U.S. General Services Administration
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RWA policy
Click any of the sub-categories listed below to jump to that particular section of the page. You may also use CTRL+F to search for a particular question.
- Appropriations law
- Bona fide need
- RWA policy
- RWA amendments and antecedent liabilities
- Personal property
- 90 day “reasonable time” restrictions
- 5 year liquidation period
- Remaining funds at closeout
- Economy act
- RWAs in leased space
Appropriations law
Under what authorities does PBS perform reimbursable work for other Federal agencies?
Generally, GSA performs reimbursable work for other Federal agencies using the authority 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 on a reimbursable basis is 40 U.S.C. § 581(g). GSA may also use the authority provided by 40 U.S.C. § 583 to acquire land and construct buildings on behalf of other agencies, including those maintained by other agencies outside of GSA’s jurisdiction, custody, and control.
When does PBS use the authority provided by 40 U.S.C. § 592(b)(2) versus the Economy Act?
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.
When should a customer agency obligate its funds?
The customer agency should obligate its funds when PBS signs and accepts the RWA in accordance with the Recording Act, 31 U.S.C. § 1501. This is communicated through an Acceptance Letter and signed RWA from PBS.
When do the customer agency’s funds transfer from the customer to PBS?
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.
What is the difference between a customer’s obligation of its funds and PBS’s obligation of those funds?
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 obligation of those funds occur as PBS executes contracts to deliver the scope of work identified on the RWA.
Can PBS start an RWA project without having customer agency funding?
No. PBS may not begin RWA projects prior to receiving the full amount of funding needed from the customer agency. Only planning, requirements development, and cost estimating services can be performed by PBS before an RWA is accepted. Customers should submit an RWA Work Request (WR) in eRETA as soon as they identify a need for a project or service so that GSA may sufficiently plan for future staffing and support needs.
What are the different Appropriation Fund Types?
1) Annual appropriation: An appropriation that is available for obligation only during a specific fiscal year. It remains available to liquidate, via expenditures properly chargeable to that funding, for five fiscal years until the end of that fiscal year after the period of availability expires.
2) Multiple year appropriation: An appropriation that is available for obligation for a definite period of time, as determined by Congress, in excess of one fiscal year, and remains available to liquidate expenditures properly chargeable to that funding for five fiscal years until the end of that fiscal year after the period of availability expires.
3) 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.”
Can a customer agency provide an RWA to cover Rent?
No, customer agencies receive direct appropriations for Rent. As a result, providing an RWA to pay for Rent could increase the customer agency’s appropriation. Thus, PBS cannot facilitate the use of an RWA as a funding source for Rent.
Bona fide need
What is bona fide need and how does it apply to customers?
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.
Can PBS accept an RWA in September for work that will not start until October? How does the Bona Fide Needs rule work in this instance? Does this violate the Bona Fide Needs rule?
Yes, PBS can accept an RWA for a project 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). It does not violate the bona fide needs rule.
RWA policy
What is incremental funding?
Incremental funding is defined as funding the scope of work for a project, over a period of time. RWA requests for non-severable services must be accompanied by funding sufficient to accomplish the entirety of the requested work, even if the work is to occur over multiple fiscal years. Non-severable services may not be partially or incrementally funded regardless of fund type, including no-year funding.
Is incremental funding permitted?
No. Fiscal Law and GSA policy prohibit incremental funding, regardless of fund type.
What does “full funding” mean?
The entire funding to support the estimate for the scope of work provides for a discrete and fully functional project deliverable (that is, a complete phase or stage of the project).
Is it okay to receive an RWA with multiple lines of accounting listed and one billing address?
Yes, RETA has the functionality to accept an RWA citing multiple lines of accounting.
Does PBS need an RWA to begin the design work?
An RWA is not needed to begin requirements development, but PBS policy requires that an RWA is accepted prior to any contracting for design work. PBS cannot begin in-depth design work before accepting an RWA and then bill for those services at a later date.
How does PBS accept an RWA for requirements prior to design for owned space?
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 range of accuracy of the SCE will improve.
What does PBS do when a customer changes its mind after the RWA is accepted and PBS has already incurred charges?
PBS must ensure that no additional obligations are placed against the RWA. PBS will then close out the RWA (rather than canceling it) and bill the client agency for any costs incurred.
How do regions receive Work Requests (WRs) and RWAs?
Regions receive WRs/RWAs in RETA since all Federal customers are required to use eRETA to send all WR/RWA information to GSA. WR/RWA information from non-Federal customers is received through the regional RWA Manager as non-Federal customers cannot use eRETA.
Can PBS accept an RWA funded with time limited funds (annual or multiple year) that expired prior to PBS’s acceptance of the RWA?
No, accepting an RWA funded with expired funds that was submitted by a customer agency but never officially accepted by PBS violates the Recording Act (31 U.S.C. § 1501). The Recording Act (31 U.S.C. § 1501) states that an amount shall be recorded as an obligation only when supported by written evidence of a binding agreement between two agencies that was executed before the end of the period of availability for obligation of the appropriation or fund used for specific goods to be delivered, real property to be bought or leased, or work or service to be provided. Since PBS did not sign and accept the RWA during the period of availability of the funds, there is no binding agreement or basis for the customer agency to obligate the funds. If the customer agency continues to desire the project, the customer agency should submit an RWA using funds that are currently available for new obligations. However, under rare circumstances, expired funding should and can be used. Should you have any questions regarding those circumstances, please contact your respective Regional RWA Manager.
Can PBS accept phased RWAs? For example, can a customer provide an RWA for the design and then submit a new RWA for the construction?
Yes, PBS can accept phased RWAs, but each phase must include a discrete and fully functional project deliverable and be fully funded at the time the RWA is accepted.
Are RWAs Interagency Agreements (IAA), or are RWAs and IAAs different types of agreements?
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, it should be uploaded into eRETA as a supplement to, but never in lieu of, the RWA Form 2957. In any event, PBS always requires an RWA 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), the Economy Act, or 40 U.S.C. § 583.
RWA amendments and antecedent liabilities
When are amendments appropriate and when is a new RWA required?
An RWA should be amended for cost increases that are attributable to within scope changes for antecedent liabilities or a reduction in scope or requirements. Amendments for new scope are only accepted in the same fiscal year the original RWA was accepted. If adding new scope in a different fiscal year, a new RWA is required.
How should a customer agency notify PBS of scope or amount changes?
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 an amended or a new RWA in eRETA, 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.
Can a customer agency change the amount of an RWA without signing the RWA again?
No, eRETA will force the customer to send an amendment to GSA which will be routed to both the Customer Funds Certifying Official and GSA Approving Official for signature.
Can customer agencies add new scope to an RWA funded with no-year funds throughout the lifecycle of the RWA?
RWAs funded with no-year funds may only be amended to add new scope during the same fiscal year in which the RWA was accepted by PBS.
Is the original customer funding still cited in RETA/eRETA when PBS accepts an amendment?
Yes, all agency accounting detail lines are available on the “Accounting Details” tab in RETA/eRETA. The Accounting Details tab can handle multiple customer detail lines that vary by Fund Year, Fund Type, Expiration Date of Obligational Authority, Treasury Symbol, or Agency Accounting Data. However GSA’s financial management system Pegasys can only handle one accounting line at a time. As such the detail line most recently updated in RETA/eRETA (highlighted green in RETA) is the line that will be sent to Pegasys and printed on the RWA bills. Customers may change the “Line to Bill” by submitting an administrative amendment, changing the accounting line, and submitting to Pegasys (see amendment user guide at www.gsa.gov/ereta for more details).
Personal property
Can PBS accept RWAs that only include personal property (i.e. furniture)?
Yes, but if the RWA is not incidental to the project as outlined in policy, then the Stand Alone Option for Furniture Acquisition (SOFA) program must be followed. For more information on SOFA please visit the Total Workplace page.
Is cabling in walls personal property?
No. It is attached to the structure so it is not considered personal property.
90 day “reasonable time” restrictions
Why do funds have to be obligated within 90 days of RWA acceptance?.
The RWA NPM requires that PBS obligate customer agency funds within a reasonable time. Following acquisition lead times, PBS considers a reasonable time to be 90 days unless otherwise noted by an attached schedule.
Do F Type RWAs require a schedule?
No, since F Type RWAs are used to cover miscellaneous services within a fiscal year, no schedule is required.
5 year liquidation period
What does the timing of availability of an appropriation mean and how is it different from the 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, 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” section of the RWA National Policy Manual.
Is the customer agency’s obligational authority year included in the 5 year liquidation period?
No. The 5 year liquidation period clock does not start until the customer’s obligational authority expires. (See 31 U.S.C. §§ 1552 - 1553).
Where does the customer’s money go if it is not liquidated before end of the liquidation period?
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.
Does the 5 year liquidation rule apply to no-year money?
The five year liquidation rule from 31 U.S.C. § 1552 does not apply to no-year funds as they have no expiration.
Remaining funds at closeout
Can customer agencies use remaining funds for other RWA projects?
No. 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 deobligate the funds on its books and determine any further availability or potential use of any remaining funds.
Can PBS move customer agency funds between RWA projects?
No. If funds are remaining on an RWA, then the RWA must be closed and notice should be given to the customer identifying the remaining balance that should be deobligated.
Should PBS return funds (remaining balance) to customers when the RWA project is complete?
No. At financial closeout, PBS should notify the customer to deobligate any remaining funds and let the customer agency determine what to do with the funds.
What happens if an RWA project is no longer needed?
RWAs without any financial activity may be canceled, but RWAs with any financial activity will follow the substantial completion process. PBS will collect any remaining expenses incurred prior to early completion and then allow the customer to deobligate the remainder.
Economy act
How does PBS perform work under the Economy Act?
When PBS performs RWA projects under the Economy Act, it must obligate the customer’s funds within the period of availability for new obligations applicable to those funds. Customer time-limited funds that are not obligated by PBS within the period of availability of those funds (with the exception of funds set aside for GSA fees) must be deobligated by the customer upon expiration.
RWAs in leased space
When is the latest time an RWA for a project in excess of a customer Agency’s Tenant Improvement Allowance (TIA) (or customization tier) in new or continuing occupancies in leased space, is required?
The RWA for the excess TI must cite currently available funds and be received and accepted by PBS no later than the date of the lease award.
Is there a rule against accepting RWAs if the lease expiration is within 2 years?
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).
How far in advance can a customer give money for leased projects?
As early as the project is identified (which usually occurs with the signed SF81), scoped and estimated, but no later than prior to lease award.
What happens if the lease process crosses fiscal years and the customer needs to amend the RWA for work within the scope of the RWA? Must the customer agency use original fiscal year funds?
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 accepted, 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 funding that is currently available.