Liability For Loss of Government Property Prime and Sub! Liability For Loss of Government Property Prime and Sub!

LIABILITY
FOR LOSS OF GOVERNMENT

PROPERTY
Prime and Sub!
Presented by:
Dr. Douglas N. Goetz, CPPM, CF
President, GP Consultants LLC
(c) 2013 GP Consultants

LOSS
• Liability for Loss of Government Property in the
possession of the contractor ‐‐ takes MANY
different forms.
• This presentation will cover:
– Loss of “Pure” Government Property
• This presentation will NOT cover other liability
provisions such as:
– Loss of Progress Payments Inventory
– Loss of Delivered End Items
– Loss under the Ground and Flight Risk clause
» Well save THOSE for another time!

LOSS
FAR 52.245‐1(a)
• DEFINITION of LOSS:
– “Loss of Government Property” means unintended,
unforeseen or accidental loss, damage or destruction to
Government property that reduces the Government’s
expected economic benefits of the property. Loss of
Government property does not include purposeful destructive
testing, obsolescence, normal wear and tear or manufacturing
defects. Loss of Government property includes, but is not
limited to—
1) Items that cannot be found after a reasonable search:
2) Theft:
3) Damage resulting in unexpected harm to property requiring repair
to restore the item to usable condition; or
4) Destruction resulting from incidents that render the item useless
for its intended purpose or beyond economical repair.

SIMPLY PUT…
LOSS HAPPENS!!!

GOVERNMENT’s OVERARCHING POLICY
45.104
• Generally, contractors are NOT held liable
for loss of Government Property under the
following types of contracts:
– COST REIMBURSEMENT contracts
– TIME AND MATERIAL contracts
– LABOR HOUR contracts
– NEGOTIATED Fixed Price contracts for which
price is NOT based upon an exception at FAR
15.403‐1:

LOSS POLICY
45.104
• Therefore, by process of elimination, without
the policy stating such, under WHAT TYPE of
contract is the contractor held liable for Loss,
theft, damage, or destruction?
– FIXED PRICE for which there IS an exception at
FAR 15.403‐1
– In other words where there is no requirement for
a certificate of Current Cost and Pricing Data
• Or what in the “old days” we called a Fixed Price
Competitive contract, or a one step process.

LIABILITY FOR LOSS
• SO, in ESSENCE there are TWO FORMS of
LIABILITY:
– LIMITED RISK OF LOSS PROVISIONS
• Found at 52.245‐1(h)
And the
– FULL RISK OF LOSS PROVISIONS
• Found at 52.245‐1 (Alternate I)

FULL RISK OF LOSS
• FIXED PRICE Contract
– (Under a COMPETITIVE contract)
– (52.245‐1 Alternate I)
– “The contractor assumes the risk of, and shall be
responsible for, ANY loss of Government property
upon its delivery to the contractor as Government‐
furnished property. However, the contractor is NOT
responsible for reasonable wear and tear to
Government property or for Government property
properly consumed in performing this contract.”
FULL RISK OF LOSS
• IN ENGLISH…
CONTRACTOR IS LIABLE FOR
“ANY”
LOSS, THEFT, DAMAGE OR DESTRUCTION
EXCEPT FOR:
– REASONABLE WEAR AND TEAR OR
– REASONABLE AND PROPER CONSUMPTION

FULL RISK OF LOSS
• YOU SOLVE THE PROBLEM!!!
• SCENARIO:
– CONTRACTOR HAS 1 ITEM OF ST
– ACQUISITION COST ‐ $200
– AGE ‐ 10 Years Old
• CONTRACTOR LOSES THE ST
• TWO QUESTIONS:
– IS THE CONTRACTOR LIABLE?
• ____________________ (Simple yes or no answer.)
– FOR HOW MUCH IS THE CONTRACTOR LIABLE?
• ____________________
LIABILITY FOR LDD&T
• QUANTUM
– ACQUISITION COST?
– APPRECIATED VALUE?
– DEPRECIATED VALUE?
– SCRAP VALUE?
– REPLACEMENT COST?

CASE LAW
• QUANTUM was Determined by a
Court Case
– Dynalectron Corporation vs U.S.
– ASBCA No 29,831;
85‐3 BCA Para 18,320

LIABILITY FOR LDD&T
• The Court used the term
“Intrinsic Value”
To define QUANTUM
– The QUANTUM may range from
• Replacement cost where the Government has a need ‐‐either current or
probable future
• Repair cost for DAMAGED GP where the Government has a need ‐‐ current
or future need for the GP
• Salvage value for DAMAGED GP where the Government has no need for
the GP
• Scrap value for LOST GP where the Government has no need for the GP

Valuation of Lost, Damaged or
Destroyed Government Property for
Liability Purposes
“INTRINSIC VALUE”
GP is Lost or destroyed. GP is Lost or destroyed.
Government has NO Government still has a
current or probable current or probable
Future need. Future need.
LIABILITY VALUATION: LIABILITY VALUATION:
SCRAP VALUE REPLACEMENT
GP is damaged. GP is damaged.
Government has NO Government still has a
current or probable current or probable
Future need. Future need.
LIABILITY VALUATION: LIABILITY VALUATION:
SALVAGE REPAIR
QUICK RECAP
• Under the FULL RISK OF LOSS concept
– Fixed Price Competitive Contracts
– Quantum means…
•INTRINSIC VALUE TO THE GOVERNMENT

LIMITED RISK OF LOSS
• WHEN IS THE LIMITED RISK OF LOSS CONCEPT
APPLIED?
– Cost Reimbursement Contracts
– T&M Contracts
– LH Contracts
– FP Contracts awarded on the basis of submission of
certified cost or pricing data. (In other words
Negotiated)
• USING the regular version of the GP Clause –
52.245‐1
– In other words we use the regular paragraph (h) in
the clause
– NOTE – DOD has a variation to this in the DFARS. See Next
Slide  (c) 2013 GP Consultants
• 245.104 Responsibility and liability for
Government property.
– In addition to the contract types listed at FAR 45.104,
contractors are NOT held liable for loss of
Government property under negotiated fixed‐price
contracts awarded on a basis other than submission
of certified cost or pricing data.
• So, for DOD Contracts – NEGOTIATED Contracts
below the threshold for requiring a Cert of Cost
and Pricing Data NOW ALLOW/REQUIRE the use
of the LIMITED RISK OF LOSS Provision within
the GP Clause (FAR 52.245‐1(h)).

52.245‐1 (h)
• Unless otherwise provided in the
contract, the contractor shall
NOT
be liable for loss of Government
property EXCEPT…

• EXCEPT… THE CONTRACTOR SHALL BE LIABLE when one
of the following applies:
– 1. The Risk is Covered by INSURANCE
– 2. WILLFUL MISCONDUCT, LACK OF GOOD
FAITH ON THE PART OF MANAGERIAL
PERSONNEL
– 3. WITHDRAWAL of the Government’s
Assumption of Risk

INSURANCE
• Generally we have two instances where
INSURANCE may come into play:
– INSTANCE # 1
• INSURANCE that the Government REQUIRES the
contractor to acquire
• MUST BE SPECIFIED IN THE CONTRACT
• IF Contract is SILENT – INSURANCE IS NOT
REQUIRED and therefore NOT ALLOWABLE
– Generally, INSURANCE for GP is NOT an ALLOWABLE
expense (See FAR Part 31)

INSURANCE
• INSTANCE # 2
–“In Fact” Insurance
• Anyone got an example???

DEFINITIONS
• 2nd allowance where the
Government MAY hold the
Contractor Liable has THREE
Components:
– Willful Misconduct
– Lack of Good Faith
– On The Part Of Managerial Personnel

DEFINITIONS
• DEFINE:
–Willful Misconduct
• Either a deliberate act or failure to act that causes or results in
Loss, Damage or Destruction to Government property.
–Lack of Good Faith
• Failure to honestly carry out a duty including gross neglect or
disregard of the terms of the Government property clause or of
appropriate directions from the Property Administrator (PA).
Note: These definitions are from the “OLD” DoD Property Manual
4161.2-M. These terms are NOT defined in the FAR.

ONE MORE DEFINITION
•DEFINE I’m the

Prez!
“Managerial
Personnel?”
MANAGERIAL PERSONNEL
• As used in this clause means:
– the Contractor’s directors, officers, managers,
superintendents, or equivalent representatives
who have supervision or direction of…
– ALL OR SUBSTANTIALLY ALL of the contractor’s
business;
– ALL OR SUBSTANTIALLY ALL of the contractor’s
operation at any one plant or a separate and
complete major industrial operation connected
with performing the contract

CASE LAW
• Fairchild Hiller Corporation ASBCA No. 14387 (1971)
– Contract for the Stripping, Washing, and Cleaning of C‐130
Aircraft
• The burning of aircraft No. 1
• The burning of aircraft No. 2
– Methylethyl‐ketone & Naptha Based Solution
• The court was concerned with the actions of the
CONTRACTOR’S MANAGERIAL
PERSONNEL.
Not its lower level employees!

• LAST OPTION TO HOLD A CONTRACTOR
LIABLE…
– The Contracting Officer has, in writing, revoked the
Government's assumption of risk for loss of
Government property due to a determination
under paragraph (g) of this clause that the
Contractor's property management practices are
inadequate, and/or present an undue risk to the
Government, and the Contractor failed to take
timely corrective action.
ACO Authority
Must be in WRITING!
• When the Government “REVOKES” its
ASSUMPTION OF RISK – the contractor
becomes liable for “ANY” Loss, theft,
damage, or destruction of Government
Property, regardless of how it occurs,
UNLESS…

• Contractor may be granted relief if…
– If the Contractor can establish by clear and
convincing evidence that the loss of Government
property occurred while the Contractor had:
• adequate property management practices or
• the loss did not result from the Contractor's failure to
maintain adequate property management practices,
– the Contractor shall NOT be held liable.

WHY?
• Why does the Government have this
policy?
• It is an economically advantageous
methodology to have the Government
act as a Self Insurer. So long as the
Contractor is a “Good Insurance Risk.”
(In other words, maintains an
adequate Property Management
System!)
– In point of fact YOU – each and every one of
you – does the same thing in your PERSONAL
LIVES!!!
– EXAMPLE???

SUBCONTRACTOR
CONTROL AND
LIABILITY
SUBCONTRACTOR CONTROL
IS A CONTRACTUAL REQUIREMENT:
FAR 52.245‐1(b) “Property management”
(1) The Contractor shall have a system of internal controls to manage
(control, use, preserve, protect, repair and maintain) Government property
in its possession….
(2) The Contractor’s responsibility extends from the initial acquisition and receipt of
property, through stewardship, custody, and use until formally relieved of responsibility
by authorized means, including delivery, consumption, expending, disposition, or via a
completed investigation, evaluation, and final determination for lost, damaged,
destroyed, or stolen property. This requirement applies to all Government
property under the contractor’s accountability, stewardship,
possession or control, including its vendors or subcontractors (see
(f)(1)(v)).
(3) The Contractor shall include the requirements of this clause in all
subcontracts under which Government property is acquired or
furnished for subcontract performance.
(c) 2013 GP Consultants LLC

IS A CONTRACTUAL REQUIREMENT:
FAR 52.245‐1(f)(1) “Contractor Plans and Systems”
Contractors shall develop property management plans, systems, and
procedures at the contract, program, site or entity level to enable
the following outcomes:…
(v) Subcontractor control.
(A) The Contractor shall award subcontracts that
clearly identify assets to be provided and shall ensure
APPROPRIATE flow down of contract
terms and conditions, (e.g., limited liability for loss of
Government property).
(B) The Contractor shall assure its subcontracts are
properly administered and reviews are periodically
performed to determine the adequacy of the
subcontractor’s property management system.
• It is the CONTRACTOR’S responsibility to
establish the PROCESS, i.e., the methods and
methodologies, to accomplish this process in
accordance with & using:
– ILPs and
– VCSes and
– CCPs!

CAREFUL ON FLOW DOWN!!!
• LIMITED RISK OF LOSS FLOWDOWN
– Simplest analysis – if the Prime flows down the
requirement for Cert of Current Cost and Pricing
data – They may flow down the “Limited” R of L
– FAR 52.215‐12 or 52.215‐13 for Mods
• Subcontractor Cost and Pricing Data
– Other Applications:
• It depends… Some examples:
• Large quantity of GP
• High Dollar Value of GP
• FULL RISK OF LOSS – 52.245‐1
– Simple answer – flow down FULL R of L to the SUB
when ALT. I (Full R of L) is in the PRIME contract.
– If Limited R of L is in the Prime then the PRIME must
make a CONSCIOUS DECISION as to the APPLICATION
of the FULL R of L.
• Competitive Contracts
– Multiple bidders
– No Negotiations
• Where situation WARRANTS FULL R of L
RHETORICAL QUESTION – For a company’s property, if
they “loan” it out, what do THEY require? Full…Limited?
A DECISION TREE APPROACH!
Let me show you these concepts in
greater specificity!

FIRST FAR APPLICATION
FIXED PRICE (COMPETITIVE)
PRIME CONTRACT/CONTRACTOR
WITH NO
Requirement for a Cert of Current Cost and Pricing Data)
WITH GOVERNMENT PROPERTY CLAUSE
Of FAR 52.245-1 (Alternate I)
FULL RISK OF LOSS
REGARDLESS OF THE PRICING ARRANGEMENT

OF THE SUBCONTRACT
PRIME WOULD AUTOMATICALLY
FLOW DOWN THE
FULL RISK OF LOSS
TO ITS
SUBCONTRACTORS AND VENDORS
WHEN
GP IS PROVIDED TO SUB
+
GP MANAGEMENT REQUIREMENTS.
Why is it simple? IF Prime has Full risk of loss –

Sub should have Full Risk of Loss!
NOTE: If Prime flows down LIMITED Risk of Loss to its sub
-- A RARITY -- it does NOT effect the liability of the prime.
The Prime is still liable.
SECOND FAR APPLICATION
1. COST REIMBURSEMENT NEGOTIATED or
2. FIXED PRICE NEGOTIATED
EXCEEDING $700,000
(Requiring a Cert of Current Cost and Pricing Data)
AND FAR 52.215-12*
AND
PRIME HAS GOVERNMENT PROPERTY CLAUSE
Of FAR 52.245-1
Automatically Flow Down the

Limited Risk of Loss
GP Provision
COST REIMBURSEMENT FIXED PRICE
SUBCONTRACTOR SUBCONTRACTOR
Being awarded a Being awarded a
NEGOTIATED subcontract NEGOTIATED subcontract
Exceeding $700,000 Exceeding $700,000
AND AND
Containing 52.215-12* Containing 52.215-12*
AND AND
Providing Government Providing Government
Property + Property +
GP MANAGEMENT GP MANAGEMENT
REQUIREMENTS REQUIREMENTS
* NOTE: There are exceptions at 15.403-1 where this clause is NOT required.
THIRD FAR APPLICATION
1. COST REIMBURSEMENT NEGOTIATED or
EXCEEDING $700,000
(Requiring a Cert of Current Cost and Pricing Data)
AND FAR 52.215-12* or
AND (For all above)
Of FAR 52.245-1
Flow Down
The FULL Risk of Loss
GP Provision to a
FIXED PRICE
SUBCONTRACTOR
Being awarded a
COMPETITIVE subcontract
Regardless of $ Value
AND
Providing Government Property +
GP MANAGEMENT REQUIREMENTS
* NOTE: There are exceptions at 15.403-1 where this clause is NOT required.
FOURTH FAR APPLICATION
1. COST REIMBURSEMENT NEGOTIATED
PRIME CONTRACT/CONTRACTOR UNDER $700,000
(NOT Requiring a Cert of Current Cost and Pricing Data)
AND WITH GOVERNMENT PROPERTY CLAUSE
Of FAR 52.245-1
In Awarding a FIXED PRICE COMPETITIVE Contract,

PRIME WOULD FLOW DOWN FULL RISK OF LOSS
TO ITS SUBs and VENDORS WHEN GP
IS PROVIDED TO SUB
+ GP MANAGEMENT REQUIREMENTS.
In Awarding a FIXED PRICE NEGOTIATED Contract,

PRIME MAY* FLOW DOWN LIMITED RISK OF LOSS
IS PROVIDED TO SUB
+ GP MANAGEMENT REQUIREMENTS
NOTE: FAR 31.2 Incorporated by Reference
In Awarding a COST REIMBURSEMENT NEGOTIATED

Contract,
PRIME MAY* FLOW DOWN LIMITED RISK OF LOSS
IS PROVIDED TO SUB
+ GP MANAGEMENT REQUIREMENTS
NOTE: FAR 31.2 Incorporated by Reference
* Prime MAY flow down Limited Risk Of Loss if… Prime

requires sub to exclude insurance for GP. See 31.205-19 for
allowability of Insurance costs. If Subktr is unable/unwilling to
exclude insurance then Prime would flow down full!
FIFTH APPLICATION FOR DOD ONLY
(NOT REQUIRING a Cert of Current Cost and Pricing Data
UNDER $700,000)
SEE DFARS 245.107 for Policy
[(6) For negotiated fixed-price contracts awarded on a basis other than submission of
certified cost or pricing data for which Government property is provided,
use the clause at FAR 52.245-1, Government Property, without its Alternate I.]
AND
Of FAR 52.245-1
In Awarding a In Awarding a
FIXED PRICE COMPETITIVE FIXED PRICE NEGOTIATED
Contract, PRIME WOULD Contract, PRIME MAY*
FLOW DOWN THE FLOW DOWN
FULL RISK OF LOSS LIMITED RISK OF LOSS
TO ITS TO ITS
SUBs and VENDORS SUBs and VENDORS
WHEN WHEN
GP IS PROVIDED TO SUB GP IS PROVIDED TO SUB
+ +
GP MANAGEMENT GP MANAGEMENT
REQUIREMENTS. REQUIREMENTS
* Prime MAY flow down Limited Risk Of Loss if… Prime requires
sub to exclude insurance for GP. See 31.205-19 for allowability
of Insurance costs. If Subktr is unable/unwilling to exclude
insurance then Prime would flow down full!
• BOTTOM LINE:
– CONTRACTORS ‐‐ You need to speak with
you SUBCONTRACTS PEOPLE to ensure that
the RULES your company establishes are:
• KNOWN and
• APPLIED!!!
– CPSR ELEMENT OF REVIEW

THANK YOU!
PRESIDENT, GP CONSULTANTS
OLD AFIT/DAU PROFESSOR
Hopefully a Good Instructor.
233 N. Maple Ave
Fairborn, OH 45324
GPCONSULTANTS@ATT.NET
WWW.GOVERNMENT-PROPERTY.COM
1‐937‐754‐1811
1‐937‐878‐6680
© 2013 GP Consultants LLC
SOME OTHER LIABILITY STUFF!

CONTRACTOR REPORTS
• RELATIVELY NEW DOD REQUIREMENT
– DFARS 252.245‐7002
– (a) Definitions. As used in this clause—
• “Government property” is defined in the clause at FAR 52.245‐1, Government Property.
• “Loss of Government property” means unintended, unforeseen, or accidental loss, damage, or
destruction of Government property that reduces the Government’s expected economic benefits of
the property. Loss of Government property does not include purposeful destructive testing,
obsolescence, normal wear and tear, or manufacturing defects. Loss of Government property
includes, but is not limited to—
– (1) Items that cannot be found after a reasonable search;
– (2) Theft;
– (3) Damage resulting in unexpected harm to property requiring repair to restore the item to usable condition;
or
– (4) Destruction resulting from incidents that render the item useless for its intended purpose or beyond
economical repair.
• “Unit acquisition cost” means—
– (1) For Government‐furnished property, the dollar value assigned by the Government and identified in the
contract; and
– (2) For Contractor‐acquired property, the cost derived from the Contractor’s records that reflect consistently
applied, generally acceptable accounting principles.

CONTRACTOR REPORTS
– (b) Reporting loss of Government property.
• (1) The Contractor shall use the Defense Contract
Management Agency (DCMA) eTools software application
for reporting loss of Government property. Reporting value
shall be at unit acquisition cost. The eTools “LTDD of
Government Property” toolset can be accessed from the
DCMA home page External Web Access Management
application at http://www.dcma.mil/aboutetools.cfm .

CONTRACTOR REPORTS
• (2) Unless otherwise provided for in this contract, the requirements
of paragraph (b)(1) of this clause do not apply to normal
and reasonable inventory adjustments, i.e., losses
of low‐risk consumable material such as common
hardware, as agreed to by the Contractor and the
Government Property Administrator. Such losses are
typically a product of normal process variation. The Contractor shall
ensure that its property management system provides adequate
management control measures, e.g., statistical process controls, as
a means of managing such variation.
• (3) The Contractor shall report losses of Government property
outside normal process variation, e.g., losses due to—
– (i) Theft;
– (ii) Inadequate storage;
– (iii) Lack of physical security; or
– (iv) “Acts of God.”

PROPERTY ADMINISTRATOR’S
RESPONSIBILITIES
• RELIEF OF RESPONSIBILITY
– PA has the AUTHORITY to Grant “Relief of
Responsibility,” where appropriate
• FAR 45.105(d) When the property administrator determines that a
reported case of loss, damage, destruction or theft of Government
property constitutes a risk assumed by the Government, the Property
Administrator shall notify the contractor in writing
that they are granted relief of responsibility
in accordance with 52.245‐1(f)(1)(vii) as the risk of loss is the
responsibility of the Government.

PROPERTY ADMINISTRATOR’S
RESPONSIBILITIES
• NOTIFY THE CONTRACTING OFFICER
– Where the property administrator determines
that the risk of loss is NOT assumed by the
Government, the property administrator shall
forward a recommendation requesting that the
contracting officer hold the contractor liable.

CONTRACTING OFFICER’S
RESPONSIBILITIES
• ACO SHALL issue final liability
determination where contractor is held
liable
• ACO may make a contract price
adjustment or withhold financing,
• ACO SHALL request corrective action for
contractor’s property control system
(45.105)
So – Ya’ think liability is EASY???
• It’s not!!!
• Not because of the FAR Regulations, but because
of LAW and COMMERCIAL PRACTICE.
– Things Like the UCC
– Things like the COMMON Law of Bailment
– Things Like the INSURANCE Industry
– And things like Accidents!!!

SOME FUTURE PONDERINGS
if you think you know it all about Liability!
 Out the Progress Payments Clause
 52.232‐16
 Out the Loss of Delivered End Items
 52.247‐19
 Out the “Ground and Flight Risk Clause” in the DFARS
 252.228‐7001 (Bonds & Insurance)
 Out the “Protection of Government Buildings,
Equipment, and Vegetation.”
 52.237‐2 (Service Contracting Provision)
 Out the “Limitation of Liability.”
 52.246‐23 (Quality Assurance Provision)

THANK YOU!
PRESIDENT, GP CONSULTANTS
OLD AFIT/DAU PROFESSOR
Hopefully a Good Instructor.
233 N. Maple Ave
Fairborn, OH 45324
GPCONSULTANTS@ATT.NET
WWW.GOVERNMENT-PROPERTY.COM
1‐937‐754‐1811
1‐937‐878‐6680
© 2013 GP Consultants LLC

Liability For Loss of Government Property Prime and Sub! Liability For Loss of Government Property Prime and Sub!

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LIABILITY

FOR LOSS OF GOVERNMENT

(c) 2013 GP Consultants

(c) 2013 GP Consultants

(c) 2013 GP Consultants

(c) 2013 GP Consultants

(c) 2013 GP Consultants

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(c) 2013 GP Consultants

•DEFINE I’m the

(c) 2013 GP Consultants

(c) 2013 GP Consultants

(c) 2013 GP Consultants

(c) 2013 GP Consultants

(c) 2013 GP Consultants

(c) 2013 GP Consultants LLC

(c) 2013 GP Consultants LLC

(c) 2013 GP Consultants

REGARDLESS OF THE PRICING ARRANGEMENT

Why is it simple? IF Prime has Full risk of loss –

Automatically Flow Down the

In Awarding a FIXED PRICE COMPETITIVE Contract,

In Awarding a FIXED PRICE NEGOTIATED Contract,

In Awarding a COST REIMBURSEMENT NEGOTIATED

* Prime MAY flow down Limited Risk Of Loss if… Prime

(c) 2013 GP Consultants

(c) 2013 GP Consultants

(c) 2013 GP Consultants

(c) 2013 GP Consultants

(c) 2013 GP Consultants

(c) 2013 GP Consultants

(c) 2013 GP Consultants

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