Department of
Defense
Item Unique
Identification of Government Property Guidebook:
Reporting Government
Property In the Possession of the Contractor (PIPC)
Guidance for:
Defense Federal
Acquisition Regulation (DFARS) 252.211-7007, Item Unique Identification
of Government Property
Version 1.0
September 21,
2007
Office of the
Under Secretary of Defense
Acquisition,
Technology & Logistics
Table of Contents
Introduction
Purpose
Background
Reporting Government
Property on Existing Contracts
Contractors have been
reporting Government property annually using the Department of Defense
Form 1662, DoD Property in the Custody of Contractors, as prescribed
by DFARS 252.245-7001 and 245.505-14(a).
On May 12, 2005, the
Under Secretary of Defense for Acquisition, Technology and Logistics,
signed a policy update for Unique Item Identification (IUID) of tangible
personal property, including Government Property In the Possession of
Contractors (PIPC).2 As part of that policy, the
UID Program Management Office (PMO) was tasked with establishing one
central DoD electronic PIPC capability as an integral function of the
DoD Item Unique Identification (IUID) Registry.
The detailed guidance
for transitioning from the DD Form 1662, DoD Property in the Custody
of Contractors, to industry electronic submission of master IUID data
for PIPC into the DoD IUID Registry is available at: http://www.acq.osd.mil/dpap/UID/dd1662.htm3.
Initiated in October
2005, the transition for existing contracts with the DD Form 1662 requirement
to electronic submission of PIPC IUID data to the DoD IUID Registry
will be cyclical, with each fiscal year, until all existing contracts
have been modified to remove the DD Form 1662 requirement or have been
completed. Transition for existing contracts is voluntary. If a contractor elects not to transition
on existing contracts, then the DD Form 1662 requirement will remain
in effect until the contracts are completed.
Reporting Government
Property on Contracts Issued After September 13, 2007
For new contracts issued
after September 13, 2007, DoD will include an Interim Rule, DFARS 252.211-7007,
Item Unique Identification of Government Property (DFARS Case 2005-D015),
which permanently revises requirements for reporting of PIPC.
The interim rule permanently replaces the DD Form 1662 reporting requirements
with requirements for DoD contractors to electronically submit, to the
IUID registry, the IUID data applicable to PIPC.
It should be
understood that in accordance with DFARS 211.274-5, Contract clauses,
the clause at DFARS 252.211-7003, Item Identification and Valuation,
must be included in any contract that incorporates the clause at DFARS
252.211-7007, Item Unique Identification of Government Property.
This is essential to assure there is no ambiguity in the requirements
for assigning, registering, reporting and marking PIPC.
Chapter 1
PIPC Business
Rules
Definitions
IUID Registry
The DoD IUID Registry
provides storage of, and access to, data that identifies and describes
Government personal property, including PIPC. The DoD IUID Registry
is described at IUID
Registry Brief.
Property In
the Possession of Contractors (PIPC)
PIPC is defined as
tangible personal property to which the Government has title, which
is in the stewardship, possession, or controlled by, the contractor
for performance of a contract. PIPC consists of both tangible
Government Furnished Property (GFP) and Contractor Acquired Property
(CAP), and includes -
Equipment – A
tangible article of personal property that is complete in-and-of-itself,
durable, nonexpendable, and needed for the performance of a contract.
Equipment generally has an expected life of one year or more, and does
not ordinarily lose its identity or become a component part of another
article when put into use. It includes Special Tooling, Special Test
Equipment, and other controlled internal use items (formerly classified
as industrial plant equipment (IPE), other plant equipment (OPE) and
Agency Peculiar Property (APP) furnished to a contractor for use on
a contract. It does not include material or reparable items.
Material - Property
that may be consumed or expended during the performance of a contract,
component parts of a higher assembly, or items that lose their individual
identity through incorporation into an end-item. Material does
not include equipment, special tooling, special test equipment or reparables.
Low Value Property
(LVP)
For PIPC, LVP is defined
as special tooling, special test equipment, and other controlled internal
use items with an acquisition cost less than $5,000.
Repairable
Item
A repairable item is
an item of supply subject to economical repair for which repair (accomplished
under a repair contract) is considered in satisfying computed requirements
at any inventory level. A major end item (aircraft, ship, combat
vehicle, etc) is not normally considered a repairable item. Examples
of repairable items include, but are not limited to, aircraft engines,
rotors, guidance systems, and electronic circuit boards.
Other Definitions
For additional terms
refer to the Integrated List of Existing Item Unique Identification
(IUID) Definitions and Acronyms, available at the IUID website at Integrated List
of Existing IUID Definitions
(June 8, 2005).
Business Rules
PIPC Reporting
Business Rules
- PIPC does not include
real property, and real property is excluded from IUID reporting requirements.
- PIPC includes only
tangible “personal” property in the custody of the contractor.
The level of reporting varies for different classes of PIPC. The
term PIPC is meant to distinguish tangible personal property in the
custody of contractors from all Government property that is owned or
leased by the Government.
- PIPC – Equipment
reporting – Government furnished Special Tooling, Special Test Equipment,
and other controlled equipment (excluding Contractor Acquired Property
(CAP)).
- Government-furnished
PIPC required for the performance of a contract with a unit acquisition
cost of $5,000 or more.
- Government-furnished
PIPC required for the performance of a contract for which the unit acquisition
cost is less than $5,000 when listed in the clause at DFARS 252.211-7007
(b) (2) (ii) or via DFARS 252.211-7003 (c) (ii) or (iii).
- Initial Report
- Tagged, accountable,
legacy PIPC meeting the requirements of 2) and 3) above.
- Reporting trigger
events include:
- New receipts, including
transfers of Contractor Acquired Property.
- Contract transfers
in place where only the contract number changes.
- When the part number
changes from the initial reporting, e.g., when the part number rolls
due to configuration changes.
- When dispositioned
for the account of the government,
- When a Loss, Damage,
Destruction or Theft (LDDT) event occurs (use of the Government’s
eTools, LDDT, will automatically update the IUID Registry).
- When an item’s
marking changes, e.g. when a 2D mark is placed on an item (primarily
upon delivery from a contractor’s plant).
- Contractor Acquired
Property (CAP) is excluded from the IUID registry. Should CAP
be delivered to the Government as Government Property, or transferred
by contract modification or other contract provision or requirement
to another contract as GFP (including items that are transferred in
place), it is to be reported to the DoD IUID Registry in accordance
with the business rules defined herein.
- PIPC – Material
Reporting – Only Government Furnished Material (GFM) items identified
for installation in an end item, or specifically required under DFARS
252.211-7007 (b)(2)(ii) or via DFARS 252.211-7003(c)(ii) or (iii) will
be reported.
- Initial Report
- Upon receipt of
an item of GFM with an established UII.
- Assignment of the
UII upon receipt of the GFM item without an UII.
- Reporting trigger
events include:
- Contract transfers
in place where only the contract number changes.
- Update to record
that GFM item had been marked with the UII.
- Update to record
installation of GFM item in an end item upon delivery of the end item. (Note:
this update will be part of the WAWF acceptance reporting of the end
item and embedded, subassemblies, etc)
- Repairable Item
– A repairable item is not subject to reporting under DFARS 252-211-7007,
but may be subject to assignment, registration and marking of UIIs under
the provisions of DFARS 252.211-7003 (c) (1) (iii).
PIPC UII Assignment
and Marking Business Rules
- If a UII was
previously established for the property, the contractor shall use the
previously established UII for reporting and marking purposes.
- If Government
furnished property furnished to the contractor by the Government does
not have an established UII and DFARS 252.211-7007 applies, the contractor
must establish a UII and submit the IUID information for the property
to the DoD IUID Registry in accordance with the business rules contained
herein.
- A concatenated Unique
Item Identifier (UII) should be created for existing PIPC using UII
Construct #1, Construct #2, or a DoD recognized IUID equivalent4.
- The asset
identification number, or other unique, innate property control number,
used to track the item may be used in place of the item’s serial number
to assign the UII for incoming Government furnished property that does
not have an established UII, i.e., Construct #1.
- The UII will
use the enterprise identifier of the enterprise establishing the serial
number or, alternatively, the unique property control number, of the
item.
- For repairable
items furnished to a contractor by the Government under a repair contract,
the Government may specify in its repair contract that repairable items
be marked with UIIs upon the completion of their repair in accordance
with DFARS 252.211-7003 and would then be reported as part of the deliverable
requirement of the repair contract.
- If the initial
transfer of CAP is delivery to the DoD as Government Property, the rules
defined in DFARS 252.211-7003, Item Identification and Valuation, shall
be applied when determining the requirement for unique identification.
- Virtual UIIs5
may be assigned to PIPC requiring unique identification, if the property
can be accurately and uniquely identified using existing innate serialized
identity until a trigger event occurs requiring physical marking with
the DoD compliant two-dimensional (2D) data matrix.6
A virtual UII is the UII data elements for an item that have been captured
in the IUID registry, but not yet physically marked on an item with
a DoD compliant 2D data matrix symbol.
- The assigned virtual
UII becomes the permanent UII and the eventual physical mark using the
DoD compliant 2D data matrix symbol when a trigger event occurs that
will require marking the item.
- MIL-STD-130M (or
contractually required later version) applies when physically marking
existing PIPC with the compliant 2D data matrix symbol at a trigger
event. The accountable custodian or the person who has possession
of the PIPC shall use due diligence to maintain the integrity of the
UII, and replace a damaged, destroyed or lost mark with a replacement
mark that contains the same UII data elements, if necessary.
- The required marking
shall be applied to an identification plate, identification band, identification
tag, or identification label securely fastened to the item, or shall
be applied directly to the surface of the item to be compliant.
- For low value items,
provided in bulk, a single UII for the total quantity of an item that
is allocated to a contract may be established when the item is listed
in (b) (2) (ii) of DFARS 252.211-7007. In the event the tag is
removed, the contractor using the item(s) will conform to the specific
procedures for that item for continued traceability of the quantity
expended, and must tag (or bag) and mark the remaining items with the
original UII prior to its delivery or shipment from the contractor’s
plant, under Government instructions, except when shipment is to a subcontractor
or other location of the contractor, or transfer to a follow-on or other
contract.
- Prime contractors
are responsible for ensuring that all personal property that falls under
this set of guidelines that is in the custody of subcontractors is recorded
in the DoD IUID Registry.
Notes on Real
Property
- Contractors
will manage Real Property in the Possession of Contractors using the
official Real Property Inventory (RPI) system of the Military Service
that is responsible for the real property.
- The Military
Services will provide access to their respective RPI systems (and the
necessary user training) to all contractors with custody or control
over their real property.
- Real
property should only be tracked in one property accountability system
at a time.
Chapter 2
Registering
PIPC in the DoD IUID Registry
Accessing the
DoD IUID Registry
The registry is located
on the internet at https://www.bpn.gov/iuid. Prior to using the Controlled
Access portion of the IUID Registry, each user must register in order
to be given login credentials and access rights. Verification of IUID
submission does not require controlled access, but all other functions
do.
Who Must Submit
Data to the DoD IUID Registry?
A prime contractor
whose contract requires IUID submissions, or a prime contractor with
reportable GFP, is required to submit data to the registry including
GFP located at a subcontractor or alternate location.
Submitting
Data to the DoD IUID Registry
The Mark Section
of the DoD IUID Registry
Detailed
guidance on recording marks on PIPC items, especially important when
a PIPC item is classified as military equipment, can be found at GUIDE for End Item
Serialization Marks Registration Version 1
(June 5, 2007)
Chapter 3
Frequently Asked
Questions
| FAQ |
QUESTION
|
RESPONSE
|
| FAQ 1 |
Does DFARS 252.211-7007
apply to repairable items under a repair contract? |
No. Repairable
items would be assigned and marked with a UII and registered in the
DoD IUID Registry only if required by the inclusion of DFARS 252.211-7003
in the repair contract.
However, if the Government
furnished equipment to the repair contractor for performance under the
repair contract, then DFARS 252.211-7007 should be included in the repair
contract and the PIPC equipment would be reported according to the DFARS
252.211-7007 provisions.
NOTE:
(a) FAR 45.107(d)
recognizes that the Government Property Clause is not required for all
repair contracts.
(b) Purchase orders
for property repair need not include a Government property clause when
the acquisition cost of Government property to be repaired does not
exceed the simplified acquisition threshold, unless other Government
property (not for repair) is provided.
|
| FAQ 2 |
Does DFARS 252.211-7007
apply to GFM? |
Yes, when GFM
has a unit acquisition cost of $5,000 or more or is specifically identified
in the contract at 252.211-7007(b)(2)(ii) if unit acquisition cost is
less than $5,000, and only if the GFM is to be installed in a deliverable
end item. |
| FAQ 3 |
Does DFARS 252.211-7007
apply to all Government furnished equipment? |
PIPC equipment
items that require reporting through the DoD IUID Registry include:
- For DFARS 252.211-7007
(b) (2) (i) Tagged Government Furnished Equipment (ST, STE, PE (IPE/OPE)),
APP at the parent level identified in contractor’s property management
systems with an acquisition cost of $5,000 or more, and items under
$5,000 listed in (b) (2) (ii) of DFARS 252.211-7007
- Items become furnished
generally as a result of contractor acquired property being transferred
to a follow-on contract.
|
| FAQ 4 |
When items that
are contractor acquired are transferred to a follow–on contract, do
they require UII? |
This property
becomes GFP upon transfer, so the answer is YES if they meet the
requirements of 211.274-2 otherwise NO unless identified in the Clause
at 252.211-7007(b)(2)(ii). |
| FAQ 5 |
Are updates required? |
Yes. See
252.211-7007(c)(5) “as transactions occur, or at least
semi-annually by March 31 and September 30 of each year”.
Reporting requirements are for “changes” to last reporting period
due to trigger events. All line items do not get reported again.
See also 252.211-7007 (c) (2) (3). 252.211-7007(c) (4) only
applies if required in the contract at 252.211-7003. |
| FAQ 6 |
Must a contractor
re-mark PIPC because of this new requirement? Or if transferred
to a follow-on contract? |
No. The
clause allows a contractor to assign a virtual UII to an item. This
allows you to use your property ID until a disposition trigger event
for delivery back to the Government or another contractor on behalf
of the Government. Transfers from CAP to GFP are for “existing”
items, therefore permissible for assigning a virtual UII. It is
recognized that remarking items for the sake of re-marking, does not
drive “best value” to the government. Innate marking is recognized
in the DoD IUID Registry. |
| FAQ 7 |
What IUID transaction
is required when a transfer of CAP to GFP occurs for reportable items? |
The DoD IUID
Registry transactions would include an “Add” transaction and a “Mark”
transaction. This would add the items as new items to the registry
and identify the “innate” mark or the contractor’s
property identification number. |
| FAQ 8 |
How does the
new reporting requirement differ from the traditional DD Form 1662 Reporting? |
The new reporting
requirement limits the items reportable based on business rules identified
in this IUID Guide for Government Property Reporting. There is no reporting of: Real
Property (land, buildings, utilities); No reporting of Contractor Acquired
Property: no reporting of PIPC under $5000 unless called out in the contract clause
at 252.211-7007(b)(2)(ii); no reporting of contractor acquired material
or government furnished material on hand (stockroom inventory) unless
identified in the contract clause at 252.211-7007(b) (2) (ii).
|
|
| FAQ
9 |
Are we required
to continue DD Form 1662 reporting for legacy contracts? |
Yes, however,
Contractors may volunteer to transition to IUID reporting.
DoD contractors with existing contracts containing DD Form 1662 reporting
requirements are encouraged to request contract modifications to designate
use of the procedures specified in this interim rule as the approved
substitute for DD Form 1662, as permitted by the clause at DFARS 252.245-7001.
See DD Form 1662 Transition
Instructions |
| FAQ 10 |
Are we required
to continue DD Form 1662 reporting after we transition to IUID Reporting |
No. The
DD Form 1662 report is no longer required nor is a “zero” DD Form
1662 required nor input into the Government’s CPMS database.
|
| FAQ 11 |
Clarification
is required in section 252.211-7007(d) (3) (iii), which asks for additional
information than currently required by Mil-Std-129…what does this
mean? |
At this point
in time, abide by the requirements in Mil-Std-129 that are in your contract,
if applicable. MIL-STD-129P w/CHANGE 4, dated 19 September 2007,
contains the most current guidance on how to include the UII in unit
pack labeling. |
| FAQ 12 |
Clarification
is required in section 252.211-7007(b)(4) and (d)(4) and (5) with regard
to parent/child relationships |
Parent/child
relationships are identified at point of delivery if required by 252.211-7003
(reference 252.211-7007(b)(6)) |
| FAQ 13 |
When must a contractor
mark a PIPC item with its assigned UII? |
When the item
is shipped from the contractor’s custody, based upon Government instructions,
and when a GFM item is installed in an end item. |
|
1 The interim
rule (DFARS Case 2005-D015) is available at: http://www.acq.osd.mil/dpap/dars/dfars/changenotice/2007/20070913/E7-18039.htm
2
The memorandum is available at: Policy
Update for IUID of Tangible Personal Property including Property in
the Possession of Contractors
(May 12, 2005)
3
“Government Personal and Real Property in the Possession of the Contractor
(PIPC), Guidance for Industry Transition from the DD Form 1662 in Support
of Defense Federal Acquisition Regulation Supplement (DFARS) 245.505-14,”
dated August 18, 2005.
4
For additional guidance in constructing a UII, refer to the Department
of Defense Guide to Uniquely Identifying Items, the most current version
in effect at the award of the contract, available at http://www.acq.osd.mil/UID/guides.htm.
5
See the Department of Defense Guidelines for the Virtual Unique Item
Identifier (UII), Version 1.2, November 28, 2006, for the process and
rules for constructing, assigning and registering the virtual UII and
for identifying trigger events when items must be physically marked,
available at http://www.acq.osd.mil/UID/guides.htm.
6
A DoD compliant data matrix symbol is encoded using the syntax of ISO/IEC
15434 and the semantics of ISO/IEC 15418 or the Air Transport Association
Common Support Data Dictionary.
