How to Report Embedded Items to the IUID Registry: A Quick Guide
It seems nothing gives government property managers more heartburn than managing IUID assets.
On January 1, 2004 IUID became a requirement on all DoD solicitations. Since then, the DFARS requirements have seen several changes meant to clarify the contractor’s responsibility…but in some cases led to more confusion.
The uncertainty has only increased with DoD system launches and changing reporting requirements involving WAWF, iRAPT, eTools and the GFP Module.
I’d like to shed a little light on the subject. This article will focus on helping property managers understand how they can report embedded items to the IUID registry. I will explain what needs to be reported depending on the contract, as well as how to report these items.
Let’s get started.
Embedded Items: Complications for Reporting
To create an item useful for our armed forces, complex defense systems often require many critical components. This means contractors creating these items must track several components. For example, contractors regularly need to track and report on asset parent/child relationships when they have contracts that require assembly/manufacture of an end item, or modification/repair of an existing item.
Tracking subassemblies, components, and parts embedded in an asset can be a daunting task. Efficiently and accurately keeping track of these “parent/child” relationships on a spreadsheet or basic asset tracking tool can be nearly impossible.
Once you add in IUID registry requirements, you can see how difficult it can be to meet all requirements.
Let’s cut through some of the confusion. How does a contractor know what to report to the IUID registry?
What Do I Need to Report?
What reporting requirements a contractor needs to follow will depend on the nature of the contract. Nowadays, DoD contracts to deliver an end item will always contain the DFARS clause 252.211-7003. The requirement and any related attachments and schedules must be reviewed by the government property manager to understand what action needs to occur. In general, all delivered items with a value greater than $5,000 must have a unique item identifier and be reported to the IUID registry.
However, customers are commonly identifying items valued under $5,000 they want to be marked with an UID and reported to the registry. Additionally, paragraph (c)(1)(iii) of this clause states “Subassemblies, components, and parts embedded within delivered items, items with warranty requirements, DoD serially managed reparables and DoD serially managed nonreparables” may also need to be uniquely identified and reported to the registry.
DoD contractors that receive Government Furnished Property (GFP) will find DFARS clause 252.211-7007 in their contract. There has been a lot of confusion about what needs to be reported to the registry under this requirement but simply put, since January 1, 2014 contractors have been required to report all furnished property not covered by an exception. See paragraph (c) of this clause to review exceptions.
Contractors executing repairs, modifications, and updates to defense systems will need to report qualifying transactions to the IUID registry. Transactions include:
- Embedded Items
- Mark Maintenance
- Shipments (Disposition)Another Contract
- Another Contractor (not Sub)
- To the Government
- End of Life/Reintroduction
Certain embedded item transactions must be reported. Specifically, the contractor must report details to the IUID registry when an item is embedded into a parent item, the item is removed from a parent item, or when the item is removed from one parent item and placed into another parent item. Depending on what tool is used as the system of record, trying to manage this data can feel like trying to juggle chainsaws and axes.
Also, be advised paragraph (g) (3) of 252.211-7007 states “The contractor shall update the IUID Registry as transactions occur or as otherwise stated in the Contractor’s property management procedure.” Maura Lachance (DCMA, Supervisor – Property) clarified this requirement at an NPMA NES 2018 IUID workshop, “If your Property Management System Policies and Procedures are silent on when you will perform transactions in the IUID Registry, your PA will expect to see them posted as transactions occur.” Make sure your PMS Policies and Procedures stipulates when you will report to the IUID registry.
How to Report to the IUID registry
The WAWF RR
Whether the assets are delivered end items or GFP dictates how the contractor ultimately reports to the IUID registry. Contractors no longer submit DD250’s to initiate invoicing for delivery of end items. They are now largely required to use the Wide Area Workflow (WAWF) Receiving Report (RR).
The neat thing about the WAWF RR is that end item and embedded item information included on the attachment will be automatically updated in the IUID registry. The Appendix F: Materials Inspection and Receiving Report (MIRR) paragraph F-301 (e)(1) states “WAWF captures the IUID data and forwards the data to the IUID registry after acceptance. WAWF shall be used to report Unique Item Identifiers (UIIs) at the line item level, unless an exception to WAWF applies, and can also be used to report UIIs embedded at the line item level.”
The catch is, some limitations apply; according to the DoD Procurement Toolbox FAQ, this method only works for end items with a single level of embedded UIIs that do not exceed 100 items. So, end items with sub-assemblies (“grandchildren”) cannot be reported to the IUID registry using the WAWF RR. In this case, contractors will need to use one of the following methods.
Option 1: The IUID Web Interface
Contractors have the option of using the IUID web interface to manually insert and update items in the IUID registry.
Contractors that deliver end items to the customer must wait until Government acceptance of the MIRR before using the IUID registry web interface. Using the IUID web interface mostly involves re-entering the data from the system of record into the IUID online system.
It takes about 6 steps to embed one item into a parent UII. Needless to say, contractors with anything more than a handful of entries to report should not use the web interface. For those with limited embedded assets to report, a slideshow from the DLA on IUID WAWF Training should be helpful.
Option 2: A Dedicated System
The most efficient way to report embedded assets to the IUID registry is to have an asset management system that produces a properly formatted XML or Flat file with the required data.
The system should be able to produce the appropriate data file based on the qualifying transactions that have occurred in the system. The files should be formatted to include all embedded sub-assemblies, regardless of the number of layers and total quantity items. It’s also preferable if the asset management system ensures data is complete and accurate prior to export to the IUID registry.
Regardless of which option you choose, the IUID registry will provide both positive and negative acknowledgment of receipt based on the results of the electronic transmission.
The contractor presently submits the XML/Flat files via their Global Exchange Service (GEX) account. Through GEX, the IUID registry will only accept XML 5.1.1 and 5.2 schemas, or Flat File version 6.1 and 7.0. To get your contractor set up with a GEX account, head over to the DoD Procurement Toolbox.
In reading dense contract clauses and confusing guides, navigating IUID requirements can lead to a lot of stress. On top of that, every few years reporting requirement seem to change. After dealing with all this, property managers might demand a pay raise or at least a long vacation.
But with the right information and the right tools, contractors can achieve (and maintain) compliance.
Some contractors try to build compliant tools in-house, but the constantly changing file schemes and DFARs requirements make it difficult for in-house developers to keep up. In fact, while the IUID registry is currently the repository for UII and IUID custody information, this capability will be migrated to the GFP Module in the future.
To stay compliant with the shifting property management requirements, many contractors are seeking to partner with organizations that can provide a modern and evolving asset management tool that automates complex tasks. To learn more about how eQuip! can help manage embedded assets and other aspects of government property management, we recommend submitting an information request here.