Just like all other business systems required for federal Government contract work, the Government property system requires compliant policies and procedures for an adequate system determination. While procedures are only a single part of a contractor’s property management system, they are the backbone of how the system should operate.
What It Means to “Enable” Government Property Outcomes
FAR 52.245-1(f) Contractor Plans and Systems tells us that:
“Contractors shall establish and implement property management plans, systems and procedures at the contract, site or entity level to enable the following outcomes….”
Those outcomes outline the core functional areas that a contractor’s property management system must address, including the following:
- Acquisition
- Receipt
- Records
- Physical Inventory
- Subcontractor Control
- Reports
- Relief of Stewardship
- Utilization
- Maintenance
- Closeout
Why PMSA Reviews Go Beyond the Ten Required Outcomes
But if you have ever been through the Property Management Systems Analysis (PMSA) with the Defense Contract Management Agency (DCMA), you know that those ten are only part of the audit, and the “outcomes” listed above also have sub-elements that must be covered.
Contractors should remember that their policies must be compliant not only with FAR 52.245-1 “Government Property” and the newer DFARS clause 252.245-7005 “Management and Reporting of Government Property,” but also with the DCMA guidebook instructions. The DCMA Guidebook for Government Property Contract Administration mentions the term “enable” a total of fourteen times.
A contractor’s written policies and procedures must provide enough detail to enable all outcomes and sub-elements to be compliant. Truthfully, the FAR/DFARS clauses on Government property provide very little information on the level of detail required for adequate procedures.
How Much Detail DCMA Expects in Property Procedures
Our team deals with Government property daily. One thing we hear a lot from contractors is, “It does not tell me anywhere in the FAR, DFARS or my contract that I should tell an auditor how many business days are required to create a property record.” You can swap “create a property record” for any other task that helps enable an outcome, from receiving in property to closing out Government property at contract completion. Their point is that contract clauses don’t mandate the level of detail required. It is only in the DCMA guidebook that you can read about the requirement of listing timeframes around tasks that enable outcomes.
How much detail is enough for a contractor to enable the outcome? Well, like everything else, it depends.
- Do your property procedures provide enough detail so that an employee can understand what he or she needs to do?
- Do your procedures list what must be done and when, to enable the outcomes?
Those are the requirements, and DCMA expects there to be sufficient detail to complete the tasks.
Government Property Compliance Requires a Complete System Approach
Compliant property procedures are only one component of an adequate Government property management system, and contractors must ensure that all related requirements work together to support audit readiness and ongoing compliance. Redstone Government Consulting assists contractors across the full scope of Government property requirements, including developing and refining property policies, conducting contractor self-assessments, and supporting responses to corrective actions resulting from a PMSA. Our team of experts also provides guidance during contract terminations, inventory disposition planning, and property closeout activities. We bring in-depth knowledge and experience with FAR, DFARS, and DCMA expectations, helping contractors interpret requirements accurately, address gaps proactively, and reduce compliance risk throughout the property lifecycle.
As Director of Compliance Consulting at Redstone Government Consulting, Jonas Clem leads our compliance team in helping government contractors navigate the complexities of federal compliance requirements. With deep expertise in DFARS business systems, cost proposal compliance, and government audits, Jonas provides strategic guidance to our clients facing DCAA and DCMA audits, ensuring compliance at every stage, from pre-audit preparation to post-audit resolution. Jonas is a recognized expert in government property management and purchasing system compliance, having successfully implemented and refined these systems for contractors of all sizes—each passing rigorous government audits. He also delivers targeted training programs, equipping clients with the knowledge needed to maintain compliance with DFARS business systems, FAR 31 cost principles, indirect rate strategies, and cost proposal requirements. With over 20 years of experience in the government contracting industry, Jonas has held senior leadership roles spanning program finance, contracts, accounting, and operations. A significant portion of his career was spent with a small business contractor that expanded into a $100M+ large business prime contractor, where he progressed through leadership positions to ultimately serve as Business Operations Manager for the NASA and Army Programs Division. Additionally, he has served as a Controller for a large NASA prime contractor, strengthening his expertise in financial management, compliance, and audit readiness. Jonas' comprehensive, hands-on experience across the government contracting lifecycle, including DoD and NASA contracts, makes him an invaluable resource to our clients. His proven expertise spans proposal development and pricing, indirect rate structuring, and DCAA/DCMA audit readiness. With an unparalleled blend of accounting, contracts, operations, and regulatory knowledge, Jonas delivers practical, results-driven compliance strategies that help our clients mitigate risk and succeed in today's highly regulated environment.