PROPERTY · BY MICHAEL BORDERNARO, ASSET LEADERSHIP NETWORK REGULAR FEATURES 04 National...

ALSO IN THIS ISSUEFor the Sake of Safety?

Federal Asset Management Forum

Tribute to James Martin Whalen, CPPM, CF

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ISSN-1072-2858

12.2015VOL 27 ISSUE 6

PROPERTYP R O F E S S I O N A L

T H E

Disposition of Supplier-Held

Property After Bankruptcy -A Case Study

A COMPARATIVE ANALYSIS OFContract Government Property Requirements:

FAR, Agency Supplements and Outliers!

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Entire contents © Copyright 2015 by the National Property Management Association, Inc. All

rights reserved. Reproduction of the contents of The Property Professional in whole or in part by

photocopying, entry into a data retrieval system or any other means is strictly forbidden.

The Property Professional is published bimonthly by the National Property Management

Association, Inc. and is mailed third class. The articles, opinions and ideas expressed by the

authors are the sole responsibility of the contributors and do not imply an opinion on the part

of the officers or members of NPMA. Readers are advised that NPMA is not responsible in

any way, manner or form for these articles, opinions and ideas. Readers are urged to exercise

professional caution in undertaking any of the recommendations or suggestions made by

the authors. The NPMA magazine welcomes and encourages contributions and suggestions

from its readers. Editorial policy dictates the right to edit or reject any material submitted for

publication. Advertising rates will be quoted upon request. Contact the National Office for

information at 404-477-5811.

POSTMASTER: Send change of address notices to Membership Coordinator, National Office -

NPMA, 3525 Piedmont Rd., Building 5, Suite 300, Atlanta, GA 30305. Phone: 404-477-5811;

Fax: 404-240-0998. The Property Professional subscription is included in the NPMA member’s

annual dues. Non-member subscription rate is $35/year.

SPECIAL FEATURES8 Memorial for James Martin Whalen,

CPPM, CF

BY ED WINTERS, CPPM, CF

20 Disposition of Supplier-Held Property

After Bankruptcy

BY RON REGALADO, CPPM, NORTH TEXAS CHAPTER

22 For the Sake of Safety?

BY RONNIE S. SPARKS, CPPM,

LAS VEGAS CHAPTER

26 Federal Asset Management Forum

Shows Potential for Dramatic Savings

of U.S. Tax Dollars

BY MICHAEL BORDERNARO,

ASSET LEADERSHIP NETWORK

REGULAR FEATURES04 National President’s Column

05 Editor’s Column

07 Special Interest Groups

17 #AssetManagement – Trending Now –

Controlled Substance Tracking

19 Puzzle Challenge

24 Ask the Expert

28 NPMA Foundation

EDUCATION30 January and February Course Schedule

ADVERTISERS02 AssetSmart

06 NPMA Call for Candidates

06 GP Consultants

16 Capitol Asset Resources

23 Metalcraft

29 NPMA NES

32 Sunflower Systems

Contract / Agreement ManagementA Comparative Analysis of ContractGovernment Property RequirementsFAR, Agency Supplements and Outliers! 10

V O L 2 7 I S S U E 6

COVER STORY

C O N T E N T S

BY DR. DOUGLAS N. GOETZ, CPPM, CF, MIAM, OHIO VALLEY CHAPTER

S O C I A L facebook.com/groups/NPMAAssetManagement linkedin.com/groups/NPMA-1676387 NPMA Asset Management channel

4 THE PROPERTY PROFESSIONAL VOLUME 27, ISSUE 6

NATIONAL PRESIDENT MARCIA WHITSON, CPPM, CF

IN THE WORLD WE LIVE IN TODAY, with ever expanding technology, seemingly endless resources just a click away, and cell phones in every hand, it would appear that our awareness of things around us would be at an all-time high. However, these are the very things that are “distracting” to our awareness.

Several years ago, as a new supervisor, I was instructed to attend a class called, “Observation.” At the time, I was extremely busy with several responsibilities, so my first thought was “Oh brother,” what a waste of time. Why would I need a class to teach me how to “observe?” But this was one of the most enlightening classes that I have ever attended. The class instructor asked each participant to bring a copy of their operating procedures to class. We were asked if we felt the procedures were good and accurately conveyed the steps our employees were following to complete their tasks. Every participant felt very good about the procedures they had written. The next part of the class required each supervisor, with the instructor, to go into their respective work areas with a copy of the procedures and “observe.” The instructor said that after about 5 minutes of curiosity from the workers, they would resume their work and ignore our presence. So, in we march to “observe” the workers in action. After watching the workers, it became very obvious to me that the procedures were not being followed. However, the most eye-opening observation was that if they were followed, the processes would not have been effective or efficient. The workers were just naturally doing the work in the most efficient way, so why were my procedures incorrect? First, I didn’t involve the workers in writing and developing the procedures for their jobs. Secondly, I wrote them from my desktop and did not observe all the steps involved. Observation leads to true understanding.

Reasons for Chapter leaders to observe:

1 If you watch the members attending your meetings, you can discover their interests.

2 By observing and working with members, you can assess their developmental needs and goals.

3 Watch the members who are reserved and hesitant, perhaps they need mentoring?

Points for NPMA members to observe:

1 Given your interests, formulate your professional development goals in your area of interest.

2 Why are others being promoted or given additional responsibilities and what are their strategies?

3 What resources are available through NPMA to help you reach your professional potential?

Before making any important decisions or working through an issue, make sure you are “observing” all of the facts first. These skills can be used in all areas of our lives. Observe first, listen next, and then question until all of your question are answered…gather the facts and then proceed to a good decision based on the facts.

Even with the holiday stresses and busy schedules coming soon, I hope you will take some time to “observe” the things that are truly important in your life and in the holiday season.

Happy Holidays

Before making any important decisions or working through an issue, make sure you are ‘observing’ all of the facts first.”

‘‘

HOW OBSERVANT ARE YOU?

WWW.NPMA.ORG 5

At this time of the year we are encouraged to reflect on our lives and celebrate the successes we had the past year, look around us and give thanks for the good things in our lives, and set goals and make plans to do even better in the new year that is ahead of us. So, let me reflect on our magazine.

Again, we managed an entire year of themed issues without running short of articles…believe me, that is no simple feat. For this, the staff of The Property Professional would like to thank the 14 authors who contributed the 18 articles published this year.

A round of applause and our deepest appreciation for the 14 authors, seven of which were brave first-time contributors, that participated this year. Kudos to Peggy Basset, CPPM, CF; Gary Charles, CPPM; Stephen Fisher, CPPS; Dr. Douglas N. Goetz, CPPM, CF, MIAM; Meg Lombardo, CPPS; Bill Love, CPPM; Bob Mahaney, CPPS; Randy Rapin; Ron Regalado, CPPM; Carolyn Richelmi, CPPS; Marilyn Richter-Arguello, CPPM CF; Ronnie Sparks, CPPM; John Waldschmidt, CPPM; and Maggie Wood, CPPS.

This year, thanks to Jessica Dzara, CPPM, CF (VP Communications & Marketing), we added two new regular features – Ask the Expert and #Asset Management. We tried to start a regular Book Review feature but sadly you (the membership) failed to respond but we are still hopeful.

What is our current status? I am proud to say that The Property Professional is still going strong and striving for excellence.

And what are our goals and expectations? As I’ve said before, our goal is to bring you six extraordinary issues of The Property Professional that will do more than just line your shelves – issues full of technical knowledge and tips that make your job easier and make the Property Management office a crown jewel of management. Next year we are taking a rest from the themed issues and going back to issues with varied content so that each issue can have something of interest for each of you. To make this happen, WE NEED YOU – please make writing an article one of your goals for 2016. Our staff of editors are there to help you, so call on us if you need help.

The staff of The Property Professional hopes that you and yours have a healthy and happy holiday season that continues into the New Year. May you continue to develop in positive ways as asset managers and members of the NPMA family.

Our final themed issue, Contract/Agreement Management, starts out with “A Comparative Analysis of Contract Government Property Requirements: FAR, Agency Supplements and Outliers!” by Dr. Douglas N. Goetz, CPPM, CF, MIAM…otherwise known as Dr. Doug. Next, we have a case study entitled “Disposition of Supplier-Held Property after Bankruptcy” by Ron Regalado, CPPM, followed by “For the Sake of Safety?” by Ronnie S. Sparks, CPPM, and finally a report on the Federal Asset Managers Forum that was held on October 20 and 21 in Washington, DC.

Ladies and gentlemen, we present Volume 27, Issue 6, of The Property Professional.

YESTERDAY, TODAY, AND TOMORROW

NATIONAL EDITOR BILLIE PERCHLA, CPPM, CF

C O N T A C T U S

NPMA NATIONAL OFFICE

3525 Piedmont Rd, Building 5, Suite 300 Atlanta, GA 30305 Tel: 404-477-5811 Fax: 404-240-0998

NPMA NATIONAL OFFICE STAFF

ME PROGRAM MANAGER: Jennifer (Jen) Sanford [email protected] AND MARKETING SENIOR COORDINATOR: David Beauchamp [email protected] AND EDUCATION SPECIALIST: Lisa Golden [email protected]: Tenez Quarles [email protected] & FLEET CERTIFICATION SPECIALIST: Emily Rhodes [email protected]

THE PROPERTY PROFESSIONAL EDITORIAL TEAM

NATIONAL EDITOR: Billie Jo Perchla, CPPM, CF [email protected] EDITOR: Betsy Tucker, [email protected] EMERITUS: Dr. Douglas Goetz, CPPM, CF [email protected] REGION EDITOR: Barbara Bays, CPPM [email protected] REGION EDITOR: Toby V. Bell, CPPM [email protected] REGION EDITOR: Keith Record, CPPM keith.c.record@L-3com

NPMA EXECUTIVE BOARD

NATIONAL PRESIDENT: Marcia Whitson, CPPM, CFTel: 865-947-3047 [email protected] VICE PRESIDENT: Cinda Brockman, CPPM, CFTel: 858-361-4270 [email protected] PAST PRESIDENT: Cheri Cross, CPPM, CF Tel: 865-574-6046 [email protected] PRESIDENT ADMINISTRATION: Ivonne Bachar, CPPM, CFTel: 650-723-9095 [email protected] PRESIDENT CERTIFICATION: Rosanne (Beth) Green, CPPM, CFTel: 321-751-9014 [email protected] PRESIDENT COMMUNICATIONS AND MARKETING: Jessica Dzara, CPPM, CF Tel: 703-400-3170 [email protected] PRESIDENT FINANCE: Brandon Kriner, CPPM, CFTel: 202-255-1085 [email protected] PRESIDENT MEMBERSHIP: Ken Black, CPPM Tel: [email protected] PRESIDENT PARLIAMENTARY PROCEDURES: Dr. Douglas Goetz, CPPM, CF Tel: 937-306-8372 [email protected] PRESIDENT PROFESSIONAL DEVELOPMENT: Cathy Seltzer, CPPM, CFTel: 703-227-2530 [email protected] VICE PRESIDENT CENTRAL REGION: Gary Quinn, CPPMTel: 575-415-3299 [email protected] PRESIDENT EASTERN REGION: Tara Miller, CPPM, CFTel: 321-867-8910 [email protected] PRESIDENT WESTERN REGION: Robert Kaehler, CPPSTel: 925-209-0944 [email protected]

NATIONAL DIRECTORS

CERTIFICATION GOVERNING BOARD CHAIR: William Beedle, CPPM, CFCOUNCIL OF FELLOWS: Pam McFarland, CPPM, CFAWARDS PROGRAM AND COMMUNICATIONS: Kimberly Saeger, CPPSCERTIFICATION: Iris Thompson, CPPM, CFCHAPTER SUPPORT – EDUCATION: Kathy Baker, CPPAHISTORICAL ARCHIVES: Nancy Chapman, CPPM, CFJOB AWARENESS: Marlene Lynn, CPPM, CFGROWTH & RETENTION: Sarah WiebensonSEMINARS: Mike Showers, CPPMSPECIAL INTEREST GROUPS: Cheri Cross, CPPM, CFFOUNDATION ADMINISTRATOR: Raam Vichare, CPPM, CF


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NPMA CALL FOR CANDIDATESSUBMISSION PROCESS:All candidates for office must submit the following materials to their region representative with a copy to [email protected] which includes:

1. Your name, position sought, NPMA certification level, chapter affiliation, length of NPMA membership, your current job title and employer name.

2. If you plan on participating in any activity for which you would receive payment from the NPMA during your term of office (for example serving as an NPMA instructor) this should be disclosed with your submission.

3. A brief statement, limit 100 words, stating the experience you would bring to your office, if elected.

4. A brief statement, limit 100 words, of your mission and goals for your office.

5. A color digital headshot photo (at least 300 dpi in jpeg format) must be submitted to the NPMA National Office ( [email protected]) by December 14.

POSITIONS:National President

Executive Vice President

Vice President Administration

Vice President Finance

Vice President Communications

Vice President Membership

Vice President Professional Development*

Vice President Certification*

Vice President Parliamentary Procedures

Chair, Certification Governing Board

Region Vice President

Region Secretary

Region Treasurer

DEADLINES:For inclusion on the full slate, materials must be received by: Friday, March 18, 2016

Inclusion in The Property Professional: Monday, December 14, 2015

Inclusion on the NPMA website: Friday, March 18, 2016

Full position descriptions and other details are available online: http://www.npma.org/?page=2016Elections

NOTE: Candidates for the positions of President, Executive Vice President and Vice President Finance are required to furnish their social security numbers and other personal information in order to participate in NPMA financial affairs.

*Candidates for VP Certification and VP Professional Development must be certified at the CPPM level to serve in those offices.

ELECTION FOR NPMA REGIONAL AND NATION OFFICERS (TERM SPANS FROM 2016-2018)

WWW.NPMA.ORG 7

SPOTLIGHT ON THE

SPECIAL INTEREST GROUPS (SIGS)

EXCESS PROPERTY & DISPOSITION SIG

The Excess Property & Disposition SIG provides the largest networking forum of excess property and disposition peers exploring the latest voluntary consensus standards, best practices, financial considerations and operational efficiencies associated with excess property and disposition. To review discussion forum topics and join the Excess Property & Disposition SIG, visit our website http://sigs.npma.org.

NPMA SIGs provide valuable professional connections to:

> Share common interests,> Participate in discussions,> Tap into knowledge and expertise,> Research solutions, and> Learn about or share issues, trends and best

practicesJoining is voluntary and free to NPMA

members, and you may belong to as many SIGs as you want.

To view and join an NPMA Special Interest Group (SIG), go to http://sigs.npma.org. There you will also find instructions on how to access the online forums.

GotQUESTIONS?

You can

start today!

Join NPMA SIGs to be part of a professional community that advances knowledge, as well as leadership, and provides the tools, resources, and opportunities to enhance and support your professional performance.

JOIN NPMA SIGS

S I G S AND THEIR CHAIRPERSONS

CHAPTER OFFICERS

Vacant

CONTRACT PROPERTY

Carolynn Bundy, CPPM, CF

and Shawn Megaw, CPPM, CF

DOE/NNSA & CONTRACTORS

Cheri Cross, CPPM, CF

ELECTRONIC STEWARDSHIP

Ronnie Sparks, CPPM

EXCESS PROPERTY & DISPOSITION

David Robbins, CPPS

FEDERAL PROPERTY MANAGEMENT

Angela Cooper, CPPM

FLEET MANAGEMENT

Russ Johnson

HOSPITALS & MEDICAL FACILITIES

Norman Pugh-Newby, CPPM, CF

NASA & CONTRACTORS

Marjorie Jackson, CPPM

PROPERTY INVENTORY

MANAGEMENT

Brian Ross, CPPS

STATE & LOCAL GOVERNMENT

Scott Pepperman

SUBCONTRACTOR-HELD PROPERTY

Terri Snook, CPPM, CF

and Niki Milsaps, CPPM

UID

Pat Jacklets, CPPM, CF

and Dan Tully, CPPM

UNIVERSITY, COLLEGE & OTHER

NON-PROFITS

Frank Gonazelz, CPPM, CF

and Rick Dillard, CPPM


MEMORIAL FOR JAMES MARTIN

WHALEN, CPPM, CF

It is with deepest sorrow that I report the passing of one of the National Property Management Association’s founding fathers. Jim Whalen, who was one of the few remaining charter members of the NPMA, passed away on Sunday, October 25th.

I first met Jim at the 1984 NPMA Seminar in Buena Park, California. We immediately became good friends and it was with his encouragement and support that I became a member of the Executive Board and the association’s National President in 1995.

Jim was always prepared for any situation and that included his final arrangements. He provided a list of people who were to be contacted to his family as well as a list of his NPMA service and professional accomplishments which included:

> Co-founded the 1st NPMA chapter in Dallas, TX in 1970> Holding many chapter, regional and national offices

including National President in 1987/1988> Awarded the Jack E. Griffith Property Person of

the Year award in 1986> Established the Consulting Fellow program and

held Certificate #1> Established the first NPMA office in Denver Colorado

and subsequently moved the office to Dunedin Florida.> Served as the first NPMA Executive Director beginning

in 1989

> Established the VP of Professional Development in 1988 and appointed Arlene Rodovich

> Established the position of NPMA Meeting Planner with the first NPMA Nationally sponsored NES being held during the summer of 1989 in San Diego

> Considered the ‘Father of Inventory by Exception’ concept

> One of the first innovators and users of Bar Code Inventory scanning

By Ed Winters, CPPM, CF

WWW.NPMA.ORG 9

There are very few people in my life who had an impact on who I am today and what I’ve accomplished professionally. In addition to my family Jim was one of those people. When he left office as President in 1988 Jim gave each member of the board a small paperweight as a token of appreciation for our support for him which I have had on my desk at work for the last 27 years. It reads ‘Don’t walk in front of me - I may not follow. Don’t walk behind me - I may not lead. Walk beside me - and just be my friend.’ I will miss you my friend!

Ed Winters, CPPM, CF - National President 1995/1996

__________________________________________________________

The NPMA had its foundation more than 45 years ago -- And since that time there have been numerous folks that left their mark, their heritage on and to this professional association. Jim Whalen was one such individual. As a Founding member and through his seminal efforts as a President of our association and leader in many areas – our association and our profession grew, expanded and matured. Though Jim is now departed – we need to remember our history and those that started it all. Jim was one of those individuals!!!

Dr. Doug Goetz, CPPM, CF, MIAMVP Parliamentary Procedures __________________________________________________________

Jim hired me into Honeywell 36 years ago and was my mentor. He prepared me by providing me such a broad-based knowledge of this new world of Government Property Management that I excelled throughout my career. He was very intuitive and was light years ahead of everyone else when it came to developing processes and was always focusing on continuous improvement. He could be feisty though! I would not be where I am today without him. I thought the world of him.

Kathy McFarland, CPPM, CFChair, Consulting Fellow Review Board __________________________________________________________

Jim Whalen was one of the first people I met in approximately 1987 when the Bay Area Chapter was hosting the last of the national education seminars put on by a chapter. Jim was so supportive in all we did and the event was very successful. He never hesitated to share information as well as his humor. His forward thinking at the time helped shape NPMA and influenced many careers. I will always remember his version of the President’s Award -- the DSE award, Dragon Slayer Extraordinaire-- intended for those who showed perseverance and commitment to NPMA. It was an honor to have known and learned from Jim.

Ivonne Bachar, CPPM, CFVP of Administration

I first heard about and met Jim Whalen shortly after I joined the NPMA in the early 1980’s. Andy Anderson introduced me to him at a Bay Area Chapter meeting. I never really got to know him as well as others as I was new to the organization and hadn’t become a part of the leadership. It didn’t take long to recognize Jim had some great qualities. He was a man of integrity, passion, dignity and perseverance.

As a man of integrity, you knew you could count on him to be a champion of the high ethical and moral qualities needed to lead the NPMA into a cohesive and unified organization in those early, sometimes turbulent years. His desire to maintain the solidarity and desire to do the right thing was evident in all his activities and writings.

He was a passionate man in that he gave 100 percent to the NPMA to help to provide the foundations necessary for a successful non-profit educational leader in the industry. He loved the NPMA family intensely.

He was a man of dignity. My recollection of him was that no matter who you were, a new comer to the NPMA, or an established leader in the association, he gave equal respect to everyone and made all of us feel our ideas and what we could contribute were important.

He was a man with great perseverance. The NPMA went through many changes in those early years at it sought to establish its identity. Jim gave all his energy to see that come to pass. It wasn’t easy and, for Jim, it often cost him a great deal. But he continued to lead and set the bar for all of us coming behind him.

My condolences to his family. We have lost a true Giant.

Dick OlsenNational President 2001/2002 __________________________________________________________

“I met Jim in 1987 when the Bay Area Chapter was hosting the NES. I was impressed with him as one of our leaders and that never changed...Jim will always be remembered with fondness and my deepest respect.

Billie Jo Perchla, CPPM, CFThe Property Professional National Editor __________________________________________________________

Jim was one of the first people I ever met at NPMA and we became friends personally, and professionally. Jim was an intellectual expert with respect to regulatory interpretation, yet had the common sense to implement practical solutions that met compliance requirements while helping his company maintain profitability. Jim always had a kind word for everyone and was always willing to help no matter what the issue was. He will be sorely missed.

Bob McFarland, CPPM, CFCharter Member NPMA


A COMPARATIVE ANALYSIS OFContract Government Property Requirements:

FAR, Agency Supplements and Outliers!

C O V E R S T O R Y

have been blessed by having the opportunity to lecture and present numerous classes to numerous individuals and organizations throughout my career. And the focus of these classes has been on CONTRACT Property, i.e., Government property in the possession of contractors. The students at these classes have been both Government employees and Contractor employees – so there is always a great deal of discussion in class – as well as some heated debates. And as we go through the class and present and discuss the contractual requirements set forth by the Federal Acquisition Regulation (FAR) there is always a murmuring in the class that emerges as a statement, “Well, we don’t do it that way!”

Interesting! I have always thought that the new FAR (2007 Version – with its two updates) is a relatively easy to read document. Well, at least much easier than the pre-2007 version with it nineteen clauses and FAR Subparts incorporated by reference – and lots of direction that had been overcome by events – does anybody remember DIPEC and IPE? So, with that in mind – why do folks think that the same requirement for all activities doesn’t apply to them? In the words of Lyle Hesterman, “Hmmmmmmm?”iI

BY DR. DOUGLAS N. GOETZ, CPPM, CF, MIAM, OHIO VALLEY CHAPTER

WWW.NPMA.ORG 11

C O V E R S T O R Y

HISTORY OF THE FARHistorically we can trace the genesis of the FAR back to the

1969 Commission on Government Procurement (COGP).ii The concept of a Uniform Procurement System for ALL Federal agencies came from the Office of Federal Procurement Policy (OFPP) with the foundational thought coming from the Office of Federal Contract Procurement Policy Act Amendments of 1978. The OFPP proposed the FAR Project in 1978. Ultimately, the FAR was published April 1st, 1984! The intent – ALL Federal Agencies would use a single procurement requirement!

I believe a brief discussion of the outcome, i.e., the transition from the Defense Acquisition Regulation. to the FAR, is needed. The ideas presented are my perspectives and analyses – as I could find no literature on the actual process. But, having talked to a few of the original committee members who were involved – I think I got it right! In the transition from the Armed Services Procurement Regulations/Federal Procurement Regulation (ASPR/FPR) to the FAR there were no “transformational” thoughts given to the project – well, at least the Government Property sections. Rather, the committee took the ASPR – and I am limiting this to the ASPR, because if you look at the materials the majority if not the whole was extracted from the ASPR vis-à-vis any inclusion of material from the FPR – and “smushed” it into the FAR.

Specifically taking the CLAUSAL REQUIREMENTS and:1. Moving the Policy requirements to FAR Part 45,

specifically 45.1, 45.2, 45.3, 45.4 and 45.6.2. Moving ASPR Appendix B to FAR Subpart 45.5.3. Moving the required clauses to FAR Part 52 – copying the

clauses verbatim, save for a GIANT amalgam of the Facilities clauses where they took twenty separate ASPR clauses and crafted three Facilities Contract Clauses – many portions of which were redundant amongst and between clauses. iii

CURRENT FAR STRUCTURE AS IT RELATES TO GOVERNMENT PROPERTY IN THE POSSESSION OF CONTRACTORS.

Let’s take a very simplistic look at the current FAR requirements related to Government property. iv

Ahhhh, but it doesn’t stop there!

SUPPLEMENTS TO THE FAR So why the previous mentioned comment that, “We don’t

do it that way!”? Because in Government contracting we deal with a multitude of various Government agencies.

Even though the FAR was meant to be the procurement regulation to be used by ALL (with few exceptions) Federal agencies…it was allowed to be SUPPLEMENTED! That’s right; each agency was allowed to supplement – ADD to the requirements. Agencies were NOT allowed to reduce, or diminish the FAR requirements without prior “approval.” FAR 1.4 discusses the issue of deviations and it states,

“Deviation” means any one or combination of the following:(a) The issuance or use of a policy, procedure, solicitation

provision (see definition in 2.101), contract clause (see definition in 2.101), method, or practice of conducting acquisition actions

FAR BASED GOVERNMENT PROPERTY REQUIREMENTS

POLICY AND DIRECTION TO THE GOVERNMENT

FOUND IN FAR PART 45

Six (6) Subparts

•Subpart 45.1 -- General

••Subpart 45.2 -- Solicitation and Evaluation Procedures

•Subpart 45.3 -- Authorizing the Use and Rental of

Government Property

•Subpart 45.4 -- Title to Government Property

•Subpart 45.5 -- Support Government Property

Administration

•Subpart 45.6 -- Reporting, Reutilization, and Disposal

FAR GOVERNMENT PROPERTY CLAUSAL REQUIREMENTS

ALL CLAUSES ARE FOUND IN PART 52 OF THE FAR

The clauses numbers correlate to the FAR Part to which

they are related.

There are three (3) FAR Government Property clauses:

•52.245-1 -- Government Property.

•52.245-2 -- Government Property Installation Operation

Services.

•52.245-9 -- Use and Charges.

[Note the prefix of the number is 52 denoting it is a clause,

while the suffix is 45 denoting that it aligns with the FAR

Part dealing with Government property.]


C O V E R S T O R Y

of any kind at any stage of the acquisition process that is inconsistent with the FAR.

(b) The omission of any solicitation provision or contract clause when its prescription requires its use.

(c) The use of any solicitation provision or contract clause with modified or alternate language that is not authorized by the FAR (see definition of “modification” in 52.101(a) and definition of “alternate” in 2.101(a)).

(d) The use of a solicitation provision or contract clause prescribed by the FAR on a “substantially as follows” or “substantially the same as” basis (see definitions in 2.101 and 52.101(a)), if such use is inconsistent with the intent, principle, or substance of the prescription or related coverage on the subject matter in the FAR.

(e) The authorization of lesser or greater limitations on the use of any solicitation provision, contract clause, policy, or procedure prescribed by the FAR.

( f ) The issuance of policies or procedures that govern the contracting process or otherwise control contracting relationships that are not incorporated into agency acquisition regulations in accordance with 1.301(a).

So, Agencies were allowed to supplement – and supplement they did!!! How many supplements are there to the FAR? Here is a list – you try and figure it out. All of the agencies are represented by their abbreviation or acronym.

> AGAR > AIDAR > CAR > DEARS > DFARS> DIARS > DOLAR > DOSAR > DTAR > EDAR > EPAAR > FEHBAR

> GSAM > HHSAR > HSAR > HUDAR > IAAR > JAR > LIFAR > NFS > NRCAR > TAR > VAAR

From Agriculture to Veterans Affairs, many agencies have issued supplementation to the FAR Government Property requirements. Some agencies have very little supplementation – others, and we won’t point out Department of Defense with its DFARS Clauses, nor NASA, nor DOE – sorry, I said I would NOT point them out, have some rather large amounts of supplemental material. So, not only does one, a Government employee, need to know the FAR – one also needs to know their agencies supplements and potential OTHER agency supplements. Contractors – even more so – because if their employer does business with multiple Governmental agencies, they need to know THOSE specific supplemental requirements.

I have charted three Agencies and the form and structure of their respective FAR Supplements – specifically, Department of Defense (DoD), National Aeronautics and Space Administration (NASA) and the Department of Energy (DOE).

AGENCY SUPPLEMENTS – POLICY REGARDING GOVERNMENT PROPERTY

AGENCY SUPPLEMENTS

DoD

Department of Defense Federal Acquisition Regulation

Supplement (DFARS)

DFARS 245

•Subpart 245.1--General

•Subpart 245.2-- Solicitation And Evaluation Procedures

•Subpart 245.3—Authorizing The Use And Rental Of

Government Property

•Subpart 245.4—Title To Government Property

•Subpart 245.5—Support Government Property

Administration

•Subpart 245.6--Reporting, Reutilization, And Disposal

•Subpart 245.70--Plant Clearance Forms

•Subpart 245.71--Plant Clearance Forms

•Subpart 245.72--Special Instructions

•Subpart 245.73--Sale Of Surplus Contractor Inventory

NASA

NASA FAR SUPPLEMENT (NFS)

NFS 1845

•Subpart 1845.1—General

•Subpart 1845.2—Solicitation and Evaluation Procedures

•Subpart 1845.3—Authorizing the Use and Rental of

Government Property

•Subpart 1845.4—Reserved

•Subpart 1845.5—Support Government Property

Administration

•Subpart 1845.6—Reporting, Reutilization, and Disposal

•Subpart 1845.71—Forms Preparation

•Subpart 1845.72—Closure of Contracts

DOE

DEPARTMENT OF ENERGY ACQUISITION REGULATIONS

(DEARS)

DEARS 945

•945.000 Scope of part.

•Subpart 945.1 — General

•Subpart 945.3 – [Reserved]

•Subpart 945.4 — [Reserved]

•Subpart 945.5 — Support Government Property

Administration.

•Subpart 945.6 — Reporting, Reutilization, and Disposal

WWW.NPMA.ORG 13

C O V E R S T O R Y

These are the Agency Supplements to FAR Part 45 – the Policy section of the FAR related to Government property. Quite clearly, numerous Federal Agencies believed that the FAR itself and its directions were inadequate to meet their Agency’s needs. Or that their Agency was “Different.”

Not only did these Agencies supplement the Policy requirements – but they also supplemented the FAR Clauses – tailoring agency specific clauses to meet their needs, real or perceived. NASA has fourteen Supplemental clauses related to Property!

In the chart below you can see the clauses that were crafted by DoD, NASA and DOE. It appears that NASA is the winner in adding supplemental clauses. For the other agencies – please do not feel slighted. To list ALL of the Agency

supplements would require hundreds of pages. So, I decided, for the sake of simplicity to address the three biggees! But I do have one other note – now all of you know that GSA is the “Big Daddy” of Property in the United State Government – as set forth in the Federal Property and Administrative Services Act of 1949 as revised!v Yet, if you were to go to the General Services Administration Acquisition Regulation System (GSAR or GSAM) FAR supplement – you would find that GSAM (GSAR) for Part 45 is “Reserved.” And for the Government Property Clausal requirements in the GSAM (GSAR) there are no supplemental clauses.

And to my GSA friends -- GSA could respond that they are the “owners” of the FAR and as such it was perfect – requiring no supplementation. Forgive my sense of humor!

AGENCY SUPPLEMENT CLAUSES

AGENCY SUPPLEMENT CLAUSES

DFARS Government Property Clauses NFS Government Property Clauses DOE Government Property Clauses

•252.245-7000 Government-

Furnished Mapping, Charting, and

Geodesy Property.

•252.245-7001 Tagging, Labeling,

and Marking of Government-

Furnished Property.

•252.245-7002 Reporting Loss of

Government Property.

•252.245-7003 Contractor

Property Management System

Administration.

•252.245-7004 Reporting,

Reutilization, and Disposal.

•252-211-7007 Reporting of

Government-Furnished Property.

NOTE: I have included 252.211-7007

even though it is not located in the

traditional spot for clauses related

to Government property as it is,

quite clearly, a clause dealing only

with Government property.

•1852.245-70 Contractor Requests for

Government-Provided Equipment.

•1852.245-71 Installation-accountable

Government Property.

•1852.245-72 Liability for Government

Property Furnished for Repair or Other

Services.

•1852.245-73 Financial Reporting of NASA

Property in the Custody of Contractors.

•1852.245-74 Identification and Marking of

Government Equipment.

•1852.245-75 Property Management

Changes.

•1852.245-76 List of Government Property

Furnished Pursuant to FAR 52.245–1.

•1852.245-77 List of Government Property

Furnished Pursuant to FAR 52.245–2.

•1852.245-78 Physical Inventory of Capital

Personal Property.

•1852.245-79 Records and Disposition

Reports for Government Property with

Potential Historic or Significant Real Value.

•1852.245-80 Government Property

Management Information.

•1852.245-81 List of Available Government

Property.

•1852.245-82 Occupancy Management

Requirements.

•1852.245-83 Real Property Management

Requirements.

•952.245-2 Government property

(fixed-price contracts).

•952.245-5 Government property

(cost reimbursement, time-and-

materials, or labor-hour contracts.)

•DOE even segregates its clauses

by the type of facility using the

property, i.e., if it is a Management

and Operating Contract. In that

instance the policy is found at

DEARS 970.4501

(Notice the policy is NOT found

in the Government Property part

of the DEARS, i.e., DEARS 945.

XXX – rather it is found at DEARS

970.45 Also entitled Government

property—which then references the

clause at DEARS 970.5245-1.)


C O V E R S T O R Y

WHY???Why are there these agency peculiar clauses? Simple

answer – because the agencies had additional requirements or wanted to provide clarification as to how THEIR agency would address or comply or act upon the FAR clauses.

DFARS CLAUSES:For example, two of the Department of Defense (DoD)

clauses (DFARS 252.245-7002 and 252.245-7004) provide direction to the contractor to use a web based system – eTools for various reporting actions.vi The eTools used to report loss of Government property in the possession of contractors are through the Loss Module, and for the declaration of Excess of contractor inventory the Plant Clearance Automated Reutilization Screening System (PCARSS) is used. Another DFARS Clause, 252.211-7007 (though not in the traditional subpart for Government property) deals with the reporting of RECEIPT of Government property through the Wide Area WorkFlow (WAWF) e-business suite (https://wawf.eb.mil/xhtml/unauth/home/login.xhtml).

NASA CLAUSES:NASA has gone even further than DoD in its use of Agency

Supplemental Clauses issuing fourteen (14) clauses that provide clarification or additional requirements upon the contractor or the management of Government property.

DOE CLAUSES:DOE has a few clauses under its Agency Supplement, the

Department of Energy Acquisition Regulation Supplement (DEARS) one of which is segregated and deals only with DOE Management and Operations (M&O) contractors. Specifically DEARS 970.5245-1 entitled Property deals with the management of Government property at the M&O Site (http://www.energy.gov/sites/prod/files/2013/07/f2/EDEAR%20July%202%202013%20final.pdf ).vii

So, the implication of this discussion is that the Property Professional needs to be aware of and well versed in not just the FAR, but in whatever OTHER contractual requirements are applied!

AGENCY MANUALS FOR MANAGING GOVERNMENT PROPERTY

DOD PGIs 245 with paragraphs cited:

245.1

245.2

245.4 and

245.6

DoD Guidebook For Contract

Property Administration (Apr 2012)

Found at: http://www.acq.osd.mil/

dpap/ccap/cc/jcchb/Files/Topical/

Property/guides/Guidebook%20

for%20Contract%20Property%20

Administration_April%202012.pdf

NOTE – DCMA has its Instructions which

may be found at http://www.dcma.mil/

policy/

Two Applicable instructions relating to

Government property in the possession

of contractors – or contract property--

are:

DCMA Instruction 111 – Plant Clearance

and

DCMA Instruction 124 – Contract

Property Management

NOTE: There are numerous OTHER

policy sections at the DCMA home page

that interact with Contract Property.

NASA has the NASA Online Directives

Information System (NODIS) Found at:

http://nodis3.gsfc.nasa.gov/main_lib.cf

m?CFID=6696636&CFTOKEN=f7755

3c74490111d-DD561AB3-EBA0-0802-

46585D0C5100550D

• NPD 4100.1C Supply Support and

Material Management Policy

• NPR 4100.1D NASA Materials

Inventory Management Manual

• NPD 4200.1C Equipment Management

• NPR 4200.1G NASA Equipment

Management Procedural Requirements

• NPR 4200.2B Equipment Management

Manual for Property Custodians w/Change

1,

• NPD 4300.1B NASA Personal Property

Disposal Policy

• NPR 4300.1C NASA Personal Property

Disposal Procedural Requirements

• NPR 4310.1A Artifact Identification and

Disposition

• NPD 4500.1 Administration of Property

in the Custody of Contractors

• NPR 4500.1 Administration of Property

in the Custody of Contractors

DOE has the Office of

Information Resources Found at:

https://www.directives.doe.gov/

DOE Order 580.1A - Department

of Energy Personal Property

Management Program

DOE Guide 580.1-1A -- Personal

Property

WWW.NPMA.ORG 15

C O V E R S T O R Y

INTERNAL AGENCY DIRECTIONThe three Agencies that we have been discussing in this

paper – DoD, NASA and DOE – also have guidance and direction to ITS employees! For Example in the Chart on facing page:

DOD – has detailed operational guidance for DoD Employees set forth in its Procedures, Guidance, and Information (PGI). PGI is a companion resource to the DFARS.viii In addition there is the replacement of the “Old” DoD Manual for the Performance of Contract Property Administration, 4161.2-M (Rescinded) and replaced by the DoD Guidebook For Contract Property Administration (Apr 2012). It is CRITICAL to note that these PGIs and the Guidebook are DIRECTION and GUIDANCE to the Government. They are NOT contractual direction to the Contractor!

NASA – has extensive guidance in its NASA Online Directives Information System (NODIS). And in the Property arena there are NASA Policy Directives (NPD) and NASA Procedural Requirements (NPR).

WOW!!! So, if I am a large contractor, doing work for MULTIPLE Federal agencies – then it is incumbent upon me to read, study, learn, and understand not just the FAR, but if I want to be a true Property Professional, I need to know the FAR – both policy and contractual clausal requirements, the Agency Supplements – both policy and contractual clausal requirements, and it would behoove me to read, study, learn, and understand the supporting manuals, directives and guidance provided INTERNALLY for the Government folks!!! In the vernacular – OMG!

And in the immortal words of the multitude of numerous pitchmen (And women) on TV, hawking their wares – “But wait – there’s more!”

A few Government agencies were exempted from the original FAR effort back in 1984. Two of those in particular are – the Federal Aviation Administration (FAA)ix and the U.S. Mint.x We have seen what the FAR policy and clausal requirements regarding Government property are – let’s look at the FAA policy and clause structure.

FAA POLICY

3.10.3.1 – Applicability of Government Property

Administration Guidance

T3.10.3 Government Property Revised 10/2009

A Government Property

1 Applicability

2 Responsibilities Revised

3 Contractor’s Property Control System

4 Audit of Property Control System

5 Official FAA Property Records

6 Types of Property Provided to Contractors

Revised

7 Contractor Use and Rental of Government

Property

8 Relief from Responsibility

9 Contractors’ Liability

10 Reporting, Redistribution, and Disposal of

Contractor Inventory

11 Inventory Schedules

12 Scrap

13 Recovering Precious Metals

14 Screening of Contractor Inventory

15 Report of Excess Personal Property

16 Donations

17 Sale of Surplus Contractor Inventory

18 Exemptions from Sale by GSA

19 Destruction or Abandonment

20 Removal and Storage

21 Special Storage at the FAA’s Expense

22 Subcontractor Inventory

23 Accounting for Contractor Inventory

24 Definitions Revised

B Clauses

C Forms

D Appendix

1 Appendix - Sample Delegation Memo

2 Sample Designation Letter

FAA GOVERNMENT PROPERTY CLAUSES

3.10.3-1 Definitions

3.10.3-2 Government Property Basic

3.10.3-2 Alternate I GP - Basic Clause

3.10.3-2 Alternate Ii GP - Basic Clause

3.10.3-3 Government Property Consolidated Facilities

3.10.3-4 Liability for the Facilities

3.10.3-5 Use and Charges

3.10.3-6 Government Property Facilities Acquisition

3.10.3-7 Government Property Facilities Use

3.10.3-7 Alternate I GP (Facilities Use)


C O V E R S T O R Y

Many of the policy areas are similar or the same as the FAR. The clauses are somewhat different from the pre-2007 and post-2007 iterations of the FAR. FAA, in its Government property clauses, appears to have “smushed” together some of the pre-2007 clauses that the FAR authors determined to be either obsolete or overcome by events, i.e., the Special Tooling Clause (FAR 52.245-17, PRE-2007) and the Special Test Equipment Clause (FAR 52.245-18, PRE-2007). One interesting and unique approach in the FAA Acquisition management system was the creation of a “definitions” clause – 3.10.3-1. Facilities contracts still exist in the FAA acquisition schema – though deleted from the 2007 iteration of FAA. And liability still has the bimodal approach of either “Full” risk of loss or “Limited” Risk of Loss. What I find most interesting for the property professional is looking at these procurement documents and requirements and seeing how they fit and how they work – their efficacy.

I really wanted to see what the US Mint was doing in its procurement process regarding Government property…I was met with failure – I was unable to find ANY information regarding their procedures.

NOTE: After an exhaustive search of the web and the US Mint webpage, and after numerous phone calls to the procurement office, I was unable to find the US Mint’s procurement regulations. There is an interesting article found at http://govinfo.library.unt.edu/npr/rego/business/usmint3.htm discussing how the US Mint was able to “the 1,500 page Federal procurement guidelines into a sleek, five-page guide for the Mint.” Now THAT would be an interesting procurement regulation!!!

IMPLICATIONS FOR THE PROPERTY PROFESSIONAL

We grow comfortable in what we know. We grow comfortable in the regulations we use. Sometimes we know what they mean – sometimes we think we know what they mean. Sometimes, we may have to ask, “What does this mean?” If you are dealing with a contractor that has contracts

from multiple Federal Government agencies, it is imperative that you become well versed in EACH of these agencies’ contractual requirements. They may not all require the same process and outcomes, procedures and methodologies. Some processes and the methodologies applied MAY be the same – others may be DIAMETRICALLY opposed. And when this happens – it is ALWAYS interesting to see how conflicts, differing requirements are solved resolved.

So, my encouragement – READ all that you can about ALL of the procurement/acquisition regulations that you are involved with. DIG DEEP – not a cursory review, but a true line by line reading to obtain knowledge of the applicable regulations. And I mean that on both sides – Government and Industry. Expand the depth and breadth of your knowledge. Maybe, just maybe, I have piqued your interest a little into looking at these “Other” regulations!!!

ABOUT THE AUTHOR:

Dr. Douglas N. Goetz is President of GP Consultants LLC (WWW.GOVERNMENT-PROPERTY.COM). He has been a working level Property Administrator, a Full Professor at two Universities – the Air Force Institute of Technology and the Defense Acquisition University. He has received the Federal Property Manager of the Year award, the Jack Griffiths Property Manager of the Year award, and in 1998 the Lifetime Achievement Award from the National Property Management Association. In 2007 was presented the NCMA Alan E. Peterson Award for Distinguished Service in Government Contracts. He has also been recognized for his teaching abilities – awarded the John Demidovich Excellence in Teaching Award by AFIT and the Outstanding Professor of the Year by DAU. A presenter at numerous NPMA conferences and seminars, NCMA World Congresses, and dozens of local NPMA and NCMA chapter meetings. Currently he is serving as NPMA Parliamentarian.

i Lyle Hesteram wrote a series of articles for the NPMA Property Professional entitled, “Things that make me go Hmmmmm?”ii Trueger, P.M., Accounting Guide for Defense Contracts, Commerce Clearing House, New York. 1953 First Edition. NOTE – there are later editions though I am not aware of their contents.iii For a more detailed analysis of the ASPR to FAR transition see Goetz , D.N., “The Regulatory History of Contract Property Management – 50 Years in the making!” Or a little bit longer!” http://c.ymcdn.com/sites/npma.site-ym.com/resource/resmgr/2012NES/NES12-HistoryofPropertyManag.pdf iv There are a multitude of clauses that impact Government property within the FAR. In this paper I am only addressing the PRIMARY (In my opinion) FAR Requirements.

v http://www.epw.senate.gov/fpasa49.pdfvi I am not sure as to the correct spelling or hyphenation or capitalization of this word. On the DCMA Homepage it is spelled ETOOLS, eTOOLS, eTools, and even e-Tools. The point is, though hosted on the DCMA homepage – it is a DoD System.vii Though one hates to be critical regarding an agency and its regulations the DEARS is woefully out of date regarding Government property. It references the pre-2007 Government property clauses of FAR 52.245-2 (Fixed Price) and 52.245-5 (Cost Reimbursement). This is a technical issue that should be correctedviii https://dap.dau.mil/acquipedia/Pages/ArticleDetails.aspx?aid=e2111ac5-603e-4915-91b2-b05a22d2896d

ix See Department of Transportation and Related Agencies Appropriations Act for FY1996, P.L. 104-50, §348, 109Stat. 460-61 (Nov. 15, 1995) (directing the Administrator of the Federal Aviation Administration to develop andimplement an acquisition system for the FAA).x See 31 U.S.C. §5136 (stating that “provisions of law governing procurement or public contracts shall not be applicable to the procurement of goods or services necessary for carrying out [U.S.] Mint programs and operations”).

WWW.NPMA.ORG 17

beyond those that are regularly seen. The reach of asset management programs across many parts of the organization like human resources, procurement, technology, and facilities provides an excellent platform to position the asset management program. As organizations onboard new team members, people are outfitted with assets and the assets they bring into the organization need to be identified and recorded. As procurement organizations integrate, new sources of acquisition are identified and new assets are put in service. Information technology resources are deployed to a wider group of constituents and asset management systems of record are often consolidated or replaced. When facilities are combined or consolidated, inventories need to be conducted and the disposal or transfer of assets is required.

Many industry experts are predicting that the swift pace of M&A activities will continue in the coming months. The pace and size of current M&A activities have already garnered attention and comment from federal leaders. This spotlight places increased pressure on the organizations involved to provide consistent service and effective organization integration. With assets playing a critical role in organizational success, asset managers have an excellent opportunity to position their programs as a critical element for successful integration.

The industry has seen significant merger and acquisition (M&A) activity that will continue to provide asset managers with challenges and significant opportunities. As a result of a flurry of M&A activity, which includes organizations like United Technologies, Sikorsky Aircraft and Lockheed Martin, Exelis and Harris Corporation, Baker Hughes and Halliburton, EMC and Dell, SRA and CSC, TASC and Engility, and Orbital Sciences and Alliant Techsystems (ATK), asset management professionals play an increasingly critical role within organizations. Leadership from, and participation by, asset management personnel throughout corporate integration activities increases positive outcomes in critical areas that include compliance, audit, utilization, valuation, data accuracy, and systems implementation.

M&A activity provides asset management organizations with an excellent opportunity to highlight the significant contribution assets (and their managers) provided in meeting corporate goals. Maintaining compliance and the need to regularly pass audits, gathers executive attention and support. However, during M&A activities, highlighting revenue generating activities, cost avoidance programs, and investment recovery programs can attract the attention of leaders looking to capitalize on and support innovative departments that provide benefits

ABOUT THE AUTHOR:Jeffrey V. Polyak, CPPS is an

accomplished leader in IT solutions sales and systems implementation. As Chief Operating Officer, Mr. Polyak manages all aspects of the implementation, sales and marketing of Sunflower Systems asset management solutions. Mr. Polyak holds a bachelor’s degree in political science from American University.

#ASSETMANAGEMENTTRENDING NOW – MERGER AND ACQUISITION ACTIVITY

By Jeffrey V. Polyak, CPPS, Federal Center Chapter

#AssetManagement is a regular Property Professional column that highlights innovative trends in the world of asset management that can be applied to new and exciting fields.

Share Your Story

HAVE YOU HEARD OF A NEW AND

EXCITING TREND IN THE WORLD OF

ASSET MANAGEMENT? We want to hear from you.

Email [email protected] to share your story.

EMAILUS

WWW.NPMA.ORG 19

WELCOME TO The Property Professional‘‘Puzzle Challenge.’’ The use of puzzles are greatfor challenging the working mind in a fun and stimulating way. In this edition, we have given you a double puzzle based on information taken from this issue. Take a look, consider the facts, rack your brain for some of those hidden answers, and good luck!

ANSWERS PAGE 31

1 122 133 144 155 166 177 188 199 2010 2111 22 23

CIPYLO

Let’s Play “What’s Dr. Goetz Talking About?”

VEIRYONTN

NYEGAC PSNEMTLSEPU

DEGIANUC

SASLEUC

MENRENGOVT RYOPEPRT

OEVANDITI

COINIASUQIT

RITNOERGP

AIBITLYLI

Double Puzzle Instructions:Unscramble each of the clue words.

Copy the letters in the numbered cells to other cells with the same number and complete the final phrase.

7

20

3

15

1

8

13

14

12

11 4

18 17

2

10 21

16 6

23 9 19

22 5


PART 1 - PROBLEM STATEMENTAs the Plant Clearance Officer, under the

authority of a DCMA Certificate of Appointment and in conformance with subpart 201.670, DoD FAR Supplement, you will direct the disposition of Government property pursuant to FAR 45 and its related clauses.

You have been asked to solve the following situation involving the disposition of excess equipment as a subcontractor. In this endeavor, your role will be both quarterback and coach.

You will be providing guidance and disposition instructions for property excess to a closed prime contract. The original subcontractor went bankrupt and there is a different owner of the former subcontractor’s company, since the subcontractor was sold in United States Bankruptcy Court, prior to your involvement. All property, both real and personal, that had been owned by the supplier, was sold to the new owner, as part of the bankruptcy proceedings. Of course, all property equipment items owned by the U. S. Government were excluded from the sale. However, the items are located on the new owner’s real property.

Throughout this paper, the term subcontractor and supplier are used interchangeably. Your task is to analyze the relevant information and come up with a proposed solution.

The disposition actions required in this case study were not handled properly and were behind schedule when you received the acceptable inventory disposal schedule. Both the prime and the new owner of the subcontractor facility, have indicated they have been waiting for disposition instructions for “quite some time,” although they had NOT adequately communicated this to you by submitting an acceptable inventory disposal schedule, using the appropriate communication mechanism and Information Technology (IT) tool.

FAR 52.245-1( j)(3), Contractor inventory disposal, clearly states that (Prime) Contractors shall report “inventory disposal schedules to the Plant Clearance Officer no later than 30 days following the Contractor’s determination that a property item is no longer required for the performance of the contract.” It has been almost two years since the property was no longer required for the performance of the contract.

This article does not represent the views of the Department of Defense (DoD) or the Defense Contract Management Agency (DCMA) and should not be construed as official Department of Defense policy. They are the views of the author and only the author.

Disposition of Supplier-Held Property After Bankruptcy - A Case Study

By Ron Regalado, CPPM, North Texas Chapter

WWW.NPMA.ORG 21

ABOUT THE AUTHOR:

Ron Regalado is a Plant Clearance Officer with the Defense Contract Management Agency. Ron has over twelve years’ service in the Federal Arena with the Department of Defense. Ron has worked for the U.S. Navy, Defense Logistics Agency and the Defense Contract Management Agency.

1 Definition of “Privity of Contract” per USLegal.com “Privity of Contract refers to relationship between the parties to a contract which allows them to sue each other but prevents a third party from doing so. It is a doctrine of contract law that prevents any person from seeking the enforcement of a contract, or suing on its terms, unless they are a party to that contract. As a general rule, a contract cannot confer rights or impose obligations arising under it on any person except the parties to it. However, the requirement of privity has been relaxed under modern laws. Doctrines of implied warranty and strict liability allow a third-party beneficiary or other foreseeable user to sue the seller of a defective product.”

The company who purchased the bankrupt subcontractor has indicated they intend to charge for storage fees, because the property has not been removed from their newly acquired subcontractor facility. In a nutshell, you have Government-owned equipment on a physically completed prime contract that was located at a subcontractor, when a prime contractor/subcontractor relationship existed. However, the prime contractor/subcontractor relationship does not exist, with this new owner.

Although FAR 45.6, Reporting, Reutilization, and Disposal, does indicate that “The Government’s failure to furnish disposal instructions within 120 days following acceptance of an inventory disposal schedule may entitle the Contractor to an equitable adjustment for costs incurred to store such property on or after the 121st day,” the firm who now owns the bankrupt subcontractor’s facility does not have “privity of contract”1 with the U.S. Government, or the prime contractor. Therefore, no storage fees would be allowable to the subcontractor (new owner).

The prime contractor and the new owner of the subcontractor facility have “lawyered-up” and are no longer amicable to each other. Threatening letters have been sent from attorneys for both sides. Amiable communication between the two has virtually stopped. Communication has totally stopped and this also has become a major issue.

Step 1, is figuring out what is going on. The following information was provided to you, shortly after you received an acceptable inventory disposal schedule of the excess equipment to be processed.

RELEVANT CASE INFORMATION:

Since the prime contract was cost plus fixed fee (CPFF) and the subcontract was time and material (T&M), all items became the property of the U.S. Government when invoiced and paid for. Several million dollars in excess Government-owned property were excluded from the bankruptcy proceedings sale.

Again, you are both quarterback and coach, being tasked to analyze the relevant information and come up with a proposed

game plan or solution. Please take a few minutes to determine the best path forward, with your recommendations, before reading Part 2 – Solution.

PART 2 - SOLUTIONA project team was formed to ensure

all the required actions were taken at the appropriate times. The project team included: Contract Administrators, Procurement Contracting Officer (PCO), and Government Property Administrators at Prime and Subcontractor locations, Plant Clearance Officer, Safety Officer, and Quality Assurance Representative.

Since the prime contract was closed, it was critical that all Government-owned property be identified and reported on inventory schedule for plant clearance. This was accomplished by reviewing the prime contract public vouchers to see what material and other direct nonrecurring charges were paid on the prime contract for this supplier’s work effort. The program subcontractor files were also reviewed for items purchased via purchase orders and invoices for contract billings at the supplier level. The information found was reviewed against the items submitted on inventory schedule.

The following FAR regulations require that prime contractors maintain records and related supporting documentation and that inventory disposal schedules be prepared for all property, including items located at subcontractors.

FAR 52,245-1(f ) (1) (iii), Records of Government Property: “The Contractor shall create and maintain records of all Government property accountable to the contract, including Government-furnished and Contractor-acquired property. (A) Property records shall enable a complete, current, auditable record of all transactions…”

FAR 52.245-1( j)(9), Subcontractor Inventory Disposal Schedules: The Contractor shall require its subcontractors to submit inventory disposal schedules to the Contractor in accordance with the requirements of paragraph ( j)(3), Contractor inventory disposal submission requirements, of this clause.”

Upon receipt of an acceptable inventory schedule, the items were promptly dispositioned through effective project management, communication amongst the project team and the sharing of the

required information between the prime contractor, the PCO, the ACO and the PLCO. The Office of Counsel was kept in the loop for advice at various stages in the process.

Since the equipment contained no hazardous or sensitive characteristics, some of the items were abandoned to the new owner of the supplier facility. All items the new owner did not want, were disconnected and sold to the highest bidder(s), “where-is, as-is.”

LESSONS LEARNED:Had the equipment at the subcontractor

been properly managed during the life of the contract, and been promptly and properly reported as excess, within 30 days, many of the issues may not have arisen. That is, the items would have been reported and dispositioned prior to the bankruptcy proceedings. The actions required by the prime contractor should have been taken long before the contract depleted all funds and there were no funds for disposition.

As soon as the prime contractor became aware the subcontractor was approaching bankruptcy, prompt, decisive actions should have been taken to properly report the excess to the Government and accelerate the disposition process.


On a recent contract start-up we conducted our 100% inventory, then waited as our procurement folks issued and finalized a subcontract for the security portion of our contract. The subcontractor brought in their people and began to hire the personnel that were already on staff, as well as accept applications for additional people. During this effort I arranged for a 100% inventory of the weapons in the arms room. Since I had done this inventory previously, I knew who to speak to and schedule the inventory transfer from us (the prime) to them (our subcontractor).

By Ronnie S. Sparks, CPPM, CGS LLC, Las Vegas Chapter

OF SAFETY?FOR THE SAKE

any of us have conducted 100% inventories during our tenures as Property Professionals. Some have conducted property close-out inventories and some have conducted start-up inventories. Some of you have even inventoried property that was going to be assigned to a subcontractor and then re-inventoried the property as you turned it over to the subcontractor.

M

WWW.NPMA.ORG 23

It was a dreary day on a Washington State Navy base as we waited for all of the personnel to arrive at the security station where the MP’s worked and where the arms room was located. Everyone arrived on time and we made contact with security personnel inside to open the door. We all hauled into the building and congregated in the break area just outside of the arms room.

The lieutenant (LT) of the security force showed up and explained to us that, “everyone entering the arms room for any reason would have to sign in and then sign out after the inventory.” Everyone acknowledged the instruction and we all descended into the arms room and signed in one by one. The LT opened the rifle racks and containers that held all of the weapons as she had done before in our previous inventory.

As she unlocked all of the weapons I explained to the group that I had conducted the previous inventory and had accepted any weapon cards that were in the space of the weapons, which were currently out on security duty. Next, I explained that the LT and I found it best for me to grab the rifle by the barrel and the stock, pull the weapon, read off the serial number and show it to the subcontractor for their due diligence. Finally, I explained that the hand guns would be handled slightly different because they were smaller. I would reach into the container and slide the hand gun to the front, lift it with two hands, call out the number and show the number to the subcontractor. I then asked if everyone was comfortable with that path forward.

We began the inventory and I was calling out the serial numbers of the rifles one by one and was nearly halfway through the rifles when a civilian Government employee came into the arms room and said, “Put that weapon down because you’re not allowed to touch that weapon.” He then chastised the LT and told her and the two accompanying soldiers that they should know better. I explained that I was the Property Manager for the prime contractor, had experience handling weapons because I had been the Unit Armorer in the Army and that these weapons needed to be verified for the subcontractor. I did NOT mention however that I had already previously touched every weapon in the arms room (I just kept that to myself ). I looked at the LT and handed the rifle to her and exited the arms room. He then asked the LT to show the serial number and call out the number for the inventory takers. He came out and apologized for putting me on the spot and said I needed a weapons card to handle a weapon. That made sense to me; however, did that mean the LT had a weapons card for every weapon in the arms room? Needless to say, the LT finished the inventory with the subcontractor as directed and I left feeling a little discouraged.

I spent the next two weeks trying to find someone who could tell me whether or not what the civilian Government employee did was right or wrong. I contacted retired security officers and small arms professionals that worked with the military. Every road I took seemed to be a dead-end.

The question that I have now is this: how would I have known if someone had created a plastic mold and replaced a real weapon with a fake weapon with the same serial number? I’m certainly glad that I had touched all the weapons previously. My question to you is this: when should you accept something that can be seen but not touched? Should we just accept what we are told for granted without proper verification?

The answer I came up with took me back about 14 years earlier when I worked at a nuclear site in Nevada. There were small experimentation areas where items were installed but because of the nuclear concerns I was not allowed in those areas to verify the items. Instead, those items were pointed out for me to see through viewing areas as I did inventory. For the sake of SAFETY I was willing to accept items that I could not touch.

ABOUT THE AUTHOR:

Ronnie Sparks is a Certified Professional Property Manager (CPPM) and has been a member of NPMA for 20 years. He has over 32 years of property management experience and currently is responsible for more than 30 contracts throughout the US and US Territories. Ronnie is a decorated veteran of the US Armed Forces and spent almost eight years in service. His duty stations included Ft. Jackson, SC, Ft. Stewart, GA, Ft. Bragg, NC, Landstuhl, Germany, and the USA Support Battalion, North Camp, Sinai, Egypt. Ronnie holds a degree from the University of Phoenix but also attended University of Maryland, Saint Leo College and the Austin Community College and is currently the Senior Property Manager for a Native Alaska Corporation.


DEAR EXPERT PANEL,Our facility is rather large in terms of

area and property is constantly moving. In the past we’ve been challenged with accomplishing an annual physical inventory primarily due to the fact that we have limited personnel to perform the effort. I recently heard that another company performs their inventories using “Inventory By Exception” however, I’m not sure exactly how that would work and haven’t been able to find anything that describes how it is performed. What does the “exception” mean?

FROM, FRANNY FACILITY

DEAR FRANNY FACILITY,Not enough room here to really go into

the detail of an Inventory By Exception but we’ll offer you the basics:

During the course of ongoing activities, property “in motion” may have recorded transactions that, based on the transaction, the assets are “touched.” When and where the touch qualifies as a “physical accounting” of the assets, recording that transaction will also record a physical inventory. The challenge is recognizing those transactions and the ability to record them with a posting reference or “supporting documentation.”

Additionally you must have a system or method that communicates that transaction to your PM System. Recording these ongoing transactions over some period of time then produces a report of assets “touched” (Inventoried). At that reporting, you then have a number of assets that were not inventoried and these are the

“exception.” These are the assets you must then go out and physically locate.

Of course, as with all Physical Inventory efforts, the Inventory By Exception method begins with a “Plan.” Put it down on paper first and identify what those transactions are going to qualify.

FROM, YOUR EXPERT PANEL

DEAR EXPERT PANEL,We have a frustrating challenge with

Location Control and assets located in cubicles. There are several floors of a few buildings where the entire floor layout has employees located in cubes that don’t have numbers assigned. We’ve considered creating a numbering scheme but then those would be our unofficial Property “internal” numbering assignment which we don’t think we should have to do. Is there another way of establishing a Location Control approach to this condition?

FROM, LOCATION LANCE

DEAR LOCATION LANCE,To begin with, change the thinking and

approach. You can’t “control” locations, only “manage.” Cubicles, or “Cube Farms,” have always been the bane of Asset Management and recording locations since they first arrived back in the early 80’s (not that we were there mind you!). Consider: A person sits in that cubicle and is assigned assets for the performance of the duties. These cubicles are (normally) located in an expansive area of a given floor, i.e. 1st floor, 2nd floor, etc. How about using first, the floor reference and then the person

the assets are assigned to. In more cases than not this person’s name is located on the outer side of a cubicle (wall?) partition whether the cubicle has a number assigned or not. Need to locate or inventory an asset? You already have what floor it’s on – call the person the asset is assigned to and ask “where are you sitting this week.” Just a thought at one approach.


DEAR EXPERT PANEL, I am interested in getting certified but

do not know where to begin. What are the requirements for the CPPS, CPPA and CPPM certifications?

FROM, PROPERTY PAT

BY YOUR NPMA ‘EXPERT’ PANEL

ASK THEExpert

Questions

DO YOU HAVE A BURNING QUESTION for our panel of experts? We want to hear from you. Email [email protected] to submit your question.

ASKUS

WWW.NPMA.ORG 25

DEAR PROPERTY PAT,The requirements for all certification

levels may be found at http://www.npma.org/?page=Certification. In summary:

• CPPS – Successful completion of two exams based on the content of The Fundamentals of Personal Property Management manual - each exam is 50 multiple choice questions.

• CPPA – Current CPPS certification, plus successful completion of two exams based on the content of The Intermediate Studies of Personal Property Management manual

AND a supplemental manual focused on the type of organization selected (Federal, Contractor, State & Local, etc.) - each exam is 50 multiple choice questions. The applicant must also complete a Summary of Work Experience and demonstrate at least three years of experience in seven of the fifteen functional areas of Personal Property Management (the fifteen areas are listed on the website).

• CPPM – Current CPPA certification, plus the successful completion of a situational judgment exam (short essay). The applicant

must also complete a Summary of Work Experience and demonstrate at least six years of experience in seven of the fifteen functional areas of Personal Property Management (the fifteen areas are listed on the website), AND have at least four years of managerial experience (managerial experience means: Supervision, decision-making, or management of resources).


LEGAL DISCLAIMER:This column and the advice contained within is for recommendation purposes only. NPMA makes no representations or warranties

of any kind, express or implied, including without limitation any implied warranty of fitness for a particular purpose. Please note that additional issues may exist that could affect the treatment of the recommendation. The recommendation does not consider or reach a conclusion with respect to additional issues.

This is not to be construed as legal advice and NPMA is not liable for any damages, etc. that result from following (or not following) their advice. In no event shall NPMA be liable for any lost profits, lost data, or any form of special, incidental, indirect, consequential or punitive damages of any kind (whether or not foreseeable), whether based on breach of contract, tort (including negligence), product liability or otherwise, even if it is informed in advance of the possibility of such damages.


High-level U.S. Federal agency executives expressed their support for adoption of the ISO 55000 asset management standard series as a key means of saving significant taxpayer dollars at the Federal Leadership in Asset Management Policy Forum in Washington, D.C. on October 20 & 21, 2015.

Convened at the National Academies of Sciences, Engineering, and Medicine historic building on the National Mall, the Forum was co-sponsored by the Federal Facility Council and the Asset Leadership Network. Participating Federal agencies included the General Services Administration, Department of Defense, Department of Veterans Affairs, Office of Management and Budget, U.S. Army Corps of Engineers, Department of Homeland Security, General Accounting Office and others.

Alex Kurien, Deputy Associate Administrator, Office of U.S. Government-Wide Policy, General Services Administration stated, “Although I am extremely busy managing eight policies protecting the interests of the American people, I made time to participate in

this Asset Management Forum because supporting advanced asset management processes, such as adopting ISO 55000, is a clear path to enhancing the stewardship of our Federal Assets and saving taxpayer dollars.”

Sessions at the forum included demonstrating how advanced technology is enabling a closer relationship between real property and personal property, an expert panel focused on improving water asset management, and a keynote presentation on proven fleet management processes. In addition, the forum hosted an Executive Envisioning session with real property leaders from four Federal Agencies, industry leaders and keynote speaker Dag

Detter, whose book, “The Public Wealth of Nations”, was used to spark discussion of repairing Federal infrastructure with the dramatic savings possible with proper asset management tools and processes.

At an evening event held at the National Press Club, the Asset Leadership Network presented four 2015 Asset Leadership Impact Awards to recognize those individuals and organizations for their significant impact in asset management programs and processes. The honorees were:

A day of briefings to the offices of many U.S. Senators and Representatives followed the Forum and resulted in positive responses for the potential adoption of ISO 55000 to improve the efficiency and effectiveness of managing federal assets and returning significantly increased value to taxpayers.

More information is available at www.assetleadership.net.

> The National Guard Bureau and the Army National Guard for their use of ISO 55000 to help tie assets to mission;

> The DoD, VA, OMB and NAVFAC for their collaborative efforts to improve management of real property and personal assets;

> Rep. Patrick Murphy (FL-18) for the introduction of the bipartisan Savings, Accountability, Value, and Efficiency Act (SAVE Act) to improve Federal asset disposition; and,

> Renowned author Dag Detter for his insight into the management of public assets described in “The Public Wealth of Nations.”

Alex Kurien, Deputy Associate Administrator, Office of U.S. Government-Wide Policy, General Services Administration addressing the Executive Envisioning Session at the Federal Leadership in Asset

Management Policy Forum that included high-level executives from many Federal Agencies.

By Michael Bordenaro, Communications Team Leader, Asset Leadership NetworkPhotos by Robert Smith

Mr. Kurien spoke about the ways ISO 55000 can help better manage $1.5 trillion in Federal personal

property and $1.5 trillion in real property during the Federal Leadership in Asset Management Policy

Forum at the National Academy of Sciences in October 2015.

FEDERAL ASSET MANAGEMENT FORUM SHOWS POTENTIAL FOR DRAMATIC

SAVINGS OF U.S. TAX DOLLARS

WWW.NPMA.ORG 27

NPMA’S ASSET MANAGEMENT CERTIFICATION PROGRAM

BENEFITS:

> Key to enhanced professional stature> Expanded knowledge> Gain technical competence in property management> National professional recognition> Extensive peer-level communication

Certification Level

Minimum Experience

Prerequisite Certification Renewal Period

CPPS Certified Professional

Property SpecialistNone required None required Five years

CPPA Certified Professional

Property Administrator

Three years CPPS Five years

CPPM Certified Professional

Property ManagerSix years CPPA Five years

ENHANCE YOUR PROFESSIONAL STATURE BY ACHIEVING CERTIFICATION.

Learn more at http://www.npma.org/?page=Certification

Certification training courses are available through NPMA.

Visit our website or call404-477-5811 to find the course

that’s right for you.

ASKUS

Fleet TrainingReleased

LOOKOUT

CERTIFIED FEDERAL FLEET COURSES NOW AVAILABLE


BACKGROUND AND ACCOMPLISHMENTS

NPMA is committed to advance the profession of property

management. To show their support and commitment to the

profession, NPMA formed the NPMA Foundation in 1997 with the

mission to provide funding opportunities for our members who would

otherwise not be able to enhance their professional development.

The Foundation receives income from the generous donations

provided by our members, chapters, and regions. Our members

volunteer to work with the NPMA Foundation to coordinate all

activities associated with the solicitation and collection of these cash

and gift donations.

Since 1997, the NPMA Foundation has awarded hundreds of grants

to our members to attend educational seminars. In 2015, the NPMA

Foundation provided nine awards to members for educational

seminars. These members were thankful the Foundation and

appreciated the generous donations from all of you. The NPMA

Foundation would like to thank you and all of the dedicated, hard-

working volunteers for making this possible. The Foundation is

managed by the Foundation Committee which includes great

volunteers from all three regions.

FUNDS AND SUPPORT

Where do all the funds come from to provide grant awards each year? The NPMA Foundation depends on the generous

donations from our members, chapters, and regions who make it all possible. In addition to the donations received each

year, the NPMA Foundation has several fund raising events at the National Educational Seminars (NES). The 2015 NES was

another great and successful year. We had several wonderful gift baskets from the chapters, special gifts from dedicated

individuals, raffles, and the live auction. It was a successful fundraising year for the NPMA Foundation at NES. This means

we will able to award even more grants in 2016. Isn’t it great?

CALL FOR ACTION

We need your support to continue this much-needed tradition. This great cause can continue only through the generous

donations from you as an individual member, your chapter and your region. Please help us by donating to the NPMA

Foundation.

Remember, it is easy to donate to this very worthwhile cause to support our colleagues. You can complete your

tax-deductible donations online at https://npma.site-ym.com/donations/ by credit card. If you prefer, you can mail your

check to our office at: NPMA Foundation, 3525 Piedmont Rd NE, Building Five, Suite 300, Atlanta, GA 30305-1509.

For info, comments or to volunteer, contact Raam Vichare, NPMA Foundation Director, at [email protected]

WWW.NPMA.ORG 29

Nashville

SAVE

THE

DATE

AUGUST 29 - SEPTEMBER 1, 20162016 National Education Seminar (NES)Gaylord Opryland Resort, Nashville, TN

www.npmaconferences.org/nes


FUNDAMENTALS OF PERSONAL PROPERTY MANAGEMENT

JANUARY 21-23 // WASHINGTON, D.C.Every organization, regardless of its size or type has critical

business functions that are integral parts of meeting its objectives and accomplishing the mission. Property management is first and foremost a general management assignment no different than the management of any other resource such as money, personnel, or facilities. Personal property managers are directly accountable to a higher authority for the acquisition, use, redistribution, and disposition of personal property. As stewards of our company or agency’s personal property, we have a fiduciary responsibility to manage property in a prudent and compliant way. The Fundamentals of Personal Property Management course is designed to teach the basics of property management, cradle-to-grave, including how to effectively manage personal property.

The Fundamentals of Personal Property Management manual is included as part of this course.

FLEET MANAGEMENT – CERTIFIED FEDERAL FLEET SPECIALIST

JANUARY 23-25 // ARLINGTON, VIRGINIA The NPMA, in partnership with Mercury Associates, is proud

to offer the first Certification for the Federal Fleet Manager. The CFFS level training is designed for persons who have basic Fleet Management responsibilities or dual roles such as the vehicle control officer. Course subjects include Basic Fleet Management, Fleet Information Management: Regulations, Systems and Data, and Optimizing the Fleet. Certification testing will be performed during the 3-day course.

FLEET MANAGEMENT – CERTIFIED FEDERAL FLEET ADMINISTRATOR

JANUARY 23-25 // ARLINGTON, VIRGINIA The NPMA, in partnership with Mercury Associates, is proud

to offer the first Certification for the Federal Fleet Manager. The Certified Federal Fleet Administrator (CFFA) level training is designed for persons who have successfully completed the Certified Fleet Specialist training. Fleet Management responsibilities or dual roles such as the vehicle control officer. Course subjects include, Fuel Management, Leased Fleet Management, Asset Management and Disposal Management. Certification testing will be performed during the 3-day course.

COURSE Schedule

Register today for an NPMA

course!

BY ATTENDING AN NPMA course, you’ll gain the knowledge and skills you need to succeed on the job. Don’t wait, register today! Seating is limited!

IF YOU HAVE QUESTIONS about NPMA courses, call 404.477.5811 or email [email protected]. For more information or to register, visit the website at www.npma.org and click on the Education tab.

DON’T WAIT

WWW.NPMA.ORG 31

FUNDAMENTALS OF PERSONAL PROPERTY MANAGEMENT

FEBRUARY 16-18 // PHOENIX, ARIZONAEvery organization, regardless of its size or type has

critical business functions that are integral parts of meeting its objectives and accomplishing the mission. Property management is first and foremost a general management assignment no different than the management of any other resource such as money, personnel, or facilities. Personal property managers are directly accountable to a higher authority for the acquisition, use, redistribution, and disposition of personal property. As stewards of our company or agency’s personal property, we have a fiduciary responsibility to manage property in a prudent and compliant way. The Fundamentals of Personal Property Management course is designed to teach the basics of property management, cradle-to-grave, including how to effectively manage personal property.

The Fundamentals of Personal Property Management manual is included as part of this course.

GOVERNMENT PROPERTY BASICS

FEBRUARY 16-18 // PHOENIX, ARIZONAWhen it comes to managing assets, understanding the

complexities of government regulations is a vital first step. This five-day course presents a detailed analysis of life cycle asset management in government property systems. In addition to the fundamentals of property management and the regulatory requirements of property management; this course includes an overview of the Federal Acquisition Regulations (FAR) and other appropriate regulations used in federal government procurement of supplies and services. This course is essential if you work in property management, supply-chain, logistics, quality assurance, contract management, procurement, subcontract administration, program management or internal auditing.

NPMA CERTIFICATION REVIEWS & TESTINGThe NPMA Certification Program is designed to elevate

professional standards and enhance individual performance for those who demonstrate a high level of competence that is essential to the practice of property management. If you have made a commitment to a career in property management, you should consider obtaining your NPMA certification. Join a distinguished group of peers worldwide who have chosen to attain this high level of excellence.

For information about NPMA certification, visit the website at www.npma.org/pages/certification.htm

CPPS CERTIFICATION REVIEW & TESTING

JANUARY 21-23 // WASHINGTON, D.C.

CPPS CERTIFICATION REVIEW & TESTING

FEBRUARY 16-18 // PHOENIX, ARIZONA

J A N U A R Y - F E B R U A R Y

Visit www.npma.org to register

1. Policy 2. Inventory3. Agency Supplements4. Guidance5. Clauses6. Government Property7. Deviation8. Acquisition9. Reporting10. Liability

ANSWERS FROMthe

PUZZLEChallenge

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PROPERTY · BY MICHAEL BORDERNARO, ASSET LEADERSHIP NETWORK REGULAR FEATURES 04 National...

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