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BLUF: Is furniture required by the FARs to be tracked as part of the contractor's GFE/GFP management plan?
I'm the COR on two C-5 flight simulator contracts and looking for guidance on any requirement for the contractors to maintain/report furniture (i.e., desk, chairs, tables, bookcases, etc.). Up until about 17 years ago my contracts actually listed the furniture the contractor had to track and account for annually but with the award of a new contract, at about that time, and at the Post Award Conference my PCO advised furniture was not longer required to be managed and tracked. So I have not performed furniture intentories the past 12 years. The term "furniture" used to be defined in the FAR but now I cannot find any reference to the term. My current SPO does not have a PM/PLCO assigned and I'm being told my contractors do have to make furniture part of their management plan and perform the 100% annual inventory, along with the Recompetition Support/Spares Packages. I attended the Property Management and Disposal classes at AFIT many years ago but that training is dated. Any input/references is greatly appreciated.
The furniture would not have to be tracked as part of the contractor's property management system under two conditions (reference FAR 45.000).
1. The contract requires contractor personnel to be located on a Government site or installation.
2. The furniture being used by the contractor on the Government site or installation will remain accountable to the Government.
If both conditions exist, the furniture may be considered Government property that is incidental to the place of performance. However, if the furniture is provided as GFP and listed on the GFP attachment, then the contractor must manage it as such within its property management system in accordance with FAR 52.245-1. I've been in situations twice where furniture was made accountable to the contract; once as a contractor and once as Government employee. This really comes down to a business decision that should be made by the requiring activity and the contracting officer. Providing GFP has to be justified using using the policy of FAR 45.102 and DFARS PGI 245.103-70. DoDI 5000.64 states the following about Government property incidental to the place of performance:
Administrative property typically does not meet the definition of GFP; however, the terms
and conditions of the contract may dictate otherwise. Before establishing formal GFP records for
administrative property when no previous accountable property record has been established, the
responsible APO must determine, in coordination with the contracting officer or legal counsel, if
the property can be designated as “incidental to place of performance” as defined in Federal
Acquisition Regulation (FAR) Part 45.000(b)(5). When administrative property can be so
designated, a formal GFP record is not required. If the property does not meet “incidental to
place of performance” criteria, the responsible APO must establish a formal GFP record.
Administrative property is a "subcategory of personal property, used for grouping property that
is operationally distinct from weapon systems and other equipment. Administrative property is
typically less than mission critical. Examples include: desktop computers and peripherals,
furniture, and office equipment."
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