There are several questions. First do you, or do you know of an organization which may have process map denoting the point(s) when to ensure that contraual wording can be drafted and proposed to ensure that the contractor complies with AR requirements?
Second, has there been an organization which has been able to require a contractor to use a governments APSR to document GE less than $5 thousand dollars? And was this done with minimal cost to the contract when considering that the number of items are in the low thousands? Third, is it generally cost effective to document GE in an APSR for items less than $5K? Excluding critical and pilferable items which fall into this category and are already on an APSR?
Lets begin with the definition of APSR (Accountable Property Systems of Record):
An Accountable Property System of Record (APSR) is defined in detail as: the business system/application used to account for and maintain accountability of government property. This system/application represents the authoritative official records for the government entity regarding the property it is responsible for and reflects the appropriate updates to the property as a result of life cycle transactions. To ensure data integrity, there must be one – and only one – system of record for a given piece of property. The APSR is a subsidiary ledger to the financial systems general ledger and represents the transactions impacting the property.
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To be considered an APSR, the system must be able to perform several property management and financial functions. APSR and help an organization maintain an auditable record of life cycle events. Property managers need to remain informed of when to create, or not to create, an accountable record. For example, an accountable record is not created for contractor acquired property until the government takes full ownership of those assets by formal acceptance and delivery.
Another important aspect of APSRs and accountable property records are the data elements required to make a comprehensive record. These requirements are outlined in DoDI 5000.64 and include the:
P&EP has developed a checklist (http://www.acq.osd.mil/pepolicy/pdfs/APSRchecklist.pdf) to be used in identifying whether your system may be an APSR for equipment. There is also APSR information in the FAQ section of our site. At the left is a link to DPAS, a system that a property manager may use for accountability management purposes.
(1) First do you, or do you know of an organization which may have process map denoting the point(s) when to ensure that contractual wording can be drafted and proposed to ensure that the contractor complies with AR requirements?
- Unaware of an organization having a process map…
- Accounting for government property while used on contract is challenging. Recent reports issued by the Inspector General indicate there is room for improvement. Property and Equipment Policy (P&EP) has identified GFP as a focus initiative for FY 2011 and kicked off projects designed to improve accountability and controls over GFP. Specifically, is:
- Name of the asset
- Unique Item Identifier (UII)
- Stock number
- Acquisition cost or full cost value
- Other essential elements.
o P&EP participating in the DPAP Office’s GFP Business Environment CONOPS Working Group which was formally organized in February 2010. The working group was tasked to provide a CONOPS for the DoD GFP Business Environment targeted for implementation in FY 2011 and beyond. This working group addressed the fact that the DoD enterprise does not have the requisite integrated, interoperable net-centric and electronic data driven capabilities needed to effectively and efficiently manage its personal property used on contracts.
o P&EP was to create process flows for GFE. Using the relevant guidance provided by FAR 45, FAR 52.245-1, DFARS 245 PGI and DoD Instruction 5000.64, P&EP created flow charts to illustrate the process of creating and accounting for GP on contract. These flow charts illustrate prescribed process as articulated in the appropriate regulation/guidance serving as the foundation for accountability. The intent is to use these process flows to document functional requirements which must be addressed in each Component’s Enterprise Resource Planning (ERP) application. As new requirements are identified and process improvements are implemented, these flowcharts will be updated to reflect the desired operating environment.
o Additional resources for GFP management may be found at DoD Procurement Toolbox which is sponsored by DPAP Program Development and Implementation.
- Include requirements to which you require the contractor to perform in your requirements document. Requirements Definition is Step Four of the Service Acquisition process. It is the most important and perhaps the hardest step because it captures all aspects of the requirement you want to put on the contract. In this phase you will need to complete your risk analysis, Independent Government Cost Estimate (IGE), and requirements document. See www.sam.dau.mil (Service Acquisition Mall – 7 Step Service Acquisition Process).
- See Reference: OUSD Memo dated Jan 07, 2012; SUBJECT: Standard Equipment Data Elements for Government Furnished Property Baseline Establishment
http://www.acq.osd.mil/pepolicy/pdfs/USA006862-11 Standard Equipment Data Elements for Government Furnished Property Baseline Est .pdf
(2) Second, has there been an organization which has been able to require a contractor to use a governments APSR to document GE less than $5 thousand dollars? And was this done with minimal cost to the contract when considering that the number of items are in the low thousands?
- Unaware of an organization which has been able to require a contractor to use a governments APSR…
- DODI 5000.64 requires “accountable property records to be established in an APSR for all Government property purchased, or otherwise obtained, having a unit acquisition cost of $5,000 or more property of any value that is controlled or managed at the item level; leased items (capital leases) of any value; and assets that are sensitive or classified (see Table 61 of Volume 10 of DoD 4100.39-M (Reference (m)).
- Should you determine “asset management” to be accomplished by the contractor, how do you justify funding for a requirement that is not required per the DODI 5000.64. Estimate of the cost involved will depend on the effort you desire of the contractor.
(3) Third, is it generally cost effective to document GE in an APSR for items less than $5K? Excluding critical and pilferable items which fall into this category and are already on an APSR?
- Generally it is not cost effective to account for “assets” that do not require property accountability, The only exception to this would be those items that are controlled or managed as the item level (i.e. critical and pilferable items), leased items (capital leases) of any value and assets that are sensitive or classified.