Where can I find 'written' validation of the continued requirement of an Annual Report to be submitted and the timeframe of submittal. I know to accomplish, but need explicit verbiage to provide to non-Property knowledgeable personnel?
Let me first start off with clarifying “Annual Report of Property” so all readers can go forward with the same understanding to the subject of the question. Since you have referred to the well-known DD Form 1662 I am going to take the liberty of assuming that what you’re referring to as the “Annual Report of Property” is what the FAR now terms as the “report of physical inventory results”, per FAR 52.245-1 (f)(1)(vi) Reports. The U.S. Government does not mandate a specific timeframe for physical inventory reports; however, this does not mean that contractors are not required. The Government allows contractors the flexibility of determining the physical inventory cycles and expects the contractor to document the specific timeframes to include the reporting of those results, for consistency and reliability.
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You are correct the old DD Form 1662 was a requirement in the old version of the FAR Government Property Clauses; however, this is no longer the case and in fact should not be used unless the requirement is still embedded within the language of the contract. For instance some program offices still include the requirement of reporting DD Form 1662 as often as quarterly in some situations. I would check your contract language as well as the statement of work for each contract to see if the requirement is there.
A few things to also consider:
Now just because the FAR and the contract do not require the annual report you will need to see if your company’s internal Property Management System (Procedure(s)) require you to provide an annual report to your Government customers. There have been many situations where contractors unnecessarily impose old requirements on themselves simply because they have not updated their procedures to current requirements.
Financial Improvement Audit Reediness (FIAR) is having some huge influence on contractor reporting so if your company is looking eliminate/change an inventory reporting practice I would highly recommend speaking with your customers, finding out what their needs are and coming up with a more innovative way of reporting your inventory results that meets both your needs.