Be Sure to Turn in Your Badges

Here's something else to add to your policy and procedure manual.

A final rule was just published in FAR addressing the concern that Government contractors do not always return their identification cards when they no longer need them. The Government issues CACs (Common Access Cards) in order to allow contractors access to Federal facilities (e.g. military bases). A CAC is the DoD term for a Personal Identity Verification (PIV) card. A year or so ago, the Inspector General's office found that these cards were not adequately accounted for after contract performance or completion.

Under the new rule which goes into effect on January31, 2011, contractors must establish policies and procedures to account for all forms of Government-provided identification issued to its employees in connection with contract performance. Contractors must return such identification to the issuing agency at the earliest of any of the following,

1. When no longer needed for contract performance
2. Upon completion of the employee's employment
3. Upon contract completion or termination

This clause flows down to subcontractors and for contractors who fail to comply, the contracting officer may withhold final payment under the contract.