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    At what point do we update and close our record showing that the Government property is no longer accountable to us? We do not have privity for the gaining contract but FAR 45.106 requires both the losing and gaining modification prior to changing contract accountability.


    If your contract is administered by the Defense Contract Management Agency, the contract modification may include the following language; “The purpose of this modification is to transfer accountability of the contract property items listed on the attachment -- from this contract to contract XXXXXXXXXXXXX.” Presuming the contracting officer (CO) for the losing contract secured concurrence from the CO for the gaining contract to transfer the property, your organization needs to comply with the contract modification that was received. Your organization would not see the gaining contract modification since it is not the prime contractor and as you stated, does not have privity of contract.
    As the prime contractor, your organization has stewardship responsibility of the Government owned tooling until all necessary actions are complete (e.g., shipping, updating the Invoice, Receiving, and Property Transfer (IRAPT) module within Wide Area Workflow (WAWF)). (Note: Property transfer entries will be processed using the Government Furnished Property Module within WAWF approximately mid-July 2018 per Defense Procurement Acquisition Policy. See for details.) The record should be closed out in your property management system after all actions are complete and documented in the appropriate systems. Your organization should have a process established to accomplish this within its written property management procedures. It is suggested that someone in your organization seek clarification from the Contracting Officer and the assigned Property Administrator if needed.

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