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Recently proposed FAR and DFAR rules changes, etc. Aerospace Industries Association Property Management Committee Reported by: Alex N. Barenblitt, CPPA AAI Corporation/Textron. DoD Instruction 5000.64. Accountability and Management of DoD-Owned Equipment and Other Accountable Property

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Recently proposed far and dfar rules changes etc

Recently proposed FAR and DFAR rules changes, etc.

Aerospace Industries Association

Property Management Committee

Reported by: Alex N. Barenblitt, CPPA

AAI Corporation/Textron


Dod instruction 5000 64
DoD Instruction 5000.64

  • Accountability and Management of DoD-Owned Equipment and Other Accountable Property

  • Reissues Reference (a) to establish accountability and management policy for tangible DoD-owned equipment and other accountable property, in accordance with the authority outlined in Reference (b).

  • 1.2. Establishes policy and procedures to comply with References (c) and (d); outlines requirements that reflect both the accounting perspective, which supports the documentation of life-cycle events and transactions, and the accountability perspective, which supports the lifecycle management of assets.

  • 1.3. Provides policy and procedures for DoD-owned equipment and other accountable property; assists DoD property managers, accounting and financial managers, and other officials in understanding their roles and responsibilities.


The uid registry
The UID Registry

  • Currently you must register all GFP/GFE that is serialized or greater in value than $5,000 in UID Registry via the Wide Area Workflow (WAWF)

  • Proposed rules changes remove the $5,000 threshold

  • All ST/STE will be serialized, requiring UID

  • Virtual UII’s must also be registered

  • GFP Module (originally proposed “HUB”) is for non-UII parts

  • Government wants Registry visibility to all GFP, regardless of cost to Contractors to implement

    • Cost/Benefit Analysis does not seem to be present

    • Reliance on Contractors for reporting does not seem to be present (formerly DD1662’s)

    • Multiple Property systems – no consistent interface among major ERP/Asset Management systems

  • Reference DFARS Case 2009-D043


Uid impacts
UID Impacts

  • Impact on Repair on Repairables (Also known as Maintenance, Repair and Overhaul – MRO) is likely to be significant

    • Parts returning for repair may not yet be registered but will need to be prior to returning repaired item

    • Subassemblies and “children” of “Parent” parts may also need to be registered

  • Parts built by other OEM’s may be registered, but become part of your delivered system (Which CAGE Code is used? Which DODAAC? …)

  • Property Type has returned (although when DD1662’s were terminated, Property Type was to be eliminated)

    • Agency Peculiar

    • Special Tooling (Government Title Only)

    • Special Test Equipment

    • Government Material (Furnished)

    • Government Material (Acquired)



Loss of government property
Loss of Government Property

  • Reference FAR Case 2010-009

  • Clarifies reporting, reutilization, and disposal of Government property and the contractor requirements under the Government property clause

  • Clarifies that FAR Part 45 and FAR Part 52.245-1 does not apply to Government Property “incidental to the place of performance at a Government site or installation”

  • Adds definitions of “loss of Government Property” and “unit acquisition cost”

  • Moves the definition of “surplus property” to Part 2

  • Revises language references in Public Comments from Government and Contractors, exchanges (such as with AIA), and questions received for FAR Case 2008-011


Dfars proposed rule on responsibility and liability for government property
DFARS Proposed Rule on Responsibility and Liability for Government Property

  • Reference DFARS Case 2010-D018

  • Extends the FAR Government self-insurance policy to Fixed Price contracts awarded on a basis other than a submission of cost pricing data.

  • Contractors will not be held liable for loss of Government Property under the following contract types:

    • Cost-reimbursement

    • Time and materials

    • Labor Hour

    • Fixed Price (negotiated on a basis other than cost-pricing data)

  • Eliminates use of Alternate 1 which requires Contractors to assume that risk


Contractor self assessments
Contractor Self Assessments Government Property

  • Guidance from Tom Ruckdaschel

  • PMSA’s should be less mechanical, rely on good CSA’s for day-to-day operations

  • Updated PMSA Guidebook is in development

  • DoD/DCMA encourages more robust Contractor Self Assessments than PMSA – Early Warning System


Challenges (Tom Government Property Ruckdaschel)

  • New focus on contractor property systems as a business system

    • Timeliness

    • Accuracy

    • Reliability

    • CONSISTENCY

  • Requires

    • Understanding root causes; implement preventive actions

    • Finding the right remedy for inadequate systems; and

  • Documentation, documentation, documentation


  • Helpful sites from tom ruckdaschel
    Helpful sites (from Tom Government Property Ruckdaschel)

    • Review DFARS and FAR proposed and interim rules

      • Change Notices:http://www.acq.osd.mil/dpap/dars/change_notices.html

    • Submission input of public comments: http://www.acq.osd.mil/dpap/dars/out_for_public_comment.html

      • View public comments on proposed & interim rules

      • DFARS rules: http://www.acq.osd.mil/dpap/dars/out_for_public_comment.html

      • FAR rules: www.regulations.gov

    • View status of open cases

      • DFARS rules: http://www.acq.osd.mil/dpap/dars/case_status.html

      • FAR rules: http://www.acq.osd.mil/dpap/dars/far_case_status.html


    Nasa regulations
    NASA Regulations Government Property

    • Presentation by Mike Showers, NASA Contract Property Manager

    • 1852.245-70 Contractor Requests for Government Provided Equipment

      • Limited to equipment acquisition only

    • 1852.245-74 Identification and Marking of Government Equipment

      • Items may be marked using commercial techniques if they are durable enough to survive the item

    • 1852.245-75 Property Management Changes

      • Requires submission of reports to the PA rather than the IPO

    • 1852.245-78 Physical Inventory of Capital Personal Property

      • Requires submission of reports to the PA rather than the IPO

    • 1852.245-76 List of GFP

      • Used with FAR 52.245-1

    • 1852.245-77 List of GFP

      • Used with FAR 52.245-2


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