I would like to know if the Common Access Card (CAC) is considered Government Furnished Property? If so, is there a FAR or DFARS reference or other DoD policy on how CAC's should be handled by our contractors? Specifically, if a CAC has been issued to a contractor and that contractor leaves his/her position, how much time does the prime have to return that card to the government?
There is no guidance in the FAR or DFARS relating to contractor return of CAC cards. There is one deviation, CD 2013-O0017, for the demobilization of personnel in Afghanistan that states:
" The Contractor shall ensure that all employees, including all subcontractor
employees at all tiers, return installation and/or access badges to the local Access
Control Badging Office for de-activation and destruction according to the approved
demobilization plan. The Contractor shall submit a Badge Termination Report to
ensure each record is flagged and the badge is revoked. If an employee's badge is
not returned, the Contractor shall submit a Lost, Stolen or Unrecovered Badgeheeport to the appropriate Access Control Badging Office. Contractor employees in
possession of a Common Access Card (CAC) shall be responsible for turning in the
CAC upon re-deployment through a CONUS Replacement Center in the United
States. Failure to comply with these requirements may result in delay of final
I would recommend putting a local clause in all soliciations and contracts stating within a certain time period (i.e. 72 hours) after a contractor leaves, their Common Access Card must be returned to the government. Creating a consequence such as delaying payment should ensure compliance.