(Non) recurring and (Non) severable
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.
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’s FAQ site here.
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.
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.
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.
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.
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).
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.