Costs

The CAAS rate is assessed for the cost associated with administering procurement services, used in completing the reimbursable activity, that are subject to audit requirements and exceed $1 million. CAAS charges are applicable to the pass-through procurement actions meeting these criteria. The Agency Office of Procurement sets and manages the standard CAAS rate for these services. The CAAS rate in effect at the time the agreement is signed will be used to determine the applicable CAAS cost and will be identified as a separate indirect cost line item on the EPR/ECR. 

• The CAAS rate is not considered a pricing adjustment nor a waived cost. 

• Will automatically calculate on the EPR.

The pass-through rate represents an administrative charge to cover the cost associated with agreements that typically identify existing contract(s) through which work will be completed and for which NASA does not directly provide the product, service, or use of facilities.  

The Center CFO is responsible for approving the pass-through rate calculated annually. The pass-through rate should be consistent throughout the year unless there is a substantial change to the cost components requiring the rate to be recalculated. The pass-through rate is not considered a pricing adjustment nor a waived cost. 

Requirements:

• Work must be incidental to and utilize an existing contract vehicle.

• Work is covered within existing scope of the contract.

• Work does not require significant technical oversight or direction by NASA.

• Work does not involve the use of NASA facilities (i.e. cannot be onsite) or resources.

NPR 9090.1C section 3.2.2.2

b. General criteria for determining whether an agreement may be considered for use of the pass-through rate includes:

(1) Work may be performed using an existing contract or a contract action (e.g., task order) that does not require special terms or a modification to the scope. An example is a contract action where the reimbursable partner has developed the technical content and NASA is executing the contract action.

(2) Work may be performed with minimal technical oversight or direction by NASA. Accordingly, a contract would not include a Statement of Work tailored for this agreement to meet the requirements of the partner. Limited and insignificant participation by NASA is allowable to provide for normal contract management, monitoring of contract performance, and financial management responsibilities.

(3) Work may be performed without the use of NASA facilities or other resources. Limited and insignificant participation by NASA is allowable to provide for normal contract management, monitoring of contract performance, and financial management responsibilities.

The standard AAI rate is representative of the Agency and Center’s indirect cost associated with an agreement based on the SSMS20 budget. Annually, the Agency OCFO Budget Division will calculate and distribute the AAI rate to the Center OCFOs. The AAI rate should be used by Center OCFOs.

• FY25 Rate is 13.9%

• Covers Center support costs such as security, grounds, utilities, AAI functions.

• Only considered where there is a clear and demonstrated NASA benefit  

  • • • Benefit should be quantifiable to the extent that the value can be reasonably estimated

      • Supporting rationale should demonstrate how NASA benefit is achieved

      • Rationale and amount must be clearly recorded on the EPR 

      • Outreach/goodwill is not a valid rationale

• EPR is priced at full cost and an adjustment is entered as a negative amount and shown as waived cost

  • • • All adjustments require concurrence of the responsible Program Manager absorbing the waived costs 

      • Direct funding source must be identified

• Waivers of direct cost require Center CFO and Agency CFO approval.

• Waivers of indirect cost (AAI) require Center CFO and AAI Manager approval.

• All waivers require the agreement to be abstracted to HQ.

• HQ OCFO will also request the HQ Mission Directorates approval.

• Contractor is operating a Facility for NASA (e.g., NBL, Labs, RITF, etc.)

• Authorized under Clause H of their contract.

• Performed on excess capacity basis.

• Requires a Space Act Agreement between NASA and our Contractor (e.g., Raytheon for the NBL).

• Requires strict adherence to the process to ensure:

  • Requested 3rd party is reviewed and approved by NASA.

  • NASA estimates and documents the price for the work for the partner based on the methodology.

  • Funding for the work must be in place prior to approval of the work – Verified for each set of work approved.

  • Funds should be obligated on the contract to offset NASA’s operating costs for the facility.

• Requires a pricing methodology approved by the JSC CFO Policy Office and Chief Accountant.

• CS Labor should be minimal oversight or tangential (slightly connected) and no Contract Labor.

• This is a charge between the contractor and the partner.

• Should not flow through to NASA on the NF533.

• Procurement costs should be based on our costs paid to the contractor to operate the facility.

  • NF533 should be used as the basis for determining costs applicable to operating the facility.

  • Equipment maintenance and operational costs associated with the work or operation of the facility should be captured.

  • Consumable materials paid for by the contractor can be included in the price if ordered through a NASA contract.