NASA NPD 4500.1,
NPR 4500.1 and Their Relationship
to Standards
PRESENTATION TO
NES 2014 NASA/CONTRACTOR SIG MEETING
MIKE SHOWERS, ASSET MANAGEMENT ASSISTANCE, L.L.C.
FAR 52.245-1,
Government Property

(b) Property management.

(1) The Contractor shall have a system of internal controls to
manage (control, use, preserve, protect, repair, and maintain)
Government property in its possession. The system shall be
adequate to satisfy the requirements of this clause. In doing so,
the Contractor shall initiate and maintain the processes, systems,
procedures, records, and methodologies necessary for effective
and efficient control of Government property. The Contractor
shall disclose any significant changes to its property
management system to the Property Administrator prior to
implementation of the changes. The Contractor may employ
customary commercial practices, voluntary consensus standards,
or industry-leading practices and standards that provide effective
and efficient Government property management that are
necessary and appropriate for the performance of this contract
(except where inconsistent with law or regulation).
Issues




No definition of “Industry Leading Practice or
Standard”
No definition of “Customary Commercial
Practice”
No clear internal NASA guidance related to
recognition, acceptance, or implantation
Confusion between recordkeeping systems
and overall property systems, plans, standards,
etc.
Standards, Practices, Plans
and Systems – NPD/NPR 4500.1
Definitions
Customary Commercial Practice. A documented practice or
standard accepted across an industry developed through a
consensus process limited to that industry.
Industry Leading Practice and Standard. A documented, proven
practice or standard that exceeds common industry practice or
standard in performance or effectiveness and in cost control.
Industry leading practices and standards prove increased
performance or effectiveness, in addition to decreased or
constant cost through their acceptance and publication in
refereed, professional journals.
Voluntary Consensus Standards. Standards developed or adopted
by voluntary consensus standards bodies, both domestic and
international. (See OMB Circular A-119).
Voluntary Consensus Standards

PL 104-113, National Technology Transfer
and Advancement Act of 1995

OMB Circular A-119


Implements Act

Requires use by Federal Agencies in lieu of Government
unique standards

Defines the term
Purpose

Cost reduction

Promote Government use of private sector
NASA POLICY DIRECTIVE
(NPD) 4500.1 Highlights

NASA policy regarding the “Administration of Property in the
Custody of Contractors”

Issued September 13, 2013

Instruction to NASA Civil Servants

Available NASA NODIS website:
http://nodis3.gsfc.nasa.gov/displayDir.cfm?t=NPD&c=4500&s=1


Requires

CO approval for the PROVISION of Government property to
contractors

Regular review of contractor performance of property management
Prohibits NASA personnel from reducing or removing the
requirement for contractors to maintain systems and records for
offsite property
NASA POLICY DIRECTIVE
(NPD) 4500.1 Highlights


Establishes Recordkeeping Requirements

NASA maintains fiduciary (financial) records

Contractor maintains stewardship (custodial or property) records for
offsite property and some on-site property

NASA Procedural Requirements and Policy Directives are used for
the management and recordkeeping of onsite property

NPR 4200 requires equipment valued greater than $5000 or which is
defined by the center and NPR as sensitive be recorded in the NASA
PP&E (NPROP)

NPR 4100 requires that NASA Centers establish material control and
accountability systems

Stores Stocks – require central control

Program Stocks – may be decentralized
Property that does not qualify for RECORDKEEPING in NASA
systems must be recorded in Contractor systems in accordance
with FAR 52.245-1
Contractor Held /Used
Recordkeeping Requirements
Record
Yes
No
Financial
?
Yes
NPR 9250
NF-1018
CHATS
No
Yes
No
FAR
52.245-1
Store
Stock?
Equipment
?
On-site?
No
No
Yes
SEMO
Authorized
NASA System
Qualify
for
internal
control?
Yes
PP&E/
NPROP
Yes
NASA
Recorded
Program
Stock?
No
Standards, Practices, Plans
and Systems – NPD 4500.1

NASA requires offsite recordkeeping and management to be
performed in contractor’s systems

NASA permits the use of VCS, ILPS, and CCP

Use is conditional


Must be offsite

Government provided property

Must be adequate for contract requirements
Restricts imposition of additional requirements unless absolutely
necessary for safety or security reasons
Standards, Practices, Plans
and Systems – NPD 4500.1
1. Policy
…”c. When NASA property is provided for use outside of a NASA
Center or Installation, it is considered Government Provided
Property (GPP), and NASA will rely on contractors to be responsible
for the stewardship of that property. This includes property acquired
by the contractor when that property is titled to the Government
under the Government Property clause or under contract financing
provisions.”
…”f. To avoid unnecessary costs associated with duplication of
effort, contractors performing outside of NASA Centers and
Installations are required by contract to record GP in existing
corporate property systems and to manage property using
corporate plans, procedures, practices, and standards. NASA
projects, programs, and mission support activities shall not attempt
to reduce or remove this requirement.”
Standards, Practices, Plans and
Systems – NPD 4500.1
h. NASA will allow contractors, when performing within their own
facilities, to follow industry leading practices and standards
(ILP&S), voluntary consensus standards (VCS), or customary
commercial practices (CCP) for the stewardship and
management of GP to the extent that ILP&S, VCS, and CCP
exist and are adequate for the management of property under
the contract's circumstances. NASA officials should not impose
additional GP management, recordkeeping, or reporting
requirements on contractors when those contractors perform
within their own facilities, and the requirements would create a
NASA-unique requirement and result in increased administrative
costs to the Agency through duplication of contractor records,
systems, processes, or work effort.
NASA PROCEDURAL REQUIREMENT
(NPR) 4500.1

NASA’s Contract Property Administration Manual

Found at the NODIS Website:
http://nodis3.gsfc.nasa.gov/displayDir.cfm?t=NPR&c=4500&s=1

Preface and 8 Chapters

Generally follows a contract’s life cycle from preaward through
closeout

Describes procedures related to contract property
administration

Describes Procedures for NASA Personnel and PA Support
Contractors
NPR 4500.1 Highlights

Preface – Purpose, Applicability, Legal and
Regulatory Authorities, Applicable Documents and
Forms

Chapter 1 - Objectives, Scope, Authorities and
Responsibilities, Deviations

Chapter 2 - Pre-award processes, Solicitation
Review, Evaluation of proposed property
management plans

CHAPTER 3 - Delegation and Oversight of Property
Administration Activities

CHAPTER 4 - Performance of NASA-Retained
Property Administration Activities
NPR 4500.1 Highlights

CHAPTER 5 - Property Management System Audit

CHAPTER 6 - Contract Property Management
Reporting

CHAPTER 7 - Special Situations

CHAPTER 8. Contractor Inventory Disposition

Appendix A. Definitions
Solicitation Phase - NPR 4500.1

Section 2.1 Requires the IPO to recommend the
inclusion of the Solicitation Provision NFS1852.245-80,
Government Property Management Information

Provision requires submission of:

Property management plan

Results of last PMSA

Intention to accept GFP or directly charge property not
part of the deliverable

Use of GP from other contracts on the contract
Proposal Phase - NPR 4500.1

Section 2.2.1 Requires the IPO to Review the
contractor’s proposed property plan based
on:
 Completeness
– does the plan address all
relevant “outcomes”
 Acceptability
– based on risk to safety,
performance, and cost

IPO advises the CO of changes to plan
needed to make it adequate
Proposal Phase - NPR 4500.1

Section 2.2.2.1 Discusses the use of VCS
 IPO
work with program to determine when NASA
specific processes or standards are required to
meet safety or other performance criteria
 Discusses
the difference between procedural
and performance standards
 Procedural
standards are acceptable when they meet
the requirements of the contract
 Performance
standards are designed to address
OUTCOMES. They are preferred
OMB Circular A-119
Standards Definitions
 Different
types of standards
 Performance
 Seeks
 Does
standard –
results
not pre or proscribe methods
 Contains
a criteria for measurement or
verification
 Prescriptive
standard –
 Specifications
 Methods
Proposal Phase - NPR 4500.1

Section 2.2.2.2 Discusses the use of ILPS

Requires that the practice or standard
exceeds CCP or VCS

Requires documentation showing how it
exceeds
Proposal Phase - NPR 4500.1

Section 2.2.2.3 Discusses the use of CCPs
 Must
be acceptable under contract
circumstances

Section 2.2.2.4 Discusses the use of existing
process, standards, systems
 Many
contractors were already performing
adequately
 Must be acceptable under contract
circumstances
 Use of VCS, ILPS, CCPs should be encouraged
PMSA NPR 4500.1
5.1.1.1 Through the PMSA, the PA evaluates the
contractor’s management (control, use, preservation,
protection, repair, and maintenance) of GP in its
possession. The contractor’s performance and the PA’s
evaluation criteria shall be consistent with the
contractual requirements, as well as with VCSs, ILPSs,
and CCPs for property management that have been
determined to be adequate for the performance of the
applicable contracts. Determination of adequacy of
VCS, ILPSs, and CCPs may occur either as part of the
award process or in response to a contractor’s
reported changes.
PMSA NPR 4500.1

Section 5.1.4.2 Recommends that the PA request the
contractor’s VCS, ILPS, CCPs, and processes as part
of the PMSA pre-work

PMSAs should consider both the requirements of the
contract AND any proposed VCS, ILPS, CCPs, or
existing procedures in their evaluation
RELATIONSHIP OF ASTM
STANDARDS TO FAR
OUTCOMES
OVERALL PROPERTY
MANAGEMENT

E2135-10ae1 Standard Terminology for Property and
Asset Management

E2279-09 Standard Practice for Establishing the
Guiding Principles of Property Management

E2452-12 Standard Practice for Equipment
Management Process Maturity (EMPM) Model

E2675-09 Standard Practice for Property Management
System Outcomes

E2936-13 Standard Guide for Contractor Self
Assessment for U.S. Government Property
Management Systems
ACCOUNTING

E2453-13 Standard Practice for Determining
the Life-Cycle Cost of Ownership of Personal
Property

E2378-13 Standard Practice for the
Recognition of Impaired or Retired Personal
Property
RISK

E2495-13 Standard Practice for Prioritizing
Asset Resources in Acquisition, Utilization, and
Disposition

E2608-08 Standard Practice for Equipment
Control Matrix (ECM)

E2811-11 Standard Practice for Management
of Low Risk Property (LRP)
RECEIVING, IDENTIFICATION &
MARKING

E2605-13 Standard Practice for Receiving
Assets

E2631-09 Standard Practice for Physical
Placement of an Entity-Controlled
Supplemental Identification Label

E2672-09 Standard Practice for Identification
and Categorization of Tooling

E2606-13 Standard Practice for Receipt
Notification as a Result of Tangible Asset
Movement
RECORDS

E2499-11 Standard Practice for Classification
of Asset Physical Location Information

E2604-09 Standard Practice for Data
Characteristics of Equipment Records

E2812-11 Standard Practice for Uniform Data
Management in Asset Management Records
Systems
PHYSICAL INVENTORY

E2132-11 Standard Practice for Inventory
Verification: Electronic and Physical Inventory
of Assets
REPORTS AND RELIEFS OF
STEWARDSHIP RESPONSIBILITY

E2131-09 Standard Practice For Addressing
and Reporting Loss, Damage, or Destruction
of Tangible Property

E2674-09 Standard Practice for Assessment of
Impact of Mobile Data Storage Device
(MDSD) Loss
UTILIZATION
(MOVEMENT AND STORAGE)

E2671-10 Standard Practice for Defining
Movements, Shipments, and Transfers of
Tangible Property

E2715-09 Standard Practice for Moveable
Property Storage

E2676-09 Standard Practice for Tangible
Property Mobility Index (MI)

E2497-11 Standard Practice for Calculation of
Asset Movement Velocity (AMV)
CLOSEOUT AND DISPOSAL

E2306-13 Standard Practice for Disposal of
Personal Property

E2858-12 Standard Practice for Sales of
Personal Property

E2607-08(2013) Standard Practice for
Cannibalization/Reclamation of Serviceable
Equipment Components to Support Demand
Requirements
UNADDRESSED OUTCOMES

Utilization – actual use/assuring that property is
used only for the purpose (contract) for which
it was provided or authorized

Subcontractor control – work item scheduled
for development of a standard this year

Performance standards
with metrics
QUESTIONS?
Mike Showers
Asset Management Assistance, L.L.C.
PO Box 552
Poolesville, MD 20837
mike@assetmanagementassistance.com
301.355.0849