NASA Procedural Requirement, Administration of Property in the Custody of Contractors NPR 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 M – 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 :

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) 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 Clause for most GP NFS Clause for FAR 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

Michael (Mike) Showers Asset Management Assistance, L.L.C. (301)