OUSD(AT&L) Acquisition Resources & Analysis (ARA)
Property and Equipment Policy
DoD Property Accountability Update
Mrs. Amber Propert, CDFM, CPPS
Office of the Under Secretary of Defense
(Acquisition, Technology, and Logistics)/Acquisition
Resources & Analysis, Property & Equipment Policy
Office
June 24, 2014
Agenda
 Valuation of Department of Defense Assets
 Existence & Completeness of Mission Critical Assets
 Government Furnished Property Material Weakness
Correction
 Accountable Property System of Record
 Sustainment
General Property, Plant and Equipment (GPP&E)
as of FY 2013 (Net Book Value with dollars shown in Millions)
Assets Under
Capital Lease
$194
0%
Other
$1,034
0%
Land
$10,781
2%
CIP
$46,636
7%
Buildings,
Structures, &
Facilities
$141,786
22%
General Equipment
$36,706
6%
Leasehold
Improvements
$236
0%
Software
$2,986
1%
Military Equipment
$399,253
62%
Source: FY 2013 DoD Agency Financial Report (AFR) / DoD Performance and
Accountability Report (PAR), page 97
68% of DoD’s GPP&E is General and Military Equipment
3
ME & GE Weakness & History
9/30/2006
Weakness: Process and controls to
account for the quantity and value of
military equipment are not effective.
• Baseline ME
values
established
• CAMS-ME utilized
for reporting and
assertions
8/31/2009
• Comptroller deemphasized MEV
outlining audit
readiness
priorities
9/30/2009
• CAMS-ME shut
down
• Components
instructed to
develop own
reporting process
5/30/2011
Bottom Line – Valuation is still
required per the Accounting
Standards and is a significant
risk to DoD Audit Readiness
Success
4
• BCA published.
FASAB has not
been approached
to change
standard to date
Today
• Nov 2013 FIAR
Plan Status
Report states
valuation to be
performed.
Elimination of ME, Capitalization Threshold for GPP&E
Joint Signed Memo 09/20/14
Combine ME
with GE
• ME Definition Rescinded
• ME will be reported as “General Equipment” beginning Fiscal Year 2014
Increase Cap
Threshold for
GPP&E
• Raise from $100,000 to $1 million for Air Force and Navy General Fund assets
• Raise from $100,000 to $250,000 for remaining DoD for all IUS & other GE for
General and Working Capital Funds
• Changes to be implemented prospectively starting 10/1/2013
Increase Cap
Threshold for
Real Property
• From $20,000 to $250,000 for all new Real Property assets and modifications
• Changes to be implemented prospectively starting 10/1/2013
Conduct
Valuation for
new GPP&E
Conduct
Valuation for
Legacy Assets
5
•
•
•
•
For assets placed into Service 10/1/2013 & after
Follow FIAR guidance for adequate supporting documentation
Value assets using expenditure data if processes and systems support
OK to estimate asset costs if systems and processes can’t support accumulating
expenditure data by asset
• First priority is assets with a Net Book Value remaining by September 30, 2017
• Validate values and ensure adequate supporting documentation (as prescribe by
FIAR guidance)
• Must be completed by 09/30/2017
• Secondary priority is fully depreciated assets. Validate value and supporting
documentation for fully depreciated assets
Valuation and Audit
 Financial Improvement and Audit Readiness (FIAR)
Efforts
– Valuation is scheduled as Wave 4 of 5 total audit readiness
phases
– Wave 4 Expectations
• Justify how the acquisition value was determined
• Tied to Existence & Completeness (E&C) and property accountability
– When: Audit Ready Deadline mandated by NDAA FY10 of
September 30, 2017
Existence and Completeness Mission Critical Assets
 E&C is Wave 3 of the 5 FIAR phases
 DoD Property must be property recorded on accountable
records
 Includes all asset types
– General Property, Plant, and Equipment
• Real Property
• Equipment and other Personal Property
– Inventory
– Operating materials and supplies
 Every asset must have an DoD accountable property
record and vice versa
FIAR Guidance – Wave 3 Existence & Completeness
In order to assert to Audit Readiness, Component management
must satisfy financial statement assertions:
Existence
• Reported assets actually exist at a given date
Completeness
• All assets are properly recorded in the Component’s Accountable Property System of Record (APSR)
Rights and Obligations
• Reporting entity claims it has the rights to and “owns” the equipment, and has documentation to support its
“rights”
Presentation and Disclosure
• Assets are consistently categorized, summarized, and reported from period to period in accordance with DoD
guidance and Federal financial reporting standards
8
Documentation for Assertion – Existence
Management
Asserts:
Auditors
Examine:
Reported assets exist
Complete Asset Listing
from APSR
Documentation
proving asset
existence
Process
documentation
detailing how periodic
verification of asset
listing is performed
APSR Asset Listing
reconciles with
financial statements
Documentation
regarding the actual
performance of
inventories, including
wall-to-wall efforts

Physically
Verified
9
Documentation for Assertion – Completeness
Management
Asserts:
All assets meeting
definition of capital
equipment have
been recorded and
reported

Recorded
in APSR
Auditors
Examine:
Reconciliation of
Financial
Statements to
APSR Asset
Listings
Program Offices
activity and
Procurement
Budgets
Review “floor to
book” samples
from Physical
Inventories
Receiving and
acceptance
documentation
10
Documentation for Assertion – Rights & Obligations
Management
Asserts:
Auditors
Examine:
DD250
Notional example
Management has the
rights to and “owns” the
equipment and has
documentation
supporting its assertion
Receiving and
acceptance
documentation (e.g.,
DD250, DD3161,
DD1149)
Contract terms and GFP
listings in contracts
Receiving Report
Notional example
Preponderance of Use
documentation
11
E&C Status Update
 As of November 2013 FIAR Plan Status Report, 53% of mission critical
assets (ME, GE, OM&S, and inventory) are either under audit, have been
validated as audit ready, or have asserted audit readiness
 P&EP collaborates with Components by monitoring and providing
support with FIPs and Assertion Packages
 USD (Comptroller) established a completion date, 30 June 2016, for
E&C assertion; Department is well positioned to meet assertion date
Component Quick Win E&C Accomplishments
Total Equipment: $414.1B (NBV)
NBV in Billions
Total Asserted
63%
Remaining
37%
Assertion
Date
Assessable Unit
Assertion Made
Total Equipment
Air Force
$84,155,176,000
$95,827,947,000
87.82% 10/31/2010
Army
$0
$103,447,710,000
0% 12/31/2013
Navy
$176,918,479,722
$199,990,133,000
$1,098,073,509
$0
-
$640,972,302
$0
-
$262,812,701,533
$414,088,500,000
SOCOM
MDA
Total Military Equip
12
% of
NBV
88.46%
63.47%
Note 1 – Army has recently submitted their 12/31/13 assertion for GE in PBUSE.
9/30/2010
E&C Audit Readiness
 Deadline set for asserting to audit readiness for E&C
mission critical assets
– June 30, 2016
Earlier than the
full Audit
Readiness
deadline!!!
Government Furnished Property
 Government Furnished Property (GFP) is tied to audit
readiness, financial reporting, and property accountability
 Numerous audits have shown DoD weaknesses in
dealing with GFP
 OSD(AT&L) declared a material weakness over GFP
accountability in 2011
Bottom Line Up Front
 Not enough progress to meet deadlines, especially 2017
 Need stronger senior level engagement by the Services’
leadership
 Dual Track problem:
– Current/future business process updates
– Legacy clean up of property records
 Many issues over many domains need coordinated
support by all leadership (blame frequently falls on
logistics; problems begin in acquisition and flow through
contracting)
Government Furnished Property (GFP)
Definition:
(FAR 45.101 Definitions)
• Government-furnished property means property in the
possession of, or directly acquired by, the Government and
subsequently furnished to the contractor for performance
of a contract. Government-furnished property includes, but
is not limited to, spares and property furnished for repair,
maintenance, overhaul, or modification.
• Government-furnished property also includes contractoracquired property (CAP) if the contractor-acquired property
is a deliverable under a cost contract when accepted by the
Government for continued use under the contract.
GFP consists of both:
Equipment (expectation is to receive back intact)
Material (expectation is these items consumed or embedded)
GFP Data Points
GFP has been significantly under reported
 Estimates of GFP population is UNKNOWN
 DCMA administers $160B worth of contracts containing the property
clause, no confidence this amount equals an amount in any Service
financial statement. Service administered contracts (e.g. Naval
shipbuilding contracts) with GFP have no estimated dollar amount.
 IUID Registry GFP Study estimates $41B worth of government
property in the possession of contractors. Completeness of IUID
Registry data UNKNOWN
 Air Force Audit estimated $22B unaccounted as of January 2010.
Approx. $2B added since 2012.
 OM&S Material dollar values are current UNKNOWN
 Components have not established GFP baselines (“we don’t know
what we don’t know”)
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History
 Until 2006, FAR stated contractor records would be
official records of property
– Goes against financial principles
 FAR 2007 update corrected language
 DoDI 5000.64 (2006) added supporting language
requiring property records
 FIAR gains momentum in 2010; deadlines set by
Congress for 2017
 Department-wide Material Weakness declared in FY2011
Statement of Assurance
GFP – Get Well Plan
Immediate
(1) Stop the
bleeding.
(2) No GFP
should be
furnished
without PCO
first meeting PGI
245.103-70
(Cost Benefit
Analysis)
Short Term Intermediate
(1) Identify
contracts ending
within one year
(1) Identify
contracts going
beyond one year
(2) Plan for
property
disposal;
contractors use
PCARSS for
excess property
(2) Ensure GFE
reported to IUID
registry
(3) Use fillable
PDFs for GFE
listing
(4) Modify
contracts as
needed to add
GFE listing
Long Term
(1) Update local
policy and
procedures;
sustainment &
compliance
OSD Corrective Action Plan/Methodology
We asked for:
We explained:
• Services to include GFP in the
Financial Improvement Plans
• Participation in the quarterly GFP
working group
• Standard methods of data
requests/retrieval from
contractors
• Contracts to be modified to
include mandatory property
clauses
• GFP lists to be added in contracts
where such lists were deficient
(serves as substantiating
documentation for rights/
obligations on older assets)
• Metrics
• How to execute
• Use of audits performed on
contractors
• Stratifying by risk, contract age,
likelihood of property existence
• Expectations of metrics and
reporting of progress
• How to establish and report
metrics on methodology progress
Specific milestone status on following slides
Milestones – 3Q 2011 through 3Q 2012
OSD provides Methodology (3Q11)
• Completed January, 2011
DoD 4140.1-R update (1Q12)
• Pushed back several times by L&MR and WHS. Published 1Q14
GFP Working Group meetings (1Q12)
• Consistently happening every quarter
DoD 4161.02 update (2Q12)
• Published in April, 2012
Metrics for reporting developed (2Q12)
• Provided in 2012.
• Services now complying 2014.
Components begin existence and completeness testing (3Q12)
• Discovery phase underway; not all are GFP focused
DFARS cases on GFP to finalized and published (3Q12)
• Final clause update published August, 2012
Milestones – 4Q 2012 through 4Q 2013
GFP electronic transactions (4Q12)
• WAWF property transfers (Delayed)
• Industry asked for more time; clause says 2014
• Services slow in adopting; USMC leading implementation, Air Force close behind
• Contract systems provide data to WAWF (Partial)
• Systems compliant with Procurement Data Standard are 100%; All others need work.
• DCMA transactions through eTools (Accomplished)
OSD to provide gap analysis to DCMO (4Q12)
• Gaps have been identified. Awaiting A2R updates for implementation
DAU to update Industrial Property Courses (1Q13)
• Completed 2Q12; new IND 105 and 205 material
OSD to review metrics, assertion packages, etc. for Component progress (3Q13)
• In progress. Delayed to 2016 per Comptroller/FIAR direction
OSD to publish GFP CONOPs (4Q13)
• Completed with update to DoDI 4161.02 (2Q12). Referenced as the GFP Manual in the Instruction.
Issues
 Comptroller functions have high insistence of 100% accuracy of ALL
information in property systems. Impedes path forward by “waiting
for perfection”
 Components still insist on going to contractor facilities to perform
inventories. Highly disruptive: costly in both time and money, effects
contract performance for job #1
 Contractor site visits meant to cover all Government interests; too
difficult to coordinate among Components. Overall is ineffective and
disruptive
 GFP reported data in IUID Registry is not complete enough for use
by Components; encouraging ‘short cuts’
 Contracting officers (1102 series) are inconsistent in applying all
mandatory clauses per FAR, DFARS
 Level of “trust” of work performed in auditing contractors is lacking;
contrary to OSD methodology
 Non-DCMA administered contracts have far different levels of effort
and management; often lacking in compliance with DoDI 4161.02
Manual information due to competing guidance from parent Service
 Size of administration workforce impedes efforts (too few 1103)
Current Efforts
 Training is being developed regarding new clauses, GFP
management, personnel, etc.
– P&EP conducting Topical Webinars related to GFP
• May 2014 – Statisical Sampling, Government Property Clause,
• June 2014 – FAR vs DoD Regulation & Instruction
 FAQ entries are being written and maintained on the web
for access to both DoD and Industry
 WAWF and DPAS have developed functionality to
electronically manage GFP information; generally
Components slow to adopt.
OSD Senior Leadership Involved!
 Components are briefing the GFP Material Weakness
Senior Official in Charge and the Director, DPAP on:
–
–
–
–
What is Component’s plan for GFP accountability?
What activities have been accomplished?
What are near term milestones?
Is Component on track to make these milestones and 2017 audit
readiness deadline?
– What are any issues/obstacles standing in the way of successful
completion?
– What additional OSD guidance/assistance is needed?
– How are you measuring progress/current status (metrics)?
GFP and the APSR
 DoD property must have an accountable record for
fiduciary and managerial purposes
 Accountable records are kept in an Accountable Property
System of Record (APSR)
Accountable Property System of Record
 What is an APSR?
– An Accountable Property System of Record (APSR) is defined in
detail as: the business system/application used to account for and
maintain accountability of government property. This
system/application represents the authoritative official records for
the government entity regarding the property it is responsible for
and reflects the appropriate updates to the property as a result of
life cycle transactions. To ensure data integrity, there must be one
and only one system of record for a given piece of property. The
APSR is a subsidiary ledger to the financial systems general
ledger and represents the history of all transactions impacting the
property and its value.
What does an APSR do?
 An APSR holds the most current record of an asset’s status.
– This can include the condition, who has it, where it is, and how much it cost.
– Many systems hold information about property, so a conscious decision must be
made about which system or record is primary, i.e. accountable.
– The accountable record information must then be exported into a financial system
to complete the financial reporting process.
– Beware: if there is more than one system reporting accountable information about
a piece of property you may get double or even triple reporting of that information.
 An APSR can be specific to the type of property but does not have to
be. It is the data maintained that makes a difference.
– An APSR can maintain data for just equipment or it can maintain data for
equipment, inventory, and real property.
– The final output is data that will be used in financial reporting.
– There can be many systems, and many property systems, but only one set of
accountable data. Since the accountable data is coming from one source, that
source is the system of record for the property.
What does the APSR definition mean for my property?
 Your government property can be in different APSRs depending on
what your property is and how your data is maintained.
– The type of data that must be maintained for an equipment item is not identical to
the data maintained for a consumable item. This may require two or more
separate systems or modules to maintain all types of property information.
 The DoD path forward is pointed to getting an enterprise system that
can do all transactions, especially those of a financial nature.
– The APSR information has a direct impact to the financial data contained in these
enterprise systems.
 Since multiple modules or systems maintain records of property, it is
important to identify the system(s) that holds the accountable record
to be used for fiduciary purposes.
– Once these systems or modules are identified as holding the accountable
information, we will have a higher degree of assurance that the property is only
being counted once in our financial information.
APSR and Contractors
 Contractors are not expected to know the differences in
DoD accounting of property. Their responsibility is proper
care, use, and following the contract terms. It is the
responsibility of the DoD to maintain this data prior to
sending property or establish the data upon delivery.
 Contractors are not APSR system owners. The DoD
must not be beholden to a non-commercial solution or to
a single company which may control the software at
large.
 Contractors are not APSR users. They may provide the
DoD data, but they are not the ultimate responsible party.
In order to maintain checks and balances, it is
inappropriate for a contractor to directly edit data within
an APSR.
30
APSR in Policy
 40 U.S.C. Section 524
– Each executive agency shall maintain adequate inventory controls and
accountability systems for property under its control
 DoDI 5000.64
– Heads of the Components shall establish accountable property systems of record
(APSR); ensure the integration with core financial and other systems and
processes, particularly those for logistics and acquisition.
– Accountable Property Officers shall ensure electronic interfaces are used between
the APSR and mandated enterprise systems (e.g., Wide Area Workflow).
– Third party property management or accountability systems, such as custodial
systems, shall not supersede or replace the APSR or the accountable property
records maintained by the Department of Defense.
– APSR is defined as: the Government system used to control and manage
accountable property records; a subset of existing organizational processes
related to the lifecycle management of property; the system that is integrated with
the core financial system.
 DoD 7000-14 (Financial Management Regulation)
– Broadly categorized as a “Feeder System”
– APSR used throughout Volume 4, Chapter 6 in the context of recording property
data
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Connections
 APSR must have DoD property data for audit.
 Full audit must be complete by 2017.
 Quality property management is essential to audit
readiness (fundamental basis of E&C).
 Leadership is essential for success.
 “And miles to go before I (we) sleep…”
DoD IG Audits on Property
 DODIG-2014-054 - Defense Logistics Agency Land and Maritime Paid Too Much
for High Mobility Multipurpose Wheeled Vehicle Repair Parts
 DODIG-2014-038 - Air Force Life Cycle Management Center Could Not Identify
Actual Cost of F119 Engine Spare Parts Purchased From Pratt and Whitney
 DODIG-2013-105 - Navy Did Not Develop Processes in the Navy Enterprise
Resource Planning System to Account for Military Equipment Assets
 DODIG-2013-080 - Better Oversight and Accountability Needed for the U.S. Army
Special Operations Command C-12 Aircraft
 DODIG-2013-026 - Supply Support Activities in Afghanistan Could Be Managed
More Effectively to Improve Inventory Accountability
 DODIG-2013-025 - Accountability Was Missing for Government Property
Procured on the Army's Services Contract for Logistics Support of Stryker
Vehicles
 DODIG-2013-018 - Deliveries and Payments for the Defense Advanced GPS
Receivers Met Contract Terms, but Property Accountability Needed
Improvements
 DODIG-2012-139 - Improvements Needed in Transparency and Accountability of
U.S. Army Reserve Component Equipment Transfers (Redacted)
Audits related to GFP
General Accountability Office (GAO) GAO-04-779, Navy Needs to Improve the Management Over GovernmentFurnished Material Shipped to Its Repair Contractors, July 23, 2004
US Army Audit Agency (USAAA) Report No. A-2005-0126-FFE, Management of Government Furnished Property,
U.S. Army Garrison, Fort Hood, Texas, dated, Mar 4, 2005
GAO Report No. GAO-08-316R. Subject: Defense Logistics: The Army Needs to Implement an Effective Management
and Oversight Plan for the Equipment Maintenance Contract in Kuwait, dated January 22, 2008
DoD Inspector General (DoD IG) Report No. 2009-089, Internal Controls Over Government Property in the
Possession of Contractors at Two Army Locations, dated June 18, 2009
USAAA Report No. A-2009-0183-ALL, Applying Agreed-Upon Procedures to Determine if There Was a Potential for
Theft of Property and Loss of Funds to the Government Due to the Actions of a Government Property Administrator,
dated August 14, 2009
USAAA Report No. A-2010-0018-ALL, Audit of Management and Visibility of Government Property Provided to the
Contractor Performing Bulk Fuel Operations in Kuwait, dated December 17, 2009
Air Force Audit Agency Report No. F2010-0005-FB3000, Government Furnished Equipment Financial Statement
Reporting, dated January 11, 2010
USAAA Report No. A-2010-0133-FFE, Time Sensitive Report - Accountability of Contractor Acquired Property, Audit of
Planning for Disposal of Chemical Demilitarization and Storage Facilities, dated July 13, 2010
DoD IG Report No. D-2010-088, Accountability and Disposition of Government Furnished Property in Conjunction with
the Iraq Drawdown – Logistics Civil Augmentation Program, dated September 30, 2010
FIAR Audit Readiness
Audit Readiness efforts ARE NOT JUST
for being Audit Ready!
Its about “Day to Day” business
processes & improving Operational
Readiness by:
•
•
•
•
Eliminating Losses
Eliminating Excess Acquisitions
Increase Asset Utilization and
Increase productivity through Standardized
Processes
• Financial transactions accurately reflect business
activity
What are we doing now
 Analyzing and improving business processes
 Establishing procedures
 Correcting deficiencies
 Maintaining documentation
 Using technology (systems, AIT, electronic forms)
 Educating the organization
Where are we going
 Short term goals
– Audit readiness efforts
• E&C
• Valuation
• Supporting Documentation
– Establishing baseline property records
 Long term goals
–
–
–
–
Repeatable processes
Continuous improvement
Educated workforce
Consistent application of policy
How do we maintain the course
 Statistical sampling
 Physical inventory techniques
 Collaboration between disciplines
 Open communication
 Evaluate for improvement
 Annual training requirements
 Self assessments
 Tone from the Top to Bottom
Accountability Path Forward
Four Concepts to making accountability
manageable and approachable:
1.
Processes: the “how-to” of management
2.
Systems: the “tools” of management
3.
Records: the “documentation” of management
4.
Methodology: ways to improve processes, systems, and
records
Processes
Examples of processes for how DoD manages and is
accountable for government property:
– Acquisition
 FARS and DFARS regulations
– Issues and returns, distribution techniques, utilization
– Physical inventories
 At a minimum, every three years for unclassified and
non-sensitive property per DoDI 5000.64
– Operating procedures
– Disposition
Systems
– Helps demonstrate how DoD maintains control and accountability
over assets. Examples include:
 Accountable property systems of record (APSRs)
 Accounting systems
 Logistics systems
 Supply systems
 Maintenance systems
Per DoDI 5000.64:
– DoD Component Heads shall establish APSRs and ensure the
integration with core financial and other systems and processes
(acquisition and logistics)
– Accountability is to be established and maintained using
information technology; the use of automatic identification
technologies is mandatory
Accountable Property System of Record (APSR)
– Should have sufficient capability to maintain records
suitable for audit
– An important tool in managing accountable property
records, which can include:





Any stock record account
Organizational record
Installation property book
Clothing and equipment record
Any file that supports and/or documents property
accountability
APSR requirements are located in DoDI 5000.64
Records
– All actions that affect an item typically have some form of
record to accompany it. Examples include:





Standard forms, e.g. DD250
Custodial records, inventory documents, bills of lading
Accountable property records
Maintenance logs
Usage logs (e.g. flight hours, miles driven, operational hours)
– Per DoDI 5000.64, accountable property records must:
 Be kept current and available
 Reflect current status, location, and condition of all assets until
disposition
 Provide a suitable audit trail of all transactions
Methodology
DoD approach: continuous process improvement
– Analysis of day to day business should be regularly performed to
develop maximized management maturity
– Improving methodologies gives higher accountability of assets,
taxpayer confidence, and stewardship.
 Do we have the appropriate personnel in place to ensure
operational efficiency?
 Are adequate controls in place to ensure compliance with laws
and regulations, protection against fraud, waste, and abuse, and
reliability of financial and accountable data?
 Are the records kept in an accessible way?
 How many steps are in this process to reach the end?
Can we prove our accountability over property with an audit?
Testing our Processes and Methodology
Audits
– A financial audit examines records tied to accounting
practices and economic transactions
– Performance audits show how well day to day processes
are executed
Audits can help identify ways to improve methodologies
by showing strengths and weaknesses in processes,
systems, and records.
DoD Audits
DoD audits focus on management’s assertions:
– Does the equipment recorded in the financial statements
exist (can we go out and touch it)?
– Can equipment be traced from its physical location to a
financial or accountable property record?
– Does DoD have rights (ownership, etc.) to the equipment
or obligations (liabilities) on the equipment?
Transaction Audits
– An audit trail is a transaction-based history of asset activity,
including:




Receipt and acceptance
Modifications
Improvements
Individual additions and deletions, for all accountable property
throughout its life cycle
– Must include dollar value, maintenance, and adjustments so that the
quantity and dollar value on the accountable property record
reconciles with the general and subsidiary financial ledgers
– Records must continuously document the status of the personal
property, from receipt through all stages of the life cycle
Takeaways
 Lots of progress has been made
 Current efforts are on the right path
 Still more work to be done
 Leverage AIT and System improvements
 Maintain a knowledgeable workforce
 Cross-functional approach to processes
 Continuous improvement of accountability
 Important to everyone; lead by practice
When we each do our part
 Remember… 3 legged stool
Audit Readiness and Accountability
Logistics
Program Offices
Questions? Comments?
Contact us at:
Amber.L.Propert.civ@mail.mill
For general questions
and information,
visit our website:
http://www.acq.osd.mil/pepolicy/
Thank You!
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