LA-24-04

Updated Compliance Checklist for Federal Agencies Seeking Lease Delegations

Digitally signed by Crofton Whitfield. Effective 11/12/2024.

Crofton Whitfield
Assistant Commissioner
GSA PBS Office of Leasing

Purpose

This Leasing Alert issues updated instructions and procedures and an updated organizational compliance checklist (compliance checklist) for federal agencies seeking lease delegations. Note this Leasing Alert replaces Leasing Alert LA-19-12 entitled “Compliance Checklist for Federal Agencies Seeking Lease Delegations.”

Background

On December 16, 2019, the Office of Leasing issued Leasing Alert LA-19-12, entitled “Compliance Checklist for Federal Agencies Seeking Lease Delegations.”
1. This was issued in response to GAO Report Number 19-405, “Federal Real Property: GSA Needs to Strengthen Oversight of Its Delegated Leasing Program.”
2. This established a requirement for the completion of a certification of compliance checklist by federal agencies seeking to utilize a delegation of GSA lease acquisition authority for real property leasing activities.
3. In order to be eligible for a delegation of leasing authority, agencies must annually represent and self-certify to GSA their organizational capacity utilizing the compliance checklist.
The compliance checklist was updated and the Office of Leasing is issuing this new Leasing Alert with the updated attachments.

Effective date

This Leasing Alert and attachments are effective immediately.

Cancellation

Leasing Alert LA-19-12, “Compliance Checklist for Federal Agencies Seeking Lease Delegations” is canceled.

Applicability

This Leasing Alert and its attachments are mandatory and apply to all federal agencies seeking to utilize a delegation of GSA lease acquisition authority for real property leasing activities. It does not apply to GSA lease acquisitions.

Instructions and procedures

See Attachment 1 of this Leasing Alert for instructions and procedures.

Attachments

Attachment 1: Instructions and Procedures

Certification of Organizational Compliance

In order to be eligible for a delegation of lease acquisition authority, federal agencies must represent and self-certify annually to GSA using the certification of organizational compliance checklist (compliance checklist) as outlined in Attachment 2 of this Leasing Alert. This compliance checklist represents to GSA the federal agency’s capabilities regarding program oversight and Federal Management Regulations (FMR) compliance. Delegated federal agencies must represent both the qualifications of their contracting workforce and the adequacy of the organization’s support structure, policies and procedures necessary to manage a lease portfolio. Delegated agencies can access the fillable PDF compliance checklist through the G-REX templates library.

Due Date

A completed compliance checklist must be provided to GSA’s PBS Office of Leasing, Center for Lease Delegations and Contract Administration annually no later than November 30th. Note that, in the event the checklist is not timely submitted, GSA will notify that agency’s Senior Real Property Officer (SRPO) or equivalent; depending upon the circumstance, further delegations of authority may be suspended until the compliance checklist is transmitted to GSA. For a federal agency seeking a delegation of lease acquisition authority for the first time, the compliance checklist must be completed and submitted to GSA prior to GSA granting the delegation authority. Completed compliance checklists shall be submitted to the following GSA email inbox by November 30th of each year to: delegate@gsa.gov.