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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 9. Requirements for Grants and Cooperative Agreements

9.1 General

9.1.1 The NASA OP PMPD GPC Team writes, maintains, and distributes the GCAM as part of its NASA-wide grant and cooperative agreement policy roles and responsibilities. On the other hand, NSSC is responsible for issuing, administering, and managing all grants and cooperative agreements for NASA. Grants and cooperative agreements are part of the HQ-Contract Property Program for off-Center NASA awards with GP and plant clearance.

9.1.2 NPD 9680.1, Use and Authority of the Grant and Cooperative Agreement Manual, provides policy guidance to NASA GOs, TOs, program managers, and all other award-management-related personnel to implement Government-wide and NASA-specific regulations for awarding and administering grants and cooperative agreements with State, local, and indigenous tribal governments; with educational and non-profit organizations; and with

for-profit organizations.

9.1.3 Policies established in the GCAM are based primarily on the following regulations:

a. The requirements in 2 CFR pt. 200 apply to all Federal agencies that issue awards for grants and cooperative agreements to non-Federal entities that receive such Federal awards. Subpts. A through F of 2 CFR pt. 200 apply to all recipients of NASA grant and cooperative agreement awards except for for-profit entities. For-profit entities adhere to 2 CFR pt. 200, subpts. A through D and Cost Accounting Standards Administration, 48 CFR pt. 30, and 48 CFR pt. 31.

b. Federal Agency Regulations for Grants and Agreements, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR pt. 1800. This is the NASA supplement to 2 CFR 200. The requirements in this part are applicable to awards issued by NASA to non-Federal entities, for-profit organizations, and foreign organizations as required by the Applicability sections 2 CFR § 200.101 and 2 CFR § 1800.3.

9.1.4 All requirements in 2 CFR pt. 200, 2 CFR pt. 1800, and an award’s terms and conditions flow down to subaward recipients unless stated otherwise. All recipients shall ensure that subaward recipients comply with all applicable sections of the regulations mentioned in Section 9.1.3. (See the GCAM for more information.)

9.2 Type of Award Instruments

The Federal Grant and Cooperative Agreements Act of 1977 (FGCAA), 31 U.S.C. § 6301 et. seq., was enacted to give agencies a better understanding of the types of instruments executive agencies may award by characterizing the relationship between executive agencies and award recipients (States, local governments, and other recipients) in acquiring property and services and in providing federal financial assistance (See 2 CFR pt. 200 for a definition of Federal financial assistance. See the GCAM for more information.)

9.3 Relationship between the GCAM and Grant Information Circulars (GICs)

9.3.1 GPC may issue policies or guidance periodically using a Grant Information Circular (GIC) to supplement, clarify, augment, remove, and/or alter information included in the GCAM or to provide other important updates. GPC will make GICs publicly available at: https://www.nasa.gov/offices/ocfo/gpc/regulations_and_guidance/active_gics and will distribute GICs to NASA personnel via e-mail.

9.3.2 During the annual GCAM update process, GPC incorporates relevant and active GICs into the text of the GCAM and then retires the active GICs to the GIC archive for future reference. Expired GICs are stored at https://www.nasa.gov/offices/ocfo/gpc/regulations_and_guidance/gics_archive. (See the GCAM for more information.)

9.4 Relationship between the GCAM and the FAR

A grant and cooperative agreement award issued to a for-profit organization is governed by the FAR cost principles in accordance with 48 CFR pt. 30, and 48 CFR pt. 31, 2 CFR pt. 200 subpts. A through D, and the GCAM. Additionally, a NASA Research Announcement (NRA) that may result in an award (grant, cooperative agreement, and/or contract) is subject to the GCAM Appendix A, Standard Format for a NASA Notice of Funding Opportunity (NOFO). (See the current version of the GCAM for more information about the relationship between GCAM and the FAR.)

9.5 Roles and Responsibilities

9.5.1 GPC is responsible for developing Agency-wide award policies and guidance, for ensuring that NASA complies with applicable statutes and regulations, and for providing technical assistance and training to NASA’s award-management community.

9.5.2 Each NASA award is assigned a NASA Grants TO to manage the programmatic, scientific, and technical aspects of the award. Program offices are responsible for identifying funding; soliciting, evaluating, and selecting proposals; and monitoring awards to ensure performance goals are met and deliverables are achieved. TOs are responsible for reviewing the technical aspects of performance reports and providing feedback to recipients, addressing recipients’ technical questions, conducting site visits as necessary, and working with the NSSC to provide programmatic input on recipients’ requests for any changes to the award (e.g., key personnel changes, no-cost extension requests). Only NASA civil servants or personnel participating in the Intergovernmental Personnel Act (IPA) Mobility Program, 42 U.S.C. § 4701 et seq., may serve as TOs on NASA grants and cooperative agreements. When key personnel who are the points of contact on NASA awards change, the TO shall notify the Center IPO when property is associated.

9.5.3 Only an NSSC GO (who may also be a CO) may issue new awards, amend awards, and provide prior approval for certain post-award actions in accordance with the section Prior Written Approval, 2 CFR § 200.407. Only GOs may make the final determination regarding the allowability, allocability, and reasonableness of a recipient’s expenditures charged to an award. If an award needs to be terminated, a GO is the final approving official on such termination decisions. (See the GCAM for more information on roles and responsibilities.)

9.6 Performance Report Requirements

9.6.1 All NASA award recipients with GP associated with their awards shall submit an annual and final property submissions via https://ness.nasa.gov/contractor for audit-readiness in the Agency. (See Section 1.3.7.3, Annual and Final Property Submissions and Table 6-1 for more information.)

9.6.2 All earlier chapters (1-Administration of NASA Property in the Custody of Award Recipients, 2-Pre-Award Process, 3-Delegation and Oversight of Property Administration Activities, 4-Performance of NASA-Retained Property Administration Activities, 5-Property Management System Analysis (PMSA), 6-Award Property Management Reporting, 7-Special Situations and 8-Award Recipient Inventory Disposition) are applicable according to the terms and conditions of grant and cooperative agreement awards with GP associated. (See 2 CFR 200, GCAM for more information.)

9.6.3 Awards that are in their final year or have a period of performance of less than a year are only required to submit final performance reports. Final performance reports are due within 120 days after the expiration of the award’s period of performance. Note that subaward recipients are still required to submit their final reports to their pass-through entity within 90 days after the expiration of their subaward’s period of performance. (See the GCAM for more information on reporting requirements, public release of Scientific and Technical Information (STI) by NASA, methods of procurement, administrative change and supplements, approval of equipment, exempt equipment, and other topics.)

9.7 Continued Services

9.7.1 One of NASA’s FIPs terminated their memorandum of agreement (MOA) for university and grants and cooperative agreements, and research institutions LODs prior to the end of FY23. NASA has an extremely low number of grants and cooperative agreements with GP associated; and many of the awards do not meet the acquisition threshold and others are part larger acquisition awards that are delegated to another FIP. (See Table 5-1 for more information.)

9.7.1.2 The majority of awards received PMSAs by the previous FIP that had GP associated according to the FIP’s risk category schedule. Awards that meet the acquisition threshold and located at larger acquisition award locations will be included in FIP PMSAs (if not currently reporting); and other low-risk awards will remain with the NASA Centers to manage according to the terms and conditions with GP associated and Risk Assessment Matrix. Any NASA retained awards will follow the applicable outcomes for PMSAs via NF-1019.

9.7.1.3 Although recipients of grants and cooperative agreements are not required to maintain a property plan, minimum equipment requirements for grants and cooperative agreement recipients are established under 2 CFR § 200.313.

9.7.1.4 NF 1019 is used for the following but not limited to additional outcomes by the GPA:

a. All full PMSAs require an entrance conference. If limited PMSA is appropriate (based on risk), there is no formal entrance briefing required but an exit conference is required. (See Chapter 5 for applicable items and Access to Records, 2 CFR § 200.337 for more information)

b. Current records listing all GP for all categories of furnished or provided property (equipment, STE, ST, and materiel).

c. Additions, deletions, and reported losses with supporting documentation.

d. Cost principles are still applicable according to 2 CFR pt. 200.

e. Verify that the property listing contains the required Equipment section, 2 CFR § 200.313, property record data elements and that the recipient maintains source documentation and audit traceability for transactions.

f. Verify completeness and timelines of submitted reports to include property submissions.

g. Evaluate utilization elements to include authorized use, screening for continued use/need, storage and or timely disposal.

h. Verify processes for materiel consumption, receipt, and issue.

i. Verify the recipient retains complete, authorized records for relief of stewardship for any dispositioned property.

j. Verify the award recipient has plans and procedures for award closeout activities, or the performance activities if awards have closed during the review period.

k. Prepare a determination letter for the CO/GO to sign that includes at a minimum:

(1) Findings and conclusions,

(2) A statement addressing the adequacy of the overall system, and

(3) Document resolution of any corrective actions and deficiencies.

9.7.1.5 The IPO or GPA shall update the PMSA’s Summary and Outcome tabs and upload the PMSAs, corrective action plans, and reanalysis reports in the Documents tab by award number in NESS. All required reports associated with PMSA. (See Section 1.3.8.3.j. for more information.)

9.8 Overview of the Closeout Phase

Award closeout is the process by which NASA, or a pass-through entity determines that all applicable administrative actions and all required work of the Federal award have been completed by the award recipient. The closeout process ensures that all applicable final reports are received; award deliverables are documented; amounts due to the award recipient are paid; unexpended funds are returned to NASA; and equipment is properly dispositioned, as necessary. All awards with GP associated follow the final property submissions in NESS to close out awards in the Agency. (See Section 1.3.7.3, Annual and Final Property Submissions, Table 6-1, and GCAM for more information on the award recipients’ and NASA’s responsibilities.) The key closeout activities that award recipients and NASA perform in accordance with Closeout, 2 CFR § 200.344 are:

a. Limitations.

b. Program Planning Design (Pre-Award Phase).

c. Competitive Awards.

d. Non-Competitive Awards.

e. Information Contained in a NASA Award (Award Phase).

f. Terms and Conditions.

g. Pre-Award Risk Assessment.

h. Performance Measurement, in accordance with:

(1) Equipment and Other Capital Expenditures, 2 CFR § 200.439.

(2) Exempt Equipment.

(a) Federally Owned and Exempt Property, 2 CFR § 200.312.

(b) Equipment, 2 CFR § 200.313.

(d) Federally Owned and Exempt Property, Federally Owned and Exempt Property, 2 CFR § 1800.312.

i. Delegation of Property Administration and Plant Clearance.

j. NASA Insignia Guidelines.