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Wednesday, June 16, 2010

Government Property

The idea of obtaining Government property when performing a contract is attractive to some contractors, especially if it reduces the amount of capital a company needs to invest. However, Government property does come at a cost - added administrative work mainly - and contractors need to consider those costs.

Government property as used in FAR Part 45 means all property, both real and personal. It includes facilities, material, special tooling, special test equipment, and agency-peculiar property. Government property includes both Government-furnished property and contractor-acquired property.

 
Contractors are required to establish and maintain a property system that will control, protect, preserve, and maintain all Government property because the contractor is responsible and accountable for all Government property under the provisions of the contract including property located with subcontractors. Does that sound simple? Well, here are some of the specific provisions included in FAR Part 45

 

  1. FAR 45.606-1 requires a contractor to submit inventory schedules.
  2. FAR 45.606-3(a) requires a contractor to correct and resubmit inventory schedules as necessary.
  3. FAR 52.245-1(f)(1)(ii) requires contractors to receive, record, identify and manage Government property.
  4. FAR 52.245-1(f)(1)(iii) requires contractors to create and maintain records of all Government property accountable to the contract.
  5. FAR 52.245-1(f)(1)(iv) requires contractors to periodically perform, record, and report physical inventories during contract performance.
  6. FAR 52.245-1(f)(1)(vi) requires contractors to have a process to create and provide reports.
  7. FAR 52.245-1(f)(1)(viii) requires contractors to promptly disclose and report Government Property in its possession that is excess to contract performance.
  8. FAR 52.245-1(f)(1)(ix) requires contractors to disclose and report to the Property Administrator the need for replacement and/or capital rehabilitation.
  9. FAR 52.245-1(f)(1)(x) requires contractors to perform and report to the Property Administrator contract property closeout.
  10. FAR 52.245-1(f)(2) requires contractors to establish and maintain source data, particularly in the areas of recognition of acquisitions and dispositions of material and equipment.
  11. FAR 52.245-1(j)(4) requires contractors to submit inventory disposal schedules to the Plant Clearance Officer.
  12. FAR 52.245-9(d) requires a contractor to identify the property for which rental is requested.

 


 

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