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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
  • 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
slide9

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
helpful sites from tom ruckdaschel
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
nasa regulations
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