Subject: Administration of Property in the Custody of Award Recipients

Responsible Office: Office of Strategic Infrastructure

Chapter 3. Delegation and Oversight of Property Administration

3.1 Letter of Delegation of Off-Center Property Administration Activities

3.1.1 It is NASA policy to delegate property administration activities for award recipients performing off Center unless the Center IPO retains the activities. Delegation allows NASA to utilize resources that are already in place geographically and organizationally and that are ready to perform these functions. Delegations are made to Federal agencies who are FIPs (e.g., DCMA, etc.). FIPs assist NASA with property administration and plant clearance off Center for private-for-profit and non-profit research entity and educational institution award recipients. This allows NASA to better utilize its own resources and presents “one face of the Government” to award recipients.

3.1.1.1 External agencies do not provide oversight for an award recipient when the recipient does not perform within a geographical area under the oversight of an external agency, or the place of performance is within a NASA Center when IPO retains the authorities and responsibilities associated with property administration. The requirements for delegation are set forth in Support Government Property Administration, 48 CFR subpt. 1845.5 and 2 CFR 200.

3.1.1.2 This chapter provides guidance on NASA oversight of delegated activities and

NASA-retained property administration activities.

3.1.2 Oversight of Delegated Property Administration Activities

3.1.2.1 NASA IPOs and GPAs shall use NESS via https://ness.nasa.gov to maintain records of property administration activity, whether delegated or retained.

a. The IPO shall maintain a record of the cognizant GPA when notified by the delegated FIP of the acceptance of a delegation or a change of personnel in NESS. The signed LOD(s) with Mission Directorate identified and Program Office, updated descriptive property listing, original signed award and award modification are uploaded by IPO in NESS Contracts screen under Documents tab.

b. The IPO shall send descriptive property listing with all updated period of performance requirements.

c. When a CO/GO delegates authority to perform GPA and PLCO duties for off-Center awards to FIPs by means other than LODs (i.e., alternate delegation), the HQ-CPPM is responsible for ensuring through a concurrence that the delegation complies with award property management and general property management requirements including those of the GCAM, CFR, FAR, and NFS prior to the CO/GO executing the delegation.

d. Figure 3-1, LOD Process Flow Chart, depicts the LOD process of approval for NASA awards assigned off Center. The requirement for property administration is sent by Center IPO to HQ-CPPM with supporting documentation (e.g., original signed award, last award modification, descriptive property listing indicating Mission Directorate and Program Name, etc.). LODs need to be 12+ months for the period of performance, and plant clearance LODs can be requested separately as a one-time assist (if necessary) but it usually with both (property administration and plant clearance). Once HQ-CPPM acknowledges for approval, the CO/GO shall create, sign, and send the NF 1430, NF 1430A and NF 1674 to HQ-CPPM. The HQ-CPPM creates and signs NF 1430C, NF 1430D, and NF 1674 prior to execution by the CO/GO. HQ-CPPM sends supporting documentation (e.g., signed LOD(s), original signed award, last award modification, descriptive property listing, etc.) to FIP cc: CO/GO, and IPO.

NPR4500.1AC3G1 Figure 3-1, LOD Process Flow Chart, depicts the LOD process of approval for NASA awards assigned off Center.

Figure 3-1 Letter of Delegation (LOD) Process Flow Chart

e. The FIP shall accept NASA’s LODs by providing hours to the HQ-CPPM and by signing the acceptance and returning the original NF 1430C, NF 1430D, or NF 1674 to the CO/GO, Center IPO, and HQ-CPPM within 30 business days of receipt. The LOD(s) are valid throughout the period of performance of the award unless NASA terminates, transfers to another award/Center, NASA or FIP rescinds it; or property is no longer associated.

f. The FIP or NASA’s CO/GO can also rescind the LOD(s) by notifying HQ-CPPM and Center IPO with the originally signed LOD(s) by FIP and HQ-CPPM; and by signing the “Rescind” portion. HQ-CPPM will notify the FIP to close LOD(s) per Center request.

g. The IPO shall send all signed LODs (acceptance and any rescinds) to award recipients’ POCs via e-mail within 30 business days and add HQ-CPPM to e-mail transmission. Afterwards, upload signed LODs, and current property listing in NESS via Contracts screen under Documents tab.

h. The IPO shall ensure the GPA create and update all individual award records including Summary and Outcome tabs and upload reports and supporting documents under the Documents tab of PMSAs upon 30 days of receipt and more current than that existing in NESS according to LOD instructions and contact HQ-CPPM via e-mail with award number within 30 business days if not performed according to schedule provided. (See Chapter 5, Property Management System Analysis (PMSA) for more information.)

i. The IPO shall review report submissions in NESS to ensure GPA verification of property reports according to supporting documentation, delegation instructions and reporting requirements.

j. The IPO shall review the GPA’s reports of property system deficiencies identified during the PMSA and based on the recommendations of the GPA, determine whether to provide further recommendations to the CO/GO to remedy the situation. These recommendations may include but are not limited to holding the award recipient liable for property loss until any deficiencies are corrected.

3.2 Support of Delegations

3.2.1 NASA GPAs may seek support delegations from FIPs for any off-Center award performance where no NASA personnel are located. For all such delegations required, the FIP has the prime award delegation to avoid any duplication of effort. GPAs should ensure that support delegation instructions comply with the requirements of this NPR, the NFS, and the award language.

3.2.2 Support Delegation Requirements

3.2.2.1 The IPO shall forward copies of the award, latest award modification, novation, descriptive listing of property listing, and delegation justification to the NASA HQ-CPPM for review and approval. There may be approvals for medium and low risk categories if other awards are delegated at the same location. Property Administration delegations are based on the high-risk category under Risk Assessment Matrix under this program. (See Table 5-1 for more information.)

3.2.2.2 The IPO shall include the prime award under which the charges for FIPs property administration will be billed within the support delegation instructions. There are no duplications of efforts in delegations in which FIP is performing the same activity as NASA.

3.2.2.3 The GPA shall provide NASA’s IPO with a determination letter if the award recipient has an existing award belonging to another FIP’s agency.

3.2.2.4 The NASA cognizant CO/GO shall write determination letters and make the determination of the property system acceptability if there are no existing awards with the FIP.

3.3 Retention of On-Center Property Administration Activities

3.3.1 NASA requires the use of NASA systems, as available, for record-keeping of on-Center IAGP being used by award recipients. NASA procedures are used to manage IAGP being used by on-Center award recipients performing within NASA Centers. Because external award property administration personnel might not be familiar with internal NASA systems and guidance, award property administration activities are retained for recipients performing on Centers/Installations. When required, NASA IPOs and GPAs shall perform on-Center reviews of recipient performance unless otherwise specified in the NASA award.

3.3.2 On-Center Property Administration Requirements

3.3.2.1 The IPO shall work with the SEMO to define the depth and extent of audits of on-Center award recipient performance.

a. IPOs and SEMOs should consider the need to audit award recipient property performance when the Statement of Work requires significant independent recipient action in the execution of property transactions and activities.

b. Centers should seek the review and the opinion of the IPO in preparing performance evaluations when significant award recipient property management activities are specified within the Statement of Work.

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