nasa procedural requirement, administration of property in the custody of contractors npr 4500.1...
TRANSCRIPT
NASA Procedural Requirement,
Administration of Property in the Custody of ContractorsNPR 4500.1
Michael (Mike) Showers
1
What is it?
• NPR 4500 is NASA’s Contract Property Administration Manual– Developed over the last 7+ years– Based on a group that met in Dayton to update and re-write
the old DoD 4161.2M– Incorporates much of the information on how to perform
Property Management System Audits– Incorporates the 2007 and subsequent FAR changes– Provides language specific to NASA on transfers, accountability,
etc.
• 83 pages
• Found at the NODIS Website: http://nodis3.gsfc.nasa.gov/displayDir.cfm?t=NPR&c=4500&s=1
Composition
• Preface and 8 Chapters• Generally follows a contract’s life cycle from
pre-award through closeout• Describes procedures related to contract property
administration– NPD (NASA Policy Directive) 4500.1 provides NASA Policy on
Contract Property Administration
• Related to NASA property administration activities
Preface
• Purpose• Applicability• Authorities• Applicable Documents and Forms
CHAPTER 1. Administration of NASA Property in the Custody of Contractors
• Objectives of Property Administration• Scope• Authorities and Responsibilities
– NASA Center Directors– Contracting Officers– Industrial Property Officers– Property Administrators– Plant Clearance Officers
• Deviations
IPO Responsibilities
• Serve as center expert on contract property • Maintain training• Participate in acquisition planning• Evaluate the contractor’s proposed property plan• Review CO plans for retention of PA• Oversee PA activities both retained and delegated• Oversee annual reporting process• Assure center data is entered into NESS
CHAPTER 2. Pre-Award Processes• Solicitation Preparation
– Involves the IPO in solicitation/contract creation– Assure insertion of solicitation provisions– Get the right clauses in– Coordinate any lists of property to be “offered” as part of the
solicitation
• Evaluation of Contractor’s Proposed Property Plans (PPP)– IPO check for applicability of proposed plan to contract
circumstances– IPO works with PA to determine if contractor’s system has been
reviewed and, if so, status– IPO advises the CO of needed changed to plan and contractor
performance– CO requires the contractor to address any deficiencies between
the proposed plan and contract requirements
Contractor PPP Reviews
• IPO Reviews for:– Completeness – Does the plan address all applicable outcomes
and sub-outcomes that are likely to be performed by the contractor in support of the contract?
– Use of VCS – Should be acceptable except in specific circumstances where a NASA requirement necessitates higher or different performance
• May be procedural• Performance based are preferred
– Use of ILPS – Must meet definition of ILPS in the document – proven and published (scientific method), must exceed the norm or standard in performance and cost control
– Use of CCP – Defined in document as a documented, consensus developed practice acceptable or limited to a single industry
CHAPTER 3. Delegation and Oversight of Property Administration Activities
• Delegation of Offsite Property Administration Activities– Normally delegated
• DCMA for for-profit entities• ONR for non-profit and educational entities
– IPO remains responsible for oversight and assuring completion of PA activities
• Support Delegations– NASA PAs may seek support from other NASA
activities or from DCMA as appropriate – Support delegation requirements must be reviewed
and approved by HQ
CHAPTER 3. Delegation and Oversight of Property Administration Activities
• Retention of Onsite Property Administration Activities– Normally, NASA onsite contractors must follow NPR
guidance as opposed to FAR for equipment management– Material and property not qualifying for control under NPR
equipment guidance must be managed according to FAR– NASA IPOs are responsible for reviewing any property
managed under FAR• Retention of Property Administration by the
Contracting Officer (CO)– CO may retain PA, but must
• Obtain approval of procurement officer• Perform all PA activities including PMSA• Must report findings and activities to the IPO
CHAPTER 4. Performance of NASA-Retained Property Administration Activities
• Property Transfers– With award
• NFS 1852.245-76 Clause for most GP• NFS 1852.245-77 Clause for FAR 52.245-2 property
– Post award• Modification of the -76 clause
– Documentation requirements
• Transfers Between Contracts• Relationship with NASA Equipment Manager
– Less than capitalization threshold items are retired to the contract– Greater than capitalization threshold transfers are retired but reported
to finance
• Relationship with Supply and Equipment Management Officer
• Transfers TO NASA
CHAPTER 5. Property Management System Audit
• Purposes of Audits• Risk Assessment• Establishing the Annual Audit Schedule• Pre-Audit Communications With the Contractor• Contractor Self-Assessments
– PA may participate, but CSA cannot be used as a substitute for PMSA
• Testing Contractor Performance– Review all applicable segments or outcomes– GAGAS
• Documentation of Audits• Loss of Government Property
CHAPTER 6. Contract Property Management Reporting
• Support for Financial Reporting– Verification of reports– Timeliness of submission
• Property Administration Reporting/Metrics– Overall performance in the contract life cycle
• Percent of applicable solicitations reviewed• Percentage of proposed plans reviewed• Percentage of high risk contractors audited• Percentage of contractors audited
• Annual Contractor Property Reporting Requirements• Use of NESS
CHAPTER 7. Special Situations
• Progress Payments Contracts• Small Business Innovative Research Property• Storage of Property Under Contracts• Property Administration for Major Programs• Foreign Contracts• Contractors Performing Within NASA Facilities• Other Instruments
– Space Act Agreements– Cooperative Research and Development Agreements
CHAPTER 8. Contractor Inventory Disposition
• Property Disposition
• Delegation of Offsite Plant Clearance Activities
• Retention of Onsite Plant Clearance Activities
• Retention of Offsite Plant Clearance by the CO
• Coordination of Property Administration and Plant Clearance
• Disposition of NASA Installation Property Used by Contractors
• Disposition of Property Through Delegated Plant Clearance
• Reports
