July 27, 2001
GUIDANCE FOR DELEGATION OF PROPERTY ADMINISTRATION
PURPOSE: To re-issue guidance for delegation of property administration and property management system reviews. This PIC is intended to clarify misinterpretation of PIC 01-10, and supercedes it in its entirety.
BACKGROUND: NASA accomplishes much of its mission through the use of contractors. The Agency often provides its contractors Government-furnished property, or the contractors acquire property using NASA funds. This property is referred to as contractor-held property. While NASA has overall responsibility for oversight of this property, the Agency can either retain property administration or delegate this function to the Defense Contract Management Agency (DCMA), or Office of Naval Research (ONR). NASA's policy is to delegate property administration for off-site contractors and retain property administration for on-site contractors. One of the critical oversight functions is the analysis of the contractor's property management system. It is through this analysis that property administrators determine whether the contractor is complying with the contract terms and conditions regarding property.
The FAR and NASA FAR Supplement (NFS) provide guidance and direction to NASA contracting officers for delegating contract administration services, such as property administration. These requirements are set forth in FAR Subpart 42.2, "Contract Administration Services," and NFS Part 1842, "Contract Administration and Audit Services."
The FAR and NFS also provide guidance and direction to contractors who manage and account for property either provided to them by NASA or acquired using Government funds. These requirements are set forth in FAR Part 45 and NFS Part 1845, "Government Property."
GUIDANCE: The FAR and NFS contain requirements and guidance on contract administration that includes property administration. NASA centers are encouraged to delegate property administration to DCMA or ONR, as appropriate, for all off-site contractors and grantees, since center property offices are not staffed to perform this work. The process begins with the NASA contracting officer issuing the delegation on NASA Form 1430, "Letter of Contract Administration Delegation, General." The NASA Form 1430 should be prepared and forwarded to DCMA/ONR at time of contract award. The NASA Form 1430A, Letter of Contract Administration, Special Instructions, will supplement the NASA Form 1430, to modify previously delegated functions and provide additional or particular information considered necessary to ensure clear understanding of all delegated functions. The NASA Form 1431, Letter of Acceptance of Contract Administration, should accompany the NASA Form 1430 or 1430A. Property administrators can accept or reject the delegation. Acceptance shall be evidenced on NASA Form 1431, Letter of Acceptance of Contract Administration Delegation. Contracting officers shall use the returned NASA Form 1431 as contract file documentation that the delegation has been accepted or rejected by the contract administration office and as a reference for points of contact for each of the functional areas delegated. To ensure proper oversight, the NASA Forms should also be forwarded when delegating property administration to other NASA sites. Contracting officers should review contract files to ensure prompt receipt of NASA Form 1431.
When overseeing a contractor's property management system, DCMA, ONR and NASA personnel must follow the Department of Defense (DOD) guidance in DOD 4161.2-M, "DOD Manual for the Performance of contract Property Administration" (DOD Manual). The purpose of property administration, according to the DOD Manual, is to attain efficient, economic, and uniform management of contractor-held property. The manual identifies the functions that property administrators must perform. A critical property management function is the analysis of the contractor's property management system. The purpose of the analysis is to ensure uniformity and consistency in the administration of contract provisions relating to Government property in the custody of contractors. It is through performing this analysis that property administrators determine whether contractors are complying with contract terms and conditions regarding property.
EFFECTIVE DATE: This PIC is effective as dated and shall remain in effect until canceled or superseded.
CANCELATION: PIC 01-10 is canceled.
HEADQUARTERS CONTACT: Lou Becker, Code HK, (202) 358-4593, email: firstname.lastname@example.org
R. Scott Thompson
Director, Contract Management Division