Introduction
Navigating the complex landscape of federal procurement requires understanding the specific roles that govern contract execution. For large contractors or those dealing with complex, multi-divisional federal projects, the Divisional Administrative Contracting Officer (DACO) is a pivotal figure. While many contractors are familiar with the Procuring Contracting Officer (PCO), the DACO plays a critical, ongoing role in the post-award phase. At SamSearch, we emphasize that understanding who holds authority over your contract is essential for maintaining compliance and ensuring smooth project delivery.
Definition
A Divisional Administrative Contracting Officer (DACO) is a specialized government official, typically operating under the Defense Contract Management Agency (DCMA), responsible for the administration of contracts within a specific business division of a large contractor. Unlike a PCO, who is primarily focused on the solicitation and award phase, the DACO is tasked with the day-to-day oversight of contract performance, compliance, and financial administration.
Under the Federal Acquisition Regulation (FAR) Part 42, the DACO is delegated authority to perform functions such as contract modifications, property administration, and the review of contractor business systems. Because they are embedded within a specific division, they possess a deep understanding of the contractor’s internal operations, making them the primary point of contact for audits, overhead rates, and compliance with the Defense Federal Acquisition Regulation Supplement (DFARS).
Key Responsibilities of a DACO:
- Business System Oversight: Evaluating and approving contractor business systems, including accounting, estimating, and purchasing systems.
- Contract Administration: Managing modifications, monitoring delivery schedules, and ensuring compliance with contract clauses.
- Cost Monitoring: Reviewing and negotiating forward pricing rate agreements (FPRAs) and final overhead rates.
- Regulatory Compliance: Ensuring the contractor adheres to Cost Accounting Standards (CAS) and other federal mandates.
Examples
- Business System Audit: A large aerospace firm is undergoing an audit of its accounting system. The DACO coordinates with the Defense Contract Audit Agency (DCAA) to ensure the system is compliant with CAS, which is a prerequisite for receiving future cost-reimbursement contracts.
- Contract Modification: A defense contractor needs to change a delivery schedule due to supply chain disruptions. The DACO reviews the request, assesses the impact on the contract price, and executes the formal modification.
- Rate Negotiation: A contractor provides engineering services across multiple federal agencies. The DACO negotiates the indirect cost rates for that specific division, which will then be applied to all active contracts within that business unit.
Frequently Asked Questions
What is the primary difference between a PCO and a DACO?
A PCO is responsible for the contract award and the initial solicitation process. Once the contract is awarded and enters the performance phase, administration is often delegated to a DACO or an Administrative Contracting Officer (ACO) to manage performance, payments, and compliance.
How does a DACO impact my small business?
While DACOs are typically assigned to large, multi-divisional contractors, small businesses may interact with them if they are a major subcontractor to a prime contractor overseen by a DACO. Understanding their role is vital if your prime contractor requires DACO approval for subcontracts or material purchases.
Can a DACO change the scope of my contract?
A DACO has the authority to issue contract modifications, but these must remain within the scope of the original contract. Any changes that fundamentally alter the scope or value beyond the DACO's delegated authority may require PCO intervention.
Where can I find information about my assigned DACO?
Contractors can typically find the contact information for their assigned administrative personnel within the contract document itself, specifically in the 'Administration' block of the SF 26 or SF 33 form. SamSearch users can also leverage our platform to monitor contract modifications and identify key government stakeholders associated with their specific contract vehicles.
Conclusion
The DACO is a cornerstone of the federal acquisition ecosystem, ensuring that large-scale contracts remain compliant and perform as intended. For contractors, maintaining a transparent and professional relationship with the DACO is essential for navigating audits and contract modifications. By staying informed on the regulatory requirements enforced by the DACO, your business can mitigate risks and improve its standing in the federal marketplace.
