ASTM E2936-20

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Designation: E2936 − 13 E2936 − 20
Standard Guide for
Contractor Self Assessment Self-Assessment for U.S.
Government PropertyAsset Management Systems
This standard is issued under the fixed designation E2936; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
INTRODUCTION
The purpose of this standard is to provide guidance for a Contractor Self Assessment Self-
Assessment (CSA) program that addresses the requirement of Federal Acquisition Regulation (FAR)
52.245-1 (Government Property) that contractors perform periodic reviews, surveillances, self
assessments self-assessments or audits. This guide is intended to assist contractors in developing a
CSA program that provides reasonable assurance of the effectiveness of the contractor’s government
propertyasset management system to internal and external stakeholders. Use of this guide should
enable contractors to objectively evaluate Government propertygovernment asset management system
risks, discover deficiencies, identify the root causes, and implement corrective actions.
1. Scope
1.1 This guide is intended to be used by entities engaged in contracts with the Government of the United States of America.
1.2 This guide applies to the current version of the FAR Government Property clause 52.245-1 dated April 2012.January 2017.
Entities with earlier or subsequently dated requirements/contracts should address any contractual difference when applying this
guide.
1.3 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility
of the user of this standard to establish appropriate safety safety, health, and healthenvironmental practices and determine the
applicability of regulatory limitations prior to use.
1.4 This international standard was developed in accordance with internationally recognized principles on standardization
established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued
by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
2. Referenced Documents
2.1 ASTM Standards:
E2135 Terminology for Property and Asset Management
E2279 Practice for Establishing the Guiding Principles of Property Asset Management
E2452 Practice for Equipment Management Process Maturity (EMPM) Model
E2234 Practice for Sampling a Stream of Product by Attributes Indexed by AQL
E2811 Practice for Management of Low Risk Property (LRP)
2.2 Federal Acquisition Regulation (FAR):
52.245–1 Government Property (current version)
2.3 OtherGAO Standards:
GAGAS Generally Accepted Government Auditing Standards (current version)
This test method guide is under the jurisdiction of ASTM Committee E53 on Asset Management and is the direct responsibility of Subcommittee E53.20 on United States
Government Contract Property Management.
Current edition approved Nov. 1, 2013July 1, 2020. Published November 2013July 2020. Originally approved in 2013. Last previous edition approved in 2013 as
E2936–13. DOI: 10.1520/E2936–1310.1520/E2936-20.
For referenced ASTM standards, visit the ASTM website, www.astm.org, or contact ASTM Customer Service at service@astm.org. For Annual Book of ASTM Standards
volume information, refer to the standard’sstandard’s Document Summary page on the ASTM website.
Available from U.S. General Services Administration (GSA), One Constitution Square, 1275 First Street, NE, Washington, DC 20417, http://acquisition.gov/far/
index.html.
Available from U.S. Government Accountability Office, Office (GAO), 441 G Street, NW, Washington, DC 20548, http://www.gao.gov/yellowbook.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
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3. Terminology
3.1 Definitions: ForDefinitions—For definitions of additional terms, refer to Terminology E2135.
3.1.1 classification of defects, n—the enumeration of possible defects of the assessment sample classified according to their
seriousness, that is, critical, major or minor defect.
3.1.2 confidence level, n—a statistical measure of the amount of reliability that a random statistical sample represents the entire
population.
3.1.3 contractor, n—an entity that has entered into a contractual relationship with one or more agencies of the Government of
the United States of America to provide goods or services.
3.1.4 contractor self assessment self-assessment (CSA), n—An auditing, assessment, review or surveillance program
implemented by a contractor to identify, evaluate and take corrective action on compliance and operational risks resulting from
business practices for government property management.
3.1.5 critical defect, n—a significant and systemic defect that would have a material effect on contract performance or cause
concern for the reliability of the information provided by the property management system.
3.1.6 defect, n—a condition in which a functional segment, a sample item or sample item element of a property control system
contains one or more deficiencies. E2135
3.1.6 federal acquisition regulation (FAR), n—The primary regulation for use by Federal Executive Agencies in their acquisition
of supplies and services with appropriated funds.
3.1.7 government propertyasset management system, n—the plans, processes, procedures, information systems, human and
physical resources used to manage government property accountable to a contract.
3.1.9 judgment sampling, v—is the performance of nonrandom, non-probability sampling technique where the auditor selects
items to be sampled based upon their knowledge and professional judgment.
3.1.8 major defect, n—a significant, but not systemic defect that may affect the control of government property, possibly
increasing the risk to the Government.government.
3.1.9 methodology, n—a set or system of methods, principles and rules for regulating a given discipline.
3.1.10 minor defect, n—a defect that is administrative in nature, non-systemic and would have no material outcome for the
control of Governmentgovernment property.
3.1.11 population, n—for purposes of auditing a contract property management system using statistical sampling a population
may consist of a collection of assets, inventory, records, documents, locations, actions or transactions that have common
characteristics for the process undergoing audit
3.1.12 purposive sampling, v—the act of selecting specific items for audit or review purposes based on prior knowledge of a
situation, usually to identify causal factors or progress in rectification of a prior problem.
3.1.15 sample, n—a subset of a complete population that exhibits the same characteristics as the complete population and which
is used in a statistical sample to estimate the overall population’s characteristics.
3.1.16 statistical sampling, v—the use of random statistical tests to estimate the characteristics of a complete population, with
a minimum of bias.
4. Significance and Use
4.1 The intent of this guide is to provide a foundation for the minimum effective internal assessment of a contractor’s
Government propertygovernment asset management system. A contractor may incorporate all or part of this guide in accordance
with its established procedures and operating environment. Self assessment Self-assessment should be used to identify deficiencies,
related increases to risk, and to serve as a method for obtaining correction to those deficiencies, independent of, and often in
advance of, a Governmentgovernment audit, review or assessment. It should also be used to assist in determining the effective
assignment of propertyasset management resources; and to serve as a method for promoting continuous improvement in
propertyasset management practices. Self assessments, Self-assessments, in and of themselves may not be sufficiently independent
to address external or Governmentgovernment review, assessment, or audit requirements.
4.2 To the extent possible, a CSA Contractor Self-Assessment (CSA) program should provide a level of objectivity similar to
like that of a propertyan asset management system analysis performed by a Governmentgovernment or other external auditor.
Individuals who perform assessments should not be the same individuals who perform the functions being tested when
sufficientenough resources are available. The contractor’s official written procedures should identify functional positions
responsible for performing the self assessment self-assessment and address management controls used to maintain independence
and prevent conflicts of interest whenever individuals who perform property functions also participate in CSA activities.
4.3 The results of the CSA alone do not determine adequacy or inadequacy of the contractor’s Government propertygovernment
asset management system but should identify the level of risk presented by the contractor’s business practices. The results of the
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CSA should be made available to external auditors or reviewers for potential inclusion in their audits or reports in accordance with
contractual requirements and the contractor’s procedures.
5. Resources
5.1 The performance of a CSA, at the prime contractor or subcontractor level, requires the budgeting for and application of
adequate resources. The contractor should determine the individuals who will perform and manage the CSA process, considering
the issue of audit independence requirements and the contractor’s asset management procedures. The contractor should also
determine any additional resource requirements, including budgeting for travel and per diem, access to information systems, and
any unique expertise needed, for example, statistical applications. Those who will be held accountable for the results should
manage and control the resources in accordance with Practice E2279.
6. Usage
6.1 Procedures:
6.1.1 Contractors should clearly describe and define their self-assessment program in their procedures. The procedures should
address the following concepts:concepts.
6.1.2 The audit, assessment, review or surveillance methodology to be used should be defined. The methodologies may include:
6.1.2.1 Application of a Governmentgovernment agency’s established propertyasset management system analysis criteria.
6.1.2.2 Application of Practice E2452.
6.1.2.3 Application of industry-leading practices and customary commercial practices as used by the contractor.
6.1.2.4 Application of any other assessment methodology, for example, Balanced Scorecard or Maturity Model, for example,
Capability Maturity Model Integration (CMMI).
6.1.3 The processes and outcomes subject to review should be clearly defined. These may include the requirements enumerated
in FAR 52.245-1, contractor-specific processes as applicable or other additional contractual requirements.
6.1.4 The parties responsible for performing the assessment should be identified. To the extent possible, contractors should have
the assessment reviewed by an impartial party in order to ensure objectivity of the results.
6.1.5 The organizational scope of the assessment should be defined, that is, the business units, sites, or other sub-divisions of
the entity to which the assessment applies. Multiple assessments may be performed when processes or procedures are significantly
different among business units or sites to constitute a separate propertyasset management system or when a higher level of risk
has been identified.
6.1.6 The contractor’s procedures should define a “defect” for the purposes of the assessment and the differences between minor,
major, and critical defects in the context of the contractor’s business environment. Corrective action requirements for defects
should be established.
6.1.7 The procedures should include a process and a schedule for reporting CSA results to management, Governmentgovern-
ment property administrators, and other stakeholders.
6.2 Risk Assessment at the Process and Entity Level:
6.2.1 Contractors should apply a risk assessment in planning the CSA. Risk assessments should address potential future risks
but may also include past incidents, that is, past performance areas. Criteria for determining risk may include but are not limited
to:
6.2.1.1 The propertyasset management system’s procedures,
6.2.1.2 The propertyasset management system’s impact on schedule or performance,
6.2.1.3 Internal controls, and
6.2.1.4 Contractor experience.
6.2.2 Risk assessments may be grouped into one of three categories:
6.2.2.1 Low risk entities are those with mature procedures that undergo continuous improvement, there are no impacts on
schedule or performance; internal controls produce positive high value results; contractor’s management and employees are stable;
no significant issues in previous CSAs or other internal or external audits.
6.2.2.2 Medium risk entities are those with changing procedures or system that needs validation; there has been an impact to
schedule or performance caused by propertyasset issues; contractor’s management and employees have recently changed; a critical
defect revealed through past CSA or other internal or external audits.
6.2.2.3 High risk entities are new contractors with no experience in asset management; contractors with new untested or
undocumented procedures; contractors with numerous critical defects revealed through past CSAs or other internal or external
audits.
Kaplan, R. S. and Norton, D. P., Balanced Scorecard, Harvard Business Review Press, Cambridge, MA, 1996.
Bush, M., and Dunaway, D., CMMI Assessments: Motivating Positive Change, Addison-Wesley Professional, Boston, MA, 2005.
Defense Acquisition University, “Risk Department of Defense Risk, Issue, and Opportunity Management Guide for DoD Acquisition,”Defense Acquisition Programs,
Sixth Edition, Version 1.0, August 2006January 2017,
http://www.dau.mil/publications/publicationsDocs/RMG%206Ed%20Aug06.pdf.https://www.dau.edu/tools/Lists/DAUTools/Attachments/140/RIO-Guide-January2017.pdf.
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6.2.3 The frequency of a CSA performance, either a complete CSA or the individual processes, should be based upon the risk
assessment, that is, the higher the risk rating the more frequent the CSA performance, the lower the risk rating the less frequent
the CSA performance.
6.2.3.1 Low risk entities should perform a CSA no less than once every three years.
6.2.3.2 Medium risk entities should perform a CSA no less than once every two years.
6.2.3.3 High risk entities should perform a CSA annually.
6.3 Process Tests:
6.3.1 Contractors should establish process tests that provide sufficientenough evidence to credibly evaluate the effectiveness and
risk level of the property management system in terms of business system process segments and as a whole.
6.3.2 Process tests may evaluate compliance with specific contract terms and conditions, or other business processes as required
by the contractor’s operating environment. Process tests should also evaluate the effectiveness of and level of adherence to the
contractor’s propertyasset management procedures.
6.3.3 Process tests may involve quantitative tests such as statistical sampling, metrics derived from Statistical Process Controls
(SPC), or non-statistical tests such as judgment or purposive sampling. When applying statistical sampling the acceptance and
rejection goals, acceptable ranges or other criteria for measuring risk levels should be established for each process test.
6.3.4 Contractors must include support documentation and evidence for each process test with the results of the self-assessment
to demonstrate the integrity of the process.
6.4 Populations for a Contractor Self Assessment: Self-Assessment:
6.4.1 The proper definition and selection of a population or populations when using statistical sampling for testing the FAR
propertyasset management processes is a critical component of performing a CSA. In statistics, sample data from a population are
observed in order to make estimate attributes of the population from which they were selected.
6.4.2 Populations should be defined and selected based upon common characteristics of the process being reviewed (FAR
52.245-1(f)(1)(i) through (x)) and the criteria embedded within the process or outcome. These outcomes include Acquisition,
Receiving, Records, Physical Inventory, Subcontractor Control, Reports, Relief of Stewardship Responsibility and Liability,
Utilization, Maintenance and Property Closeout. Care should be taken to ensure that populations address not only the stated process
or outcome, but any sub-processes subsumed under or within the listed processes.
6.4.3 Populations may be based upon transactions or attributes.
6.4.3.1 A population based upon transactions is one where the population is driven by actions that have occurred over a set
period of time, period, for example, all receiving of Governmentgovernment property assets that has occurred over the past year,
the maintenance of property assets over the past year – or whatever the timeframe defined within the CSA procedures.
6.4.3.2 Generally a transactional population should consist of and encompass transactions going back one year (365 days) or
to the last CSA, whichever is less.
6.4.4 A population based upon attributes is one where the population does not lend itself to testing transactions but rather other
characteristics, for example, storage locations, physical use locations, records of property, asset records, etc. These populations
involve the testing of criteria that are not driven by acts or actions over a period of time. period. For example, under the process
of storage, the CSA is not concerned with the propertyassets moving into and out of a storage facility but rather the locations where
all Government property isgovernment assets are stored – so there are no transactions involved. In regard to Regarding the process
of records, the population consists of records of all assets regardless of the actions performed on that record.
6.4.4.1 Processes may have more than one population:
(1) The process of Acquisition under FAR 52.245-1(f)(1)52.245-1(f)(1)(i) applies to the acquisition of both Government
Furnished Property (GFP) and Contractor Acquired Property (CAP). The criteria testing the acquisition of GFP and CAP may be
different; therefore, the populations for these two items may be different.
(2) Populations may be segregated within a process by classification of Government property, government property assets, that
is, Material, Special Test Equipment, Special Tooling, Equipment or other classifications as required or allowed by other
Governmentgovernment agencies.
(3) Populations may be segregated by the sensitivity of the Government property,government assets, for example, precious
metals, nuclear materials, arms, ammunition and explosives, Communications Security Equipment (COMSEC), etc.
(4) Populations may be stratified either by dollar value or the criticality of items using a “A, B, C” type methodology or based
on the criteria in Practice E2811.
6.4.5
...