Administrative Contracting Officer (ACO)

An Administrative Contracting Officer (ACO) is a warranted Contracting Officer responsible for post-award contract administration functions on one or more contracts, typically assigned from DCMA or the agency's contract administration office rather than from the original procuring office.

What is an Administrative Contracting Officer?

When a contract is awarded, administrative functions - monitoring performance, approving invoices, processing modifications, managing government-furnished property, and preparing CPARS evaluations - may be delegated to an ACO rather than retained by the Procuring Contracting Officer (PCO) who awarded the contract. This division of labor is particularly common on large DoD contracts, where DCMA provides ACO support for contractors with significant defense portfolios.

The ACO has full contracting officer authority within the scope of the contract administration delegation from the PCO. This includes the authority to issue administrative modifications (such as address changes and delivery schedule adjustments), approve invoices and progress payments, process consent to subcontract requests, and issue cure notices or show cause notices when performance problems arise. The ACO does not have authority to change the scope of work or fundamentally alter the contract terms without coordination with the PCO.

For contractors, the ACO is the day-to-day contractual counterpart during performance. The ACO approves invoices, handles questions about contract interpretation, manages government-furnished property records, reviews subcontracting plan compliance, and initiates CPARS evaluations at the end of each evaluation period. Building a productive working relationship with the ACO - through timely reporting, accurate invoice submissions, and proactive communication about performance risks - directly affects payment efficiency and past performance ratings.

Why ACO matters for government contractors

On many large DoD contracts, the ACO is the contractor's primary government contact for the duration of performance, while the PCO who awarded the contract may have little day-to-day involvement. Understanding who the ACO is, what their authority encompasses, and what they need from the contractor to do their job effectively is as important as understanding the PCO relationship. Invoice payment, CPARS ratings, subcontracting plan compliance tracking, and government property management all run through the ACO.

Example

A large defense IT services firm holds 14 contracts administered by DCMA, with a resident ACO team of three officials at the firm's main facility. The firm's contracts administration director holds monthly meetings with the ACO team to review invoice status, discuss upcoming contract modifications, and address any surveillance findings. When the firm needs to substitute a key personnel member on one contract, the contracts director submits a formal request to the ACO with the replacement's qualifications rather than simply making the change and notifying the program manager. The ACO approves the substitution within five business days. The proactive relationship with the ACO team means the firm's invoices are processed without delay, and the ACO's annual performance evaluations of the firm consistently note responsive contract management.

Frequently Asked Questions

What is the difference between an ACO and a PCO?

The Procuring Contracting Officer (PCO) is responsible for the competitive acquisition process from solicitation through contract award. Once the contract is awarded, administrative functions may be delegated to an Administrative Contracting Officer (ACO). The PCO retains responsibility for significant changes to contract scope, terminations, and determinations that require the original source selection authority. The ACO handles the day-to-day performance of the contract after award. For some contracts, particularly smaller ones, one CO performs both functions.

Can an ACO terminate a contract?

ACOs typically have authority to initiate cure notices and show cause notices, which are precursors to termination. A Termination Contracting Officer (TCO) is designated to handle the termination process itself - either for convenience or default. In some agencies, the ACO and TCO roles overlap. Significant termination actions typically involve coordination between the ACO, PCO, and agency legal counsel.

How do I find out who my ACO is?

The contract document's block 7 ("Administered By") identifies the contracting office assigned to administer the contract. For DCMA-administered contracts, this will show the relevant DCMA field office. Contact information for the specific ACO within that office is often provided in the contract document or through DCMA's online contract inquiry system. If your contract has not been assigned to DCMA, the PCO's office may handle administration directly.

What authority does the ACO have over invoice approval?

The ACO has authority to approve invoices and payment requests consistent with the contract's payment clauses. For fixed-price contracts, the ACO confirms that invoices align with contract milestones or delivery schedules. For time-and-materials contracts, the ACO (often through the COR) reviews labor hours, rates, and ODCs against contract authorization. For cost-type contracts, the ACO reviews provisional billing rates and may adjust billing rates based on DCAA recommendations. Final invoice approval for large cost-type contracts often involves both ACO approval and DCAA audit of the final incurred cost submission.