Administrative Contracting Officer vs. Procuring Contracting Officer (ACO vs. PCO)

The procuring contracting officer (PCO) awards the contract and keeps every function not delegated; the administrative contracting officer (ACO) performs the postaward functions FAR 42.302 assigns, working from a contract administration office (in DoD, DCMA). FAR 2.101 defines the ACO; PCO is shorthand, not a FAR-defined term.

FAR 2.101 defines a contracting officer as a person with authority to enter into, administer, or terminate contracts, then names two specialties: the administrative contracting officer, who administers, and the termination contracting officer, who settles terminations. The FAR never defines a procuring contracting officer. PCO is shorthand for the awarding contracting officer; DFARS uses the phrase in spots such as 242.302(b)(S-71). FAR 2.101 adds that one person can hold all three roles.

The split happens under FAR 42.202. The PCO delegates administration to a contract administration office, and 42.302(a) lists the functions that transfer by default, from forward pricing rate agreements to property administration. The PCO may withhold any of them in the delegation. The 42.302(b) functions, such as negotiating supplemental agreements for change orders, go to the ACO only when the delegation authorizes them in writing, and anything unlisted stays with the PCO under 42.302(c). In DoD, DFARS 242.202 bars activities from retaining contracts that need administration at or near the contractor's plant, and the DoD overhaul deviation text names DCMA as the office that administers them.

The friction point is scope. Contractors bring schedule and price questions to the ACO they see every week, and an ACO who agrees to a change the delegation did not cover has acted past the authority FAR 1.602-1 allows. Read the delegation before answering.

Regulatory Reference

FAR 2.101; FAR 1.602-1; FAR 42.202; FAR 42.302; DFARS 242.202; DFARS 242.302

RFO Status

The Part 42 model deviation keeps the 42.202 delegation mechanics and the full 42.302 function lists, adding text that the contracting officer may retain any paragraph (a) function except the four reserved to the cognizant Federal agency (forward pricing rate agreements, final indirect cost rates, Cost Accounting Standards administration, and accounting system adequacy); DoD adopted the model text with DFARS 242 through class deviation 2026-O0050 effective March 6, 2026, and Part 42 was not among the parts in the four proposed rules published June 23, 2026.

Category

Processes & Methods

How AcqBot Helps

AcqBot reads the delegation letter and the contract's clause set and tells the ACO which 42.302 functions are theirs, which were withheld, and which need written authorization from the PCO before acting on a contractor's request; on the PCO side it drafts the delegation with withheld and added functions spelled out the way 42.202(a) requires.