Recently proposed FAR and DFAR rules changes

Report
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
• 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
• 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
• 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)
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Agency Peculiar
Special Tooling (Government Title Only)
Special Test Equipment
Government Material (Furnished)
Government Material (Acquired)
Traceability of Items with WAWF and IUID Registry
Changes in Traceability of Items
Target Operational Date
for IUID Registry
Target Operational
Date for WAWF
1) Tracking of ST/STE designation
April 2011
Target Winter 2012
2) Ability to designate Service or
Component designation
April 2011
Will use ship to DODAAC
as initial designation
3) Ability to record receipt of GFP
including non-UII’d property
Oct 2011 – GFP Hub Target
IOC
Target July 2011
4) Ensure WAWF has a searchable
reports capability
N/A
Dec 2010
5) Require Original Part & Serial
Number as a mandatory field for
Construct 1
TBD
TBD
6) Define warranty data to be
captured at time of delivery
TBD
Warranty flag operational;
Warranty attachment in
design
7) Make type designation a separate
field for all items
April 2011
Target Winter 2012
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
• 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
• 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 Ruckdaschel)
• New focus on contractor property
systems as a business system
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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)
•
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
• Presentation by Mike Showers, NASA Contract Property Manager
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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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