Is the contractor relieved of stewardship responsibility and liability per 52.245-1(f)(vii)(C)(1) at the point of issuance from the system or when the a/c is dd250 with our piece of GFM attached? The problem is that when the contractor returns the Government Furnished Material (aircraft part) back to the property management system via a "return to inventory" posting transaction, they are not reactivating the original Government property record, or reversing the consumption transaction. The contractor is creating a brand new record because the system does not have the capability to retrace its steps and find the actual part that was issued due to the part not being serialized (this is not a problem for records that have serial numbers). I need to be clear that this is not MMAS inventory, it's GFP inventory. If one of these "return to inventory" parts is selected for a PMSA, the contractor cannot show anything regarding its original receipt/information. Additionally, the property system reflects that the part was "consumed", that consumption transaction is not reversed. Thus, the part is subject to being selected for a Consumption PMSA even though it is sitting in stock on the shelf with a different activated record. Another concern is that the acquisition value of the part changes since research isn't performed (or it isn't possible) to locate the original data on the original record. The counter argument is that the part was consumed per the property management system and manufacturing planning (52.245-1(f)(vii)(C)(1)), so therefore relief of stewardship is granted (even though the part was only virtually consumed and not actually consumed). The return to inventory is treated as a brand new receipt into the property management system at which point the original Receiving and Records information is lost. What we are left with is a part whose acquisition value changed from the original documents and record, and a part in stock that has two records, one showing it was consumed and one showing it as active (though as stated previously, these two records can't be linked). Is this a compliant property management system? Must issued parts (unserialized Government furnished aircraft parts) be returned back to the property management system maintaining the original Records and Receiving information? It would seem to me that this is a broken audit trail for a piece of Government property.
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FAR 52.245-1(b)(2) states that the Contractor is responsible for Government property until formally relieved of responsibility by authorized means. Consumption and expending are amongst the authorized means identified. Based on the information provided, unless otherwise stated in the contract, the Contractor would not be relieved of stewardship responsibility at the point of issuance from the system. Presuming consumption is proper and reasonable, relief of responsibility would occur when the item is attached to the aircraft. The Contractor’s records should reflect the Government-furnished material (GFM) as issued. If the GFM is removed and returned to inventory, it should still be reflected as such in the Contractor’s property management system records since the Government retains title to all Government-furnished property (GFP). The Contractor’s records of Government property must enable a complete, current, auditable record of all transactions as required by FAR 52.245-1(f)(1)(iii). That means original records and receiving transactions are to be maintained. Records should reflect a complete transaction history for every item of Government property. With regard to the unit acquisition cost, it is the Government’s responsibility to assign the dollar value and identify it in the contract. GFP should be identified using a GFP attachment in accordance with DFARS Procedures, Guidance and Information (PGI) 245.103-72. The Contractor should not arbitrarily change the unit acquisition cost of GFP. Concerning the status of the Contractor’s property management system, for the Department of Defense, it is the responsibility of the Contracting Officer to make the determination about the acceptability of the Contractor’s property management system. Based on the information provided it does appear that at least one of the Contractor’s processes may be non-compliant. However, that is for the Property Administrator to decide as a part of the PMSA, which includes, but is not limited to, evaluating written property management procedures as well as conducting quantitative and qualitative analysis of each process audited.