This Article Was Written by Pat Jacklets, formerly the Manager of Property Management for Northrop Grumman’s Aerospace Systems Sector Eastern Region. She is currently A2B Tracking’s Asset Management Expert.
I’ve recently returned from Nashville after attending the 2016 National Education Seminar for the National Property Management Association. I conducted two sessions – one was for the Special Interest Group (SIG) on Item Unique Identification (IUID). I was amazed at how many folks out there are just embarking on the IUID journey! It is a reflection of the government issuing contracts that require IUID compliance with new products and with GFP reparables and reporting.
New Receiving Report
While at the NES, the Government issued a final rule on the use of the WAWF Receiving Process for “Reparables”. A new receiving report, WAWF RRR, is required when invoicing the government for reparables that are GFP. It combines the invoicing and reporting of the return of the GFP reparable item.
Other changes are on the way too!
The Government issued a revised Procedure Guidance and Instruction: PGI 245.402-71 on the delivery of Contractor Acquired Property (CAP). The PGI provides direction to the Government on certain events that require CAP to be a delivery at which time the property becomes GFP.
The National Defense Industry Association (NDIA) reported that the DAR Council is working to issue a proposed DFARS rule on the Use of the Government Property Clause.
“It expands the prescription for use of FAR clause 52.245-1, Government Property, to: (1) all purchase orders for repair, regardless of the acquisition cost of items to be repaired; and (2) all commercial contracts where the Government is providing property, regardless of the acquisition cost of the property.”
It is identified as DFARS Case 2015-D035 affecting DFARS Policy 245.107. This opens additional reporting requirements for contractors
It was also interesting to note that there are companies out there doing manual entry with thousands of items to enter or using spreadsheets to keep track of what has or has not been reported. Manual entry is not a long term solution when you have more than a few items to report. It is not only inefficient, compared to an automated system; but, there is also a high chance for errors and problems that can lead to DCMA Audit trouble.