NASA Procedural Requirements

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

Subject: Administration of Property in the Custody of Award Recipients

Responsible Office: Office of Strategic Infrastructure

Chapter 6. Award Recipient Property Management Reporting

6.1 Support for Financial Reporting

6.1.1 While the GCAM, CFR and FAR intend that award recipients’ property records are to be used as custodial records, several areas of those records serve cross-functional purposes with financial management activities. To that extent, property systems need to provide reports that can also be used for financial reporting purposes. Reports used to support financial statements need to be accurate, complete, and submitted in accordance with award requirements by individuals who are authorized by the recipient to submit them.

6.1.2 Review of Annual Government Property Financial Reports (NASA Property Submissions)

6.1.2.1 All property submission reports need to be supported by a GPA’s PMSA verification that the award recipient’s property system can produce accurate reports. Accuracy is determined using several methods. They include reviews of the recipient’s physical inventory process, which are expected to provide reasonable assurance of the existence and completeness of the property records. Determination of accuracy is also facilitated by the PMSA, where the GPA obtains insight into, evaluates, and provides oversight for the recipient’s entire property management effort. The recipient’s PMS is reviewed at inception and the Agency’s audit frequency can be found in Section 5.2, Risk Assessment and Table 5-1, Risk Assessment Matrix.

6.1.2.2 Special Considerations of High-Risk Award Recipients

a. To validate information contained in property submission reports, GPAs, annually prior to September 30, regardless of the FIP risk assessment, shall:

(1) Ensure the validity of the recipient’s property records by reviewing the Records, Physical Inventory, and Reports segments of the recipient’s annual PMSA prior to approving the property submission.

(2) Test the recipient’s records or system to ensure they are correct, valid, and either based on appropriate supporting documentation or derived from other validated recipient systems.

(3) For international awards (i.e., awards to entities outside the United States, its possessions, and its territories), ensure the recipient’s recorded property values remain constant and do not change due to fluctuations in exchange rates.

(4) Check to ensure the recipient does not prematurely record deletion transactions. Transactions associated with physical transfers between recipients should be recorded only as instructed by the award language or written instructions from the Government.

(5) Upload the adjustment records (deletions or additions, etc.) into NESS awards under the Documents tab for IPO, OCFO Property Accountant, and audit trail in the Agency.

6.1.2.3 Use of NESS

a. Award recipients shall not report property submissions in NESS when no GP was ever awarded to them. If award recipients currently have a requirement in their non-GP award for annual property submissions and a final property submission, the recipients will request the latest NF 1018 from https://nef.nasa.gov via their Center CO/GO or IPO and submit a $0 value version to the Center CO/GO and IPO until the CO/GO removes the requirement in their updated award modification.

b. All NASA reporting related to the annual and final property submissions occurs in the Agency’s APSR/NESS when GP is associated with the award. After property submissions are completed and submitted by award recipients, NESS produces the results in NF 1018. Recipient use of NESS for all property submission reports is mandatory. If an award recipient has any challenges gaining access to NESS, the recipient is to contact the Center IPO immediately.

c. NESS opens on October 1st each calendar year for annual property submissions. All final property submissions with GP associated in the award can be submitted year-round in NESS at https://ness.nasa.gov/contractor.

d. When an award recipient’s unit cost of items to be acquired, furnished, constructed, or fabricated will meet or exceed the capitalization threshold of $500,000 or above, the recipient shall report monthly in NASA/OCFO CHATS via https://chats.nasa.gov for more information. OCFO is tracking embedded leases according to Accounting Standards Codification (ASC) 842 for required reporting in annual property submission in NESS. ASC 842 is a lease accounting standard by the Financial Accounting Standards Board (FASB), requiring all leases longer than 12 months to be reflected on the award recipient’s balance sheet. Some common types of awards that may contain embedded lease include agreements for information technology arrangements, transportation, inventory management and warehousing, cable, and satellite, etc., Heritage Assets will be captured by award recipients under annual/final property submissions and reported monthly in NASA/OCFO CHATS. (See Center OCFO and NPR 9250.1, for additional information).

e. Table 6-1 indicates the Agency’s APSR/NESS annual/final property submissions reporting deadlines for all internal/external stakeholders set by NASA’s OCFO.

Table 6-1 NESS Annual/Final Property Submission Approvals
and Reporting Deadlines

6.1.2.4 GPA Verification of Adequacy

The GPA shall verify the figures in the property submission reports.

a. The GPA shall verify that the recipient’s property system can produce correct and accurate reports based on the GPA’s evaluation of the recipient’s property system.

b. The GPA will consider the most recent complete PMSA findings related to records, physical inventory, or reporting outcomes and any recipient actions to address the findings and will annotate the property submission accordingly.

6.1.2.5 IPO Responsibilities

a. The IPO shall review the property submission reports to ensure that the GPA verification is completed, and the report appears to contain correct information based on documents and data retained in NESS and resolve any identified discrepancies with the GPA and the recipient prior to verification.

b. The IPO shall maintain the award with award recipients, GPAs, and other personnel to ensure the timely submission of property reports in NESS.

c. For reports that are not submitted by the award recipient within the requirements established in the award, the IPO shall report the award number, name, and points of contact on the award to the CO/GO and HQ-CPPM in 10 business days for further action. (See Table 6-1 for more information.)

d. For more information on financial management reporting requirements for personal property, including property in the custody of award recipients, refer to the GCAM; NPR 9250.1, Property, Plant, and Equipment and Operating Materials and Supplies; and this NPR.

6.2 Property Administration Reporting/Metrics

6.2.1 PMS metrics not only support financial reporting but should also help NASA management determine whether the program is succeeding, whether the resources allocated to the program are sufficient, and whether they are being effectively utilized. Internal metrics and reports should provide insight into whether the requirements of regulations are being met, and the HQ-CPPM, the Center OCFO Property Accountants, the OP PMPD, and the NSSC will monitor certain critical issues on a regular basis to ensure compliance.

6.2.2 Solicitations Issued Versus Solicitations Reviewed

a. IPOs shall establish a method for collection and reporting of information on the number of solicitations issued versus the number of solicitations reviewed.

b. IPOs shall submit the report annually to the HQ-CPPM.

c. The following data are required: (See Table 6-2 for more information.)

(1) Subtotal number of solicitations issued for cost awards.

(2) Subtotal number of fixed price solicitations with GFP issued or anticipated.

(3) Total number of solicitations reviewed by the Center GP activity.

(4) Ratio of solicitations reviewed to applicable award solicitations issued.

Table 6-2 Solicitation Review Metric

6.2.3 Review of Recipient Proposed Systems

6.2.3.1 IPOs shall establish a method for collecting and reporting information on the number of off-Center recipient systems reviewed versus the number subject to review.

6.2.3.2 IPOs shall submit the report annually to the HQ-CPPM.

6.2.3.3 The following data are required: (See Table 6-3 for more information.)

a. Subtotal number of cost type awards issued.

b. Subtotal number of fixed price awards with known GFP issued.

c. Total number of applicable awards issued by Center procurement activities.

d. Total number of proposed PMSAs reviewed by the Center industrial property activity.

e. Ratio of audits to applicable awards.

Table 6-3 Proposed System Reviews

6.2.4 Ratio of High-Risk Awards to PMSA Performance

6.2.4.1 IPOs shall establish a method for collecting and reporting metrics on the performance of PMSAs. The most critical PMSAs are audits associated with high-risk recipients.

6.2.4.2 IPOs shall submit the report annually to the HQ-CPPM.

6.2.4.3 The following data are required: (See Table 6-4 for more information.)

a. The number of audits of high-risk recipients completed by NASA and delegated GPAs during the fiscal year.

b. The number of audits required for high-risk recipients according to the risk matrix shown in Table 5-1.

c. The ratio between the number of required reviews and the number performed.

Table 6-4 High-Risk Reviews

6.2.5 Ratio of Overall Awards to PMSA Performance

6.2.5.1 The IPO shall report the overall effort as of the end of the fiscal year to the HQ-CPPM.

6.2.5.2 The following data are required: (See Table 6-5 for more information.)

a. The number of audits of all recipients completed by NASA and delegated GPAs during the fiscal year.

b. The number of reviews required for all recipients according to the risk matrix shown in Table 5-1.

c. The ratio between the number of required audits and the number performed.

Table 6-5 PMSA Reviews Conducted

6.2.6 Number of Awards with Unresolved Findings at End of Period

6.2.6.1 The IPO shall report the number of awards with unresolved findings as of the end of the fiscal year to the HQ-CPPM.

6.3 Annual Award Recipient Property Reporting Requirements

6.3.1 Information on recipient property holdings needs to be accumulated for a variety of management activities. In addition to the financial reporting activities discussed in Section 6.1, reports are used to determine risk levels associated with recipient possession of GP, to appropriately allocate industrial property resources, and to provide information for planning future activities such as disposition. Information will be reported by the recipient in accordance with the GCAM, 48 CFR § 52.245-1, and 48 CFR § 1852.245-73.

6.3.2 Property Information Derived from Property Submissions

In support of property management activities, NESS provides significant data on recipient holdings of GP. This information should be used to determine risk and to support PMSA audit scheduling. NESS data includes:

a. Overall acquisition value of property on hand at the beginning and end of a period.

b. Overall number of line items of property on hand at the beginning and end of the period.

c. Value of items acquired by the recipient or furnished to the recipient over the period.

d. Value of property by 2 CFR pt. 200 and FAR property classification.

e. Value of items dispositioned over the period.

f. Summary of disposition activities by disposition type.

g. Values of items lost.

h. Quantity of equipment, ST, and special test items on hand at the end of the period.

i. Embedded lease.

j. Heritage assets.

6.3.3 NASA Electronic Submission System

6.3.3.1 All NASA recipients with GP shall submit property submissions electronically via https://ness.nasa.gov/contractor. Once three levels of approvals are completed by Federal employees in NESS, the system produces a pdf version of the OMB-controlled NF 1018. Its principal use is the collection of GP and financial management information in support of financial and audit reporting. In addition to the data elements listed above, NESS also accumulates data in support of PMSAs.

6.3.3.2 Additional NESS property datasets include:

a. Awards in the enterprise management resource system, (i.e., the System Applications and Products (SAP), EPDW, etc.).

b. Awards with GP accepted into NESS, with detail.

c. History of property submissions which produced NF 1018s for completed annual and final awards.

d. Status of PMSA and the status of property system segments.

e. Contact information associated with awards.

f. An audit trail of transactions and supporting documentation associated with the NESS award records.

6.3.3.3 Maintenance of NESS Data

a. IPOs shall assess the list of incoming SAP awards to determine whether it is appropriate to add the skeletal records for awards in the list to NESS and accept or reject the award skeletal records accordingly.

b. GPAs and IPOs shall update information in the NESS Contract/Award Details page regularly as changes are received, including updates to periods of performance, assigned personnel, and addition or deletion of clauses.

c. GPAs and IPOs shall update the recipient’s system status (from PMSAs) when received from NASA or delegated GPAs and when the date of the audit is more recent than the date on file.

(1) GPAs and IPOs shall ensure that copies of reviews are stored in NESS electronically for the Agency’s record-keeping and audits.

(2) IPOs at other Centers may request copies of the reviews from the HQ-CPPM when needed in support of activities such as proposals.

d. IPOs may request several actions from the HQ-CPPM who is the system administrator at Headquarters. These include resetting an award to pending so that a recipient may resubmit a rejected annual or final property submission report, moving an award from history to active status, and adding a new cage code with novation letters from CO/GO and related recipient information when not part of the system.

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