New DoD Defense Contract Management Agency Instruction on Counterfeit Mitigation

DoD Defense Contract Management Agency Instruction DCMA-INST 1205 – Counterfeit Mitigation (July 6, 2015)

http://www.dcma.mil/policy/1205/DCMA-INST-1205.pdf

From DCMA Public Policy List.

This is a comprehensive instruction on how DCMA will go about surveillance and assessment of Contractor Counterfeit Electronic Part Avoidance and Detection Systems.

Here are some observations about this new instruction …

System Assessments

In addition to evaluating Counterfeit Electronic Part Avoidance and Detection Systems in conjunction with CPSR (as required by DFARS), systems will also be evaluated during QMS audits.

Contract Review

DCMA will play a role in ensuring DoD program offices include appropriate counterfeit avoidance and detection clauses . During pre-award contract reviews, DCMA will be involved in identifying counterfeit avoidance and detection clauses to include in DoD contracts and participate in Post Award Orientation Conferences to recommend counterfeit mitigation strategies

Obsolete Hardware/Software and DCMA Surveillance

In cases where material (hardware or software) is obsolete or out of production, DCMA will elevate surveillance.

Material Supplier Selection vs Risk

The instruction assigns general levels of risk which align well current industry standards and recommendations from subject matter experts. Surveillance frequency is assigned accordingly.

System Implementation

If DCMA finds that a contractor did not follow its own internal Counterfeit Detection and Avoidance System, DCMA TS’s are instructed to issue a Level II CAR.

Reporting

DCMA Technical Specialists will contact the Contract Integrity Center (CIC) when any suspicion of fraud or counterfeit is encountered. The CIC will coordinate investigations among DCMA, criminal investigative organizations, intelligence authorities, etc.

If GIDEP reporting is not contractually required, DCMA will encourage the contractor to self-report counterfeit item discoveries to GIDEP; otherwise, DCMA and the CIC will report the finding to GIDEP.

Disposition

DCMA will oversee control and disposition of suspect and confirmed counterfeit material. Once a contractor receives disposition approval or direction from “the appropriate authority”, DCMA will confirm that material is rendered unusable.

Embedded Software/Firmware

DCMA will be conducting product acceptance to mitigate counterfeit risk when equipment contains embedded software and firmware (see DCMA-INST 203).

Flowdown

DCMA will be looking for flowdown of counterfeit detection and avoidance requirements to subcontractors, including COTS items.

Henry Livingston

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