Most organizations, when first awarded a contract with the Department of Defense, are unprepared for the scope and depth of asset tracking and reporting that is required to be able to ship and invoice their items. This is also true for military contracts that require management of government property. Naively, these contractors assume they can comply with their new contract by altering existing internal systems, using spreadsheets, buying non-military grade software or creating a custom database to maintain internal records.
What does “DIY” mean for tracking and reporting shipments and assets?
A Do-It-Yourself approach to military IUID and RFID compliance means that you are currently considering or taking any one of these paths to tracking and reporting to iRAPT and the IUID Registry.
- Custom software development
- Modification of an internal legacy system or ERP system
- Commercial or legacy software that doesn’t meet military standards
IUID and RFID Compliance is Always Changing
While such “Do-It-Yourself” tactics can work if your contract is small and you are tracking and reporting just a few dozen items, these DIY tactics quickly become unsustainable the more items you have to accurately track and report in iRAPT (formerly WAWF) and the IUID Registry.
The US Military also struggles with their own compliance requirements to mark, track and report legacy assets to the IUID Registry. They too fall victim in attempting to build an internal approach that reaches a dead end. In fact, we’ve watched a branch of the military invest millions of dollars to build their own tools to identify, mark, track and report on assets with IUID, only to scrap the application when they realized that it’s more complicated and expensive than initially thought.
One of the main reasons that even the military struggles with their own standards—is that the standards are constantly evolving. When the US Military tried to retrofit legacy software and databases for the modern IUID requirements, they realized that their existing systems did not provide the granularity that was needed to meet the new regulations of item-level asset identification with 2D barcodes. Serialization had been around for decades but global serialized identifiers were new to this environment and needed to be accounted for. As the regulations changed, the military also needed to be able to report assets, asset pedigree and asset lifecycle events to the IUID Registry. After a painful process, they realized that their legacy system did not support this kind of modern integration and would require significant modification and investment to do so.
Understanding and keeping-up with the ever changing requirements to military asset tracking is critical to the success of your program. Following is a quick summary of the major changes to the military compliance standards for asset tracking since 2004.
The Evolution of the IUID Policy and MIL-STD 130
In 2004, the Department of Defense embraced Item Unique Identification (IUID) as a means to enable global asset tracking of military items. Defense contractors and suppliers as well as the military branches were impacted. Due to the advent of the IUID policy, property tracking and reporting would never be the same.
IUID, as a method to use a modern 2D barcode to create a global asset identifier, was inserted to MIL-STD 130, as means of creating, enforcing, and cataloging a truly a Unique Item Identifier (UII) to end all unique item identifiers that had come before. A compliant UII under this standard requires item pedigree about the item (like manufacturer, part number, serial number, date of manufacture, etc.) to be recorded in one single record and reported to the government. In addition, the IUID in the form of a barcode must also last the entire lifecycle of the asset.
The data required to report military assets is extensive, and can be confusing to interpret. You can see an example of this is in this report, which represents the most recent XML schema for submitting data to the government. The list of required data includes, among many other things, the product’s acquisition cost, a description of the product, the product’s part number and serial number, and information about the contract between the government and the contractor. Once the product has a uniquely identified number along with all asset pedigree it can be listed in the IUID Registry.
The Evolution of the RFID Policy and MIL-STD 129
A year later in 2005, MIL-STD 129 required RFID technology to be embedded in shipping labels as a way to ensure uniformity in shipments of military equipment and supplies. This technology essentially allows you to “nest” dozens of IUIDs under one parent” RFID tag assigned to, say, a shipping pallet or shipping crate. Items must be marked with the appropriate RFID tag before transportation.
RFID technology allows the military to gain real-time visibility into the movement of key containers and shipments throughout their tightly controlled supply chain. It represents a monumental advance over prior manual tracking procedures such as the use of clipboards, pencils, and visual inspections.
The Expansion of IUID Registry with DFARS 252.211-7003 and -7007
With DFARS 252.211-7003 and -7007, the Pentagon mandated all of its contractors to comply with a process that leads to assets and property being listed in the IUID Registry. For this transfer of custody to meet contract requirements under DFARs, contractors must have the correct IUID label that matches the custody transfer documents and data being submitted to the IUID Registry.
Also, it should be noted while both clauses involve the IUID Registry, each reflects fundamentally different requirements:
- DFARS clause 252.211-7003 pertains to delivery of newly procured end items.
- DFARS clause 252.211-7007 pertains to reporting of Government-Furnished Property.
Introduction of iRAPT
In November 2014, WAWF changed its name to Invoicing, Receipt, Acceptance and Property Transfer (iRAPT). The iRAPT system was created to support DoD’s goal of moving to a paperless acquisition process and to create a single, master database of all DoD property.
Electronic reporting to iRAPT is Mandatory
While contractors may be following the military standard in the identification and shipment of products, if they are not reporting electronically to iRAPT and IUID Registry then they are not in compliance with DFARs regulations. All contract obligations now require any invoice or property transfer to include the reporting of all asset data through iRAPT, which allows certain asset data to flow through to the IUID Registry. Contractors are held to this electronic reporting obligation to drive adoption so the military can benefit once assets enter the military environment.
Repercussions to Not Properly Reporting to iRAPT
If your organization is not managing this reporting requirement correctly, you are at risk of delayed payments, shipment rejections, a failed audit or jeopardizing your DoD contract.
Why DIY Compliance Doesn’t Work
While a DIY record-keeping solution may work in the short-term for small contracts and a small population of assets, if you expect to grow, a DIY approach to asset tracking and reporting is not scalable without great effort or cost.
Some organizations, when newly awarded a government contract, will attempt to create a customized approach to tracking and managing military compliance using a spreadsheet or rudimentary software — like Microsoft Access. They typically end up meeting only a small fraction of the total military IUID and RFID compliance requirements. For instance, a company might put in place a DIY approach to generating serial numbers and 2D barcodes but fails to implement a verification process to grading the barcode and overlooks the need for an audit trail of the entire transaction. This approach leaves an organization exposed to rejected invoices, rejected shipments or, worst of all, a failed audit.
Don’t Risk Your Military Contract
Learn more about the potential risks and complications that are associated with using an inferior solution to tracking and managing military assets. Download our recent eBook: The Problems with a DIY approach to Military IUID and RFID Compliance.