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Federal Acquisition Certification for Contracting Officers’ Technical Representatives (FAC-COTR)

APM 2008-01  


To:                    Heads of Contracting Activity
                        Executive Officers

From:                Martin J. Brown  /s/
                        Senior Procurement Executive

Subject:            Federal Acquisition Certification for Contracting Officers’ Technical 
                        Representatives (FAC-COTR)

Effective Date:    October 1, 2008

1.  Purpose:  This memorandum (a) represents the Department of Health and Human Services’ (HHS) implementation of the Federal Acquisition Certification - Contracting Officers’ Technical Representative (FAC-COTR) program; (b) establishes FAC-COTR certification as a prerequisite for serving as a COTR within HHS, and (c) promulgates interim acquisition guidance (attached), pending incorporation in the HHS Acquisition Regulation.

To earn certification under FAC-COTR, HHS’ COTR candidates must: (a) demonstrate they have met minimum training requirements as described in paragraph 4 below; and (b) refresh this training through continuous learning as described in paragraph 5 below.

2.  Background: HHS’ success depends on a knowledgeable and skilled acquisition workforce to contract for the supplies and services it needs to accomplish its mission. Contracting Officer Technical Representatives (COTRs) are valued members of that workforce because they help to monitor and manage HHS’ contracts.  

Recognizing the COTR’s critical role, the Office of Federal Procurement Policy (OFPP), in conjunction with the Federal Acquisition Institute (FAI) and the Chief Acquisition Officers Council (CAOC), established government-wide COTR certification standards (November 26, 2007).  See

3.  Applicability:  The FAC-COTR certification prerequisites and continuous training requirements apply to all HHS employees who wish to be delegated authority to perform COTR functions, including current COTRs who wish to continue performing COTR functions.  Contractors and contractor employees are not eligible to be certified or to serve as COTRs.

4.  FAC-COTR Training Requirements:  HHS Contracting Officers shall not delegate authority to act as COTR to uncertified personnel.[1]  Heads of Contracting Activity (HCAs) or their designees [typically Acquisition Career Managers (ACMs)] are hereby delegated authority to:  (a) establish, manage and monitor their OPDIVs’ FAC-COTR programs; (b) grant, suspend, deny, revoke, and reissue certifications; (c) evaluate candidate proficiencies and determine course equivalencies for certification, in accordance with FAI’s required COTR competencies; and (d) resolve any certification-related disputes.

Current COTRs should review their training needs in light of both HHSAR 301.604 (attached) and the FAI’s recommended competencies for COTRs (, and must be certified no later than six months from the effective date of this acquisition policy memorandum.

HHS FAC-COTR certification may be earned in any of the following ways:

i. Completion of HHS University’s “Basic Project Officer” course or its equivalent.  Per HHSAR 301.604, additional training is required for COTRs on Information Technology and Biomedical Advanced Research and Development Authority (BARDA) projects.

ii. Completion of a minimum of 40 hours of Continuous Learning Points (CLP) in

COTR training, of which 23 hours must be completed from the following FAI online training courses or their equivalents:

CLC 106 - COR with a Mission Focus (8 CLPs)
CLM 024 - Contracting Overview (8 CLPs)
CLC 004 - Market Research (3 CLPs)
CLC 007 - Contract Source Selection (2 CLPs)
CLM 003 - Ethics Training for Acquisition Technology & Logistics (2 CLPs)

Coursework modules for the mandatory 23 hours can be found and completed at  Classroom training obtained from a Defense Acquisition University-approved training vendor may serve as an acceptable alternative to online training.  The remaining 17 hours of training shall include electives and other courses identified by the COTR's supervisor, in consultation with the Contracting Officer, as necessary for managing particular contracts.

iii. Completion of the FAC-COTR Fulfillment Process[2] HCAs or their designees may certify individuals who are already proficient in the required competencies.

iv. Completion of Federal Acquisition Certification in Contracting (FAC-C) Level I or Federal Certification for Program and Project Managers (FAC-P/PM) Mid-Level/Journeyman.  Individuals certified under either of these programs have met HHS’ FAC-COTR requirements.  However, individuals certified under FAC-COTR have not necessarily met the requirements for FAC-C Level I or FAC-P/PM Mid-Level/Journeyman.

5.  Maintaining FAC-COTR:  HHS COTRs must (a) maintain their skills currency by earning 40 CLPs every two years, starting from their dates of certification, and (b) document completion of all basic and refresher training in the Acquisition Career Management Information System (ACMIS).  See Appendix A of OFPP’s FAC-COTR memorandum, dated November 26, 2007, for additional guidance on obtaining continuous learning points.

Continuous learning activities related to FAC-COTR include, but are not limited to: training activities, such as teaching, self-directed study, mentoring professional activities, such as attending or presenting at professional seminars/conferences educational activities, such as formal training and formal academic programs experience such as developmental or rotational assignments.

Failure to complete the 40 CLPs may result in the lapse of the FAC-COTR certification and suspension or revocation of delegated authority, at the discretion of HCAs or their designees. Lapsed certifications may be reinstated when 40 CLPs have been accumulated. 

6.  Certifications from other Federal agencies:  HHS recognizes and accepts FAC-COTR certifications issued by other Federal agencies.

 7.  FAC-COTR Application Process:  Applicants for HHS FAC-COTR certifications shall submit application packages to their respective HCAs or designees.  Application packages[2] must include a transmittal memorandum; copies of relevant training certificates (or documentation supporting “fulfillment”, FAC-C Level 1, FAC-P/PM Mid-Level/Journeyman, or a FAC-COTR certificate from another Federal agency); and a complete and up-to-date ACMIS record[3].

HCAs or designees shall: (i) provide guidance on the preparation of applications; (ii) evaluate application packages; (iii) sign and issue FAC-COTR certificates, and (iv) maintain records relating to FAC-COTR certification.

8.  FAI’s ACMIS:  ACMIS is HHS’ system of record for the FAC-COTR program.  Individual COTR candidates and certified COTRs are responsible for entering, maintaining, and updating COTR training and CLP data in ACMIS.  HCAs or designees shall periodically review ACMIS records for quality assurance purposes.



cc: Acquisition Career Managers
Gina Nightengale, HHS University
Mary Oliver-Anderson, ASRT/OCIO
Michael Blumenfeld, ASPR/BARDA
Diane Stewart, ASAM/OFMP     


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[1] See HHSAR 301.604 (attached) for exceptions.
[2] ASAM/OAMP is currently developing a FAC-COTR Handbook, including standardized application and fulfillment forms/templates.
[3] Because of ACMIS’ current volatility, ACMIS registrants are encouraged to keep print-outs of their ACMIS records until further notice.