| NODIS Library | Property, Supply and Equipment(4000s) | Search |

NASA
Procedural
Requirements

NPR 4500.1A
Effective Date: April 10, 2024
Expiration Date: April 10, 2029

COMPLIANCE IS MANDATORY FOR NASA EMPLOYEES

Subject: Administration of Property in the Custody of Award Recipients

Responsible Office: Office of Strategic Infrastructure

Chapter 2. Pre-Award Processes

2.1 Solicitation Preparation

2.1.1 Procurement Support

The IPO and GPA may begin their support of award administration activity with the solicitation preparation process. IPOs and GPAs provide valuable professional guidance in property management, ensuring use of appropriate award language during preparation of the solicitation and assisting in the collection of property-related information such as the quantity and value of inventory holdings and lists of available property. As the correct selection of award property clauses and the correct collection of property-related information are critical to the eventual success of property management efforts, the IPO review of any awards with a potential for providing property is essential. (For information related to grant and cooperative agreement solicitation preparation, 2 CFR pt. 200 and the GCAM.)

2.1.2 Review of Solicitation/Award

2.1.2.1 The IPO shall review the requirements of the solicitation or award, in particular any requirement related to property management.

2.1.2.2 The review begins with the Statement of Work to determine if it contains property management tasks, tasks related to property management, or tasks that will not be successful without effective property management. This review should be used to guide the IPO in selecting appropriate award property clauses and coordination of Center and other NASA property in support of the property management effort.

2.1.2.3 When consulting on future acquisitions prior to issuance of solicitations or reviewing solicitations after issuance, the IPO shall:

a. Recommend appropriate solicitation provisions in accordance with Contract Clauses, 48 CFR § 1845.107.

b. Advise the CO to use the appropriate provision with its alternate for prospective award recipients to review the existing property for function and condition.

c. Assist the CO in determining the appropriate application of Solicitation Provisions and Contract Clauses, Government Property Installation Operation Services, Government Property Installation Operation Services, 48 CFR § 52.245-2, and which property may be offered under its authority.

2.1.2.4 The IPO should recommend including Alternate II to the clause in any award where research property will be provided to nonprofit institutions of higher education or nonprofit research institutions. The IPO may recommend including items of contractor -acquired property valued at greater than $5,000 when it is likely that NASA will have no further need for the property and at the conclusion of the award, the award recipient expresses an interest in retaining the property, and the program office concurs. The IPO should consult the Center Equipment Manager and the Center PDO to determine the likelihood of further use by NASA activities prior to making this recommendation.

2.1.2.5 In all awards that contain 48 CFR § 52.245-1, the IPO shall recommend including:

a. 48 CFR § 52.245-9.

b. Solicitation Provisions and Contract Clauses, Property Management Changes, 48 CFR § 1852.245-75.

2.1.2.6 The IPO may recommend including 48 CFR § 52.245-2, in an award where there is exclusive on-Center performance by the award recipient, existing GFP will be provided, and it is expected that the serviceable life of the GFP will not survive the term of the award. Weapons, property controlled under the International Traffic in Arms Regulation (ITAR) and Export Administration Regulations (EAR), and items requiring demilitarization may not be included under this clause. This property may only be provided at award inception. Additional property cannot be added to that identified in the award.

2.1.2.7 The IPO should recommend including Solicitation Provisions and Contract Clauses, Contractor Requests for Government-Furnished Property, 48 CFR § 1852.245-70, in all awards with property associated.

2.1.2.8 When NASA anticipates an award with on-site performance, the IPO should recommend including the IAGP clause, 48 CFR § 1852.245-71. This clause requires the use of Center property management processes and practices for the on-Center activities of the award recipient. Center property information systems are to be used to maintain records to the degree that they are available unless otherwise specified in the award.

a. If a Center property information system is not available or is inadequate to support award performance, the award recipient is required to manage property and record property in accordance with 48 CFR § 52.245-1. This includes any property that does not qualify for control under NASA procedural guidance or Center procedural guidance. IPOs should note that the recipient should propose the system of record-keeping and it may include recording of low-cost durable items in quantity when cost-effective and there is low risk of loss, damage, or destruction.

b. The IPO should coordinate the use of the IAGP clause with the Center SEMO to determine its effect on Center operations. When Center operations are unable to support any or all the effort and the award recipient will perform some or all property management activities, the IPO shall work with the SEMO to provide language for inclusion in the award that provides the description of appropriate property management tasks to be accomplished by the recipient. Tasks may be included within the clause requirements or within the Statement of Work.

c. The IPO shall:

(1) Recommend including the IAGP clause 1852.245-71 with its alternate if the award recipient is to perform receiving activities.

(2) Ensure all IAGP 1845.245-71(c) section checkmarks correctly reference the service or listing being provided. For example, “(c) 3. Property listed in [Insert attachment number or ‘not applicable’ if no equipment is provided]” should reference an IAGP listing attachment or be marked “not applicable.”

(3) Recommend including the NFS clause Liability for Government Property Furnished for Repair or Other Services, 48 CFR § 1852.245-72, when the exclusive purpose of the award is the repair, maintenance, or calibration of NASA equipment.

(4) Recommend including 48 CFR § 1852.245-73, in any award when GP is furnished or when a cost line item and any off-Center performance requirement exists. The clause should also be included in any award that contains the FAR clause Progress Payments, 48 CFR § 52.232-16.

(5) Recommend including Solicitation Provisions and Contract Clauses, Identification and Marking of Government Equipment, 48 CFR § 1852.245-74, in any award that contains 48 CFR § 52.245-1, or that requires the delivery of property.

(6) Recommend including Solicitation Provisions and Contract Clauses, List of Government Property Furnished Pursuant to FAR § 52.245-1, 48 CFR § 1852.245-76, and 2 CFR pt. 200 in any award where the award recipient has requested property and ensure that either the property is listed within the 48 CFR § 1852.245-76 clause or a property list is referenced in an attachment. The government will provide GP under 48 CFR § 52.245-1.

(7) Recommend including Solicitation Provisions and Contract Clauses, List of Government Property Furnished Pursuant to FAR 52.245-2, 48 CFR § 1852.245-77, in on-Center awards when property will be furnished as is to the award recipient in an initial provision; the IPO, program officials, and CO/GO anticipate that the performance life span of the furnished property will not survive the performance period of the award; and the recipient will be required to replace nonfunctional property with contractor-owned property unless otherwise stated in the award.

(8) Recommend including Solicitation Provisions and Contract Clauses, Physical Inventory of Capital Personal Property, 48 CFR § 1852.245-78, in any award where property will be provided. The requirement to conduct physical inventory of items under this clause is limited to those items with a value of $500,000 or above where the award recipient does not have custody of items under that value. Including 48 CFR § 1852.245-78 provides assurance that the recipient will identify and ensure the existence of any items that may meet NASA’s capitalization criteria on an annual basis.

(9) Recommend including Solicitation Provisions and Contract Clauses, Records and Disposition Reports for Government Property with Potential Historic or Significant Real Value, 48 CFR § 1852.245-79, in awards that are likely to generate property of this nature. The Center Cultural Resource Manager (CRM) and the CO/GO are required by the NFS prescription to determine the appropriate use of the clause. However, the IPO should be aware of its use to ensure award recipients’ compliance with record-keeping and reporting requirements.

(10) Recommend including Solicitation Provisions and Contract Clauses, Government Property Management Information, 48 CFR § 1852.245-80, in all awards with GP solicitations, carefully review all responses, and advise the CO/GO when there is a significant response that will require further consideration.

(11) Recommend including Solicitation Provisions and Contract Clauses, List of Available Government Property, 48 CFR § 1852.245-81, in all solicitations where GP will be made available for award performance and ensure that property lists are referenced in the applicable sections.

(12) Work with the Center facilities and real property offices to ensure the correct insertion of real property clauses (i.e., Solicitation Provisions and Contract Clauses, Occupancy Management Requirements, 48 CFR § 1852.245-82, and Solicitation Provisions and Contract Clauses, Real Property Management Requirements, 48 CFR § 1852.245-83) in awards.

(13) Consult with Center CTO when transportation assets (such as motor vehicles, trailers, and vessels) are to be provided to award recipients, to ensure that the award contains Solicitation Provisions and Contract Clauses, Federal Automotive Statistical Tool Reporting, 48 CFR § 1852.223-76, as well as NFS clauses 48 CFR § 1852.228.75, 1852.245-73, 1852.245-74, and FAR clauses 48 CFR § 52.208-6, 52.228-7, 52.228-8, 52.228-10, 52.247.21, and 52.251-1.

2.1.2.9 Award Property Clauses

a. The IPO shall review award terms and conditions and apply professional judgment to determine the appropriate FAR and NFS clauses to be used in the award. IPOs should consider costs associated with implementing property clauses within the award in addition to the requirements of associated laws and regulations.

b. The IPO should recommend including 48 CFR § 52.245-1, in any award where property is furnished or associated.

c. The IPO should recommend including Alternate 1 to the clause in any fixed price award when the conditions of the FAR section Contract Clauses, 48 CFR 45.107(a)(2), apply.

d. The IPO should recommend including Alternate II to the clause in any award where research property will be provided to nonprofit institutions of higher education or nonprofit research institutions. The IPO may recommend including items of contractor -acquired property valued at greater than $5,000 when it is likely that NASA will have no further need for the property and at the conclusion of the award, the award recipient expresses an interest in retaining the property, and the program office concurs. The IPO should consult the Center Equipment Manager and the Center PDO to determine the likelihood of further use by NASA activities prior to making this recommendation.

e. In all awards that contain 48 CFR § 52.245-1, the IPO shall recommend including:

(1) 48 CFR § 52.245-9.

(2) 48 CFR § 1852.245-75.

f. The IPO may recommend including the 48 CFR § 52.245-2, in an award where there is exclusive on-Center performance by the award recipient, existing GFP will be provided, and it is expected that the serviceable life of the GFP will not survive the term of the award. Weapons, property controlled under the ITAR and EAR, and items requiring demilitarization may not be included under this clause. This property may only be provided at award inception. Additional property cannot be added to that identified in the award.

g. The IPO should recommend including 48 CFR § 1852.245-70, in all awards with property associated.

h. When NASA anticipates an award with on-site performance, the IPO should recommend including the IAGP clause, 48 CFR § 1852.245-71. This clause requires the use of Center property management processes and practices for the on-Center activities of the award recipient. Center property information systems are to be used to maintain records to the degree that they are available unless otherwise specified in the award.

(1) If a Center property information system is not available or is inadequate to support award performance, the award recipient is required to manage property and record property in accordance with 48 CFR § 52.245-1. This includes any property that does not qualify for control under NASA procedural guidance or Center procedural guidance. IPOs should note that the recipient should propose the system of record-keeping and it may include recording of low-cost durable items in quantity when cost-effective and there is low risk of loss, damage, or destruction.

(2) The IPO should coordinate the use of the IAGP clause with the Center SEMO to determine its effect on Center operations. When Center operations are unable to support any or all the effort and the award recipient will perform some or all property management activities, the IPO shall work with the SEMO to provide language for inclusion in the award that provides the description of appropriate property management tasks to be accomplished by the recipient. Tasks may be included within the clause requirements or within the Statement of Work.

(3) The IPO shall:

(a) Recommend including the IAGP clause 1852.245-71 with its alternate if the award recipient is to perform receiving activities.

(b) Ensure all IAGP 1845.245-71(c) section checkmarks correctly reference the service or listing being provided. For example, “(c) 3. Property listed in [Insert attachment number or ‘not applicable’ if no equipment is provided]” should reference an IAGP listing attachment or be marked “not applicable.”

(c) Recommend including the NFS clause Liability for GFP for Repair or Other Services, 48 CFR § 1852.245-72, when the exclusive purpose of the award is the repair, maintenance, or calibration of NASA equipment.

(d) Recommend including 48 CFR § 1852.245-73, in any award when GP is furnished or when a cost line item and any off-Center performance requirement exists. The clause should also be included in any award that contains the FAR clause Progress Payments, 48 CFR § 52.232-16.

(e) Recommend including 48 CFR § 1852.245-74, in any award that contains 48 CFR § 52.245-1, or that requires the delivery of property.

(f) Recommend including 48 CFR § 1852.245-76, and 2 CFR pt. 200 in any award where the award recipient has requested property and ensure that either the property is listed within the

48 CFR § 1852.245-76 clause or a property list is referenced in an attachment. The Government will provide GP under 48 CFR § 52.245-1.

(g) Recommend including 48 CFR § 1852.245-77, in on-Center awards when property will be furnished as is to the award recipient in an initial provision; the IPO, program officials, and CO/GO anticipate that the performance life span of the furnished property will not survive the performance period of the award; and the recipient will be required to replace nonfunctional property with contractor-owned property unless otherwise stated in the award.

(h) Recommend including 48 CFR § 1852.245-78 in any award where property will be provided. The requirement to conduct physical inventory of items under this clause is limited to those items with a value of $500,000 or above where the award recipient does not have custody of items under that value. Including 48 CFR § 1852.245-78 provides assurance that the recipient will identify and ensure the existence of any items that may meet NASA’s capitalization criteria on an annual basis.

(i) Recommend including 48 CFR § 1852.245-79, in awards that are likely to generate property of this nature. The CRM and the CO/GO are required by the NFS prescription to determine the appropriate use of the clause. However, the IPO should be aware of its use to ensure award recipients’ compliance with record-keeping and reporting requirements.

(j) Recommend including 48 CFR § 1852.245-80, in all awards with GP solicitations, carefully review all responses, and advise the CO/GO when there is a significant response that will require further consideration.

(k) Recommend including 48 CFR § 1852.245-81 in all solicitations where GP will be made available for award performance and ensure that property lists are referenced in the applicable sections.

(l) Work with the Center facilities and real property offices to ensure the correct insertion of real property clauses (i.e., the NFS clause Occupancy Management Requirements,

48 CFR § 1852.245-82, and 48 CFR § 1852.245-83) in awards.

(m) Consult with Center CTO when transportation assets (such as motor vehicles, trailers, and vessels) are to be provided to award recipients, to ensure that the award contain 48 CFR § 1852.223-76, as well as NFS clauses 48 CFR § 1852.228.75, 1852.245-73, 1852.245-74, and FAR clauses 48 CFR § 52.208-6, 52.228-7, 52.228-8, 52.228-10, 52.247.21, and 52.251-1.

2.1.2.10 Offering Property for Award Performance

While the decision to provide property to an award recipient is a decision reserved for the CO/GO, the IPO shall advise the CO/GO regarding the provision of property, noting such factors as the risk to both award performance and to the loss, damage, destruction, or misuse of the property, as well as the increased cost of administration and disposition of property.

2.1.2.11 Funding for Administration and Disposition of GP

a. The Mission Directorates shall identify and provide funding in the award for the administration and disposition of GP.

b. The NFS solicitation provision 48 CFR § 1852.245-80 requests information from the award recipient regarding the direct charging of property. Under cost award, property that is directly charged to the Government becomes titled to the Government and is considered “provided” to the award recipient. As a result, the IPO shall:

(1) Consider that in awards with cost components, some award recipients may not request property in response to the solicitation but will acquire it as a direct cost after award in accordance with their disclosed cost accounting practices.

(2) Advise the CO/GO of this possibility when the IPO believes it to be appropriate.

2.1.3 Award Recipients Operating Within NASA Facilities

2.1.3.1 In accordance with IAGP clause, 48 CFR § 1852.245-71, on Center recipients operating within NASA Centers and Installations are required to utilize available NASA systems to maintain property records and to follow NASA policies and procedures for the management of GP unless stated otherwise in the award.

2.1.3.2 The IPO shall ensure that the Center SEMO is informed of any use of the IAGP clause and obtain the Center SEMO’s concurrence prior to completing the solicitation evaluation.

2.1.3.3 Center procedures need to provide for any additional coordination of award reviews. When additional coordination is required, Center procedures will include instructions and assign responsibility for proper maintenance of any procurement-sensitive information.

2.1.3.4 IPOs shall monitor the receipt and, if required, ensure the prompt completion of any additional reviews.

2.1.4 Award Recipient Use of NASA Property Management Information Systems

a. The IPO shall work with the SEMO to ensure that Center procedures provide clear implementation of the requirements of Chapter 4 of this NPR regarding processing transfers of property to and from awards.

b. The IPO, working with the CO/GO and SEMO, shall ensure that language is included within the IAGP clause or that other appropriate guidance is provided to award recipients regarding:

(1) When property will be managed within a recipient’s system.

(2) When property will be managed within NASA systems.

(3) How it will be managed during transitions between the two (recipient and NASA systems).

c. The IPO shall work with the SEMO and real property personnel to identify local procedures that require incorporation in the appropriate section of the IAGP clause.

d. IPOs should also ensure the proper notation of the IAGP clause related to the services and property to be provided from Center sources.

e. When award recipients are required to perform significant property management tasks, i.e., logistics support or program logistics, the IPO shall assist in the development of special requirements for inclusion in the Statement of Work.

2.1.5 Award Recipient with Mixed On- and Off-Center Performance

2.1.5.1 IPOs shall pay special attention to awards when it is anticipated that recipients will have both on- and off-Center performance requirements. Proper application of the IAGP clause is essential.

a. The IPO shall work with the SEMO and the CO/GO to ensure that language is included in the IAGP clause to provide clear guidance to award recipients regarding:

(1) When property will be managed according to award recipient plans and recorded in the recipient’s system.

(2) When it will be managed according to Center process and systems.

(3) How it will be managed during transitions between the two.

2.1.5.2 Receiving Activities

The IPO shall:

a. Ensure that the award contains the appropriate alternates regarding award recipient’s receiving facilities.

b. Consult with the SEMO to determine the impact of award receipts on Center operations.

c. After consulting with the SEMO, advise the CO/GO of any requirement for use of the alternate clause.

d. Establish processes to ensure the Center Equipment Manager is advised of the recipient’s acquisition and receipt of Government-owned property when the property will be used within the Installation or Center.

2.1.6 Documentation of Recommendations

a. The IPO shall:

(1) Establish an award property file for each solicitation or award reviewed. The folder should contain all relevant documents. Electronic files are adequate for this purpose if they can be readily referenced and are organized consistently.

(2) Document any recommended changes to the solicitation or award in the form of a memorandum or e-mail to the CO/GO and retain a copy in the award property file and follow any special communication and data storage methods of sensitive information.

2.2 Evaluation of Award Recipient’s Proposed Property Plans

2.2.1 Completeness of Proposed Property Plans

2.2.1.1 Prior to review of the award recipient’s proposed property plan (PPP), the IPO shall identify applicable segments or outcomes required by the circumstances of the award. Some awards may not require all segments or outcomes. For example, some recipients may not be required to store GP, or all property provided to a recipient may be consumed during performance, negating the requirement for maintenance as none of those items would fall within equipment, special test equipment (STE) or special tooling (ST) categories. As such, the IPO needs to be familiar with all aspects of the award’s GP requirements.

2.2.1.2 For grants and cooperative agreements with recipient-purchased equipment that vest in the Federal Government, the PPP does not apply. However, 2 CFR pt. 200 does establish minimum equipment management requirements for grant and cooperative agreement recipients. The IPO shall document the solicitation/award file as to whether a particular segment or outcome of the property system is applicable and, if not, why not.

2.2.1.3 After determining the applicability of segments or outcomes, the IPO shall:

a. Determine whether the PPP addresses all applicable segments or outcomes.

b. Consider the factors associated with risk to safety, performance, and cost when determining the criticality of property plan performance to the overall award effort and when establishing the scope and depth of the review of the award recipient’s PPP for acceptability.

c. If an applicable segment or outcome is not adequately addressed, advise the CO/GO that the award recipient’s PPP is deficient in that regard, and that the recipient is required to address the deficient areas prior to award.

d. Ensure the award recipient’s property management procedures clearly describe how they will perform physical inventories, identify by title, the employees responsible for performing each phase of the inventory, and specifically define the frequency of physical inventory performance. e. The physical inventory method and frequency need to be sufficient to ensure the accuracy of the balance on hand as reflected in the award recipient’s records. The procedures need to clearly define a process for normal and reasonable inventory adjustments.

f. Ensure the award recipient’s procedure requires that severable items of commercially available equipment incorporated into STE or systems are uniquely within the recipient’s record system.

g. Ensure the award recipient’s PMS enables correct categorization of GP for property submission reporting purposes in accordance with the GCAM and 48 CFR § 1852.245-73.

2.2.2 Award Recipients’ Proposed Standards, Practices, Processes, and Systems

2.2.2.1 Use of Voluntary Consensus Standards (VCS)

a. Federal Law, the FAR, Executive Orders, OMB Circulars, and U.S. Department of Commerce regulations encourage the use of VCS in lieu of creating and implementing specific Federal or Agency standards and practices, except where VCS do not satisfy the specific, justified requirements of the Agency. NASA or Center-specific requirements may drive additional award cost, so the application of NASA or Center-specific requirements should be considered carefully and added only when the need for the additional activity, report, or record outweighs possible costs, schedule delays, or other negative outcomes.

b. It is important to establish whether an award recipient’s proposed VCS satisfy both Government and NASA-specific requirements. While VCS are likely to be sufficient and applicable for most awards and should be approved for those segments or outcomes of the property systems they address, the IPO should work with program and project management personnel to determine whether the circumstances of the award justify NASA-specific procedural requirements or performance requirements. For example, property acquired for human-rated space flight systems is likely to require a higher level of quality to ensure safety. As such, the award recipient’s property system may require specific shelf-life standards and special storage requirements. The recipient’s records and supply issue processes may need to have a high level of accuracy to ensure that the correct, authentic, and current part is used. Similarly, the award’s circumstances may require retention of sufficient inventory or the ability to acquire sufficient inventory within limited, award-required timeframes to avoid flight delays. Higher performance standards may be required within the award recipient’s acquisition and consumption segments or outcomes to ensure this.

c. Voluntary Consensus Standards—Procedural. Some VCS provide procedural guidance or instructions on how to perform an activity. These standards describe the award recipient’s methods for performing property activities. These standards generally provide minimal standard requirements that can be agreed to by all parties. To the degree that these procedures are both adequate to ensure the proper use and protection of NASA property and the execution of the requirements of the award, the IPO should accept them.

d. Voluntary Consensus Standards—Performance. Some VCS specify levels of performance. For example, a standard may categorize a PMS’s risk based on the loss rate experienced over a period, recognized during a physical inventory, or based on the criticality of the item to mission performance. The FAR places greater emphasis on the outcomes of a property system than on the methods used to achieve the outcome; performance standards should be preferred to procedural standards. IPOs should encourage use of performance standards or a combination of their use with procedural standards.

2.2.2.2 Use of Industry Leading Practices and Standards (ILPS).

The IPO should take care in accepting the use of ILPS. While the FAR allows for their use, it does not define their term. Considering this, it is important to differentiate between CCP and ILPS. When all members of a representative industry group develop a practice, it is a CCP. NASA expects ILPS to exceed the CCP or the VCS. When a recipient proposes ILPS, it should be ready to provide data that proves the ILPS’s efficacy, cost-effectiveness, and status as the “industry leader.” Some award recipients may propose a CCP. This is not prohibited but should be treated more as an existing procedure, process, or system with greater scrutiny during the evaluation process.

2.2.2.3 Use of Customary Commercial Practices (CCPs).

Award recipients may propose, and the IPO may accept CCPs when they are adequate to satisfy the specific requirements and circumstances of the award and when they are fully documented as accepted CCPs or standards by a recognized industry group.

2.2.2.4 Use of Existing Procedures, Processes, and Systems

a. IPOs shall evaluate the efficacy and applicability of existing award recipient’s procedures, processes, and systems.

b. Use of existing systems is not prohibited; however, in lieu of award recipient-specific standards and practices, IPOs shall recommend the use of VCS, ILPS, and CCPs when available and to the degree they are applicable to the award circumstances.

2.2.2.5 Use of Award Recipient Self-Assessment Processes

Contract award recipients are required to establish, maintain, and execute internal self-assessment processes adequate to ensure the efficiency and effectiveness of controls for the management of GP in their possession. Programs may vary widely in scope and content depending on factors such as the complexity of the recipient’s operations and the amount and types of GP to be managed. Programs may be self-contained or may relate to or be part of an overall self-assessment program such as a corporate internal audit program, an internal International Organization for Standardization (ISO) audit, or an external ISO certification program when the program contains specific GP audit requirements. Award recipient’s self-assessment programs are not a substitute for government oversight and for Government insight as they lack the critical element of independence.

2.2.3 Risk Considerations

2.2.3.1 Proportional Value of Property

a. The IPO shall consider the expected value of GFP and the potential value of contractor -acquired property (CAP). When the estimated average annual value of property does not exceed $10 million, risk should be assessed based on the ratio of property acquisition value to the estimated annual value of the award according to the following:

(1) When the estimated annual average value of provided GP exceeds $10 million or above, the award recipient is required to report monthly in NASA’s OCFO Contractor Held Asset Tracking System (CHATS) via https://chats.nasa.gov or exceeds 10 percent, the risk is considered high and greater oversight and control should be exercised.

(2) Awards where the estimated annual average value of provided GP is between 5 and 9.9 percent of the estimated annual average value of the award should be considered medium risk for value factors and require moderate levels of oversight and control.

(3) Awards where the estimated annual average value of provided property is less than 5 percent of the estimated annual average value of the award should be considered low risk for value factors and require only minimal oversight and control.

2.2.3.2 Award Type

a. The IPO shall consider all cost type awards to have greater risk as the likelihood of award recipient’s acquisition of property titled to the Government under 48 CFR § 52.245-1, is high and the recipient’s risk of responsibility for loss, damage, or destruction of that property is lower than most fixed price awards.

b. The IPO shall consider fixed price awards under Alternate 1 of 48 CFR § 52.245-1, to be of lower risk as property acquired by the recipient is titled to the recipient and the recipient is fully liable for loss, damage, destruction, or theft of the GFP.

c. The IPO shall consider fixed price awards under Progress Payments, 48 CFR § 52.232-16 and Performance-Based Payments, 48 CFR § 52.232-32, to have a low risk unless the value of actual and potential property titled to the government during the award exceeds the $10 million threshold or one of the value thresholds under Section 2.2.3.1.

2.2.3.3 Relationship with Award Tasks/Products

The use and management of property may have a profound effect on an award recipient’s ability to perform and to complete the requirements of the award. This may be applicable both to deliverable property and deliverable service awards. The following factors should be considered when establishing risk:

a. Logistics Support Awards

(1) Logistics support award recipients are responsible for significant amounts of Government personal property. Their procedures and standards are likely instituted to ensure compliance with NASA procedural guidance required by the NFS clause IAGP, 48 CFR § 1852.245-71.

(2) When Centers prescribe implementing procedures, the IPO shall work with the SEMO to ensure that the award recipient’s PPP complies with NASA procedural guidance.

(3) When the award allows the recipient to provide implementing procedures, the IPO should work with the SEMO to ensure that the recipient’s PPP is adequate for implementation of NASA procedural requirements and NASA policy guidance.

b. High-Risk Program Suppliers

(1) Award recipient supply of property to high-risk NASA programs increases risk in a variety of ways. First, there is a risk of late delivery of procured items, which may be related to a deficiency in the award recipient’s property program. While failure of any aspect of a recipient’s property system will increase risk to the Government, the property plan of high-risk suppliers should receive greater scrutiny in the areas of subcontract property management, acquisition, records, and physical inventory.

c. Award Recipients with Significant Property Management Duties

(1) An award recipient, other than a logistics support recipient, may be required to provide property custodians to support Center property management operations by entering data into NASA systems, processing receipts, reporting disposition actions, and performing other related activities. This may result in increased risk to Center property and operations. When the Center SEMO determines that it is necessary to task recipients with property management support activities, the IPO should coordinate the review of the recipient’s PPP with the SEMO to ensure their compliance with property management requirements.

2.2.3.4 Special Requirements

a. Hazardous Property

When required by the circumstances of the award, special attention should be given to award recipient qualifications and experience in handling hazardous items. The CO/GO and program, environmental, and safety officials shall provide the required Safety Data Sheet (SDS) when hazard material is associated with property. Prior to the award the IPO should ensure the recipient’s PPP appropriately addresses storage, handling, and disposition of these items. The IPO should coordinate their response to these plans with the Center environmental activity.

b. Human-Rated Flight Activities

(1) As human-rated flight activities involve risk to the life, health, and safety of the crew and the condition of the craft, the IPO shall work with program officials and safety officials to ensure the award recipient’s PPP adequately addresses these topics. Special consideration may be given to acquisition of qualified, authentic supplies; storage and preservation; accuracy of inventory records; receiving; and issuance.

(2) The IPO should work with program officials and quality assurance personnel to ensure that the recipient’s property system properly addresses documentation in support of Flight Readiness Certification when such certification is required by the award.

c. Special Program Requirements

The IPO shall work with the program to ensure the PPP addresses all specific program requirements.

d. Foreign Awards

(1) Foreign awards require special attention as the disposition of property in foreign countries may be subject to a variety of U.S. laws and regulations including ITAR and EAR. These awards require a great deal of scrutiny.

(2) Foreign awards are likely to be governed by international agreements and property management activity may be subject to foreign law. As such, the IPO shall request copies of the international agreement under which the award will be executed.

(3) International agreements may require alteration of standard FAR clauses or use of entirely different language. If other than standard FAR clauses are used, deviations authorizing the use of that language should be in place prior to award and evidenced in the award property file.

(4) The IPO shall work with the Center Export Administration Officer to ensure that property under the award is properly approved for export and that the conditions for disposition are identified in the award at award inception.

(5) Some property may require return to the United States for disposition or demilitarization on Center.

e. Awards Likely to Produce Historically Significant Property

The IPO shall review awards likely to produce historically significant property when the CO/GO, working in consultation with the Center CRM, inserts 48 CFR § 1852.245-79, in an award. The award recipient’s PPP should address the record-keeping requirements under this clause.

2.2.4 Pre-Award Evaluation of Past Property Management Performance

2.2.4.1 Under 48 CFR § 1852.245-80, offerors are required to submit the results of their latest PMSA and award information for the assigned GPA. The IPO shall:

a. Review the offeror’s submissions to determine the status of the award recipient’s system and who conducted the audit.

b. Advise the CO/GO immediately of any instances where the GPA found the offeror’s PMSs or practices to be inadequate or the Agency’s Administrative CO/GO/Grant TO removed approval for the property system.

c. Consult the cognizant GPA to determine if there have been any updates to the last PMSA and to compare the proposed system to the system last rated by the GPA. Changes to the offeror’s system may signify improvements required by the GPA or the implementation of new, improved processes and standards. They may also signal a retreat to a lower standard or unacceptable procedure. In either case, instances in which the award recipient’s proposed system and the existing system differ significantly should be considered as a possible risk by the IPO and carefully reviewed.