Defense Procurement and Acquisition Policy (DPAP) Presented by: Government Furnished Property Basics Carol Vigna, OSD AT&L DPAP David Guinasso, supporting OSD AT&L DPAP 29 July 2014

DISCLAIMER  This information: »Should not be construed as changing or modifying any statute, regulation, DoD policy or guidance, or any term(s) of any contract with the U.S. Government or any department or agency of the U.S. Government. 2

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

Synchronizing the Policy DoDM 4140 Material/ Logistics Equipment/ Accountability Acquisition/ GFP DoDM 4140DoDI DoDI Published February 2014 Published May 2011Published April 2012 Policies based on 19 business rules ensuring consistency of policy and terminology across organizations 4

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

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

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

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

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

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

Documentation necessary to Support Providing GFP to the Contractor »PGI (2) “Prior to furnishing Government property to the contractor, the contracting officer shall ensure that each of the requirements of FAR are addressed as follows, and documented in the contracting file—” -Element 1: Government’s best interest; -Element 2: Overall benefit to the acquisition; -Element 3: Government’s assumption risk; and -Element 4: Requirement cannot otherwise be met **Must meet all 4 Elements** 11

Element 1: Government’s Best Interest »In the Government’s best interest -Discussion should be specific & factual -Actual or projected dollars should be addressed »Discussion should address the following: -Economy – achieves lowest cost or price objective -Standardization – critical need for precise replication (e.g., special tooling for consistent measurements) -Security – needed for national security reasons -Expedite production – critical for achieving timely delivery -Scarcity – Government is the only source -Maintain the Industrial base – ensure future capability -Contract type – potential for a more favorable contract 12

Element 2: Overall Benefit to the Acquisition »Overall benefit to the acquisition must significantly outweigh the costs of administration »Property in the hands of contractors drives program costs -Controlling -Managing -Disposal »Costs must be either less than what the contractor might otherwise incur; or benefit to the Government must outweigh additional costs 13

Element 3: Government’s Assumption Risk »Risk analysis must demonstrate that the Government is not substantially increasing its risk. »Risks must be considered, discussed and documented. 14

Element 4: Requirement cannot otherwise be met »The Government property being provided is critical and significant to meeting acquisition plan objectives. 15

GFP Attachments »The Government is required to list the property it will provide and information and data about that property (FAR ). »To ensure all required data and information is provided DoD has implemented mandatory standard property attachments (PGI ). »There are two formats for the attachment: -Scheduled GFP -Requisitioned GFP »The Contracting Officer, with the input of the requiring activity, will ensure the attachment is included in solicitations and awards. 16

Scheduled Government Furnished Property Attachment (SGFP)  Provides a listing of the Government property to be provided, including when major end items are being provided under a modification or upgrade contract; or when reparables are being provided under a repair, modification, or overhaul contract.  Parts of the SGFP Attachment: »1. Identifies the Attachment Number and the Contract Number » 2. Serialized Items List and Non-Serialized Items List -These two lists are very similar and have significant overlap in their data fields. The difference is that the Serialized Items List is used to list serially-managed items (See DFARS (a)) and the Non-Serialized Items List is for items that are not serially- managed.  Available at DFARS PGI (c) or at the DoD Procurement Toolbox. 17

Requisitioned Government Furnished Property Attachment (RGFP)  Provides a listing of Government Property to be authorized for contractor requisition from DoD supply sources in accordance with the clause at FAR  Part of the RGFP Attachment: »1. Identifies the Attachment Number and the Contract Number »2. Reimbursable List and the Non-Reimbursable List. - The Reimbursable List is a list of parts that the contractor can requisition from the supply system that they must pay for. Requisitioned parts paid for by the contractor are not GFP. On cost reimbursable contracts they are Contractor Acquired Property (CAP). On Fixed-Price Contracts those parts become Contractor Furnished Material (CFM). -The Non-Reimbursable List is a list of parts the contractor can requisition that the contractor does not have to pay for. These items become GFP when received by the contractor.  Available at PGI (b) or at the DoD Procurement Toolbox. 18

Scheduled Government- Furnished Property: Step-by-Step Tutorial 19

Scheduled GFP Attachment The Scheduled Government Furnished Property format consists of three distinct parts: 1.Attachment Number and Contract Number 2.Serialized Items List 3.Non-Serialized Items List Attachment Number and Contracts Number Identification Serialized Items List Non-Serialized Items List 20

SGPF Step 1: Attachment Number and Contract Number Identify the Attachment Number when the form is used in solicitations, contract awards, and contract modifications. When used as an attachment to a solicitation, leave the “Contract Number” section blank. When the Scheduled GFP Attachment is included during contract award or modification, include component parts of the contract number for DoD FAR type contracts. For Non-DoD or non-standard contract numbers, enter the complete contract number in the “Non-DoD Contract” field. Enter only one contract number format. 21

Step 2: Serialized Items and Non- Serialized Items Lists Serialized Items List and Non-Serialized Items List, are very similar and have significant overlap in their data fields. The difference is that the Serialized Items List is used to list serially- managed items (See DFARS (a)) and the Non-Serialized Items List is for items that are not serially- managed. 22

Step 3: Step 2: Serialized Items and Non-Serialized Items Lists REQUIRED: Item Number, Description, Nomenclature, Quantity, Unit of Measure and Use As is. OPTIONAL: CAGE, Model Number, National Stock Number, Part Number, Part or Identifying Number, and Type Designation NOTE: Unit Acquisition Cost is required to be identified by the Government in the contract per FAR However, it may not be available at the time of contract award. If the Unit Acquisition Cost is not available, the field can be left blank, but the attachment should be modified to add the Unit Acquisition Cost once it becomes available. 23

Step 4: Marking Instructions Marking Instructions is a mandatory field for all items on the Serialized Items List. A value of YES in the field identifies that the item must be tagged, labeled or marked in accordance with the clause If an item has the value YES, the Government should provide marking instructions in the contract. A value of NO means the items do not require tagging, labeling or marking. Leave Marking Instructions BLANK in Non-Serialized Items List (not used currently). Only fill in Serialized Items List Marking Instructions Field LEAVE BLANK 24

Step 5: Serial Number and Unique Item Number All serially managed items should have a serial number, but those serial numbers may not be known at the time of contract award. For example, the number of items to be repaired on a contract may be known, but the exact items that will be sent for repair may not have been determined. GFP engines may be identified as being provided to incorporate into the deliverable end item, an aircraft, but the serial numbers and Unique Item Number of the engines are not known at contract award because they have not been manufactured yet. In these situations, identify the quantity of the item and leave the Serial Number and Unique Item Number fields blank. If the Serial Number is known, but the Unique Item Number is not, enter an Item Number line for each item including its Serial Number, and leave the Unique Item Number field blank. If no serial number and unique item number, enter quantity. If know serial number but not UII, enter item number for each item and Serial Number. Leave Unique Item Number Blank. 25

Submission of the GFP Attachments  DPAP has published fillable formats on to collect the required GFP data. »The formats are in Excel or fillable PDF. -The Excel format must be converted to PDF using the PDF converter tool described on the Procurement Toolbox.  The attachments will be included in the contract or mod sent to EDA in accordance with DFARS , IAW local procedures for distributing contract attachments.  EDA will make the GFP list available to track data about property provided to the contractor against the property required by the contract. 26

Property Clauses MANDATORY  FAR Government Property, in solicitation and contracts that are Cost reimbursable, T&M, Labor Hour, and any contract where the Government intends to provide GFP. FAR  FAR Use and Charges, in solicitations and contracts when the clause at is included. FAR  DFARS –7001 Tagging, Labeling, and Marking of Government- Furnished Property, in solicitations and contracts that contain the clause at FAR , Government Property. DFARS –7001  DFARS –7002 Reporting Loss of Government Property, in solicitations and contracts that contain the clause at FAR –1, Government Property. DFARS –7002  DFARS Contractor Property Management System Administration, in solicitations and contracts containing the clause at FAR , Government Property. DFARS  DFARS –7004 Reporting, Reutilization, and Disposal, in solicitations and contracts that contain the clause at FAR , Government Property. DFARS –7004  DFARS Reporting of Government-Furnished Property, in solicitations and contracts that contain the clause at FAR , Government Property. DFARS OPTIONAL  DFARS Government-Furnished Mapping, Charting, and Geodesy Property, in solicitations and contracts when mapping, charting, and geodesy property is to be furnished. DFARS

GFP Regulations- DFARS PGI  DFARS Procedure, Guidance and Information (“PGI”) »PGI Government Furnished Property- General »PGI Guidance to determine if government property should be furnished to contractors »PGI Government Furnished Property- Solicitation and Evaluation Procedures »PGI GFP Attachments to Solicitations and Awards »PGI Title to Government Property 28

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

WAWF & the IUID Registry Delivery of new property Transfer of Property Contractor Receipt of GFP Delivery & Shipment of Reparables Government Receipt of Property WAWF Records for UII’d items and non-UII’d GFP IUID Registry Records about a Components Property for financial reporting APSR GEX Electronic capture of valuation and movement to establish Existence and Completeness for Auditability 30

For Contract Management Property Loss Tool (PLT) Plant Clearance Automated Reutilization and Screening System (PCARSS) Records for UII’d items and non-UII’d GFP Records about a Components Property for financial reporting APSR IUID Registry Reporting the “Death” of Property 31

On the Horizon  Data Integrity »SSAE 16 review of WAWF »AT&L review of integrity of the Registry -Significant issues with direct entry data -Fewer issues with WAWF data  Merger of WAWF and IUID Registry »Eliminate duplicate data storage »Improve data integrity »Simplify user access controls, help desk  WAWF Mobile Property Transactions »Make the best method of data capture available anywhere. 32

For more information or Contact Carol Vigna at or GFP Policy Training, Procedures, Tools 33

Any Questions? 34