2013 npma fall conference value through professional asset management iuid are you ready? mike...
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2013 NPMA Fall ConferenceValue Through Professional Asset Management
IUID Are you Ready?
Mike Herskovits, CPPM
November, 2013
2013 NPMA Fall ConferenceValue Through Professional Asset Management
IUID – Are You Ready?
Disclosure – This presentation has extracted from several sources of
information and is not intended to be construed the presenter’s employer or as changing or modifying any statute, regulation, DoD policy or guidance, or any term(s) of any contract with the U.S. Government or any department or agency of the U.S. Government.
This briefing focuses on the August 2012 version of DFARS Clause 252.211-7007
2013 NPMA Fall ConferenceValue Through Professional Asset Management
AGENDA Background & History Focus of Presentation Evolution of Reporting Types of GFP What is UII What is Serially Managed Reporting Events Assumptions
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Background & History DoD has a long tradition of identification and marking of
its military property. The Defense Standardization Act of 1952 gave rise to the
national stock number (NSN) system to provide unification & standardization of consumable items to assure like items would be identified as such.
After WWII, an effort was made to prevent unnecessary duplication of supply and allow for sharing across all services.
March 4, 1953 – MIL-STD-130 ID of Marking Published. Rev. L in 2003 – Allowed for other than only human
readable information.
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Background Con’t 1990 – Chief Financial Officer’s Act called for improved
financial management. DoD needed capability for enhanced total asset visibility, improved lifecycle management accountability and clean financial audits.
Combatant Commanders need battlefield awareness and total asset visibility.
2002 – DoD initiated an effort to re-engineer the process.
2013 NPMA Fall ConferenceValue Through Professional Asset Management
FOCUS
This briefing focuses on the August 2012 version of DFARS Clause 252.211-7007
•The clause does not contain a “marking” requirement •The clause does contain a GFP reporting requirement •The clause is often confused with DFARS 252.211-7003 •Both clauses involve the DoD IUID registry. However, each
reflects fundamentally different requirements: •DFARS clause 252.211-7003 pertains to delivery of items •DFARS clause 252.211-7007 pertains to reporting of GFP
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Focus Background 2007: Contractor reporting of GFP begins in earnest •Regulatory (DFARS) timeline: •252.211-7007 [August 2012] (Includes new 2014
requirements*) •252.211-7007 [November 2008] (Final Rule) •252.211-7007 [September 2007] (Interim Rule) •Multiple changes created a degree of confusion, but
core reporting requirements did not change
*Afforded industry adequate time to prepare for new requirements
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Evolution of 252.245.7001
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Types of GFP Item is serially managed or over $5,000
Item is NOT serially managed AND Under $5,000
Registered Not Registered
Marked Compliant Failure to Report
Not Marked Failure to Mark Non-Complian
Registered Not Registered
Marked Permitted by draftRevised DDFARS
252.211-7003
Failure to Report
Not Marked Failure to Mark IUID Not RequiredNo ISSUE
2013 NPMA Fall ConferenceValue Through Professional Asset Management
What is UII “a set of data elements marked on items that is globally
unique and unambiguous. The term includes a concatenated unique item identifier or a DoD recognized unique identification equivalent.”
Why do some GFP items have UII’s ? Because – • The contractor assigned and registered a UII by virtue of
delivery under DFARS 252.211-7003 requirements, or• •The DoD Component assigned and registered a UII while
the item was in its custody By default, items with a UII are serially managed
2013 NPMA Fall ConferenceValue Through Professional Asset Management
What Does Serially Managed Mean?* “An item designated by DoD to be uniquely tracked,
controlled, or managed in maintenance, repair and/or supply systems by means of its serial number.” DFARS clause 252.211-7007
• * In addition to items previously marked with a UII, certain FAR property categories already meet this definition.
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Inherently Serially Managed Items All items subject to DoD Instruction (DoDI) 5000.64 are
considered serially managed, i.e., “designated by DoD”• Special tooling (ST), special test equipment (STE), and
equipment all fall under DoDI 5000.64• Therefore all ST, STE, and Equipment items are subject to
DFARS 252.211-7007 reporting Material (items other than ST, STE and Equipment) is a
different matter; material cannot be considered “inherently” serially managed*
*True, “some” material items have serial numbers— but that does not make them inherently “serially managed”
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Identification of Serially Managed THE GOVERNMENT – Not the Contractor,
Has to Identify Serially Managed Items
Contract Terms and Conditions MUST identify ALL items to be Serially Managed
Example – Items individually listed on the “Scheduled” GFP Attachment (SGFP)
2013 NPMA Fall ConferenceValue Through Professional Asset Management
What Does Report Mean - In simplest terms, it means sending information to the
DoD IUID registry (“the registry”) related to a property item’s custody.
2013 NPMA Fall ConferenceValue Through Professional Asset Management
REPORTING (Cont) (2014) Reporting involves the following events:
• Receipt of property• Delivered or shipment from the contractor’s plant (unless
to a subcontractor)• Consumed or expended• Disposed of• Transferred to a follow-on or other contract
Let’s look at each of these reporting events
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Reporting - Receipt Receipt means acknowledging (electronically) the physical receipt
of all GFP This is the clearly the most important reporting requirement:
• Impacts overall property accountability• The Government’s warranty of timeliness of GFP delivery• Contract performance• Readiness• Applies to all categories of GFP. Period. No exceptions.
Universal electronic acknowledgement of all GFP items is a fundamental requirement of DFARS 252.211-7007 and property accountability!
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Receipt (Cont.) Electronic receipt acknowledgment is crucial and
required for all GFP items It does not matter if the GFP is:
• Serially managed• Not serially managed*• Valued above or below $5,000• An item for repair• Lacks a UII
*If the property is not serially managed, acknowledgement of receipt is all that’s needed. No other reporting is required under the clause. Done!
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Receipt (Cont) GFP reported to the IUID Registry in 3 ways –
1. Through Wide-area Workflow (WAWF)
2. Registry website – if has UII and in registry
3. Electronic File submission
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Other Reporting Events Delivered or Shipped from Contractor’s Plant
• IAW Contract T&C or Direction of Contracting Officer• Shipped to a DoD entity or another DoD contract• Requires electronic acknowledgement of receipt by
gaining contractor & WAWF repairable repors Disposed of (Different than above) Means:
Transfer to a non-DoD federal Agency Donation, sale or abandonment
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Other Reporting Events (cont) PCARSS automatically to update registry when
“disposed of” events occur PCARSS does NOT automatically update the registry
when “shipment” (to Army, Navy, Air Force, Federal ciovil agencies) events occur.
Note – DCMA’s Property Loss Tool updates the registry automatically upon contractor reporting of property loss (ref: DFARS 252.245-7002)
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Other Reporting Events (cont) Consumed or expended
• Destructive testing• Test firing a missile• Certain types of drill bits
Transferred to a follow-on or other contract means: a contractual transfer of property accountability (same contractor/same CAGE)
Registry (via WAWF) must be updated to reflect the new contract
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Reporting Assumptions If an item is not –
• “Delivered” by the contractor• “Shipped” by the contractor (as part of the T&Cs)• “Disposed of” as defined above• Processed through PCARSS• Reported as lost through DCMA’s Loss Tool (etools)• Transferred to another Contract at the same Cage• Then it would be considered consumed as part of the
process. Issue records should be able to verify.
2013 NPMA Fall ConferenceValue Through Professional Asset Management
Questions
Mike Herskovits, [email protected]
2013 NPMA Fall ConferenceValue Through Professional Asset Management
References -History of UID and MIL-STD-130
HTTP://www.camcode.com/asset-tags/uid-overview-series-part-i-iud.
Ruckdaschel, Tom, GFP Reporting Under DFARS Clause 252.211-7007, 2013/10/23.
https://home.dcma.mil/POLICY/124r/index.cfm
Resources
https://home.dcma.mil/POLICY/111r/index.cfm
http://dodprocurementtoolbox.com/
http://www.acq.osd.mil/dpap/pdi/gfp/index.html