DoD Issues Final Rule on Material Inspection and Receiving Report
September 20, 2011
DoD is issuing a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS), Appendix F, Material Inspection and Receiving Report, to incorporate new procedures for using the electronic Wide Area WorkFlow (WAWF) Receiving Report. Effective date: September 20, 2011. Reference Federal Register, Vol. 76, No. 182, September 20, 2011.
DoD published a proposed rule in the Federal Register (75 FR 56961) on September 17, 2010, to amend DFARS Appendix F, Material Inspection and Receiving Report, to provide new
coverage on the use, preparation, and distribution of the electronic WAWF receiving report, which is the primary method for documenting acceptance of supplies and services and for electronic invoicing. The rule also addressed WAWF capability to provide the following:
• Item Unique Identification (IUID). When the clause at DFARS 252.211– 7003, Item Identification and Valuation, is used in the contract and requires reporting of IUID data, WAWF captures the IUID data and forwards the data to the IUID registry after acceptance. WAWF may be used to report Unique Item Identifiers (UIIs) at the line item level and also UIIs embedded at the line item level.
• Radio Frequency Identification (RFID). When the clause at DFARS 252.211–7006, Radio Frequency Identification, is used in the contract, WAWF will capture the RFID information and forward the data to the receiving location. Using WAWF is the only way a contractor can comply with the clause to furnish RFID data via an Advance Shipping Notice. Insertion of the new WAWF coverage into Appendix F necessitates relocating and renumbering existing coverage for use, preparation, and distribution of the DD Form 250 Material Inspection and Receiving Report, and the DD Form 250–1 Tanker/Barge Material Inspection and Receiving Report.
Discussion and Analysis
In response to the proposed rule, DoD received comments from five respondents. A discussion of the comments follows.
A. Revise F–103, WAWF RR and DD Form 250
Comment: Two respondents suggested changing the text at F–103(b)(2) for the transfer of Government property using the property transfer function. Another respondent recommended adding where training for the preparation of document types is available.
Response: These recommendations are incorporated into the final rule.
B. Limitation on the Quantity of Embedded Items in WAWF
Comment: A respondent asked if there was a limit on the quantity of embedded items at the line item level that may be reported in WAWF.
Response: A quantity limit of 100 embedded items currently exists in the software capability, however, this limit is subject to change in future versions of WAWF.
C. F–103(e)(2), Radio Frequency Identification (RFID)
Comment: A respondent suggested adding clarification on the use of RFID information.
Response: As suggested, paragraph F–103(e)(2) is revised to clarify that the RFID information can be added either at submission or via the ''WAWF Pack Later'' functionality.
D. F–104, Application
Comment: A respondent asked about the meaning of ''consigned to'' at F–104(a)(4) and for clarification regarding use of a continuation sheet. The respondent stated that they have no
control over how the continuation sheet appears or prints from WAWF.
Response: The phrase ''consigned to'' is the one to whom a line item is given, transferred, or delivered for control. In regard to use of a continuation sheet, the format printed out from WAWF will suffice as long as the required contractor information is entered.
E. F–301, Preparation Instructions—General Comments
Comment: Two respondents suggested, at paragraph F–301(a)(1), replacing ''contractor'' with ''vendor'' to be consistent with the label used on the training Web site provided in the
proposed rule. A respondent suggested:(1) Revising F–301(a)(2) to reflect the creation of an extension to the prime Commercial and Government Entity (CAGE); (2) replacing, at paragraph F–301(a)(4), ''official DoD sites'' with ''DoD definitive sources''; (3). Adding text at paragraph F–301(b)(1)(iii) to clarify that comments in the miscellaneous information tab will
appear in the comments section of the printed WAWF receiving report; (4). changing, at paragraph F–301(b)(1)(iv), ''DoD contract number'' to ''DoD contract number and delivery order
number''; and, (5) updating paragraph F–301(b)(3) to correctly refer to the data field as ''Estimated'' and reflect that data entry is a drop-down box.
Response: The final rule is revised to incorporate these recommendations.
F. Inclusion of Shipping Documents
Comment: A respondent requested at paragraph F–301(b)(2)(i), SHIPMENT NO., that contractors must always provide packaging documentation in their shipment containers. If contractors choose to provide their own packaging documentation they must ensure their documentation includes their shipment number data. The respondent recommended the addition of a statement that any document utilized as a packing list must include the shipment number information. Additionally, the respondent suggested revising the text with an example to clarify that the shipment number format requires first three data positions to be alpha, fourth position alpha-numeric and last three positions are numeric e.g., DFAR001 or DAR0001.
Response: The recommendations are incorporated into the final rule.
Comment: A respondent requested at paragraph F–301(b)(3), Date Shipped, that a ''MIRR clause does not identify electronic data submission timeline.'' The respondent recommended the DFARS MIRR language include the statement that the contractor will submit the completed MIRR via WAWF within one business day of material shipment. The respondent stated that
material shipments missing shipment numbered data causes manual research in order to process the receipt acceptance.
Response: The MIRR is completed at the time of delivery of goods or services and, for both WAWF and paper DD form 250s, copies of the MIRR accompany the shipment. Paragraph F–301(b)(3) is revised to add a reference to ''see F–303).''
Comment: A respondent requested at paragraph F–305, Invoice instructions, adding a statement that contractors should ensure the packaging documentation includes a Government
signed receiving report when the contract requires origin inspection and acceptance. The respondent further stated that contractors must include the signed document indicating material receipt acceptance has occurred in the container with the exception of material shipments that are approved for Alternate Release Procedures.
Response: The final rule is revised to incorporate the recommendations.
G. F–301(b)(4)—Bill of Lading Information
Comment: A respondent stated, at paragraph F–301(b)(4)(i), that bills of lading are obtained when an item is being scheduled to ship, and thus may not be available until after the item has been source inspected/accepted. The respondent recommended clearly stating that the field is not required prior to source inspection and acceptance, nor, in their opinion, should a receiving report correction be issued only for adding a bill of lading after it has been obtained. Further, the respondent suggested revising F–301(b)(4), to enter the commercial or
Government bill of lading number after ''BL.''
Response: Currently, the ''Bill of Lading Number'' field is not a mandatory field in WAWF. Additional changes to the Bill of Lading functionality may be made later on.
H. Line Haul Information Changes
Comment: One respondent suggested at paragraph F–301(b)(5), Line Haul Mode, that this is an item that may not be stated accurately until after signature, when the item is scheduled for shipment, and recommended that this field not be required prior to source inspection/acceptance.
Response: There is flexibility in WAWF regarding this entry as ''Line Haul Mode'' field is not a mandatory field.
I. Allow for WAWF Acceptance at ''Other'' Using Code ''D''
Comment: Two respondents suggested that paragraph F–301(b)(6), Inspection and Acceptance Point, be changed from ''WAWF allows acceptance at Other'' to ''WAWF allows acceptance at Other (O).'' Two respondents suggested adding, that for purposes of conforming to contract, ''0'' is equivalent to ''D''.
Response: The final rule is revised to incorporate the recommendations.
J. Marked for Codes
Comment: A respondent suggested at paragraphs F–301(b)(7), Prime Contractor/Code, F–301(b)(9), Shipped From/Code, and F–301(b)(11), Payment Will Be Made By/Code, that these codes must match the contract, however, the street address is not required to match the contract. The respondents further opined that WAWF does not require the entry of an address code in either WAWF 4.2 or 5.0, and concluded that the requirement of an address should be clarified.
Response: No clarification is needed in the rule. Contractors can fulfill contracts with shipments from their location or from subsidiaries or subcontractors. Therefore, the shipped from code doesn't necessarily need to match the contract. Further, the receiving report is used for services as well as supplies where there will be no ship-from code.
Comment: One respondent requested clarification at paragraph F–301(b)(13), Marked For/Code, concerning the ''Marked For Address.'' Previously,textual marking information associated
with the ''Marked For DoDAAC'' was placed in the address lines of the ''Marked For DoDAAC.'' Now that DoD is moving away from paper documents, the respondent wanted confirmation to use the data fields as labeled using the code area for the ''Marked For DoDAAC'' and address only, and the ''Mark For Rep'' and ''Mark For Secondary'' fields used for the text information.
Response: The respondent is correct concerning use of these fields. No change to the rule is required.
K. Marked for Codes
Comment: A respondent requested revisions at paragraph F–301(b)(13) to reflect that a ''Marked For Code'' cannot be a CAGE code, only a DoDAAC or Military Assistance Program AddressCodes.
Response: No revision is required in response to this comment since a CAGE code can be entered in the ''Mark For Code'' field.
L. National Stock Number Entry Requirements
Comment: A respondent recommended at paragraph F–301(b)(15)(1)(A) clarifying that in the ''Type'' drop-down field, that the user is to select the corresponding type for the
data entered, and that if no National Stock Number or other valid ''Type'' is available, the word ''None'' may be entered for the Stock/Part Number, with a corresponding ''Type'' of any value other than the National Stock Number selected from the drop-down box. Another respondent stated that if the contract contains NSNs as well as other identification (e.g., part numbers), a contractor should place the NSN information in the Stock Part Number field and the remaining numbers in the line item description field.
Response: The paragraph is revised accordingly to incorporate the first recommendation. In regards to the second comment concerning NSNs as well as other identifying information,
the respondent is correct in how this process works. The text is revised to ensure this meaning is understood.
M. The ''Description'' Field Length and Use
Comment: A respondent asked whether or not at paragraph F–301(b)(15)(ii), if exceeding 20 characters in the description field is a cause for the rejection of a receiving report. Further,
the respondent requested clarification on whether or not the description refers to what is defined in the payment system as a ''service'' line item as opposed to a ''supply'' line item. A
WAWF RR for a repair is for acceptance of the repair and not of the item repaired. However, repair line items are frequently defined as ''supply'' line items and therefore the ship-to location is the actual ship-to of the repaired item.
Response: Exceeding 20 characters in the description is not a cause for rejection of a receiving report. In response to the second comment, the respondent is correct that the
description refers to the designation in the payment system as a ''service'' line item as opposed to a ''supply'' line item.
N. GFP Drop-Down Box
Comment: A respondent suggested that clarification at paragraph F–301(b)(15)(iv)(E) is required for how the text relates to the GFE drop-down box, and whether or not the drop-down box is insufficient for this situation. The correct use of GFE drop-down box needs to be fully explained. If it is not the same as the entry of ''GFP'' in the description text, the differences must be clarified.
Response: The drop-down GFE box is not related to this section. It is obsolete and no longer used and will be deleted in a future version of WAWF. The GFP drop-down box is sufficient for use of GFP.
O. F–301—General Comments Regarding Unit Price
Comment: Two respondents stated that at paragraph F–301(b)(18), the proposed text is identical to that used in the current Appendix F for unit price (see F–301, block 19, on current
Appendix F). They further stated that this document will never be used as an invoice; thus, in their opinion, there should not be a requirement to fill in a unit price, except in the cases listed. Further, one respondent recommended at paragraph F–301(b)(18)(i) the addition of the text to clarify the handling of unit prices and property transfer. Another respondent had a
concern with unit prices that were as little as twenty cents and not being accepted by the Government agency. This respondent also noted that an estimated price can be entered in the description field, but the Government contracting office expects the price entered in the price field, even though WAWF does not accept the entry the way the agency had requested. The respondent went on to state that the DFARS does not address the electronic aspect of WAWF and billing.
Response: The unit price is required. In regard to the intent of the paragraph on the WAWF initiated property transfer, the purpose is to alert the contractor that a property transfer will
be generated as a result of the completion of the WAWF RR. In regard to the unit price, it is required when the clause at DFARS 252.211–7003, Item Identification and Valuation, is used; otherwise the use of the field is optional and at the discretion of the vendor. When used for item unique identification, the unit price does not necessarily reflect the billing price on the contract. The DFARS addresses electronic billing at 252.232.7003, Electronic Submission of Payment Requests and Receiving Reports. No change in the rule is required in response to these comments.
P. F–301—General Comments Regarding Contract Quality Assurance
Comment: One respondent suggested at paragraph F–301(b)(20)(ii), that the term ''execute'' is misleading and will cause confusion. The respondent also stated that removing the quotation marks will ensure a clear direction. The respondent further suggested at paragraphs F–301(b)(20)(iv)(A)(3) and (v) the steps described should match the actual step taken in WAWF to electronically sign the document and recommended the text be revised.
Response: The quotation marks used for the term ''execute'' are removed. In regard to the electronic signatures, the text has been revised accordingly to match the actual steps taken in WAWF.
Q. Comment Regarding F–301(b)(21)
Comment: One respondent suggested paragraph F–301(b)(21) should be referenced as the COMMENTS block and/or MISC INFO tab.
Response: The title is revised to incorporate ''MISC. INFO'' as suggested.
R. Printed Documents
Comment: One respondent recommended at paragraph F–306(b), that the text be revised to clarify that if a signed copy is required by the contractor, the contractor will print the
WAWF RR only after a signature is applied by the Government Inspector or Acceptor in WAWF.
Response: This text is revised accordingly to incorporate the suggestion.
S. Part 4—General Comments
Comment: One respondent stated that in Part 4 there are multiple references to section F–301 and recommended, where appropriate, the references be updated to the corresponding F–401 reference. The respondent also suggested that at paragraph F–401(b)(2), ''Starting over with 0001'' cannot be used in an electronic world, and that the DD Form 250 needs to conform to the same requirement (F–301(b)(2)) as the WAWF RR.
Response: Part 4 references in the final rule are updated as required. In regard to shipment numbering, the system will not allow the shipment number to start over with 0001 as any
duplication of the combined contract number, delivery order number, and shipment number results a duplication error. In these cases, WAWF requires a change in the shipment number prefix. While on a paper DD Form 250, it is possible to start over with 0001 when the series is completely used, a change in the shipment number prefix should be required for consistency. The text at F–401(b)(2) is revised to clarify this process.
T. Part 5 Comments
Comment: A respondent commented on Part 5 concerning the ''alternate'' release procedure. The respondent noted that all other references in the document are to ''alternative'' release
procedure, and would like to know which is correct.
Response: The final rule is revised in Part 5 to refer to ''alternative'' in lieu of ''alternate.''
U. WAWF Versions
Comment: A respondent stated there are a number of changes incorporated in the latest WAWF release that impact MIRR data entry. The respondent noted that changes include removal of ''other'' as an acceptance point and replacing it with more specific data entries for inspection, acceptance, and ship to DoDAAC codes.
Response: There is no need to change paragraph F–301(b)(6) as ''Other'' will remain an option for the inspection and acceptance point. DoD adopted business rules regarding the inspection, acceptance, and ship-to fields but kept the source, destination, and other inspection and acceptance points.
Therefore, no change is necessary.
V. General Comments
Comment: One respondent stated that Appendix F addresses the use of the MIRR in WAWF, yet multiple types of receiving and performance transactions exist. Examples include:
Æ Receiving Report. Æ Receiving Report—COMBO. Æ Invoice 2-in-1 (Services Only).
Response: Appendix F only provides instruction for use of the MIRR. Invoice 2-in-1 (services only) is used to document acceptance of services when a MIRR is not required. The COMBO
transaction in WAWF allows for the vendor to do one set of data entry that is split in the system into both a receiving report, identical to the non-COMBO receiving report, and an
invoice. The instructions for the data entry in the COMBO are the same as the data fields for the receiving report.
Comment: A respondent suggested at paragraph F–301 rewording to state that Electronic Document Access (EDA) will automatically populate all available and applicable contract data.
Response: This change is incorporated at F–301(a)(3) in the final rule.
Comment: A respondent stated that they had received multiple rejections of receiving reports due to a formatting issue. In one case, the receiving report was rejected due to a dash being dropped out of the line item stock number upon loading to WAWF. In the respondent's opinion, the missing dash should not be a reason for rejection. The respondent requested adding specific language to F–301(b)(15) to indicate that missing dashes are acceptable in the line item stock number.
Response: The respondent indicates a dash was missing from the part number. This changes the item identification significantly. There are no known concerns with the National Stock
FOR FURTHER INFORMATION CONTACT: Mr. Julian Thrash, telephone 703–602–0310.