Aerospace Industries Association
Mission and Advocacy
NPMA NES, Anaheim, CA June 2014
What is AIA?
• Founded in 1919, the Aerospace Industries Association is the most
authoritative and influential trade association representing the
aerospace and defense industry.
• Comprised of more than 330 aerospace and defense manufacturers
and suppliers.
• AIA is at the forefront of critical issues, such as advocating for robust
federal budgets for aerospace and defense, as well as a strong U.S.
industrial base.
What does AIA do?
• AIA is the voice of the aerospace, defense, and homeland security
industry, representing the nation’s leading manufacturers
• AIA shapes public policy that ensures the U.S. aerospace, defense,
and homeland security industry remains preeminent and that its
members are successful and profitable in a changing global market.
• AIA establishes industry-wide consensus on issues and solutions to
aerospace and defense industry concerns.
AIA Initiatives:
Second To None
• Our campaign continues to focus
on reaching elected officials and
candidates for office with factbased information with one
underlying message :
• America’s economic and national
security, our competitiveness and
our ability to innovate in the
future must be protected
See more at:
http://secondtonone.org
AIA Initiatives:
National Aerospace Standards
• What is an NAS/NA standard?
– “NAS” stands for National
Aerospace Standard. The NA prefix
is for Metric standards. NAS
standards include Part Standards
for high strength, precision
fasteners.
• What is an NASM/NAM standard?
– AIA, in coordination with the
Department of Defense, has
converted over 500 MIL-spec's to
NAS. These converted documents
carry a “NASM” (for inch based) or
“NAM” (for Metric based) prefix.
The standard continues to be
procured to the MS part number.
AIA Initiatives:
Team America Rocketry Challenge
• Our 2014 Champions:
– Creekview High School
of Canton, Ga
See more at:
http://www.rocketcontest.org/
AIA Initiatives:
National Aerospace Week
• National Aerospace Week was
established by the Aerospace
Industries Association in 2010
• An opportunity for the aerospace
and defense industry and its
supporters to recognize the
enormous contributions that the
industry makes to the U.S.
economy and global
competitiveness.
See more at:
http://nationalaerospaceweek.org/
AIA Organization
•
CEOs of our member companies and their senior managers define and drive our agenda.
•
We work together through our councils, committees and working groups to shape regulatory and
legislative policies
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AIA has four policy divisions:
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Civil Aviation,
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National Security & Acquisition Policy
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Space Systems
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International Affairs,
Four supporting divisions:
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Legislative
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Communications,
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Membership Services Corporate Events
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Financial Services.
National Security & Acquisition Policy oversees 8 councils, which in turn supervise the work of their
associated committees.
Organization of the National Security and
Acquisition Policy Division
• NS&AP has 8 Councils:
– CFO
– Procurement and Finance
– Technical Operations
– Business Technology
– National Security Policy
– Workforce Policy
– Supplier Management
– Industrial Security
NS&AP Procurement & Finance Council
Committees
• Procurement & Finance Council Committees
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Executive
Cash Flow
Cost Principles
Government Property
Intellectual Property
Procurement Techniques
Legal
• Procurement & Finance Council Working Groups
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Cost of Regulation
Counterfeit Parts
Commercial Items
Overseas Contracting
Government Property Systems
Committee (GPSC)
•
What is the GPSC?
– Committee charged by the
Procurement and Finance Council
responsible for activities, laws and
regulations affecting facilities and
property (both contractor and
government) of member companies.
– Chair: Tamra Zahn, CPPA Boeing
– Vice Chair: Pam McFarland, CPPM
Raytheon
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GPSC Representation:
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Lockheed Martin
Deloitte
General Electric
Rockwell Collins
Bombardier
Harris Corporation
BAE Systems
Honeywell
Raytheon
Northrop Grumman
Aerojet
United Technologies
Sikorsky
SAIC
ATK
General Dynamics
Rolls Royce
GPSC Activities
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DCMA CAR Policy
DFARS 2011-D055 Item Unique Identifier
DOSAR Part 645
PCARSS Wish List
FAR/DFARs Review
Resources
DCMA CAR Policy
• DCMA Instruction 1201
– Updated Dec, 2012
DCMA CAR Policy
• Chapter 2, Para. 2.1.2.1, specifically directs that the ACO be responsible
for issuance of Level III and Level IV CARs.
• Chapter 3, Para. 3.6, Level II and above CARs will not be issued to
subcontractors. Level II and above CARs will be sent to the Prime CMO for
issuance to the Prime contractor.
• Contractor Business Systems Rules per DFARS 242.70 are incorporated in
Chapter 4 of the instruction. (Significant Business System deficiencies are
to be documented at a minimum at Level III CAR, leading to payment
withholding).
• Chapter 3, Para. 3.1.1 no longer exempts all CAFU from the CA instruction.
(Only "deficiencies identified in DCAA Audit reports for Accounting,
Material Management and Accounting Systems, and Estimating Systems
that are not significant" are exempted from the CA Instruction.)
• Requirement for escalation of CARs when a contractor is unwilling or
unable to effect corrective action have been added to 3.13.
• Requires the use of the agency CAR eTool.
DCMA CAR Policy
• Industry Concerns
– Early 2013 comments submitted to AIA’s
Procurement and Finance (P&F) Executive
Committee
– P&F realized that many functions were impacted
– Decision made to submit one response from AIA
versus multiple comments from multiple
committees
– DCMA held a public (limited) meeting to hear
from industry
DCMA CAR Policy
• CAR Policy Updated again Sep 2013
– When DCMA discovers a noncompliance at a subcontract level, the
appropriate level CAR shall be issued to the prime contractor. When DCMA
discovers a noncompliance requiring a Level I or II CAR at a subcontract level,
the appropriate CAR (Level I or II) shall be issued directly to the subcontractor
with notification to the prime contractor via the prime CMO…… In situations
where a noncompliance(s) at the subcontract level meets the criteria for a
Level III CAR, the CAR shall be issued to the prime contractor.
– Added: In situations where a systemic lack of prime control of subcontractors
exists (for example: recurring subcontractor noncompliances), or if a
subcontractor is unwilling or unable to implement effective corrective action,
DCMA will issue a CAR to the prime contractor. The CAR will be issued by the
DCMA office cognizant of the prime.
DCMA CAR Policy
• New Add: Note: Noncompliances discovered by DCMA
personnel at alternate contractor locations that are part of
an overall corporate structure, shall be addressed to the
management of the alternate location (for the purposes of
the contracted actions). For example, if the ABC
Corporation in Sunnyvale, CA is the contract receipt point
for a USAF contract and some of the work is being
performed at the ABC Corporation facility in Denver, CO via
an Interdivisional Work Order and that effort has been
delegated to the supporting DCMA CMO in Denver, DCMA
personnel shall issue CARs directly to ABC Corporation in
Denver, CO for noncompliances observed while performing
the delegated surveillance.
DFARS 2011-D055 Item Unique Identifier
• Proposed Rule published June 15, 2012
• Final Rule published Dec 16, 2013
• Purpose:
– Revise the prescription and the clause 252.2117003 to update and clarify instructions for the
identification and valuation processes.
DFARS 2011-D055 Item Unique Identifier
• Specific Changes:
– Revised the section heading to: Item Unique
Identification And Valuation (Dec 2013) vs. Unique
Item Identification and Valuation
– Added definition for “Data Matrix” and Type
“Designation”
– Para C added an option to list “exceptions” to
reporting of deliverables when listed in the
contract
DFARS 2011-D055 Item Unique Identifier
• Added a 4th criteria under section 4
– (iv) Any item of special tooling or special test
equipment as defined in FAR 2.101 that have been
designated for preservation and storage for a
Major Defense Acquisition Program as specified in
Attachment Number ll.
DFARS 2011-D055 Item Unique Identifier
• Added a 4th criteria under section 4
Exceptions
allowed
– (iv) Any item of special tooling or special test
equipment as defined in FAR 2.101 that have been
designated for preservation and storage for a
Major Defense Acquisition Program as specified in
Attachment Number ll.
New
New
DFARS 2011-D055 Item Unique Identifier
• Added a 4th criteria under section 4
– (iv) Any item of special tooling or special test
equipment as defined in FAR 2.101 that have been
designated for preservation and storage for a
Major Defense Acquisition Program as specified in
Attachment Number ll.
NEW
DFARS 2011-D055 Item Unique Identifier
• Added in red
– (e) For embedded subassemblies, components,
and parts that require DoD unique item
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 or associated
with, the Material Inspection and Receiving
Report specified elsewhere in this contract, the
following information:
DFARS 2011-D055 Item Unique Identifier
OLD
• (f) The Contractor shall submit the information required by paragraphs (d) and (e) of this
clause in accordance with the data submission procedures at
http://www.acq.osd.mil/dpap/pdi/uid/data_submission_information.html.
New
• (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 252.232-7003. If WAWF is not required by this contract, and the
contractor is not using WAWF, follow the procedures at
http://dodprocurementtoolbox.com/site/uidregistry/.
(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
http://dodprocurementtoolbox.com/site/uidregistry/; 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 1423.
DFARS 2011-D055 Item Unique Identifier
REMOVED ALTERNATE I (DEC 2011)
As prescribed in 211.274-6(a)(4), delete paragraphs (c), (d), (e), (f), and (g) of the basic clause,
and add the following paragraphs (c) and (d) to the basic clause:
(c) For each item delivered under a contract line, subline, or exhibit line item under paragraph (b)
of this clause, in addition to the information provided as part of the Material Inspection and
Receiving Report specified elsewhere in this contract, the Contractor shall report the
Government’s unit acquisition cost.
(d) The Contractor shall submit the information required by paragraph (c) of this clause in
accordance with the data submission procedures at
DOD Working Group
• Continuous Support to Ensure Win-Win
• Key Topics 2013/2014
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Use of the GFP smart attachment in solicitations and contract award
DoD serialized vs non-serialized responsibility and determination
Electronic shipment and receipt of GFP to contractors (e.g. WAWF, DLMS, etc.)
Responsibility assignment for documenting GFP to contractors (i.e. CO, or
Component Item Managers)
– CAP reporting
– DoD is making minimal progress in meeting policy requirements and
compliance
Department of State Acquisition Regulation
(DOSAR) Part 645 Government Property
Final Rule published Dec 16, 2013/effective Jan 15, 2014
Changes were adopted to ensure that the DOSAR conforms to
Federal Acquisition Regulation (FAR) changes.
• It added a new DOSAR clause at 252.245-70 regarding the
reporting of the status of the Offerer’s Government Property
Management System.
• It identifies specific information required for that reporting.
Department of State Acquisition Regulation
(DOSAR) Part 645 Government Property
• In addition, DOSAR clause at 252.245-71 discusses how, when
and to whom reports are to be submitted, including a
timetable for submitting quarterly reports.
• It identifies the specific types of property to be reported and
their designated classifications. (Not the same as those
identified in the FAR)
• Specific required data elements are identified.
• It spells out the wording for the affirmation of the physical
inventory and that it is to be supplied to the customer
annually.
PCARSS Wish List
1.
2.
3.
4.
Simplify the flat file process. Give the users the capability to upload a flat file straight from
Excel (.xls or .xlsx). Remove the need to convert the template to three separate .csv files
and then consolidate the .csv files into a .txt file. This Request will allow more users to
utilize the flat file process.
Send out automated emails to the Property Location POC email and the Prime Contractor
POC email when the status of a case changes. Right now, we have to periodically review
PCARSS to see if any statuses have changed for all our cases. If we received an email upon
status change, it would save time for the users and let them know to take action. The
second part of this Request would be to include the applicable documents in the email.
Add the capability for user to export the information on the Active/Draft/Inactive screens to
Excel. Fields to export: Schedule Reference Number, Contract Number, Case Number, Case
Established Date, Submitted Date, Disposition Date, Remaining Items, Total Items,
Remaining Acquisition Cost, and Status.
Provide users read-only access to past plant clearance cases that are no longer available in
PCARSS.
PCARSS Wish List Cont.
5. Automatic notification to prime when a PCC has been relegated to another PLCO.
6. Add the UII to the flat file schema to reduce manual input of the UIIs, this also helps with the
disposal action in the IUID registry.
7. Display the gaining contract number on the transfer schedule generated after the info is
submitted.
8. Develop a check box that would indicate serially managed if checked. Currently, if one enters
a serial number in the serial # field, the item goes on the DoD serially managed listing
regardless of whether the items is designated as serially managed.
9. It would be nice for the Prime contractor to be notified of the Plant Clearance activity taking
place at a sub as it happens, such as a notification back when items are physically scrapped.
• DFARS 2014-D021
Current FAR/DFARS
Watch List
6/13/2014
– IUID Prescription Correction
– Correction to the prescription for DFARS 252.211-7003
• DFARS 2014-D005
– Detection and Avoidance of Counterfeit Electronic Parts-Cont’d
– Further implements section 818 of the NDAA for FY 2012
• DFARS 2012-D042
– Business Systems Compliance
– Revises business systems clauses to include contractor reporting and
documentation requirements regarding contractor compliance with
DFARS business systems criteria.
– DFARS 252.245-7003 Contractor Property Management System
Administration is not included
Property Plan/Industry Leading Practices
Property Plan Template
• Updated and Revised !
• 05/14/2014 - On AIA website.
Industry Leading Practices
• 51 published
• 05/14/14 – archived #10-04 & minor edit #1104
Resources and Tools
Click “Connections”
Click “For Suppliers”
Click “Gov’t Property
Management
Standards”
Resources and Tools
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AIA Property Management Plan (Template)
This document is a template that your company may use to better manage government property. This template is an overview of what
constitutes commonly held best practices for the aerospace and defense industry. It is not a legal document and should not be viewed
as such. These guidelines are required by FAR 52.245-1 Government Property.
AIA Self Assessment Metrics Definitions, Guidelines & Tools
These guidelines, definitions, and metric tools are considered Industry Leading Practices on the performance of Contract Property
Management Self Assessments and measuring the health of a property management system. Based on the maturity of the property
management system, an entity must determine which metrics they will utilize and in turn which of these documents, will be used in
whole or part.
AIA Industry Leading Practices
These Industry Leading Practices (ILP) are documented to assist in the establishment and performance of contract property
management plans, processes, and systems. When implementing these ILPs, an entity may utilize all or part of these practices.
Guideline for Contractor Self Assessment for Government Owned Property
This guideline creates an Industry standard for Contractor Self Assessment process (CSA) for Government Property management to
comply with the FAR 52.245-1 Government Property, while providing reasonable assurance in assessing the effectiveness of a
contractor’s property management system.
Subcontractor Flow Down Terms & Conditions Template
This guideline provides suggested language for standardizing a prime contractor’s flow down requirements to a subcontractor or
supplier that possesses Government owned property.
Supplier Surveillance Standard Form for Performing Subcontractor Assessments
This form provides a standard template for obtaining supplier information in assessing the health, strength, and compliance of a
supplier’s property management system.
http://www.aia-aerospace.org/connections/for_suppliers/government_property_standards/
Questions?