AIA Q&A Panel

1. AIAQ&A Panel Cinda Brockman Rich Culbertson Brandon Kriner Pam McFarland Tamra Zahn

2. Participating Companies

3. AIA Panel DiscussionNPMA Educational Conference Series 1 - West Question/Scenario When will we see a formally released copy of the replacement DOD 4161.2-M DCMA manual? Response: • DOD manual has been rescinded 2/08 • DCMA uses as a reference. • Available on DOD website. • DCMA Guidebook developed 9/09 AIA website http://www.aia.aerospace.org

4. AIA Panel DiscussionNPMA Educational Conference Series 1 - West Question I would like to see an example or template style for a metric designed for responding to ASTM E2132-01 Standard Practice for Physical Inventory of Durable, Moveable Property. Response: The standard provides a method for calculating the annual overage and loss rate by both value and number of line items. AIA website http://www.aia.aerospace.org

5. AIA Panel DiscussionNPMA Educational Conference Series 1 - West (# or $ of missing assets / # or $ of total population) Loss Rate = Time in years since last inventory (# or $ of overages/ # or $ of total population) Overage Rate = Time in years since last inventory • Excessive losses indicate possible weaknesses in record keeping and property control • Excessive overages indicate possible weaknesses in receiving and identification (tagging) processes • The standard does not prescribe “acceptable” overage or loss rates- must be taken in context of business or contract requirements and nature of assets under control AIA website http://www.aia.aerospace.org

6. AIA Panel DiscussionNPMA Educational Conference Series 1 - West Asset Counters, Inc. had 189,087 assets at the end of its 2007 annual inventory. At the end of the inventory, 12,987 assets were missing and there were 19,923 overages. This inventory was the company’s first since 2004. What was the company’s physical inventory picture in 2007? (12,987/189,087)/3 = 2.3% annual loss rate (19,923/ 189,087)/3= 3.3% annual overage rate Would this loss rate be acceptable at your organization? What about the overage rate?. AIA website http://www.aia.aerospace.org

7. AIA Panel DiscussionNPMA Educational Conference Series 1 - West AIA website http://www.aia.aerospace.org

8. AIA Panel DiscussionNPMA Educational Conference Series 1 - West Question/Scenario Who can revoke a Government’s assumption of risk of loss? Response: FAR 45.104 (b) (b) “The contracting officer may revoke the Government’s assumption of risk when the property administrator determines that the contractor’s property management practices are inadequate and/or present an undue risk to the Government.” FAR 52.245-1 (h) (1) (iii) The Contracting Officer has, in writing, revoked the Government’s assumption of risk for loss, theft, damage or destruction….. AIA website http://www.aia.aerospace.org

9. AIA Panel DiscussionNPMA Educational Conference Series 1 - West Question/Scenario What is the procedure for changing the FAR and DFAR? AIA website http://www.aia.aerospace.org

10. AIA Panel DiscussionNPMA Educational Conference Series 1 - West Response: • Issue can come from a variety of sources – • government agencies , industry, from Congress ,from audit reports or from the people who make up the DAR and FAR Council staffs. • DAR or FAR staff will write up a description of the issue and ask the DAR or FAR Council itself to agree to open a case.   • When a rule is ready to go out for public comment, it goes to the appropriate Council to be considered.   • Office of Information and Regulatory Affairs (OIRA) at OMB for clearance.   • Once it clears OIRA, it goes to GSA for publication in the Federal Register • Finally, out to the public for comment. • After the close of public comments- • Issue team considers the comments and makes adjustments to the rule.   • All comments received must be considered and adjudicated  and identified in the final rule summary.   • The final rule is considered and voted on by the appropriate Council, goes back to OIRA, and, if approved, goes to GSA for publication in the Federal Register as a final rule. AIA website http://www.aia.aerospace.org

11. AIA Panel DiscussionNPMA Educational Conference Series 1 - West Example of Proposed Rule DFAR Case 2009-D043 in the making • Federal Register for Public Comment 12/22/10 • Comments due 2/22/11 • Met with Industry reps to document concerns • Requested Public Meeting and extension to comment 1/18/11 • Public Meeting 3/18/11 • Comments ECD extended 4/8/11 AIA website http://www.aia.aerospace.org

12. TIP OF THE DAY Review the DPAP website weekly for new rules. http://www.acq.osd.mil/dpap/dars/index.html AIA website http://www.aia.aerospace.org

13. AIA Panel DiscussionNPMA Educational Conference Series 1 - West Question/Scenario Can anyone comment on “proposed rules”? Response: Public is given the opportunity to comment during the “proposed rule” Directions on how to comment are provided in the proposed rule The public comment period generally lasts 60-90 days. Any person or group may comment on a rule and can easily submit comments online. There are three basic steps to commenting on rules online. Regulations.gov Step 1: Know Your Rule Step 2: Find Your Rule Online Step 3: Submit Your Comments AIA website http://www.aia.aerospace.org

14. AIA Panel DiscussionNPMA Educational Conference Series 1 - West Question/Scenario Our CSA plans and processes are not being accepted by our GPA. Is there anything we can do about this? Response: 2009 DCMA Guidebook Determine Type and Frequency of Review.   Based on the annual risk assessments, the PA shall conduct a standard or limited PMSA to determine if the contractors’ property management system is adequate to satisfy the requirements of FAR 52.245-1, Government Property. The PA should consider whether the contractor’s self-assessment procedures and the results of those procedures can be relied on to demonstrate that the contractor is compliant with the FAR requirements.  The PA should work collaboratively with the contractor to ensure an understanding of the contractor’s operation and use of Voluntary Consensus Standards (VCS) and Industry Leading Practices (ILPs).  AIA website http://www.aia.aerospace.org

15. AIA Panel DiscussionNPMA Educational Conference Series 1 - West Questions? AIA website http://www.aia.aerospace.org