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Change Number: Change 175 GSAR Case 2022-G519
Effective Date: 02/15/2024

Subpart 537.5 - Management Oversight of Service Contracts

Subpart 537.5 - Management Oversight of Service Contracts

537.504 Contracting officials' responsibilities.

(a) Below is a non-exhaustive list of techniques the acquisition team can use to effectively manage and oversee service contracts, while avoiding the appearance of prohibited personal service contracts described in FAR 37.104(d)—

(1) Identification. Have contractor staff clearly identify themselves as contractors in both email signature lines and identity badges.

(2) Communication of roles and responsibilities. During the contract kickoff meeting let the contractor and their personnel know how work assignments will be communicated and who should be included in the communication.

(3) Clear terms and conditions. Clearly define performance roles, expectations, and deliverables in the terms and conditions of the contract. Have terms and conditions specify that the contractor supervise their staff onsite when feasible.

(4) Contract type. Firm fixed price (FFP) contract type is preferable for work performed that could have the appearance of personal services, since other contract types require more Government oversight which could lead to the appearance of personal services; however all contract types are susceptible to perceptions that can prompt personal services.

(5) Limit who can assign work. Contractor assignments should be communicated by the contracting officer, or COR, directly to one representative for the contractor (such as a contractor's team lead or program manager).

(6) Avoid ad hoc work assignments. Avoid ad hoc work assignments which can create a personal services relationship, and may also cause "scope creep" to the contract, which places the Government at risk of a future claim.

(7) Do not provide managerial or administrative support to contractors. To avoid the appearance of personal services, do not approve contractor staff's performance plans or leave.

(8) Computer system access. Avoid personal services by limiting the electronic systems, and roles within systems, that contractors may have access to (e.g., do not provide approval access in any system in which there may be an obligation of funds, such as a contract writing system).