Sharrieff Christmas and I recently held a webinar where we discussed Reporting Assets to the IUID Registry. Being compliant with MIL-STD-130 and DFARS clause 252.211-7003 in marking your assets with an IUID label is crucial in order to secure future contract awards with the DoD. What is equally important is reporting those assets to the IUID Registry by following DFARS clause 252.211-7007. In this post, I will discuss the options that are available in order to report your assets to the IUID Registry and how you can determine which option works best for you by meeting your compliance requirements while staying within your budget.
Reporting Assets to the IUID Registry
Essentially, there are three options:
1. Manually enter your pedigree information into Wide Area Workflow (WAWF). WAWF is now part of the Procurement Integrated Enterprise Environment (PIEE). This option would require manually keying-in all the pedigree information into WAWF and if necessary also to the IUID Registry. The IUID Registry is hosted in the WAWF system and is the ultimate repository for all IUID data.
2. Another option is to simply outsource the requirement to a vendor, perhaps A2B Tracking, and we can handle this reporting obligation for you using our own compliance software that performs dozens of data validations prior to electronically reporting those assets to the government. Much like tax preparation software, A2B Tracking has created the same approach to submitting critical data to WAWF and IUID Registry. Once the assets have been reported you would then receive a confirmation back that this obligation has been fulfilled.
3. The third option is to purchase government property management software that will assist you to electronically register your IUID assets and ensure that your organization maintains compliance and supports your audit readiness.
In order to determine which option is the best choice for your organization, you need to consider how many assets you have to report. If you’re only reporting one or two items to the government — you may want to consider option #1 and just manually enter the pedigree information into WAWF. Reporting a few items this way should not be a heavy burden on your workforce and it’s certainly the lowest cost.
But, if the number of assets starts to increase (Let’s say… getting into the double or triple digits), I would recommend that you submit those electronically. This would be either by outsourcing the reporting obligation (option #2) or purchasing an in-house system (option #3).
Why Automation makes sense
Keep in mind that there are a number of pieces of information that have to be submitted to the IUID Registry. And unfortunately, manually entering the information into the government website is not as user-friendly as you might hope. It is certainly possible and it’s being done every day; but, it’s very detail-oriented, slow work that does not allow for any mistakes.
The data that needs to be reported to the IUID Registry includes:
• Contract number
• Contract type
• CLIN level detail
• Acquisition cost
• Unit of Measure
• CAGE code
• Part number
• Serial number
• UID number
• Ship date
• Acceptance date
All these pieces of information are required to fully report the asset to the IUID Registry and maintain compliance. Consider the number of data points for just one item and multiply that times the number of items that you have to report. Depending upon your contract, this can be a daunting task to perform manually. And in many cases, it’s simply not sustainable.
Data Accuracy is Critical
Reporting assets to the IUID Registry requires 100% accuracy. The IUID Registry is the master database for all DoD Property. When you report your IUID asset information it needs to be correct the first time.
Of course, it’s possible to make changes and modifications to your IUID data after you have reported it — but it’s painful.
Audit Preparation
Another important perspective to consider, is that it probably will not be looked upon too favorably from a DCMA auditor if you’re reporting a fairly high volume of assets using a manual process.
The accuracy and efficiency of electronic reporting is significantly improved over a manual process. And depending upon the software, it can help you maintain compliance and avoid mistakes early. The proper technology will also provide an audit trail with robust asset detail history to prove in the future that your assets have been reported accurately and completely. It can also help automate your annual inventories. Leveraging technology to help your organization with audit readiness is a smart investment in today’s environment.
Outsource or In-house
As far as deciding between using a vendor or selecting software to help you do this process, really depends upon your internal team. Do you have the manpower internally to take this project on? If so, that is great and there are some distinct advantages to being able to control the process internally.
However, there are many organizations that do not have the manpower to be able to do this job properly and it makes sense for them to work with a trusted vendor to make sure the job is done right. This decision often comes down to personnel and how your team is structured.
Obviously, the decision on how to report assets to the IUID Registry is going to be different for each organization. Whichever process you choose, it’s essential to prioritize accuracy and compliance to the reporting obligations along with keeping an internal record (or audit trail) — so that you can prove your compliance to the DCMA auditors.
Watch the Video
To learn more about How to Report your assets to the IUID Registry watch this video.
