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Cross-Functional Teaming: Contract Property Touchpoints
Breakout Session #A06Edwin Hoenig – Property Team Supervisor DCMA-AQBYOLuke Wayne – Plant Clearance Team Supervisor DCMA-AQBPE
December 4, 2017 10:00am – 11:15am
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Workshop Objectives
• Business Capabilities Framework• Overview
• How/Where do Property/Plant Clearance Fit?
• Property Administration Touchpoints• Processes
• Actors/Transactions/Outcomes
• Plant Clearance Touchpoints• Processes
• Actors/Transactions/Outcomes
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DCMA's capability framework is a set of high level contractmanagement functions that underpin the Agency's strategic plan and capture the results of the daily, multi-functional activities of our personnel in order to provide actionable insight to the Defense Acquisition Enterprise.
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Four Key Initiatives:
•Maintain functional expertise with multifunctional execution•Separate policy from procedure•Establish value through a capabilities-based approach•Govern the Machine
Leadership Engagement
• Transition from Lines of Service to Business Capabilities• Get the message to the workforce• Create a multi-functional environment• Begin reporting activities as they are associated with Business
Capabilities• Assess the ROI of products that support the acquisition enterprise• Adjust organizational and individual performance measures to
reflect the alignment to Business Capabilities
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The Primary Capabilities are the key mission elements that provide
value. Each requires all job series, and all mission organizations to participate
and share information related to administrating existing and future
contracts
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Contract Property Touchpoints
Contractor Effectiveness
Contract Maintenance
Product Acceptance and Proper Payment
• MRB Scrap (product reject)
• Cancelling Funds (product acceptance)
• Contractor Inventory Disposal
• Contract Closeout• Contract Termination
• Property Management System Analysis
• MMAS and Utilization Audits
• Subcontract Control
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Contract Property Touchpoints
Touchpoint:
An encounter where customers and business engage to exchange information, provide service, or handle transactions. For example, in retail banking the touchpoints include tellers and ATMs.
Actors Transaction Outcome
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The DCMA Property Group by the Numbers
• DCMA administers approximately 340K contracts
• Only 5%, 16,544, are contracts with GP (MOCAS Spec Prov Code E)
• The 16,544 contracts are with 2,169 contractors.
• DCMA has about 230 Property Administrators (PA)• Mostly Itinerant PAs• Some Resident PAs
• Of our 5% (16K) there are about 3% (2K) in closeout
• Of the 3% (2K) in closeout, 2% (264) delayed due to Property
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Property Administration Overview
Mission: The DCMA Property Group is DoD’s subject
matter expert for Contract Property Administration,
around the world. The DCMA Property Group
provides surveillance/oversight to ensure contractors
are providing effective and efficient stewardship of
the Government property in their custody; therefore,
assuring its availability for contract performance,
reducing the risk to our customers, and fulfilling
supporting mission requirements.
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Property Administration Overview
• There are four core tasks a DCMA Property Administrator (PA) performs: • Contract Maintenance
• Contract Receipt and Review • Property Loss Cases• Contract Property Closeout
• Contractor Performance• Property Management System Analysis (PMSA)
• Additionally we can be asked to support:• MMAS Reviews - DCAA driven• Verification of Plant Clearance submissions
• We don’t do customer requested inventories.• We don’t update the services’ records• We don’t sign for things• We have no role to play in transfers, but can be
asked to support complex transfers
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Deciding to Furnish GP or Not
• PGI 245.103-70 Furnishing Government Property to Contractors• The requiring activity (project or program
Manager) is the decision point• Decision must be documented, to the PCO
• The PCO ensures: • In the Government’s best interest
• Economy, standardization, security, expedite production, scarcity, maintain the industrial base, contract type
• Overall benefit must outweigh cost of admin and disposal?
• Gov assumption of risk • Discussed and documented
• Gov requirements can not otherwise be met.
Actors:Program
Manager, PCO
Transaction:Justify need for
GFP
Outcome:Documented Justifications
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Property Management System Analysis (PMSA)
• Government Property Clause – FAR 52.245-1(f) requires contractors to have “plans and systems” to manage Government property in their possession
• Risk Based Surveillance. PMSAs are performed on an Annual, Biennial, or Triennial basis, depending on risk and secondary factors
• The goal of the PMSA is to determine compliance with the 10 Outcomes described in FAR 52.245-1(f) (i) through (x)
• The PMSA Audit Report is the driver behind the Property Management Business System Assessment Summary (BSAS), given to the cognizant CO
Actors:KTR, PA, CO
Transaction:FAR 52.245-1 Compliance
Outcome:BSAS to
Cognizant CO
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PMSA Continued• DCMA has broken out the 10 Outcomes listed
in FAR 52.245-1(f) (i)-(x) into 22 Elements.
Actors:KTR, PA, CO
Transaction:FAR 52.245-1
Outcome:BSAS to
Cognizant CO
• Written Procedures• Contractor Self
Assessment• Acquisition• Receiving• Discrepancies
Incident to Shipment
• Identification• Records• Receipt and Issue
System• Physical Inventory• Subcontractor
Awards and Flow Down
• Subcontractor Reviews
• Reports• Relief of
Stewardship• Utilization• Declaration of
Excess• Consumption• Movement• Storage• Storage
Commingling• Maintenance• Disposal• Property Closeout
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PMSA Continued“Why We Do Site Visits”
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PMSA Continued• The PA can perform an on-site Standard PMSA
or a Limited PMSA (a.k.a. Desk Audit).
• Compliant vs Non-Compliant• There is an overall result for the system• There are sub-element results• CARs are issued for non-compliances if not
corrected on the spot.
• CARs and Re-Analysis• A PA can issue a Level I or II CAR for sub-
element non-compliance. • If the PA is recommending that the CO
should consider the overall system to be non-compliant then a Level III is drafted and sent to the CO.
• A Re-Analysis could be on-site or not. It could also be incorporated into the following year’s PMSA.
Actors:KTR, PA, CO
Transaction:FAR 52.245-1 Compliance
Outcome:BSAS to
Cognizant CO
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PMSA Continued - Timeline• Oct 1st, Internal DCMA FY PMSA schedule created• PA issues a 30-Day Notice to the contractor 30 days
prior to an on-site Standard PMSA • The PMSA is performed• Within 30 days the PA:
• Completes the PMSA Audit Report• Issues Level I or II CARs if needed• Submits a BSAS to the Cognizant CO
• Within 10 days more the CO:• Issues a Determination Letter and updates
CBAR or…
• If the overall system is at risk of being found non-compliant, the CO issues an “Initial” Determination (with Draft Level III CAR) within 10 days and requests a contractor response within 30 days
• If significant deficiencies persist, the CO can disapprove the system and seek remedies in accordance with the Business System clause, DFARS 252.242-7005
Actors:KTR, PA, CO
Transaction:FAR 52.245-1 Compliance
Outcome:BSAS to
Cognizant CO
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Property Loss Cases• The U.S. Government is a self insurer.
• We do this because we are so large.• We do this to save money, disallowing the
cost of commercial insurance contractors may have.
• We offer Relief of Liability to contactors conditionally.• If they have other insurance or are
otherwise compensated, they must reimburse the government.
• There must not be “willful misconduct or lack of good faith on the part of managerial personnel.”
• Must not have a disapproved Property Management System.
• PAs give relief, COs hold liable.
Actors:KTR, PA, CO
Transaction:Report of LTDD
Outcome:Relief of
Liability or Not
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Property Loss Continued• Property Loss used to be described by the
acronym LTDD, which stood for the Loss, Theft, Damage, and Destruction (LTDD)
• “The contractor shall have a process to enable the prompt recognition, investigation, disclosure and reporting of loss of Government Property.” This is spelled out in 52.245-1(f)(vii) Relief of stewardship responsibility and liability
• Contractors are required to use the Property Loss Etool. PA assistance might be required
• Each report must includes lots of mandatory information about the incident, including• Root cause analysis• Corrective actions taken• An assessment of continued need
Actors:KTR, PA
Transaction:Report of LTDD
Outcome:Relief of
Liability or Not
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Property Loss GFR Clause • The Ground Flight Risk clause, DFARS 252.228-
7001 has unique liability requirements that pertain to and prevail in cases of loss, damage, or destruction of aircraft that occurs • “in the open,” • during “operation”, • and “in flight.”
• Reporting is different. DoD Instruction 6055.07 Mishap Notification, Investigation, Reporting, and Record Keeping” is used in lieu of the Property Loss Etool.
• The Government Flight Representative is responsible for making liability recommendation to the ACO for all incidents involving loss of Government aircraft when DFARS 252.228-7001 is in the contract.
Actors:KTR, Gov Flt
Rep, CO
Transaction:GFR Report and
Assessment
Outcome:Relief of
Liability or Not
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Contract Property Closeout• There are lots of ways to dispose of residual
property on a contract. • The CO can make targeted transfers of
items of property.• Other contracts• Other units/organizations
• With PCO/PLCO permission, the contractor can buy back unused material.
• The PLCO has options the CO doesn’t, beyond targeted transfers for reutilization, which Luke will talk about in detail.
• The PA can not direct the contractor to do anything with the property.
• The PA has the final step of “Perform (MOCAS) Property Administration Contract Closeout.”
Actors:KTR, CO, PLCO,
PA
Transaction: Disposition of Residual GP
Outcome:R-9 55 Code in
MOCAS
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Contract Property Closeout Steps
• At the end of the contract, the contractor performs a final physical inventory of GP on the contract.
• Submits Property Loss cases, if needed, to the PA.
• Notifies the ACO via email of property required on another contract. Simultaneously reporting the same list as a case in PCARSS.
• Reports remaining property items in a separate case in PCARSS Etool to the PLCO for disposition instructions.
• After all Property Loss and PCARSS cases have been closed, the contractor submits a Property Closeout Letter to the PA declaring that no more property remains on that contract.
• The PA enters the R-9 55 Code in MOCAS, typically using the CPAS Etool interface.
Actors:KTR, CO, PLCO,
PA
Transaction: Disposition of Residual GP
Outcome:R-9 55 Code in
MOCAS
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Contract Property Closeout Continued
• Causes for contracts being Over-Age due to Property. • It happens, but is not statistically
significant.
• Most often due to decisions made by the Program Office. • They tell the contractor to wait.
• They are aware of a future contract that will need the GP.
• The are unsure about the future.
• What property is normally on the Over-Age list? Expensive reusable uniquely military property
• Most contractors don’t charge for storage, but they could.
Actors:KTR, CO, PM,
PCO, PLCO, PA
Transaction: Disposition of Residual GP
Outcome:R-9 55 Code in
MOCAS
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Plant Clearance Overview
Mission:
Provide timely and cost effective reutilization,
sale and disposal of excess government property in
the possession of contractors.
FY 17 by the Numbers
• 13,202 cases processed totaling $3.8 billion in acquisition cost• Over 115,000 line items demilitarized, a sum of $1.7 billion• $1.8 billion reported in useable condition property• $743 million reutilized for future use. 41% Reutilization rate• $3.4 million in sales proceeds
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Disposition Lifecycle
In-Use
Sale
Donation SalesExcess
Disposal at any stage: Non-federal transfers; Abandoned/Destroyed; and Lost
Stage of Asset Life Cycle
Acquisition
(Source of Chart: Robert Holcomb, NPMA NES Presentation)
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PCARSSPlant Clearance Automated Reutilization Screening System
1. Contractor Submission of
GFP/CAP to PCARSS
2. PLCO Reviews, Accepts and
Screens
3. PLCO Issues Disposition
4. KTR completes action(s) and submits docs
5. PLCO reconciles, closes and maintains file
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Inventory Submission• Government Property Clause – FAR 52.245-1(j)
requires submittal of inventory schedules by contractors listing government property excess to their contracts
• Prior to submission the KTR shall internally screen for reuse within their DoD contracts. Best practice is also to prescreen with PCO/Program Office
• FAR 52.245-1(j)(3) – Submission Requirements• 30 days following contractor
determination item is no longer needed• 60 days following completion of deliveries
or services• 120 days following contract termination
(partial or complete)
Actors:KTR, PCO, PLCO
Transaction:Notice of Excess
Outcome:SF1428/PCARSS
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PLCO Review, Accept, and Screen
• PLCO has 10 days to review and accept or reject the schedules per FAR 45.602-1
• Screening of excess property is based on –Type of property (EQ,M, ST, STE)Condition of propertyAcquisitioncost of property
• Standard Screening Timeframes (FAR 45.602-3) –0-20 days screen with Owning Activity and other DoD Agencies21-46 days screen with GSA for Federal Agencies and Donation
• Normally no screening for scrap condition items except scrap aircraft must be screened with GSA (26 days)
Actors:PLCO, PCO, PM
Transaction:Excess Property
Review
Outcome:Reutilization(ROI)
or Clearance to Dispose
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PLCO Issues Disposition Instructions
Actors:PLCO, KTR,
Sub-KTR
Transaction:Flow-down of Instructions
Outcome:Letter of
Instruction < 120 Days
• PLCO must provide disposition instructions to the contractor within 120 days after receipt of inventory schedule IAW the reutilization priorities found in FAR 45.602-2
• Transfer within the Owning Activity or other Federal agency
• Transfer of educationally useful equipment to schools and nonprofit orgs (E.O.12999 & Stevenson-WydlerAct)
• Donation to eligible parties via GSA• Demilitarization• Sales• Scrap• Abandon
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Disposition Completion (Transfer)
• Transfer within the Government –• Requisition received from screening
agency• Owning Agency• Other DoD Activities• Federal Agencies (via GSA)
• PLCO forwards requisition to the contractor
• Contractor prepares items for shipment and transfers in accordance with PLCO direction
• Donations –• Requisition received from GSA to
donate property to eligible donee• PLCO forwards requisition to the
contractor• Contractor prepares items for
shipment and transfers in accordance with PLCO direction
Actors:KTR, Sub-KTR,
Donee, TO
Transaction:Transfer of Title
Outcome:DD1149, SF97
Note: This does not involve a CONTRACT transfer. Only a SF30 can transfer property from one contract to another.
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Disposition Completion (Demilitarization)
• Demilitarization• PLCO directs contractor to demil items
with assigned demil code other than A, B, or Q
• Contractor performs the required demil• Removal/Destruction of Key Points (C)• Total Destruction of Item (D)• Item Manager Direction (E)• Special instructions HAZ (F)• Neutralization of AA&E (G)• Declassification from Original
Classification Authority (P)
• Government witness/certification required when contractor performs the demil
Actors:KTR, Sub-KTR, Vendor, Gov’t Rep, ACO, PCO
Transaction:Destruction and
disposal of sensitive items
Outcome:Demil Cert,
Declass Cert, DD1639, DD1348
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Disposition Completion (Demilitarization)
Antiquated training gear “drop-shipped” to contractor as GFP.Demil D
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Disposition Completion (Demilitarization)
RQ-15 Neptune TerminationDemil A, B, D
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Disposition Completion (Demilitarization)
Aircraft Maintenance ScaffoldingDemil A
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Disposition Completion (Demilitarization)
Grumman C-2A GreyhoundDemil C
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Disposition Completion (Demilitarization)
Aircraft Ground Maintenance CartsDemil A
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Disposition Completion (Sales)
• Sales (four types) –• Formal Sale• Informal Sale• Negotiated Sale• Auction Sale
• PLCO determines items to be sold
• Contractor conducts the sale based on PLCO direction
• Proceeds collected by PLCO shall be applied IAW FAR 45.604-3:• Contract• Termination• US Treasury Miscellaneous Receipts
Actors:KTR, Sub-KTR,
PLCO, Sale Vendor, Awardee
Transaction:Efficient Sale of Surplus Gov’t
Property
Outcome:Proceeds ROI,
DD1149
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Negotiated SalesFAR 52.245-1 (j)(2) Inventory Disposal Schedules
(ii) The Contractor may annotate inventory disposal schedules to identify property the Contractor wishes to purchase from the Government, in the event that the property is offered for sale.
• Two types of Contractor Inventory:
1.) Government Furnished Property (GFP)
2.) Contractor Acquired Property (CAP)
• The offer will only by heard by the PLCO when screening is complete. (20-46 days depending on property type and condition)
Note: CAP can be re-purchased at full acquisition cost to avoid the screening period and potential loss to intragovernmental transfer or requisition.
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Negotiated Sales• A Contractor may make an offer to purchase on each
type of property prior to disposition instructions being issued
• There is no guarantee an offer will be accepted
• It is a negotiation
Ways to pay:
• Credit to the contract (via PCO/ACO discretion)• Certified Bank Check/ Money Order made out to
U.S. Treasury sent to PLCO
• Credit Card, ACH withdraw, PayPal, Etc.
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Disposition Completion (Scrap)
• Scrap
• PLCO directs contractor to dispose of items via their approved scrap procedure
• Scrap items from all contracts are co-mingled
• Proceeds credited to overhead in accordance with the contractor’s procedure
Actors:KTR, Sub-KTR,
Vendor
Transaction:Efficient Sale of Scrap Surplus
Gov’t Property
Outcome:Proceeds,
DD1639 Scrap Warranty
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Disposition Completion (Abandonment)
• Abandonment
• PLCO abandons items that have no sale potential or scrap value to the contractor IAW FAR 52.245-1(k)
• Cannot abandon hazardous or sensitive items without contractor consent
Actors:KTR, Sub-KTR
Transaction:Unilateral or
Bilateral Transfer of Title
Outcome:DD1149, signed
acceptance
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• Contractor completes disposition
• PLCO closes plant clearance case and forwards completed file to the Contracting Officer for incorporation with contract files • ACO - in house contract
• TCO - termination
• Referring PLCO - delegation
• PLCO creates electronic case file and uploads the documents directly into IWMS for retention
Actors:PLCO(s), ACO, TCO
Transaction:Closure and Retention
Outcome:SF1424,
electronic case file
Plant Clearance Case Closure
Contact InformationEdwin HoenigTeam Supervisor, DCMA-AQBYOProperty Administration International Team(804) [email protected]
Luke WayneTeam Supervisor, DCMA-AQBPPlant Clearance International Team(407) [email protected]
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