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Started: 6/5/2018 9:24 AM
Picture Placeholder: KARREN CARRUTHERS
KARREN CARRUTHERS
Items requiring installation, are they GFP? (AAP)

​I am going to solicit a Task Order on our MACC and in this project a small part of it is an Air Compressor that was purchased via GPC many years ago that requires installation.  No titles will be transferred and this item will never leave the facility in which it is currently stored.  Is this item considered GFP to be furnished to the contractor, and do the normal rules apply?  I have asked several other CO's and some say all the rules apply and some say it is overkill.  In this case isn't it more of an installation service, such as if we had cubicles that required assembly?  Although we are in a sense supplying items that will necessitate contract completion, we never lose control of it and never leaves government inventory.

 

 We highly encourage comments, examples, feedback and continued discussion.

Picture Placeholder: KARREN CARRUTHERS
  • KARREN CARRUTHERS
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KARREN CARRUTHERS

​I am going to solicit a Task Order on our MACC and in this project a small part of it is an Air Compressor that was purchased via GPC many years ago that requires installation.  No titles will be transferred and this item will never leave the facility in which it is currently stored.  Is this item considered GFP to be furnished to the contractor, and do the normal rules apply?  I have asked several other CO's and some say all the rules apply and some say it is overkill.  In this case isn't it more of an installation service, such as if we had cubicles that required assembly?  Although we are in a sense supplying items that will necessitate contract completion, we never lose control of it and never leaves government inventory.

 

 We highly encourage comments, examples, feedback and continued discussion.

16/5/2018 9:24 AM6/5/2018 9:24 AMNoAsk the Community
27.3217848191508
4/27/2018 11:17 AM
Posted: 6/27/2018 4:04 PM
Picture: DONALD MANSFIELD
DONALD MANSFIELD

If by "normal rules" you mean FAR part 45/DFARS part 245, then they wouldn't apply based on what you have written. These rules apply when the contractor will be the custodian of the Government property. In that case, they would have to keep records of it, include it in its inventory, report it, etc. What you describe is similar to the provision of Government property for repair, maintenance, overhaul, or modification (see FAR 45.102(d)). They are not using the property to perform the contract, the property is the object of performance.

Picture: DONALD MANSFIELD
  • DONALD MANSFIELD
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DONALD MANSFIELD

If by "normal rules" you mean FAR part 45/DFARS part 245, then they wouldn't apply based on what you have written. These rules apply when the contractor will be the custodian of the Government property. In that case, they would have to keep records of it, include it in its inventory, report it, etc. What you describe is similar to the provision of Government property for repair, maintenance, overhaul, or modification (see FAR 45.102(d)). They are not using the property to perform the contract, the property is the object of performance.

KARREN CARRUTHERS5106/27/2018 4:04 PM6/27/2018 4:04 PM
7/27/2017 2:46 PM