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Overview for Performing DOE Inter-entity Work

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    Title:

    Overview for Performing DOE Inter-entity Work


    Publication date:

    1/30/2019

    Effective date:

    1/30/2019

    BRIEF

    Policy Summary

    Lawrence Berkeley National Laboratory (Berkeley Lab) sometimes receives requests to perform work for another Department of Energy (DOE) laboratory or a segment of DOE. This work, formerly known as "Management and Operating (M&O) Contractor Funding," is known as inter-entity work (IEW). This document defines guidelines for processing funding from another DOE M&O contractor to Berkeley Lab.
    The Strategic Partnerships Office (SPO) is responsible for reviewing all IEW proposals. Further, the SPO has authority to accept awards for IEW if the funding is under $1 million. This policy and its associated procedures describe the requirements for the management of IEW funds.

    Who Should Read This Policy

    Any Berkeley Lab employee involved with submitting, reviewing, or approving proposals and accepting, performing, or administering awards from DOE Integrated Contractor sponsors

    To Read the Full Policy, Go To:

    The POLICY tab on this wiki page

    Contact Information

    Strategic Partnerships Office (SPO) Managing Contracting Officer



    Title:

    Overview for Performing DOE Inter-entity Work

    Publication date:

    1/30/2019

    Effective date:

    1/30/2019

    POLICY

    A. Purpose

    Lawrence Berkeley National Laboratory (Berkeley Lab) sometimes receives requests to perform work for another Department of Energy (DOE) laboratory or a segment of DOE. This work, formerly known as "Management and Operating (M&O) Contractor Funding," is known as inter-entity work (IEW). This document defines guidelines for processing funding from another DOE M&O contractor to Berkeley Lab.
    The Strategic Partnerships Office (SPO) is responsible for reviewing all IEW proposals. Further, the SPO has authority to accept awards for IEW if the funding is under $1 million. This policy and its associated procedures describe the requirements for the management of IEW funds.

    B. Persons Affected

    Any Berkeley Lab employee involved with submitting, reviewing, or approving proposals and accepting, performing, or administering awards from DOE M&O sponsors

    C. Exceptions

    None

    D. Policy Statement

    1. General
      1. "Inter-entity" is defined as work performed by one DOE office or DOE site/facility management contractor for another. DOE site/facilities management contractors are frequently referred to as Management and Operating (M&O) contractors and/or DOE integrated contractors.
      2. Berkeley Lab will follow the requirements of Contract 31 and Chapter 12 of the DOE Financial Management Handbook when processing inter-entity work (IEW).
      3. The SPO Contracts Officers (COs) have delegated authority from DOE to accept DOE contractor orders under $1 million without DOE approval. Therefore, the SPO is the institutional organization responsible for submitting proposals and accepting awards for IEW from DOE integrated / M&O contractors.
    2. Proposals to other DOE entities
      1. DOE approval. DOE approval is not required for inter-entity proposals.
      2. Standard process. The SPO will apply the same process it uses for Sponsored Research, including Conflict of Interest (COI); Environment, Safety & Health (ES&H); and Animal and Human Subjects Research approvals.
      3. Submission to sponsor. The SPO CO prepares the inter-entity proposal transmittal letter within eSRA; attaches the proposed scope of work, budget, and other sponsor application forms, if required; and transmits the paperwork to the inter-entity sponsor contact identified by the scientific division.
    3. Awards to Berkeley Lab from other DOE entities
      1. An inter-entity award may be issued to Berkeley Lab as a Memorandum Purchase Order (MPO) or similar contracting mechanism (i.e., subcontract, standard purchase order, etc.), or as an Inter-entity Work Order (IEW Order).
      2. MPO (Less than $1 million)
        1. The MPO is used by M&O / integrated contractors if the project is expected to be under $1 million in funding. The MPO must be reviewed by the SPO to ensure that it provides the terms and conditions under which work performed by Berkeley Lab is compliant with Contract 31.
        2. Other terms including the budget and scope of work must also be reviewed for acceptability. If the scope of work or budget differs from what Berkeley Lab proposed, the scientific division must be consulted to ensure it accepts the changes and the funding level.
        3. If the MPO is acceptable, the SPO CO signs the MPO and returns a copy to the sponsor.
        4. In the event that a modification of the MPO increases the total value of the MPO to over $1 million, an IEW Order must be issued as described below.
      3. IEW Order (More than or Equal to $1 Million): The IEW Order is used by M&O/integrated contractors if the project is expected to be $1 million or greater in funding (See the IEW Order form for an example). Sometimes, the sponsor also sends a contractual document (which could be an MPO) along with the IEW Order to provide for additional terms and conditions. The IEW Order is initiated by the M&O/integrated contractor sponsor, approved by their DOE Contracting Officer, and then sent to the SPO.
      4. IEW Order Process
        1. If the IEW Order is accompanied by a contractual document (e.g., MPO), the SPO CO reviews it to ensure it provides the terms and conditions under which work performed by Berkeley Lab is compliant with Contract 31.
        2. Other terms, including the budget and scope of work, must also be reviewed for acceptability. If the scope of work or budget differs from what Berkeley Lab proposed, the SPO CO must consult with the scientific division to ensure it accepts the changes and the funding level.
        3. If the IEW Order, along with its contractual document, is acceptable, the SPO CO signs the contractual document (e.g., MPO) and forwards only the IEW Order to the DOE Berkeley Site Office (BSO) Contracting Officer for signature. (No proposal is required by DOE for this type of award document.)
        4. Upon receipt of the approved IEW Order from the BSO, the fully executed IEW Order and contractual document (if appropriate) are transmitted by the SPO to the sponsor.
      5. Award Authorization: The SPO CO enters award data elements in the Electronics System for Research Administration (eSRA) and authorizes the award. Once activated, the award is routed to the principal investigator (PI), division post-award analyst, and appropriate Office of the Chief Financial Officer (OCFO) groups.

    E. Roles and Responsibilities

    Managers, supervisors, and employees have the responsibility to adhere to the provisions of this policy.

    Role

    Responsibility

    Division

    • Ensures that all proposal documentation is provided to the SPO with division director (or designee) approval.

    Strategic Partnerships Office

    • Has delegated authority to review and submit proposals, and accept awards under $1 million.
    • For awards over $1 million, responsible for coordinating approvals with the site office.


    F. Definitions/Acronyms

    Term

    Definition

    DOE Integrated Contractor

    An integrated contractor is a contractor that works for DOE; uses DOE funds to finance its operations under a cost-type contract; and maintains a separate set of accounts and records for the recording and reporting of all business transactions under the contract in accordance with DOE accounting practices and procedures, and whose accounts, maintained for operations under the contract, are integrated with those of DOE

    DOE Management and Operating (M&O) Contractors

    Private-sector companies, universities, and nonprofit organizations that manage DOE national laboratories and production installations through a DOE site/facility M&O contract

    ICO

    Integrated Contractor Order

    IEWO

    Inter-entity Work Order

    Management and Operating (M&O) Contract

    "An agreement under which the Government contracts for the operation, maintenance, or support, on its behalf, of a Government-owned or controlled research, development, special production, or testing establishment wholly or principally devoted to one or more major programs of the contracting Federal agency." (Source: Federal Acquisition Regulation [FAR] 17.601)

    MPO

    Memorandum Purchase Order is a contractual mechanism under which a DOE M&O Contractor performing under its M&O contract procures work from another DOE M&O Contractor

    G. Recordkeeping Requirements

    None

    H. Implementing Documents

    None

    I. Contact Information

    Strategic Partnerships Office (SPO) Managing Contracts Officer

    J. Revision History

    Date

    Revision

    By Whom

    Revision Description

    Section(s) Affected

    Change Type

    10/3/2018

    2

    D. Garcia

    Update for changes to terminology consistent with DOE Financial Management Handbook; update for OSPIP/SPO change; WFO to SPP change

    All

    Major

    11/11/2012

    1.1

    R.Inada

    Periodic review completed 10/23/12; no changes

    Pub & rev dates

    Minor

    5/14/2012

    1

    M. Mock

    Re-format for wiki (policy)

    All

    Minor

    1/2/2012

    0

    M. Mock

    Re-format for wiki (brief)

    All

    Minor

    DOCUMENT INFORMATION

    Title:

    DOE Management and Operating (M&O) Overview

    Document number

    06.01.008.000

    Revision number

    2

    Publication date:

    1/30/2019

    Effective date:

    1/30/2019

    Next review date:

    111/1/2022

    Policy Area:

    Non-DOE Funded Project Mechanisms

    RPM Section (home)

    Non-DOE Funded Project

    RPM Section (cross-reference)

    none

    Functional Division

    O SPO

    Prior reference information (optional)


    Source Requirements Documents

    Other References

    Implementing Documents

    None