In late January this year, the DoD issued a final ruling to update, clarify and streamline Government property management requirements. The result of this ruling creates a new GFP Reporting clause – DFARS 252.245-7005, Management and Reporting Government Property.
The new rule consolidates four existing clauses into one (DFARS 252.245-7005) and therefore removes the following clauses:
- DFARS 252.245-7001, Tagging, Labeling, and Marking of Government-Furnished Property
- DFARS 252.245-7002, Reporting Loss of Government Property
- DFARS 252.245-7004, Reporting, Reutilization, and Disposal of Government Property
- DFARS 252.211-7007, Reporting of Government-Furnished Property
This initiative was proposed in April 2023 to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to consolidate existing contract clauses for the management and reporting of Government property into a single contract clause. Furthermore, the DoD wanted to update and replace references to legacy software applications used for reporting Government property.
GFP Module Reporting
GFP Module ReportingThe new clause, DFARS 252.245-7005, instructs contractors to use the GFP module in the PIEE instead of legacy applications when reporting receipt, shipment, transfer, or loss of Government property, and for reporting excess property.
The DoD developed the GFP module within the Procurement Integrated Enterprise Environment (PIEE) to house the GFP life-cycle reporting requirements to provide end-to-end accountability for all GFP transactions within a single, secure, integrated system, while employing enhancements in technology to reduce burden on the public and the Government.
Specifically, DFARS 252.245-7005 requires contractors to use the GFP module to report the following:
- Receipt of GFP
- Transfer of GFP from one contract to another DoD contract
- Shipments of GFP to the Government or to a contractor
- Loss of Government property
- Government property excess to contract performance for the purpose of disposal
- Request to buy Contractor-acquired property (CAP) or convert it to GFP
What this means for Government Contractors
This new DoD ruling clarifies and updates the requirements for managing and reporting Government property. Most notably, is the requirement for contractors to use the GFP module to report all of their GFP lifecycle events.
Importance of Automation
This requirement to utilize the GFP module and embrace available modern technologies will provide a more secure, accountable and integrated system that will streamline operations for both the Government and the contractor community.
Contractors with a history of managing and reporting Government property will notice this as a continued shift towards automation and an increase in the importance of modern integrations with the PIEE.
Definitive Timeliness of Reporting
Another clarification that this new ruling provides is a much more definitive timeline in regards to GFP reporting. DFARS 252.245-7005 states:
…the Contractor shall report the updated status of the property to the GFP module within 7 business days of the date the change in status occurs, unless otherwise specified in the contract.
Contractors only have 7-business days to report the receipt, shipment, transfer, or loss of Government property to the GFP module. This is not entirely surprising but reinforces the importance of a direct, electronic submission to the GFP module.
Alex Mikhelson, Director at Baker Tilly, explains in his recent article that “Historically, it has been up to contractors to design and manage systems to handle government property to include the establishment and prescription of self-imposed time frames”. However, with this new ruling Government contractors in 2024 need to make sure that their procedures are updated to accommodate for capturing and reporting these events into the PIEE system within the 7-day requirement. This requirement is another indication of the DoD embracing automation and raising the expectations for contractors to leverage modern technology as an important element of their contract requirements.
New Marking Requirement
As mentioned above the DFARS clause 252.245-7001 – Tagging, labeling and marking of Government Furnished Property, has been removed. Apparently, there was some confusion as to the marking requirements for reparable items. The new clause updates the Unique Item Identification (UII) marking requirement, where contractors are required to apply MIL-STD-130 compliant labels on new items and extends that requirement to serially-managed reparable items.
Conclusion
DFARS 252.245-7005 provides an amendment and detailed update to the contract requirements related to managing Government property. Most importantly, is the explicit requirement to utilize the GFP module in the PIEE for reporting lifecycle events of GFP and additionally, these events need to be reported within 7-business days.
The GFP module consolidates Government property management into a single automated platform that enables data reuse throughout the lifecycle of the property. By using the GFP module, we will improve data accuracy and reduce manual data entry by contractors.
The identification, tracking and reporting of Government property remains a critical focus area for the Department and has been repeatedly identified as a material weakness. Accountability of Government property in the possession of contractors has a direct impact on operational military readiness and towards achieving the DoD’s financial audit objectives.
This new DFARS clause makes it clear that contractors are required to leverage modern technology and automate their reporting of Government property through the exclusive use of the GFP module in a timely manner.
Feel free to contact us if you would like to speak with a Government property management specialist to discuss how this new ruling might affect your program. A2B Tracking’s Government Property Management platform, UC! Web, provides total compliance to FAR 52.245-1 with automated reporting to PIEE, WAWF, GFP Module and the IUID Registry.
