The Essential Property Management Guideto Contracts, Asset Management Responsibilities and Government Reporting in 2017

Introduction ..................................................................................... 2

Federal Acquisition Regulation (FAR) ............................................... 4

Defense Federal Acquisition Regulation Supplement (DFARS) ......... 4

Department Of Defense Instruction .................................................. 6

DoD Procedures, Guidance And Information (PGI) ............................ 9

How A2B Tracking Supports Property Managers .............................. 11

Definitions ...................................................................................... 13

References ...................................................................................... 14

TABLE OF CONTENTS

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Introduction

Winning federal contracts can be lucrative and often provide numerous networking and

growth opportunities. But being awarded a contract also means complying with laws and

regulations unique to government contractors. Many property managers and administrators

are unprepared for the avalanche of rules that may or may not apply to their contracts. This

can lead to costly errors. This guide will help property professionals become familiar with the

rules and regulations that apply to most federal contractors.

A Contract is an agreement in writing between two or more individuals or entities in which a

court can impose penalties in the event one party attempts to negate on a promise set forth

in the signed document. Contract elements include offer-acceptance-consideration. If all the

elements are present, then it is an enforceable contract.

The Federal Acquisition Regulation (FAR) is the principal set of rules in the Federal Acquisition

System governing the federal government’s purchasing processes. The FAR ensures

purchasing procedures are standard and consistent, and conducted in a fair and impartial

manner.

Many contract clauses incorporate parts of the FAR into government contracts by reference,

thus imposing FAR rules on contractors. If the FAR requires that a clause be included in a

government contract, and if the government’s acquisition personnel omit the clause without

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authorization, the agency boards of contract appeals and federal courts may interpret the

contract as though the clause were, in fact, included. Known as the “Christian Doctrine,” this

legal rule is based on the principle that government regulations have the force and effect of

law, and government personnel may not deviate from the law without proper authorization. The

FAR applies to all agencies in the Executive Branch.

Furthermore, nearly every major cabinet-level department (and many agencies below them)

has issued regulations that often place further restrictions or requirements on contractors

and contracting officers. The Defense Federal Acquisition Regulation Supplement (DFARS)

is an agency supplement used by the Department of Defense (DoD). The DFARS contains

requirements of law, DoD-wide policies, delegation of FAR authorities, deviations from FAR

requirements, and policies/procedures that have a significant effect on the public.

Procedures, guidance, and information (PGI) that do not meet the criteria for inclusion in the

DFARS are issued in the DFARS companion resource, PGI. Unclassified, non- confidential

memoranda and guidance can be found in the appropriate PGI subpart.

What follows are the rules, regulations and instructions that are likely to appear in many

contracts where GFP is involved. A2B Tracking property management experts encourage you

to read each contract line item carefully and to call for assistance when necessary.

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FEDERAL ACQUISITION REGULATION (FAR)

Part 45 Government’s Policy

Prescribes policies and procedures for providing Government property to contractors.

Contractors’ use and management of Government property, and reporting, redistributing, and

disposing of contractor inventory. Part 45 is now strictly limited to requirements placed upon

the Government.

FAR 52.245-1 (June 2007, August 2010, April 2012)

The contractor shall have a system of internal controls to manage (control, use, preserve,

protect, repair and maintain) Government property in its possession (April 2012). FAR 52.245-

1 is limited to requirements placed upon the Contractor.

DEFENSE FEDERAL ACQUISITION REGULATION SUPPLEMENT (DFARS)

Part 245 Department of Defense (DoD) Policy

It is DoD policy that Government-furnished property be tagged, labeled, or marked based on

DoD marking standards (MIL Standard 130) or other standards, when the requiring activity

determines that such items are subject to serialized item management (serially- managed

items). The list of Government-furnished property subject to serialized item management

will be identified in the contract in accordance with PGI 245.201-71, GFP attachments to

solicitations and awards.

GFP shall remain on a contractor’s stewardship records until government

receipt or acceptance (as required) of the returned GFP asset is complete.

Contractors are responsible for performing this requirement using their

Contractor Property Management System.

When contractors receive GFP shipped direct from another contractor or the

government, the gaining stewardship contract shall be indicated on the receipt.

If the stewardship contract cannot be determined at the time of receipt, it must

be annotated in the IUID Registry. Government and Contractor are responsible

for this requirement using Contractor Property Management System, Invoicing,

Receipt, Acceptance and Property Transfer (iRAPT) formerly Wide Area Work

Flow (WAWF), Defense Logistics Management System (DLMS) and Item Unique

Identification (IUID) Registry.

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When performance requires the use of Government-furnished property,

contracting officers shall use the fillable electronic “Requisitioned Government

Furnished Property” or “Scheduled Government Furnished Property” formats

as attachments to solicitations and awards. See PGI 245.103-72 for links to

the formats and procedures for preparing Government-furnished property

attachments to solicitations and awards. Government and Contractor are

responsible for performing this requirement; contractor using its Contractor

Property Management System. See PGI 245.103-72 for 2016 update.

252.242-7005 Contractor’s Business System (February 2012)

Requires contractors to maintain “acceptable business systems” to comply with the terms

and conditions of the applicable business system clauses listed within this clause. There are

six contractor business systems specifically named:

• Accounting• Earned Value Management• Estimating• Material Management and Accounting• Property Management

• Purchasing

252.245-7001 Tagging, Labeling and Marking of GFP (April 2012)

252.245-7002 Reporting Loss of Government Property (April 2012)

252.245-7003 Contractor Property Management System Administration (April 2012)

252.245-7004 Reporting, Reutilization, and Disposal (September 2016)

252.211-7007 Reporting GFE to the DoD UID Registry (November 2008, August 2012)

Changes to DFARS 252.211-7007:

November 2008 clause required Contractors to report government-furnished

equipment (GFE) which consisted of special tooling, special test equipment and

equipment with a unit cost of $5K or more and excluded items for repair.

August 2012 clause required contractors to report GFP that is serially managed

with a unit cost of $5K or more and includes items for repair. Starting January

1, 2014, contractors will be required to report GFP that is serially managed

regardless of dollar value and non-serially managed. This clause only applies to

covered contracts that are subject to the Cost Accounting Standards under 41

U.S.C. chapter 15, as implemented in regulations found at 48 CFR 9903.201-1

(see the FAR Appendix).

DFARS Part 245-104 Responsibility and Liability for Government Property (January 2015)

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DEPARTMENT OF DEFENSE INSTRUCTION

DoD 4161.02 Accountability and Management of Government Contract Property (cancels

DoD 4161.2-M) (April 27, 2012)

The DoD Components shall implement the policies and procedures in a manner that will

ensure proper management, control, reporting, and disposal of Government property in the

custody of contractors.

All government property with a unique item identifier (UII) shall be reported to

the DoD IUID Registry as being receipted.

All GFP without a UII assigned shall be reported to the IUID Registry as being

in a GFP state. Government and Contractor are responsible for performing

this requirement. DoD Components shall use electronic transactions when

transferring Government property to a contractor and upon return of property

to DoD. Government and Contractor are responsible for performing this

requirement using iRAPT (formally known as WAWF).

Require contractors to use the iRAPT to receipt property transfers or use DLMS

standard logistic transaction set 527R, available on the DLMS Supplements

page of the DLMS website to provide materiel receipt acknowledgment citing

the applicable contract number for property shipments.

Cite a contract number and, where applicable, the call or order number,

in electronic transactions under which the property is accountable for

stewardship, if known at the time of shipment. If not known, record the contract

number in the accountable property system of record within 30 days of receipt.

Government and Contractor are responsible for performing this requirement

using Contract Property Management Systems and WAWF.

Require contractors to report GFP to the DoD IUID Registry and its integral GFP

module in accordance with subparts 211.274-4 and 252.211-7007 of DFARS,

current edition. Contractor is responsible for this requirement using Contractor

Property Management Systems and IUID Registry.

Use the DoD IUID Registry and its integral GFP Module as the master data

source for reporting GFP in custody of contractors to:

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Require that contractors, as part of the required receipt of any

government property, report to the DoD IUID Registry using WAWF,

DLMS transactions, or direct update of the Registry. The receipting

transaction shall identify the property by the data elements specified in

subpart DFARS 252.211-7007, current edition.

Ensure appropriate accountable property records are maintained

utilizing the data reported in the DoD IUID Registry and its integral GFP

Module in accordance with DoD Instruction 5000.64, “Accountability

and Management of DOD Equipment and Other Accountable

Property,” May 19, 2011.

Contactor-Aquired Property (CAP) – While retaining title to property on cost

type contracts, the DoD components shall ensure that CAP is not recorded in

Government accountable property systems of record until receipt or acceptance

in accordance with DoD Instruction 5000.64, “Accountability and Management

of DOD Equipment and Other Accountable Property,” May 19, 2011 and DFARS

Guidance and Information, Subpart 245.4.

Establish accountability of CAP by ensuring the contractor maintains an

adequate property system in accordance with the current requirements of FAR

52.245-1 (b) (1). Government and Contractor are responsible for performing this

requirement; contractor using its Contractor Property Management System.

Establish accountable property records for CAP only upon delivery to or

acceptance by the Government on a contract line item (CLIN) in the DoD

Component’s accountable property system of record. Contractor is responsible

for performing this requirement using its Contractor Property Management

System.

Contractor Access to the DoD Supply System: The DoD Components shall

provide contractor access to DoD supply sources for requisitioning Government

property and account for this property under FAR Part 51.

Ensure that all contractor requisitions of Government property include the

contract number under which requisition authority is granted. Contractor is

responsible for performing this requirement using its Contractor Property

Management System.

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Identify non-serialized Government contract property authorized for contractor

requisition on a non-reimbursable basis by the data elements in DFARS

Guidance and Information, 245.201-72(2).

Maintain accountability of each GFP item meeting the requirements of DFARS

subpart 252.211-7007 by its UII.

Maintain accountability of GFP items not marked with a UII using the NSN,

manufacturer’s part/model/lot number and CAGE or NCAGE code for the

applicable unit of measure. Serial numbers for items subject to serialized

item management, but not yet marked with a UII, shall be provided. Items not

identified to an NSN or manufacturer’s part number/Cage code combination

shall be further identified by description.

GFP is either assigned a UII and tracked using the UII or is not assigned a UII

and is tracked using NSN or other identifier. The preference is that items that

meet the UID criteria according to the contract are identified and marked prior

to GFP custody transfer. If UII assignment and marking is not possible before

custody transfer, DoD may include the UII assignment and marking as an

additional contractor task while the items are in custody.

DoD 5000.64 - Accountability and Management of DoD Equipment and Other

Accountable Property (May 19, 2011)

Establishes accountability and management of tangible DoD-owned equipment and other

accountable property; establishes policy and procedures and outlines requirements that

reflect the accountability perspective of property management, which supports

the lifecycle management of items to include documentation of lifecycle events and

transactions. Although the Department of Defense may not have physical custody, in order

to maintain effective property accountability and for financial reporting purposes, DoD

Components shall establish and maintain records and accountability for property (of any

value) furnished to contractors as Government furnished property (GFP).

DoD 8320.04 – Item Unique Identification (IUID) Standards for Tangible Personal Property

(September 3, 2015)

The DoD IUID Registry shall be the master data source for the identification of GFP in the

custody of contractors in accordance with DoDI 4161.02.

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DoD PROCEDURES, GUIDANCE AND INFORMATION (PGI)

PGI 245.103.70 Furnishing Government property to contractors. (November 6, 2014)

PGI 245.103-71 Provides guidance on transferring accountability to new or follow on

contracts. (November 6, 2014)

1. The Standard Form 30, Amendment of Solication/Modification of Contract, is

the only form used to execute transfers of Government property accountability

between existing contracts. No other forms or documents, such as the DD

Form 1149, Requisition and Invoice/ Shipping Document, are authorized for the

transfer of Government property accountability from one contract to another.

2. Modifications for the transfer of Government property accountability shall:

i. Use the fillable PDF formats prescribed at http://www.acq.osd.mil/dpap/

dars/pgi/pgi_htm/PGI245_1.htm.PGI 245.103-72.

ii. Incorporate FAR clauses 52.245-1, Government Property, and 52.245-9, Use

and Charges, and the associated DFARS clauses (see http://www.acq.osd.

mil/dpap/dars/dfars/html/current/245_1.htm.245.107, Contract clauses) to

the extent that the gaining contract lacks the required clauses.

Government property can only be transferred from one contract to

another when firm requirements exist under the gaining contract (see

FAR 45.102, Policy.). Such transfers shall be documented by modifications

to both gaining and losing contracts. (Note: This also applies to orders

issued under the same contract.) Once transferred, all property shall be

considered GFP when retained by the contractor for continued use under

the gaining contract.

PGI 245.103-72 Government-furnished property attachments to solicitations and awards.

When GFP is anticipated, include the fillable electronic “Requisitioned

Government Furnished Property” and/or “Scheduled Government Furnished

Property” formats provided at the URLs listed in paragraphs (b) and (c) in

solicitations and awards to specify the required GFP data elements; and

accomplish the electronic transmission of requisitioned GFP lists and/or

scheduled GFP lists.

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Requisitioned GFP format is a listing of Government Property to be authorized

for contractor requisition from DoD supply sources in accordance with the

clause at FAR 52.251-1. The fillable PDF format for this attachment is available

at http://dodprocurementtoolbox.org/site/detail/id/26. In accordance with PGI

204.7105(b)(5) (DFARS/PGI view), enter a numerical sequence number for the

attachment.

Scheduled GFP format is a listing of the Government property to be provided,

including when major end items are being provided under a modification

or upgrade contract; or when reparables are being provided under a repair,

modification, or overhaul contract. The fillable PDF format for this attachment

is available at the DoD Procurement Toolbox http://dodprocurementtoolbox.

orgsite/detail/id/26. In accordance with PGI 204.7105(b)(5) DFARS/ PGI view),

enter a numerical sequence number for the attachment.

The GFP Attachment format has been updated to better serve the property

management community. The new GFP Attachment should be used in

solicitations and contract awards. This attachment can be found in the DoD

Procurement Toolbox www.dodprocurementtoolbox.com ; Government

Furnished Property tab; Attachment information bullet.

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How A2B Tracking Supports Property Managers

A2B Tracking provides essential support for the Property Manager by making sense of

these contract obligations and simplifying these challenges by developing a government

Property Management System called UC! Web™ that was specifically designed for US

military requirements and to comply with FAR 52.245-1 (Government Property), DFARS

252.211-7003 (Item Identification and Valuation) and DFARS 252.211-7007 (Reporting of

Government Furnished Property). It’s different from other systems because it was designed

from the ground up with military standards for asset identification (IUID and RFID) as well as

integrated iRAPT and IUID Registry reporting as core capabilities.

UC! Web™ is military-grade software that lives in the cloud and lets you take control of your

assets and inventory by tracking and reporting serialized and non-serialized items. Create

linear or 2D Data Matrix barcodes (IUID) and RFID labels, and track any mission critical asset

or corporate asset for accurate data from the very start.

UC! Web™ was designed for enterprise asset management, tracking and military reporting

from acquisition and receipt through final disposition. Capture and record all historical events

and transaction history. Manage contract and subcontract data and asset assignments.

Print, mark, track, ship and update the status of any asset using IUID or RFID throughout its

lifecycle and perform physical inventories throughout the year. Manage and report items to

be main tained internally as well as property transfers while automatically reporting to iRAPT

and the IUID Registry. Generate DD250s, DD1149s and other custody transfer documentation

automatically.

UC! Web facilitates compliance for branches of the military as well as DoD contractors and

suppliers who support them. Plus, you’ll be using best practices set by the U.S. military for

asset tracking and reporting of shipments.

One Solution to Meet all Requirements:

• FAR 52.245-1 Government Property

• DFARS 252.211-7003 Item Identification and Valuation

• DFARS 252.211-7007 Reporting of Government Furnished Property

• DFARS 252.211-7006 Passive Radio Frequency Identification

• DFARS 252.245-7001 Tagging, Label, and Marking of Government-Furnished Property

• DFARS 252.245-7002 Reporting Loss of Government Property

• DFARS 252.245-7003 Contractor Property Management System Administration

• DFARS 252.245-7004 Reporting, Reutilization, and Disposal

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About A2B Tracking

A2B Tracking has pioneered military-grade enterprise-class solutions for identifying, marking

and tracking critical assets for DoD agencies and the contractors who support them. We’ll

help your enterprise take control of your assets by providing you cloud-based asset tracking

and data management solutions that incorporate advanced barcode and RFID technologies.

We enable total compliance to military asset and shipment identification standards and we

automate your reporting to government systems.

What Sets A2B Tracking Apart?

1. Military Proven: Our secure cloud-based tracking solutions are more intuitive and

can be deployed and integrated faster than the competition. We’re military-tested

and proven in the most complex and harshest of environments.

2. Deep Expertise: We have a 20-year track record of enabling DoD agencies and

military contractors of all sizes to fully comply with constantly evolving policies

and requirements for asset identification, marking, tracking and reporting.

3. Customer Centric: Our unwavering commitment to customer success through

tightly coupled solutions and services.

Call the Experts

Learn more about how UC! Web™ will give you greater control over all your

assets, parts and tools, improve decision making, and enhance the overall

performance of your enterprise.

Call A2B Tracking at 1-800-733-7592. Or email sales@a2btracking.com.

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DEFINITIONS

Defense Logistics Management System (DLMS)

DLMS is a broad base of business rules implemented to support commercial Electronic

Data Interchange (EDI) transaction sets and to facilitate the elimination of Military

Standard Logistics System (MILS) transactions. MILS transactions are limited to 80

characters and lack the data content needed to adequately identify critical GFP data.

DLMS messages are generally used to convey property transfer data related to items

that are enhanced to incorporate data required to support GFP visibility. To support

adequate GFP visibility and processing, it is imperative that DoD and Contractor

systems interfacing with the DoD Supply System upgrade to accommodate the

enhanced DLMS data structure. As defined in DoD Government Furnished Property,

Operating Guide, Version 0.2, June 2012.

Global Exchange Services (GEX)

GEX provides broker and mediation services between government agencies,

commercial industry, and government systems. To support GFP processing, DoD

systems and Contractor systems may send electronic property transfer messages

to GEX which are transferred and transmitted to WAWF. As defined in reference DoD

Government Furnished Property, Operating Guide, Version 0.2, June 2012.

Government Furnished Property (GFP)

Property in the possession of, or directly acquired by, the Government and subsequently

furnished to the contractor for performance of a contract. Government furnished

property includes, but is not limited to, spares and property furnished for repairs,

maintenance, overhaul, or modification. Government furnished property also includes

contractor acquired property if the contractor acquired property is a deliverable under a

cost contract when accepted by the Government for continued use under the contract.”

Reference: FAR Part 45.101. Invoice, Receipt, Acceptance and Property Transfer

(iRAPT) iRAPT was known as WAWF until release 5.6.0 in 2014. iRAPT is a secure,

Web-based system that is a paperless contracting environment allowing vendors and

government users to submit invoices and receiving reports (DD250s) electronically free

of charge. It enables contractors to transmit shipping notices electronically and DoD to

perform both receipt and acceptance electronically. iRAPT enables electronic form of

submission of invoices, government inspections and acceptance documents. If DFARS

252.232-7003 Electronic Submission of Payment Requests and Receiving Reports (June

2012) appears in the contract, iRAPT (formerly WAWF) should be used for electronic

submissions.

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Item Unique Identification Registry (IUID)

IUID is the data repository for items where unique identification is required pursuant to

the OSD Policy for Unique Identification and DFARS 252.211-7003 and 252.211-7007.

The primary mission of the IUID Registry is to receive and store IUID pedigree data for

the military services. The IUID Registry is the authoritative source for DoD for IUID data.

Data is received via iRAPT/ WAWF transactions, system data exchanges, and direct

submissions to the Registry. The IUID Registry has been enhanced to capture UII’d and

non-UII’d GFP to support GFP visibility. It serves as an acquisition gateway to identify:

• What the item is

• How and when it was acquired

• The initial value of the item

• Current custody (government or contractor)

• How it is marked

GFP items in the IUID Registry may or may not be uniquely identified. For more

information regarding GFP see http://dodprocurementtoolbox.com/page/gfp.

REFERENCES

Federal Acquisition Regulation, current edition

Defense Federal Acquisition Regulation Supplement, current edition

DoD Instruction 4161.02, “ Accountability and Management of Government Contract Property,” April 27, 2012

DoD Instruction 5000.64, “Accountability and Management of DoD Equipment and Other Accountable Property,” May 19, 2011

DoD 8320.04, “Item Unique Identification (IUID) Standards for Tangible Personal Property,” DoD Government Furnished Property, Operating Guide, Version 0.2, June 2012Defense Federal Acquisition Regulation Supplement Procedures, Guidance and Information, current edition

DFARS 252.211-7003, “Item Unique Identification and Valuation” March 2016 DFARS 252.242-7005, “Contractor Business Systems”, revised February 2012DFARS 252.211-7007, “Reporting of Government-Furnished Equipment in the DoD Item Unique Identification (IUID) Registry” August 2012

Business Dictionary-binding-contract

Information in this document may be subject to change without notice. This document and all of the information it contains, is provided “as is” as of November 2016.

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www.a2btracking.com • (800) 733-7592 • sales@a2btracking.com