Operating Status
FULLY OPERATIONAL
OPERATING STATUS
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.
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