NESDIS Interagency Agreement (IAA)

Standard Operating Procedures As of October 2017

Table of Contents

1. Overview………………………………………………………………………… 2

2. Roles and Responsibilities……………………………………………………… 2

3. Required Forms………………………………………………………………… 2

4. Additional Forms (if applicable)……………………………………………….. 3

5. PHASE ONE……………………………………………………………………. 3

6. PHASE TWO…………………………………………………………………… 5

7. PHASE THREE………………………………………………………………… 6

8. PHASE FOUR…………………………………………………………………... 7

9. PHASE FIVE…………………………………………………………………… 7

10. IAA Process Flow Chart……………………………………………………….. 9

11. Frequently Asked Questions (FAQs)………………………………………….. 10

12. Review Guidance DOC/OGC………………………………………………….. 14

13. Appendices……………………………………………………………………… 15

a. Appendix A……………………………………………………………… 15

b. Appendix B……………………………………………………………… 19

c. Appendix C……………………………………………………………… 24

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1. Overview

The Interagency Agreement (IAA) approval & distribution process begins when an appropriation

bill is enacted by Congress, and apportioned by the Office of Management and Budget (OMB).

Following this, appropriation levels are verified by NOAA Finance and funds are allotted to the

appropriate NOAA/NESDIS Program Office. The NESDIS Program Office creates the draft

IAA package using Forms 7600 A&B. The package must then go through the NESDIS Office of

the Chief Financial Officer (OCFO) and the Department of Commerce (DOC) Office of General

Counsel (OGC) for approval. Once this occurs, the signed IAA package is sent to NOAA

Finance to review and complete the transfer or obligation of funds.

The estimated timeframe for processing IAAs under normal circumstances is 30 – 60 business

days. If an IAA package requires an expedited turnaround time, it is the program office’s

responsibility to communicate this to NESDIS/OCFO Liaison in advance along with a

justification for the reason it needs to be expedited.

2. Roles and Responsibilities

NESDIS Program Office: prepares the IAA package (by completing the required and

additional forms listed below) and submits the package to the NESDIS/ OCFO Liaison.

NESDIS/OCFO Liaison: serves as the main Point of Contact (POC) for the routing

and tracking of the IAA package through the NESDIS/OCFO and DOC/OGC offices.

Also performs a high level review of the IAA documents.

Contracting Officer (CO): reviews, clears, and signs the Determination & Findings

(D&F) or Best Interest Determination (BID) document for IAAs that result in

acquisitions.

General Law Attorney (GL): reviews the IAA package and sends follow up questions

to the NESDIS/OCFO Liaison.

Contract Law Attorney (CL): reviews the IAA package related to assisted

acquisitions.

NOAA Finance: reviews the signed IAA documents; assigns a Purchase Order (PO)

number that is used to track the agreement in the Management Analysis and Reporting

System (MARS) & the Commerce Business System (CBS). Then they complete the

transfer or obligation of funds.

3. Required Forms

Form 7600 Part A – General Terms & Conditions (GT&C): Appendix A

Form 7600 Part B – Order & Funding Requirements: Appendix B

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4. Additional Forms (if applicable)

IAA Checklist: Appendix C

Statement of Work (SOW) - required if the IAA will result in an acquisition

Independent Government Cost Estimates (IGCE)

Previous OGC Cleared Package

Determination & Findings (D&F) or Best Interest Determination (BID)

5. PHASE ONE

NESDIS Program Office Budget Analyst creates IAA Package: 1-5 Business Days

STEP 1: The NESDIS Program Office prepares the IAA package by completing the

following steps using the IAA SharePoint Tool:

1A. Completes the Part A (7600A) General Terms & Conditions (GT&C)

form, and creates a unique IAA number.

1B. Completes the Part B (7600B) Order & Funding Requirements

(Order) form, and ensures that the period of performance on the 7600B aligns

within the agreement period on the 7600A.

1C. Completes the IAA Checklist, and provides a clear and concise

description of the purpose of the IAA. (Only when the agreement is not entered

into the IAA SharePoint Tool)

1D. Submits a Statement of Work (required for IAAs that result in an

acquisition), unless significant detail is already included in the 7600B, box 28.

1E. Completes an Independent Government Cost Estimates (IGCE) and

Determination & Findings (D&F) or Best Interest Determination (BID) if

applicable and submits the package to AGO for their initial review. AGO will not

complete their review and signature until they have OGC CLD review and

concurrence.

The program office shall do the following:

A. Prepare a memorandum addressed to “NOAA Contracting

Officer” from the program manager providing the information

required to support the attached Determination and

Finding (D&F) by responding to the following:

i. Explain the need for the supplies or services,

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ii. Describe why it is in the best interest of NOAA to

partner with this federal agency (i.e., identify the

essential capabilities or expertise the federal agency

receiving the funds possesses that NOAA does not

possess),

iii. Explain why the supplies or services cannot be obtained

as conveniently or economically by contracting directly

with a private source. A business case must be made

that this action is in the best interest of NOAA, and

iv. If the Economy Act Order requires contract action by

the federal agency receiving the funds from NOAA,

include a statement explaining why at least one of the

following circumstances applies:

1. The acquisition will be made under an existing

contract of the federal agency, entered into

before placement of the order. Provide contract

number and vendor,

2. The federal agency has the capabilities or

expertise to enter into a contract for such

supplies or services that are not available within

NOAA, or

3. The federal agency is specifically authorized by

law or regulation to purchase such supplies or

services on behalf of other federal agencies.

B. Provide a signed statement that the funds are currently

available for the supplies or services, which will include the

accounting code information.

C. Attach a copy of the following documents to the D&F before

submission:

i. D&F supporting documentation (memorandum to

contracting officer),

ii. Interagency Agreement, and

iii. OGC CLD review and concurrence.

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NOTE: If the IAA is related to Information Technology (IT) support, the package

should first be routed to the NESDIS ACIO for review and signature.

STEP 2: The NESDIS Program Office submits the IAA package either via the IAA

SharePoint Tool or to the NESDIS/OCFO via the NESDIS Agreements email

inbox nesdis.agreements@noaa.gov

NOTE: If at any point after the NESDIS Program Office has submitted the IAA

package to the NESDIS/OCFO and there are changes to the IAA package it is

the responsibility of the NESDIS Program Office to inform the NESDIS OCFO

Liaison immediately and send any corrected updates.

6. PHASE TWO

NESDIS/NOAA Internal Review: 1-2 Business Days

STEP 3: The NESDIS OCFO Office Designated Liaison receives the drafted IAA

package via the IAA SharePoint Tool or the NESDIS agreements email inbox

nesdis.agreements@noaa.gov

3A The NESDIS OCFO Liaison reviews the package to ensure that all the

required documents are included, the contents of the agreement are accurate, and

adequate funds are available.

3B The NESDIS OCFO Liaison will work with the Program Office Budget

Analyst to address any issues.

STEP 4: After reviewing the package, the IAA is assigned a NOAA Folder Number (ex.

17-101523) using Data by Design (DBD).

STEP 5: The NESDIS OCFO Liaison routes the IAA package to the NESDIS Budget

Integration Branch Chief or the Deputy Chief Financial Officer for the

OFCO approval.

STEP 6: Once the IAA package is approved by NESDIS DCFO leadership, it is routed to

the DOC/OGC Office via email GeneralLaw@doc.gov.

STEP 7: A DOC/OGC Administrative Law Assistant assigns the IAA package to an

Attorney.

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7. PHASE THREE

DOC OGC Review: 20-30 Business Days

STEP 8: The General Law Attorney reviews the IAA documents:

9A. After OGC receives the IAA for review, it is then assigned to an Attorney

from the General Law (GL) division.

9B. The assigned GL Attorney begins their review by sending an email to the

NESDIS/OCFO Liaison confirming receipt and including any initial

questions/revisions.

9C. The NESDIS/OCFO Liaison will review questions from the attorneys

and if unable to address the issues will then forward the emails as quickly as

possible to the NESDIS Program Offices point of contact for resolutions.

9D. The GL Attorney coordinates the concurrent review of IAAs with the

Contract Law (CL) Attorney for IAAs related to assisted acquisitions.

STEP 9: The Contract Law Attorney reviews the IAA documents related to assisted

acquisitions. Assisted acquisitions do not require CL clearance prior to GL

review.

STEP 10: DOC/OGC leadership performs the final review and clearance:

11A. The NESDIS/OCFO Liaison will coordinate the certification of funding

for the agreement (if applicable) to the GL Attorney.

11B. After the GL & CL (if necessary) Attorneys have completed their review,

a clearance memo is prepared and submitted it to DOC/OGC leadership for final

review of the IAA package.

11C. If there are no further questions or issues, DOC/OGC leadership will sign

the memo.

NOTE: The NESDIS/OCFO Liaison serves as the main point of contact (POC)

on all emails between OGC and the Program Office throughout the OGC review

process. This allows the Liaison to assist in streamlining the review process

where necessary. NESDIS Program Offices should not inquire with OGC

directly without the Liaison’s knowledge. Likewise, the OGC should not

communicate directly with the Program Offices without the involvement of the

NESDIS/OCFO Liaison.

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8. PHASE FOUR

NESDIS/NOAA Program Office Execution: 15-20 Business Days

STEP 11: Program Office Receives Cleared IAA Memo via email:

12A. Once the clearance memo is received from OGC, the NESDIS/OCFO

Liaison sends the signed clearance memo to the respective NESDIS Program

Office contact.

12B. The agreement included with the clearance memo is the final version and

should be signed and executed.

12C. Program Offices should thoroughly review the clearance memo, which

includes instructions on how to manage the agreement going forward.

12D. If any changes to the agreement need to be made after the final OGC

clearance has been completed, the NESDIS Program Office contacts the

NESDIS/OCFO Liaison to address the change.

STEP 12: Obtain NOAA AGO Clearance of Determination & Findings or Best Interest

Determination (if applicable):

13A. If the IAA involved an acquisition, a D&F or BID should have already

been submitted to NOAA/AGO prior to submitting the IAA to DOC/OGC. (See

step 1E).

13B. If that review by AGO is still not complete, the NESDIS Program Office

forwards the DOC/OGC clearance memo to AGO, and addresses any issues and

obtains the final clearance.

STEP 13: NESDIS Program Office coordinates signatures of necessary internal and

external stakeholders:

14A. Once all the necessary signatures are obtained, the Program Office

Budget Analyst forward a copy of the final agreement to the NESDIS agreements

email.

14B. The NESDIS/OCFO Liaison will then save a copy to the archives.

9. PHASE FIVE

NOAA Finance: 1-2 Business Days

STEP 14: NESDIS Program Office coordinates with NOAA Finance and NESDIS CFO

to Facilitate Funds Transfer:

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15A. NOAA Finance receives a notification of the IAA transmittal for

obligation from the NESDIS Program Office

15B. NOAA Finance will assign a Purchase Order (PO) number that is used to

track the agreement within the MARS financial system. The PO number is also

provided to the servicing agency. This allows the servicing agency to identify the

correct order to submit IPACs against.

15C. The final IAA documentation is reviewed by NOAA Finance to complete

the transfer or obligation of funds.

15D. Once reviewed, the NESDIS Program Office receives a notification of

confirmation from NOAA Finance of the obligated or transferred funds along

with an assigned PO number.

15E. Funds are transferred to the servicing agency via the Intra-governmental

Payment and Collection Approval (IPAC) payment process. The NOAA

Finance Office will send a copy of IPACs in excess of $25 thousand

electronically to the NESDIS Program Office upon receipt from Treasury to be

used for verification of payments.

15F. The NOAA Finance Office is required to process IPACs within (5) days

or by month end accounting close, whichever is sooner. Therefore, the NOAA

Finance Office will record the IPACs within the mandated time period and

operate under the premise that the costs are accurate, complete and thoroughly

documented by the NESDIS Program Office unless the IPAC is sent back citing

the reason for the chargeback.

15E. NESDIS Program Office coordinates any additional information to the

Servicing or Requesting Agency as necessary.

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10. IAA Process Flowchart

FY 2017 NESDIS Interagency Agreement Process Flow Chart

NO

AA

/NES

DIS

Pro

gram

O

ffic

e Ex

ecu

tio

n (P

hase

4)

DO

C/O

GC

Rev

iew

(P

ha

se 3

)

NO

AA

/NES

DIS

/OCF

O

Rev

iew

(P

hase

2)

NO

AA

/NES

DIS

Pro

gram

O

ffic

e R

evie

w(P

has

e 1

)

NO

AA

Fin

ance

(Pha

se 5

)

1-5

Bu

sine

ss D

ays

(Var

iabl

e)

1-2

Bu

sine

ss D

ays

(Fix

ed

)20

-30

Bu

sin

ess

D

ays

(Fix

ed)

15-2

0 B

usi

ness

D

ays

(Var

iab

le)

NESDIS/OCFO reviews IAA

Package

Are there any issues ?

IAA Package submitted to NESDIS/DCFO for clearance

IAA package is routed via email

to the DOC/OGC

IAA Package is received by a

DOC/OGC Administrative Law Assistant

NO

NESDIS Program offices address

the issues.

YES

Start

NESDIS Program offices creates

draft of IAA Package

Is the IAA related to IT support?

Submit IAA Package to

NESDIS/OCFO

Submit draft to ACIO for review and approval/

signature

YES

NESDIS/OCFO Liaison sends

cleared package to the Program

office

Does the agreement result in an acquisition?

Program office coordinates

signatures from all parties

Program office coordinates with NOAA Finance to

transfer funds (includes OCFO)

Program office forwards signed IAA Package to NESDIS/OCFO

NO

Submit copy of cleared package

to AGO

YES

IAA Package assigned to a GL

attorney to review

Does the agreement result in an acquisition?

IAA Package is submitted for

final clearance to OGC Leadership

An OGC clearance memo

is emailed to NESDIS/OCFO

NO

IAA Package assigned to a CL

Attorney to review

YES

Does either of the

attorneys have any questions?

NO

NESDSIS/OCFO Liaison works

with the Program office to address

issues

YES

NOAA Finance receives

notification of IAA transmittal for

obligation

Assigns a PO number, used to track agreement

in MARS

Reviews financial documentation to

complete the transfer/

obligation

Sends notification back to the

NESDIS program office

End

1-2

Bu

sine

ss

Day

s (F

ixed

)

Does the agreement result in

an acquisition?

Submit draft D&F or BID to NOAA/AGO

NO

YES

NO

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11. Frequently Asked Questions (FAQs)

Q) Why are you encouraging the use of the Forms 7600 A&B?

A) Financial management and budget standardization involves the uniformity of business processes

and data elements. It enables the government to communicate financial information in a

consistent and reliable manner to support the efficient and effective management of government

programs and the use of taxpayers' money. To be effective, standardization must be applied

government wide. Therefore, cooperation is needed from each government agency in order to

achieve the benefits of standardization. The Bureau of the Fiscal Service (Department of

Treasury) intends to work closely with government agencies to implement financial

standardization on a government wide basis.

Q) What is the timeline/sequence of events between part A & B?

A) An estimated timeframe of 40-70 business days is expected for the end to end process.

* For step-by-step details regarding the sequence of events, see IAA Process Flow Chart

Q) What information will be needed to complete the forms?

A) IAA number: The IAA number is a unique agreement number that must be established between

the requesting agency and servicing agency that will be used to track each IAA from the

beginning through the completion or termination. This number consists of three components:

GT&C number

Order number

Amendment/Modification number

Servicing Agency Agreement Tracking Number: This number is generated and maintained by

the servicing agency and is separate from the IAA number.

Agreement Period: The agreement period identifies the period during which the Requesting

Agency expects all orders to be completed by the Servicing Agency. An IAA becomes effective

when both parties have signed the document.

For the start date, enter the date (Month, Day, Year) when the IAA will begin; this date

must be on OR after the date the IAA is signed by both parties.

For End Date, enter the date (Month, Day, Year) when the IAA will end and all orders

will be completed with delivery of products and/or services and closeout activity.

If cancellation is checked in the GT&C Action block, enter the End Date for the effective

cancellation date.

Performance Period: The Performance Period identifies the dates between which the products

and/or services for the Order will be provided. The Performance Period could include the

Servicing Agency’s activities to prepare for and closeout the delivery of the requested

products/services. The Performance Period will be defined depending on the business needs for

each IAA.

* For a Performance Period modification, insert the Start and End Dates that reflect the new

Performance Period.

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Requesting Agency Funding Cancellation Date: For each line, enter the date (Month, Day,

Year) that the Requesting Agency’s funds will cancel for this Order Line. The cancellation date is

the fifth year from the expiration date (the last date the payment must be disbursed.

For example, if “09-30-2009” is the last year the funds will be available for obligation,

then the Requesting Agency will have a cancellation date of “09-30-2014”. This does not

apply to No-Year Funds.

Project Number & Title: Enter the Requesting Agency’s project number and title.

Q) What Billing and Payment Information is needed?

A) Payment Method: Intra-governmental Payment and Collection (IPAC) is the preferred method.

Billing Frequency: An invoice must be submitted by the Servicing Agency and accepted by the

Requesting Agency before funds are reimbursed (i.e. via the IPAC transaction).

Payment Terms: Payment is expected from the Requesting Agency in 7 days.

Funding Clauses/Instructions (Optional): Include availability of funds or other funding clauses

as deemed necessary. If a “subject to the availability of funds” clause is used, it is important to

note that no services may be performed until the Requesting Agency gives written notice to the

Servicing Agency that funds are available and that the Servicing Agency can proceed.

Delivery/Shipping Information for Products (Optional): Enter the Agency Name, Point of

Contact (POC) Name & Title, Email Address, Deliver Address/Room Number, and POC

Telephone Number of the person who will receive the shipment.

* For step-by-step instructions on how to complete the form, see 7600A-B Instructions

Q) What are the main reasons why IAA packages are rejected?

A) IAA packages often get rejected because of:

Package content errors (e.g. using the wrong IAA number)

Untimely submissions by the Requesting Agency

Lack of the sufficient funds prior to submission

Q) What does OCFO review focus on?

A) OFCO’s review focuses on the completeness and accuracy of the package.

Q) What are OCFO’s expectations for completeness/accuracy when they receive it?

A) Once the NESDIS OCFO liaison receives the IAA Package, it is first reviewed to confirm that all

the required documents are included. The content of the agreement will also be reviewed for

accuracy, clarity and funds availability.

Q) What does NESDIS HQ (Requesting Agency) fill it out vs the other agency (Servicing Agency)?

A) The Requesting Agency (NESDIS HQ) is responsible for filling out the forms initially while the

servicing agency completes the remaining applicable sections.

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Q) Do other offices/bureaus within DOC and NOAA go through similar routing processes as

NESDIS HQ, and do they involve their own internal attorneys?

A) It depends. The bureau or office is responsible for making its own determination on whether or

not to involve internal attorneys first, prior to submission to DOC.

Offices/bureaus that use internal attorneys do so mostly for programmatic related

questions.

Q) What is the typical timeframe for the DOC/OGC review of the IAA package?

A) The DOC/OGC designated attorney is required to make the initial response once the documents

are received from Executive Secretary within 5 business days. The entire review process takes

20-30 business days.

The timeframe also considers the number of documents that the Executive Secretary

receives on a daily basis from all of DOC.

Q) What are the main reasons why the DOC/OGC timeframe has increased to 20-30 business

days?

A) The DOC has combined the GL and CL reviews which in turn has led to the additional processing

time.

The timeframe is also impacted by how quickly the program offices are responding to the

comments/questions/revisions that the DOC requests.

Q) What are the delegation signatures or authorities for IAAs?

A) The Assistant Administrator (AA) for NESDIS HQ retains the authority to approve procurement

requests for all Interagency Personnel Act Agreements. These documents must be routed to the

AA for signature through the NESDIS Chief Financial Officer/Chief Administrative Officer and

the Deputy Assistant Administrator (DAA) for their review/concurrence. If the AA is unavailable,

the responsible DAA may sign the document. If the DAA and DAAS are also unavailable, then

the CFO/CAO or Deputy CFO/CAO can sign the document. The AA delegates the authority to

approve procurement requests and other acquisition documents within the limits stipulated to the

following NESDIS officials:

Director, Joint Polar Satellite Systems (JPSS)

Director, Geostationary Operational Environmental Satellites – R Series (GOES-R)

All other Financial Management Center (FMC) Directors and the NESDIS Assistant

Chief Information Officer (ACIO)

* For more details regarding the delegation of authority, see Delegation of Authority Guidance

Q) What are Severable Charges?

A) Severable services are services that are ongoing or repetitive in nature. These are services that

generally have natural breaking points. A severable service is a recurring service or one that is

measured in terms of hours or level of effort rather than work objectives. Severable services,

which are recurring in nature, are bona fide needs at the time the service is completed, and

obligations for severable services should be charged to appropriations current at that time.

Q) What are Non-Severable Charges?

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A) Non-severable services are services that constitute a single, indivisible undertaking for which the

requesting agency receives no benefit until the entire project is completed. This would include a

project where the requesting agency does not receive anything of consequential value until the

entire project is completed and it receives a final report. The general rule is that a non-severable

service is considered a bona fide need at the time the agency orders the service and, therefore,

should be charged to an appropriation current at the time the agency enters into the contract.

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12. Guidance on review of IAAs for the Department of Commerce/Office of General

Counsel

Send a complete agreement package. Agreements with missing information or pages

cause clearance delays.

Consider adding a cover letter with a brief explanatory statement describing the project in

layman’s terms.

Cite to proper authorities, including the authority for the transaction and “programmatic”

authorities.

Fully identify within the agreement the responsibilities of each party and any

deliverables.

Ensure that the period of performance for the activity is clearly stated, and if the term of

the agreement is different than the activities’ period of performance, that must also be

clearly stated.

Include proper appropriation information (e.g., type of funds and period of availability) in

the agreement. If the agreement is with another Federal agency and funds are being

transferred for services, you must also include appropriate accounting data, which

includes each party’s: DUNS/BPN Number, TAS, and BETC.

Include a dispute resolution provision within the agreement.

Cut and paste carefully! When using boilerplate language from another agreement, make

sure that it is applicable to the agreement currently being drafted.

Provide to OGC/Admin appropriate points of contact (with telephone numbers) who can

address questions during the course of legal review.

Check for inconsistent statements and dates in the agreement.

Agreements should not be signed by Department officials until legal clearance is

received. Generally, fully executed or retroactive agreements will not be cleared.

Expired agreements cannot be amended! The Department operating unit should instead

draft a new agreement.

When an amendment is being forwarded for legal review, it should cite the termination

date of the underlying agreement as well.

If you are forwarding an amendment for clearance, it is useful to reference the underlying

agreement and prior amendments (if any) in an accompanying cover letter.

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13. APPENDICES

Appendix A – 7600 Form A

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Appendix A – 7600 Form A

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Appendix A – 7600 Form A

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Appendix A – 7600 Form A

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Appendix B – 7600 Form B

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Appendix B – 7600 Form B

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Appendix B – 7600 Form B

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Appendix B – 7600 Form B

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Appendix B – 7600 Form B

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Appendix C – IAA Checklist

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Appendix C – IAA Checklist

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