NASA Property

Michael (Mike) ShowersManager, Contract Property

Program

• Expectations• NFS Update• To Do List• NESS Update• Financial Reporting• Management Controls• Space Shuttle Closeout

AGENDA

EXPECTATIONS

EXPECTATIONS

• Outcomes, • Standards of Practice• Performance Standards• VCS• Industry Practices• ILPs

OUTCOMES

• FAR 52.245-1 Discusses Outcomes–Minimizes Government Direction–Maximize Flexibility in Process–Adopt and Promote the Use of VCS–Promote the use of Industry Leading

Practices and Standards

STANDARDS OF PRACTICE

• How to……• Procedures• Process Oriented• Old FAR 45.5

VCS• Voluntary Consensus Standards– "voluntary consensus standards" are standards

developed or adopted by voluntary consensus standards bodies, both domestic and international.

– A voluntary consensus standards body is defined by the following attributes: (i) Openness. (ii) Balance of interest. (iii) Due process. (vi) An appeals process. (v) Consensus.

NOT VCS

• Non-consensus standards–Industry Standards–Company Standards–De facto Standards

• Government – unique standards• Legally mandated

INDUSTRY LEADING PRACTICES AND STANDARDS

LEADING –Better than accepted industry practice• More cost effective• Improved practices • Higher standards

–Proven• Claims insufficient• Publication and repetition

ILPS

• INDUSTRY LEADING PRACTICE OR STANDARD is a documented, proven, practice or standard that exceeds common industry practice or standard in performance or effectiveness AND in cost control.

ILPS

• Industry leading practices or standards prove increased performance, or effectiveness, in addition to decreased or constant cost through---

PUBLICATION AND REPETITION

INDUSTRY STANDARDS

• Common Industry Practice or Standard–A documented practice or

standard accepted across an industry through a consensus process limited to that industry.

PERFORMANCE STANDARD

• "Performance standard" is a standard as defined above that states requirements in terms of required results with criteria for verifying compliance but without stating the methods for achieving required results.

OMB Circular A-119

BOTTOM LINE

Less How

More How Well!

NFS UPDATE

NFS UPDATE• Clauses and Solicitation Procedures– Final rule published January 12, 2011– Implements 2007 FAR Changes

• Procurement Notice (PN) 04-56 – http://www.hq.nasa.gov/office/procurement/regs/

pn04-56.html– Implements remaining NFS internal changes– Consolidates internal and external changes– Published early June– Obviates PIC 07-09 and PIC 05-07

Solicitation Provision Changes

• 1852.245-80 Government Property Management Information–Changes default condition from As-Is,

Where-Is to FAR 52.245-1 standard–Adds an alternate • Used when Contracting Officers are able to

provide access to existing property for contractor review prior to bid submission• Returns As-Is, Where-Is conditions

Solicitation Provision Changes

• 1852.245-81, List of Available Government Property– Section for property offered under

standard FAR Government Property Clause– Section for property offered under FAR

52.245-2 clause• AS-IS, Where Is

CLAUSE CHANGES FROM PIC 07-09

• 1852.245-70 Contractor Requests for Government Provided Equipment–Limited to equipment acquisition

only–Alternate allows self screening of

approved requests–Ties to financials

• 1852.245-74 Identification and Marking of Government Equipment–Items may be marked using

commercial techniques if they are durable enough to survive the item

• 1852.245-75 Property Management Changes–Requires submission of reports to the

PA rather than the IPO

CLAUSE CHANGES FROM PIC 07-09

CLAUSE CHANGES FROM PIC 07-09

• 1852.245-78 Physical Inventory of Capital Personal Property–Requires submission of reports to

the PA rather than the IPO

OTHER CLAUSES

• 1852.245-73 Financial Reporting of NASA Property in the Custody of Contractors– No change other than citation to FAR 52.245-1

• 1852.245-76 List of GFP– Used with FAR 52.245-1

• 1852.245-77 List of GFP– Used with FAR 52.245-2

NFS GOVERNMENT INSTRUCTIONS• 1845 – Revision published under PN 04-56– Reorganizes and removes guidance to contractor

from 1845 (except 1018 instructions)– Add solicitation requirements– Better define roles of NASA IPO, PA, and CO– Discuss support delegations– Provides guidance on processing of requests for

equipment• 1852 – Recently Revised– January 12, 2010 Federal Register final rule

• Clause revisions– Some adds– Several Revised

• Solicitation provisions added

NFS GOVERNMENT INSTRUCTIONS

• Provided clause prescriptions• 1845.3 limited FAR 45.3 to commercial use of GP• 1845.302 discussed contracts with foreign

entities• 1845.5 Sets NASA requirements for delegations• 1845.501-70 Requires the CO to obtain updated

property management plans (during solicitation phase) when the IPO or PA determines them to be inadequate

NFS Guidance - Clauses• 1852.245-74 Requires identification and marking for

delivered property• 1852.245-75 Requires notification when contractor

wishes to change property standards and practices– Loss reporting– Physical Inventory– Recordkeeping– Transport or delivery– Disposition

• 1852.245-76/77 Lists of GFP under FAR 52.245-1 and 2 respectively

• 1852.245-78 Physical Inventory of Capital Personal Property requires annual inventory verification of items valued over $100K

NFS GOVERNMENT INSTRUCTIONS

• 1845.503-70 Requires delegation of PA whenever property segments are managed under FAR GP clause

• 1845.505-70 Defines general duties of NASA PA• 1845.506-70 Defines general duties of NASA PLCO• 1845.606-70 Requires scrap reporting on inventory

schedules (or electronic equivalent) lacking approved scrap procedure

• 1845.7101 Requires the CO to direct contractor to provide additional information on transfer documents when incomplete

MANAGEMENT CONTROLS

Property Management Control Structure

Property Management System AuditProperty Control System Analysis

Industrial Property Officer Oversight

HQ Compensating Controls Review

Contract Requirements

PROPERTY ADMINISTRATION

• Overseen by center Industrial Property Officer

• Some PA activities and surveys are performed by NASA Personnel

• NASA PA retains partial responsibility for on-site contractors

DELEGATIONS

• DCMA for commercial contractors• ONR for non-profit research and

educational• NF 1430c delegates CO authority and

responsibility for Property Administration• NF 1431d delegates CO authority and

responsibility for Plant Clearance

NF1430c – PROPERTY ADMINISTRATION

• Recognizes delegated agency authorities for most actions

• Requires special actions for NASA– Review and evaluate proposed property procedures

when asked– Provide current system status– Provide current risk determination– Provide PCSA summary within 30 days of completion– Provide immediate notification of increased risk for

loss– Verify all reports

NF1430c – PROPERTY ADMINISTRATION

• Special actions for NASA continued– Property values• Ascertain the source of recorded property values• Determine whether that source has been reviewed by

the Government• Qualify value data element if appropriate

– Identify components of special test equipment when it may be operated separately

– Review for correct categorization of property– Provide Loss reporting

PROBLEM

• DoD’s thresholds for risk are higher than NASA’s–The value of their contracts is higher

by far–NASA’s $10 million threshold does not

trip their risk standards

RESOLUTION!

• Special Delegation Instructions– Optional In NF 1430C– For “major” contractors

• Designated by NASA Finance as having property holdings exceeding $10 million

– Requires• Annual reviews of contractor records, physical

inventory and reports regardless of DoD risk assessment• Written, annual reports to the IPO and DCFO

– Email OK

INTERNAL NASA REVIEWS

• Compensating Control Reviews• Internal Reviews of all NASA

property programs–Eight Centers/Installations Complete–Two Remaining–SSC in two weeks

• Performed by HQ Subject Matter Experts

INTERNAL NASA REVIEWS

• Current Contract Property Concentration On:– Assuring reviews of solicitations for correct

language– Assuring reviews of contractor’s proposed

systems– Assuring proper delegations of authority– Assuring completion of PMSAs

• Future Reviews Concentrate On– Quality of PMSAs– Reporting and Internal Metrics

TO-DO LISTTO-DO LIST

• NASA Procedural Requirements for Property Administration– Internal NASA Guidance for NASA IPOs, PAs, and

COs– Supplements NFS • 8 Chapters covering all aspects of PA• Includes information on performance of property

management system audits• Incorporates risk based scheduling• Addresses specific NASA requirements

To-Do List

To Do List

• Delegation Instruction Update– Last update just before FAR change– Need to incorporate FAR and NFS changes– Back Burner at present but getting hotter

• Vehicle Management and Reporting– Needed to implement new Executive Orders– Support the NASA MVA/DMV requirements – Look for

– Increased requirements for acquisition approval– Increased requirements for reporting and recordkeeping

FINANCIALS

FINANCIAL

• Improvement– Property no longer considered a material

weakness

• New Auditor This Year – PWC replaces E&Y

• Will be looking specifically at Contractor Held Property – Still cited as a cause for concern

FINANCIAL • Property Management Objectives– Bottom Line

Obtain “Clean Opinion”– Leverage property management audits to the

greatest extent possible to limit repetitive processes and reduce cost to the Government and the contractor• Must be able to depend on findings of another audit

activity (Yellow Book)• May require additional oversight of PMSA process

NESSNESS

NESS CHANGES• No changes to report or reporting requirements for

contractors• Additional items for NASA IPOs and NASA IPMS personnel

(PMSA Related)• VASTLY different requirements to obtain user id

– HSPD12 Requirement– Outside of NESS – NASA Wide– Must obtain NASA Identity– Must be provided access to NESS– Must take NASA IT Training

• Takes place THIS YEAR!

SPACE SHUTTLE CLOSEOUT

SPACE SHUTTLE CLOSEOUT• Remaining shuttle property to be dispositioned after last

wheel stop (starting NOW!)• STS 135 Landed last week• Final Flight of Atlantis and Shuttle• Approximately 1.2 million line items of property • Located at contractor and NASA sites across the country• 75% In contractor custody/25% Accountable to NASA• 75% located on NASA Installations/25% Located at

Contractor Facilities• Expected to take over 2 years to disposition all property

SHUTTLE PLACEMENT• Announcement By Administrator

April 12–Discovery – National Air and Space

Museum–Endeavor – California Science Center–Atlantis – Kennedy Space Center–Enterprise – Intrepid Sea Air and

Space Museum

ARTIFACT PLACEMENT• Significant GSA Assistance• Restricted to – Federal Agencies– Schools– Non-profit museums via State Agencies for Surplus

Property• >29000 Potential Artifacts Screened – (Individual Items)

• >3000 Allocated, most shipped• 7 Screening Periods Complete, 8th underway• Shuttle Tiles– Schools only– +7000 originally available– >4000 requested

What’s Next for NASA?• Recognize the incredible accomplishments of those who were

part of Shuttle Program• Recommit NASA to Human Space Flight• Live and work on the International Space Station• Use AMERICAN companies to place people and property in low

earth orbit• Focus on deep space exploration• Travel to the Moon, asteroids, and Mars• Build a deep space crew vehicle and heavy lift rocket• Continue science missions both in the solar system and to earth• Build the future through STEM Education

QUESTIONS?

Contact:Mike Showers,

Manager, NASA Contract Property ProgramMichael.showers-1@nasa.gov or

mtshowers37@msn.comPhone: 202.358.0272