How Does 15 Go Into 10? Functions To Outcomes. presented by: Marlene Lynn, CPPM Manager of Asset Management BAE SYSTEMS

Transcription

1 How Does 15 Go Into 10? Functions To Outcomes presented by: Marlene Lynn, CPPM Manager of Asset Management BAE SYSTEMS

2 15 Functions of Property Per the Old DoD M 1. Property Management 2. Acquisition 3. Receiving 4. Identification 5. Records 6. Storage 7. Movement 8. Physical Inventory 9. Reports 10. Utilization 11. Consumption 12. Maintenance 13. Subcontractor Control 14. Disposition 15. Contract Close-Out

3 10 Outcomes of Property Per The New FAR Clause (f) (1) 1. Acquisition 2. Receiving 3. Records 4. Physical Inventories 5. Subcontractor Control 6. Reports 7. Relief of Stewardship (Disposition) 8. Utilization 9. Maintenance 10. Property Close-Out

4 What Happened to the Other Five Functions? Property Management Didn t go away now the foundation of the new FAR Clause Identification included in Receiving Storage included in Utilization Movement included in Utilization Consumption included in Utilization

5 Passing a DCMA Audit What Do We Have to Do Now? Per Circular #34 issued in September of 2009, we have come up with the guidelines on the rest of the slides.

6 PROPERTY MANAGEMENT Know the new FAR Rule Change your policies, processes and procedures to comply Ensure that your system covers all of the reports, records and elements required under the new FAR Rule Make sure any corrective actions identified during the year were implemented as spelled out Create a Property Plan Develop a Self-Audit Plan

7 PROPERTY MANAGEMENT The Contract Takes Precedence Read It Know It What is the list of property to be furnished under the contract? What property will be acquired under the contract? Is there a UID Reporting Requirement? Is there a CAV Reporting Requirement? What is the period of performance? Is there a warranty period?

8 ACQUISITION Property Management begins with Acquisition Know what assets are to be furnished, acquired or fabricated. Ensure that assets being furnished are accompanied by the proper Government paperwork (DD1149, DD250, etc.) Screen other Programs when assets are required. Make sure that all assets are documented appropriately so that there is an audit trail.

9 RECEIVING Receipt Furnished Property: For each asset furnished by the Government or Customer the contractor will demonstrate: The appropriate Receiving documentation That items are checked for quantity and damage That appropriate reports are generated (RODs) Actions are taken to reconcile discrepancies

10 RECEIVING Receipt - Acquired Property: The Purchasing System reflects receipt Receiving records include receipt, packing list, shipping information, etc.

11 RECEIVING Receipt: Property is adequately protected and stored during the receiving process. All Government Property is to be tracked and recorded in the Government Property System The system accounts for Reusable Containers, when furnished by the Government.

12 RECEIVING Identification: Government/Customer property are to be identified as such. Accommodate contract specific tagging requirements. System carries UID tag information.

13 RECORDS The contractor is required to maintain complete, current and auditable records of all transactions relative to Government property in their possession. The records must be accurate. We are required to provide support documentation for system records. Contracts may have additional requirements. Sensitive or Classified property should be identified in the system as such. Reporting of assets to the IUID Registry will be reviewed.

14 RECORDS There are changes to the elements of certain records identified in the new FAR Clause. Required Elements include: Name Part Number Description Manufacturer Model Number UID (if required by contract) NSN (if needed for additional identification tracking &/or Unit Acquisition Cost disposition of an item) Unit of Measure Location Disposition Posting Reference Date of Transaction Date Placed In Service Quantity Received (or Quantity Issued (material) fabricated) Quantity On Hand (material)

15 PHYSICAL INVENTORIES Requirement to periodically do a physical inventory and report to the customer. Method and timeframe are up to the contractor, except sensitive property. Sensitive property requires at least annual physical inventory. The method and timeframe are to be spelled out in your Property Plan. The people performing the inventory cannot be those who maintain the records or have physical custody of the assets, unless approved by the GPA.

16 PHYSICAL INVENTORIES A reconciliation between the records and the actual physical count should be done. Floor to Record audits are where we show the auditor the record for assets selected from the floor. Record to Floor audits are where the auditor selects records and we show them the actual asset on the floor Unlocated assets are reported to the DCMA GPA. The good news in the FAR Rewrite, is that limited contractor liability is the rule rather than the exception.

17 SUBCONTRACTOR CONTROL Audits look at the flow down of property clauses in subcontracts. Identify the specific assets to be furnished under the subcontract in the subcontract. Ensure subcontracts are properly administered Reviews are performed periodically to determine the adequacy of the subcontractor s property management system.

18 REPORTS Per Block change modification of October 2009, DD1662s have been eliminated. Replaced by IUID Registry twice a year input for certain assets. Many customers still want DD1662s. Other reports to DCMA include: LTDD Reports, physical inventory results, RODs, audit reports, selfassessment reports Additional reports may be required by contract or agreement with PCOs, ACOs and GPAs.

19 RELIEF OF STEWARDSHIP (formerly DISPOSITION) Relief of stewardship comes in several forms: Disposal of assets through plant clearance Transfer of assets to another contract Return or shipment of assets to the Government/ Customer Relief granted by GPA after a review of LTDD Other than renaming this, there is little change in what is expected.

20 UTILIZATION This Outcome now encompasses Utilization, Consumption, Movement and Storage. Auditable points under Utilization include: Proper authorization for utilization, movement and storage of assets. Use assets only on the contract that owns them. Correctly allocate rental charges for the use of Government assets on commercial contracts.

21 UTILIZATION Auditable points under Consumption include: Maintain accurate records of consumption of material and piece parts Reasonable quantities of parts consumed Auditable points under Movement include: Documentation of movement of assets, including dates, locations, etc.

22 UTILIZATION Auditable points under Storage include: Assets are adequately protected Company and Government assets are not commingled. Excess assets are not supposed to be stored for long periods of time. It s All About the Audit Trail!

23 MAINTENANCE Maintain Government Property in compliance with current technical publications and manuals. Have a system which will enable the identification, disclosure, and performance of normal and routine preventative maintenance and repair. Report and obtain approval from the DCMA GPA or Contracting Officer for replacement and/or capital rehabilitation of Government property.

24 PROPERTY CLOSEOUT Contractors will be audited to ensure that they: Perform final physical inventory of the assets on the contract Screen excess property in-house to determine if the property can be used on other contracts Promptly report excess property Investigate and close all LTDD reports Obtain proper authority for disposition Dispose of or transfer all assets on the contract Remove all tags and markings prior to disposal Have the required documentation and it is all in order

25 PROPERTY CLOSEOUT Contractors will be audited to ensure that they: Post data properly in the system Properly apply any proceeds from sales per the FAR and contract Submit a contract close-out letter reflecting a zero balance in a timely manner The FAR requires modifications to both the gaining and losing contracts for a transfer of property to take place.

26 CONCLUSION: While things are a bit different, they are mostly the same. Yes, we went from 15 Functions to 10 Outcomes, but everything is still there and will still be audited. As the old adage says: The more things change, the more they remain the same. So, what has changed???? We have gone from prescription to process.

27 Any Questions?????