Subcontractor Control

In the rare case that Government-owned equipment is required by a subcontractor, the same property control requirements that are placed on UNM will be flowed down to the subcontractor. Property management requirements, flow-down clauses, extent of liability for damage or loss, and annual inventory reporting will be included in all subcontracts. OSP will determine if the subcontractor’s property management system is satisfactory. If not, OSP will not authorize either the use of or the procurement of Government property. If the subcontractor purchases equipment under the agreement, OSP will notify Property Accounting for equipment tagging purposes.

Any Government property transferred to a subcontractor will include a full listing, to include a description, manufacturer, serial number, part number, unit of issue, quantity, and condition. All Government property transferred to the subcontractor will be clearly identified and marked as “Government Property” with the UNM asset tag blue label. The Inventory Contact will obtain a receipt for all transferred property and report to Property Accounting to update the Inventory Database. This receipt will be filed in the subcontractor’s contract file. The subcontractor will be made fully liable for any loss of Government property, either acquired as part of the subcontract or provided to the subcontractor by UNM. UNM will continue to maintain the property records for any Government property furnished to subcontractors. The subcontractor will also be responsible for the proper control and inventory of any contractor-acquired property.

Any subcontractor purchasing or utilizing Government-owned property in support of UNM-related efforts will be required to perform an annual inventory. This inventory will be conducted on the same schedule as UNM department’s inventory, and the results of the subcontractor’s inventory will be reported to the Department’s Inventory Contact no later than ten (10) working days before the due date assigned to the responsible department. In addition, a UNM representative can participate, if deemed necessary, in the subcontractor’s inventory. Refer to Purchasing/Information for Suppliers/Applicable FAR and DFAR Clauses to complete guidance for this process (http://purchase.unm.edu/supplier-information/far-and-dfar.pdf).

If a subcontract requires the fabrication of Government-owned property, UNM will, as part of the subcontract, require the subcontractor to notify UNM after the completion of a fabrication. The PI or Inventory Contact will, upon notification of completion, verify that the subcontractor has either properly shipped/transferred the item or has properly entered the item into its property control system. Verification will be accomplished by the subcontractor sending copies of the shipping/transfer documentation or copies of the inventory control records for the item. The Inventory Contact will notify Property Accounting for equipment tagging purposes.

Upon completion of any subcontract, the subcontractor will be required to provide a closeout inventory of any Government-owned property within thirty (30) days of physical completion.