 

FEMA’s Temporary Housing Unit Program and Storage Site Management, 

OIG-09-85, June 2009 

Federal Protective Service Contract Guard Procurement and Oversight Process, 

OIG-09-51, April 2009 

Challenges Facing FEMA’s Disaster Contract Management, OIG-09-70, 

May 2009 

Internal Controls in the FEMA Disaster Acquisition Process, OIG-09-32, 

February 2009 

Hurricane Katrina Temporary Housing Technical Assistance Contracts, 

OIG-08-88, August 2008 

Acquisition Workforce Training and Qualifications, OIG-08-56, May 2008 

FEMA’s Preparedness for the Next Catastrophic Disaster, OIG-08-34, 

March 2008 

Challenges Facing FEMA’s Acquisition Workforce, OIG-09-11, November 2008 

Improper Payments Assessment Disaster Relief Fund Vendor Payments, 

Fiscal Year 2009, October 2007 

An Audit of FEMA’s Acquisition Workforce, OIG-04-12, March 2004 

Government Accountability Office 

National Flood Insurance Program: Continued Actions Needed to Address 

Financial and Operational Issues, GAO-10-631T, April 2010 

National Flood Insurance Program: Financial Challenges Underscore Need for 

Improved Oversight of Mitigation Programs and Key Contracts, GAO-08­

437, June 2008 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 43 
Appendix G 

List of Related Reports 

Ineffective FEMA Oversight of Housing Maintenance Contracts in Mississippi 

Resulted in Millions of Dollars of Waste and Potential Fraud, GAO-08-106, 

November 2007 

Miscellaneous Documents 

Federal Acquisition Institute: 2008 Acquisition Workforce Competencies Survey 

Results Report and Survey Content, 2008 

Federal Emergency Management Agency: FEMA’s Strategic Plan: Fiscal Years 

2008–2013, January 2008 

Federal Emergency Management Agency: FEMA Contracting Enhancements and 

Improvements Post Katrina, FEMA Press Release, 2007 

Merit Systems Protection Board: Contracting Officer’s Representatives: 

Managing Government’s Technical Experts to Achieve Positive Contract 

Outcomes, U.S. Merit Systems Protection Board, December 2005 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 44 
Appendix H 

Major Contributors to this Report 

Donald Bumgardner, Director 

Trudi Powell, Audit Manager 

Eric Young, Audit Manager 

Alexandra Vega, Program Analyst 

Meredith Needham, Program Analyst 

Puja Patel, Program Analyst 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 45 
 

Appendix I 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

FEMA GAO/OIG Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

FEMA’s Contracting Officer’s Technical Representative Program 

Page 46 
ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.