Is using the DD1149 a work-around for the IUID Registry, which replaced DD1662 procedures?
It is highly advisable to talk to your Government Contracting Officer about specific contract terms and conditions. They are responsible for providing clarification and interpretation of contract requirements. Since they have access to the contracts, modifications, correspondence, and other information they are more intimately familiar with these requirements. If you are trying to solve a legal issue please contact your legal counsel. The response provided below is an opinion based upon the limited information provided.
The typical meaning of a “work-around” is that it is a plan or method to circumvent a problem without eliminating it. The information that is available does not seem to support the belief that the DD Form 1149 is a “work-around” for the IUID Registry. The DoD UID Policy has been required since 2003 and the DD Form 1149 has been in existence since the early 1950s.
The contractor is required to comply with all the terms and conditions of the contract and this includes any contractual requirement for the DoD Item Unique Identification and Registry. DFARS 211.274-6 instructs the Contracting Officer to use specific contract clauses that must be included in the contract. Here is what is required:
(a)(1) Use the clause at 252.211-7003, Item Identification and Valuation, in solicitations and contracts that require item identification or valuation, or both, in accordance with 211.274-2 and 211.274-3.
(2) Complete paragraph (c)(1)(ii) of the clause with the contract line, subline, or exhibit line item number and description of any item(s) below $5,000 in unit acquisition cost for which DoD unique item identification or a DoD recognized unique identification equivalent is required in accordance with 211.274-2(a)(2) or (3).
(3) Complete paragraph (c)(1)(iii) of the clause with the applicable attachment number, when DoD unique item identification or a DoD recognized unique identification equivalent is required in accordance with 211.274-2(a)(4) for DoD serially managed subassemblies, components, or parts embedded within deliverable items.
(4) Use the clause with its Alternate I if—
(i) An exception in 211.274-2(b) applies; or
(ii) Items are to be delivered to the Government and none of the criteria for placing a unique item identification mark applies.
(b) Use the clause at 252.211-7007 (excerpt provided below), Reporting of Government-Furnished Property, in solicitations and contracts that contain the clause at FAR 52.245-1, Government Property.
The DFARS Clause at 252.21-7007 defines the “IUID Registry” and it specifies the reporting requirements and any required data for Government-furnished property. When the IUID requirements are included in the contract (including IUID Registry requirements) then the contractor is required to comply with them. The information found on DD Form 1149, the IUID Registry, and DD Form 1662 is not the same. Since each one serves a different purpose it is important to read your contract to make sure that you know the requirements that are specified. The contractor must comply with the terms and conditions of the contract.
The Department of Defense amended the Defense Federal Acquisition Regulation Supplement (DFARS) to revise requirements for reporting of Government property in the possession of DoD contractors. It replaced existing DD Form 1662 reporting requirements with requirements for DoD contractors to electronically input the property to the Item Unique Identification (IUID) Registry. The objective is to achieve a more efficient and accurate reporting of Government property in the possession of contractors.
The former DoD Manual for the Performance of Contract Property Administration (DoD 4161.2-M) provided an insight to the uses for the DD Form 1149 (unless otherwise approved by the PA, CO, or contract). These uses include:
a. Return of Government Furnished Property (GFP) except for material obtained through the Military Standard-Requisitioning and Issue Procedures (MILSTRIP) and Real Property. MILSTRIP material may be returned on DD Form 1348-1, as prescribed by DoD Manual 4000.25-1-M. Real Property will be transferred on DD Form 1354.
b. Shipment of Industrial Plant Equipment (IPE) controlled by the Defense Industrial Plant Equipment Center (DIPEC), Memphis, Tenn. (Use DD Form 1149 issued by DIEC.)
c. Internal transfer of Government property accountability from one contract to another, with proper authorization: e.g., contract modification.
d. Shipment of Government Property to other contractors and subcontractors. DD Form 1149 may also be used for shipments to secondary locations of the prime contractor.
252.211-7007 Reporting of Government-Furnished Property.
As prescribed in 211.274-6(b), use the following clause:
REPORTING OF GOVERNMENT-FURNISHED PROPERTY (AUG 2012)
(a) Definitions. As used in this clause—
“Commercial and Government entity (CAGE) code” means—
(i) A code assigned by the Defense Logistics Agency Logistics Information Service to identify a commercial or Government entity; or
(ii) A code assigned by a member of the North Atlantic Treaty Organization that the Defense Logistics Agency Logistics Information Service records and maintains in the CAGE master file. The type of code is known as an “NCAGE code.”
“Contractor-acquired property” has the meaning given in FAR clause 52.245-1. Upon acceptance by the Government, contractor-acquired property becomes Government-furnished property.
“Government-furnished property” has the meaning given in FAR clause 52.245-1.
“Item unique identification (IUID)” means a system of assigning, reporting, and marking DoD property with unique item identifiers that have machine-readable data elements to distinguish an item from all other like and unlike items.
“IUID Registry” means the DoD data repository that receives input from both industry and Government sources and provides storage of, and access to, data that identifies and describes tangible Government personal property. The IUID Registry is—
(i) The authoritative source of Government unit acquisition cost for items with unique item identification (see DFARS 252.211-7003) that were acquired after January 1, 2004;
(ii) The master data source for Government-furnished property; and
(iii) An authoritative source for establishing the acquisition cost of end-item equipment.
“National stock number (NSN)” means a 13-digit stock number used to identify items of supply. It consists of a four-digit Federal Supply Code and a nine-digit National Item Identification Number.
(i) The combination of a Government-assigned type designation and an approved item name;
(ii) Names assigned to kinds and groups of products; or
(iii) Formal designations assigned to products by customer or supplier (such as model number or model type, design differentiation, or specific design series or configuration).
“Part or identifying number (PIN)” means the identifier assigned by the original design activity, or by the controlling nationally recognized standard, that uniquely identifies (relative to that design activity) a specific item.
“Reparable” means an item, typically in unserviceable condition, furnished to the Contractor for maintenance, repair, modification, or overhaul.
“Serially managed item” means 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.
“Supply condition code” means a classification of materiel in terms of readiness for issue and use or to identify action underway to change the status of materiel (see http://www2.dla.mil/j-6/dlmso/elibrary/manuals/dlm/dlm_pubs.asp).
“Unique item identifier (UII)” means a set of data elements permanently marked on an item that is globally unique and unambiguous and never changes, in order to provide traceability of the item throughout its total life cycle. The term includes a concatenated UII or a DoD recognized unique identification equivalent.
“Unit acquisition cost” has the meaning given in FAR clause 52.245-1.
(b) Reporting Government-furnished property to the IUID Registry. Except as provided in paragraph (c) of this clause, the Contractor shall report, in accordance with paragraph (f), Government-furnished property to the IUID Registry as follows:
(1) Up to and including December 31, 2013, report serially managed Government-furnished property with a unit-acquisition cost of $5,000 or greater.
(2) Beginning January 1, 2014, report—
(i) All serially managed Government-furnished property, regardless of unit-acquisition cost; and
(ii) Contractor receipt of non-serially managed items. Unless tracked as an individual item, the Contractor shall report non-serially managed items to the Registry in the same unit of packaging, e.g., original manufacturer’s package, box, or container, as it was received.
(c) Exceptions. Paragraph (b) of this clause does not apply to–
(1) Contractor-acquired property;
(2) Property under any statutory leasing authority;
(3) Property to which the Government has acquired a lien or title solely because of partial, advance, progress, or performance-based payments;
(4) Intellectual property or software;
(5) Real property; or
(6) Property released for work in process.
(d) Data for reporting to the IUID Registry. To permit reporting of Government-furnished property to the IUID Registry, the Contractor’s property management system shall enable the following data elements in addition to those required by paragraph (f)(1)(iii) (A)(1) through (3), (5), (7), (8), and (10) of the Government Property clause of this contract (FAR 52.245-1):
(1) Received/Sent (shipped) date.
(2) Status code.
(3) Accountable Government contract number.
(4) Commercial and Government Entity (CAGE) code on the accountable Government contract.
(5) Mark record.
(i) Bagged or tagged code (for items too small to individually tag or mark).
(ii) Contents (the type of information recorded on the item, e.g., item internal control number).
(iii) Effective date (date the mark is applied).
(iv) Added or removed code/flag.
(v) Marker code (designates which code is used in the marker identifier, e.g., D=CAGE, UN=DUNS, LD=DODAAC).
(vi) Marker identifier, e.g., Contractor’s CAGE code or DUNS number.
(vii) Medium code; how the data is recorded, e.g., barcode, contact memory button.
(viii) Value, e.g., actual text or data string that is recorded in its human-readable form.
(ix) Set (used to group marks when multiple sets exist).
(6) Appropriate supply condition code, required only for reporting of reparables, per Appendix 2 of DoD 4000.25-2-M, Military Standard Transaction Reporting and Accounting Procedures manual (http://www2.dla.mil/j-6/dlmso/elibrary/manuals/dlm/dlm_pubs.asp).
(e) When Government-furnished property is in the possession of subcontractors, Contractors shall ensure that reporting is accomplished using the data elements required in paragraph (d) of this clause.
(f) Procedures for reporting of Government-furnished property. Except as provided in paragraph (c) of this clause, the Contractor shall establish and report to the IUID Registry the information required by FAR clause 52.245-1, paragraphs (e) and (f)(1)(iii), in accordance with the data submission procedures at http://www.acq.osd.mil/dpap/pdi/uid/data_submission_information.html.
(g) Procedures for updating the IUID Registry.
(1) Except as provided in paragraph (g)(2), the Contractor shall update the IUID Registry at https://iuid.logisticsinformationservice.dla.mil/ for changes in status, mark, custody, condition code (for reparables only), or disposition of items that are—
(i) Received by the Contractor;
(ii) Delivered or shipped from the Contractor’s plant, under Government instructions, except when shipment is to a subcontractor or other location of the Contractor;
(iii) Consumed or expended, reasonably and properly, or otherwise accounted for, in the performance of the contract as determined by the Government property administrator, including reasonable inventory adjustments;
(iv) Disposed of; or
(v) Transferred to a follow-on or other contract.
(2) The Contractor need not report to the IUID Registry those transactions reported or to be reported to the following DCMA etools:
(i) Plant Clearance Automated Reutilization and Screening System (PCARSS); or
(ii) Lost, Theft, Damaged or Destroyed (LTDD) system.
(3) The contractor shall update the IUID Registry as transactions occur or as otherwise stated in the Contractor’s property management procedure.
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