Item Unique Identification (IUID) Government Furnished Property (GFP) of Government Furnished Property (GFP) 6 September 2016 Carol Vigna, OSD AT&L DPAP carol.a.vigna.civ@mail.mil Craig MacDougall, NSWC Corona craig.macdougall@navy.mil www.dodprocurementtoolbox.com August 2016

Topics Background Policy Process Marking GFP with UID Reporting GFP with UID

Definitions - IUID Unique Identification (UID) is a system of identifying entities to distinguish them from each other. Item Unique Identification (IUID) is a system of marking items with globally unique, Unique Item Identifiers (UIIs) that distinguish them from all other like and unlike items. Unique Item Identifier (UII) is a string of characters which is globally unique. Exactly one UII is assigned to exactly one item. Points to be made: Vocabulary refresher Notes: Some words and phrases have a particular meaning within the context of IUID.

Scope of the UII A UII is… A UII is not… a data element a unique identifier for an item globally unique permanent created by concatenating specific data elements an enabler for business intelligence a device for communicating data, such as Radio Frequency Identification (RFID) tags or contact memory buttons a replacement for the National Stock Number (NSN) intelligent data that yields information about the item transferable from one item to another Points to be made: The UII is the unique data string that identifies the item (it is derived from what is encoded in the IUID mark, but is not the encoded data verbatim). The UII is what is required to be permanent and unique per policy. Notes: The UII is similar to a social security number for an item. It does not give any specific information about the item, only uniquely identifies the item so information can be identified/associated/gathered from information systems. Just as your social security number is yours forever, the UII is that item’s forever. The UII is not intended to replace any existing item information, it should be consider a new data element.

NOT ALL GFP IS IUID RELEVANT. Definitions - GFP 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. 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. Some GFP has a UII when received; some may be UID’d while in contractor custody. NOT ALL GFP IS IUID RELEVANT.

Not considered GFP Government property that is incidental to the place of performance, when the contract requires contractor personnel to be located on a Government site or installation, and when the property used by the contractor within the location remains accountable to the Government. Located on a Government site or installation Used within the location Remains accountable to the Government

Topics Background Policy Process Marking GFP with UID Reporting GFP with UID

IUID Policy Marking & Reporting of Delivered Items (NOT GFP) DFARS 211.274-2 – Policy for Item Unique Identification: It is DoD policy that DoD item unique identification, … is required for all delivered items, including items of contractor-acquired property delivered on contract line items… When acquisition cost  $5,000 For items designated as “mission essential” “controlled inventory items”, “special tooling”, or “special test equipment” For high risk items - “vulnerable to supply chain threat”, “counterfeit”, “cyber attack” For DoD serially managed items For items which are parent items to uniquely managed sub-component(s) For serialized items which have a warranty

IUID Policy (cont’d) Marking & Reporting of Delivered Items (NOT GFP) DFARS 252.211-7003 – Item Unique Identification and Valuation The contractor shall provide a unique item identifier… The contractor shall submit the information End items reported using the receiving report capability in WAWF Embedded items via WAWF or Direct to Registry The contractor shall mark the UII on the item(s) in an ECC200 Data Matrix (using appropriate syntax and semantics)

So what’s (relatively) new for IUID? DoDI 8320.04 issued 3 September 2015 $5,000 threshold removed* New flowchart to determine which items require IUID IUID shall be employed for all items that require unique item level traceability at any time in their lifecycle Alignment with other IUID related policies is in progress DFARS 252.211-7003 Property accountability * This applies to legacy items. The $5,000 criteria is still in effect for new acquisition.

Legacy IUID Decision Flowchart

Legacy IUID Decision Flowchart (cont’d) IUID relevant items should be marked and registered prior to shipment to a contractor (opportunistic marking). If not possible, consider whether the contractor should mark it while in their custody.

IUID Decision Flowchart Bottom Line “IUID shall be employed for all items that require unique item level traceability at any time in their lifecycle” Small arms: we need to account for them individually Calibration gages: we need to recalibrate them periodically Aircraft engines: we need to keep track of flight hours for each engine Nuclear Related Weapons Material (NWRM): individual accountability required A Short List of Examples …many other examples exist…

GFP Policy GFP Policy DFARS 211.274-4 – Policy for reporting of Government-furnished property: 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 252.211-7007 MARKING – DFARS 252.245-7001 – Tagging, Labeling, and Marking of Government-Furnished Property Contractor shall tag, label, or mark GFP items identified in the contract as … serially managed items To be updated to identify “in accordance with drawings” REPORTING - 252.211-7007 – Reporting of Government Furnished Property: …The contractor shall report… Government-furnished property to the IUID Registry

Property Clauses Summary MANDATORY FAR 52.245-1 Government Property, in all cost type and T&M solicitations and contracts, and in labor hour and fixed-price solicitations and contracts when the Government will provide property. FAR 52.245-9 Use and Charges, in solicitations and contracts when the clause at 52.245-1 is included. DFARS 252.245–7001 Tagging, Labeling, and Marking of Government-Furnished Property, in solicitations and contracts that contain the clause at FAR 52.245-1, Government Property. DFARS 252.245–7002 Reporting Loss of Government Property, in solicitations and contracts that contain the clause at FAR 52.245–1, Government Property. DFARS 252.245-7003 Contractor Property Management System Administration, in solicitations and contracts containing the clause at FAR 52.245-1, Government Property. DFARS252.245–7004 Reporting, Reutilization, and Disposal, in solicitations and contracts that contain the clause at FAR 52.245-1, Government Property. DFARS 252.211-7007 Reporting of Government-Furnished Property, in solicitations and contracts that contain the clause at FAR 52.245-1, Government Property. OPTIONAL DFARS 252.245-7000 Government-Furnished Mapping, Charting, and Geodesy Property, in solicitations and contracts when mapping, charting, and geodesy property is to be furnished.

GFP Clauses Compliance Audits of contracts with GFP show lots of room for improvement for including the appropriate FAR and DFARS Property Clauses If the correct clauses aren’t in the solicitations and contracts we obviously have problems with contractor compliance

Topics Background Policy Process Marking GFP with UID Reporting GFP with UID

GFP Attachment PGI 245.103-72 Directs creation and inclusion of GFP Attachment Added to solicitations and awards of contracts that may provide GFP (including all cost type contracts) Two types Scheduled GFP (items that will be “pushed” to the contractor Requisitioned GFP (items that will be requisitioned by the contractor) non-reimbursable section items are GFP; reimbursable section is CAP/CFM ONE format – “readable” PDF Can be manually entered OR created from Excel conversion Attached to contract or mod when distributed to EDA Attachment data transmitted to and captured in IUID Registry

The GFP Attachment is Important Because it… Identifies the type, quantity of property to be provided Establishes the unit acquisition cost that will be reported by the contractor Identifies which items of GFP are serially managed (for 252.211-7007) Identifies if property is used “as-is” Transmitted to the Registry as the “planned” GFP This information is required to be provided by the Government

Using iRAPT to support GFP iRAPT=Invoice, Receipt, Acceptance, Property Transfer Wide Area Workflow (WAWF) is the umbrella suite under which many enterprise systems fall – EDA, CORT, IUID Registry, My Invoice, etc Property Transfers Between: DoD to Contractor (and receipt) Contractor to DoD (and receipt) DoD to DoD (and receipt) Contractor to Contractor (based on formal contract action) Shipment of GFP to Contractor should be entered in iRAPT by DoD, including UII if known Receipt of GFP by Contractor must be reported Non-UII GFP can ONLY be receipted in iRAPT

Overview of iRAPT Property Transfers Property to Contractor from DoD DoD can and should input the Property Transfer (PT) into iRAPT to alert contractor of inbound items Contractor receipts items in iRAPT (including UII) Based on preceding DoD iRAPT PT document Unilaterally if no iRAPT PT document was created by DoD Custody transfer flows to IUID/GFP Registry and APSR IUID’d items update custody record; nonUII’d item capture the event Property to DoD from Contractor (returned GFP including reparables) Contractor inputs PT into iRAPT (via PT or RRR) DoD acknowledges receipt of item APSR=Accountable Property System of Record RRR=Reparable Receiving Report

Benefits of Using the iRAPT Process for GFP Visibility Early notification of inbound GFP items Both to Contractors and upon return to DoD Assurance of receipt Or the ability to follow up on shipments that are not overtly received The only method for Contractors to report non-UII’d GFP UII’d GFP can be receipted or returned via direct submission to the IUID Registry Supports FIAR related processes and visibility FIAR=Financial Improvement and Audit Readiness

GFP Data Flow Architecture Requiring Systems GFP List (attachment in fillable PDF - TBD BI Reports of GFP Status Industry iRAPT GFP Property Transfer Contract Writing DoD (Management Control Activities) GFP Receipt & Shipment Notice Property Transfer DLA GFP Attachment DoD Supply System IUID Registry DLA GFP list as XML Record of property transfer EDA DLA Shipment Notice DLA Property loss or disposal Receipt Contract Deficiency Reports for missing GFP terms or data Shipment Notice Component Accountable Property Systems Distribution Standard System (reparable return) PCARSS/ PLT CDRs DCMA DLA Note: DPAS Operational DCMA Operational Incremental deployment Future Capability

Topics Background Policy Process Marking GFP with UID Reporting GFP with UID

Why IUID? IUID provides… the “data key” to item lifecycle traceability in business processes and information systems reliable and accurate data for financial, accountability, and asset management purposes IUID enables… the discovery and correlation of item information globally accessible and secure enterprise data joint paperless management Points to be made: IUID provides the key to enable data for a single item to be linked across business process (e.g., financial, logistics, maintenance) to provide a more complete and accurate lifecycle picture. Notes: The incorporation of AIT also provides an opportunity to re-engineer business processes, potentially streamlining them and realizing savings of cost and/or time while increasing data accuracy and reliability.

When Marking IUID on GFP Standard IUID rules apply: Must be encoded into an ECC200 Data Matrix barcode Must include syntax from ISO/IEC 15434 Must include appropriate semantics Must adhere to data element length requirements Must use only A through Z, 0 through 9, /, and – No lower case letters, periods, asterisks, commas, … UII ≤ 50 characters UII must be unique across the globe IUID data matrix must be “permanent”… forever Points to be made: Additional IUID data constraints that are required for IUID compliance. Notes: The character constraints are most frequently problematic when it comes to part numbers. If this is a problem for a particular program often suggest using either construct #1 (just avoid the situation entirely) or define a business process for handling the illegal characters (consistent use). The UII is permanently assigned to the item, meaning it never changes. It stays with the item through modifications, part number rolls, retirement, destruction, and/or death, never to be assigned to another item.

UID And GFP Lessons Learned DoD should mark and register items prior to shipment to the contractor (this doesn’t always happen) DoD is responsible for identifying which items are to be UID marked and registered while in contractor custody Government must communicate requirements clearly Explicitly in the contract language Listed on “Serially Managed” items list of GFP Attachment Provision of technical authority and documentation when required Identification of IUID relevant embedded items to be marked during repair activity – in process

Topics Background Policy Process Marking GFP with UID Reporting GFP with UID

Reporting Receipt of GFP Start Is Item IUID’d*? On SM List in GFP Attachment? Yes No No Receipt item by Product ID and Quantity via iRAPT PT Yes Receipt GFP by UII via iRAPT PT or direct to Registry Receipt item by SN via iRAPT PT Notes: *UII (derived from data matrix) is present in the IUID Registry PT = Property Transfer document SM = Serially Managed

Reporting UII of Reparables Is item IUID’d?* Is item identified as SM in GFP Attachment? Yes No No IUID mark upon Receipt? Yes Receipt GFP by UII via IRAPT PT or direct to Registry Receipt item by SN/NSN via iRAPT PT No Receipt item by SN via iRAPT PT Yes Mark item Yes Repair item Repair item Repair item Register UII as GFP direct to Registry only Include UII in RRR via iRAPT Mark item Return item with SN via iRAPT RRR Convert nonUII item to UII (manual) Notes: *UII derived from data matrix is present in the IUID Registry iRAPT requires the UII to be present in the Registry for receipt of UII’d GFP. If the item is assigned a “defined” (virtual) UII, it must be updated to “compliant” when marked before submission of RRR

IUID Registry for GFP Captures planned GFP from GFP Attachment Captures custody history of UII’d items throughout their lifecycle Via iRAPT Property Transfer Via Direct Submit (web, XML, Flat File) Captures non-UII GFP from iRAPT Property Transfer Provides reporting for visibility of GFP in contract/contractor custody IUID and GFP are not the same. All GFP is reported by custodial contractor; some of it MAY have UII

Training, Procedures, Tools For more information GFP and IUID Policy GFP and IUID Training, Procedures, Tools http://www.acq.osd.mil/dpap/pdi/index.html www.dodprocurementtoolbox.com or Contact Carol Vigna at carol.a.vigna.civ@mail.mil or 703-697-4373

Any Questions?