Contracting Officer
CO / KO
Also known as: KO, PCO (procuring contracting officer), ACO (administrative), TCO (termination)
Sits on: Buying agency
At a Glance
- Works for
- The buying agency's contracting activity
- Authority
- A written warrant (SF 1402) up to a stated dollar limit
- When you deal with them
- From solicitation questions through award, administration, and closeout
- Can bind the government?
- Yes — the CO is the only one who can
- Governing authority
- FAR 1.602-1 (authority), FAR 1.602-2 (responsibilities)
Who They Are
A Contracting Officer, often abbreviated CO or KO, is the single federal official the law entrusts with the power to enter into, administer, and terminate government contracts on behalf of the United States. That power comes from a written warrant — Standard Form 1402, the Certificate of Appointment — that states the dollar limit and any conditions on the CO's authority. Under FAR 1.602-1, no contract commitment is binding unless it is made or ratified by a warranted CO acting within that authority, which is why a good idea from a program manager, an engineer, or even a Contracting Officer's Representative is worth nothing until the CO puts it on paper. FAR 1.602-2 makes the CO responsible for ensuring that contractors receive impartial, fair, and equitable treatment, for safeguarding the interests of the United States, and for requesting and considering the advice of specialists — legal, audit, small-business, and technical — as appropriate. In larger agencies the role is split: a procuring contracting officer (PCO) runs the buy and makes the award, an administrative contracting officer (ACO) handles the contract after award, and a termination contracting officer (TCO) settles terminations. All three are the same warranted authority, just at different stages.
When You Deal With Them
- During the solicitation — questions, amendments, and the pre-proposal conference all run through the CO.
- At proposal submission — the CO (or the contract specialist on the CO's behalf) receives and evaluates your offer.
- At award — the CO signs the contract; the CO's signature is what makes it binding.
- During performance — changes, modifications, invoicing disputes, and interpretation questions are the CO's call.
- At the end — the CO issues the contracting officer's final decision on any claim and closes the contract out.
What They Do
| Responsibility | What It Means |
|---|---|
| Binds the government | Only a warranted CO can obligate federal money and sign a contract. Directions from anyone else — even to 'just start the work' — are unauthorized and may not be paid unless the CO ratifies them. |
| Runs the competition fairly | The CO must give every offeror impartial, fair, and equitable treatment, keep proposal information confidential, and make the award consistent with the solicitation's stated evaluation scheme. |
| Makes the responsibility determination | Before award the CO must affirmatively find the apparent winner responsible — financially capable, with the resources and integrity to perform — under FAR 9.104-1. |
| Issues the final decision | Under the Contract Disputes Act, the CO decides claims in a written 'contracting officer's final decision,' which is what starts the clock to appeal to a board of contract appeals or the Court of Federal Claims. |
| Designates the COR | The CO appoints the Contracting Officer's Representative in writing (FAR 1.602-2(d)) and defines — and limits — what the COR may do on the contract. |
What It Means for an SDVOSB
For an SDVOSB, the Contracting Officer is both the gatekeeper and the decision-maker. The CO decides whether to set an acquisition aside for SDVOSBs (applying the 'rule of two' — a reasonable expectation of two or more capable SDVOSBs at a fair price), verifies your certification in SAM.gov/VetCert at the time of the initial offer, makes the responsibility determination, and signs the award. Everything you want — a set-aside instead of full-and-open, a fair evaluation, a timely payment, a favorable modification — the CO has to sign off on. Just as important: only the CO can change your contract. If a COR, an inspector, or a program manager tells you to do extra work, do not do it on that say-so alone; get the CO's written direction or a modification, or you may perform out-of-scope work you will never be paid for. Build a professional, documented relationship with the CO, put questions in writing, and keep the CO informed — the CO's affirmative responsibility determination is also the last thing standing between you and award if a competitor challenges you.
Watch Out For
- 'Unauthorized commitments' — work directed by anyone without warrant authority may go unpaid unless the CO formally ratifies it. Get direction in writing from the CO.
- Assuming a warrant is unlimited — a CO's authority is capped at the dollar figure on the SF 1402; above it, a higher-level CO must act.
- Treating the COR as the CO — the COR monitors performance but cannot change price, scope, schedule, or terms.
- Missing the CO's final decision deadline — once the CO issues a final decision on your claim, a strict appeal clock starts (90 days to a board, 12 months to the Court of Federal Claims).
Run the Numbers
Frequently Asked
What does a contracting officer do?
A contracting officer (CO or KO) is the only federal official with the legal authority to enter into, administer, and terminate a contract and to obligate government money. That authority comes from a written warrant (Standard Form 1402) with a stated dollar limit. Under FAR 1.602-2 the CO runs the competition fairly, makes the responsibility determination before award, signs the contract, administers changes and payments, and issues the contracting officer's final decision on any claim. No commitment binds the government unless a warranted CO makes or ratifies it.
Can anyone besides the contracting officer change my contract?
No. Only the warranted contracting officer can modify a federal contract's price, scope, schedule, or terms. A Contracting Officer's Representative (COR), inspector, program manager, or technical point of contact can monitor and communicate, but they cannot direct changes or bind the government. If someone without warrant authority tells you to do additional work, it is an 'unauthorized commitment' and may not be paid unless the CO formally ratifies it — always get the CO's written direction or a signed modification first.
Who decides whether a contract is set aside for SDVOSBs?
The contracting officer decides. Applying the 'rule of two,' the CO sets an acquisition aside for SDVOSBs when there is a reasonable expectation that offers will be received from two or more capable SDVOSBs and that award can be made at a fair market price. The CO's decision is reviewed by the agency's small business specialist and, for larger buys, the SBA Procurement Center Representative, who can recommend a set-aside and appeal a decision not to set one aside.
Primary Sources
- FAR 1.602-1 — Authority (contracting officers)
- FAR 1.602-2 — Responsibilities
- FAR 1.603 — Selection, appointment, and termination of appointment
- FAR 9.104-1 — General standards (responsibility)
Plain-English reference, not legal advice. Federal roles are reorganized and their titles and reporting lines change over time, and the FAR/CFR sections that define them are amended from time to time — always confirm the current role, its authority, and the governing citation against the official source and the actual solicitation before relying on it, and consult qualified counsel for your specific situation.
Change log (1)
- LaunchedPublished the federal contracting roles & officials reference covering the people an SDVOSB deals with across a set-aside — the contracting officer (FAR 1.602), contract specialist (FAR Part 1), contracting officer's representative (FAR 1.604), source selection authority (FAR 15.303), OSDBU director (15 U.S.C. § 644(k)), small business specialist (FAR 19.201), SBA procurement center representative (FAR 19.402), SBA commercial market representative (FAR 19.402(e)), SBA Area Office size specialist (13 CFR § 121.1001), SBA Office of Hearings and Appeals judge (13 CFR Part 134), competition advocate (FAR 6.501), task- and delivery-order ombudsman (FAR 16.505(b)(8)), and APEX Accelerator counselor (10 U.S.C. §§ 4951–4955) — each with an at-a-glance quick-facts card, a when-you-deal-with-them list, a responsibilities table, an SDVOSB-specific angle, watch-outs, FAQPage, Article, Dataset, and BreadcrumbList structured data, primary-source citations, and cross-links into the glossary, how-to guides, forms, clauses, FAQ, and the set-aside eligibility, size-standard, win-probability, price-to-win, and subcontracting calculators.