Comment on FR Doc # 2011-11691

1. The proposed change to require ACO determination of property management system compliance is inconsistent with ACO determinations of other business systems. Except for Property Management, all business systems proposed for ACO determination of acceptability are reviewed by DCAA functional specialists outside of the DCMA or Program Office organizational structures, or by functional specialists who do not have a defined Career Field Certification Standard and warrant/letter of appointment. In those instances, functional specialist recommendations are advisory and the ACO determination of system status is necessary. Property management system compliance differs from the system status determinations cited in the proposed change in that Property Administrator certification/qualification requirements are identified under the unique DAWIA Career Field Certification Standard for Industrial Contract Property Management and they are issued letters of appointment which requires them to routinely perform their duties as warranted contracting officers and communicate system status determinations. 2. ACO responsibility for determinations of Property Management System compliance does not support consistent treatment of contractors assigned for DCMA administration. The DCMA Centers concept was established when it was found that certain specialty functions such as Property, Plant Clearance, Terminations, Transportation, etc., suffered declines in communications and technical expertise due to lack of functional supervision. Within DCMA, infrastructure and tools to support consistency in property management resides in the DCMA Business Centers, not the COO/CMO structure. 3. GAO Standards require performance of duties by appropriate, trained personnel. ACOs do not have the appropriate competencies (Knowledge, Skills, and Abilities) to perform this function and there has been no analysis of the ACO workforce to determine capability.