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  • Question

    Per 52.245-1 (f)(iv), is disclosing physical inventory of GFP, to the Government, a required deliverable? Even if, the contract does not have a CDRL DD-1423 referencing a DID for the deliverable? The clause does reference the record floormat in (f)(iii) Records of Government Property.


    Answer

    The following response is based solely on the question and background information provided. As we do not have the entire facts particular to your contractor, program, and situation, we suggest you discuss with your contracting team, program manager, legal department, and/or contractor, as appropriate.

    Each DoD acquisition team will determine what is a required deliverable and the use of the DD Form 1423 or a general deliverable before the solicitation is issued/released. If your agency procedures do not dictate that this be a required deliverable, then the answer to your question is no. But the contractor must comply with the following:

    52.245-1 Government Property clause (GPC).

    First, FAR 52.245-1( f)(1)(iii) only lists the minimum fields of a compliant Government property stewardship record maintained by the contractor. The minimum fields may not sufficiently correlate with a physical inventory (PI) count sheet or report, but is not “how to” report a PI.

    Next, FAR 52.245-1(f)(1)(iv) has a PI “disclosure” component to it which is further captured in FAR 52.245-1(f)(1)(vi) Reports (The Contractor shall have a process to create and provide physical inventory results). Again, these are requirements to perform PIs and report the results – NOT how/when/when/who performs these.

    The specifics of how and when the PI will be performed (e.g. annual wall-to-wall) and how the results will be disclosed to the Government will be in the contractor’s Property Management System (PMS) procedures, which are required by FAR 52.245-1(b)(1) and FAR 52.245-1(f)(1):

    (b) Property management. (1) The Contractor shall have a system of internal controls to manage (control, use, preserve, protect, repair, and maintain) Government property in its possession. The system shall be adequate to satisfy the requirements of this clause. In doing so, the Contractor shall initiate and maintain the processes, systems, procedures, records, and methodologies necessary for effective and efficient control of Government property…

    (f) Contractor plans and systems. (1) Contractors shall establish and implement property management plans, systems, and procedures at the contract, program, site or entity level to enable the following outcomes.

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