GFP Reporting Under DFARS Clause Cleared For Public Release. Revision of

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1 GFP Reporting Under DFARS Clause Revision of Cleared For Public Release Presented by: Tom Ruckdaschel Deputy Director, Govt Property

2 This information: Should not be construed as changing or modifying any statute, regulation, DoD policy or guidance, or any term(s) of any contract with the U.S. Government or any department or agency of the U.S. Government. Does not affect in any way, any on-going or future property management system analysis. 2

3 Background 2007: Contractor reporting of GFP begins in earnest Regulatory (DFARS) timeline: [August 2012] (includes new 2014 requirements*) [November 2008] (Final Rule) [September 2007] (Interim Rule) Multiple changes created a degree of confusion; however, core reporting requirements did not change *Afforded industry adequate time to prepare for new requirements 3

4 This briefing focuses on the August 2012 version of DFARS Clause

5 DFARS November 2008 Contractors are required to report Government-Furnished Equipment Special Tooling Special Test Equipment Equipment Valued at $5,000 or more Excludes item for repair August 2012* Contractors are required to report Government-Furnished Property (includes items for repair), as follows: Through December 31, 2013: Each serially managed item $5,000 or more in dollar value As of January 1, 2014: Each serially managed item regardless of dollar value Non-serially managed material items (receipt ONLY) *applies to new solicitations and contracts 5

6 Background (cont.) DFARS clause continues to be misunderstood: The clause does not contain a marking requirement The clause does contain a GFP reporting requirement The clause is often confused with DFARS Both clauses involve the DoD IUID registry. However, each reflects fundamentally different requirements: DFARS clause pertains to delivery of items DFARS clause pertains to reporting of GFP 6

7 Types of GFP With respect to DFARS reporting, there are two (2) types of GFP: 1. Serially managed 2. Non-serially managed Of the two types, there could be: GFP previously marked with a registered UII (or) GFP not marked with a registered UII; these items could be serially managed or not The method of reporting depends on the existence of a UII. More on that later 7

8 Unique Item Identifiers What is a UII? a set of data elements marked on items that is globally unique and unambiguous. The term includes a concatenated unique item identifier or a DoD recognized unique identification equivalent. Why do some GFP items have UIIs? Because The contractor assigned and registered a UII by virtue of delivery under DFARS requirements, or The DoD Component assigned and registered a UII while the item was in its custody Most items with a UII are serially managed 8

9 9 Okay. So what exactly does serially managed mean?

10 10 Serially managed means*: An item designated by DoD to be uniquely tracked, controlled, or managed in maintenance, repair and/or supply systems by means of its serial number. DFARS clause *In addition to items previously marked with a UII, certain FAR property categories already, today right now meet this definition!

11 Inherently Serially Managed Items All items subject to DoD Instruction (DoDI) are considered serially managed, i.e., designated by DoD Special tooling (ST), special test equipment (STE), and equipment all fall under DoDI Therefore all ST, STE, and Equipment items are subject to DFARS reporting [as serially managed items] Material (items other than ST, STE and Equipment) is a different matter; material cannot be considered inherently serially managed* *True, some material items have serial numbers but that does not make them inherently serially managed 11

12 12 Responsibility Remember: the Government, not the contractor, has to identify serially managed items; contract terms and conditions must identify all items to be serially managed* *For example, items individually listed on the [Serialized Item List section of the Scheduled GFP Attachment (SGFP) ]

13 Smart Attachment A new requirement for all DoD contract writing systems OSD memo April 11, 2012 Required by PGI

14 14 So what exactly does report mean? In simplest terms, it means sending information to the DoD IUID registry ( the registry ) related to a property item s custody.

15 Reporting Events Reporting involves the following events: Receipt of property Delivered or shipment from the contractor s plant (unless to a subcontractor) Consumed or expended Disposed of Transferred to a follow-on or other contract Let s look at each of these reporting events 15

16 Receipt Receipt means acknowledging (electronically) the physical receipt of all GFP This is clearly the most important reporting requirement: Impacts overall property accountability The Government s warranty of timeliness of GFP delivery Contract performance Readiness Applies to all categories of GFP. Period. No exceptions. Universal electronic acknowledgement of all GFP items is a fundamental requirement of DFARS and property accountability! 16

17 Receipt (cont.) Electronic receipt acknowledgment is crucial and required for all GFP items It does not matter if the GFP is: Serially managed Not serially managed* Valued above or below $5,000 An item for repair Lacks a UII *If the property is not serially managed, acknowledgement of receipt is all that s needed. No other reporting is required under the clause. Done! 17

18 Receipt (cont.) The receipt of GFP items can be reported to the registry three (3) ways: 1.Through Wide-area Workflow (WAWF) 2. By using the registry website (if the item has a UII and is was previously registered) 3. Via direct submission to the registry through electronic files (if the item has a UII and was previously registered). Note: a UII can be added at the time of direct submission IMPORTANT: The presence of a UII and its existence in the IUID registry impacts the method of reporting! 18

19 19 Receipt (cont.) If the GFP item has a UII: reporting may be accomplished via WAWF or direct update to the registry If the GFP item does not have a UII: reporting can only be accomplished by WAWF There is no requirement for contractors to SIGN FOR GFP upon its receipt!

20 Reporting Events (cont.) Delivered or shipped from the contractor s plant (this is different from disposed of ): IAW contract terms and conditions or by direction from the contracting officer Shipped to a DoD entity or to another DoD contractor (this would require electronic acknowledgment of receipt by the gaining contractor) and WAWF reparable receiving reports (for repair items only) Disposed of (this is different from delivered or shipped ) means: Transfer to a non-dod Federal agency Donation, sale, or abandonment 20

21 Reporting Events (cont.) PCARSS automatically updates the registry when disposed of events occur PCARSS does not automatically update the registry when shipment (to Army, Navy, Air Force, Federal civil agencies) events occur Note: DCMA s Property Loss Tool updates the registry automatically upon contractor reporting of property loss (reference: DFARS ) 21

22 Reporting Events (cont.) Consumed or expended Destructive testing Test firing a missile Certain types of drill bits Transferred to a follow-on or other contract means: a contractual transfer of property accountability (same contractor/same CAGE) Registry (via WAWF) must be updated to reflect the new contract 22

23 Resources Contract Property Resource Page: cfm Plant Clearance Resource Page: DoD Procurement Toolbox: DPAP GFP Page:

24 Questions? 24

25 BACK UP SLIDES

26 Cost Contracts Containing FY13 2 nd Quarter Army 9.2% Navy 6.9% Air Force 31.5% USMC 17.6% All cost reimbursable contracts must contain the GFP Clause FAR % did! Other 16.9%

27 DFARS Property Clause FY13 1 st Quarter Army 6.8% 9.1% 2 nd Quarter Navy 3.1% 11.5% Air Force 8.3% 44.4% USMC 0.0% 0.0% Other 33.1% 28.6% Percent of contracts containing all required DFARS property clauses when contract contains DFARS DFARS DFARS DFARS DFARS

28 DoDI

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30 Contract Property Assets Personal Property Equipment Special Tooling Special Test Equip. Material For Repair For Use Equipment (for use or repair) Special Tooling Special Test Equipment These are inherently serially managed

31 PCARSS and Property Loss Tools PCARSS automatically updates the registry when certain property life cycle events occur: Disposition Type UID Lifecycle Event AA ABANDON ABANDONED DA DESTROY/DEMIL-ABANDON RESIDUAL-CONTACT PLCO IF FUNDS REQ ABANDONED DO DONATION - REQUISITION ATTACHED DONATED DS DESTROY/DEMIL-SCRAP RESIDUAL-CONTACT PLCO IF FUNDS REQUIRED SCRAPPED PR PURCHASE OR RETAIN AT COST SOLD-NONGOVT RS RETURN TO SUPPLIER SOLD-NONGOVT SO SCRAP PER APPROVED PROCEDURE WITH PROCEEDS CREDITED OVERHEAD SCRAPPED SS SELL AS SCRAP SCRAPPED SU SELL AS USABLE PROPERTY SOLD-NONGOVT SX SELL AS SALVAGE SOLD-NONGOVT UA TRANSFER TO ARMY - REQUISITION ATTACHED ** NOT SENT TO UID ** UF TRANSFER TO AIR FORCE - REQUISITION ATTACHED ** NOT SENT TO UID ** UG TRANSFER TO OTHER DOD AGENCY - REQUISITION ATTACHED ** NOT SENT TO UID ** UN TRANSFER TO NASA - REQUISITION ATTACHED ** NOT SENT TO UID ** UO TRANSFER TO OTHER GOVERNMENT AGENCY - REQUISITION ATTACHED ** NOT SENT TO UID ** US TRANSFER TO STORAGE AGREEMENT ** NOT SENT TO UID ** UQ TRANSFER TO NAVY - REQUISITION ATTACHED ** NOT SENT TO UID ** WD ITEM WITHDRAWN FROM PLANT CLEARANCE ** NOT SENT TO UID ** ## INITIAL DISPOSITION STATUS, DO NOT DELETE ** NOT SENT TO UID ** FU FORMAL SALE - USABLE SOLD-NONGOVT FX FORMAL SALE - SALVAGE SOLD-NONGOVT FS FORMAL SALE - SCRAP SOLD-NONGOVT IU INFORMAL SALE - USABLE SOLD-NONGOVT IX INFORMAL SALE - SALVAGE SOLD-NONGOVT IS INFORMAL SALE - SCRAP SCRAPPED NU NEGOTIATED SALE - USABLE SOLD-NONGOVT NX NEGOTIATED SALE - SALVAGE SOLD-NONGOVT NS NEGOTIATED SALE - SCRAP SCRAPPED AU AUCTION - USABLE PROPERTY SOLD-NONGOVT PM TRANSFER TO DRMO FOR PRECIOUS METAL RECOVERY ** NOT SENT TO UID ** MO TRANSFER TO DRMO - WITHDRAWN ** NOT SENT TO UID ** UP INVALID CODE - DO NOT USE!!!!!!!!!!!!!!! ** NOT SENT TO UID ** DN DESTROY/DEMIL/RECYCLE-NO RESIDUAL-CONTACT PLCO IF FUNDS REQ RETIRED WP WITHDRAWAL PENDING ** NOT SENT TO UID ** W WITHDRAWN ** NOT SENT TO UID ** CT CONTRACT TRANSFER ** NOT SENT TO UID **

32 PCARSS and Property Loss (cont.) The PL etool automatically updates the registry when Case Type (Property Loss/LTDD) Lost Damaged Theft Destroyed Accident Destroyed Combat UID Life Cycle Event (Condition Code) Lost Abandoned Stolen Destroyed-Accident Destroyed-Combat