FAR 52.245-1(f)(v)(B), Subcontractor Plans and Systems, requires that there be adequate controls of government-purchased equipment for even the tiniest subcontractors. The problem is that there is very little technology available that offers any kind of traceability.
FAR 52.245-1 Government Property:
(f) Contractor plans and systems.(1) Contractors shall establish and implement [equipment] management plans, systems, and procedures at the contract, program, site or entity level to enable the following outcomes: (v) Subcontractor control.
(B) The Contractor shall assure its subcontracts are properly administered and reviews are periodically performed to determine the adequacy of the subcontractor’s [equipment] management system.
Think of a D.I.Y. License Plate
Imagine if people could just make up motor vehicle license plate numbers on their own. That is what much of the asset tagging industry is like today. The power of a motor vehicle license plate is its traceability. It’s actually 120-year-old technology that has become available to everybody in the age of the internet.
Traceability is the Missing Element
To be traceable, the asset tag needs to have the features described in Loss Prevention Standard 1224:
Providing a secure, internet-based asset registration service designed to support the identification and repatriation of assets when those assets are lost or stolen.
…and the features described in Loss Prevention Standard 1225:
i) Enable the marked asset to be traced to the legal owner via an internet-based, secure database register linked to the marking system employed
ii) Act as a theft deterrent in the first instance by virtue of a visible marking.
…combined with an integrated license plate system for states.
…combined with a regulated and anonymous peer-to-peer (P2P) communication strategy.