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  • Question

    Do I use the new contract number or the old one?


    Answer

    Sorry but it’s a little more complicated than that…
     
    1st – You are specifically PROHIBITED from using the DD form 1149 by DFARS PGI 245.103-71- Transferring Government property accountability (see immediately below):
     
    (1) Use only the Standard Form 30 to execute transfers of Government property accountability between existing contracts.  No other forms or documents, such as the DD Form 1149, Requisition and Invoice/Shipping Document, are authorized for the transfer of Government property accountability from one contract to another.
    (2) Modifications for the transfer of Government property accountability shall:
    (i) Use the fillable PDF formats prescribed at PGI 245.103-72.
    (ii) Incorporate FAR clauses 52.245-1, Government Property, and 52.245-9, Use and Charges, and the associated DFARS clauses (see 245.107, Contract clauses) to the extent that the gaining contract lacks the required clauses.
     
    That said, there is still more you must do…
     
    2nd – Simply because GFP may be useful on another contract does not fulfill the justification requirements of FAR 45.102.  Please reference the FAR policy guidelines at 45.102 which state the following: 
     
    45.102 -- Policy.
    (a) Contractors are ordinarily required to furnish all property necessary to perform Government contracts.
    (b) Contracting officers shall provide property to contractors only when it is clearly demonstrated
    (1) To be in the Government’s best interest;
    (2) That the overall benefit to the acquisition significantly outweighs the increased cost of administration, including ultimate property disposal;
    (3) That providing the property does not substantially increase the Government’s assumption of risk; and
    (4) That Government requirements cannot otherwise be met.
     
    PGI 245.103-70 Furnishing Government property to contractors provides specifics regarding roles and documentation requirements first noting that:
     
    The basis for any decision to provide Government property shall be documented by the requiring activity and provided to the contracting officer
     
    It then provides specific direction to the contracting officer compelling them to ensure that each of the four FAR 45.102(b) requirements of are addressed and documented in the contracting file.
     
    Following these regulatory requirements will help assure proper accountability and control of Government property.
     
     
    Additional References:
    AAP - https://dap.dau.mil/aap/pages/qdetails.aspx?cgiSubjectAreaID=5&cgiQuestionID=125139
     

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