Returning to Facilities - GSA Leased Locations

Leasing Policy, Project and Process Guidance

  • Rent Credits/Billing Adjustments: We will continue to pass through rent for leased space assigned to occupant agencies when a building is closed due to any COVID-19 issue. Any rent credits we receive from a lessor due to a closure will be passed through to occupant agencies on their rent bill.
  • Released Space Requests: Occupant agencies may request to release space, but standard pricing policy applies. Space must be vacant (no furniture or information technology equipment).
  • Closing Buildings: We consider closing a building on a case-by-case basis. The Lease Contracting Officer (LCO) should first contact the occupant agency to see if it is mission critical to remain open and functioning within the leased premises. If so, the lessor must be notified of the need to keep the facility open. Should the lessor notify the federal government of a state or local government stay-in-place order, the LCO must obtain a copy of the stay-in-place order and determine if it applies to federal government employees and contractors. If it does, and if the occupant agency advises the LCO that its offices must remain open, the LCO must notify the lessor that they need to keep the facility open. If a lessor refuses to reopen its building for a mission critical function, the LCO should consult regional counsel, as the federal government has the right to occupy the premises.
  • Locking Out: A lessor may not lock out a federal government tenant from a leased building. If an occupant agency advises the LCO that its offices must remain open, the LCO must notify the lessor of the need to keep the facility open. If a lessor refuses to reopen its building for a mission-critical function, the LCO should contact regional counsel, as the federal government has the right to occupy the premises.
  • Restricted Access: In GSA leased space, when an occupant agency wishes to restrict access or implement screening procedures, the agency should contact their GSA point of contact (POC) to coordinate with the Facility Security Committee (FSC) and the lessor. The GSA POC will coordinate with the occupant agency, the FSC, and the lessor to determine an appropriate implementation strategy at the lease location.
  • Project Delay Costs and Approvals: The federal government is responsible for project delay costs if the occupant agency does not provide access to space for contractors to complete the tenant improvement buildout. Discuss all delay claims with regional counsel first.
  • Lease modifications: Lease modifications may only be carried out by the LCO through a lease amendment. There can be no contractually binding communication between the lessor and the occupant agency concerning ongoing construction in leased premises. The LCO must communicate with the occupant agency and then the lessor when this becomes an issue.
  • Cleaning and Disinfectant Services Procured by Occupant Agency: Only LCO approval is required, not a delegation. The LCO should notify the lessor that the occupant agency has the authority to procure these services dependent upon dollar threshold. The LCO must respond to the occupant agency in writing that the occupant agency has authority, as long as it follows the directions as issued in previously approved related guidance and uses the approved Cleaning and Disinfection Scope of Work. This notification can be completed by email to both the lessor and the occupant agency simultaneously.

Enhanced Entry Screening Services (EESS) Guidance

  • Implementing EESS in leased locations: Leased locations cannot impose Enhanced Entry Screening. While occupant agencies may require COVID-19 screening for their employees or visitors to their offices, they cannot impose such restrictions on other building occupants (i.e., employees, contractors, and visitors). The FSC or the occupant agency should contact the GSA POC. The GSA POC will coordinate with the occupant agency, the FSC, and the lessor to determine how to put the procedures into place within the confines of the occupant agency’s space.
  • EESS responsibilities in leased locations: Consistent with the Federal Management Regulation and OMB Memorandum M-20-23, each FSC is responsible for deciding enhanced entry screening procedures at the GSA-controlled facility where it is constituted. These screenings could include implementing a set of questions to be asked upon entry, temperature checks or other screening methods. To implement enhanced entry screening procedures at a GSA-controlled facility, the building’s FSC must convene, either in person or virtually. After consulting the GSA facility manager and the FPS representative, it must vote to adopt such procedures. In GSA-controlled leased space, when the FSC wishes to restrict access or implement screening procedures, the occupant agency must contact its GSA POC to coordinate with the FSC and the lessor. The GSA POC will coordinate with the occupant agency, the FSC, and the lessor to determine how to implement the procedures within the confines of the occupant agency's space.
  • Federal Judiciary procedures: In facilities occupied by the federal judiciary, the GSA facility manager, the FPS representative, and the U.S. Marshals Service representative must meet to discuss EESS. If the FSC votes to adopt such procedures, it must review the minimum enhanced entry screening procedures included in the EESS Sample Performance Work Statement to determine if the minimum procedures described in the sample work statement are sufficient or if additional procedures are needed. If the FSC determines that additional procedures are needed, the FSC must provide a list of those procedures to the GSA facility manager within 24 hours of the vote, to include in the final performance work statement.
  • Process to implement EESS: Once the FSC has decided to implement enhanced entry screening procedures, checked that the required funding is in place, and developed an enforcement strategy, the GSA project team, including the Lease Administration Manager “LAM), the Lease Contracting Officer’s Representative (COR) and the LCO will determine an appropriate acquisition strategy if using GSA’s procurement resources to acquire the services.
  • Funding to implement EESS:
    Funding for EESS depends on the occupancy of the facility. In single-occupant, GSA-controlled facilities, the occupant agency is solely responsible for funding the cost and must either provide the Public Buildings Service (PBS) with a reimbursable work authorization (RWA) or, in coordination with the GSA facility manager, procure the services directly. In a multi-occupant, GSA-controlled facility, if the FSC votes to implement enhanced entry screening procedures, the occupant agencies are responsible for providing the funding based on their pro rata share of rentable square footage in the facility. In these cases, if requesting GSA to perform the work, the occupant agencies must provide PBS with a reimbursable work authorization (“RWA”) for their pro rata share of the estimated cost.

Procurement Guidance

  • Signage / Wayfinding Guidance: Lessors are responsible for procuring and placing signage in the common areas of leased locations. The LAM/COR should encourage lessors to post signage on keeping physical distance, wearing face coverings, washing hands, and following other COVID-19-related infection control measures in building common areas, such as the lobby. Since pandemic signage is not outlined in the lease, GSA cannot require the lessor to post signage. Occupant agencies may procure and post signage within their leased space, once coordinated with the lessor. Signage can be printed directly from the Centers for Disease Control and Prevention (CDC) website or procured through the Federal Acquisition Service.
  • Face Masks: Since early April 2020, CDC advised the use of face coverings (masks) while in public places. Each occupant agency is responsible for establishing any requirements or guidance for face mask usage among its employees, contractors, and visitors. Some agencies have already issued such guidance.
  • Procuring cleaning products: Occupant agencies are responsible for funding, procuring, and making available sanitizer products, disinfectant wipes and similar products for use by their employees and visitors to use. Products for disaster relief and pandemic protection are available through GSA Advantage!

Cleaning and Disinfecting Guidance

GSA is issuing unilateral lease amendments (ULAs) for existing leases to incorporate additional daily cleaning and disinfecting requirements for high contact surfaces in common and high traffic areas.

Lessor instructions include the requirement to wipe down daily all solid, high contact surfaces in

  • building common areas (defined as those areas that government’s employees and visitors use or access, and
  • within the leased space, using a disinfectant from the EPA-registered list of products identified as effective against Novel Coronavirus SARS-CoV-2, or other products containing the same active ingredient(s) at the same or greater concentration than those on the list.

Cleaning staff shall use products in accordance with directions provided by the manufacturer. Cleaning staff shall wear disposable gloves (e.g., latex, nitrile, etc.), facemasks, and any additional personal protective equipment (PPE) as recommended by the cleaning and disinfectant product manufacturers. Disinfection application and products should be chosen so as to not damage interior finishes or furnishings.

Examples of solid, high contact surfaces in building common and high traffic areas include, but are not limited to, handrails, door knobs, key card scan pads, light switches, countertops, table tops, water faucets and handles, elevator buttons, sinks, toilets and control handles, restroom stall handles, toilet paper and other paper dispensers, door handles and push plates, water cooler and drinking fountain controls.

It does not include agency-owned equipment such as desks, telephones, computers, keyboards, docking stations, computer power supplies, and computer mouse, personal fans and heaters, desk lighting, etc.

The routine cleaning and disinfecting specified in this paragraph shall not extend beyond lease expiration (unless in holdover status) or September 30, 2021, whichever is earlier.

For all new lease actions, GSA has already mandated incorporating this cleaning and disinfecting standard requirement into our lease documents.

Guidance for Confirmed or Suspected Cases in Leased Locations

  • Notification and Cleaning: Once an occupant agency notifies the GSA Property Manager/LAM of a confirmed or suspected case of COVID-19/Coronavirus, GSA will notify the lessor of the COVID-19 incident and provide the date and time of the incident and areas accessed. It will not include Personally Identifiable Information (PII). GSA must establish if the lessor has a pandemic plan in place that follows CDC guidelines and matches the GSA scope of work. If so, GSA must confirm that the cleaning for agency-occupied and common areas accessed by the individual with the confirmed or suspected case of COVID-19 will be done under General Clause #12, Maintenance of the Property, Right to Inspect. GSA must also confirm whether or not the cleaning will be provided free of charge to the federal government. If not, GSA will negotiate with the lessor to perform the cleaning according to the following directions.
    • For confirmed or suspected coronavirus cases, GSA will fund and provide for detailed cleaning and disinfection of those portion(s) of the facility accessed by the infected individual(s) according to CDC guidance, which may exceed GSA's National Custodial Specification or as otherwise described in the lease agreement.
    • On a reimbursable basis, GSA will also provide for the cleaning and disinfecting of those portion(s) of the facility not accessed by the infected individual(s) according to the recommended CDC guidance.
    • On a reimbursable basis, GSA will provide cleaning and disinfecting services requested by occupant agencies that include, but are not limited to, the following: additional cleaning and disinfecting services that exceed the recommended CDC guidance, increased frequency of cleaning and disinfection services, and the use of special cleaning supplies and materials.
  • Lease Administration Manager Role: The LAM will work with a warranted contracting officer to order detailed or supplemental routine cleaning services at or below the SAT. The LAM will discuss with the lessor whether the lessor can provide the cleaning services or whether GSA may be required to procure its own cleaning contractor. The LAM will also notify the LCO of any action.
  • Lease Contracting Officer Role: For detailed or routine supplemental cleaning service requests in excess of the SAT, the LCO is responsible for procuring the extra services from the lessor through a lease amendment.
  • Occupant Agency Role: For supplemental services not related to a confirmed or suspected coronavirus case, the occupant agency must inform GSA if it plans to fund additional services with an RWA or order and pay the lessor or cleaning contractor directly. Please see the Customer Direct Contracting section for additional details.
  • Funding/payment for Additional Cleaning Services: Additional cleaning services in response to both confirmed and suspected COVID-19 cases in leased facilities are funded as follows:
    • In confirmed or suspected case situations, GSA will fund and provide for detailed cleaning and disinfection for portions of the leased premises the individual accessed. Such cleaning will follow the recommended CDC guidance, which may exceed GSA's National Custodial Specification or as otherwise described in a lease agreement.
    • The requesting agency must fund an occupant agency request for cleaning and disinfection beyond the areas accessed or that exceed the CDC guidance as a reimbursable service according to the current pricing policy.
    • These procedures do not apply to leases that have been delegated to occupant agencies. For such leases, the occupant agency remains responsible for all cleaning and disinfecting services according to the terms and conditions of the delegation agreement and according to the lease.

Supplemental Routine Cleaning Services

  • Occupant Agency Direct Contracting: Occupant agencies must contact their GSA property manager and Lease Administration Manager (LAM) to discuss supplemental routine cleaning services. The GSA LAM will coordinate with the Lease Contracting Officer ( LCO) and then discuss with the lessor whether the lessor will provide the cleaning services or whether the occupant agency will procure its own cleaning contractor.
  • Costs Below the Micro-Purchase Limit: If the services needed are at or below the micro-purchase limit, the occupant agency may procure the services directly from the lessor and pay for those services according to the existing micro-purchase delegation of authority.
  • Costs Above the Micro-Purchase Limit, But Under Simplified Acquisition Threshold (SAT) of $750,000: If the services needed exceed the micro-purchase threshold, but fall below the SAT, the occupant agency must request authority in writing from the GSA LCO. The letter must cite that it has a qualified Contracting Officer (CO) available to carry out the request for the services and that it will use the GSA-provided scope of work (SOW)* developed according to CDC guidelines. Occupant agencies may use a more stringent Statement of Work (SOW) for cleaning and disinfecting based upon mission need, as long as the more stringent SOW is equivalent to or or exceeds the GSA SOW and adheres to CDC guidelines.
  • Costs Above the Micro-Purchase Limit and SAT: The GSA LCO will procure cleaning services directly from the lessor, if the occupant agency requests it.
  • GSA Cleaning Standards: GSA has notified lessors about cleaning and disinfecting according to current recommended CDC guidelines. GSA will direct lessors to clean according to the current recommended CDC standards. These standards include the routine cleaning and disinfecting of high-touch surfaces in common and high-traffic areas. These high-touch surfaces include, but are not limited to: handrails, door knobs, light switches, countertops, table tops, water faucets and handles, elevator buttons, sinks, toilets and control handles, restroom stall handles, toilet paper and other paper dispensers, door handles and push plates, and drinking fountain controls in common and high-traffic areas. GSA will work with lessors to amend all current leases to include this language.
  • Agency-Owned Personal Property: CDC recommends disinfecting agency-owned personal property such as desks, workstations, computer accessories, and phones. Agencies are responsible for procuring and providing services and/or products to clean and disinfect these items as desired. This service is also available from GSA on a reimbursable basis, upon request. You can find GSA resources to help you procure disinfecting supplies at www.gsa.gov/coronavirus.

HVAC Information

GSA is notifying lessors for all active GSA leases that they are expected, as the landlord, to follow current industry practices by considering the application of the latest Centers for Disease Control and Prevention (CDC) guidance concerning building ventilation and water systems.

These building ventilation and water systems guidelines are located in the Interim Guidance for Businesses and Employers Responding to Coronavirus Disease 2019 (COVID-19), May 2020, under sections “Consider improving the engineering controls using the building ventilation system” and “Ensure the safety of your building water system and devices after a prolonged shutdown.”

In accordance with current CDC guidance, GSA recommends lessors consider modifying the engineering controls using the building ventilation system, which may include some or all of the following activities:

  • Increase ventilation rates.
  • Ensure ventilation systems operate properly and provide acceptable indoor air quality for the current occupancy level for each space
  • Increase outdoor air ventilation, after taking into account the outdoor air quality of the surrounding area.
  • Disable demand-controlled ventilation (DCV).
  • Further open minimum outdoor air dampers (as high as 100%) to reduce or eliminate recirculation. In mild weather, this step should not affect thermal comfort or humidity. However, this may be difficult to do in cold or hot weather.
  • Improve central air filtration to the MERV-13 or the highest compatible filter with the filter rack, and seal edges of the filter to limit bypass.
  • Check filters to ensure they are within service life and appropriately installed.
  • Extend operating hours of systems to increase air exchanges in the building space.

Additional Cleaning Guidance for Leased Space

Last Reviewed: 2020-09-14