What is the definition of Capital Type Rehabilitation?
None of the typical acquisition related (FAR, DFARS, etc.) publications, nor DoD regulations/guidance defines the term.
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Here are a couple of options and their sources:
· Retired DoD Property Manual – “Work that is clearly above and beyond recurring maintenance, such as major repairs, replacement and rehabilitation of deteriorated property.”
· Education brief by Mr Ed Hoenig, 18 May 2011 – “Definition of Capital Rehabilitation - assets that have worn out due to reasonable constant use and require major overhaul for continued use.”
Perhaps a good way to define “capital type rehabilitation” is to understand what it IS NOT and frame it against a definition of capital type rehabilitation.
Immediately below, I’ve provided you an excerpt from a DCMA published white paper* on the outcome/objective of MAINTENANCE, referenced with permission:
· Preventive Maintenance, FAR 52.245-1(f)(1)(ix). The maintenance program should include regularly scheduled inspections, calibration and maintenance performed to sustain suitability for intended use and to detect and correct minor deficiencies before they result in damage to property. Preventive maintenance includes lubrication, servicing, inspection, normal parts replacement to forestall excessive wear, malfunction, or deterioration of production or non-production facilities to ensure effective use for their designated purpose.
The program should also identify any special maintenance requirements; procedures and/or instructions should insure that the Government property’s maintenance is performed in a timely manner and that all actions are recorded. Work orders and/or instructions for preventative maintenance should assign responsibility and include a checklist identifying all maintenance performed.
When performed by equipment operators, preventive maintenance procedures shall identify tasks, checklists, frequencies, recording requirements, and provide for reporting deficiencies when corrective maintenance is required. These procedures and instructions may be based on manufacturer’s recommendations; Government instructions or technical manuals/publications, plant experience (peculiar operating conditions); engineering analysis (age and condition), tolerance requirements, safety considerations, Voluntary Consensus Standards, customary commercial practices and Industry leading practices.
· Corrective Maintenance. The maintenance program should provide for corrective actions and repair. This includes the disclosure and/or reporting of deficiencies by operational personnel; disclosure of deficiencies through preventive maintenance and/or inspections; initiating work orders with detailed assignment, guidance, and responsibilities; and recording work accomplished.
· Capital Type Rehabilitation (CTR). CTR is work that is substantially outside of normal maintenance obligations. Contractors are required by FAR 52.245-1 to disclose CTR need to the Contracting Officer (CO). Generally, notification is required when routine and preventative maintenance and repair is not sufficient to sustain a property item’s suitability for intended use the contractor should notify the CO promptly, and request direction regarding repair or replacement or other actions directed by the Government.
One last source for you to check! That is your Property Management System (PMS). Since your PMS already talks to the various types of maintenance required under the Government Property clause (FAR 52.245-1), you want to insure that your definition of capital type rehabilitation is properly framed so that it does not conflict or overlap the other types of maintenance covered by your PMS program. In addition, you’d be wise to run this past your resident Government Property Administrator (PA) for their thoughts as well.
*This and white papers on other outcomes/objectives are posted to the DCMA website but are not easily accessible