Who Inspects the Work, and Who Can Actually Accept It

On a federal construction contract, the quality assurance representative checks the work, the contracting officer's representative monitors performance on the contracting officer's behalf, and only the contracting officer can change the contract or accept what was built. The first two can tell you a great deal. Neither can commit the government to a dollar or a day.

Updated October 2026. Rule statements on this page are taken from the Federal Acquisition Regulation as published at acquisition.gov. Agencies supplement the FAR and every contract carries its own clauses, so read yours before relying on a general rule.

Most of the friction between the field and the contract on a federal job comes from one confusion: the person on site every day is rarely the person who can say yes. A superintendent asks the inspector whether a substitute fixture will do, gets a nod, installs it, and learns at the punch walk that a nod was never a decision. Knowing which role owns which question costs nothing at the start of a job. Learning it halfway through costs a change you cannot recover.

The three roles

The quality assurance representative. The QAR is the government's eyes on the work. Agencies use different titles for it; the function does not change. On site, the QAR watches the work against the plans and approved submittals, reads the contractor's daily quality control reports, attends the preparatory and initial inspections on jobs run under three-phase control, and records deficiencies. What the QAR does not do is run quality control for the contractor. The Inspection of Construction clause, FAR 52.246-12(c), says government inspections and tests are for the sole benefit of the government and do not relieve the contractor of responsibility for its own quality control.

That is why we staff a dedicated Construction Quality Control Manager on public work instead of leaning on the government's inspector to catch things. The QAR is a check on our system. If the QAR is the system, the job has none.

The contracting officer's representative. A COR is designated in writing by the contracting officer under FAR 1.602-2(d). The designation has to state the extent of the COR's authority, the limits on it and the period it covers. A COR monitors technical performance, coordinates with the contractor and reports back. The same paragraph is blunt about the ceiling: a COR has no authority to make any commitment or change that affects price, quality, quantity, delivery or other terms of the contract, and cannot direct the contractor to work in conflict with it.

The contracting officer. The contracting officer enters into, administers and terminates the contract, and under FAR 1.602-1 binds the government only to the extent of the authority delegated in writing. Changes, equitable adjustments and acceptance all run through this one office.

Why "the inspector saw it" is not acceptance

Acceptance is a contract action, not an observation. FAR 46.502 makes it the contracting officer's responsibility, or that of a contract administration office the responsibility has been assigned to. A QAR walking past a finished room and saying nothing has not accepted the room.

The timing matters because acceptance moves the risk. Before it, paragraph (f) of the inspection clause lets the government require nonconforming work to be replaced or corrected at the contractor's expense, including work an inspector had already looked at. After it, paragraph (i) makes acceptance final and conclusive except for latent defects, fraud, gross mistakes amounting to fraud, and the government's rights under any warranty or guarantee.

So a contractor cannot bank a QAR's silence, and an agency should not treat its inspector's daily presence as a substitute for a deliberate acceptance decision. Both sides want that line drawn clearly at the end of the job, which is where as-built drawings and the closeout package come in.

When the direction comes from the wrong person

This is where money gets lost. Someone on site, meaning well, tells the crew to move a panel, add a conduit run or resequence a floor. The crew does it. Then the question is who pays.

On a fixed-price construction contract above the simplified acquisition threshold, FAR 43.205(d) puts the Changes clause at 52.243-4 in the contract. Its paragraph (b) treats a direction, instruction or interpretation from the contracting officer as a change order only if the contractor gives written notice stating the date, circumstances and source of the order and that it regards the order as a change. Paragraph (d) holds the part most people miss: no adjustment is made for costs incurred more than 20 days before that written notice.

A direction from someone without authority is worse off still, because it is not a contracting officer's order at all. FAR 1.602-3 calls it an unauthorized commitment. It can be ratified, but only by an official who holds that authority, ordinarily the head of the contracting activity, and only when the conditions are met: among them, that the government received a benefit, that the price is fair and reasonable, and that funds were available then and are available now. Nobody on either side enjoys that file.

The habit that prevents it is dull and it works. Anything said in the field that changes scope, cost or time goes back to the contracting officer in writing, promptly, tied to the RFI that prompted it. The field direction might be right. It is still not a change until the contracting officer makes it one.

Which role to ask, and about what

• Is this installed to the approved submittal, and can we cover it? Ask the QAR, once the contractor's own quality control has already checked it.
• Does this RFI answer change cost or time? Only the contracting officer can say, and it should be in writing.
• Can we accept a substitute, resequence, or work outside the agreed hours? That call belongs to the contracting officer. A COR can coordinate the request but cannot commit to it.
• Is the work accepted? Acceptance sits with the contracting officer, or with the office it was assigned to.
• What can the COR on this job actually decide? Read the designation. Under FAR 1.602-2(d)(7) it is furnished to the contractor in writing, and it has to state the limits of the COR's authority.

That last question is the cheapest one on the list. The time to read the designation is at the post-award conference, before mobilization, when the written communication plan gets settled and every name on it can be matched to what that person is allowed to decide.

What the contracting office can do to keep this clean

Most of these disputes are avoidable at the start. Say plainly at the post-award conference who the QAR is, who the COR is if there is one, and that changes come only from the contracting officer. Hand over the COR designation. Then hold the line when a well-meant field direction goes around it, because the ratification file that follows lands on the contracting office, not the field.

A contractor whose daily reports, RFI log and change notices already respect these lines is easier to administer, and that shows up later in the past performance record. Our piece on federal construction documentation covers what that record looks like, and our construction management services list document control, submittal logs and RFI logs as deliverables in their own right.

If your office is building a list of contractors for federal, state or municipal work in New Jersey and the Northeast, contact us to request our capability statement, including the quality control and site safety staffing we would put on your project. Imperial holds MBE and SBE certification and bids public work either as the prime or under one.