Training & FAQs
Welcome to the RWA Training and Frequently Asked Questions Page. The materials included on this page are aimed for all individuals that handle, process, or authorize RWAs with PBS on behalf of their agency. All of these materials are considered "self-service" in that they can be reviewed at any time at your own pace. However, should a customer request onsite training, PBS can customize training to address key customer issues. Please contact us at AskRWA@gsa.gov to discuss your needs.
This Introduction to Reimbursable Services training is available to both GSA employees and external customers in an effort to impart the same basic level of knowledge, understanding, and common language surrounding the Reimbursable Services Program. It provides information on RWA basics, outlines the RWA management process from receipt of RWA to closeout, and issues guidance on following Federal Fiscal Law and GSA Policy.
Level I Training - Introduction to Reimbursable Services [PDF - 4 MB] (updated 4/11/2017)
In August 2017 we held an overview session on RWA policies, procedures, and program updates- titled RWA Protocols for 2017- as part of GSA's Client Enrichment Series (CES). You can find a closed captioned video of the presentation at this link. Also we encourage you to visit the CES website where you can find presentation slide decks, Q&A Documents, and other resources including announcements on other CES presentations!
Looking foRWArd to more Client Enrichment Series (CES) Presentations? How about some RWA March Madness?
- eRETA eNCORE - March 1st, 1-3pm ET: We invite you to learn about the Digital RWA Movement and how to use eRETA to enter, digitally sign, and submit RWAs electronically to GSA! Click here to register!
- RWA Program Updates - March 15th, 1-3pm ET: We invite you to an overview session on RWA Program Updates, including updates to our newly published RWA National Policy Document, along with some process and systems updates. Registration link forthcoming!
Frequently Asked Questions (FAQs)
Below you will find FAQs pertaining to RWAs. In order to best navigate the site, please click on the tab which you believe your question might fall under and search the page for a particular question or topic. If you have any further questions or comments please feel free to contact us at AskRWA@gsa.gov.
General Questions on Standard Customer Letters
Four of the customer letters are required for nonrecurring RWAs for Federal Customers (A, B, F, and N Type RWAs), with the exception of F-types which do not require a completion letter. The Follow-Up Letter and Cancellation Letter are both optional for all RWA Types.
Yes, the signed RWA must be scanned and uploaded to be sent electronically from system with the Acceptance Letter.
These letters are official RWA correspondence generated by PBS’s official RWA system, RETA. They are not signed by PBS, but are intended to communicate with the customer at important trigger points throughout the project.
PBS requires customer letters be sent to all contacts (PBS and Customer) listed on the RWA. Additionally, PBS may add anyone else identified as being involved with the project.
No. There is not a standard reason why RWAs are rejected. PBS should be reaching out to the customer to explain why the RWA is not being accepted and assist them with updating the RWA for consideration of acceptance if possible. Starting in mid-FY2016 and beyond, the deployment of eRETA 8.0 functionality will allow customers to initiate work requests or amendments directly in RETA/eRETA. PBS can “reject” such requests online and automated communications will be sent back to the customer informing them of the rejection.
Yes. The Receipt Letter and Acceptance Letters are sent specifically for the amendment that changes the authorized amount and/or the Description of Requirements. Administrative amendments would not require a new Receipt and/or Acceptance Letter as they can be made without a newly signed RWA 2957 Form. The Completion Letter and Closeout Letter are sent for the overall RWA.
The requirement is for the letter to be uploaded to RETA if it is sent from outside the system itself, though the preference remains to utilize RETA to create and send the letters whenever possible.
Yes. Receipt is not acceptance; it is simply an acknowledgement that PBS has received the customer’s request. It does not commit PBS to anything other than reviewing the RWA.
Any POCs listed on the RWA Form 2957 (3 customer POC fields and 2 GSA POC fields). Also, anyone within GSA identified at the time as being involved with the project because additional email addresses may be added.
Yes. The Receipt Letter is also known as The Acknowledgement of Receipt Letter.
Currently, PBS does not specify a timeframe, although timely communication is encouraged and further reinforced through evolving metrics and measures.
Yes. With eRETA 8.0 a work request number will be issued once the customer agency submits a work request electronically. That work request number will eventually become the RWA number as well. The exception is for A- or B-type RWAs where that number will differ from the original eRETA generated work request number as A- and B-type RWA numbers are ultimately the ASID number generated in IRIS for split-funded projects.
PBS does not send the RWA number with the Receipt Letter to avoid confusion for when the customer should obligate funding. The RWA number at acceptance solidifies that PBS has accepted the RWA.
Yes, however it is not necessary to send a Receipt Letter for administrative amendments. Only when a new RWA 2957 Form needs to be signed (change in authorized amount or change in scope) should a new Receipt Letter be generated and sent to the customer.
The Receipt Letter is simply an acknowledgement that PBS has received the customer’s request. The Acceptance Letter communicates PBS’s acceptance of the RWA, signaling the project initiation of the RWA, and it is when customer agencies should obligate the funding associated with the RWA. It is important to remember customer agencies should only obligate once the agency receives the Acceptance Letter from PBS.
Must be within 5 business days of when PBS signs and accepts the RWA.
No, PBS must upload and send the signed version with the Acceptance Letter.
The Follow-Up Letter is used when no activity has been performed on an RWA and PBS is not able to move forward on a project until the customer responds with information. PBS uses the Follow-Up Letter when normal communication lines have not proven successful in removing whatever obstacle is preventing the project from moving forward. The concern necessitating the Follow-Up Letter is PBS’s burden of delivering the project scope within a reasonable timeframe. Further delay could result in the closure of the RWA, and need for additional funding when/if the issue(s) preventing the continuation of the project is provided.
De-obligation should NOT occur until the customer receives the Closeout Letter, which comes AFTER the Completion Letter and identifies financial closeout.
F Type RWAs do not require a Completion Letter, but they do require the use of the Closeout Letter.
The customer should follow the instructions included in the Closeout Letter. Receipt of this letter indicates the customer may de-obligate the amount identified for de-obligation on the Closeout Letter.
Year-End Customer Letters
PBS makes every effort to send the year-end letters to customer agencies in the second quarter of each year, and posts them online at www.gsa.gov/rwa. The year-end letters are directly emailed to all customer agencies and should not be confused with individual customer letters generated in RETA for each RWA.
In the Policy and Guidance section on the external RWA website: www.gsa.gov/rwa
These are hard deadlines and the regions should plan according to their resources and workload. DoD is typically in June and all other customer agencies and the Judiciary are typically the end of August.
Yes, these are specific dates customer agencies need to be aware of. The risk for the customer is if PBS does not receive RWAs by the year-end letter date, PBS will reject the RWAs and request they be provided in the following fiscal year should the bona fide need still exist.
Yes. The year-end letters only speak from a time perspective as to consideration and do not make any acceptance guarantees.
External RWA Entry and Tracking Application.
RETA is used internally by GSA associates. eRETA is a customer-facing version for RWA customer agencies. Customer agencies have access to view and edit Work Requests and RWAs associated with Agency Bureau Code(s) their user ID has access to. GSA RETA users have access to all Work Requests and RWAs within their own region (regardless of Agency Bureau Code).
Yes, go to www.gsa.gov/ereta and scroll to the section labeled "eRETA Resources."
Yes, the “RWA Search” and Summary screens have summary level financial information about the RWA. The “Financial Review” section includes a more detailed breakdown of financial activity against the RWA.
Work requests initiated by the customer electronically in eRETA will be visible at all times after it is saved, routed to GSA, and on to become an eventual RWA. Work requests or RWAs submitted to GSA outside of eRETA will not be visible to customers in eRETA until GSA has entered them into RETA.
The balance can be found on the RWA Summary screen, on the Financial Review summary, and even the Documentation Summary of any RWA.
The Closeout Letter date reflects the timing of the most recent Closeout Letter, either generated in RETA or manually uploaded into RETA and sent to the customer by GSA.
All eRETA questions may be directed to firstname.lastname@example.org.
Contact the National Application Helpdesk (NAH) at COPBSApp@gsa.gov or at 866.367.7878
Contact these offices in the following order: (1) Follow up with your home agency Personnel Security Office (or HR Office) to verify if your Form was successfully submitted to GSA's Personnel Security Office. (2) Follow up with the GSA Personnel Security at GSA.SecurityOffice@gsa.gov to verify your application status. (3) Lastly, if necessary email eRETA@gsa.gov to look into the request further - please do NOT send a copy of your Form to eRETA@gsa.gov as it contains Personally Identifiable Information (PII).
Make sure the following actions have taken place (in this order): (1) Did you follow all the instructions in the eRETA Welcome Email from COPBSApp@gsa.gov, most importantly completing the "eRETA User Account Validation Form [XLSX - 9 KB] (Step 3 of 3)" online? If not complete this online form, or contact eRETA@gsa.gov if you cannot locate your Welcome Email. (2) Has it been 72 hours since you completed the "eRETA User Account Validation Form (Step 3 of 3)"? If not, please wait at least 72 hours before contacting eRETA@gsa.gov. (3) Contact eRETA@gsa.gov if the previous two conditions have been met.
Email eRETA@gsa.gov to provide your former email address/user log-in name and indicate you've changed agencies. GSA is required to remove access under your old account. Next, follow Steps 1-3 above in the "eRETA User Account Request Process" to request a new user ID with your new email address and access to new ABC(s) under your new agency.
“GSA Order CIO P 2181.1” dated 10/20/2008 drives this requirement. More specifically Chapter 1, Section 2 states: "HSPD-12 requires all Federal Executive departments and agencies to conduct personnel investigations, adjudicate the results, and issue identity credentials to all Federal employees and contractors who require routine access to their building facilities and information technology (IT) systems." Since granting access to eRETA falls under the umbrella of granting access to GSA IT Systems, it falls under the HSPD-12 purview. Since GSA does NOT have access to the background check/clearance of associates in other agencies, the one page “eRETA Application Clearance Verification Form” is effectively an abbreviated HSPD-12 background clearance to confirm that the requestor has an approved HSPD-12 clearance on file with his/her home agency. The “GSA Order CIO P 2181.1” outlines the procedures for granting logical access to GSA IT Systems in Chapter 6 - Chapter 6 of the CIO policy is provided below for your reference. GSA Order CIO P 2181.1 - Chapter 6
Yes. GSA strongly encourages you and/or your Personnel Security Office (or HR Office) contact the GSA Personnel Security at GSA.SecurityOffice@gsa.gov to ask any questions about the process. Please remember the “eRETA Application Clearance Verification Form” is only handled by you, your Personnel Security/HR office, and the GSA Personnel Security Office – all groups that are cleared to handle government employee and contractor PII. This information is not shared with the eRETA business line owners nor any other GSA associates outside of GSA Personnel Security. The email address and the fax number provided on the “eRETA Application Clearance Verification Form” are secure connections to transmit this information.
GSA is in the process of reviewing how to handle users that fall into these categories. At the moment “GSA Order CIO P 2181.1” dated 10/20/2008 only recognizes those with HSPD-12 clearances.
“GSA Order CIO P 2181.1” applies to ALL GSA IT applications where user access must be requested and granted. As such, all existing applications that may have once had fewer requirements to gain access are being revamped to comply with “GSA Order CIO P 2181.1.” New users requesting access to eLease, Del-eGate, or any other GSA system or application today, are asked to follow the same procedures outlined above.
Yes. eRETA provides global project and financial information on individual Reimbursable Work Authorization (RWA) projects. eRETA also includes a document storage tool that includes copies of signed RWA forms, estimates, customer letters, other customer communications, and much more. VCSS is a complementary application to eRETA and specifically provides access to bills and billing data for not only RWAs, but all GSA business lines. For more information on VCSS, please go to vcss.gsa.gov.
Not at this time. To gain access to eRETA, please follow the three-step process outlined above. To gain access to VCSS, visit vcss.gsa.gov and click on the "Registrations & Access Requests" button.
Self-service training and reference materials are available by clicking the "Training" tab at vcss.gsa.gov. Training tutorials as well as sample copies of new IPAC and non-IPAC billing statements are available here. Also, VCSS is part of a larger GSA initiative to consolidate all billing functions for all GSA business lines into a single billing system. The project known as Pegasys has valuable information, FAQs, and other materials at http://pegasys.gsa.gov/index.htm.
General Estimates Questions
Customers have 30 calendar days to respond to a cost estimate provided by PBS.
PBS does not charge for estimates, as they are considered a cost of doing business.
The customer must always pay overages. This is why it is crucially important for the Project Manager to manage the customer’s expectations especially in regard to cost estimates and accurately utilize the ranges of accuracy identified on the SCE Form.
Customers complain about estimates because the level of expectation is often not set with the customer according to the ranges of accuracy of PBS’s cost estimates. Customers use PBS’s “budget” and “order of magnitude” estimates at the beginning of a project to budget for future needs without understanding these estimates are preliminary in nature.
Summary Cost Estimate (SCE)
Yes, it is based on the GSA Cost Estimate or Independent Government Estimate (IGE) and must match the RWA authorized amount to within a dollar. For large lease projects, PBS must have an SCE that breaks out the RWA costs from the overall lease project costs.
An SCE is required for each RWA; thus, costs must be able to be separated.
The Summary Cost Estimate is usually filled out by the Project Manager.
Yes. PBS should continually update estimates and the SCE as work progresses and it becomes apparent that estimated costs may be higher or lower than originally estimated. The “range of accuracy” fields on the SCE allow PBS to be more transparent with how accurate an estimate is at any given point in the project lifecycle. As more requirements are known or phases of a project are completed, the final, total costs of a project become better known and the estimate and the authorized amount of the RWA should be adjusted accordingly.
PBS charges for travel when the travel is outside of PBS’s local area (50 miles) or is in excess of the typical travel required for a project (e.g., the customer requires PBS to be on-site more than the typical project).
Line 8 is for reimbursable travel costs (e.g., per diem, airfare, car rental and mileage) of PBS employees overseeing the project where the project has design and/or construction related expenses. Line 22 is for reimbursable travel costs (e.g., per diem, airfare, car rental and mileage) of PBS employees overseeing the project where the scope of work for the RWA is completely for personal property. Both lines are directly charged to the RWA and paid for by the customer.
Furniture installation included in the furniture vendor’s furniture costs are captured in the personal property items on line 18, but if installation is a separate contract, then it is captured in line 7 “Miscellaneous Construction Costs.”
DVRs, cameras, metal detectors, and similar types of equipment.
This service should be estimated in the base estimate and included in the Construction Costs.
Enter the security clearances on line 21 “Misc. Personal Property Costs” and specify the number of clearances in the “identify” box.
The second page is not required for RWAs. The SCE is shared across multiple business lines and the second page is used for other business line functions.
No, but the name of the preparer and date of preparation are required.
The customer may provide cost estimates at its discretion, but it is always up to PBS to perform due diligence on the estimates to verify and validate them. PBS will still need to assess whether the costs are fair and reasonable by completing a GSA Cost Estimate or IGE, or from written confirmation from a GSA PM or Cost Estimator that what the customer provided is sufficient.
Yes, but PBS must still conduct its own due diligence to verify the validity of the customer’s estimate.
Yes, the customer can send PBS an RWA without an amount, but PBS must not accept it until it has been revised to include an authorized amount that coincides with the SCE and has been signed by a customer certifying official. Though permitted, this is a practice that is discouraged, with the preference being for early and frequent communication to discuss and develop requirements together prior to RWA submission.
Yes, this is acceptable, but PBS needs to perform due diligence to ensure the historical estimate is derived from projects with similar requirements, locations and time constraints. These estimates should be assembled in a costing database that tracks by location, and must account for inflation and material increases. For instance, historical estimates for alterations in New York, New York will differ greatly from a similar project in Billings, Montana.
Independent Government Estimates
Yes, but PBS must conduct due diligence to accept the customer’s estimate with written confirmation from a GSA PM or Cost Estimator that the costs are fair and reasonable.
PBS may use appropriate market or historical data in its preparation, but an IGE is still required.
General Questions on Fees
No. The 4% PM Fee is for regional project management oversight, contracting, entry, and tracking whereas the Sliding Scale Fee is a Central Office overhead fee that covers the program office, finance activities, RETA and eRETA.
The fees are separated as a result of the fee structure determined in years past. The fees are currently being reviewed and may change in the future.
The Sliding Scale Fee is applied to the 4% PM Fee and all other costs (including personal property). The “order” and “timing” at which the Fees are charged is driven by expenses incurred (i.e., gradually throughout project delivery).
Assuming construction-related function codes are used, the 4% PM Fee will apply to every nonrecurring RWA, including F Type RWAs, and the Sliding Scale Fee is additionally applied to all nonrecurring RWA Types.
A Contingency is meant to cover the unknown risks associated with a project. Each project has a unique set of circumstances that may require a higher or lower contingency than other related projects. The more risk (or unknowns) a project has, the higher the contingency will need to be. Regardless, the RWA needs to have a clear and succinct scope of work.
4% Project Management (PM) Fee
The Sliding Scale Fee is added on top of all RWA costs to cover the costs of managing the Reimbursable Services Program. This includes the costs of tracking personal property information in RETA and eRETA and therefore is captured in program overhead.
No, only the Sliding Scale Fee has a maximum of $30,000. The 4% PM Fee has no maximum and no minimum.
PBS charges the 4% PM Fee to all customers on all eligible project expenses.
The 4% PM Fee is charged on ALL construction-related costs on nonrecurring RWAs. The 4% PM Fee only applies to eligible project expenses including such things as design, construction, and construction management and does NOT apply to other non-construction related project expenses such as personal property, moving costs and severable services.
PBS charges the 4% PM Fee to cover the indirect costs of doing business. If a PBS associate is performing any of the work related to the project scope (e.g. design intent drawings), then PBS should directly charge the customer for that time. All project management, contracting, and coordination duties are covered by the Fee.
The 4% PM Fee is based on expenses incurred. As expenses are incurred and entered into the PBS financial system, the fee is automatically applied and bills the customer accordingly.
PBS uses the Summary Cost Estimate Sheet to figure out what the Fees are for the project.
Not for typical projects, as this is captured as part of the 4% PM Fee. However, PBS offers workplace design services where a PBS interior designer works directly with the customer, something considered beyond normal scope development, and would have direct costs associated, as detailed in the cost estimate prior to RWA acceptance.
PBS does not charge for developing a reasonable number of scope scenarios for a customer, as this is considered a part of doing business, though resources are not endlessly unlimited either. The 4% PM Fee is meant to cover “indirect costs”.
This is the cost of doing business and is captured by the 4% PM Fee.
Yes. Change orders fall under the same rules as the original RWA.
No, it does not apply to any overtime utilities.
Yes. Every single RWA obligation under an F Type RWA may not exceed $25,000, inclusive of fees.
The 4% fee covers the moving and installation of items which are fixed or attached to the real property. If the furniture or other personal property does become fixed or attached to the real property, then the 4% fee applies to the installation. If the furniture or other personal property does not become fixed or attached to the real property, then the 4% fee does not apply to the installation.
Yes, because moving costs are included in the construction cost. Moving is charged a fee based on the way it is procured, in this case with the construction contract.
No. Contracting for personal property is a cost of doing business.
There are two types of overhead fees: the Sliding Scale Fee is for nonrecurring RWAs and the $100 Flat Overhead Fee is for Recurring RWAs. They both cover National Program Costs (Policy, Procedures, Coordination, Systems, Training, etc.).
Yes, the Sliding Scale Fee is automatically charged as the RWA incurs expenses.
Yes, the Sliding Scale Fee has a maximum threshold of $30,000.
Direct costs must be included in the SCE and authorized amount of the RWA.
Having a PBS associate on-site after hours is not a typical project management function covered by the 4% PM Fee, so PBS can charge customers for that employee’s time directly.
Billing & Receiving Reports
PBS bills customers for both recurring and nonrecurring RWAs on a monthly or quarterly basis.
Bills are no longer sent to customers, but can be accessed on approximately the 25th of each month on the Vendor & Customer Self Service (VCSS) website: https://vcss.ocfo.gsa.gov/
A customer obligation to PBS only means the funds are reserved by PBS for the project. For PBS to be reimbursed for the project services being delivered, PBS must bill the customer to receive payment thereby liquidating the customer’s obligation. PBS bills are generated by expenses incurred.
The customer bills show the fees that PBS charges. There is a line item for “PBS RWA Fees” on the second page of the bill under “Cumulative Billed Financial Summary”.
GSA transitioned billing systems in FY2013 and at the time also reconfigured the RWA billing statement format to include additional information RWA customers had been requesting. For information regarding the FY2013 billing system transition (known as the Billing and Accounts Receivable (BAAR) project) and for a copy of the revised RWA billing format, please visit the BAAR website at: http://www.gsa.gov/portal/content/142063
Copies of RWA billing statements can be found at vcss.gsa.gov. Instructions for VCSS are available at www.gsa.gov/rwa.
The Government Accountability Office (GAO) published a list of five FAQs regarding IPAC transactions along with several real-life situations and the GAO decision on each of those instances. This March 2008 FAQ publication can be found at the following website: http://www.gao.gov/special.pubs/appforum2008/interagencytransactions.pdf
No. The VCSS billing system no longer sends bills to customers. Instead, customers are encouraged to log into the system to review bills on a monthly basis, after receiving an email notification from VCSS that they have a new bill.
PBS bills the customer against the RWA, and it is up to the customer to ensure the correct fund year is cited when issuing payments to PBS.
PBS should be directly billing for PBS-provided CM Services to the RWA.
When the landscaping services are considered above standard (i.e. not in rent) and PBS receives an invoice or bill, the services are considered nonrecurring. When the landscaping services are considered above standard (i.e. not in rent) and PBS does NOT receive an invoice or bill, the services are considered recurring.
Non-IPAC RWAs require additional administrative effort by GSA finance. The $1,000 threshold is in place so GSA is not needlessly spending time reconciling and addressing issues with small dollar amounts. Once expenses exceed $1,000, the RWA will bill the customer. If the RWA as a whole or a final bill amount is less than $1,000, then the amount is billed once the completion date is entered.
No, those items impact financial closeout, but should not delay physical substantial completion.
Yes, but GSA discourages IPAC customers from using credit cards because it costs the government unnecessary credit card fees. Additionally, credit card information is no longer requested on the RWA Form, and the customer is required to log into pay.gov to use their credit cards to pay for services received from PBS via an RWA.
On each bill, there is a point of contact from GSA Finance, who should be able to assist with answering financial related questions, including billing. If the questions are specific to the project, the RETA point of contact or the Project Manager may be a better source of information.
Vendor and Customer Self-Service.See their website at http://vcss.gsa.gov.
The process of how a customer pays is unchanged; VCSS is simply a different venue for them to retrieve a copy of their bill. Billview (https://finance3.gsa.gov) will remain the system of record of all bills prior to July 2013.
There are always two "bills" for IPAC customers; the Treasury IPAC transmission is a one page document with some basic data elements, including the amount of the bill, and has PBS POC information (for RWA bills) for questions or where to go to get more details. VCSS is the location of the more detailed bill - the dollar amount is the same as the IPAC version, just with additional details of the bill they were first notified of via the IPAC system.
PBS cannot verify the correct funding year is being used unless other information on the RWA indicates that the funding year is incorrect.
When PBS finds that the fiscal year used in the accounting string is different from the Agency Fund Year.
Have a conversation with the customer and let him/her understand that in order to deliver the project, the requirements should not change.
PBS should verify the no-year fund type against all other financial data on the RWA to ensure that all information is consistent with no-year funding. PBS should verify with the customer agency if doubt remains. PBS usually does this when an agency that typically provides RWAs with annual funding, requests work with no-year funds.
Generally, GSA performs reimbursable work for other Federal agencies using the authority of provided by 40 U.S.C. § 592(b)(2) or 31 U.S.C. § 1535 (the Economy Act). GSA’s authority to obtain payments for the work it provides to other Federal agencies on a reimbursable basis is 40 U.S.C. § 581(g).
PBS uses the authority provided by 40 U.S.C. § 592(b)(2) to perform reimbursable work in property within the jurisdiction, custody and control of PBS. PBS uses the authority provided by the Economy Act to perform reimbursable work in property that is not within the jurisdiction, custody and control of PBS, as well as all Department of Defense RWAs.
The customer agency may obligate its funds when PBS signs and accepts the RWA in accordance with the Recording Act, 31 U.S.C. § 1501, but the customer agency usually does not know to obligate its funds until it receives the Acceptance Letter and signed RWA from PBS. PBS’s signing and acceptance of the RWA, that acceptance being recorded in RETA, and the Acceptance Letter being sent, should happen almost simultaneously.
The funds are obligated to PBS when PBS accepts the RWA and the customer records that obligation in their own accounting system for the scope of work intended to be delivered by PBS. Transfer of the funds takes place when PBS incurs expenditures, bills the customer, and the customer agency makes payment to reimburse PBS for those expenditures.
The customer agency’s obligation of its funds occurs once PBS accepts the RWA and notifies the customer of acceptance (via the Acceptance Letter). PBS’s obligations of those funds occur as PBS signs contracts to deliver the scope of work identified on the RWA throughout the duration of the project.
As a matter of policy, PBS does not begin RWA projects prior to receiving the full amount of funding needed to complete the project from the customer agency. Only planning, requirements development, and cost estimating services can be performed by PBS before an RWA is accepted. These services are considered the cost of doing business and are reimbursed by the fees associated with the reimbursable program. At no point should PBS require a customer agency to submit a $0 RWA to develop requirements or estimate costs.
-Annual appropriation: An appropriation that is available for obligation only during a specific fiscal year. This is the most common type of appropriation. It is known as both a "fiscal year" or "annual" appropriation, and remains available to liquidate obligations properly chargeable to that account for five fiscal years after the period of availability expires. -Multiple year appropriation: An appropriation that is available for obligation for a definite period of time in excess of one fiscal year, and remains available to liquidate obligations properly chargeable to that account for five fiscal years after the period of availability expires. -No-year appropriation: An appropriation that is available for obligation for an indefinite period. A no-year appropriation is usually identified by appropriation language stating that funds are, "to remain available until expended." http://disbursements.house.gov/glossary.shtml
No, customer agencies receive direct appropriations for Rent. As a result, providing an RWA to pay for Rent could augment the customer agency’s appropriation. Thus, PBS cannot facilitate the use of an RWA as a funding source for Rent, as customers receive directly appropriated funds for that purpose.
BONA FIDE NEED
Bona fide need is a fiscal law requirement established in 31 U.S.C. § 1502 specifying that a time-limited appropriation can be obligated only to meet a legitimate need arising in (or in some cases arising before but continuing to exist in) the fiscal year for which the appropriation was made. In other words, an agency cannot use current year funds for a future year’s need.
PBS’s role in checking the bona fide need is to make sure that the customer agency’s need for the goods or services aligns with the timing of its appropriation, making sure the customer can document and define the need so as not to allow current year funds to be “banked” for future year needs, and ensuring that the contract can be awarded within a reasonable amount of time. PBS’s role is to ensure that projects are fully defined and funding is appropriately spent.
Yes, GSA can accept an RWA for nonseverable services and begin the work in the next fiscal year because the customer’s bona fide need for the work exists when the RWA is accepted (i.e., in September). Bona fide need refers to the timing of the need and not the timing of the expenditure. If the customer needs the project, could use the project today, and can define the need for the project today, then the Bona Fide Needs rule has been satisfied.
Funding of the same scope of work for a nonseverable service over several fiscal years. More specifically, incremental funding is defined as using time-limited funds (annual or multiple year funding) or mixed fund types such as annual or multiple year funding and funding that is available until expended (no-year funds) from multiple fiscal years to fund a nonseverable service, such as construction.
No. Fiscal law and GSA and DoD policy prohibit incremental funding, regardless of fund type.
The entire funding to support the estimate for the scope of work must provide for a discrete and fully functional project deliverable (that is, a complete phase or stage of the project or essentially a severable component of the scope of work for the nonseverable service).
Ensure each RWA fully funds the associated scope of work and is for a discrete deliverable (i.e. other RWAs have not already been accepted for the same scope of work).
Yes, but if the customer agency wants to use multiple billing addresses, then it needs to submit multiple RWAs.
No, PBS cannot issue a Request for Proposal or Request for Price (RFP) prior to accepting an RWA. It is not unusual to seek market prices when developing an RFP, however a contractor cannot be given information that will assist it with bidding or preparing a proposal. For a lease, the lessor can solicit estimates.
An RWA is not needed to begin requirements development, but PBS policy requires that an RWA is accepted prior to contracting for billable design work. PBS cannot begin in-depth design work before accepting an RWA and then back bill for those services.
PBS must ensure that no additional obligations are placed against the RWA. PBS will then close out the RWA (rather than cancelling it) and bill the client agency for the costs already incurred.
PBS may use historic data, lump sum costs, square footage costs, or a combination to provide cost estimating based on the understanding of the project and facility. As requirements are further defined and phases of a project are completed, the level of accuracy of the SCE will improve. Insite Link to P-120 Project Estimating Requirements form: https://insite.gsa.gov/portal/content/510100
Customers can submit RWA work requests directly to GSA via eRETA. In those cases, RETA automatically routes the request to the appropriate regional POCs depending on the work location. For cases where customers do not use eRETA to submit RWA work requests, several regions process RWAs through their regional centralized mailboxes found here at www.gsa.gov/rwa under the “Submitting an RWA to GSA” section. Ultimately, any GSA associate may receive an RWA and he or she should forward it to the regional centralized mailbox, RWA Manager, or appropriate GSA POC.
No, accepting an RWA funded with expired funds that was submitted by a customer agency but never officially accepted by PBS by signing the RWA violates the Recording Act (31 U.S.C. § 1501) which states that an amount shall be recorded as an obligation only when supported by written evidence of a binding agreement between 2 agencies that was executed before the end of the period of fund availability. Since PBS did not sign and accept this RWA during the period of fund availability, there was no binding agreement or basis for the customer agency to obligate the funds. If the customer agency continues to desire the project, the RWA with the expired funds should be returned to the customer agency unaccepted and the customer agency should submit a new RWA using funds that are currently available for new obligations.
Yes, PBS can accept phased RWAs, but each phase must include a discrete and fully functional project deliverable and be fully funded.
RWAs are a type of IAA. Upon acceptance by PBS, the RWA is the document used by PBS to obligate the funds on behalf of the requesting agency. As such, PBS then becomes the servicing agency and the funds are recorded on the requesting agency’s accounting records as an obligation. If there is a separate memorandum of agreement, or IAA, PBS requires that it be attached to the RWA Form 2957 as a supplement to, but never in lieu of, the RWA. In any event, PBS always requires an RWA to be submitted when a customer agency is requesting work to be performed by PBS, as the servicing agency, under either 40 U.S.C. § 592(b)(2) or the Economy Act.
RWA Amendments and Antecedent Liabilities
An RWA should be amended for cost increases that are attributable to work within the scope of the original RWA or for new scope when added during the period of availability of the customer agency’s funds from the original RWA. A new RWA is required for work that is outside the scope of the original RWA when the customer agency’s funds from the original RWA have expired.
If there is a change needed to the scope or requirements accepted as part of the original RWA, the customer should work with the PBS project manager to define the change in requirements to determine next steps. The project manager will provide either a revised or new SCE to reflect the changes or additions, and the customer must submit either a new RWA or an amended RWA, depending upon whether or not the changes were within the scope of the original RWA or not and whether the customer agency’s funds from the original RWA remain available or have expired.
A customer agency sending a letter or email is not sufficient to make any changes to the amount on an RWA; rather, customer agencies must submit a signed RWA with the amended amount.
Yes, but the RWAs must fall into the specific guidelines and rules outlined by the Stand Alone Option for Furniture Acquisition (SOFA) program.
No. It is attached to the structure so it is not considered personal property.
No. PBS does not perform this type of work.
90 Day “Reasonable Time” Restrictions
GSA’s Acquisition Policy requires that PBS re-obligate customer agency funds within 90 days after acceptance, unless a schedule is in place at the time of RWA acceptance that details when the obligation will take place. This is to ensure the Bona Fide Needs rule is not broken and that PBS is accepting funds for projects that customer agencies truly need.
Customer agency funds must be re-obligated by PBS within a “reasonable time” after acceptance of the RWA. 90 days is a standard applied by PBS. Contracting time should be built into the schedule, so if 90 days to obligate is not realistic, then the schedule should be reviewed with the customer prior to RWA acceptance.
No. In the case where a customer agency gives PBS an RWA for miscellaneous services (F Type), which closes at the end of the FY, the 90 day rule does not apply.
5 Year Liquidation Period
The timing of availability of an appropriation means an agency is given funds through an appropriation and those funds must be obligated within a specific time period. If an agency is given a $1M annual appropriation for the current fiscal year, this means the agency has until the end of the fiscal year to obligate that $1M. If the agency obligates $1M to PBS on an RWA, and PBS has re-obligated the customer agency’s funds within a reasonable time, then PBS has up to 5 fiscal years from the end of the customer’s obligational authority (the end of this fiscal year in this case) to incur all obligations and to liquidate (expend) the obligations incurred. (See 31 U.S.C. § 1553). PBS is required, by law, to incur its obligations within a reasonable time, as detailed in the “reasonable time” questions.
The customer’s obligational authority is determined by the type of appropriation it receives from Congress. For an annual appropriation, the customer’s obligational authority expires at the end of the fiscal year in which it was received. For a three-year appropriation, it expires at the end of the third year after the funds were received. PBS must re-obligate customer agency funds within a reasonable time as specified in the RWA or within 90 days from acceptance of the RWA. PBS can liquidate funds obligated to it by the customer for up to 5 fiscal years after the customer’s obligational authority has expired.
No. For annual funding, the customer only has 1 fiscal year to obligate those funds to PBS. (See 31 U.S.C. § 1502). PBS then has up to 5 fiscal years, if necessary, to obligate to contractors and liquidate those obligations (See 31 U.S.C. § 1553).
No. The 5 year liquidation period clock does not start until the customer’s obligational authority expires. (See 31 U.S.C. §§ 1552 - 1553).
The funds are sent back to the customer agency who must return the funds to the Treasury. The customer agency may be able to obligate currently available funds in accordance with 31 U.S.C. § 1553(b) if the customer wants to continue with the project and also to cover any costs PBS may have incurred that were not yet billed.
The five year liquidation rule from 31 U.S.C. § 1552 does not apply to no-year money. No-year funds are generally marked for specific projects and normally remain available until they are expended, thus never really “expiring” unless Congress withdraws or rescinds the funding. That said, projects exceeding five years in duration are not common and require heightened review and scrutiny.
Remaining Funds at Closeout
If there are funds remaining on an RWA at the end of a project, PBS must send a Closeout Letter to the customer so the customer can de-obligate the funds on its books and determine any further availability or potential use of any remaining funds.
No. If funds are remaining on an RWA, then the RWA should be closed and notice should be given to the customer identifying the remaining balance that should be de-obligated.
If the customer de-obligates funds, then it is up to their Fund’s Certifying Official to reprogram and recertify the funds. If it comes back to PBS as an RWA, then PBS has to view it as a new project. If the obligational authority of the funds has expired, PBS will reject the RWA.
Not at completion, but at financial closeout PBS should return any remaining funds to the customer and let the customer agency decide what to do with the funds.
RWAs without any financial activity and all R-type RWAs (regardless of financial activity) may be canceled, but RWAs with any financial activity (except for R-types) will follow the substantial completion process. PBS will collect any remaining expenses incurred prior to early completion and then allow the customer to de-obligate the remainder.
Economy Act & Department of Defense RWAs
For goods and severable services, PBS must accept the RWA, award a contract, and the contractor must begin performance for the requested goods or services prior to the end of the fiscal year. For nonseverable services, PBS must accept the RWA and award a contract for the requested services prior to the end of the fiscal year.
The year-end letter dates are provided to ensure the customer (DoD) gets its RWAs in with enough time for PBS to perform its due diligence. It is up to the region to accept the RWA according to the time and resources available.
The DoD procedures are different as a result of DoD-specific policies.
RWAs in Leased Space
If lump sums are known, then PBS should ask for the RWA after the first round of offers.
No, provided the estimated project completion date of the RWA is within the performance period of the lease (e.g., in this case within 2 years), though business case justifications will likely be required.
The scope must be as detailed as possible at the time of acceptance. The amount must be based on a bona fide need, scope of work, and cost estimate.
After initial cost estimates, but prior to issuance of a Request for Proposal (RFP).
No, customers can only buy down the customized portion of its TIs.
Yes, but only in second generation space.
The customer may elect to give PBS a lump sum payment RWA for all, or part, of its customized portion of the TI allowance. If the customer does not exercise this option, the customized portion of the TI gets amortized into the rent payments and may not be changed.
Yes, if there is no change in scope, the customer agency must fund the antecedent liability with funds it had available when the original RWA was submitted, or if it has no such funds, it can submit a Statement of Further Written Assurance certifying that it has no funds that were available when the original RWA was submitted and then submit currently available funds.
General RWA Process Questions
Specific project questions should always be directed to your Project Manager, but an additional resource for other RWA questions are the regional RWA Managers. The list of regional RWA Managers is available at this link: http://www.gsa.gov/portal/mediaId/182039/fileName/RS_CoreTeam_Date_Removed_from_Banner.action
RWA Form 2957
The RWA Form 2957 contains blocks that have to be completed by both the customer and PBS. All customer required fields are located on page 1 of the form and instructions on filling out the form are found on pages 3 and 4. The form is located here. Note: Customers are encouraged to enter RWA data directly into eRETA. Data entered into eRETA is autopopulated onto the RWA Form 2957, so if a customer fills out the information in eRETA, then they won’t have to manually fill out the Form since eRETA does it for them. More information can be found at www.gsa.gov/ereta under the ‘eRETA Training Materials’ tab.
Since this is a customer code, the customer is responsible for providing the correct value. Customers should confirm with their internal Finance office if uncertain. Valid Treasury Symbols are available to the public at Treasury’s “Shared Accounting Module” (SAM) site. This site replaces the former Treasury FASTBook, as SAM is updated daily while the FASTBook may only be updated annually. Information about the SAM site can be found at http://fms.treas.gov/sam/index.html. A list of valid Treasury Symbols can be found at https://www.sam.fms.treas.gov/sampublic/tasbetc.htm.
It is suggested that PBS assist the customer with filling out the RWA form, but not do it all for the customer. It is important that the customer know and understand its financial information and requirements.
No. The level of specificity depends on the type of project, but to be clear and acceptable the Description of Requirements must include, at a minimum, the location, the type of work, and the description of work. The scope of work is necessary to set expectations and support a cost estimate, so requesting more detail (i.e. square footage of any existing carpet to be demoed, square footage/style/and type of new carpet to be installed, type of paint, etc) will allow PBS to accurately determine the level of work necessary.
Normally it is the requesting agency’s budget officer, but it can be any position within the requesting customer organization that is qualified and certified by the requesting organization to commit and obligate funds on behalf of the organization.
The customer signature is certifying the availability of the funds for the purpose(s) requested in the RWA. Once PBS signs the RWA to accept those funds, they are shown as an obligation on the accounting records of the requesting agency and entered into the customer financial system of record.
If the date the customer signed is a significant time from the date received, then the PM should contact the customer to verify the RWA is still needed and likely request they confirm by resigning and dating the RWA.
Yes, PBS should have the customer make a pen and ink change and initial the change.
Yes. The RWA Form provides the option for electronic signatures and PBS guidance indicates “the Form meets the requirements for valid obligation…if doubt exists as to the validity of the digital signature, Regional Staff are encouraged to seek additional assurance…if necessary request a traditional ‘wet’ signature.”
Scope of Work
The scope of work is used to create the cost estimate, so a project scope should be developed before PBS can estimate its cost. A cost estimate is required prior to creating an RWA.
Every project will have a scope of work that gives detail as to what the project involves and drives the cost estimate. The Description of Requirements can function as the scope of work for less complex projects, but there must be sufficient detail for an accurate cost estimate to be created from the information provided.
Yes, but only for the travel portion and not for developing the scope of work.
Yes, but the new project still needs to be documented.
No. Unforeseen conditions are part of the percentage added for contingencies.
As detailed as possible at the time of acceptance. The amount must be based on a bona fide need, scope of work, and cost estimate. It should give the reason PBS knows a lump sum is required.
No. If the customer needs to deviate from the RWA scope after the customer’s obligational authority has expired, then PBS must ask for a new RWA.
The scope of work from the RWA is refined during contracting. RWA scopes of work need to have enough detail to create a cost estimate and clear deliverable(s). This will assist in moving the project forward more quickly as the overall project scope of work will need further refinement during contracting.
The RWA ]scope will be less detailed than the overall project scope as the RWA scope of work encompasses only those items the RWA applies to.
Customers may only amend for new scope in the same fiscal year as when the original RWA was accepted. Otherwise a new RWA is required. For example, an RWA accepted in FY2018 may only be amended for new scope in FY2018. If in a later fiscal year, then a new RWA is required.
If there is a change needed to the scope or requirements accepted as part of the original RWA, the customer should work with the PBS project manager to define the change in requirements to determine next steps. The project manager will provide either a revised or new SCE to reflect the changes or additions, and the customer must submit either a new RWA or an amended RWA, depending upon whether or not the changes were within the scope of the original RWA or not, and if we are still in the same fiscal year as when the original RWA was accepted.
It is advised that scope changes be related to original program/scope, especially if obligations to a contractor have occurred. If the scope changes are completely outside of the original scope, then PBS should close the project, return the funds to the customer, and ask for a new RWA. This is a matter of keeping our RWA projects clear and free from confusion.
Yes, because the RWA would have to be amended or a new one provided and would require a new signature certifying the bona fide need and funding availability.
If the scope of an RWA changes after the fiscal year in which the original RWA was accepted, PBS must get a new RWA with new funding based on a new estimate.
There is no official time as RWA acceptance is based on many factors. Project Managers should be aware that customers want projects accepted within a timely manner, so it is up to the Project Manager to manage the customer’s expectations for acceptance.
This depends on the variables surrounding the project; regional resource availability, project complexity, customer requirements status, etc. GSA regions follow an intake process that aims to manage the intake timeline to within 15 business days of receipt of a fully executable RWA. GSA encourages customers to engage in open and continuous communication with RWA Managers to ensure timely responses. The RWA Managers Map can be found on our website at gsa.gov/rwa or directly at this link.
Yes, but the PBS representative receiving, reviewing, or accepting the RWA must have reasonable assurance, and be comfortable that, the digital signature is valid. If PBS has doubts as to the validity of the digital signature, PBS is encouraged to seek additional assurances from the certifying and approving official and, if necessary, request a traditional "wet" signature.
Yes, schedules are required and procurement activities and milestones must be shown if the procurement is anticipated more than 90 days beyond the acceptance of the RWA.
A schedule is only required for acceptance if the award date by PBS is anticipated beyond 90 calendar days from RWA acceptance. If a schedule is not provided then PBS will begin execution of the RWA within a reasonable time, further defined by PBS as 90 calendar days. Either way, it is advisable that PBS prepares and utilizes schedules to the extent possible for all projects.
No. DIDs and CDs will allow for increasingly accurate cost estimates. If estimates increase as a design matures, PBS must ask for an amendment to the previous RWA. If no RWA was collected during a lease project because no known lump sums existed and the DIDs and CDs lead to lump sums, then PBS will ask for the RWA at that point.
Yes. GSA encourages this approach but must ensure that each phase is a fully deliverable project as detailed in the individual scopes of work.
No, there should be a description of the service the customer needs. It is only assumed the services to be provided are of a miscellaneous nature when an F Type RWA is used.
This is not a practice PBS supports. A customer agency is required to pay for the services they request and use. If PBS receives an RWA with this verbiage, or any vague or ambiguous language, PBS will return the RWA to the customer requesting the language be removed and the RWA resubmitted.
Substantial Completion & Cancellation
RWA substantial completion means the RWA is substantially complete and the customer agency may take beneficial occupancy of the space. There may still be punch list items remaining, but the customer can use the space for its intended purpose.
Completion means the RWA project is substantially and physically complete. Essentially, the customer can take beneficial occupancy and Rent can begin.
Yes, because the customer can then take beneficial occupancy of the space.
When an RWA is substantially complete, the PBS office responsible for the RWA will initiate prompt action to submit the project completion dates to the customer agency and in RETA. Since C, F, and R Type RWAs require a completion date upon initial acceptance, they are not required to be certified complete a second time when the completion date occurs.
RWA substantial completion happens when the last item on the RWA is complete. If the construction is complete, but the furniture has not come in, then the RWA is not yet substantially complete. In other words, if the furniture is necessary for beneficial occupancy of the space, then the RWA is not yet complete. If furniture was procured independently by the agency, then substantial completion is achieved at the completion of all scope within the RWA.
In a large project, this occurrence is possible but not very probable. Closing out the financial side of a project usually takes some time after project completion even if no punch list items exist, however it is up to the financial community to determine financial closeout and to send the Closeout Letter.
No. RWA substantial completion must be identified in RETA when the space is substantially complete. This is an important milestone that must be accurately captured, as it often signifies when Rent may begin.
Completion is based on the scope of work for each RWA, not the entire “Project.” Enter the completion date on each RWA based on when each RWA is physically substantially complete.
If there is one RWA for all phases, then the substantial completion will be the physical substantial completion date on the final phase of the project. If an RWA was obtained for each separate phase, then the substantial completion date would be the dates that each of the phases are completed for each respective RWA.
Substantial completion is the RWA substantial completion, so this will be determined by the final item completed on the RWA.
Yes. Customers can cancel RWAs after they have been accepted. A cancellation date (D-input code in RETA) is applied to nonrecurring RWAs with no financial activity ($0) and all R-types (regardless of financial activity). For nonrecurring RWAs that have had some financial activity, PBS will bill the customer for all spending incurred to date. Instead of a cancellation date however, an early completion date (N-input code) should be applied to the RWA.
Typically, yes. The customer should sign a revised RWA Form with the authorized amount reduced to $0 (or the amount of goods/services rendered up until the point of cancellation). However, PBS can unilaterally cancel an RWA for an unresponsive customer, which does not require the customer's signature.
The customer must contact the PBS office in charge of the RWA and request the cancellation in writing. If costs have been incurred on any nonrecurring RWA, PBS should follow the substantial completion process instead of this cancellation process. If costs have not been incurred, upon receipt of a cancellation request from the customer, PBS should take steps to update the RWA Form accordingly before requesting the customer sign and date it.
-Completion means the RWA project is physically and substantially complete and the customer can take beneficial occupancy. The completion date is entered in RETA upon inspection and determination that the need identified on the RWA has been successfully delivered to the customer. -Closeout means that the project is financially ready for closure, meaning all funds have been obligated, expensed, billed and collected. This signifies the termination date in RETA can be set. -The termination date triggers the Closeout Letter, alerting the customer that he/she can de-obligate any remaining balance.
In a large project, this occurrence is possible but not very probable. Closing out the financial side of a project usually takes some time after project completion even if no punch list items exist, however it is up to the PBS financial associates to determine financial closeout and to send the Closeout Letter.
No. RWA Substantial Completion must be marked in RETA when the space is substantially complete. This is an important milestone that must be accurately captured because this is when Rent can start for the customer.
(Non)recurring and (Non)severable RWAs
Recurring RWAs provide services to client agencies where the costs of those services cannot be readily differentiated or separated from standard operating costs. Nonrecurring RWAs are those RWAs that provide services where costs can be readily identified and separated from standard operating costs.
A severable service is one in which the client agency receives value as the service is rendered; the services are continuing in nature. A task is severable if it is divisible into components where each component meets a separate client agency need. A nonseverable service is one in which the client agency receives value only at the completion of the service. A task is nonseverable if it is required in its entirety to meet the client agency need.
A & N Types
N Types are the most commonly used RWA and are fully funded by the customer. They are for Federal and leased space. A Type RWAs are for split-funded projects in which both PBS and the customer agency provide funding for a project in Federal space.
The “one time need” as described in the N Type definition means that N Type projects are typically nonrecurring, nonseverable projects that result in a specific and unique final deliverable such as an alteration project.
Yes, an N Type for nonseverable services can be accepted during the period of availability of the funds and can be liquidated for up to 5 years beyond the expiration of the customer’s funds. If an annually funded severable service is performed on an N Type, the N Type RWA can only last 12 calendar months.
Yes, but only for nonrecurring services.
No. This is the definition of parking funds and violates both PBS policy and appropriations law.
A prospectus project must be approved by Congress as a line item in the PBS budget. The prospectus thresholds can be found on GSA's website: http://www.gsa.gov/portal/content/101522
This decision is based on whether or not the renovation is a part of the original prospectus project. If the renovation is a part of the prospectus project and will be associated with the project as a supplemental RWA, then a B Type will be used. If the renovation is outside the scope of the original prospectus project, then an N Type will be used.
No, additional approvals for prospectus RWAs are not necessary or required by PBS. Prospectus approvals are the responsibility of the customer. By signing the RWA, the requesting agency attests that all necessary requirements have been completed.
Yes. The RWA should be a B Type and should cite the original project.
C and D Types
A non-federal customer would use an RWA for services and space needs in a GSA building just as a federal customer would.
C Type RWAs are used for non-federal recurring services and D Type RWAs are used for non-federal nonrecurring services.
Unlike all other RWA types, C & D-Types require prepayment by the customer via check (which must include the RWA number) or credit card (through the Department of Treasury's "Pay.gov" website)". Checks should be mailed to the Fort Worth Finance/USDA Financial Management Line of Business (FMLOB) offices. A list of appropriate lock box addresses can be found on Forth Worth Finance’ FAQ site here: https://finance3.gsa.gov/homepage/FAQ.aspx. Then, click on the Region 7 FAQ link.
Non-federal customers holding events in federal space need to use an RWA to pay for the use of the federal space.
Non-federal customers requiring overtime utility services in one of GSA’s buildings.
E Types (Emergency)
E-Type RWAs were previously provided to PBS in response to FEMA Mission Assignments, but that responsibility transferred to the Office of Mission Assurance (OMA) in FY2014. E-types are no longer utilized and are decommissioned in RETA.
They should be referred to a GSA OMA representative at the following email address:eoc.gsa@gov
OMA is a customer, so they should be completing page 1 and signing page 1 as the customer certifying official (block 18A). PBS should complete and sign page 2 (upon acceptance) as the GSA Approving official (28A) as we do with all other RWAs.
PBS should code the RWA to the organization code of the field office that is performing the work, for example the leasing specialist’s organization code.
The correct BOAC is 473F72.
PBS should start planning with customers as soon as possible, even before the start of the FY, for F Type services that will be needed. Customers can provide F Type RWAs at the start of the FY for miscellaneous services throughout the FY.
F Type RWAs are for miscellaneous services that are typically needed throughout a fiscal year not to exceed $250,000 total per RWA and $25,000 per order. These RWAs are not allowed to cross fiscal years and it is presumed that these services will be needed based on prior history.
Yes, PBS can amend an F Type up or down during the course of the fiscal year.
Any funds that have not been paid to PBS are still on the customer’s books as an obligation. The customer simply de-obligates that obligation when PBS closes the RWA and the customer receives a Closeout Letter.
Yes, F Types have to be obligated and expended before the end of the fiscal year as F Types close at the end of the FY. This highlights the importance of monitoring the funding balances, so customers can preemptively de-obligate and redirect unused funding to other projects prior to the end of the fiscal year.
Yes, liquidations are allowed in the new fiscal year.
F Types require signatures, just as the other RWA Types, because they are RWAs customers are obligating funding against.
Yes, but GSA discourages IPAC customers from using credit cards primarily because the assessed credit card fees represent a less than optimal use of government funding where other funding options exist.
F Types can still be used for credit card payments in GSA to GSA transactions; however, GSA no longer allows F Types with an authorized amount of $0.
Identify historic costs and estimate accordingly. F Types spending should be monitored so that PBS can appropriately request additional funds or suggest the customer de-obligate balances throughout the fiscal year.
It needs to provide the anticipated amount of service from which the authorized amount was derived and needs to give the basic required information in field 5: Description of Requirements; Location, Type of Work, Description of Work, etc.
Typically severable, but can be nonseverable on rare occasions.
No, R Types can also bill quarterly.
R Types are most commonly used in federally owned space. In leased space, the lessor typically has separate metering capabilities for utilities, making an N Type the more appropriate choice.
Severable Services & Nonseverable Services
No, severable. One cannot mix severable and nonseverable items on an RWA. If a service is a one-time repair, then it would be nonseverable.
Yes, but the period of performance cannot exceed 12 months for annually funded RWAs in accordance with 41 U.S.C. § 3902.
No, recurring RWAs cannot cross fiscal years.
No. This violates PBS policies and appropriations law including 41 U.S.C. § 3902.
RWAs in Leased Space
If lump sums are known, then PBS should ask for the RWA after the first round of offers.
An RWA for a tenant improvement (TI) scope of work that exceeds the agency’s Tenant Improvement Allowance (TIA) or customization tier must be received and accepted by GSA no later than the date of the lease award, and must cite currently available funds.
If a lease was awarded in a previous fiscal year but an agency did not submit an RWA for above-standard TI costs, they may fund the scope of work with funds that were available in the fiscal year that the lease was awarded. These funds could potentially come from savings on other projects in that fiscal year. In the event that an agency does not have available funds from the appropriate fiscal year, options include: 1.Working with GSA to descope the requirements to make the space acceptable within the Tenant Improvement Allowance (TIA). 2.Amortizing the cost of above-standard TI work into monthly rent payments (this requires leadership approval).
If an RWA WAS NOT accepted prior to lease award, the agency has the same options listed in the previous question. If an RWA WAS accepted prior to lease award, and the scope of work did not change, and the requirements included in the lease (the bona fide need) also did not change, but the cost to deliver the same scope increases, these antecedent liabilities should be covered by funds that were available when the original RWA was provided. If such funds are not available, current year funds may be provided along with a Statement of Further Written Assurance confirming the original funding source is no longer available.
The full funding requirement, which states that agencies must submit an RWA and fund it with current year funds prior to the date of lease award, is not a change in policy, it is a clarification that puts us in compliance with fiscal law, specifically 31 U.S.C. § 1502(a), which requires customer agencies to provide funds from the fiscal year in which the bona fide need arises. For more information on this topic, see GAO decision 71 Comp. Gen. 428.
No, provided the estimated project completion date of the RWA is within the performance period of the lease (e.g., in this case within 2 years), though business case justifications will likely be required.
The scope must be as detailed as possible at the time of acceptance. The amount must be based on a bona fide need, scope of work, and cost estimate.
After initial cost estimates, but prior to issuance of a Request for Proposal (RFP).
No, customers can only buy down the customized portion of its TIs.
Yes, but only in second generation space.
The customer may elect to give PBS a lump sum payment RWA for all, or part, of its customized portion of the TI allowance. If the customer does not exercise this option, the customized portion of the TI gets amortized into the rent payments and may not be changed
PBS should accrue the services which will generate a bill to the customer agency. Once the lessor bills for the services, PBS will create a receipt to match the accrual.
If the travel is above and beyond the typical travel needed for a lease construction project, then yes, remote travel (typically in excess of 50 miles) or frequent travel in excess of the routine project milestone schedule can be charged to the RWA. This must be discussed and anticipated before the RWA is accepted and included in the SCE as a direct cost to be reimbursed by the customer.
The Reimbursable Services Program allows both N and F Types to be used for nonrecurring OU services, though the preference is to use an N Type because the F Type has many financial limitations and are harder to “track” overtime utility usage and needs.
N or F Types because PBS cannot use recurring RWAs (R Types) for leased space if the lessor provides specific invoices/bills for the above standard services.
Generally, yes. PBS uses an R Type for estimated overtime utility services and an N Type for separately metered and/or billed overtime utility services. Most leased space has separate metering or billing and Federally owned space does not.
Overtime utilities are severable because a benefit is received each time the overtime utilities are used.
Estimated overtime utilities are recurring, whereas overtime utilities that are separately billed to PBS or separately metered are nonrecurring (the costs can be specifically identified).
It depends on the type of funding the customer provides. Annual funds would not be acceptable in this scenario. Multiple year funds may be used as long as the service's period of performance falls within the period of obligational authority of the funds, e.g. FY16-18 funds could be accepted in FY18 for FY17 overtime utility services. Also any no year funds could be used, since they are available for any past, present, or future need.
A CR should not prevent a customer from paying for its utilities. If a customer is unable to pay for its overtime utilities, then PBS should assist it in reducing its required services to a sustainable level. Even when customer agencies are operating under a CR, they are allowed to operate at the previous year spending levels. As such, customer agencies have the funding to pay for overtime utilities and should provide PBS an RWA for each CR period until the CR ends. Once the customer receives their full annual appropriation, an RWA for the remainder of the year must be provided to PBS.
General Questions on RWA Types
YES! It is imperative that PBS assign the correct RWA Type to an RWA. This matters for data reporting, audits, financial reporting, customer billing, and accurate application of policies and appropriations laws.
PBS, specifically the RETA Data Entry User, based on whether or not the work requested is for a recurring or nonrecurring need, and whether or not the work requested is a severable or nonseverable service.
It is up to PBS to determine the Type; however, PBS should have conversations with the customer to ensure PBS is providing the correct service to meet the customer’s needs.
RWA Types are decided by the project, not by amount (e.g. a space project is an A Type or an N Type unless it is associated with a prospectus project which makes it a B Type.) There is a $250,000 limitation for F Types, and though an important consideration for the F Type RWA, the dollar amount of the RWA should not be the leading consideration for selecting the RWA Type.
An A Type RWA.
Preventative maintenance for GSA-owned building equipment is an estimated amount for overtime utilities, therefore it should be part of the overtime estimate and included on the R Type RWA for recurring services.
Preventative maintenance for Customer-owned building equipment is based on the actual number of hours spent providing preventative maintenance services on the equipment, therefore it should be provided on an N Type RWA and will be billed based on actual costs incurred.