PCARSS: Transfers of Accountability Bradley Hill Asset Management Lockheed Martin MST Bradley.r.hill@lmco.com 407-306-1397

What is PCARSS? Plant Clearance Automated Reutilization Screening System (PCARSS) Part of DCMA’s eTools suite It automates the process for reporting, screening, requisitioning, and dispositioning excess government property located at contractor facilities. PCARSS is not used by DoD Components/Military Services for personal property disposal

Why do we use it? FAR 52.245-1(j)(2)(i): “Absent separate terms and conditions for property disposition…the contractor…shall use SF 1428, Inventory Disposal Schedule (or electronic equivalent), to identify and report…” PCARSS is simply the SF 1428 electronic equivalent Operationalized under DFARS clause 252.245-7004 252.245-7004(b):  “Inventory disposal schedules.  Unless disposition instructions are otherwise included in this contract, the Contractor shall complete SF 1428, Inventory Schedule B, within the Plant Clearance Automated Reutilization Screening System (PCARSS).”

When do we use it? When Government property is no longer required on a contract, the FAR clause at 52.245-1 requires contractors to: Report property to the plant clearance officer for disposition (DCMA’s etool PCARSS is used for this purpose) or Notify the Contracting Officer that property can be used on another contract In general, these requirements involve two (2) processes: PCARSS reporting: standardized, automated, consistent, well-established Notification/request for property transfer of accountability: ad-hoc, manual, inconsistent The new process (PCARSS 3.2) collapses everything into one standard automated process

Transfers of Accountability All Government contract property (whether Government furnished or contractor acquired) must be contractually accountable to a contract – and only one contract at a time Government property can only be transferred from one contract to another when firm requirements exist under the new, follow-on or gaining contract. See PGI 245.103-71 Transfers of contractual accountability must be accomplished by contract modification of both gaining and losing contracts; contract modifications shall use the fillable PDF formats prescribed in the “smart” attachments found at PGI 245.103-72 The cognizant DCMA contracting officer may execute contract modifications, in coordination with the cognizant procuring contracting officer(s)

FAR 45.106 Transferring accountability. “Government property shall be transferred from one contract to another only when firm requirements exist under the gaining contract.” “Such transfers shall be documented by modifications to both gaining and losing contracts. Once transferred, all property shall be considered Government-furnished property to the gaining contract.”

OSD Memo

Smart Attachments http://www.acq.osd.mil/dpap/pdi/pc/docs/RequisitionedGovernmentFurnishedProperty-VERSION1.3_distributed_0005.pdf http://www.acq.osd.mil/dpap/pdi/pc/docs/ScheduledGovernmentFurnishedProperty-VERSION1.4_distributed_.pdf

PCARSS 3.2!!! Implemented May 6, 2013 Under PCARSS 3.2, contractors can identify property requiring transfer and report it in the same manner as other excess property PCARSS will convert the property data from the Inventory Schedule into the DoD prescribed standard “Smart” attachment Benefits include: Smart Attachment generated by PCARSS Standardizes the transfer process and templates Provides additional guidance to COs enhancing compliance to FAR 45.201

Process Flow

Getting Started Reporting property to PCARSS does not constitute a contractor request for transfer of accountability – contractors must still make a formal request (outside of PCARSS) The reasoning behind this is in most cases, contractor personnel who work PCARSS are not in a position (i.e., do not have the authority) to request a  contractual transfer of accountability   Ensures that the contractual transfer of accountability has been properly internally vetted by the contractor Once the formal request outside of PCARSS has been submitted to the contracting officer, the contractor can immediately proceed with making the request in PCARSS; a response is not required

Getting Started (cont.) Click Yes on the transfer radio button Enter the gaining contract number in the transfer contract number field All other steps are identical to a normal Inventory Schedule including the submittal Notes: The gaining and losing contracts must be administered by DCMA, otherwise you will receive an error message!

TIPS Set a discriminator to identify transfer request versus schedules submitted for disposition You can still do flat file uploads!

What’s Next? When a transfer request is submitted, it automatically assigns a case number and the status goes to Disposition – Action complete

What’s Next? (cont.) The PLCO does not accept or assign a case number; everything is assigned automatically The submit and disposition date are the same since these actions occur immediately

What does the CO and PLCO receive? Here is a sample email sent from eTools to the COs and PLCO

What do the COs and PLCO receive (cont.)? Attached to the email in the prior slide will be a system generated Smart Attachment similar to this for both the gaining and losing contracts The email will not include any other attachments (e.g. Inventory Schedules)

What do they do with it? The PLCO is not involved like a normal Inventory Schedule (e.g. accepting a schedule, establishing a case, issuing disposition instructions, etc.) The CO can approve or disapprove the transfer If approved, the CO can create the contract modification through the Modifications and Delivery Orders eTool—using the smart attachment as a part of (“attached to”) the contract modification. The contract modification is then distributed like any other contract modification, e.g., through EDA, etc. The Contracting Officer should notify the PLCO after processing the contract modification; there is no interface between PCARSS and MDO Once approved, the PLCO should file the contract modification in the case file and close the case

If the request is disapproved….. Current process is all or nothing hence the importance of being vetted internally by the contractor The CO will need to manually notify the PLCO of the denied request The PLCO will withdraw the case and annotate in the comments block to reflect the contracting officer's denial of the transfer request The property does not continue processing in PCARSS; once a case is established PCARSS does not allow the input of a screener rule The contractor will need to resubmit the Inventory Schedule; the excess property is disposed of like any other excess property

Indefinite Delivery Contract (IDC) Individual orders are not considered individual contracts Cannot have property accountable to them Do not require individual property assignment or closeout in MOCAS

Future Enhancements Expand to contracts/contractors not administered by DCMA Expand capacity of maximum number of line items in PCARSS Automatically notify the PLCO after processing the contract modification Property Loss eTool – Modify to permit use of “Smart” attachment for property loss reporting (already in process)

There's more to Asset Management than -1 FAR (Federal Acquisition Regulation) 45.102, Policy 45.103, General 45.106, Transferring Accountability 45.201, Solicitation 52.245-1, Government Property DFARS (Defense Federal Acquisition Regulation Supplement) 252.211-7007, Reporting Government-Furnished Property 252.245-7004, Reporting, Reutilization, and Disposal PGI (Procedures, Guidance, and Information) 245.103-70, Furnishing Government property to contractors 245.103-71, Transferring Government property accountability 245.103-72, Government-furnished property attachments to solicitations and awards 245.103-73, Contracting office responsibilities http://www.acq.osd.mil/dpap/pdi/gfp/index.html

Questions?

Sources Tom Ruckdaschel, DCMA, PCARSS 3.2. Expediting Contractual Transfers of Contract Property Accountability Tom Ruckdaschel, DCMA, “Brown Bag” – Understanding and Standardizing Contractual Transfers of Government Property (PCARSS 3.2) PCARSS 3.2 Frequently Asked Questions DCMA Website, PCARSS, http://www.dcma.mil/ITCSO/cbt/PCARSS/index.cfm FAR, DFAR, and PGIs found on slide 22