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  • Question

    The question concerns whether an operating contractor on a GOCO installation can restrict access to authorized government employees from a government operating system due to the contractor adding properiety information on the government system, which they entered this information at their own risk since the system is government owned and furnished.


    Answer

    Clarification was received that this question isn't about the IT aspects of access, rather to ascertain that the Government is required to evaluate the contractor's property system, and to oversee corrective actions when appropriate. Subject to any specific directions provided in the contract, the contractor is obligated by FAR 52.245-1 to provide access to the data that is pertinent to ascertain the efficacy of the Contractor's property management system, to ensure that there are no undue risks to the Government. Related references follow. You may also refer to the list of Life Cycle Tasks found in the Toolkit in the ACC Community of Practice for Industrial Property. 
     
    45.105  Contractors’ property management system compliance.
     
    (a) The agency responsible for contract administration shall conduct an analysis of the contractor’s property management policies, procedures, practices, and systems. This analysis shall be accomplished as frequently as conditions warrant, in accordance with agency procedures.
     
    REF 52.245-1(f)(1)(iii) Records of Government Property (A)(1) through (5) requires records for all Government property, and (g) Systems analysis (1) through (4) provides for access to evaluate contractor performance:
       
    (1) The Government shall have access to the contractor’s premises and all Government property, at reasonable times, for the purposes of reviewing, inspecting and evaluating the Contractor’s property management plan, systems, procedures, records, and supporting documentation that pertains to Government property.
       
    (2) Records of Government property shall be readily available to authorized Government personnel and shall be safeguarded from tampering or destruction.
       
    (3) Should it be determined by the Government that the Contractor’s property management practices are inadequate or not acceptable for the effective management and/or control of Government property under this contract, and/or present an undue risk to the Government, the Contractor shall immediately take all necessary corrective actions as directed by the Property Administrator.
       
    (4) The Contractor shall ensure Government access to subcontractor premises, and all Government property located at subcontractor premises, for the purposes of reviewing, inspecting and evaluating the subcontractor’s property management plan, systems, procedures, records, and supporting documentation that pertains to Government property.  

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