IUID and Government Furnished Property Basics

1. IUID and Government Furnished Property Basics Carol Vigna, OSD AT&L DPAP carol.a.vigna.civ@mail.mil David Guinasso, supporting OSD AT&L DPAP dguinasso@altamconsult.com 24 June 2014

2. DISCLAIMER • 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. 2

3. Why is Knowing about GFP Important? • Currently: • We don’t know what we own. • We don’t know where it is. • We don’t know what it’s worth. • Therefore: • We don’t get the most value out of what we own. 2 3

4. Synchronizing the Policy DoDM 4140 Policies based on 19 business rules ensuring consistency of policy and terminology across organizations 4

5. Types of Government Property on Contracts • Government Property on a contract may be Contractor Acquired Property or Government Furnished Property. • These two types of property have many common requirements, but each also has its own unique requirements. 5

6. Definitions • Government Furnished Property (GFP) – is defined as property in the possession of or acquired by the Government and subsequently furnished to the Contractor for performance of a contract. It includes items like spares and property furnished for repair, maintenance, overhaul, or modification. It can be items taken or requisitioned from Government inventory or purchased by the Government specifically to be provided on a contract. (Includes GFM and GFE.) • Contractor Acquired Property (CAP) - is property purchased or fabricated by a contractor for use on a contract to which the Government has title but has not performed receipt and acceptance. CAP is usually generated on Cost Type and Time and Material contracts where the Government has title to property that is fabricated or purchased for use on the contract. • GFP also includes contractor-acquired property if the contractor-acquired property is a deliverable under a cost contract that has been accepted by the Government for continued use under that contract or a future contract. 6

7. GFP and CAP Differences • The differences between CAP and GFP start at the beginning of the acquisition process. • CAP or the potential for CAP is driven by the decision on the type of contract. • Providing GFP on the other hand is a business decision. 7

8. Property in the Business Enterprise Architecture P2P Process Award Procurement Instrument Administer Procurement Instrument Perform Receipt, Acceptance, Return Manage Disbursement Perform Procurement Instrument Closeout Manage Procurement Instrument Entitlement Sub-processes Issue Contract Completion Notices Accept Products / Services Award Procurement Instrument Administer Government Property Data Object Contractor Receipt of GFP Plant Clearance Disposition Instruction Advanced Shipment Notice Property Transfer Disposition of Loss Acceptance List of GFP Provided by the Government Contract Completion Notice List of GFP Transferred to next contract Procurement Instrument WAWF IUID Registry APSR Logistics Systems ERPs WAWF IUID Registry APSR Logistics Systems ERPs LTDD PCARSS CWS GFP Attachment EDA CWS PCARSS GFP Attachment EDA System 8

9. GFP and Acquisition Planning • The Government makes the decision during acquisition planning about whether or not to provide GFP. • The requiring activity (project or program manager, or purchase request generator), as part of its responsibility for acquisition planning (FAR part 7, Acquisition Planning), is the decision point as to whether or not to furnish property to contractors. • The basis for providing GFP must be documented in the contracting file except when the property is provided to be repaired, modified, or overhauled under a contract. • The decision to provide GFP is not made by the contractor. • Reference: PGI 245.103-70 Furnishing Government property to contractors. 9

10. When it’s allowable to Provide GFP FAR 45.102: Contracting officers shall provide property to contractors only when it is clearly demonstrated— “To be in the Government’s best interest; that the overall benefit to the acquisition significantly outweighs the increased cost of administration; that providing the property does not substantially increase the Government’s assumption of risk; and that Government requirements cannot otherwise be met. The contractor’s inability or unwillingness to supply its own resources is not sufficient reason for the furnishing or acquisition of property.” 10

11. GFP Attachments • The Government is required to list the property it will provide and information and data about that property (FAR 52.245-1). • To ensure all required data and information is provided DoD has implemented standard property attachments (PGI 245.103-72). • There are two formats for the attachment: • Scheduled GFP • Requisitioned GFP • The Contracting Officer, with the input of the requiring activity, will ensure the attachment is included in solicitations and awards. 11

12. Property Clauses MANDATORY • FAR 52.245-9 Use and Charges, in solicitations and contracts when the clause at 52.245-1 is included. • DFARS 252.245–7001 Tagging, Labeling, and Marking of Government-Furnished Property, in solicitations and contracts that contain the clause at FAR 52.245-1, Government Property. • DFARS 252.245–7002 Reporting Loss of Government Property, in solicitations and contracts that contain the clause at FAR 52.245–1, Government Property. • DFARS 252.245-7003 Contractor Property Management System Administration, in solicitations and contracts containing the clause at FAR 52.245-1, Government Property. • DFARS252.245–7004 Reporting, Reutilization, and Disposal, in solicitations and contracts that contain the clause at FAR 52.245-1, Government Property. • DFARS 252.211-7007 Reporting of Government-Furnished Property, in solicitations and contracts that contain the clause at FAR 52.245-1, Government Property. OPTIONAL • DFARS 252.245-7000 Government-Furnished Mapping, Charting, and Geodesy Property, in solicitations and contracts when mapping, charting, and geodesy property is to be furnished. 12

13. GFP Regulations- DFARS PGI • DFARS Procedure, Guidance and Information (“PGI”) • PGI 245.1 Government Furnished Property-General • PGI 245.103-72 Guidance to determine if government property should be furnished to contractors • PGI 245.2 Government Furnished Property-Solicitation and Evaluation Procedures • PGI 245.201-71 GFP Attachments to Solicitations and Awards • PGI 245.402-71 Title to Government Property 13

14. IUID and Property It is DoD policy that DoD item unique identification, or a DoD recognized unique identification equivalent, is required for all delivered items, including items of contractor-acquired property delivered on contract line items (see PGI 245.402-71 for guidance when delivery of contractor acquired property is required), Regardless of value for any Item of special tooling or special test equipment, as defined at FAR 2.101, for a major defense acquisition program that is designated for preservation and storage in accordance with the requirements of section 815 of the National Defense Authorization Act for Fiscal Year 2009 (Pub. L. 110-417). It is DoD policy that all Government-furnished property be recorded in the DoD Item Unique Identification (IUID) Registry, as defined in the clause at 252.211-7007 14

15. WAWF & the IUID Registry WAWF IUID Registry Delivery of new property Transfer of Property Contractor Receipt of GFP Delivery & Shipment of Reparables Government Receipt of Property GEX Records for UII’d items and non-UII’d GFP APSR Records about a Components Property for financial reporting Electronic capture of valuation and movement to establish Existence and Completeness for Auditability 15

16. For Contract Management IUID Registry Records for UII’d items and non-UII’d GFP Property Loss Tool (PLT) APSR Plant Clearance Automated Reutilization and Screening System (PCARSS) Records about a Components Property for financial reporting Reporting the “Death” of Property 16

17. On the Horizon • Data Integrity • SSAE 16 review of WAWF • AT&L review of integrity of the Registry • Significant issues with direct entry data • Fewer issues with WAWF data • Merger of WAWF and IUID Registry • Eliminate duplicate data storage • Improve data integrity • Simplify user access controls, help desk • WAWF Mobil Property Transactions • Make the best method of data capture available anywhere 17

18. For more information GFP Policy Training, Procedures, Tools http://www.acq.osd.mil/dpap/pdi/gfp/index.htmlwww.dodprocurementtoolbox.com or Contact Carol Vigna at carol.a.vigna.civ@mail.mil or 703-697-4373 18

19. Any Questions? 18