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USAID Acquisition Regulation (AIDAR) 752.245-71, “Title to and Care of Property,” sets forth a contract clause under which contractors must prepare and establish a program, to be approved by the mission, for the receipt, use, maintenance, protection, custody, and care of nonexpendable property for which it has custodial responsibility, including the establishment of reasonable controls to enforce such a program.
AIDAR 752.245-70 also requires the contractor to submit an annual report on all nonexpendable property. The contractor needs to attest that physical inventories of government property are taken at least annually, accountability records for government property agree with inventories, and the total of the accountability records agrees with the property values.
ADS 629.3.3.2, “Property Accounting Systems for Contractors,” also states that USAID does not prescribe a specific system of property accounting for contractors. However, any system employed by a contractor requires written approval by the cognizant property administrator. This process ensures adequate contractor control, accuracy, and consistency in reported information. In addition, the USAID COTR is responsible for:
- Monitoring the contractor’s management of government property.
- Reporting annually on government property and any property acquired by the contractor for use in the contract.
- Verifying the return or disposition of government property.
General Recommendations
Require the contractor to submit its property accounting system for approval and (2) determine whether that system is acceptable for managing government property according to USAID Acquisition Regulation requirements.
SOURCE: AUDIT REPORT NO. E-267-11-002-P MAY 16, 2011
The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations. Please see the disclaimer of this site before using recommendations.
- Storage Conditions for Food Commodities Need Improvement - Generally Accepted Commodity Accountability Principles - 22 CFR 211.10(c) - 22 CFR 211.5(a)
- Requiring Containerization Has Not Been Fully Considered - Principle IV-2 of the Generally Accepted Commodity Accountability Principles
- Assets May Have Been Diverted - GAO’s “Standards for Internal Control in the Federal Government
- Strengthen Commodity Controls - P.L. 480 Handbook
- Options for Unused Equipment - ADS 324.5.4b
- Adequate Controls Over Food Distribution Were Not Fully Implemented - Principle II-3 of the Generally Accepted Commodity Accountability Principles - 22 CFR 211.10(a)
- Storage Conditions for Food Commodities Need Improvement - Generally Accepted Commodity Accountability Principles, Principle IV-2,11 - 22 CFR 211.5(b) - USAID Commodity Reference Guide
- Assets Were Missing, Diverted, and Sold for Profit - GAO publication Standards for Internal Control in the Federal Government, pages 14 and 15
- Partner Did Not Track or Manage Inventory Effectively - ADS 596.3.1 - GAO’s publication Standards for Internal Control in the Federal Government
- Sustainability of Facilities Is Questionable - Section 611(e) of the Foreign Assistance Act of 1961
- Property Transfers Were Not Appropriate - Title 22 Code of Federal Regulations Part 226, Administration of Assistance Awards to U.S. Non-Governmental Organizations, Section 226.34, Equipment - U.S. Government Accountability Office issued Standards for Int
- Plan for End-Use Checks of Donated Commodities is Not Available - Automated Directives System (ADS) 324.5.6,
- Inventory is Not Tracked or Managed Effectively - ADS 596.3.1 - U.S. Government Accountability Office’s publication Standards for Internal Control in the Federal Government
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