(February 17, 1993)
PURPOSE: To provide additional information concerning the roles and responsibilities of contracting personnel in managing the recently implemented NASA/DOD contract administration billing system.
BACKGROUND: Part 18-42 of the NASA FAR Supplement (NFS) details the current NASA policy for assigning and managing performance of contract administration functions to DOD and other Government agencies. Under the previous billing system, bills for delegated services were submitted by the various DOD offices to NASA Headquarters, reviewed by Code B, and paid for from a contract administration account established annually by taxing the relevant program offices. The bills provided only summary data which was not broken out functionally or by individual contracts. The centers were not involved in reviewing the bills prior to payment. This led to documented cases of mischarging and an overall climate of poor communication between NASA Contracting (Jfficers and DOD Administrative Contracting Officers (ACOs).
A new billing system, developed in cooperation with the Defense Contract Management Command (DCMC, has been accumulating incurred cost information over the past year by rolling up charges for delegated services by contract number and identifying the hours incurred by the cognizant DCMC office. These hours also include delegated services performed for subcontracts and purchase orders where DCMC has issued subordinate delegations. The hours are categorized as either contract administration or quality and booked under seven functional areas. Monthly reports generated by the DCMC billing system will now allow the centers to review specifically where the hours lare being incurred on their contracts. In short, centers are now able to directly monitor and manage contract administration services received from DCMC. The DCMC system is an important element in our overall delegated serviccs management policy and the billing data is the window into seeing specifically the direct cost to NASA programs for delegated services. Now with the detail now available, the contracting officer is better equipped to make cost effective delegation decisions which best serve the specific program.
GUIDANCE: NASA policy regarding delegation of contract administration services has not changed with the advent of this new billing system. NASA Contracting Officers are responsible for proper and effective management of all phases of their contracts, regardless of whether certain functions have been assigned to DOD ACOs.
With the advent of the new billing system, NASA Contracting Officers are expected to directly monitor the performance of delegated functions. This includes maintaining a current knowledge of issues associated with contractor performance and the ACO's oversight, and assessing the level of effort incurred by DOD personnel in performance of the delegated functions. Direct and frequent contact with the contract administration office is essential and will foster a team approach to contract management.
In situations where billing report incurred hours do not track with what was expected based on delegations, contact the responsible DCMC offices to discuss and resolve the discrepancies. The reconciled billing data now available will allow for a quick and reasonable adjustment. Procurement offices should perform their analysis of monthly DCMC billing reports in accordance with recent correspondence (NASA HQ letter from Code HK (OHK 930102 dated 01/08/93) to the Procurement Officers and NASA HQ letter from Code B (dated 02/03/93) to the Center Comptrollers) which provided specific review actions to be completed. Specific procedures for reviewing the data will be developed by each center and tailored to the level of DCMC delegated services in use. In order to use the reporting system data as an effective management and forecasting tool, procurement office review should be coordinated with reviews conducted by the quality office. Contracting personnel are encouraged to contact the Headquarters point of contact for any assistance or clarification necessary as billing system management is implemented.
EFFECTIVE DATE. This PIC is effective as dated and shall remain in effect, un1ess extended, superseded, or cancelled.
HEADQUARTERS CONTACT. Ken Stepka, Code HK, (202) 358-0492.
Acting Associate Administrator