Question is, are these assets considered GFP for property records and accountability by the contractor with all issues/receipts recorded by Task Order modification or should they just be tracked and reported under the contractor's Property Management System but managed under the customers accountable property systems of record?
1. When we are talking about Customer Owned Property the person submitting the question was referring to Government Property owned by various units within the Department of Defense.
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2. The Government Activity for this Government property (GP) has an Accountable Property System of Records (APSR), in accordance with DoDI 5000.64 (entitled Accountability and Management of DoD Equipment and Other Accountable Property) to meet DoD Financial and Property Management Controls. In addition, this Government activity is maintaining the accountability of these assets in accordance with AR 735-5 and is using Property Book Unit Supply Enhanced (PBUSE) system.
3. A contractor has been awarded a Contract – to run a warehouse where this GP is turned in by one Government unit for various actions, e.g., repair, storage, and possible future issuance to another Government unit.
4. One of the Contractual requirements contained within this Contract is the Government Property Clause of FAR 52.245-1
So, the question was narrowed down to, “What requirements is the contractor to follow in regard to the GP provided to them in their warehouse operations?”
In regard to the GP furnished to the contractor by these various units -- The contractor is required to comply with the terms and conditions of the contract -- in this case, the Government Property clause of FAR 52.245-1.
The GP Clause requires the contractor to establish and maintain a Property Management System which includes a life cycle approach, acting as stewards of this property. This system requires that a contractor establish processes and outcomes in the areas of receiving, storage, movement, physical inventories, and a number of other outcomes (See FAR 52.245-1(f)) with one of the most critical processes and outcomes being that of RECORDS.
Even though the Government has ITS set of records – the APSR – the contractor, acting as the steward for this GP while in its possession, is required to establish its own set of records – meeting the data requirements of FAR 52.245-1(f)(1)(iii).
Now, a couple of technical issues –
1. The FAR and the DFARS (And supporting PGIs) all require that GFP be listed in the Contract. As such it would be wise to review the contract to ensure that this requirement, a requirement on the Government, is being properly complied with. FAR 45.201 and the equivalent DFARS spell this out in very detailed fashion.
2. Even though the GP is in the contractor’s possession, the Government must still maintain ITS FIDUCIARY records. The contractor maintains STEWARSHIP RECORDS.
I hope that after our discussion and the above framework of the problem this assists you with the proper application of the Government’s policy, requirements and clauses.