IUID Education and Training Series. IUID Contracting. IUID Center Representative NSWC Corona, IUID Center 2 August 2016

Transcription

1 IUID Education and Training Series IUID Contracting IUID Center Representative NSWC Corona, IUID Center 2 August

2 Housekeeping Please mute your telephone Please use the chat box for questions which are critical to the understanding of the presentation Please submit any question not requiring immediate attention to Questions will be answered as time permits 2

3 Overview Contract clause compliance metrics are being collected The Defense Federal Acquisition Regulation Supplement (DFARS) and Department of Defense Instruction (DODI) are not synchronized yet Do not specify within the contract how the contractor creates Unique Item Identifiers (UIIs) Do not specify within the contract how the contractor encodes the IUID Data Matrix Data Item Descriptions (DID) exist Getting the Contract Line Item Number (CLIN) structure right avoids most IUID problems in contracts Lessons learned 3

4 Contract Compliance Policy has been signed out which: Requires each service/ agency to report their IUID clause* compliance metrics quarterly Directs the Defense Procurement and Acquisition Policy office to perform their own calculations to verify the results * The IUID clause in this case is specifically DFARS

5 Summary IUID Clause Compliance Metrics Note: Total Volume of Contracts and Orders *DLA self-reported 5

6 IUID and the DFARS There are five IUID-related clauses in the Code of Federal Regulation (CFR). All are in title 48 of the CFR in the Defense Federal Acquisition Regulation Supplement (DFARS) Policy for Unique Item Identification Item Identification and Valuation Reporting of Government-Furnished Property Use of Government-assigned Serial Numbers Electronic Submission of Payment Requests and Receiving Reports 6

7 CFR Policy for unique item identification (a) It is DoD policy that DoD item unique identification, or a DoD recognized unique identification equivalent, is required for all delivered items, including items of contractor-acquired property delivered on contract line items (see PGI for guidance when delivery of contractor acquired property is required) - (1) For which the Government's unit acquisition cost is $5,000 or more; (2) For which the Government's unit acquisition cost is less than $5,000 when the requiring activity determines that item unique identification is required for mission essential or controlled inventory items; or (3) Regardless of value for any - (i) DoD serially managed item (reparable or nonreparable) or subassembly, component, or part embedded within a subassembly, component, or part; (ii) Parent item (as defined in (a)) that contains the embedded subassembly, component, or part; (iii) Warranted serialized item; (iv) Item of special tooling or special test equipment, as defined at FAR 2.101, for a major defense acquisition program that is designated for preservation and storage in accordance with the requirements of section 815 of the National Defense Authorization Act for Fiscal Year 2009 (Pub. L ); and (v) High risk item identified by the requiring activity as vulnerable to supply chain threat, a target of cyber threats, or counterfeiting. (b) Exceptions. The contractor will not be required to provide DoD item unique identification if - (1) The items, as determined by the head of the agency, are to be used to support a contingency operation or to facilitate defense against or recovery from nuclear, biological, chemical, or radiological attack; or (2) A determination and findings has been executed concluding that it is more cost effective for the Government requiring activity to assign, mark, and register the unique item identifier after delivery, and the item is either acquired from a small business concern, or is a commercial item acquired under FAR part 12 or part 8. (i) The determination and findings shall be executed by - (A) The Component Acquisition Executive for an acquisition category (ACAT) I program; or (B) The head of the contracting activity for all other programs. (ii) The DoD Unique Identification Policy Office must receive a copy of the determination and findings required by paragraph (b)(2)(i) of this subsection. Follow the procedures at PGI

8 CFR Item identification and valuation (a) Definitions. As used in this clause [ a lot of definitions deleted to make the clause fit on the slide ] (b) The Contractor shall deliver all items under a contract line, subline, or exhibit line item. (c) Unique item identifier. (1) The Contractor shall provide a unique item identifier for the following: (i) Delivered items for which the Government s unit acquisition cost is $5,000 or more, except for the following line items: Contract Line, Subline, or Exhibit Line Item Number Item Description (ii) Items for which the Government s unit acquisition cost is less than $5,000 that are identified in the Schedule or the following table: Contract Line, Subline, or Exhibit Line Item Number Item Description (If items are identified in the Schedule, insert See Schedule in this table.) (iii) Subassemblies, components, and parts embedded within delivered items, items with warranty requirements, DoD serially managed reparables and DoD serially managed nonreparables as specified in Attachment Number. (iv) Any item of special tooling or special test equipment as defined in FAR that have been designated for preservation and storage for a Major Defense Acquisition Program as specified in Attachment Number. (v) Any item not included in (i), (ii), (iii), or (iv) for which the contractor creates and marks a unique item identifier for traceability. (2) The unique item identifier assignment and its component data element combination shall not be duplicated on any other item marked or registered in the DoD Item Unique Identification Registry by the contractor. (3) The unique item identifier component data elements shall be marked on an item using two dimensional data matrix symbology that complies with ISO/IEC International Standard 16022, Information technology International symbology specification Data matrix; ECC200 data matrix specification. (4) Data syntax and semantics of unique item identifiers. The Contractor shall ensure that (i) The data elements (except issuing agency code) of the unique item identifier are encoded within the data matrix symbol that is marked on the item using one of the following three types of data qualifiers, as determined by the Contractor: (A) Application Identifiers (AIs) (Format Indicator 05 of ISO/IEC International Standard 15434), in accordance with ISO/IEC International Standard 15418, Information Technology EAN/UCC Application Identifiers and Fact Data Identifiers and Maintenance and ANSI MH Data Identifier and Application Identifier Standard. (B) Data Identifiers (DIs) (Format Indicator 06 of ISO/IEC International Standard 15434), in accordance with ISO/IEC International Standard 15418, Information Technology EAN/UCC Application Identifiers and Fact Data Identifiers and Maintenance and ANSI MH Data Identifier and Application Identifier Standard. (C) Text Element Identifiers (TEIs) (Format Indicator 12 of ISO/IEC International Standard 15434), in accordance with the Air Transport Association Common Support Data Dictionary; and (ii) The encoded data elements of the unique item identifier conform to the transfer structure, syntax, and coding of messages and data formats specified for Format Indicators 05, 06, and 12 in ISO/IEC International Standard 15434, Information Technology Transfer Syntax for High Capacity Automatic Data Capture Media. (5) Unique item identifier. (i) The Contractor shall (A) Determine whether to (1) Serialize within the enterprise identifier; (2) Serialize within the part, lot, or batch number; or (3) Use a DoD recognized unique identification equivalent (e.g. Vehicle Identification Number); and (B) Place the data elements of the unique item identifier (enterprise identifier; serial number; DoD recognized unique identification equivalent; and for serialization within the part, lot, or batch number only: original part, lot, or batch number) on items requiring marking by paragraph (c)(1) of this clause, based on the criteria provided in MIL-STD-130, Identification Marking of U.S. Military Property, latest version; (C) Label shipments, storage containers and packages that contain uniquely identified items in accordance with the requirements of MIL-STD-129, Military Marking for Shipment and Storage, latest version; and (D) Verify that the marks on items and labels on shipments, storage containers, and packages are machine readable and conform to the applicable standards. The contractor shall use an automatic identification technology device for this verification that has been programmed to the requirements of Appendix A, MIL-STD-130, latest version. (ii) The issuing agency code (A) Shall not be placed on the item; and (B) Shall be derived from the data qualifier for the enterprise identifier. (d) For each item that requires item unique identification under paragraph (c)(1)(i), (ii), or (iv) of this clause or when item unique identification is provided under paragraph (c)(1)(v), in addition to the information provided as part of the Material Inspection and Receiving Report specified elsewhere in this contract, the Contractor shall report at the time of delivery, as part of the Material Inspection and Receiving Report, the following information: (1) Unique item identifier. (2) Unique item identifier type. (3) Issuing agency code (if concatenated unique item identifier is used). (4) Enterprise identifier (if concatenated unique item identifier is used). (5) Original part number (if there is serialization within the original part number). (6) Lot or batch number (if there is serialization within the lot or batch number). (7) Current part number (optional and only if not the same as the original part number). (8) Current part number effective date (optional and only if current part number is used). (9) Serial number (if concatenated unique item identifier is used). (10) Government s unit acquisition cost. (11) Unit of measure. (12) Type designation of the item as specified in the contract schedule, if any. (13) Whether the item is an item of Special Tooling or Special Test Equipment. (14) Whether the item is covered by a warranty. (e) For embedded subassemblies, components, and parts that require DoD item unique identification under paragraph (c)(1)(iii) of this clause or when item unique identification is provided under paragraph (c)(1)(v), the Contractor shall report as part of the Material Inspection and Receiving Report specified elsewhere in this contract, the following information: (1) Unique item identifier of the parent item under paragraph (c)(1) of this clause that contains the embedded subassembly, component, or part. (2) Unique item identifier of the embedded subassembly, component, or part. (3) Unique item identifier type.** (4) Issuing agency code (if concatenated unique item identifier is used).** (5) Enterprise identifier (if concatenated unique item identifier is used).** (6) Original part number (if there is serialization within the original part number).** (7) Lot or batch number (if there is serialization within the lot or batch number).** (8) Current part number (optional and only if not the same as the original part number).** (9) Current part number effective date (optional and only if current part number is used).** (10) Serial number (if concatenated unique item identifier is used).** (11) Description. ** Once per item. (f) The Contractor shall submit the information required by paragraphs (d) and (e) of this clause as follows: (1) End items shall be reported using the receiving report capability in Wide Area WorkFlow (WAWF) in accordance with the clause at If WAWF is not required by this contract, and the contractor is not using WAWF, follow the procedures at (2) Embedded items shall be reported by one of the following methods (i) Use of the embedded items capability in WAWF; (ii) Direct data submission to the IUID Registry following the procedures and formats at or (iii) Via WAWF as a deliverable attachment for exhibit line item number (fill in), Unique Item Identifier Report for Embedded Items, Contract Data Requirements List, DD Form (g) Subcontracts. If the Contractor acquires by subcontract, any item(s) for which item unique identification is required in accordance with paragraph (c)(1) of this clause, the Contractor shall include this clause, including this paragraph (g), in the applicable subcontract(s), including subcontracts for commercial items. 8

9 CFR Item identification and valuation (a) Definitions. As used in this clause [ a lot of definitions deleted to make the clause fit on the slide ] (b) The Contractor shall deliver all items under a contract line, subline, or exhibit line item. (c) Unique item identifier. (1) The Contractor shall provide a unique item identifier for the following: (i) Delivered items for which the Government s unit acquisition cost is $5,000 or more, except for the following line items: Contract Line, Subline, or Exhibit Line Item Number Item Description (ii) Items for which the Government s unit acquisition cost is less than $5,000 that are identified in the Schedule or the following table: Contract Line, Subline, or Exhibit Line Item Number Item Description (If items are identified in the Schedule, insert See Schedule in this table.) (iii) Subassemblies, components, and parts embedded within delivered items, items with warranty requirements, DoD serially managed reparables and DoD serially managed nonreparables as specified in Attachment Number. (iv) Any item of special tooling or special test equipment as defined in FAR that have been designated for preservation and storage for a Major Defense Acquisition Program as specified in Attachment Number. (v) Any item not included in (i), (ii), (iii), or (iv) for which the contractor creates and marks a unique item identifier for traceability. (2) The unique item identifier assignment and its component data element combination shall not be duplicated on any other item marked or registered in the DoD Item Unique Identification Registry by the contractor. (3) The unique item identifier component data elements shall be marked on an item using two dimensional data matrix symbology that complies with ISO/IEC International Standard 16022, Information technology International symbology specification Data matrix; ECC200 data matrix specification. (4) Data syntax and semantics of unique item identifiers. The Contractor shall ensure that (i) The data elements (except issuing agency code) of the unique item identifier are encoded within the data matrix symbol that is marked on the item using one of the following three types of data qualifiers, as determined by the Contractor: (A) Application Identifiers (AIs) (Format Indicator 05 of ISO/IEC International Standard 15434), in accordance with ISO/IEC International Standard 15418, Information Technology EAN/UCC Application Identifiers and Fact Data Identifiers and Maintenance and ANSI MH Data Identifier and Application Identifier Standard. (B) Data Identifiers (DIs) (Format Indicator 06 of ISO/IEC International Standard 15434), in accordance with ISO/IEC International Standard 15418, Information Technology EAN/UCC Application Identifiers and Fact Data Identifiers and Maintenance and ANSI MH Data Identifier and Application Identifier Standard. (C) Text Element Identifiers (TEIs) (Format Indicator 12 of ISO/IEC International Standard 15434), in accordance with the Air Transport Association Common Support Data Dictionary; and (ii) The encoded data elements of the unique item identifier conform to the transfer structure, syntax, and coding of messages and data formats specified for Format Indicators 05, 06, and 12 in ISO/IEC International Standard 15434, Information Technology Transfer Syntax for High Capacity Automatic Data Capture Media. (5) Unique item identifier. (i) The Contractor shall (A) Determine whether to (1) Serialize within the enterprise identifier; (2) Serialize within the part, lot, or batch number; or (3) Use a DoD recognized unique identification equivalent (e.g. Vehicle Identification Number); and (B) Place the data elements of the unique item identifier (enterprise identifier; serial number; DoD recognized unique identification equivalent; and for serialization within the part, lot, or batch number only: original part, lot, or batch number) on items requiring marking by paragraph (c)(1) of this clause, based on the criteria provided in MIL-STD-130, Identification Marking of U.S. Military Property, latest version; (C) Label shipments, storage containers and packages that contain uniquely identified items in accordance with the requirements of MIL-STD-129, Military Marking for Shipment and Storage, latest version; and (D) Verify that the marks on items and labels on shipments, storage containers, and packages are machine readable and conform to the applicable standards. The contractor shall use an automatic identification technology device for this verification that has been programmed to the requirements of Appendix A, MIL-STD-130, latest version. (ii) The issuing agency code (A) Shall not be placed on the item; and (B) Shall be derived from the data qualifier for the enterprise identifier. (d) For each item that requires item unique identification under paragraph (c)(1)(i), (ii), or (iv) of this clause or when item unique identification is provided under paragraph (c)(1)(v), in addition to the information provided as part of the Material Inspection and Receiving Report specified elsewhere in this contract, the Contractor shall report at the time of delivery, as part of the Material Inspection and Receiving Report, the following information: (1) Unique item identifier. (2) Unique item identifier type. (3) Issuing agency code (if concatenated unique item identifier is used). (4) Enterprise identifier (if concatenated unique item identifier is used). (5) Original part number (if there is serialization within the original part number). (6) Lot or batch number (if there is serialization within the lot or batch number). (7) Current part number (optional and only if not the same as the original part number). (8) Current part number effective date (optional and only if current part number is used). (9) Serial number (if concatenated unique item identifier is used). (10) Government s unit acquisition cost. (11) Unit of measure. (12) Type designation of the item as specified in the contract schedule, if any. (13) Whether the item is an item of Special Tooling or Special Test Equipment. (14) Whether the item is covered by a warranty. (e) For embedded subassemblies, components, and parts that require DoD item unique identification under paragraph (c)(1)(iii) of this clause or when item unique identification is provided under paragraph (c)(1)(v), the Contractor shall report as part of the Material Inspection and Receiving Report specified elsewhere in this contract, the following information: (1) Unique item identifier of the parent item under paragraph (c)(1) of this clause that contains the embedded subassembly, component, or part. (2) Unique item identifier of the embedded subassembly, component, or part. (3) Unique item identifier type.** (4) Issuing agency code (if concatenated unique item identifier is used).** (5) Enterprise identifier (if concatenated unique item identifier is used).** (6) Original part number (if there is serialization within the original part number).** (7) Lot or batch number (if there is serialization within the lot or batch number).** (8) Current part number (optional and only if not the same as the original part number).** (9) Current part number effective date (optional and only if current part number is used).** (10) Serial number (if concatenated unique item identifier is used).** (11) Description. ** Once per item. (f) The Contractor shall submit the information required by paragraphs (d) and (e) of this clause as follows: (1) End items shall be reported using the receiving report capability in Wide Area WorkFlow (WAWF) in accordance with the clause at If WAWF is not required by this contract, and the contractor is not using WAWF, follow the procedures at (2) Embedded items shall be reported by one of the following methods (i) Use of the embedded items capability in WAWF; (ii) Direct data submission to the IUID Registry following the procedures and formats at or (iii) Via WAWF as a deliverable attachment for exhibit line item number (fill in), Unique Item Identifier Report for Embedded Items, Contract Data Requirements List, DD Form (g) Subcontracts. If the Contractor acquires by subcontract, any item(s) for which item unique identification is required in accordance with paragraph (c)(1) of this clause, the Contractor shall include this clause, including this paragraph (g), in the applicable subcontract(s), including subcontracts for commercial items. 9

10 Data Item Descriptions Current and previous versions (for reference) are available at: DI-MGMT-81803, 19-Jul-2011, IUID Marking Plan DI-MGMT-81804A, 12 Feb-2013, IUID Marking Activity, Validation, and Verification Report DI-MGMT-81858, 12-Jan-2012, IUID Marking and Verification Report *No account is required for using the "Quick Search" 10

11 Defining Requirements for IUID Determining what to uniquely identify End items Embedded items Ensuring items are properly described Determining where to place marks Ensuring marks are applied, inspected, and recorded 11

12 Who s Job is it Anyway? Program Managers What is the strategy for managing system components? Engineers What needs to be tracked for engineering analysis? How should we mark these parts? How do we want marks verified? Logistics Managers What needs to be tracked across the maintenance lifecycle? Property Managers Which items are accountable property? Do we have traceability of GFP? Do we have Special Tooling or Special Test Equipment? Financial Managers How will I track costs to items? Contracting Officers Have we identified what is to be delivered and marked? Do the line items track to the deliverables? Are the IUID and WAWF clauses included and complete? Do we have inspection criteria defined? 12

13 Line Item Life Cycle Requirement Requirement identifier Item Number Description Quantity Unit of Issue Specs and Standards Descriptive Identifiers (e.g. NSN, Type Designation, PN) Delivery date Ship to GFP Provided Funding data (AAI/LOA) Contract Contract Number Item Number Description Quantity Unit of Issue Specs and Standards Descriptive Identifiers (e.g. NSN, Type Designation, PN) Delivery date Ship to GFP Provided Contract Type Unit Price Payment provisions Funding data (AAI/ACRN/LOA) Delivery Contract Number Item Number Description Quantity Unit of Issue Descriptive Identifiers* (e.g. NSN, Type Designation, PN) Unit Price Date Delivered GFP embedded UII RFID Invoice Contract Number Item Number Quantity Unit of Issue Unit Price Date Delivered Contract Type Unit Price Payment provisions Funding data (AAI/ACRN/LOA) Invoice Number Invoice Amount 13

14 Early example of use of line items (c2037 BCE) 6 pairs of *** linen and green-yellow leather boots. 17 pairs of *** boots 7 pairs of soft green-yellow boots 1 pair of dyed gall-nut leather boots 15 pairs of green-yellow leather sandals 10 pairs of soft green-yellow leather sandals By the hand of Lugulla, duplicate tablet of Nurilli, inscribed at Drehem, on the 9th month of the first year SU-SIN became king. 14

15 It s All About Getting the Line Items Right So, what is a line item? It has a single unit price. The item shall have a single unit price or a single total price. It is separately identifiable. A contract line item must be identified separately from any other items or services on the contract. It has a separate delivery schedule. It has a single accounting classification citation. 15

16 Separately Identifiable Supplies: no more than one National stock number (NSN); Item description; or Manufacturer's part number. Services: no more than one Scope of work; or Description of services. 16

17 Using a Single SOW for Multiple Deliverables If there are multiple line items citing the same Statement of Work, Statement of Objectives, or Performance Work Statement, Then the line items should be for different delivery dates or performance periods, or There should be a clear delineation in Section C as to which tasks belong to which line item. Example: Item 0002 The contractor shall provide the ABC component of the XYZ system in accordance with Paragraphs 6.1 through 6.8 and 9.1 through 9.3 of Attachment 1, Specification for XYZ system, dated 31 March

18 How to Know if the Line Items are Properly Constructed Items should be bought the way they will be delivered, shipped, accounted for and managed. Performance or delivery must not be divisible except by the quantity, i.e. if you will deliver part of one unit separately, it needs to be a separate item. Thus: A shipment must contain a whole number quantity of each line item delivered and; The total of the shipment quantities should match the line item quantity. 18

19 10 Basic Questions 1. What do we expect the contractor to deliver (list hardware, services, software, and data)? 2. Do we have a line item, assigned to each in section B? 3. When is each item due to be delivered? 4. How much will the contractor get paid? 5. Are there interim payments before delivery? If so, on what basis? How are billings apportioned across funding lines? 6. When will the contractor get paid? What documentation will be required to effect payment? 7. How is the timing of contract payments related to deliveries? 8. Is it clear in the line item structure and sections F - I how payments relate to delivery? 9. What constitutes acceptable performance? How is it measured? 10.How do the inspection and acceptance criteria in section E relate to the answers to 9? If you can t answer these questions, do not sign the contract. 19

20 IUID Contracting DOs DFARS in solicitations and contracts for supplies Specify CLINs the clause applies to Identify any embedded components that are subject to IUID Include DFARS clause for the use of WAWF/iRAPT Ensure each deliverable has a separate CLIN, SLIN, or ELIN and a defined delivery schedule Ensure inspection and acceptance criteria are defined DFARS in solicitations and contracts with GFE 20

21 IUID Contracting DON Ts Do Not lump dissimilar units of issue together as a lot or kit Do Not specify a particular IUID construct which must be used Do Not require the contractor to use Government-assigned identifiers for enterprise, part, or serial number Do Not impose unusual payment or acceptance procedures through poorly structured CLINs, SLINs, and ELINs Do Not use a prior contract award as a template without ensuring it is properly constructed 21

22 IUID Resources OSD UID Policy Office Website Trusted site for policy (DoD Instructions, Directives, Publications, DFARS Clauses, Memorandums and Standards) DoD Procurement Information Website Trusted site for implementation information (Marking, Registering Items, Contracting, etc.) MIL-STD 129 (current version is R as of Feb 2014) Marking standards and requirements for shipping and storage MIL-STD 130 (current version is N, Change 1 as of Nov 2012) Marking standards and requirements for items DoD Guide to Uniquely Identifying Items (currently v3.0 as of Dec 2014) Business rules, additional guidance for implementation IUID Helpdesk iuid.helpdesk@dla.mil 22

23 QUESTIONS & ANSWERS 23