Tom Ruckdaschel

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A Discussion of DCMA Contract Property Management
Presented By Tom Ruckdaschel
703-428-0994 tom.ruckdaschel_at_dcma.mil
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Overview

• Federal Acquisition Regulation Part 42.302,
  Contract Administration Functions
• (26) Perform Property Administration
• What is Property Administration?
• Regularly reviewing contractor property
  management procedures to ensure they meet current
  contractual requirements performing oversight of
  assigned contractors and completing operational
  audits
• Property Administration does not involve the
  keeping of property records.
• Agency responsibility (DoDI 5000.64)

Our mission is to provide Contract Administration
Services to the Department of Defense
Acquisition Enterprise and its partners to ensure
delivery of quality products and services to the
warfighter on time and on cost.
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Contractor Responsibility

• Contractors have stewardship responsibility for
  property in their possession and are required to
  establish a system to manage (control, use,
  preserve, protect, repair and maintain)
  Government property in its possession. (Federal
  Acquisition Regulations, 52.245-1, Government
  Property Clause)
• Oversight/surveillance/audit of that system is
  conducted by the agency responsible for contract
  administration, e.g., DCMA
• DCMA oversees the contractor ensuring that the
  contractor keeps and maintains records has an
  adequate property management system

Stewardship responsibility The requirement
placed on an individual or organization acting
as the custodian of anothers propertyby
controlling, supervising and managing the
property in their care.
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Oversight Policy Per Current 4161.2-M

• Systems Analysis (Site Visit)
• Large amounts of GP (lt500,000)
• Annual or bi-annual basis (w/3 consecutive years
  of goodness)
• Limited Analysis (Desk Audit)
• Small amounts of GP (gt500,000)
• Site visits every 3 years
• Problem Rigid and inflexible
• Arbitrary requires oversight based on a
  fixed-schedule regardless of true need
• Example
• - Good contractors subject to perpetual
  review
• - Bad contractors not reviewed because its not
  their turn
• Requires oversight based on how much property
  is out there, as opposed to results (how well its
  being managed)
• This strains limited resources
• Costs exceed benefits

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Draft Guideline Under Review

• PAs conduct an annual (once each fiscal year)
  written assessment of all assigned contractors to
  prioritize the performance of each PMSA/desk
  audit
• The assessment is be based on past experience
  with the contractor, current status of the
  contractors property management system and best
  information available
• Determination will be either
• High (PMSA is required)
• Moderate (PMSA may be required)
• Low (PMSA not required)

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Summary/Conclusions

• Annual assessments help plan the workload
• This is where I need to spend my time
• High, Moderate, Low criteria help manage the
  level or resources targeted
• This is how I need to spend my time (Full
  systems analysis, desk audit, site visit?)
• Criteria is not all inclusive PAs can review
  based on special circumstances not addressed in
  the criteria
• High, Moderate, Low determinations do not mean
  Good contractor or Bad contractor
• Contractor systems will still be either adequate
  or inadequate

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Any Questions?