Similarities and Differences Between Federal Property Accounting and Federal Property Management Michael (Mike) Showers, CPPA Shared Interest PERSONAL PROPERTY FINANCE ACCOUNTS FOR MANAGES NON-CAPITAL ACCOUNTABLE EQUIPMENT NON-CAPITAL EXPENSED PP&E CAPITAL EQUIPMENT REAL PROPERTY SUPPLIES AND MATERIAL CONSTRUCTION IN PROGRESS Differences Between Property Management and Financial Accounting and Reporting • PROPERTY MANAGEMENT – TYPICALLY DOES NOT INCLUDE REAL PROPERTY – PERSONAL PROPERTY • ACCOUNTABLE – 100% OF INVENTORY ON RECORD – 100% OF VALUE ON RECORD – USEFUL LIFE CALCULATION NOT DEPRECIATION • SUPPLIES AND MATERIAL • DOES NOT INCLUDE WORK IN PROGRESS • FINANCIAL ACCOUNTING AND REPORTING – INCLUDES REAL PROPERTY – PERSONAL PROPERTY • CAPITAL PP&E – SUBSET OF ACCOUNTABLE – DEPRECIATED • EXPENSED PP&E • OPERATING MATERIAL AND SUPPLIES • WORK IN PROGRESS SIMILARITIES AND SIMILARITIES AND DIFFERENCES IN DIFFERENCES IN GUIDANCE GUIDANCE Financial Management Guidance CFO Act FASAB Standards/Accepted Financial Standards Agency Implementing Regulations Local Operating Procedures Property, Plant and Equipment • Heritage Assets • Stewardship Land • CAPITAL General PP&E Example – Equipment and Real Property Valued over threshold (Agency discretion) – Not for sale – USEFUL LIFE > 2 YEARS – ALTERNATE USE POSSIBLE • EXPENSED PP&E – Equipment and Real Property Valued under threshold (Agency discretion) Property Management Guidance 40 USC Federal Management Regulation Agency Implementing Regulations Local Operating Procedures Property Legal and Regulatory • 40USC – Maintain adequate inventory levels – Catalog property – Maintain adequate inventory controls and accountability systems – Survey to identify excess – Promptly report excess • FMR – Limited to excess Agency Property Regs • HHS Logistics Management Manual • NASA Procedural Requirements/Policy Directives – 4000 series • DoDI 5000.64 – Accountability and Management of DoD Equipment and Other Accountable Property Recognition - Finance • PP&E recognized (added to records): “Title passes to the acquiring entity or when the PP&E is delivered to the entity or to an agent of the entity.” Record Creation - Property • Usually occurs after: – Receipt, inspection and acceptance • Title may transfer prior to receipt dependent on FOB Point and contract language Contract Property Record Creation • FAR Government Property Clause 52.245-1 • Records are created on title transfer • Title to contract property according to FAR Government Property Clause 52.245-1 may occur at different times – Government furnished property is always Government titled – Contractor acquired property is generally titled to the Government at the earlier of: • Issued for Performance • Processing Commenced • Government reimbursement – Title can be given to non-profit research and educational institutions SFFAS 6 Value Definition • Acquisition cost = Unit price + any other costs associated with putting an item in to performance (Transport, install, assemble) • Present value or book value = acquisition cost less depreciation Different Value Definitions • Federal Management Regulation (FMR) – Normally used to create a property record – Unit Price = the cost of the item itself FMR 102-35.20 “Acquisition cost” means the original purchase price of an item. • DoD 5000.64 Acquisition Cost – The amount, net of both trade and cash discounts, paid for the property, plus transportation costs and other ancillary costs. Financial Equipment Definition • Property, Plant, and Equipment (SFFAS6) – – Tangible – Estimated useful life of 2 or more years – Not intended for sale in the ordinary course of business, – Intended to be used or available for use by the entity FAR Equipment Definition • Tangible item that is functionally complete for its intended purpose • Durable, nonexpendable, • Not intended for sale, • Does not ordinarily lose its identity or become a component part of another article when put into use. • Needed for the performance of a contract • Excludes material, real property, special test equipment or special tooling Different Equipment Definitions • Equipment (NPR Definition) - adds – NASA personal property – Configured as mechanical, electrical, or electronic machines, tools, devices, and apparatuses – Useful life of two years or more – Not consumed or expended in an experiment • DoD 5000.64 adds – Has been acquired or constructed with the intention of being used” Accountable Equipment Examples of INTERNAL PROPERTY REQUIREMENTS • NASA, HHS, DoD • Equipment valued at or over $5,000 • Any sensitive items – DoD Sensitive = Statutory requirements, high value, high tech, hazardous, and arms – NASA/HHS = Subject to pilferage and hazardous Operating Materials & Supplies • Inventory SFFAS 3 – Items held for sale – Excess, obsolete and unserviceable inventory – Inventory held for repair • Operating Materials and Supplies (Consumeables) • Stockpile Materials (held for emergencies) • Seized, Forfeited and Foreclosed property • Different Commodity Categories Example Supply Definitions/Categories • Store Stock – To be consumed in regular business • Program Stock – Items consumed in regular business, spares, acquired for and held by a particular operating activity • Standby Stock – emergency supplies not supported by consumption analysis • Bench stock – locally maintained, small storage areas used to immediately resupply production activities WORK IN PROGRESS (COST ACCUMULATION) LOGISTICS MATERIAL FROM STOCKS TRANSPORTATION PROPERTY RECORD RECEIPT AND ACCEPTANCE FINANCE WORK IN PROGRESS VALUES OF: MATERIAL ISSUED FROM STOCK ACQUIRED MATERIAL EXTERNAL LABOR INTERNAL LABOR OVERHEAD CONTRACTOR OVERHEAD TRANSPORATION INSTALLATION FINISHED PERSONAL PROPERTY ACQUISITION COST OTHER SOURCES PROJECT INTERNAL LABOR OVERHEAD PROCUREMENT ACQUIRED MATERIAL LABOR TRANSPORTATION INSTALLATION CONTRACTOR OVERHEAD Oversight and Management Control Contract Property Requirements • Based on Contract Language – Contract Clauses – Statement of Work – Data Deliverables • Contractors must manage ALL personal Property, not just capital or accountable property • Contractors use their own systems to keep records of property and their own processes to manage it Government Property Clause FAR 52.245-1 • Provides Additional Definitions – – – – Acquisition Cost Equipment Material Property Records • Requires contractors to maintain a system for the management of ALL Government Property – – – – – – Control Use Maintain Preserve Protect Repair Government Property Clause FAR 52.245-1 • Is not intended to implement financial accounting or reporting requirements – Contractor records are “stewardship” or property records – Government maintains any “fiduciary” or financial records • Accounting and cost requirements are implemented in other parts of the FAR – Part 30, Cost Accounting Standards Administration – Part 31, Contract Cost Principles and Procedures Government Property Clause FAR 52.245-1 • Defines 10 “outcomes” covers entire life cycle of property • Allows the Government to perform a Property Management System Analysis (PMSA) • Does not require perfection in cost contracting – Cost contracts must only provide “best effort” to deliver Government requirements • Fixed price contractors must deliver the deliverable or not be paid – Property Management requirements are not deliverables • Contractor performance is obtained through the PCSA process and through enforcement of contract language, e.g. changes in liability for loss Financial Management Control Structure Agency Management IG CFO Financial Management Assurance Office Financial Management Office External Auditor Internal Property Management Control Structure Agency Management Property Management Officer Property Custodian User Contract Property Management Control Structure Contracting Officer Agency PA Management Review PA/Property Management System Analysis Contractor Self Assessment Contract Requirements Property Management System Analysis • Performed by the Property Administrator • Schedule based on risk to Governmen • Utilizes standard review techniques – Based on published, accepted ,methods • DCMA guidance at: http://guidebook.dcma.mil/34/index.cfm