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2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

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Page 1: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

IUID Are you Ready?

Mike Herskovits, CPPM

November, 2013

Page 2: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

IUID – Are You Ready?

Disclosure – This presentation has extracted from several sources of

information and is not intended to be construed the presenter’s employer or as changing or modifying any statute, regulation, DoD policy or guidance, or any term(s) of any contract with the U.S. Government or any department or agency of the U.S. Government.

This briefing focuses on the August 2012 version of DFARS Clause 252.211-7007

Page 3: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

AGENDA Background & History Focus of Presentation Evolution of Reporting Types of GFP What is UII What is Serially Managed Reporting Events Assumptions

Page 4: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Background & History DoD has a long tradition of identification and marking of

its military property. The Defense Standardization Act of 1952 gave rise to the

national stock number (NSN) system to provide unification & standardization of consumable items to assure like items would be identified as such.

After WWII, an effort was made to prevent unnecessary duplication of supply and allow for sharing across all services.

March 4, 1953 – MIL-STD-130 ID of Marking Published. Rev. L in 2003 – Allowed for other than only human

readable information.

Page 5: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Background Con’t 1990 – Chief Financial Officer’s Act called for improved

financial management. DoD needed capability for enhanced total asset visibility, improved lifecycle management accountability and clean financial audits.

Combatant Commanders need battlefield awareness and total asset visibility.

2002 – DoD initiated an effort to re-engineer the process.

Page 6: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

FOCUS

This briefing focuses on the August 2012 version of DFARS Clause 252.211-7007

•The clause does not contain a “marking” requirement •The clause does contain a GFP reporting requirement •The clause is often confused with DFARS 252.211-7003 •Both clauses involve the DoD IUID registry. However, each

reflects fundamentally different requirements: •DFARS clause 252.211-7003 pertains to delivery of items •DFARS clause 252.211-7007 pertains to reporting of GFP

Page 7: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Focus Background 2007: Contractor reporting of GFP begins in earnest •Regulatory (DFARS) timeline: •252.211-7007 [August 2012] (Includes new 2014

requirements*) •252.211-7007 [November 2008] (Final Rule) •252.211-7007 [September 2007] (Interim Rule) •Multiple changes created a degree of confusion, but

core reporting requirements did not change

*Afforded industry adequate time to prepare for new requirements

Page 8: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Evolution of 252.245.7001

Page 9: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Types of GFP Item is serially managed or over $5,000

Item is NOT serially managed AND Under $5,000

Registered Not Registered

Marked Compliant Failure to Report

Not Marked Failure to Mark Non-Complian

Registered Not Registered

Marked Permitted by draftRevised DDFARS

252.211-7003

Failure to Report

Not Marked Failure to Mark IUID Not RequiredNo ISSUE

Page 10: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

What is UII “a set of data elements marked on items that is globally

unique and unambiguous. The term includes a concatenated unique item identifier or a DoD recognized unique identification equivalent.”

Why do some GFP items have UII’s ? Because – • The contractor assigned and registered a UII by virtue of

delivery under DFARS 252.211-7003 requirements, or• •The DoD Component assigned and registered a UII while

the item was in its custody By default, items with a UII are serially managed

Page 11: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

What Does Serially Managed Mean?* “An item designated by DoD to be uniquely tracked,

controlled, or managed in maintenance, repair and/or supply systems by means of its serial number.” DFARS clause 252.211-7007

• * In addition to items previously marked with a UII, certain FAR property categories already meet this definition.

Page 12: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Inherently Serially Managed Items All items subject to DoD Instruction (DoDI) 5000.64 are

considered serially managed, i.e., “designated by DoD”• Special tooling (ST), special test equipment (STE), and

equipment all fall under DoDI 5000.64• Therefore all ST, STE, and Equipment items are subject to

DFARS 252.211-7007 reporting Material (items other than ST, STE and Equipment) is a

different matter; material cannot be considered “inherently” serially managed*

*True, “some” material items have serial numbers— but that does not make them inherently “serially managed”

Page 13: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Identification of Serially Managed THE GOVERNMENT – Not the Contractor,

Has to Identify Serially Managed Items

Contract Terms and Conditions MUST identify ALL items to be Serially Managed

Example – Items individually listed on the “Scheduled” GFP Attachment (SGFP)

Page 14: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

What Does Report Mean - In simplest terms, it means sending information to the

DoD IUID registry (“the registry”) related to a property item’s custody.

Page 15: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

REPORTING (Cont) (2014) Reporting involves the following events:

• Receipt of property• Delivered or shipment from the contractor’s plant (unless

to a subcontractor)• Consumed or expended• Disposed of• Transferred to a follow-on or other contract

Let’s look at each of these reporting events

Page 16: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Reporting - Receipt Receipt means acknowledging (electronically) the physical receipt

of all GFP This is the clearly the most important reporting requirement:

• Impacts overall property accountability• The Government’s warranty of timeliness of GFP delivery• Contract performance• Readiness• Applies to all categories of GFP. Period. No exceptions.

Universal electronic acknowledgement of all GFP items is a fundamental requirement of DFARS 252.211-7007 and property accountability!

Page 17: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Receipt (Cont.) Electronic receipt acknowledgment is crucial and

required for all GFP items It does not matter if the GFP is:

• Serially managed• Not serially managed*• Valued above or below $5,000• An item for repair• Lacks a UII

*If the property is not serially managed, acknowledgement of receipt is all that’s needed. No other reporting is required under the clause. Done!

Page 18: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Receipt (Cont) GFP reported to the IUID Registry in 3 ways –

1. Through Wide-area Workflow (WAWF)

2. Registry website – if has UII and in registry

3. Electronic File submission

Page 19: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Other Reporting Events Delivered or Shipped from Contractor’s Plant

• IAW Contract T&C or Direction of Contracting Officer• Shipped to a DoD entity or another DoD contract• Requires electronic acknowledgement of receipt by

gaining contractor & WAWF repairable repors Disposed of (Different than above) Means:

Transfer to a non-DoD federal Agency Donation, sale or abandonment

Page 20: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Other Reporting Events (cont) PCARSS automatically to update registry when

“disposed of” events occur PCARSS does NOT automatically update the registry

when “shipment” (to Army, Navy, Air Force, Federal ciovil agencies) events occur.

Note – DCMA’s Property Loss Tool updates the registry automatically upon contractor reporting of property loss (ref: DFARS 252.245-7002)

Page 21: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Other Reporting Events (cont) Consumed or expended

• Destructive testing• Test firing a missile• Certain types of drill bits

Transferred to a follow-on or other contract means: a contractual transfer of property accountability (same contractor/same CAGE)

Registry (via WAWF) must be updated to reflect the new contract

Page 22: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Reporting Assumptions If an item is not –

• “Delivered” by the contractor• “Shipped” by the contractor (as part of the T&Cs)• “Disposed of” as defined above• Processed through PCARSS• Reported as lost through DCMA’s Loss Tool (etools)• Transferred to another Contract at the same Cage• Then it would be considered consumed as part of the

process. Issue records should be able to verify.

Page 23: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

Questions

Mike Herskovits, [email protected]

Page 24: 2013 NPMA Fall Conference Value Through Professional Asset Management IUID Are you Ready? Mike Herskovits, CPPM November, 2013

2013 NPMA Fall ConferenceValue Through Professional Asset Management

References -History of UID and MIL-STD-130

HTTP://www.camcode.com/asset-tags/uid-overview-series-part-i-iud.

Ruckdaschel, Tom, GFP Reporting Under DFARS Clause 252.211-7007, 2013/10/23.

https://home.dcma.mil/POLICY/124r/index.cfm

Resources

https://home.dcma.mil/POLICY/111r/index.cfm

http://dodprocurementtoolbox.com/

http://www.acq.osd.mil/dpap/pdi/gfp/index.html