Is this proper procedures for handling government property and for managing equipment under a service contract? Is the contractor required to fill out a DD1149 each time they check out equipment? If both contractor and government use the same equipment for tasking, is this considered comingling of tasking?
This question did not include any information regarding contract or internal military requirements regarding the use and handling of the Government Property in Question. It is important to read the requirements that are specified in the contract where the Government Property is accountable because that information is essential in providing an accurate response to this question.
It sounds like the property is "Contract Government Property" or, that property that is provided under a Government Contract. If it is, then, the Government Property Clause at FAR 522.45-1 is most likely included in the contract. This clause requires the contractor to have a Property Management System: "
Is the contractor required to fill out a DD1149 each time they check out equipment? In order to find out refer to the contract to see if it is a contract requirement. Also, if the contractor has included this as a requirement in their Property Management System then it would be mandatory.
If both contractor and government use the same equipment for tasking, is this considered comingling of tasking? According to the Merriam-Webster Dictionary commingling means: "1. to blend thoroughly into a harmonious whole
2. to combine (funds or properties) into a common fund or stock." It is not apparent what your organization’s intent is for the tasking mentioned. That is something that you would have to clarify by talking to your cognizant Contracting Officer. It is also possible that this may be specified in the contract or other written agreement so please check those sources.
(1) The Contractor shall have a system of internal controls to manage (control, use, preserve, protect, repair and maintain) Government property in its possession. The system shall be adequate to satisfy the requirements of this clause…" Paragraph (f) of this clause "
Contractor plans and systems" states the following:
- Contractors shall establish and implement property management plans, systems, and procedures at the contract, program, site or entity level to enable the following outcomes:
These "outcomes" include: Acquisition, Receipt, Records, Physical Inventory, Subcontract control, Reports, Relief of stewardship responsibility and liability, Utilizing Government property, Maintenance, and Property closeout.
FAR 52.245-1 restricts the use of the Government Property that is accountable to a contract to that contract unless the contract specifies otherwise OR if it is approved (in writing) by the Contracting Officer.