RPM | REQUIREMENTS AND POLICIES MANUAL

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    Title:

    Overview for Processing Incoming Inter-Contractor Purchases (ICP)

    Publication date:

    4/10/2024

    Effective date:

    4/10/2024

    BRIEF

    Policy Summary

    Lawrence Berkeley National Laboratory (Berkeley Lab) sometimes receives requests to perform work for another Department of Energy (DOE) laboratory integrated contractor. This process is known as inter-contractor purchases (ICP). This document defines guidelines for processing ICPs. The Strategic Partnerships Office (SPO) is responsible for reviewing all ICP proposals. Further, the SPO has authority to accept awards for ICP.

    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 Processing Incoming Inter-Contractor Purchases (ICP)

    Publication date:

    4/10/2024

    Effective date:

    4/10/2024

    POLICY

    A. Purpose

    This policy establishes the requirements and responsibilities for the oversight, management, and administration of inter-contractor purchases from another DOE integrated contractor to Berkeley Lab. The Strategic Partnerships Office (SPO) is responsible for reviewing all ICP proposals. Further, the SPO has authority to accept funding documents for ICPs. This policy and its associated procedures describe the requirements for the management of ICP funds.

    B. Persons Affected

    Any Berkeley Lab employee involved with submitting, reviewing, or approving proposals and accepting, performing, or administering funding documents from a DOE integrated Contractor.

    C. Exceptions

    None

    D. Policy Statement

    1. General
      1. Berkeley Lab will follow the requirements of Contract 31 and Chapter 12 of the DOE Financial Management Handbook section 2. d. Inter-contractor purchases between DOE integrated contractors when processing ICP funding from another DOE integrated contractor.
      2. “Inter-contractor purchase (ICP)” is a purchase transaction for supplies or services between two or more DOE/NNSA Management and Operating (M&O) contractors or site/facility management contractors that are integrated contractors. The ICP process permits one DOE integrated contractor to request work from another DOE integrated contractor as needed to support authorized work.  
      3. The SPO Contracts Officers (COs) have delegated authority from DOE to accept  ICPs between DOE integrated contractors. Therefore, the SPO is the institutional organization responsible for submitting proposals and accepting awards for ICPs from DOE integrated / M&O contractors.
    2. Proposals to other DOE integrated contractors 
      1.  The Principal Investigator (PI) and administrative support group are responsible for preparing proposals including all required Berkeley Lab and requesting DOE integrated contractor forms. Proposals must be approved by the PI and Division Director or authorized designee. Each ICP proposal should have a scope and budget to complete the project.
      2. DOE approval. The BSO Contracting Officer will approve the ICP statement of work (SOW).
      3. Institutional Approvals. The SPO CO confirms conformance to applicable policies and ensures appropriate approvals as necessary:
        1. Use of human subjects approved by the Human and Animal Regulatory Committee (HARC) (see the "Human and Animal Subjects Research" policy area).
        2. Use of animal subjects approved by HARC and submitted to BSO for Office of Science approval (see the "Human and Animal Subjects Research" policy area).
        3. National Environmental Policy Act / California Environmental Quality Act (NEPA/CEQA) Review.
        4. Conflict of Interest (COI) approval by the Research Compliance Office.
      4. Submission to DOE Integrated Contractor. The SPO CO prepares the ICP 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 DOE integrated contractor contact identified by the scientific division.
    3. Funding to Berkeley Lab from other DOE integrated contractors
      1. An ICP may be issued to Berkeley Lab as a Memorandum Purchase Order (MPO) or similar contracting mechanism (i.e., subcontract, standard purchase order, Integrated Contractor Order (ICO) etc.), or as an Inter-entity Work Order (IEWO) or with both documents (i.e., MPO and IEWO).
      2. MPO/ICO/PO adding scope and/or funding
        1. The MPO/ICO/PO is the mechanism generated by the DOE Lab sending funds to LBNL under which LBNL will perform work under its M&O contract. The MPO/ICO/PO must be reviewed by the SPO to ensure that it provides minimal terms and conditions and specifies that work is performed by Berkeley Lab under Contract 31. The SPO CO will seek approval through Lab Counsel and BSO Contracting Officer as applicable.
        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/ICO/PO is acceptable, and DOE SOW approval and other applicable approvals are received, the SPO CO signs the MPO and returns a copy to the sponsor.
        4. In the event that the MPO/ICO/PO is issued with an IEWO, the SPO CO will follow the procedure as described below.
      3. IEWO. The IEWOis sometimes issued by the DOE Lab in lieu of or in addition to the MPO/ICO/PO (See an example of the IEWO form on page 9 of Chapter 12 of the DOE Financial Management Handbook ).  The IEWO is initiated by the M&O/integrated contractor sponsor, approved by their DOE Contracting Officer, and then sent to the SPO.
        1. If the IEWO is accompanied by a funding document (e.g., MPO), the SPO CO reviews it to ensure that it provides minimal terms and conditions and specifies that work is performed by Berkeley Lab under Contract 31. The SPO CO will seek approval through Lab Counsel and BSO Contracting Officer as applicable.
        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 IEWO, along with its contractual document, is acceptable, the SPO CO signs the documents as required (the MPO/ICO/PO and/or IEWO). The SPO CO forwards the IEWO, along with its contractual documents and SOW, to the DOE Berkeley Site Office (BSO) Contracting Officer for signature of the IEWO. The BSO Contracting Officer will not sign the MPO/ICO/PO. Upon receipt of the signed IEWO from the BSO, the fully executed IEWO and contractual document (if appropriate) are transmitted by the SPO to the sponsor.
      4. 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.
    4. Funding Considerations. See Funds Control Policy.

    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 (SPO)
    • Has delegated authority to review and submit proposals, and accept awards.
    • Is responsible for coordinating approvals with the site office.
    • Ensures all compliance items, including nonstandard terms and conditions, are approved prior to execution.
    • Enters award information into eSRA.

    Principal Investigator (PI)
    • Responsible for the conduct of awards consistent with the award from the participant and the terms of the UC-DOE Prime Contract (DOE Contract No. DE-AC02-05CH11231).
    • Has overall financial responsibility and accountability for managed programs/projects/functions and meeting all contractual terms and conditions.
    • Manages and controls project funds in a prudent manner and expends funds in accordance with the restrictions imposed by contract terms and Laboratory policies. Note that while PIs may delegate the day-to-day management of project finances to other professional staff, accountability for compliance with contractual and financial requirements cannot be delegated and remains with the PI.
    • Proposes and plans the financial aspects of assigned projects, working closely with Office of the Chief Financial Officer (OCFO) RAs.
    • Understands and appropriately applies Laboratory and funding participant financial policies, guidelines, and contract terms.
    • Executes the project, ensuring all costs (labor, procurements, travel, etc.) are appropriate, allowable, and allocable to the project/activity benefiting from the cost.
    • Has a responsibility to ensure, in consultation with the division's or area's OCFO resource management staff, that costs charged to PIs' projects are allowable.
    • Ensures the Closeout Checklist is submitted in eSRA so that the award can be closed per the DOE requirement.

    Resource Analyst (RA)
    • Assists the PI with the proposal preparation and overall management of the award.
    • Reviews the request for proposal to gain an understanding of the proposal requirements, prepare administrative proposal forms, including the budget.
    • Provides divisional financial support, knowledge, and expertise and has financial responsibility and accountability.
    • Working closely with the PI:
      • Prepares and/or coordinates the planning, development, and submission of the financial and related administrative aspects of a project proposal based upon the PI's technical work scope and resource requirements.
      • Develops an executable, fully burdened spend plan that ensures full cost recovery.
      • Reviews and updates the spend plan and cost projections in a timely manner to ensure successful project execution.
      • Analyzes and formulates the areas' and divisions' indirect budgets and rates.
      • Prepares source materials and analysis required for conducting periodic division program/financial reviews.
      • Offers advice on mitigating potential overcommitment and costing issues at funding control points during the year.
      • Understands, interprets, and applies knowledge of funding participant financial guidelines, policies, and contract terms as well as Laboratory policies.
      • Provides the division with periodic standard and ad hoc summary and detailed financial reports that are timely, accurate, and complete for the division's programs and projects.
      • Exercises delegated signature authority on financial and/or procurement actions.
      • Develops, monitors, and maintains division project and activity IDs and costing structures.
      • Identifies problematic issues concerning interpretation and implementation of DOE, UC, and laboratory financial management policies and procedures. Reviews with the Division Business Manager or the Deputy for Operations and OCFO Field Finance Manager.
      • Finalize costs in eSRA so the Request for Closeout Checklist activity can be completed.

    Reimbursable Group (RG)


    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 Contractors with a contractual requirement for integrated accounting, 48 CFR 970.5232-8, Integrated Accounting, or successor clause. Contractors with integrated accounting are noted in the list of site/facility management contractors maintained by MA Office of Acquisition Management (MA-60) DOE/NNSA Site Facility Management Contracts, lists FFRDC integrated contractors.

    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

    Inter-contractor purchases (ICP), previously referred to as DOE Inter-Entity Work

    An inter-contractor Purchase (ICP) is a purchase transaction for supplies or services between two or more DOE/NNSA Management and Operating (M&O) contractors or site/facility management contractors that are integrated contractors. The ICP process permits one DOE integrated contractor to request work from another DOE integrated contractor as needed to support authorized work.

    Inter-entity Work Order (IEWO)

    A funding document used to document work from one DOE organization to another DOE organization. An IEWO is not a procurement form and does not authorize any procurement actions.

    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)

    Memorandum Purchase Order (MPO),
    Integrated Contractor Order (ICO),
    Purchase Order (PO)

    A mechanism generated by the DOE Lab sending funds to LBNL under which a DOE M&O Contractor performing under its M&O contract procures work from another DOE M&O Contractor.

    DOE Payment and Collection System (DOE-PAC)

    The DOE system facilitates billing and payments between DOE federal entities and contractors, and is integrated with the DOE primary accounting system STARS.
    The performing contractor (LBNL) receives payments for work directly from the requesting contractor through the DOE-PAC system. The performing DOE contractor initiates bills in DOE-PAC, and DOE-PAC automatically generates billings and e-mail notifications to the requesting 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
    4/10/2024 3 T. Pray Periodic review: major re-write. Title changed from Overview for Performing DOE Inter-entity Work to Overview for Processing Incoming Inter-Contractor Purchases (ICP) All Major
    6/15/2020 2.1 S. Iwatate Minor language clarifications (D.3.4.3) and R&R clarification for SPO (E) D, E Minor

    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:

    Overview for Processing Incoming Inter-Contractor Purchases (ICP)

    Document number

    06.01.008.000

    Revision number

    3

    Publication date:

    4/10/2024

    Effective date:

    4/10/2024

    Next review date:

    4/9/2027

    Policy Area:

    Non-DOE Funded Project Mechanisms

    RPM Section (home)

    Non-DOE Funded Project

    RPM Section (cross-reference)

    none

    Functional Division

    SPO

    Prior reference information (optional)

    N/A

    Source Requirements Documents

    Other References

    Implementing Documents

    None



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