BowtechDan

Don't forget handling govt furnished property if there is any.

52.246-2 Inspection of Supplies (if applicable): (d) If the Government performs inspection or test on the premises of the Contractor or a subcontractor, the Contractor shall furnish, and shall require subcontractors to furnish, at no increase in contract price, all reasonable facilities and assistance for the safe and convenient performance of these duties.

I've heard a few discussions concerning this topic since COVID-19 teleworking began. What does the contract say? If the PC was incidental, then it technically should have stayed on post. I'm assuming the contractor was liable for the incidental GP? Not sure a local unit "Property Pass" takes precedence over the FAR unless it was addressed in the contract. I know one organization in the USAF did a waiver to allow contractors to take PC's off base as and still keep them as "incidental". Either way.....good question for legal.

I've seen and heard the term "AOR" used for Agreements Officer Representative on OTA's and TIA's, but I don't believe the regs and instructions for appointments have caught up to agreements yet (at least in DoD). JMO, but the terms mean the same, but folks will say otherwise in order to bypass the PIEE JAM/SPM requirements.

You might try Army Contracting Command. They deal with many service contracts.

If 1102's knew what a 1910 and 1103 should be doing, that would be a great start.

Has anyone explained the issue to them? Maybe COMM needs to be aware it's a requirement.

Not only the time, but the statement of "all work done" and "all hospital policies & requirements were met". Yikes.

GAR and CARP have been labeled as trash-fish by many. Just sayin.

Karla, on a contract such as LOGCAP, there may be as many as 60-70 COR's. If the contract has multiple, different services where one can't be a technical expert on everything (i.e. construction, power generation, DFAC's, vehicle maintenance, etc), then appointing several CORs are acceptable. As stated, multiple locations are a factor too. From a management standpoint, I've seen where the multiple CORs funnel their activities / surveillance results into one Lead COR.

I've seen a few in DoD. I think it really comes down to what their roles and responsibilities are in the appointment letter. A COR is a representative of the KO and performs the functions needed. If the appointee is going to work a contract and face contractor's, they "should" have the same type training IMO. But offices like to change the person's title as something different than "COR" to bypass the DoDI minimum training and use of CORT. - Technical Monitor (TM) - Technical Inspector (TI) - Quality Assurance Representative/Specialist (QAR/QAS) - Property Administrator (PA)

Robert, (Assuming here you are a contractor) Is the govt paying you for the vehicles, or are you buying the vehicles to perform a service? If the govt is paying you to get vehicles to perform a service, those vehicles "normally" become GFP when you procure them, not wait until the end of the contract. Being a cost-type contract, 52.245-1 is "supposed" to be on the contract. The contractor would then maintain stewardship of those vehicles while the govt has title. The govt is normally self-insured and we don't pay the added expense for insurance. To mitigate that, the -1 clause assumes the contractor will take care of the property IAW an approved Property Management System. And normally, the contractor isn't held liable for damage.......normally. You should contact the contracting officer.

True. But the OP did state: "They found a contract that had a few performance issues written up by the COR and were not happy that the contract did not provide for deducts for these deficiencies. "

52.246-4 Inspection of Services gives you the authority to make deductions: (e) If any of the services do not conform with contract requirements, the Government may require the Contractor to perform the services again in conformity with contract requirements, at no increase in contract amount. When the defects in services cannot be corrected by reperformance, the Government may -- (1) Require the Contractor to take necessary action to ensure that future performance conforms to contract requirements; and (2) Reduce the contract price to reflect the reduced value of the services performed.

On the previous audits you mentioned. what did they keep as audit evidence? Good notes? Print screen? Thank you.

I understand the OP. I was just making a comment in relation to (or lack of) a CLIN to a contract.

I've never read a requirement in black and white on transferring material from CLIN to CLIN. There is a requirement to issue 2 mods and credit and debit costs from one contract to another. At some point, you need to identify how much and when this material is no longer needed and becomes excess. The govt will have title to that material.

Please tell me what part I have said is wrong (most part is accurate). I have never said anything was "junk". I have said some things may be "stuff" and when I say ""stuff", I mean it as equipment that isn't being used toward the contract, but laying around on the installation. If GFP is provided to a contractor to be used for the contract, it should be listed as GFP. It just requires a little work that many don't want to do to do the job right.

Now I understand what you mean by "not clearing the hurdles of 45.102". It sounds like a govt problem with "stuff" accumulating that needs cleaned out. If the property isn't on contract, and isn't needed to support the contract, it's not "contract" GFP.......it's stuff the USAF needs to get rid of from their govt installation. Normally that would be DLA Disposition Services (formerly called "DRMO"), but I don't know what the USAF process for equipment turn-in is.

Looking at USAJOBS and being in the field, 1101's are contracting catch-alls for general contract admin.

Scorpimouse, Yes the govt has fiduciary responsibility. But what govt entity owns the equipment? The USAF? What office/squadron,etc? Did they make the decision to provide GFP IAW PGI 245.103-70? If you are providing GFP to the contractor (KTR) and the contract has 52.245-1 (and subsequent clauses as prescribed), the KTR is required to have a Property Management System of internal controls to manage (control, use, preserve,protect, repair, maintain) our equipment. This equipment should be on a list as an attachment to the contract IAW the PGI 245.1. When the new KTR comes in, the old/new KTR should do an inventory, reconcile any losses,and then the CO would do modifications to transfer the GFP list from the old to the new contract (two mods). As stated in your previous post, the KTR does not take "title" to GFP. When they buy equipment or materials on a cost CLIN and we reimburse them, the title is now to the govt. The KTR has "stewardship" and will manage it IAW 52.245-1 and their property management plan,but we have "title" to it. You mentioned the FIAR. All GFP provided to KTR's shall be included in our (USAF unit who owns the equipment) property books. DoDI 5000.64, ENCL 3 states: 3. PROPERTY FURNISHED TO A THIRD PARTY. Although the Department of Defense may not have physical custody, in order to maintain effective property accountability and for financial reporting purposes, DoD Components shall establish and maintain records and accountability for property (of any value) furnished to contractors as Government furnished property (GFP). This requirement also includes property that is loaned to outside entities such as Federal agencies, State and local governments, and foreign governments. <end> That would be the USAF PBO responsibility. I recommend you find an 1103 Property Administrator in your agency and get this contract back on track in regards to GFP. If the GFP currently on hand is needed to perform the contract, you don't sale it and buy new........you transfer from one contract to another via a mod. But if the GFP isn't officially on the contract, it should be.

I'll disagree with you on spec tolerances are not AQL's. The specs determine a go/no-go range. An AQL is about defects to an extent, but more about allowable variation. When an AQL is between x and y number of defects and still considered good (or acceptable), that is our range or variation. So for construction, our range is "+" or "-" 3 inches. Anything outside of that range is unacceptable. For widgets, we may have a lot of 100 and 2 bad is acceptable, or taxi service may run on time 97-100% and still be acceptable. American Society of Quality defines an AQL as the maximum percentage or proportion of variant units in a lot or batch, for the purpose of acceptance sampling.

Vern, I've seen so many instances of misusing AQL's in service contracts. ANSI Z1.4 usually doesn't apply, but PRS's try to some time! LOL As for AQL's in construction....it's easy. You have specs. Those specs may have + or - ranges. That is your AQL for the task. It's different from acceptance lots of widgets, or "97% of the time" as an acceptable service AQL. Sampling is about efficiency, hence develop and apply efficient procedures ACQuipedia may say no QASP, but the DODIG does. http://www.dodig.mil/pubs/documents/DODIG-2015-059.pdf EDIT: And DAU says otherwise also: https://dap.dau.mil/aap/pages/qdetails.aspx?cgiSubjectAreaID=3&cgiQuestionID=115308 Construction is a service if you look at the Taxonomy of Services: http://www.acq.osd.mil/dpap/policy/policyvault/USA004219-12-DPAP.pdf

C Culham, you are probably right, we're getting hung up on terms. To me, FAR Part 46 is clear, you develop a plan (call it what you want) on how you are going to perform "government contract quality assurance". “Government contract quality assurance” means the various functions, including inspection, performed by the Government to determine whether a contractor has fulfilled the contract obligations pertaining to quality and quantity. - (c) Government contract quality assurance is conducted before acceptance (except as otherwise provided in this part), by or under the direction of Government personnel; - (a) Develop and apply efficient procedures for performing Government contract quality assurance actions under the contract in accordance with the written direction of the contracting office; (emphassis added - do we document this or do we just "word-of-mouth?) - (a) Government contract quality assurance shall be performed at such times (including any stage of manufacture or performance of services) and places (including subcontractors’ plants) as may be necessary to determine that the supplies or services conform to contract requirements. BLUF: Document (develop and apply efficient procedures) how you are going to reasonably ensure we are getting what we pay for. Call that procedure whatever you want.