Information Memorandum No.
06-183
Subject: Berry Amendment Compliance for Specialty Metals (USD(AT&L)
Memorandum dated June 1, 2006) (INFORMATION)
Date: June 8, 2006
Target Audience: Administrative Contracting Officers (ACOs), Quality
Assurance Specialists and Other Personnel involved in subject issue
New Information/Guidance/Tools:
- It was our expectation when we
released our interim Specialty Metals Instruction, Noncompliance with the Preference for Domestic
Specialty Metals Clause, DFARS 252.225-7014, that OSD would set forth a
Departmental policy largely endorsing our approach. The subject
USD(AT&L)
Memorandum, Berry Amendment Compliance for Specialty Metals, June
1, 2006 does just that.
- That Memorandum also establishes
a requirement for noncompliant suppliers to submit corrective action plans. In
addition, it identifies responsibilities for contracting officers in reviewing
the plans. DCMA contracting officers will be responsible for obtaining and
evaluating plans submitted on a segment, sector, or corporate basis. We expect
most plans from larger contractors to be submitted on those “broader” bases.
- We have been working with OSD,
the Services, and industry on the required contents of, and a standard template
for, those plans. We are also developing procedures for plan tracking and
evaluation as DCMA contracting officers are responsible for tracking of all
corrective action plans regardless of the scope of the plan. We have already executed an agreement with NAVSUP’s
Price Fighter Division to assist us with evaluation of the plans.
- Specific direction will be
provided soon (likely within a few weeks) in an update to our Specialty Metals
Instruction. In that policy, we will also address other issues that have been
raised on the Specialty Metals Community of Practice and other forums (e.g.,
closeout of impacted contracts, Government contract quality assurance for
subcontracted items).
- This information is applicable to the
Specialty Metals Clause Compliance Interim Instruction.
Point of Contact for Further Information
Signature:
Director, Supplier Operations