III.  Additional Technical Changes Required

During the final rule development, DoD restructured the layout of the rule to reduce burden to contractors and to facilitate data capture. This change required moving the tables from the clause at 252.246-7006, Warranty Tracking of Serialized Items, to 246.710-70, Warranty attachment. This will enable data capture through the use of the warranty attachments. DoD has posted schema to the DPAP/Program Development and Implementation Web site at http://www.acq.osd.mil/dpap/pdi/eb/gfp.html, to facilitate this process. A summary of the required technical changes follows--

DFARS 211.274-2, Policy for unique item identification--added the term "any warranted serialized item" to clarify that this rule applies to serialized warranted items, regardless of the value. The existence of a warranty does not solely create a criterion for Item Unique Identification applicability.

DFARS 246.701, Definitions--added references to definitions for "duration," "enterprise," "enterprise identifier," "fixed expiration," "issuing agency," "item type," "starting event," "serialized item," "unique item identifier," "usage," "warranty administrator," "warranty guarantor," "warranty repair source," and "warranty tracking' as being defined in the clause at 252.246-7006.

DFARS 246.710, Solicitation provision and contract clauses, paragraph (5)--replaced previous references to tables I and II as the warranty attachments were added to DFARS 246.710-70. Related subparagraphs were revised accordingly to incorporate tables I and II, which were previously referred to in the provision at 252.246-7005, and included in the clause at 252.246-7006. Electronic business systems are being expanded to capture the data elements needed to support warranty tracking through the use of an attachment format. The procurement data strategy, the DoD method to implement data capture, relies on attachment file formats. This format can be embedded in the contract data file by the contract writing system, or sent in parallel as a separate attachment. To facilitate data capture, the tables for warranty data have been translated into an XML attachment schema published by DPAP, and available at this website: http://www.acq.osd.mil/dpap/pdi/eb/gfp.html. This schema will enable data flow from system to system. Data flow from a clause is not possible because the clause is text, not data. Extracting the data requirements from the clause and carrying it separately in an attachment will make the flowing of the data to the various business systems possible without modifying every DoD contract writing system.

DFARS 246.710-70, Warranty attachment--a new section was added to provide two attachments and completion instructions to replace two tables previously included in the proposed clause at 252.247-70YY. The two new attachments are "Attachment ----: Warranty Tracking Information," and "Attachment ----: Warranty Repair Source Instructions."

The "Warranty Tracking Information" attachment title is supplemented to include "Solicitation or Contract Number [To be filled in by the contracting officer]." Further, this attachment indicates that data marked "*" is to be completed by the requiring activity if a warranty is specified by the Government otherwise all offerors are to complete those elements as part of their offers. Data marked by "**" is to be completed by the contractor at the time of award. A reference to "***" was added for data to be completed at or after the time of award. The definition for "warranty administrator enterprise identifier" was revised to include the term "globally unique" identifier code.

The "Warranty Repair Source Instructions" attachment title is supplemented to include "Solicitation or Contract Number [To be filled in by the contracting officer]." Additionally, the numbering for the table notes was revised for that table only. The definition for "warranty administrator enterprise identifier" was revised for clarity to include the term "globally unique" identifier code rather than using the term "non-repeatable." Also, a note for "instructions" was moved from the table, and made a stand-alone note under the table.

252.211-7003(a), Item Identification and Valuation--the definition of "issuing agency" was revised for clarity to include the term a "globally unique" identifier code rather than using the term "non-repeatable."

252.246-7005, Notice of Warranty Tracking of Serialized Items, was revised to replace references to tables I and II, which were incorporated into DFARS 246.710 as a warranty attachment.

252.246-7006, Warranty Tracking of Serialized Items--

Paragraph (a), the definition of "DoD Item Unique Identification Registry" was not required for the clause and was removed. The definition of "issuing agency" was revised to include the term "globally unique" identifier code for clarity.

Paragraph (b) was revised to remove references to tables I and II as these tables are incorporated into 246.710-70 as a warranty attachment to facilitate data flow.