Interagency Reimbursable Work Agreements (IRWA)

[Pages:48]Interagency Reimbursable Work Agreements (IRWA)

Andrew Jepson

Deputy, Reimbursable Agreements Division CG-835

Andrew.M.Jepson@uscg.mil / #202-372-1323

Sarah Habbert (SME policy panelist)

Management & Program Analyst Financial Policy & Analysis Division Sarah.A.Habbert@uscg.mil / #202-372-1347

Homeland Security

Assistant Commandant for Resources

References & Change

? Regulations

? Subpart & Reference FAR 17.5 (c) ? AUG 2012

? HSAM 3017.5 ? DHS Interagency Acquisitions Guide (Assisted/Direct only)

? DHS CFO FMPM Section 3.7 Intragovernmentals, May 2018

? 31 U.S.C. 1535 Economy Act ? 14 U.S.C. 151 CG Project Order authority ? 10 U.S.C. 2410a Crossing Fiscal Years ? Government-Wide Agreement Forms Standardization ? FS 7600 A (GT&C)

Treasury

Link:

. g-

invoice/resources. html#admin

? FS 7600 B (Order)

? IRWA Communications Center ? Ask an Expert ? Coming Soon!

? Fiscal Treasury G-Invoicing ? What is G-INV? ? It is the government's long-term sustainable solution for Buy/Sell

transactions and will manage the receipt and acceptance of Agreements, Orders,

and Performance through to Settlement. ? Training ? To assist in using G-INV, the Fiscal Service offers a variety of

downloadable resources, including rules, standards, guides, and presentations.

For cooperative training, see ? USCG Participation ? CG-835 currently assessing Agency implementation and will

reach out to applicable financial communities in the near future on status

Homeland Security

Assistant Commandant for Resources

Learning Objectives & Concepts

? IAA ? Inter/Intra-Agency Agreement ? IA ? Interagency Acquisition (assisted) ? IRWA ? Inter/Intra-Agency Reimbursable Work

Agreement (non-assisted) ? Inter/Intra-Agency Reimbursable Transaction

Determination Questionnaire (D&F) ? Agreement Formats & Required Provisions ? Basic Authorities and Appropriation Law Principles ? Trading Partner Negotiation & Forms Preparation ? Monitoring Agreement Performance & Acceptance

Homeland Security

Assistant Commandant for Resources

Principles of COMITY

Agreements within or between agencies are governed by "principles of comity"

a. Courtesy and considerate behavior toward others; and

b. An association of nations for their mutual benefit; recognition of the laws and customs of others.

Homeland Security

Assistant Commandant for Resources

Requirements &

Determination

Let's Get Started!

Trading Partner Negotiations & Forms Preparation

Execution, Monitoring Agreement Performance, & Reconciliation

Closeout,

Audit &

Measurement

Developmental Stage

Homeland Security

Operations Stage

Close-out & Analysis Stage

Assistant Commandant for Resources

IRWA Full Lifecycle Management

? All services received,

UDOs, liquidated/expended,

? ? ?

Unobligated $ returned Closeout reports, IPACs TP comms Assess Recurring

? ?

requirements Validate UDO's Document Support

Matrix

Closeout, Audit &

Measure

Requirements &

Determination

? ?

Define requirements Transaction

Questionnaire ?

Trading Partner

(TP) input,

?

documentation Record

?

Commitment Legal advice

as

necessary

? ?

Record Obligation Performance

? Receipt of supplies

?

and or services Payment

?

Management Reconciliation

?

(PES, IRWA,TPIN) TP comms

Execution, Monitoring

& Reconciliation

Trading

Partner Negotiations

& Forms Preparation

? FS 7600A/B or

agreed upon format

? Required provisions ? TPs Program

review

? TPs legal review ?

>$500K

? Bi-lateral signature

? offer/acceptance

Homeland Security

Assistant Commandant for Resources

"Incidental Contracting"

Requirements &

Determination

Definition of incidental contracting:

a. Definition (1) - Contracts entered into by the servicing agency for supplies or services for its own use that may also indirectly benefit performance of a reimbursable agreement on behalf of a requesting agency, e.g., IRWA. However, the requesting agency is not directly receiving the contracted services or supplies.

b. Definition (2) - Instances in which the servicing agency awards a contract action(s), or otherwise uses services or supplies acquired by contract(s), in support of its performance of an Interagency Agreement (IAA) on behalf of a requesting agency (e.g., IRWA). However, the servicing agency is not providing acquisition services that would result in a contract action that provides contractor performance specifically for the requesting agency.

Homeland Security

Assistant Commandant for Resources

INTER/INTRA-GOVERNMENTAL TRANSACTION QUESTIONNAIRE, FINDINGS, AND DETERMINATION PURPOSE

Requirements &

Determination

How the Servicing Agency will perform for the Ordering Agency will determine how the transaction is treated. Additionally, should the Servicing Agency require third party contracting in accepting and supporting the order, how the Ordering agency receives performance or participates in acquisition activities will also determine whether it is incidental contracting or an assisted acquisition.

Determination, when third party contracting is being utilized by the servicing agency, places emphasis on contractor performance. Specifically, who the contractor is directly performing for and any related acquisition assistance activities being conducted by the Coast Guard as the Ordering Agency, is key in determining whether the third party contracting is incidental or primary to the purpose of the Order placed by the Coast Guard. Acquisitions assistance activities are those functions where a CG Ordering Program or Contracting Office would be directly involved with the Servicing Agency Contracting Office in the administering of the third party contract. These may include, but are not limited to, designation as Contracting Officer Representative (COR), responsible for performing market research, develop acquisition strategy documents, or preparing statements of work for the Servicing Agency Contracting Officer, responsible for receiving, reviewing, accepting/rejecting deliverables of the Servicing Agency contract, responsible for reviewing, approving/rejecting invoices of the Servicing Agency contract, or responsible for contractor performance evaluation of the Servicing Agency contract.

This form will be used by USCG offices in determining whether the inter/intra agency transaction is an Interagency Acquisition (IA) or Interagency Reimbursable Work (IRWA) (with or without incidental contracting) as defined by FAR 17.500. This form and any supporting documentation which assists in the determination shall be kept on file locally as part of the official record. If determined to be an Interagency Acquisition, please seek guidance from your respective acquisitions/procurement policy for further requirements.

In order to ensure proper determination, the USCG Requesting Office will be required to communicate to and receive responses from, the Servicing Agency. This may include, but is not limited to, technical or program, budget or CFO, and acquisition or procurement points of contacts. This communication is required as supporting documentation to USCG inter/intra agency transaction findings below.

The term incidental contracting and examples are provided at the end of this form. Additionally, a full glossary of terms is available at {new glossary wherever this resides} for assistance.

Homeland Security

Assistant Commandant for Resources

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