Can Air force Property Administrators issue a CAR? Is there any regulatory guidance that forbids us from administering a CAR for this real time event and not associated with an Audit or PMSA. Is there regulatory guidance that says we can? I can't just look the other way. This appears to be Systemic problem -- I need to request a Systemic fix!
You have asked a great question and made an excellent point. Noncompliances discovered outside of a property management system analysis (PMSA) should certainly be addressed. There is nothing in the Federal Acquisition Regulation (FAR) or the Department of Defense Federal Acquisition Regulation Supplement (DFARS) that addresses the issuance of corrective action requests (CAR) for noncompliances discovered outside of a PMSA.
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To my knowledge, the issuance of a corrective action request (CAR) under such circumstances is not addressed in any regulation. However, issuing a CAR for a noncompliance outside of a PMSA is not unheard of and is quite prudent in my opinion. The Defense Contract Management Agency (DCMA) has Contract Property Management Instruction 124 which authorizes DCMA property administrators to issue CARs for contractual noncompliances during and outside of PMSAs. Maybe your agency has a similar policy.