Automated Reporting of Government Property

The new DFARS 252.245-7005 clause that was introduced in January has received a lot of attention in the GovCon community this year. We’ve spoken with a number of organizations looking to make changes to their internal procedures to meet these obligations – specifically the ability to leverage automated reporting of government property.

It’s pretty clear that the DoD is looking to improve the accountability of government property and is encouraging contractors to leverage modern integrated systems that will automate the reporting of Government property to the GFP Module.

Take a look at this 2-minute video demonstrating the automated reporting capabilities of UC! Web to the IUID Registry, GFP Module and to WAWF.

What has changed?

At the most basic level, the new DFARS 252.245-7005 clause consolidates three legacy clauses and removes a fourth. It provides updated language to reflect DoD’s current systems and generally reflects DoD’s desire to have more precise and timely reporting on GFP. Also important is that this -7005 clause only applies to new contracts and is not retroactive.

For a deeper dive and more background information, here is our blogpost on the new DFARS 252.245-7005 Management and Reporting of Government Property clause and here is another article from our friends at Baker Tilly.

What does this mean for Contractors?

Contractors would be wise to review their internal policies and procedures to make sure that they are meeting the revised reporting requirements. Here are some key areas to pay attention to:

Reporting to the GFP Module is now required for GFP lifecycle events such as: receipts, transfers, shipments and when serially managed GFP is incorporated into higher level components. The DoD developed the GFP Module in the PIEE to provide an end-to-end accountable and integrated system to record all GFP life-cycle activities. This is another step in the DoD’s move towards automation and an increase in the importance of modern integrations with the PIEE.

New Time frame: Another important element of the -7005 clause is the new 7-business day reporting requirement. Historically, contractors were left alone to manage their government property systems and establish self-imposed time frames. Contractors now need to report lifecycle events that impact GFP within 7 business days. Again, this reinforces the DoD’s efforts towards the use of automation and encourages the use of a direct, electronic submission to the GFP Module.

IUID Compliance: Not surprising – but worth noting – the new -7005 clause reinforces the IUID Marking Requirement to identify, mark and report GFP. DFARS 252.245-7005 – provides language to include IUID requirements for reparable items when contractors are supplied with technical drawings which include IUID marking methods and locations.