The use of the term Government-Furnished Property (GFP) is less than exact in the defense industry. Generally speaking it is Government-owned stuff that falls into two categories:
- Items sold to the Government that are sent to a contractor for maintenance, repair or overhaul (MRO)
- Equipment and/or material provided to contractors to build or maintain such items
For most contractors, GFP falls into the first category. But there are nuances of the definitions which include Government-owned stuff in these forms, each with its own set of rules for defense contractors to follow:
- GFP end-item that requires service, sometimes referred to a Reparable GFP
- GFP end-item that includes a Reparable GFP embedded-item to be serviced
- GFP end-item into which a new item is to be installed under a new acquisition contract
- GFP which is to be installed in a new acquisition item being sold by the contractor
- Government-Furnished Equipment (GFE) used in either new acquisition or service contracts, which will be returned
- Government-Furnished Material (GFM) provided by the Government for use the manufacture or repair of items under a defense contract
Servicing Reparable GFP items is the most common occurrence of the scenarios listed above. However, a contractor may find themselves in more than one situation at the same time, such as servicing a secure radio in a Hummer. Two different kinds of GFP at the same time.
Items sent to a defense contractor for maintenance, repair or overhaul (MRO) are by their nature generally identified with UID / IUID markings, or should be. This creates three sets of burdens for contractors, who may discover one of the first rules of process IUID-marked GFP when attempting to ship the serviced item back on a Wide Area Workflow (WAWF) Receiving Report (RR). WAWF will likely present an opportunity to learn about the DFARS rule that GFP must be shipped on a Reparable Receiving Report (RRR) because it will generally reject the item which it has found to already exist in the IUID Registry (aka UID Registry). A contractor performing MRO on unmarked GFP items will likely be asked to mark them and register them.
WAWF will sometimes fail to reject UID-marked items shipped on a standard RR, usually because the items are not already in the UID Registry. Good thing? No. Because the effect of this is place the item into the IUID Registry with the date and cost of repair as the item’s cost and date of acquisition, something that will need to be corrected.
Gaining Custody of GFP in the IUID Registry
Shipping serviced items back to the Government is not as simple as just using the Reparable Receiving Report. WAWF will not accept an RRR from a contractor that does not officially have custody of the items according to the UID Registry. So, the first step when receiving reparable GFP is to acknowledge custody of the item(s) in the IUID Registry.
Gaining custody should be done as soon as possible in the MRO process because it may uncover a number of issues that impact the process. Like items not found in the Registry. While this is likely due to factors in the acquisition process, service contracts generally require correction. Besides, there is the regulation requiring use of an RRR for reparable items, and that requires successful custody acknowledgement, which requires dotting all the i’s.
First-time registration of GFP requires the cost of acquisition and date of acceptance. For items not originally sold by the servicing contractor, the contracting officer would be the source of this information. Items that fall under the UID-marking requirements, but lack a part mark, will likely need to be marked during MRO. This requirement should be spelled out in the service contract.
WAWF Property Transfer Transaction
The use of a WAWF Reparable Receiving Report (RRR) is generally conditioned on whether or not a charge occurred for the service. The RRR give the Government the opportunity to accept (or reject) the serviced item and thus trigger payment for the service. The RRR also transfers custody of the item from the contractor back to the Government. A WAWF Property Transfer transaction is used instead when only a change of custody is occurring. This is often referred as a DD1149, after the form used for such purpose prior to WAWF.
There are situations in which a GFP item is returned to the Government via a Property Transfer.
- A reparable item was scrapped
- A reparable item was replaced under warranty
- GFE that contains an item to be serviced, in which case the GFE is returned on a DD1149 while the reparable item is returned on an RRR to authorize payment
- GFE into which a new acquisition item is to be installed
When GFE is installed in a new acquisition UID-marked item it becomes embedded in that item, custody of both are transferred to the Government when upon acceptance of the shipment via a standard WAWF Receiving Report.
Read more about DoD Item Unique Identification (UID).