Agency wants our admin temps to take daily direction from their office manager. Is that a personal services problem?

FAR 37.104(c)(1) draws the line at relatively continuous supervision and control by a Government officer or employee, so it's the whole setup, not one piece of it. Each item alone is a warning sign. Together they describe an employer-employee relationship.

The rule says giving an order for a specific service, with the right to reject the result, is fine. Handing your people their tasks every morning, approving their leave and signing their timesheets is the office manager acting as their supervisor. Then add the FAR 37.104(d) guide factors that already fit an admin support order: work on site, government equipment, and the same work civil servants do in similar offices. That's the picture the prime's contracts person is worried about, and FAR 37.104(b) bars agencies from personal services contracts without specific statutory authority.

The fix runs up the contract chain:
- The contracting officer owns the task order terms and how it's administered, so the prime raises it with the CO, not with the office manager.
- The prime confirms in writing that work requests go through your site lead.
- Your site lead assigns the daily work, approves leave and signs timesheets. The office manager tells the lead what she needs and rejects work that isn't right.

We had two of our engineers sitting in an agency office and set it up exactly that way. It felt clunky for about a week, then nobody noticed.