What do the DoD Instructions 8320.04 and the FIAR Mandate have in common? They both link to the responsibilities of accurately accounting for and reporting tangible personal property. Read on to understand the latest policy developments and how that will impact defense contractors who are required to report property.
Instructions in the form of DoDI 8320.04 were created to establish policy and assign responsibilities for the process of uniquely identifying tangible personal property and required attributes. It instructs Defense Contract Management Agency (DCMA) to develop policies and procedures to assess contractor marked assets using Data Matrix barcodes per MIL‑STD‑130 and aspects of Military Shipping Labels per MIL‑STD‑129.
As the government prepares to ensure compliance, it is important to know upfront what items are going to be part of the lifecycle planning event and include the preservation and storage of tooling that’s associated with major defense programs through the end of the service life and the weapon’s service life.
It also requires that the parents of an item that requires a UII also have a unique item identifier in accordance with DFARS clause 252.211-7003.
DCMA must make sure the policies and procedure are written, implemented, and ready to go! Once the audits happen, they must be reported up through the organizational levels of the military components.
Next step is to test for the operational requirements which includes registering UIIs on contract delivery. The information resides in the IUID Registry which is the central repository. Remember, that is also the master data source for all government furnished property. GFP (Government Furnished Property) is recorded and assigned property ID numbers or IUIDs as dictated by contracts.
It’s important for the government to be complying with their own requirements which means they’ll be also relying on contractors to fulfill their obligations. One of these requirements is that there should be reasonable notification to contractors to “open their doors” when asked for audit purposes. Reasonable notification can be as quickly as 10 business days — which is quite different from the traditional 30 business days. The key is that audit support should be the new norm for DoD contractors. The new norm in 10 days might be a little difficult but that’s still the government’s intent.
We can expect more from contracting officers, the contracting officer’s reps, and the DCMA reps. They are really digging their feet in. They’re getting ready and they’re set to implement and look at all aspects of contractors systems.
How should you meet the property reporting obligations? The government is leveraging the IUID Registry to help it achieve the audit readiness reporting requirements for the new, the legacy, and GFP items. It will pass data from the IUID Registry to the APSR or Accountable Property System of Record.
iRAPT as we know ‑‑ formerly WAWF ‑‑ has been enhanced and renamed to support automated GFP recording of serially managed (IUID data) and non-serially managed items (receipt only). The government is looking to enhance their automated capabilities within the department for more system‑to‑system information processing, and they want to increase the emphasis on establishing that electronic end‑to‑end business process.
All defense contractors need to seriously consider a professionally developed property management system that handles all of the requirements of IUID, Asset Management, Inventory Automation and Reporting with direct connection to iRAPT and PCARSS. This is crucial to managing DCMA and customer audit requirements. To learn more, go to: https://www.a2btracking.com/property-managers/
Watch the video
Take a look at this video segment from a recent webinar that Peter Collins and I hosted on the importance of compliance to the FIAR Mandate. In the video, I explain the DoD Instructions 8320.04 and how that gives the DCMA the authority to systematically assess items from the defense community to ensure compliance to MIL STD 130 and MIL STD 129.
