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Property on Base IDIQ


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There is a ongoing debate among my fellow Property Administrators about whether or not GFP (and if CAP is allowed) should be tracked and reported on the Base IDIQ and not the individual Task Orders (TO).

Due to reporting that was / is required (Annual & Quarterly - with Quarterlies only for property that meet capitalization threshold) and with some contracts having many TO's, a decision was made to allow Contractors to report all contract property on the Base IDIQ, and not on the task orders. This reduced the number of reports that were submitted, along with much manual labor on the Governments end for processing those reports.

I don't believe that is the correct way to track property, and have never done so. The way it's always been presented to be is to look at the Base IDIQ as a "catalog of services" of sorts, with the TO's being where the work is performed, hence the property would be tracked on the TO.

I also liken it to a Program vs.  Project, where the Program is the overarching, "umbrella" so to speak, and the project is the meat and potatoes.

Additionally, although the Base IDIQ states minimums, in order to execute those minimums, a TO has to be generated to execute.

Although I cannot find a FAR definition of Base IDIQ outside of what is stated in 16.500, Subpart 16.5-2 states the three "types" of IDIQ's, further indicating that the Base is not the appropriate location to track / report property.

I thought I've seen in some of the research that I've done where tracking on the Base ... should not be done (I want to say it said not to, but I can't locate that / those references). 

I'm interested in the groups opinions and if there is anything out there that can provide some additional clarification, whether that be FAR, DFARS, or even Red Book.

Thanks in advance for the time to read and respond!

 

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1 hour ago, Jeff D. said:

There is a ongoing debate among my fellow Property Administrators about whether or not GFP (and if CAP is allowed) should be tracked and reported on the Base IDIQ and not the individual Task Orders (TO).

Due to reporting that was / is required (Annual & Quarterly - with Quarterlies only for property that meet capitalization threshold) and with some contracts having many TO's, a decision was made to allow Contractors to report all contract property on the Base IDIQ, and not on the task orders. This reduced the number of reports that were submitted, along with much manual labor on the Governments end for processing those reports.

I don't believe that is the correct way to track property, and have never done so. The way it's always been presented to be is to look at the Base IDIQ as a "catalog of services" of sorts, with the TO's being where the work is performed, hence the property would be tracked on the TO.

I also liken it to a Program vs.  Project, where the Program is the overarching, "umbrella" so to speak, and the project is the meat and potatoes.

Additionally, although the Base IDIQ states minimums, in order to execute those minimums, a TO has to be generated to execute.

Although I cannot find a FAR definition of Base IDIQ outside of what is stated in 16.500, Subpart 16.5-2 states the three "types" of IDIQ's, further indicating that the Base is not the appropriate location to track / report property.

I thought I've seen in some of the research that I've done where tracking on the Base ... should not be done (I want to say it said not to, but I can't locate that / those references). 

I'm interested in the groups opinions and if there is anything out there that can provide some additional clarification, whether that be FAR, DFARS, or even Red Book.

Thanks in advance for the time to read and respond!

 

I don't know what the rule is, but the GFP attachment form for DoD has a block for the contract number and order number. See here

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14 hours ago, Jeff D. said:

Thanks in advance for the time to read and respond!

My quick thoughts -

Is not the rule FAR 45.106?

Is not the base IDIQ a contract and subsequent TO/DO's separate contracts ? 

Is not the rule supported by FAR 52.245-1 and its reference to "contract" especially when read commensurate with FAR 52.216-22 which in part says "delivery or performance shall be made only as authorized by orders issued in accordance with the Ordering clause..." support the rule? 

I would note that if your "decision" to account for GFP (and CAP_ on the base IDIQ  is documented as a contract term/condition that in essence deviates from the standard FAR principles and clauses then tracking and reporting on the base could be an option.

Or as alternative if GFP and maybe CAP where "ordered" and made applicable across the entire IDIQ that might work as well.

My thoughts are based on the operation of the IDIQ itself pursuant to its clauses without any real knowledge of property administration rules yet I get the gist of of what your OP is looking for responses on. 

Also it would seem that as part of the acquisition team, you as property administrators, should be visiting with the applicable CO's and program folks about your dilemma so that future IDIQ's can be crafted and awarded where life is made easy for all including the contractors.

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Apologies for the late replies. 

@Retreadfed I’m not sure the program people know for sure. When they’re writing the IDIQ’s, they’re putting in all the clauses and stating that property either may be issued (GFP) or purchased (CAP). Any list that’s generated is at the TO level. 

As stated in my original post, prior to my arrival on the team, there had been a decision by a few to ‘reduce’ the amount of reports that needed to be submitted to a single report (as we have some IDIQ’s that have mid double digit TO’s on them) instead of all the TO reports. So I gather that where in the process it was known, I don’t think I made any difference, as all contractors were being told they could do this. As also previously mentioned, this was something I’d never done as a contractor, and even if I could, the material management systems I used wouldn’t let me. 

As for the contractor identifying property needed, for GFP the govt provides a list that the contractor can negotiate on, but as for CAP, that’s decided at the time of performance.

@Don Mansfield Thanks for the reference. I’m not with  DoD or a affiliated Agency that subscribes to the DoD framework (I would be so much better if we did, but that’s another story). I do know about the toolbox but oftentimes forget about it. Need to do better with that, as there is   a lot of good information there. I will have a look at the reference and see how I might be able to use it. We're really in the baby steps of getting processes, procedures, and SOP's in place, so I'm looking for anything that I don't have to create from scratch to work with.

@C Culham Yes, rule is at 45.106

Yes, the Base and TO/DO’s are separate contracts. 

Yes, there is some supporting language in 52.545-1, but to your other points, I’d forgotten about Subpart 16.5 where it talks about the work being issued off of the TO/DO’s, and I think that’s where I saw it once before. 

The PA side really isn’t all that complicated, except for the way this Agency does it. I’m a CO on the team working as a PA, but also as a BA / BPI for the team on developing processes / procedures / SOP’s for the team and as a part of an acquisition wide initiative to improve accountability and recordkeeping, as it’s all a manual process now.

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