1 / 11

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

Download Presentation

Recently proposed FAR and DFAR rules changes, etc.

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript


  1. Recently proposed FAR and DFAR rules changes, etc. Aerospace Industries Association Property Management Committee Reported by: Alex N. Barenblitt, CPPA AAI Corporation/Textron

  2. 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.

  3. 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

  4. 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)

  5. Traceability of Items with WAWF and IUID Registry

  6. 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

  7. 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

  8. Contractor Self Assessments • 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

  9. Challenges (Tom 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

  10. Helpful sites (from Tom 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

  11. NASA Regulations • 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

More Related