NASA Property
Michael (Mike) Showers
Manager, NASA Contract Property
Program
Agenda
•
•
•
•
•
•
Expectations
NFS Update
Space Shuttle Closeout
To Do List
Financial Reporting
Internal NASA Reviews
EXPECTATIONS
Expectations
•
•
•
•
•
•
Outcomes,
Standards of Practice
Performance Standards
VCS
Industry Practices
ILPs
Outcomes
• FAR 52.245-1
“(f) Contractor plans and systems. (1)
Contractors shall establish and implement
property management plans, systems, and
procedures at the contract, program, site or
entity level to enable the following
outcomes:”
Standards of Practice
•
•
•
•
How to……
Procedures
Process Oriented
Old FAR 45.5
Performance Standards
• "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
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 Standards
• Common Industry Practice or Standard
– A documented practice or standard accepted
across an industry through a consensus process
limited to that industry.
Industry Leading Practices and
Standards
Industry
LEADING
Practices and Standards
– Better than accepted industry practice
• More cost effective
• Improved practices
• Higher standards
– Proven
• Claims insufficient
• Publication and repetition
Industry Leading Practice or
Standard
• 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.
Industry leading practices or standards prove
increased performance, or effectiveness, in addition
to decreased or constant cost, through their
acceptance and publication in refereed, professional
journals and through the process of repetition.
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/pn0456.html
– Implements remaining NFS internal changes
– Consolidates internal and external changes
– Expected April/May release and publication
– 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 07-09
(Continued)
• 1852.245-78 Physical Inventory of Capital
Personal Property
– Requires submission of reports to the PA rather
than the IPO
Other Clauses
• 1852.245-71 Installation Accountable
Government Property
– Used for contracts where place of performance is
on a NASA Center or Installation
– Requires use of NASA Internal Guidance for
property management and use of NASA
recordkeeping systems when available
Other Clauses
• 1852.245-72 Liability for Government
Property Furnished for Repair or Other
Services
– Limited to property which will be repaird or
serviced and returned
– Retains accountability and recordkeeping
– Obviates FAR 52.245-1
– Different liability
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
Other Clauses
• 1852.245-79 Records and Disposition Reports
for Government Property with Potential
Historic or Significant Real Value
– Requires additional recordkeeping for property
when added by the CO
– CO consults with Center Historic Preservation
Officer to determine use
Other Clauses
• 1852.245-82 Occupancy Management
Requirements
• 1852.245-83 Real Property Management
Requirements
– Restrict improvements or changes to NASA Real
Property
– Require some levels of real property reporting
NFS Internal 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 Internal 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
SPACE SHUTTLE CLOSEOUT
Space Shuttle Closeout
• Shuttle Placement Announcement
–
–
–
–
Discovery – National Air and Space Museum
Endeavor – California Science Center
Atlantis – Kennedy Space Center
Enterprise – Intrepid Sea Air and Space Museum
• Remaining shuttle property to be dispositioned
after last wheel stop
–
–
–
–
STS 135 scheduled for June 28
12 Day Mission
Final Flight of Atlantis and Shuttle
Approximately 1.2 million line items of property
Space Shuttle Closeout
• Artifact Placement
– Restricted to
• Federal Agencies
• Schools
• Non-profit museums via SASPs
– +29000 Potential Artifacts Screened
• (Individual Items)
– +3000 Allocated, most shipped
– 6 Screening Periods Complete, 7th underway
– Shuttle Tiles
• Schools only
• +7000 originally available
• +4000 requested
TO DO LIST
To-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
• 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
– Material Weakness to Qualified Opinion
• New Auditor This Year
– PWC replaces E&Y
• Will be looking specifically at Contractor Held
Property
– Cause for Qualified Opinion
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
INTERNAL NASA REVIEWS
Internal NASA Reviews
• Compensating Control Reviews
– Internal Reviews of all NASA property programs
• Seven Centers Complete
• Three Remaining
– Performed by HQ Subject Matter Experts
– 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