For anyone involved with DCMA and contracting with the Department of Defense, one of the big concerns is compliance to federal regulations. The government is notorious for having strict guidelines that must be followed in order to continue to earn their business. In order to keep contractors in line with these regulations, the DoD will periodically send out a DCMA auditor to take a look at a contractor’s operations to make sure that all contract obligations are being met.
When DCMA auditors show up at your workplace, they know how your operation should be run and will reference what they observe against these standards. Fortunately, there’s no mystery to the things that DCMA auditors will inspect. Auditors want to know that all employees understand and adhere to all specifications of the IUID policy, that the physical IUID labeling system is being performed to specifications, that the assets and shipments are being registered properly to iRAPT, and that all subcontractors are supporting the IUID asset identification methodology. Each of these areas of focus are discussed in more detail below:
Employee Adherence: DCMA auditors are looking to verify that all employees involved with IUID asset identification and reporting to iRAPT understand their organization’s processes and consistently support effective implementation of these processes. The auditor will look for an IUID execution plan that documents the company-wide strategy for adhering to all contract requirements and provisions, from standard operation procedures and best practices to engineering drawings, material selection, serialization of part numbers, and employee training programs.
IUID Marking: DCMA auditors are looking to verify that all physical IUID labeling with plates, tags and labels is done in accordance with military standards. Auditors will look at every aspect of IUID markings, from verifying that physical markings appear on assets to ensuring those markings are visible and readable by commercial off the shelf scanners. Auditors will inspect the durability and type of materials used for the labeling, including how the Direct Part Mark (DPM) is being applied, if being used. Auditors also will ensure that the location of the tags is correct, even going so far as to compare the tags’ placement against the original engineering drawings. Finally, auditors will seek proof that all IUID marks have been validated and verified in compliance with military standards, which includes having the appropriate construct, data qualifiers, enterprise identifier type and a certificate of conformance to MIL STD 130.
Proof of Registration: DCMA auditors are seeking to verify that all assets and shipments are properly registered in the iRAPT (Invoicing, Receipt, Acceptance and Property Transfer) system, the DoD’s web-based system for electronic invoicing, acknowledgement of receipt, and asset acceptance. If you’re not familiar with iRAPT, perhaps you may be familiar with its predecessor, WAWF (Wide Area Workflow), which served a similar function. DCMA auditors specifically will look to ensure each IUID number is registered under the correct domain (i.e., acquisition, custody, legacy), and that this information is being submitted accurately in iRAPT and the IUID Registry. Auditors also will be seeking to confirm that when the contractor updates its records (i.e., for lifecycle events, part number rollovers, custody transfers, condition changes), these updates are being propagated into iRAPT and the IUID Registry in real time. iRAPT also requires ASNs (Advanced Shipping Notices) for the automation of shipment notification.
Subcontractor oversight: DCMA auditors will look to verify that a company’s subcontractors are following all protocols for IUID compliance. For example, when evaluating the application of labels that have been outsourced, the auditors will look for proof of application from the subcontractor and review the subcontractor’s processes. For labels that are produced by subcontractors and applied by the contractor, auditors will look for proof of compliance with marking and verification standards.
Why is accurate tracking data so important?
Being able to reliably and consistently track assets through their full lifecycle including the reporting to iRAPT is essential for passing DCMA audits. But investing in the infrastructure and resources necessary to support accurate tracking data is important for strategic company reasons as well.
When you track assets in real time, you are able to identify errors and problems early on, and correct them before the error is propagated to internal ERP or government systems. Once erroneous tracking data has been submitted to iRAPT and the IUID Registry or another registration authority, the mistake becomes increasingly complicated and costly to correct. Furthermore, the IUID Registry is an ecosystem; all IUID data that go into the system are, by design, linked to invoices and the payment approval process, ensuring total compliance. Thus, all data that is put into this system create a domino effect through the ecosystem: If you don’t input data correctly, you may not get paid.
If you are working with the DoD in any capacity, strict adherence to regulations is a must to keep your contract in effect. You can bet on being audited at some point during the life of the contract. For more information regarding DCMA audits and how you can prepare for them, check out our eBook The DCMA Survival Guide.