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  • Question

    Should a contract have specific language that addresses requirements for property accountability by the contractor? Should a government or contractor property administrator be required and appointed? When would it be the COR responsibility to be accountable for equipment?


    Answer

    Thank you for your submission to the AAP. All three questions are answered below. In the future, please try to submit one question at a time to make answers more searchable by topic to the community. Good questions!

    Concisely-

    Contractor property management requirements are addressed in the FAR clause 52.245-1.  Additional instructions/requirements not addressed in 52.245-1 should be spelled out in the statement of work or in a special provision [Reference FAR 45.201 (d)].
    COR designations are addressed at DFARS 252.201-7000, COR responsibilities do not typically involve property accountability; such responsibility most often goes to the Accountable Property Officer
    To elaborate-
    1) Contract Specifications - The contract protects the Government’s interests regarding property accountability with adequately specific language. For example, if property provided under FAR 52.245-1 should be returned when contract performance is complete, the contract directs how to transfer the property back; without specific direction, FAR 52.245-1 (j) provides generic guidance to account for property disposition. Another example of specific language is authorization for non-interference use (Ref 52.245-9).
    2) Government & Contractor Property Administrators – The KO has primary responsibility for the property duties listed in FAR 42.3. The KO can delegate those tasks in accordance with FAR 42.2. Also, the Contractor’s managerial personnel, or an employee who is delegated those duties, must be capable of property management for the contractor to be considered responsible according to FAR 9.104-1(e).
    3) Responsibility for the Property Account - Though the COR may be delegated oversight of contract performance, the KO is responsible for the Accountable Property System of Record (APSR). The APSR account often extends beyond the Contractor’s stewardship account that is closed at the end of the contract. Only the KO can authorize the use of Government property by a contract or modification. The KO may delegate oversight of property management to a COR; however, adequate training is needed.  The certificate of appointment for a Property Administrator (PA) provides signature authority to relieve a contractor of liability for property loss, among other duties (Ref: FAR 45.105); the certificate of appointment for a Plant Clearance Officer (PLCO) provides signature authority to direct disposition (Ref: FAR 45.6) and other duties.  PAs and PLCOs (1103 Series) are not usually a COR.

    The tasks of the PA and PLCO are identified in the life-cycle chart for contract property found in the Government Property Community of Practice (CoP) Toolkit.
    You are welcome to visit the CoP at https://acc.dau.mil/gpg and to suggest how the toolkit can work better for you. If assistance is needed to access the Property CoP, or if this answer doesn’t fully respond to your questions, please contact govproperty@DAU.mil

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