2011 NPMA Conference Series III National Capital Area Conference Leaders in Asset Management...
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Transcript of 2011 NPMA Conference Series III National Capital Area Conference Leaders in Asset Management...
2011 NPMA Conference Series III
National Capital Area ConferenceLeaders in Asset Management
National Capitol Area Conference
November 14, 2011
2011 NPMA Conference Series III
National Capital Area Conference
10:15 AM
LeAntha SumpterLegislative and Regulatory Changes
Department of Defense Government Property
Defense Procurement and Acquisition Policy
November 14, 2011
Government Furnished Property
The Problem with Government Furnished Property
We aren’t sure of what we haveWe aren’t sure where it isWe aren’t sure what its worthWe don’t think its where we need it
Audits related to GFPGeneral Accountability Office (GAO) GAO-04-779, Navy Needs to Improve the Management Over Government-Furnished Material Shipped
to Its Repair Contractors, July 23, 2004
US Army Audit Agency (USAAA) Report No. A-2005-0126-FFE, Management of Government Furnished Property, U.S. Army Garrison, Fort Hood, Texas, dated, Mar 4, 2005.
GAO Report No. GAO-08-316R. Subject: Defense Logistics: The Army Needs to Implement an Effective Management and Oversight Plan for the Equipment Maintenance Contract in Kuwait, dated January 22, 2008
DoD Inspector General (DoD IG) Report No. 2009-089, Internal Controls Over Government Property in the Possession of Contractors at Two Army Locations, dated June 18, 2009.
USAAA Report No. A-2009-0183-ALL, Applying Agreed-Upon Procedures to Determine if There Was a Potential for Theft of Property and
Loss of Funds to the Government Due to the Actions of a Government Property Administrator, dated August 14, 2009.
USAAA Report No. A-2010-0018-ALL, Audit of Management and Visibility of Government Property Provided to the Contractor Performing Bulk Fuel Operations in Kuwait, dated December 17, 2009.
AFAA Report No. F2010-0005-FB3000, Government Furnished Equipment Financial Statement Reporting, dated January 11, 2010.
USAAA Report No. A-2010-0133-FFE, Time Sensitive Report - Accountability of Contractor Acquired Property, Audit of Planning for Disposal of Chemical Demilitarization and Storage Facilities, dated July 13, 2010.
DoD IG Report No. D-2010-088, Accountability and Disposition of Government Furnished Property in Conjunction with the Iraq Drawdown
– Logistics Civil Augmentation Program, dated September 30, 2010.
Government Furnished PropertyBusiness Rules*
• Electronic transactions will be used to transfer government property to a contractor and/or return property to DoD. Contractors and DoD components shall confirm receipt by contract number for property received electronically.
• All transactions used to transfer property to contractor custody or return property to DoD custody shall cite contract number under which the property is or was accountable for stewardship
• For contractor requisitions of GFP, the DoD components shall capture or link to the contract number under which requisition authority to contractors is granted, and shall reject any contractor requisitions that are not authorized.
*January 11, 2010 DPAP Memo
Government Furnished PropertyBusiness Rules* (Con’t)
• Consistent with FAR 45.201, GFP requirements shall be fully described and listed in an Attachment in any solicitation or contract to notify the contractor of those items of GFP that are due-in from DoD or that are authorized for requisition from a DoD Component supply source.
• GFP transfer transactions and receipts for non-UII’d property shall be routed to a GFP Hub co-located with the DoD IUID Registry as a prototype effort until Defense FAR Supplement guidance is final.
*January 11, 2010 DPAP Memo
Synchronizing the PolicyMaterial/Logistics
Equipment/Accountability
Acquisition/GFP
DoDM 4140 DoDI 5000.64 DoDI 4161.02
Re-write in progress Signed May 2011 In coordination
Ensuring consistency of policy and terminology across organizations and functions
The Vision to Accompany the PolicyUsing automation, data standards and standard
electronic transactions (together with business rules) to:– Standardize– Simplify– Provide accountability– Provide visibility– Provide efficiency– Eliminate multiple redundant requests for data– Communicate with humans in a consistent fashion
Today’s Regulatory Baseline• Two property clauses published in the last five (5) years
– 52.245-1 (June 2007)– 52.245-1 (August 2010)
• A third FAR revision is now completed– Will be published in 2011– Focus: property disposition and plant clearance
• New PGI 245 – Government Property
• Six new DFARS clauses now in place:– 252.211-7007 Reporting GFE to the UID registry– 252.245-7001 Tagging, Labeling and Marking of GFP– 252.245-7002 Reporting Loss of Government Property– 252.245-7003 Contractor Property Management System Administration– 252.245-7004 Reporting, Reutilization, and Disposal– 252.242-7005 Contractor Business Systems
• Revision to 252.211-7007 in process
DFARS Case 2009-D043: Reporting GFP to the DoD Registry/Hub• Revises current DFARS clause 252.211-7007
– Removes some reporting exception– Removes dollar threshold on reporting
• Status: – Proposed Rule published Dec. 22, 2010 (canceled) – Public Meeting conducted March 18, 2011– Case rewritten based on comments and public meeting– Published in the Federal Register October 14, 2011 under
new case number 2010-D001– Public Meeting scheduled for November 17, 2011
12
252.211-7007 Revision
WAWF is part of the solution
GEX
Vendors
WAWF
View Only Users-ContractingOfficer-Payment Clerks
GovernmentWorkflow Users-Inspectors-Acceptors-Auditors-Certifiers-Receivers
Vendor EDIGEX
Vendor FTP
Vendor Web
Vendor EDI
Create•Invoice•Receiving Report•Property Transfer•View status
•Process Invoice/RR•Create and Process Property Transfer and Misc Pay
CCR
IUIDRegistry
LogisticsSystems
EntitlementSystems
• MOCAS - DCMA• SAMMS - DLA• EBS* - DLA• One Pay - Navy• CAPS - Army/ODAs• IAPS – AF• Navy ERP*•DAI*
• ACMS - JS• EBIZ - DFAS• SABRS – USMC• Navy ERP• STARS•DAI*
View
Property MgmtSystems
AFEMS
DPAS
PBUSE
WAWF RolesWAWF Roles
AccountingSystems
Cont
ract
Dat
a
Contract
Data
DoDA
ACs (
Govt
Ad
dres
s Cod
es)
Cont
ract
Dat
a
Unique Identifier
CAGEs (Vendor
Address Codes)
Contract Writing Systems (7)DAASC
EDA
GFP Process Flow – Govt to Contractor
WAWF Property Transfer
Contract w/GFP
Material Control Activity
Contractor Receiver
Items being sent Items being sent
Items received
UID Registry
Custody updated
Items received
PropertyAccountability
Cust
ody u
pdat
ed
Organization input can be manual web input or system electronic formatted message
LTDD
PCARSS
GFP Module in the IUID Registry
Non-UII’d UII’d
GFP Module
IUID Registry
WAWF,Property Systems
Property Systems
Bulk Load XML
527RXML
GEX
Bulk Load XML
DAASC
Supply Systems
MILS X12 DLMS
Transactions
DCMAeTools
GEX
15
GFP Pilot Participants
Vendors
Bell
Boeing
Lockheed
Northrop
Raytheon
Government
Air Force
Navy
Marines
Pilots will run through 2nd quarter FY12
Participants will pilot portions of the functionality with and without a Government trading partner
Additional participants being accepted
Events•WAWF and Registry capability for UID’d items Now•WAWF Capability for non-UIIs Now•Registry capability for non-UII’d property Now•Bulk upload of non-UII property Dec 2011•Pilot/Test GFP Capabilities* July 2011 - January 2012•Complete remaining property cases CY 2012•GFP Module user interface February 2012
Warranty Traceability
IUID Items OnlyPhase I
Warranty Data – An Evolving Plan
Warranty Planning Process Contract Writing
Receipt & Acceptance
Use Phase
Establish requirement
Forward demand to contracting office
Identify warranty requirements
Incorporate government warranty requirements
into solicitation Proposal submitted
Award contract w/ warranty provisions
Evaluate proposed warranty provisions &
cost
Send warranty data to be centrally
retrieved
Contractors deliver goods via WAWF
Create & deliver warranty data (not
available in contract)
Government/Industry records a warranty issueForward warranty data from
contract & acceptance so it can be retrieved
DoD Warranty GuideFAR/DFAR
Past Performance & Quality Assurance Sandbox
246.710-70 Warranty attachment.This is the prescribed attachment and format required and referenced in the provision at 252.246-7005, Notice of Warranty Tracking of Serialized Items, and the clause at 252.246-7006, Warranty Tracking of Serialized Items. The contracting officer shall number the attachment upon issuance of the solicitation and include the solicitation or contract number.
Preventing Counterfeit Parts
Anti-Counterfeiting• Strengthen policies requiring traceability of
procurement and quality assurance procedures at all tiers of supply chain
• Develop procedures and standards for quality assurance of commercial items
• Strengthen reporting requirements• Strengthen remediation procedures
Framework for Mitigation of High Risk Vendors, Parts, Programs, and Systems
Vendor Identification
High risk traceable
parts
High risk programs and
systems
Three way match•Part Number•Vendor•System or Program
How to identify suppliers who are
not DoD prime contractors
How to identify suppliers who are
not DoD prime contractors
How to identify high risk parts
(manual vs. automated)
How to identify high risk parts
(manual vs. automated)
PM level or DoD Level?
How to identify commercial parts
systematically
*Rulemaking required (FAR or DFARS Case)
R
R
How to determine links between parts and programs
How to determine links between parts and programs
BACKUP
GFP Business Rules• DoDI 8320.04• The DoD IUID Registry shall be the master data source for the identification of GFP in the hands of contractors.
• DoDI 4161.02 • All government property with a UII assigned shall be reported to the DoD IUID Registry as being reciepted.
• All government furnished property without a UII assigned shall be reported to the IUID Registry as being in a GFP state.
• Electronic transactions shall be used to transfer government property to a contractor and/or return property to DoD.
• Transactions transferring property from the government to contractor custody shall cite a contract number under which the property is accountable for stewardship, if known at the time of shipment.
• All contractor requisitions of Government property shall include the contract number under which requisition authority is granted.
• Accountability of contractor acquired property shall be established, not by maintaining accountable property records at the Component level, but by ensuring the contractor maintains an adequate property system in accordance with the requirements of FAR 52.245(b)(1).
• To the extent that visibility of CAP is required by the government, informational sub line items shall be established to identify each item requiring such visibility in accordance with the criteria of DFARS Subpart 204.7104-1(a).
• Accountable property records for CAP shall only be established upon delivery to the Government on a contract line item number (CLIN).
• GFE and serially managed GFM shall be identified and tracked through the use of unique item identifiers (UII), and non-serially managed GFM shall be identified by national stock numbers (NSN) in transaction-derived data from electronic business transactions
• PGI 245• GFP requirements shall be fully described and listed in an Attachment in the solicitation and contract to notify the
contractor of those items of GFP that are due-in from the government.
GFP Business Rules…continued• DFARS 245• GFP shall remain on a contractor’s stewardship records until government receipt or acceptance (as required) of the returned GFP asset is
complete
• When contractors receipt 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 within 30 days of receipt.
• DoDI 5000.64 and DoDM 4140• The DoD accountable property system of record shall be the authoritative source to establish the existence on a GFP item.
• An item of GFP shall only be recorded once in a DoD accountable property system of record.
• An item of GFP will remain recorded in a DoD accountable property system of record while in the custody of a contractor.
• Contractor systems and Government in-transit systems used to record receipt, custody or stewardship of GFP shall not qualify as authoritative DoD accountable property systems of record.
• DoDM 4140• Authorization of contractor access to the DoD supply system shall be managed using a single DoDAAC for each contractor location recorded in
the Central Contractor Registry, consistent with the provisions of FAR Subparts 51.102(c)(2) and 51.103(b)(1).
• DoDI 5000.64• When an item marked with a UII is embedded in an end item, it shall be assumed to remain in parent UII until a record indicates detachment.
2011 NPMA Conference Series III
National Capital Area Conference
LeAntha SumpterLegislative and Regulatory Changes