Roles & Responsibilities — BenefitConnect Portal Modernization

1. Why This Document Exists

On a commercial program, the people who can tell you what to do are mostly in your own organization. On a federal task order they are not. The customer holds contractual authority and sits entirely outside the contractor's chain of command, and the single most expensive mistake available on a program like this is taking direction from someone who cannot legally give it.

So this document is organized around a boundary rather than a hierarchy. It names what the contractor owns, what the Government owns, and — the part that costs money when it is misunderstood — which Government person can change the contract and which cannot.

The fact that governs everything below. The Contracting Officer (A. Reyes) is the only person who can obligate the Government. The COR (M. Whitcombe) administers the task order technically, monitors performance, and accepts deliverables — but a COR cannot direct changed work. ⚠ If the contractor performs work at a COR's direction that is outside the PWS, that is a constructive change: the work is done, nobody authorized payment for it, and recovery becomes a Request for Equitable Adjustment against evidence the contractor may not have kept. ***See REA-001, where exactly that recovery failed on recordkeeping.***

2. The Shape of the Organization

Thirty-five people, all contractor-side, all onshore. Unlike the commercial programs in this portfolio, the Task Order PM has real reporting authority over most of the team — this is a delivery organization the firm staffed against a contract, not a matrixed borrow from functional departments. The constraint is not authority over people; it is that almost nothing about scope, schedule or price can be changed without a signature the program does not hold.

Function	Who	Owns	Does not own
Task Order PM	C. Tyrrell	Delivery, schedule, cost, CDRL submission, and every commitment made to the Government	Scope. Price. Period of performance. All three require a modification.
Back-End Development	H. Ibrahim + 5	Build against the PWS, technical design, unit test	Whether a requirement is in the PWS — that reading belongs to the PM and, in dispute, to the CO
Quality Assurance	N. Castellano + 5	Test execution and the evidence package behind each CDRL	Government acceptance — QA proves conformance, the COR accepts
Data Migration	P. Ochieng, R. Talbot	Extract, transform, load and reconciliation from the legacy benefits system	Legacy data quality, which is Government-furnished and inherited as-is
508 / Accessibility	P. Duvall, L. Anders	Conformance testing and the VPAT evidence	The standard itself — Section 508 is law, not a negotiable requirement
Compliance / Privacy	K. Ashworth	Privacy impact analysis, PII handling review, ATO evidence support	The ATO decision — see §5
Technical Writing	E. Marchand	CDRL documents to the format the PWS specifies	Whether a CDRL is acceptable — the COR decides that

3. Governance — Who Decides

Three authorities, and confusing any two of them is expensive.

Authority	Who	Can	Cannot
Contracting Officer	A. Reyes	Modify scope, price or period of performance; execute an SF-30; determine an REA; terminate	— (this is the Government's full authority)
COR	M. Whitcombe	Administer technically, monitor performance, inspect and accept deliverables, raise concerns to the CO	Direct changed work. Waive a requirement. Authorize overtime. Approve anything that costs money.
Task Order PM	C. Tyrrell	Everything inside the awarded scope: sequencing, staffing, method, internal risk	Anything that alters what was awarded

⚠ The practical rule the program runs on. If a Government instruction would cost money, take time, or change a deliverable, it goes to the Contracting Officer in writing before the work starts — not after. The cost of asking is a day. The cost of not asking is an REA argued against timesheets that were never separated, which is the $268,000 the program did not recover.

4. The Functions, One at a Time

The Task Order PM is accountable for delivery and is the single contractual voice to the Government. That singularity matters more here than in commercial work: when several contractor staff talk to several Government staff, direction arrives through side channels and nobody can later establish what was authorized. Every scope-adjacent conversation routes through the PM, and every one that matters is confirmed in writing.

Quality Assurance proves conformance; it does not grant acceptance. N. Castellano's team assembles evidence that a CDRL meets the PWS, and the COR accepts or rejects. ⚠ That separation protects the contractor as much as the Government — a documented acceptance is what closes the door on a later claim that a deliverable was never adequate.

Data Migration inherits Government-furnished data. The team can profile it, report defects, and reconcile what moved; it cannot make a legacy record correct that was wrong when it was written. Scope is stated as what will be reconciled, never as what will be correct — the same discipline the commercial suites use, but here the distinction has contractual consequences.

508 / Accessibility is the one function whose requirement nobody in either organization may relax. Section 508 is statute. The COR cannot waive it, the CO cannot negotiate it away, and a VPAT that overstates conformance is a misrepresentation rather than an optimistic estimate.

5. What the Program Cannot Be Directed To Do

The Authorizing Official and the ATO. The Authority to Operate is a Government risk decision. The contractor supplies evidence and remediates findings; it does not influence the outcome and cannot be instructed to shortcut it. When the ATO ran 34 days late, the correct response was to notify in writing on day three and claim the delay — see REA-002, which was granted in full.

Government QA and inspection. The Government may inspect at any time. The program does not schedule, filter or prepare that inspection beyond keeping evidence current.

Statutory requirements. Section 508, privacy law, and records retention are not requirements the parties agreed to and therefore cannot un-agree.

A test that works here as well as commercially: if the program can change the answer by asking harder, it was never an independent authority. The CO fails that test on purpose — and so, deliberately, does the ATO.

6. How This Differs From the Commercial Programs Here

Question	Federal (this suite)	Commercial (PM, Agile)
Who approves a change?	The Contracting Officer, by signature on an SF-30	An internal board that can be persuaded
What happens to a refused change?	It never becomes a modification and leaves no trace unless separately recorded	It sits in the change log as a declined CR
Who owns the requirement?	The PWS. It was competed and awarded; nobody may quietly reinterpret it	The sponsor, who may change their mind
Who can direct the team?	The Task Order PM. Not the customer.	Functional managers, and the program only by influence

⚠ The mapping that most often misleads. A COR looks like a customer product owner and behaves nothing like one. A product owner may reprioritize freely; a COR who reprioritizes has either issued a constructive change or exceeded their warrant. Treating the two as equivalent is how contractors end up performing unpaid work in good faith.