IUID 101: 4 Key Steps for IUID Compliance in 2019
Editor’s Note: This post has been updated for clarity and accuracy. Last edit September 2019.
Have you ever gone through an organizational frenzy?
You start tidying here and there, and then before you know it, you’re rearranging your kitchen cabinet by container type?
To my roommates’ frustration, I have.
But it’s not just me. The Department of Defense (DoD) is going through some massive changes right now. Only, instead of making sure they know where their soup cans are, they’re making sure they know where billions of dollars’ worth of property is.
So, maybe a little more important.
One important piece of this effort is the IUID Registry. Today, I’m going to give a quick rundown of IUID requirements for contractors, and how contractors can better meet them.
IUID requirements set by DFARS
The Defense Federal Acquisition Regulation Supplement (DFARS) part 252.211-7007 requires defense manufactures to identify, mark, and track serialized assets with a Unique Item Identification (UII). This is achieved by placing a label or plate containing a machine-readable item unique identification (IUID), a 2D Data Matrix barcode, on property under contract.
Additionally, DFARS 252.211-7007 requires contractors to update the IUID information of the serialized government property in their custody with the IUID registry. This can be done either via the WAWF (Wide Area Work Flow) or the GFP Module.
What items need IUID identification?
According to the newest version of DFARS 252.211-7007(b), all serially managed Government-Furnished Property (GFP), regardless of acquisition cost, falls under these requirements.
There are exceptions, however. DFARS 252.211-7007(c) gives the following exceptions:
(1) Contractor-acquired property;
(2) Property under any statutory leasing authority;
(3) Property to which the Government has acquired a lien or title solely because of partial, advance, progress,
or performance-based payments;
(4) Intellectual property or software;
(5) Real property; or
(6) Property released for work in process.
If you have GFP that falls under section (b), and isn’t excluded in section (c), then you have IUID assets! In order to ensure compliance and protect yourself from Corrective Action Requests (CARs), you will need to mark these assets with UID labels (MTL-STD 130 is the standard) and update the status of these assets in the IUID Registry.
We’ll talk about the process for meeting IUID compliance later. For now, let’s learn more about when you are required to report IUID assets to the registry.
When is IUID reporting required?
DFARS 252.211-7007(g)(1) states that contractors are required to update the registry for:
- Changes in status
- Changes in mark
- Changes in custody
- Changes in condition code (for reparables)
- Disposition of items that are
- (i) Received by the Contractor;
- (ii) Delivered or shipped from the Contractor’s plant, under Government instructions, except when shipment is to a subcontractor or other location of the Contractor;
- (iii) Consumed or expended, reasonably and properly, or otherwise accounted for, in the performance of the contract as determined by the Government property administrator, including reasonable inventory adjustments;
- (iv) Disposed of; or
- (v) Transferred to a follow-on or other contract.
Transactions that have been reported or will be reported to Plant Clearance Automated Reutilization and Screening System (PCARSS) or the Lost, Theft, Damaged or Destroyed (LTDD) system do NOT have to be reported to the IUID registry.
DFARS 252.211-7007 (g)(3) states that contractors should update the IUID Registry as transactions occur, or as otherwise stated in the contractor’s procedures. This means you need to make it clear in your property management procedures (which are written and accessible, of course) how often you will update the IUID Registry.
Why is IUID reporting and marking required?
The Department of Defense has implemented IUID requirements in an effort to improve accountability for its property and to comply with financial management reform legislation. These requirements will enable the DoD to achieve a clean FIAR audit and better adhere to financial regulations.
But IUID tracking isn’t just a benefit for the DoD! It may also improve financial and asset management for government contractors. IUID tracking allows for a universal tagging system for GFP. This means you may have an easier time capturing asset data, leading to more accurate asset records.
However, some are skeptical that this can be accomplished. Major changes have been initiated before in the DoD, with mixed results.
Whether you look forward to increased accountability through IUID, or are wary of these big promises, you need to meet IUID compliance in order to continue working with the DoD.
Process for meeting IUID requirements
1. Create a UID label for any newly received assets
When you receive new assets, keep track of which assets fall under IUID requirements. You’ll need to mark these assets as soon as possible. Consult your procedures to determine how quickly you’re required to label new assets.
eQuip users create UID labels in PDF form in the UID Registry section. This video details some of that process:
2. Print UID labels for existing assets
Although IUID requirements have been active for several years now, it’s likely that you have assets that fall under these requirements that have not been properly labeled. This means you’ll need to create labels for these existing assets in order to ensure compliance.
In eQuip, you can import UID label information from the system. This means that if the unlabeled IUID asset is in eQuip, you can easily generate a MIL-STD-130 label for that asset.
3. Verify the labels to ensure quality
It’s important to ensure your labels printed correctly to reduce future errors. Double-check that all vital information on the labels are readable. You may want to test a few labels with a scanner as well.
4. Update the UID information to the IUID registry
Now that your assets have been accurately and thoroughly labeled, it’s time to update the IUID registry. This can be done by bulk uploading a UID Flat File to the Registry via the Wide Area Work Flow (WAWF). If you use eQuip, you can export a Flat File from the system, saving you some time entering asset information.
If you have a long backlog of assets that need to be labeled and added to the IUID Registry, this article may be stressful. You may even be questioning why all of this is important:
“I’ve been behind on this stuff for years! Why should I care about this now?”
While we always support contractors protecting themselves from non-compliance, the coming few years will make non-compliance even more detrimental.
The DCAA and DCMA plan to increase the number of audits completed in 2020 and 2021. This means closer scrutiny on your government property management, and an increased risk of things like CARs.
The eQuip Government Property Management software can help defense contractors to save time, minimize errors, and improve compliance. Learn more about how we help defense contractors meet IUID compliance here.