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Is this item considered GFP to be furnished to the contractor, and do the normal rules apply? I have asked several other CO's and some say all the rules apply and some say it is overkill. In this case isn't it more of an installation service, such as if we had cubicles that required assembly? Although we are in a sense supplying items that will necessitate contract completion, we never lose control of it and never leaves government inventory. Thank you in advance for any input.
Answer
DoD Instruction 5000.64 “Accountability and Management of DoD Equipment and Other Accountable Property” defines “administrative property” and “incidental to place of performance” as follows.

“administrative property. A subcategory of personal property, used for grouping property that is operationally distinct from weapon systems and other equipment. Administrative property is typically less than mission critical. Examples include: desktop computers and peripherals, furniture, and office equipment.”

“incidental to place of performance. A property designation defined at FAR Part 45.000(b)(5). Property incidental to place of performance requires the contractor to be at a government place of performance and the property to remain accountable to the government.”

FAR Part 45.000(b)(5) includes examples of items that may be considered incidental to the place of performance. It is not an exhaustive list. Since the task order (service) under the construction contract is being performed on a Government installation and the Government will maintain control and accountability of the air compressor (even after installation) you can to list it in the solicitation/contract as property incidental to the place of performance in lieu of providing it as GFP. If this route is taken, the air compressor will not be covered by the Government Property clause at FAR 52.245-1.

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