Dodge a CAR by Giving Your Written Procedures a Tune-Up
If you corner a property manager that has received a dreaded Corrective Action Request (CAR) for a property system deficiency and ask them to candidly answer the question, “Did you see this coming?” my bet is more than 90% would answer “Of course.”
Preceding the issuance of the CAR, the government property manager likely endured for months or even years the feeling of impending doom.
Efforts to relieve themselves of this anxiety were just not productive. Maybe management shrugged off pleas for help. Perhaps issues were observed, but the property manager could not identify the true root cause.
Regardless, the Defense Contract Management Agency (DCMA) now has a spotlight on the property system and the property manager is on the hot seat.
If you found this article because you are trying to Google a way out of the CAR, I suggest checking out the article on how to respond to a CAR and submitting a request to discuss the situation with an expert. This article is going to focus on ways to avoid getting hit with a CAR.
Do your procedures need a tune-up?
The Corrective Action Request is a tool that the DCMA uses to notify contractors of contractual non-compliances. The non-compliances are usually observed during a Property Management System Analysis (PMSA). This is when the contract/DCMA Property Administrator (PA) comes on site to evaluate the contractor’s property management system.
Over the years the scrutiny of the PMSAs has increased and so has their complexity.
As Deena Day of the DCMA pointed out during her education session at 2018 NPMA NES, there are 22 property elements that the PA may audit during the PMSA. The sheer volume of potential pitfalls is enough to justify frequent heartburn for government property managers.
However, of all these elements one is guaranteed to be scrutinized during every PMSA: the written property management system procedures. The Defense Acquisition University (DAU) makes it clear to all those that conduct PMSAs: “Review of the Contractor’s written property management system procedures are critical to performing a PMSA”.
If you often feel like things are out of hand, this is your brain giving you a signal that its time for a property management tune-up. Start with your procedures.
If you are a government contractor that has or is bidding on a contract with government property and you don’t have written property management procedures in place, take care of this right now. The National Defense Industrial Association (NDIA) has a template you can download.
Written procedures are the key
During a PMSA, the PAs are instructed to ensure your written procedures “identify pertinent details such as what outcome is being addressed, who is responsible for performance of the procedure when certain tasks are performed (e.g. frequency) and the steps involved.”
The upside of the written procedure review during the PMSA is that it’s an open book test. We know the PA will list out the requirements of FAR 52.245-1(f), then identify the sections/pages of your written procedures that cover each requirement.
Knowing this, we can evaluate our own written procedures by reviewing written procedures during a self-assessment.
Performing a self-assessment
When was the last time your company completed a self-assessment which also included a comprehensive review of your written procedures?
(Just skimming the document doesn’t count.)
Because you know how the PA will review your property management plan, you should replicate the PA review method to ensure a thorough self-assessment.
Certified Professional Property Managers (CPPMs) Rosanne Green and Tara Miller penned a great article on how to prepare for a property audit. In this article, they agree with the above strategy and provide some additional insight:
“…do a self-assessment (internal audit) by comparing the procedure to the actual process being followed. This may seem like a no-brainer, but often in the quest to perform more efficiently, processes are enhanced, streamlined, or changed in some way. It is not unusual to find procedures do not match processes.”
A quick note: a thorough annual review is a good start, but the written procedures should also be analyzed each time your company is awarded a contract with any government property management clauses. Don’t forget to identify any agency-specific property clauses like those seen in the DFARs, NSF (NASA Far Supplement), and the Department of State Acquisition Regulation (DOSAR).
Self-assessments in written procedures
The self-assessment is not just something your team performs. It also is a procedure that must be clearly defined in your written procedures.
The NDIA Government Property Management Systems Committee assembled guidelines for self-assessments and identified 7 concepts that should be addressed in the written procedures.
To summarize, they are:
- The assessment methodology must be defined
- The utilized processes and FAR outcomes to be reviewed should be defined
- Parties performing the assessment should be impartial (when practical) and identified in the written procedures
- The organizational scope of the assessment should be identified and should include the contractor’s entire property management system
- The assessment frequency should be documented and based on the contractor’s risk level
- The procedures should define a “defect” and subsequent corrective action requirements
- Reporting requirements of self-assessments should be documented and identify who gets the report and when
Obstacles to successful self-assessments
I have observed that many contractors neglect to complete self-assessments or fail to leverage them as a true opportunity for improvement.
Understandably, government property managers can feel like all of their available moments are consumed trying to support the operational property needs of the organization. Some are unsure of best practices for self-assessments. Many people also prefer to shy away from examinations, so self-administered reviews may be packed with confirmation bias.
The reality is every aspect of any business can be improved. Professionals that want to enhance their teams’ abilities regularly analyze for adjustments that can be made to improve productivity and efficiency.
Have you determined that using spreadsheets to manage the government property inventory just can’t cut it any longer? Are you finding that assets are constantly “growing legs” and require leadership support to correct the culture? Does your team need to hire another person to maintain compliance, but you just can’t seem to get the budget?
Completing self-assessments will arm your team with the documented facts required to communicate your needs to management.
In the end, it’s better for the business and your job if you tell management what is needed after a self-assessment rather than after a Corrective Action Request.
Writing your procedures
You should avoid being tempted to generalize your written procedures. All components should be as specific as possible. This will help provide the appropriate guidance to your internal team and establish the required expectations for the PA.
When contractors are vague on who is doing what and when, this gives the PA the ability to arrive at expectations that your team is not fulfilling.
For example; DFARS 252.211-7007 (g)(3) specifies: “The contractor shall update the IUID Registry as transactions occur or as otherwise stated in the Contractor’s property management procedure.”
This means if your written procedures do not specify when you will report changes to the IUID registry, then the PA will expect your team to update the registry immediately after the qualifying life-cycle event has occurred.
Holy cow, who actually does that!?
That’s why you need to include as much detail as possible when creating written procedures.
Written property management system procedures are easy to ignore, at least until you receive a CAR.
You can avoid getting hit by that CAR by examining your written procedures, both during self-assessments and after winning a major government contract.
You’ll look through all written procedures with a close eye, ensuring they’re specific enough to protect you from a CAR. Once you recognize any potential issues, you can give your written procedures a tune-up to better avoid Corrective Action Requests.