TL;DR. A COR can tell you what your contract already says; only the Contracting Officer can add scope, cost or schedule. "Just start" can become a months-long claim, which is a lot of paperwork for two words.
- New to this? Work done on informal direction from someone without authority may never get paid. Arguing later that it was a constructive change takes proof and time.
- Contractor PM? Reply in writing: confirm the request, flag it as out of scope, and wait for the CO.
- Senior COR? Rank is not authority. Ask for the COR's appointment letter.
- Tight deadline? Move fast, but email the CO the same day and copy the COR.
The Moment That Feels Routine (And Isn't)
Here's a scene that plays out on defense programs every week. Your COR calls or emails and says something like, "go ahead and get started on that," or "we need this done, can your team handle it." It sounds so harmless it could double as small talk. You say yes, your team starts working, and everyone moves on with their day, feeling productive and helpful.
Except your COR almost never has the authority to tell you to do new work. Only your Contracting Officer (the CO) can direct changes to your contract, and the FAR says a COR has no authority to make commitments or changes that affect price, quality, quantity, delivery or other terms. The COR's job is to watch the game, not call the plays. That gap between "sounds like a normal Tuesday" and "is actually a legally loaded request" is where a lot of contract disputes quietly get born, usually without anyone meaning any harm at all.
Why This Isn't Just a Technicality
When a contractor performs extra work because of informal government direction instead of a formal modification, the contractor usually tries to recover the cost as a constructive change. The catch: you did something outside your original scope because someone with government-sounding authority told you to, and the fight is over whether anyone with real authority ordered it. The FAR built an entire system to prevent unauthorized people from committing the government to extra costs (FAR 43.202 (formerly 43.102) tells other government personnel not to direct or encourage work that should be the subject of a modification), and a COR giving verbal direction walks right up to that tripwire wearing a blindfold.
Two things can happen from here, and neither one involves confetti:
- The government refuses to pay for it. Since the direction didn't come through the CO, the government can argue it never actually authorized the extra work or cost, leaving you to eat it.
- You end up filing a claim to get paid anyway. You can pursue a Request for Equitable Adjustment (REA) or a formal claim under the Contract Disputes Act, but that means proving the direction happened, proving it changed your scope, and waiting months (sometimes years) for a decision.
The core rule to remember: a COR can tell you what your contract already says. Only a CO can tell you something new. If what you're hearing sounds like new scope, new cost, or new schedule, that's a Contracting Officer conversation, not a COR one, no matter how nicely it was asked.
What a COR Can and Can't Do
CORs aren't villains here, and most of them are trying to keep your program moving. The issue isn't intent, it's authority. Think of it like a very competent stage manager telling an actor to hit their mark. They can absolutely tell you where to stand. They cannot rewrite the play.
Who Can Direct What
| Situation | COR Authority | Who Actually Has to Approve It |
|---|---|---|
| Monitoring performance against the existing SOW | Yes, this is their job | N/A |
| Answering technical questions within current scope | Yes | N/A |
| Asking for new deliverables, added tasks, or extra hours | No | Contracting Officer |
| Approving cost growth or schedule extensions | No | Contracting Officer |
| Accepting or rejecting final deliverables | Sometimes, if delegated in writing | Check your COR's appointment letter |
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Where We Cover This in the Lessons
This exact scenario, the friendly-sounding request that turns into a scope fight, runs through several lessons in the Defense Contracting Fundamentals module. Contract Administration & COR walks through where a COR's authority ends and a CO's begins. Modifications, REAs & Claims covers what happens after the work is done: constructive changes, Requests for Equitable Adjustment, and claims. If you spend most of your time on task orders under an IDIQ or GWAC, MACs & Technical Direction Letters covers the TDL-specific version of the same trap, since TDLs have their own quiet way of sliding into unauthorized scope.
The one sentence we teach in the modifications lesson: if the government asks for something that is not in your statement of work, "the answer is never yes and never no, it is 'let me get that in writing from the contracting officer.'" You can be responsive without being reckless, and that sentence can spare you a very uncomfortable invoice conversation.
What To Actually Do When It Happens To You
You don't need to be difficult about this, and flatly refusing can damage a working relationship you'll need for years. The fix is procedural, not personal, and it takes about five minutes.
- Get it in writing, even informally. Reply to the verbal or email direction with something like, "Confirming your request that we [do X]. This appears outside our current SOW, we'll proceed once we have direction from the Contracting Officer." That single email is often the difference between getting paid and eating the cost.
- Loop in the CO immediately, not after the work is done. A quick heads-up now is a five-minute email. Doing it after three weeks of unauthorized work is a claim, and a considerably less fun email to write.
- Know your COR's actual delegation. Every COR is designated in writing, with a letter that spells out the extent of their authority. If you've never seen it, ask for it. It's not adversarial, it's basic contract hygiene, like checking the expiration date before you cook with it.
- Document everything, always. Even when direction comes through proper channels, keep a paper trail. Constructive changes usually aren't malicious, they're just informal habits that catch up with someone eventually. Don't let it be you.
Lesson: Contract Administration & COR
Part of the Defense Contracting Fundamentals module. Covers what a COR can and cannot direct, and where unauthorized commitments actually come from.
Start This Lesson Free →Frequently Asked Questions
Does this apply even if the COR outranks me or seems very senior?
Rank doesn't grant contracting authority. Authority comes from the appointment letter and the FAR, not from seniority or how convincing someone sounds on a call. A general or a GS-15 COR still can't direct new scope without the CO.
What if refusing the request would delay a mission-critical need?
You can still move fast, just document it as you go. A same-day email to the CO copying the COR usually gets a quick answer, and it protects you either way.
Can a constructive change ever work in the contractor's favor?
Yes, if you document it properly. Contractors have successfully recovered costs through REAs and claims when they can show the government directed the work, even informally. The paperwork is what turns "extra work we ate" into "extra work we got paid for."
Is this covered under a specific FAR clause?
The general concept lives under the Changes clauses (FAR 52.243-1 through 52.243-4, one for each contract type, plus 52.243-7, Notification of Changes, when your contract includes it) and the government's broader authority rules in FAR Part 1 and Part 43. The clause numbers are the same in the FAR overhaul text DoD now uses. Your specific contract will reference which Changes clause applies to your contract type.