CROSS AGENCY SUPPORT (CAS) FUNDING

1. CROSS AGENCY SUPPORT (CAS) FUNDING GSFC August 2010 Training Forum Jim Becker

2. Funding “Severable” Efforts with CAS Funds • A severable service is a recurring service or one that is measured in terms of hours or level of effort rather than work objectives • Must be funded with appropriations current at the time the effort is performed [i.e., 2010 guard services must be funded with 2010 funds; 2011 guard services must be funded with 2011 funds] • CAN be incrementally funded [but see bullet #2 above] • For NASA, contracts CANNOT cross fiscal years, except when using “multiyear” contracting authority

3. Funding “Non severable” Efforts with CAS Funds • A non severable service is one that requires the contractor to complete and deliver a specified end product • Must be funded with appropriations current at the time the “need” arises [i.e., award] • Contracts can cross fiscal years [but keep in mind bullet #2 above]

4. Example #1 NASA issues a new task order on September 1, 2010 for a training class that starts on September 15, 2010 and ends on October 15, 2010. Training is generally considered “non severable”. What year CAS appropriations should be used to fund this training? Example #1A: Same award date, what CAS appropriations do you use if the training starts on October 1, 2010 [the next fiscal year]?

5. Answer #1 Since Training is a non severable activity, and the “need” arose when the task order was issued on September 1, 2010, 2010 CAS funds should be used to fully fund the effort. This holds true even in Example 1A, where the training doesn’t begin until October 1, 2010.

6. Example #2 Your Technical Officer calls you and says he wants you to issue a new task for a research effort with a total estimated cost of $500K. Research efforts are generally non-severable. He wants to make award in August 2010. The research will take 6 months. He needs to incrementally fund the effort. He tells you he has $100K in 2010 CAS funds now, and that he’ll fund the remaining effort with 2011 CAS funds when he gets the money next fiscal year. Do you issue the task order?

7. Answer #2 No you don’t issue the task order, at least not the way the Technical Officer wants it structured. Since the research effort is non severable, and the “need” arises when award is made in August 2010, the effort must be fully funded with 2010 CAS funds. Funding any of the effort with 2011 CAS funds is not permitted.

8. Example #3 Your Technical Officer calls and says she wants to issue a task for one year’s worth of window washing services for building 8, starting March 1, 2011 and ending February 29, 2012. [It is a leap year, I checked] Window washing services are severable. She wants to fully fund the entire year of services with 2011 CAS funds. Do you issue the task order?

9. Answer #3 No. Since window washing is a severable activity, we must use the appropriation current at the time the services are performed. Also recall that NASA contracts for severable activities cannot cross fiscal years. Therefore, we would need to issue two separate task orders to cover the planned period of performance: one task order funded with 2010 CAS funds with a POP from March 1, 2010 through September 30, 2010; and another task order funded with 2011 CAS funds, when available, with a POP from October 1, 2010 through February 29, 2011.

10. Questions/References • Jim Becker, x1296; Michelle Rook, x8400; MaryAnn Bishop, x5740 • References: • NASA HQs PIC 10-07 • OCFO website: http://www.nasa.gov/offices/ocfo/policies/gea.html