Chapter 5. Project Planning

Topics on this page: 5.1 Pre-Project Planning | 5.2 Facility Project Approval Agreements | 5.3 Real Property Acquisition Planning | 5.4 Planning and Programming Documents | 5.5 Site Selection | 5.6 Space Acquisition | 5.7 Definition of Building Areas and Spaces | 5.8 Utilization Targets for Administrative Space

Table of Contents

In accordance with FAR Part 7 and HHS policy, Divisions shall perform acquisition planning (FAR Part 7.1 and HHS Acquisition Regulations (HHSAR) 307) and conduct market research (FAR Par 10 and HHSAR 310) for all acquisitions to promote and provide for

  • Acquisition of commercial items or, to the extent that commercial items suitable to meet the agency's needs are not available, non-developmental items, to the maximum extent practicable (10 U.S.C.2377 and 41 U.S.C.3307); and
  • Full and open competition or, when full and open competition is not required in accordance with Part 6, to obtain competition to the maximum extent practicable, with due regard to the nature of the supplies or services to be acquired (10 U.S.C.2305(a)(1)(A) and 41 U.S.C. 3306a)(1).

Acquisition planning for federally owned real property assets shall integrate the efforts of all personnel responsible for significant aspects of the acquisition. The purpose of this planning is to ensure that the Government meets its needs in the most effective, economical, and timely manner. To facilitate meeting the acquisition goals and objectives, the plan should identify milestones which require decisions to be made. The plan should address all the technical, business, management, and other significant considerations that will control the acquisition. The content of plans will vary, depending on the nature, circumstances, and stage of the acquisition and include the following:

  • Background and objectives that includes statement of need; applicable condition; life- cycle cost; performance characteristics; trade-offs; risks; and acquisition streamlining; and
  • Plans of action that includes sources, competition, source-selection procedures, acquisition considerations, budgeting and funding, product or service descriptions, priorities, allocations, and allotments, contractor versus government performance, inherently governmental functions, logistics considerations, government-furnished property and information, environmental and energy conservation objectives, security considerations, contract administration, other considerations, and milestones for the acquisition cycle.

5.1 Pre-Project Planning

5.1.1 Policy

"Pre-project planning is defined as the process of developing sufficient strategic information with which owners can address risk and decide to commit resources to maximize the chances for a successful project. The process begins when a validated project concept has been identified during the business planning process and ends when a decision has been made whether or not to authorize funding for the execution of the project." (CII Website)

HHS has adopted pre-project planning as a best practice. This section describes the policies and procedures to be followed by Divisions when conducting pre-project planning activities leading up to the submission of a Facility Project Approval Agreement (FPAA). Prior to submitting an FPAA for review and approval, Divisions should develop Planning and Programming Documents alongside Concept and Schematic Designs and should use tools such as the Department of the Army's Economic Analysis Package (ECONPACK), the Construction Industry Institute (CII) Project Delivery and Contract Strategy (PDCS) Evaluation tool, the CII's Project Definition Rating Index (PDRI) tool, amongst others, as part of their pre-project planning activities.

5.1.2 Administrative Requirements

5.1.2.1 Overview

Pre-project Planning (PPP) starts with the identification of requirements and continues through the concept phase and finishes at schematic phase of the project. The pre-project planning establishes the project requirements, develops concepts and evaluates alternatives, and provides the basis for project budget and schedule, for review and approval.

5.1.2.2 Organizing for Pre-Project Planning

For projects below the Division Approval thresholds, the pre-project planning effort need not be submitted for Departmental review, however, for projects exceeding the Division Approval Threshold , the pre-project planning should be formal, rigorous, and well documented.

Partnering among all project stakeholders is necessary to ensure all requirements are defined and incorporated into the project documentation and budget. Stakeholders for the team may change as the project progresses through its planning and development phase. The team should include members based upon knowledge, skills, authority, operations and administrative functions that are needed to develop the project requirements.

  1. Concept Design

    Includes drawings, sketches, and/or graphics showing alternatives used to define a project's scope during the initial programming phase of the project.
  2. Schematic Design

    Includes drawings and other documents illustrating the scale and relationship of project components and a statement of probable costs.
  3. Economic Analysis Package (ECONPACK)

    HHS recommends the use of the Department of the Army Pamphlet 415-3, Economic Analysis: Descriptions and Methods. Per the pamphlet, an economic analysis is used to help determine the best alternative to meet a requirement as specified in the project objective. The ultimate goal of an economic analysis is to provide a recommended course of action. The economic analysis must promote a clear understanding of the stated need, possible solutions, and cost implications of various alternatives.

    Divisions are encouraged to follow the recommended Economic Analysis Process (Pamphlet Chapter 3) to, at a minimum, establish the project objective, identify alternatives, classify the economic analysis, and report the results and recommendations. Where more than one viable alternative is identified, a life-cycle cost analysis and determination of non-monetary considerations, in addition to the minimum stated above is recommended.
  1. Project Delivery and Contract Strategy

    As part of developing an acquisition strategy OPDIVs are encouraged to use the Construction Industry Institute (CII) Project Delivery and Contract Strategy (PDCS) to evaluate alternate project delivery mechanisms.

    The evaluation through PDCS, or a similar tool, must include a summary memo that describes the PDCS criteria, results and procurement strategy decision, which shall be forwarded with the FPAA on all projects requiring Department approval.

    Design-Build must be considered as the preferred strategy in the evaluation, if the results from the PDCS tool place Design-Build in the top three recommended contract strategies.

    The Project Manager and/or Contracting Officer Representative must coordinate and obtain the Contracting Officer's approval of the acquisition plan. If the plan proposes using other than full and open competition to award a contract, the plan shall also be coordinated with the Competition Advocate as required in the Competition in Contracting Act (CICA). The acquisition plan or strategy must be coordinated with the Small Business and Disadvantaged Business Utilization Specialist (SADBUS).
  2. Project Definition Rating Index

    The Project Definition Rating Index (PDRI) shall be used as a tool to evaluate the ongoing status of a project. The rating index is not used as criteria for project approval, but as an indication of the project's readiness for continued procurement. The index should be evaluated after completing the pre-planning stages of the project, as well as in subsequent stages of the project.

    A PDRI Project Score Sheet, evaluating the project after completing the pre-planning efforts of the project, is required as part of the submission of the FPAA.
  3. Sustainability Guiding Principles Checklist

    A checklist that must be submitted for projects requiring an FPAA or on new lease actions for 5,000 USF or greater to a maximum extent feasible to record compliance with the Guiding Principles for Sustainable Federal Buildings.
  4. Housing Plan

    A tool used to compute the space requirements based on staffing levels for a project space per the 21st Century Policy (See Section 5.8 Utilization Targets for Administrative Space for more information). HHS Divisions specify the staffing requirements for onboard federal staff employees excluding vacancies, federal staff approved vacancies, onboard contractors, contractor approved vacancies, interns that are full-time telework, teleworking 5 or less days per pay period, or 6 or more days per pay period. Once staffing requirements are specified for each staff category, the distribution of seating type is specified: office, workstation, or bench.
  5. Appropriations/Obligations/Budget (AOB)

    The AOB specifies the projected appropriations and obligations, and budgets and associated funding source as defined in Section 3.3 Funding Sources for the upcoming budget year (CY + 2 years) and the previous five (5) fiscal years. There are two (2) components associated with budget estimate: facility budget estimate and related budget estimate. Facility budget estimate consist of land acquisition, design, construction, and other costs. Related budget estimates consist of special studies, pre-project planning, activation (includes moving), fixed equipment, special purpose equipment, and other costs.
  6. FPAA Form HHS-300

    See Section 5.2 Facility Project Approval Agreements.

5.2 Facility Project Approval Agreements

5.2.1 Policy

HHS policy requires the submission of Facility Project Approval Agreements (FPAA), which summarize the project requirements, scope, justification, schedule and budget, for projects in owned facilities and for lease acquisition projects, with estimated costs above the Division Approval Thresholds as defined in 3 Real Property Planning - Owned and 4 Leasing - Direct Leases.

  1. Capital Review Process

    The HHS facility project review process has a three-tiered structure supporting the HHS fiscal year budget formulation process that distinguishes HHS approval authorities based on the full costs of each project considering all sources of funds. Within HHS, facility projects are approved in accordance with the approval thresholds as indicated in 3.3.2.1 Approval Thresholds.

5.2.2 Administrative Requirements

  1. Authorities and Responsibilities

    All projects approved by Headquarters will require a written approval agreement between designated officials of the sponsoring Division and ASA.

    The Facilities Project Approval Agreement (FPAA) documents the project's basis of need, scope, description, all justification funding source(s), and the total cost from each source. It also identifies execution milestones (start and completion dates) for studies, planning, design, construction, activation, and the operational phases of the project. The agreement represents a description and justification of the OPDIV's project requirements to support a program need to be submitted with the annual budget request submission.
    1. Capital Facilities Review Process

      The HHS facility project review process has a three-tiered structure supporting the HHS fiscal year budget formulation process that distinguishes HHS approval authorities based on the full costs of each project considering all sources of funds. Within HHS, facility projects are approved in accordance with the approval thresholds as indicated in 3.3.2.1 Approval Thresholds.
      1. CIRB: The CIRB will review and make recommendations to the Secretary, the ASA and ASFR on a range of issues to include: 1) the development of facility capital investment guidelines; 2) the development of guidelines to implement an investment review process that provides strategic planning for and oversight of facility investments; and 3) regular monitoring and proper management of these investments, once funded. In addition to Projects subject to CIRB Approval Threshold outlined in 3.3.2.1 Approval Thresholds, the following are additional projects the CIRB must be reviewed:
        1. Department-wide investments that affect multiple organizations;
        2. Investments that have a significant impact on a single OPDIV;
        3. OPDIV investments that the Office of the Secretary determines to have a significant risk or have high public visibility;
        4. Other project types as designated by the Board
        5. Campus Facilities Master Plans
  2. Procedures

    The FPAA package shall consist of the following documents in the following order:
    • FPAA Form HHS-300 pages 1, 2 and 3
    • Attachment A - Economic Analysis Package (ECONPACK)
    • Attachment B - Project Delivery and Contract Strategy (PDCS)
    • Attachment C - Project Definition Rating Index (PDRI)
    • Attachment D - Guiding Principles for Sustainable Federal Buildings Checklist
    • Attachment E - Housing Plan
    • Attachment F - Appropriations/Obligations/Budget Form
    • Attachment G - Transmittal Sheet list all applicable attachments signed by Division Facility Director

5.2.3 Reporting

The FPAA will serve as the project justification and must be submitted as part of the HHS budget formulation process. Draft FPAAs should be submitted for review to the PSC/RLO/RPMS no later than June 1 each year in preparation for the annual HHS Board meeting in June/July.

The final FPAA consistent with the decisions of the Secretary's Budget Council will require the signatures of the OPDIV Board Member, the Office of Acquisition, the Project Director, and the Contracting Officer Representative. Departmental sign-off will signify HQ and Board approval and acceptance of the OPDIV's commitment to execute projects within the defined scope, budget and schedule as presented, or as modified during the review process.

New requirements for projects that occur outside the normal budget formulation process will be submitted for review as soon as the requirement has been identified. PSC/RLO/RPMS will work with the OPDIV to facilitate approval of the project in a timely manner. Planning and Programming Documents are not required as part of the FPAA submission; however, as part of the review process PSC/RLO/RPMS may require that the OPDIVs submit these documents.

The HHS Facility Project Approval Agreement must be approved by the Department prior to awarding any contract for the project. FPAA approval is required before any capital B&F funds can be spent.

5.3 Real Property Acquisition Planning

5.3.1 Policy

Refer to Federal Management Regulations (FMR), Subchapter C-Real Property, Part 102-73—Real Estate Acquisition, for general provisions, applicable to HHS.

HHS policy is that:

Only real property needed for effective program operation may be acquired, after authorization and clearances; Non-government property may be acquired only when suitable Government-owned facilities are not available; and HHS activities in the same area should be co-located, wherever practicable.

Per the above, once a requirement for real property is established, other HHS assets in the area shall first be considered to determine if space may already be under ownership or lease that will accommodate the requirement and in turn, improve the utilization of an existing HHS asset.

5.3.2 Administrative Requirements

  1. Authorities and Responsibilities
    1. Principal statutes authorizing HHS acquisition of land and provision of space:
      1. Division legislative and/or regulatory authority to perform leasing activities is outlined in 4 Leasing - Direct Leases.
      2. The Secretary, through the Public Health Service - Authority to manage and operate all institutions, hospitals, and stations of the and provide for the care, treatment, and hospitalization of patients; and from time to time, with the approval of the President, select suitable sites for and establish such additional institutions, hospitals, and stations in the States and possessions of the United States necessary to enable the Service to discharge its functions and duties ((Section 321 of the PHS Act (42 U.S.C. 248a)).
      3. Section 7 of Public Law 83-568 (The Indian Health Transfer Act) (42 U.S.C. 2004), transferred authority for the construction, improvement, and extension of buildings and grounds and sanitation systems to serve Indians including the acquisition of lands, or rights or interests therein, to the Public Health Service of the Department of Health and Human Services.
      4. Section 402(b)(4)(A) of the PHS Act (42 U.S.C. 282(b)(4)(A)) provides and acquisition authority to the Director of the National Institutes of Health (NIH).
      5. Section 464P(b)(3) of the PHS Act (42 U.S.C. 285o-4(b)(3)) provides land acquisition authority to the Director of the National Institute of Drug Abuse (NIDA) in certain circumstances.
  2. Procedures
    1. Title to Federal Real Property

      Title to all Federal real property is in the name of the United States of America, unless otherwise authorized. HHS does not hold title to any real property. Transfers of property to or from other Government agencies are usually made administratively through the General Services Administration.
    2. Acquisition by Purchase

      Acquisitions by purchase require specific statutory authority and funding in an OPDIV's budget and must be approved by the HHS Capital Investment Review Board and the Secretary (see 3.3 Funding Sources).

      All acquisitions of land or buildings must be consistent with the "Department of Justice Title Standards 2001," and the Uniform Relocation Assistance and Land Acquisition Policies Act of 1970 (PL 91-646).
      1. Purchase of buildings shall be in accordance FMR §102-73.240 through 73.250, including compliance with FMR §102-73 and §102-83 location policies.
      2. The purchase of land shall be in accordance with FMR §102-73.255 through 73.260, in compliance with the Uniform Relocation Assistance and Real Property Acquisition Policies Act, 42 U.S.C. 4651-4655.
    3. Acquisition by Donation
      1. Assistant Secretary for Administration (ASA) is authorized to accept gifts of real property under Section 231 of the Public Health Service Act (42 U.S.C. 238) and 25 U.S.C. 451, as amended.
        1. The OPDIV presents the donor's written proposal and the OPDIV's program analysis to ASA for review. The program analysis must document that the gift is mission related, mission dependent, and does not constitute a conflict of interest.
        2. After ASA approval, PSC RLO RPMS will submit the offer and program analysis to the Office of General Council (OGC) for review and analysis
          1. The Secretary is authorized under 42 USC 289f, to accept conditional gifts including real property, for the benefit of the National Institutes of Health.
          2. The Director of the National Institute of Occupational Safety and Health is authorized, under Section 22 of the Occupational Safety and Health Act (29 U.S.C. 671,) to accept conditional or unconditional gifts for the benefit of the Institute.
    4. Acquisition by Transfer

      Government property may be transferred to HHS when it is more economical than acquisition of a new facility. Transfer must be made under the following:
    5. HHS Lease Procedures are outlined in 4 Leasing - Direct Leases of the Facilities Program Manual.
    6. Acquisition by Donation
      1. Assistant Secretary for Administration (ASA) is authorized to accept gifts of real property under Section 231 of the Public Health Service Act (42 U.S.C. 238) and 25 U.S.C. 451, as amended.
        1. The OPDIV presents the donor's written proposal and the OPDIV's program analysis to ASA for review. The program analysis must document that the gift is mission related, mission dependent, and does not constitute a conflict of interest.
        2. After ASA approval, PSC RLO RPMS will submit the offer and program analysis to the Office of General Council (OGC) for review and analysis
          1. The Secretary is authorized under 42 USC 289f, to accept conditional gifts including real property, for the benefit of the National Institutes of Health.
          2. The Director of the National Institute of Occupational Safety and Health is authorized, under Section 22 of the Occupational Safety and Health Act (29 U.S.C. 671,) to accept conditional or unconditional gifts for the benefit of the Institute.
    7. HHS Lease Procedures are outlined in 4 Leasing - Direct Leases of the Facilities Program Manual.
    8. Acquisition by Transfer

      Government property may be transferred to HHS when it is more economical than acquisition of a new facility. Transfer must be made under the following:

5.3.3 Guidance and Information

  1. Contract Types

In acquisition planning, determining the type of contract early in the process is important. A wide selection of contract types is available to the Government and contractors to provide needed flexibility in acquiring the large variety and volume of supplies and services required by agencies. Contract types vary according to-

  • The degree and timing of the responsibility assumed by the contractor for the costs of performance; and
  • The amount and nature of the profit incentive offered to the contractor for achieving or exceeding specified standards or goals.

The contract types are grouped into two broad categories: fixed-price contracts and cost-reimbursement contracts. Note that the following FAR defined contract types are umbrellas that sit above project delivery methods.

The specific contract types range from firm-fixed-price, in which the contractor has full responsibility for the performance costs and resulting profit (or loss), to cost-plus-fixed-fee, in which the contractor has minimal responsibility for the performance costs and the negotiated fee (profit) is fixed. In between are the various incentive contracts in which the contractor's responsibility for the performance costs and the profit or fee incentives offered are tailored to the uncertainties involved in contract performance.

  1. Firm Fixed Price Contract: A firm-fixed-price contract provides for a price that is not subject to any adjustment based on the contractor's cost experience in performing the contract. This contract type places upon the contractor maximum risk and full responsibility for all costs and resulting profit or loss. It provides maximum incentive for the contractor to control costs and perform effectively and imposes a minimum administrative burden upon the contracting parties. The Contracting Officer may use a firm-fixed-price contract in conjunction with an award-fee incentive and performance or delivery incentives when the award fee or incentive is based solely on factors other than cost.
  2. Cost-Reimbursement Contracts: Cost-reimbursement types of contracts provide for payment of allowable incurred costs, to the extent prescribed in the contract. These contracts establish an estimate of total cost for the purpose of obligating funds and establishing a ceiling that the contractor may not exceed (except at its own risk) without the approval of the Contracting Officer. There are several cost reimbursement type contracts allowed under the FAR.
    1. Cost Contracts: A cost contract is a cost-reimbursement contract in which the contractor receives no fee.
    2. Cost-Sharing Contracts: A cost-sharing contract is a cost-reimbursement contract in which the contractor receives no fee and is reimbursed only for an agreed-upon portion of its allowable costs. A cost-sharing contract may be used when the contractor agrees to absorb a portion of the costs, in the expectation of substantial compensating benefits.
    3. Cost-Plus-Incentive-Fee Contracts: A cost-plus-incentive-fee contract is a cost- reimbursement contract that provides for an initially negotiated fee to be adjusted later by a formula based on the relationship of total allowable costs to total target costs.
    4. Cost-Plus-Award-Fee Contracts: A cost-plus-award-fee contract is a cost-reimbursement contract that provides for a fee consisting of (a) a base amount (which may be zero) fixed at inception of the contract and (b) an award amount, based upon a judgmental evaluation by the Government, sufficient to provide motivation for excellence in contract performance
    5. Cost-Plus-Fixed-Fee Contracts: A cost-plus-fixed-fee contract is a cost-reimbursement contract that provides for payment to the contractor of a negotiated fee that is fixed at the inception of the contract. The fixed fee does not vary with actual cost but may be adjusted as a result of changes in the work to be performed under the contract. This contract type permits contracting for efforts that might otherwise present too great a risk to contractors, but it provides the contractor only a minimum incentive to control costs.
  1. Indefinite-Delivery Contracts

    There are three types of indefinite-delivery contracts: definite-quantity contracts, requirements contracts, and indefinite-quantity contracts. The appropriate type of indefinite-delivery contract may be used to acquire supplies and/or services when the exact times and/or exact quantities of future deliveries are not known at the time of contract award. Requirements contracts and indefinite-quantity contracts are also known as delivery order contracts or task order contracts.
    1. The various types of indefinite-delivery contracts offer the following advantages. All three types permit-
      1. Government stocks to be maintained at minimum levels; and
      2. Direct shipment to users.
        1. Indefinite-quantity contracts and requirements contracts also permit-
          1. Flexibility in both quantities and delivery scheduling; and
          2. Ordering of supplies or services after requirements materialize.
        2. Indefinite-quantity contracts limit the Government's obligation to the minimum quantity specified in the contract.
        3. Requirements contracts may permit faster deliveries when production lead time is involved, because contractors are usually willing to maintain limited stocks when the Government will obtain all its actual purchase requirements from the contractor.
        4. Indefinite-delivery contracts may provide for any appropriate cost or pricing arrangement under Federal Acquisition Regulation (FAR) Part 16, Cost or pricing arrangements that provide for an estimated quantity of supplies or services (e.g., estimated number of labor hours).
        5. A/Es should be selected for discrete tasks based on qualifications in accordance with FAR Part 36.
  2. HHSAR - PART 307

    Acquisition plans (AP) should include applicable provision of Health and Human Services Acquisition Regulation (HHSAR) Part 307 HHS Acquisition Plans.
  3. Restrictions on Improvements on Leased Space

    See 4.3 Restrictions on Improvement.
  4. Restrictions on funding sources for Improvements in Leased Space

    See 4.3 Restrictions on Improvement.

5.3.4 Reporting

  1. Facility Acquisition Planning, and Development
    1. Determination of Effect on Historic Property

      See Determination of Effect on Historic Properties.
    2. Federal Capital Improvements Program

      The National Capital Planning Commission (NCPC) is a federal agency located in the Washington, D.C. metropolitan area. It is authorized to plan the orderly development of the federal establishment in the National Capital Region (NCR). One process the NCPC uses to help guide its planning is the annual preparation of what is referred to as the Federal Capital Improvements Program (FCIP). As required in Section 7(a) of the National Capital Planning Act of 1952, as amended, the Commission reviews federal public works projects for inclusion within a six-year FCIP. Once adopted by the Commission, the FCIP's recommendations are transmitted to the Office of Management and Budget (OMB) and other federal departments and agencies, as well as local and state jurisdictions. The FCIP helps coordinate future development activities in the NCR and assists OMB in making budgetary decisions about proposed capital projects in the Washington, D.C. area. The National Capital Region includes the District of Columbia; Prince George's and Montgomery Counties in Maryland; and Arlington, Fairfax, Loudoun, and Prince William Counties in Virginia, including the cities and towns located within the geographic area bounded by these counties.
    3. National Capital Planning Commissioning Review of HHS Projects

      The National Capital Planning Act of 1952 requires each federal agency in the National Capital Region (NCR), prior to preparing construction plans for proposed development projects or land acquisitions which affect the plan and development of the National Capital, to consult with the National Capital Planning Commission. The Commission has determined that an approved Master Plan is a prerequisite for review of individual installation's project plans in the NCR. The HHS Board must approve the Master Plan before it is submitted to the Commission.
    4. Contract Compliance

      FAR 22.804-2(c) requires Contracting Officers to give written notice to the U.S. Department of Labor, Office of Federal Contract Compliance Programs (OFCCP) regional office within 10 working days of award of a construction contract that are subject to affirmative action requirements. The notification shall include the name, address, and telephone number of the contractor; employer identification number; dollar amount of the contract; estimated starting and completion dates of the contract; the contract number; and the geographical area in which the contract is to be performed. When requested by the OFCCP regional office, the Contracting Officer shall arrange a conference among contractor, contracting activity, and compliance personnel to discuss the contractor's compliance responsibilities.
    5. Federal Procurement Data System

      HHSAR 304.602 requires following internal departmental procedures for reporting to the Federal Procurement Data System (FPDS) and for resolving technical or policy issues relating to FPDS contract reporting.
    6. Congressional Notification

      The Contracting Officer shall report awards over $4.5 million, not otherwise exempt under FAR 5.303, to the Office of the Assistant Secretary for Legislation (OASL) (Congressional Liaison). The Contracting Officer shall e-mail a copy of the contract or award document face page to [email protected] prior to the day of award or in sufficient time to allow OASL to make an announcement by 5 p.m. Washington, DC time on the day of award.
  2. Acquisition Plans

    On projects requiring the Department's approval, submittal of the Acquisition Plan is not required. However, the analysis/documentation supporting the chosen acquisition methodology using PDCS or a similar tool shall be forwarded to PSC/RLO/RPMS with the initial FPAA submittal. PSC/RLO/RPMS may require that the OPDIV submit the detailed acquisition plan as additional justification.
  3. External Rent Payments

    OMB Circular A-11, Section 54 requires agencies that obligate more than $5 million annually for rental payments, to submit a space budget justification in the format of exhibit 54 at the same time as the agency's annual budget submission. Individual OPDIVs must submit an Exhibit 54 "Space Budget Justification" report to PSC/RLO/RPMS as part of the annual HHS budget process.

5.4 Planning and Programming Documents

5.4.1 Policy

HHS establishes planning and programming policies and guidelines to be followed by Divisions in determining the requirements for the development, submission, and approval of the planning and programming documents for capital projects and acquisition of facilities under lease agreements above the SRPO Approval Thresholds. The purpose of Planning and Programming documents is to describe the required performance outcomes of a project or acquisition that are needed to support the mission.

Programming is identifying the customer's needs to support developing a comprehensive solution to satisfy the requirements covering all factors that influence design. The programming process involves the following considerations: function, form, economy, and time.

Programming is the process of project definition where project goals are established; projects needs are determined; project facts are analyzed; and project concepts are tested all resulting in project problem statements.

Project goals are the customer's and user's expectations, and the programming is a cooperative process emphasizing customer/user decision-making. Project needs are the projects requirements such as space, power, utilities, etc. Project facts are site constraints, site potentials, regulations that affect the project, etc. Project concepts are functional relationships, adjacency requirements, etc.

5.4.2 Administrative Requirements

  1. Authorities and Responsibilities
    1. The SRPO has overall responsibility for establishing and implementing planning and programming policy and guidelines. The PSC RLO RPMS is designated as the coordinating point for these activities within OS. PSC RLO RPMS may require the submission of final planning and programming documents as part of the HHS B&F budget process documentation.
    2. The head of each HHS OPDIV is responsible for the development of the documents for those facilities under his/her OPDIV jurisdiction, for ensuring the sufficiency of the document to meet the policy and guidelines established in this section, and for approving the final planning and programming documents. OPDIV heads are encouraged to designate an OPDIV facilities management coordinator to ensure this compliance. OPDIV heads may also re-delegate authority for compliance with environmental requirements. Planning and Programming documents must be signed off by the customer and the OPDIV Facility Director.
  2. (Reserved)

5.4.3 Guidance and Information

Planning and programming documents should consist of and address all the issues listed, and any special requirements or features needed for the project involved. In addition to the following requirements, OPDIVs are free to provide any other background information and data that further explains the project and assists the Architect/Engineer (A/E) in the development of the design. These general requirements may be adjusted or changed to meet the requirements of the projected facility. Statutory requirements (e.g., environmental reviews) may not be omitted.

Note that facility projects are graphically oriented, and planning and program documents may contain many site plans, photographs, renderings etc. to document the planning of a project. A typical capital project may consist of dozens of pages, if not more. The following are the data fields that should be considered:

  • Introduction
  • General Overview
    • Background
      • Program Mission
      • Existing Facilities
      • Need for the Proposed Project
    • Staffing and Organizational Structure
      • Organizational Chart
      • Staff Summary
  • Site
    • Site Description
    • Site Constraints
    • Site Potential
  • Space Descriptions
    • Activity Analysis
    • Program Objectives
    • Space Descriptions
    • Space Schedule
  • Functional Relationship
  • Design Standards
    • Applicable Federal Regulations
    • Applicable Departmental Regulations
    • Applicable OPDIV Regulations
    • Applicable Local Building Codes
    • Utility Company Regulations
    • Industry Standards
  • Design Criteria and Recommendations
    • Civil
    • Sustainable Design
    • Architectural
    • Interior Design
    • Structural
    • HVAC
    • Plumbing
    • Electrical
    • Communications
    • Miscellaneous
      • Security
      • Safety
      • Operational and Maintenance
  • Budget
    • Facility Cost Estimate
      • Land Acquisition
      • Design
      • Construction
      • Equipment
    • Related Cost Estimate
      • Special Studies
      • Pre-Project Planning
      • Activation (Including Moving)
      • Special Purpose Equipment
      • Other
  • Schedule
    • Design
    • Construction
    • Commissioning
    • Activation
  • Sign-Off
    • Customer
    • OPDIV

5.5 Site Selection

5.5.1 Policy

HHS policy requires that adequate evaluation is performed, and alternatives are sought, when selecting sites for planned facilities, which may or may not be part of an existing facility complex. This policy is applicable to all sites for proposed capital projects and proposed leased or lease-purchase facilities.

5.5.2 Administrative Requirements

  1. Procedures

    One of the earliest decisions that must be made is the location of the best site for a project among the available options. To provide uniform guidance to assist OPDIVs in selecting deciding the best site, evaluation criteria are developed to help document the site selection process. An analysis of each site should be performed based on the established criteria once the analysis is complete, an evaluation matrix is developed to compare the sites and a report provided to summarize the findings.

5.5.3 Guidance and Information

  1. Laws, Regulations, and Executive Orders

    Among the laws, regulations, and executive orders applicable to the site evaluation/selection process are the following.
    1. Executive Order 12072 - "Federal Space Management of Federal Space," Dated August 16, 1978.- Proposed sites and facilities selected and developed for Federal agencies should consider the effective support of program missions as well as economies associated with efficient facilities management and administration. In the case of proposed development located in urban areas, the Federal agency is also required to coordinate the proposed development with any local, state, and regional plans directed at providing economic and social benefits within the urban metropolitan region.
    2. Executive Order 12372, "Intergovernmental Review of Federal Programs," Revised April 8, 1983. - This Executive Order requires Federal agencies to undertake coordinated planning on an intergovernmental basis with local, regional, and State agencies for Federal actions involving construction and acquisition use and disposal of Federal real property.
    3. National Environmental Policy Act of 1969. (42 USC 4321 et seq.). - The document sets forth the policy and mandatory considerations, including reports, on the planned facility's impact on the human environment. See 10 Safety and Environmental Management.
    4. National Historic Preservation Act of 1966 (16 USC 470 et seq) and Implementation Procedures Contained in Federal Register Vol. 35, No. 23, February 3, 1970, Department of the Interior, National Park Service "National Register of Historic Places." 36 CFR 800 - This document requires evaluation of the effect the proposed facility may have on properties which may be eligible for listing in the National Register of Historic Places and requires that the Advisory Council on Historic Preservation be notified and given reasonable opportunity to comment with regard to the undertaking. See 9 Historic and Archeological Preservation.
    5. Uniform Relocation Assistance and Land Acquisition Policies Act of 1970. (42 USC 4601 et seq.) - This law sets forth the policy for fair and equitable treatment of persons displaced because of Federal and Federally assisted programs.
    6. Executive Order 13690, "Establishing a Federal Flood Risk Management Standard and Process for Further Soliciting and Considering Stakeholder Input" dated January 30, 2015. This EO established the Federal Flood Risk Management Standard (FFRMS), which is a flexible framework to increase the resilience against flooding and help preserve the natural values of floodplains. The EO provides amended guidelines to EO 11988. See 10 Safety and Environmental Management.
    7. Executive Order 11988, "Floodplain Management" dated 24 May 1977. This EO requires federal agencies to avoid construction in floodplains whenever possible. The HHS GAM 30 further requires that proposals for construction in floodplains by OPDIVs obtain the approval of the Secretary (Section 30-20-20D).
    8. Executive Order 11990 dated 24 May 1977. This EO requires federal agencies to avoid construction in wetlands whenever possible. The HHS GAM 30 further requires that proposals for construction in wetlands by OPDIVs obtain the approval of the Secretary (Section 30-20-20D).
    9. Comprehensive Environmental Response Compensation and Liability Act of 1980 (CERCLA) as revised. Section 107 of the Act confers liability for environmentally contaminated real property upon the owner unless certain due diligence actions are conducted prior to acquisition (by whatever means; purchase, donation, transfer, etc.) regardless of actual contribution to the contamination. Section 120 of the Act explicitly subjects the Federal government to the Act. This means that due diligence as prescribed by 40 CFR 312 must be conducted before the acquisition of real property.
  2. Site Selection Criteria
    1. Site Size and Condition
      1. Size: The site should be of sufficient size to accommodate the building, the applicable security (barriers, setbacks, etc.) requirements, landscaping, and circulation space for pedestrians, service vehicles, emergency apparatus or other unique requirements. The site should be expressed in hectares.
      2. Condition: The site should be free of vegetation with blight, dense vegetation, and structures that require demolition.
      3. Configuration: The site should be configured to accommodate the program requirements. Sites with "dog legs" and pipe stems should be avoided, unless there is adequate land to construct the project. Irregular shaped sites should be carefully evaluated.
    2. Accessibility
      1. Vehicular Access: The site should have access to and the ability to accommodate vehicular traffic and parking.
      2. Service Access: The site should have access to and the ability to accommodate service vehicles such as trucks and semi-tractor trailers. The site should be able to accommodate a service apron and the necessary loading docks.
      3. Pedestrian Access: The site should be linked to existing walkways.
      4. Public Transportation: In urban areas the site should be accessible by public bus service, and/or rapid rail service.
    3. Physical Features
      1. Topography: The topography of the site should be as level as possible with positive drainage. Sites with slopes over 15% should be carefully evaluated to determine if they can meet the program needs and if the facility can be constructed economically.
      2. Surface Water: Flood plains, wetlands, and stream buffers must be avoided if at all possible.
      3. Landscaping: Mature trees, ground cover, natural beauty, etc., are considered an asset for the site. Forest conservation and wildlife protection areas should be avoided.
      4. Views and Vistas: Panoramic vistas and pleasant views from the site to urban areas, architecture and/or natural beauty are considered an asset. The opportunity to create a pleasant view of the site or the proposed structure from the surrounding areas is also considered an asset.
    4. Environmental Features
      1. Noise: The site should not be near sources of noise such as highways, power plants, and service areas.
      2. Vibration: The site should not be near sources that may cause excessive vibration such as generators, mechanical rooms, and utility plants.
      3. Air and Water Quality: The site should not be near sources of air or water pollution.
      4. Solid Waste Disposal: Solid waste disposal services should be economically available to the site.
      5. Hazardous Waste Disposal: Hazardous waste disposal capability should be economically available to the site.
      6. Hazardous Waste Contamination: The site should be free of hazardous materials.
      7. Historic Characteristics: The historic and archeological features of the site must be considered.
    5. Integration with the Community's Present and Future Plans
      1. Land Use: The land use of the site should be compatible with the surrounding local land use.
      2. Master Plan: If applicable the proposed use of the site shall be in compliance with the approved OPDIV master plan.
      3. Climate Change: Assess vulnerability of site to changes in tempearature and precipitation and the occurrence of heat waves, floods, droughts, extreme weather, droughts, and wildfires. See Section 10.2 Climate Adaptation and Resilience Planning.
      4. Environmental Justice: Proposed use of site empowers public through improved access to data, research, and information to enable the public to participate meaningfully to address risks and associated environmental exposures. See Section 10.3 Environmental Justice for procedures for incorporation Environmental Justice consideration into specific phases of NEPA.
    6. Utilities: The site should be evaluated as to the availability and adequacy of the utilities as well as the potential to run utilities to the site in an economically feasible manner.
      1. Water: Adequate water service, supply or storage should be available for domestic and firefighting needs. Adequate water pressure at the site should be available for firefighting.
      2. Storm Drainage: The site should have adequate surface run off or underground storm sewers. The proposed facility should not be impacted by storm drainage from other sites "upstream" nor should the facility impact other sites "downstream".
      3. Sanitary Waste Disposal: In developed areas adequate sanitary sewer should serve the site. In undeveloped areas the site should have access to onsite waste disposal systems, or the site should have the capability to develop an onsite sewage treatment system.
      4. Natural Gas: In urban areas the site should be served by natural gas.
      5. Electric and Communications: The site should be served by electrical power and communications systems.
    7. Site Development Cost
      1. Site Clearing: The cost of clearing and grubbing the site should be minimal.
      2. Site Grading: The cost for grading the site should be minimal.
      3. Site Improvements: The cost of bringing roads and utilities to the site should be minimal. The cost for developing on site water and sewage treatments systems should be evaluated.
      4. Relocation of Infrastructure: The cost of relocation of infrastructure should be minimal.

5.6 Space Acquisition

5.6.1 Policy

HHS promotes occupant health and wellness in all its workplaces as it strives to lessen negative impacts of its operations through science-based approaches that enhance human health and well-being.

Executive agencies must promote the optimum use of space for each assignment at an economical cost to the Government, provide quality workspace that is delivered and occupied in a timely manner, and assign space based on mission requirements (FMR §102-79.20).

HHS space acquisition policy follows the FMR, Subchapter C—Real Property, Part 102-73—Real Estate Acquisition.

5.6.2 Administrative Requirements

  1. Authorities and Responsibilities
    1. OMB Reduce the Footprint Implementation Memorandum

      OMB Memorandum M-12-12 Section 3: Reduce the Footprint (RTF) requires that agencies not increase their domestic inventory of owned and leased office and warehouse space, compared against its 2015 baseline, by offsetting any growth in total space with other corresponding reductions identified in component 5-Year Timelines.
    2. Update to Data Center Optimization Initiative (DCOI)

      All proposed or significant expansions to existing agency owned data centers (including rooms) must receive approval from Office of Management Budget per OMB Memorandum M-19-19.
    3. Housing Plan Approval

      All space acquisitions must be approved by the HHS Senior Real Property Officer (SRPO) with concurrence by the office of the Assistant Secretary for Financial Resources (ASFR) prior to initiating acquisition. This requirement is not applicable to tribally operated facilities.
    4. Procedures
      1. Utilization Rates

        Utilization rates (UR) for office and office support, laboratory, laboratory support, and laboratory-related office space are based upon usable and shared space for which the tenant is charged rent. URs do not establish an entitlement, but a maximum allowable rate.
        1. Office: UR is 170 USF per seat based on frequency an employee reports to the office outlined in Table 5-2: 21st Century Workspace Planning Policy for Administrative Space.
        2. Laboratories: UR must not exceed space utilization targets as specified in the HHS Real Property Capital Plan.
        3. Utilization Rate Calculation: the ratio of the total number of occupants to the total USF of office and office support space, or to laboratory, laboratory support and related office space - plus a prorated portion of shared space, if any.
        4. Utilization Rate Relevant Documents
          1. ASA Policy Issuance: Space Acquisition Policy for HHS-Occupied Facilities (March 2016)
          2. ASA Policy Issuance: 21st Century Workspace Space Planning Policy (2/18/22)
          3. HHS Final Freeze the Footprint Plan, FY 2013 - 2015 (9/9/2013).
          4. 5.3 Real Property Acquisition Planning
          5. HHS Human Resources Manual HHS Instructions 990-1.2 Department of Health and Human Services Telework Program Policy (November 18, 2011).
          6. Office and Management and Budget (OMB) Management Procedures Memorandum 2015-01, Implementation of OMB Memorandum M-12-12 Section 3 - Reduce the Footprint (March 25, 2015)
          7. OMB Memorandum for Chief Information Officers of Executive Departments and Agencies, Update to Data Center Optimization Initiative M-19-19 (June 25, 2019)
          8. National Business Space Assignment Policy, GSA Public Buildings Service, Office of Real Property Asset Management (July 2017)
          9. GSA Pricing Desk Guide (PDG), 5th Edition (Revised: November 16, 2019)
          10. Federal Real Property Council Guidance For Real Property Inventory Reporting, (Current Version)
          11. Office of Personnel Management (OPM) guidance to Federal agency staff responsible to implement the Telework Enhancement Act of 2010
          12. Executive Order (EO) 13327 Federal Real Property Asset Management (2003)
          13. EO 14057- Catalyzing Clean Energy and Jobs through Federal Sustainability (2022)
      2. New and Current Data Center Approval
        1. Submit approval requests to the HHS Senior Real Property Officer (SRPO).
        2. To request such approval for a new or significant expansion to an agency owned data center, Divisions are to submit to the at PSC/RLO/RPMS mailbox a written justification that includes the following:
          1. An analysis of alternatives, including opportunities for cloud services, shared services, and third-party colocation.
          2. Explanation of the net reduction in the Divisions' data center inventory that will be facilitated by the new or expanded data center
        3. The development freeze does not apply for new and current data centers as described in M-19-19 under the "Key Mission Facilities for Data Management" section.
      3. Housing Plan review and Approval
        1. Submit approval requests to the HHS Senior Real Property Officer (SRPO).
        2. Approval Requests must include:
          1. Memorandum signed by the Component Executive Officer or Director of Facilities (to request a template, contact PSC/RLO/RPMS mailbox, including a description and justification of the acquisition, costs, a housing plan showing the existing and proposed space or design capacity and staffing, overall UR or percentage of utilization, and a statement of compliance with:
            1. OMB Reduce the Footprint Implementation Memorandum (03/25/2015)
            2. HHS utilization rate for office or laboratory space
            3. Component 5-Year Timeline
            4. Component Data Center Consolidation Plan
          2. For Office and Laboratory Space: (to request a template, contact PSC/RLO/RPMS mailbox)
        3. SRPO requests for additional information (if required) will be made within one week of receipt of Housing Plan Approval Request.
        4. Complete submissions will be reviewed within three weeks of receipt, subject to ASFR review and concurrence.
        5. HHS Submission Schedule:
          1. Federally Owned Space: 24 months before OA expiration.
          2. Leased Space: 36 months before lease expiration.
        6. Upon occupancy, submit an electronic copy of the final OA, inter-agency agreement, or lease to the SRPO.
      4. Project Revision Approval Requirements
        1. Housing plan scope or budget increases of over 10% must be reviewed and approved by the SRPO prior to proceeding.
        2. Submit an explanation of proposed increases to SRPO staff prior to submission of revised Approval Request documents.
        3. After SRPO staff review, submit a summary of staff discussions or revised Approval Request documents to the SRPO.
      5. Waivers

        Freeze-the-Footprint (FTF) waivers will be considered where additional space is required to carry out new, statutory, mission-related mandates and no offsets are available.
        1. UR and sole source (succeeding lease) waivers will be considered where, as specified in the GSA Leasing Desk Guide, the contracting officer:
          1. Determines that the asset contains unique, mission-related space;
          2. Cannot identify other, potentially acceptable locations in the market;
          3. Documents through a cost-benefit or business case analysis that accepting a non-compliant UR or remaining in the existing space results in substantial cost savings to the Government as compared to other offers;
          4. Identifies unique architectural features that cannot be altered to achieve compliance, such as property listed or eligible for listing on the National Register of Historic Places.
        2. Warehouse waivers will be considered for assets less than 10,000 USF which do not increase the inventory.

5.6.3 Guidance and Information

Federal agencies must utilize a comprehensive, multidisciplinary approach to developing workspace and work strategies that best support the organization's strategic business goals and work processes, and that have the flexibility to accommodate the changing needs of the occupants and the organization, in accordance with the Federal Management Regulatio, Subchapter C-Real Propert, Part 102-79.105/110/111, the Integrated Workplace.

  1. Private Offices:
    1. Exceptions to the utilization rate are guided by 21st Century Workplace Planning Policy. Where waivers are required contact the SRPO.
    2. Private conference rooms, toilets, sinks, showers, kitchen, and dining areas are not authorized.
  2. Health promoting and productive workplaces:
    1. Access to daylight:
      1. Access to daylight must be provided and maintained for all employees.
      2. Where mission requirements preclude daylighting (e.g., certain laboratories), access should be provided in a common area, such as a break room.
      3. If an office does not have access to day light (i.e., skylight), Private offices and/or conference rooms located at exterior windows must have clear glass interior walls to provide daylight to interior work areas that would otherwise not have access to daylight.
    2. Visual Privacy: If an office does not have access to day light (i.e., skylight), clear glass office walls or workstation panels may be frosted up to 33% of area to provide visual privacy.
    3. Acoustical Comfort:
      1. Workspaces should use an integrated approach to reducing sound distractions and enabling speech privacy without impairing the benefits of interaction.
      2. Incorporate spatial factors and technologies into an overall approach to achieve acoustic comfort and to support the work of the office.
    4. Resources for compliance:
      1. For HHS Office Design Guidelines, contact PSC/RLO/RPMS mailbox
      2. GSA Total Workplace Program Website
      3. GSA "Sound Matters: How to Achieve Acoustic Comfort in the Contemporary Office" (December 2011)
      4. GSA Circulation Defining and Planning (May 11, 2012)
      5. GSA Total Workplace Standards Benchmarking (March 6, 2012)
      6. GSA Total Workplace Scorecard (9/26/13)
      7. GSA-CDC Fitwel Building-Certification Program Website
      8. Whole Building Design Guide - Design for the Changing Workplace Website

5.6.4 Reporting

  1. OMB RTF 5-Year Timeline

    Submissions must be in accordance with the latest component Five Year Timeline (5YTL), which contains information on all anticipated facility actions for a 5 year period, including: lease or occupancy agreement acquisition, replacement, termination, or changes; and owned asset acquisition, modification, demolition or disposal.

5.7 Definition of Building Areas and Spaces

5.7.1 Policy

The purpose of this section is to provide uniform definitions of building areas and spaces used in planning and programming. Building areas and their measurement methods should follow the GSA National Business Space Assignment Policy (NBSAP) applications for Federal Owned and Leased Buildings. Building spaces should follow the NBSAP Space Assignment Room Name Application and Definitions.

Planning and programming documents should utilize the three standard categories of: Gross area, Rentable area and Usable area as applicable. These three standard area categories shall be used in determining maximum limits for the projects, and if proposed concepts and schematics conform to those limits.

This section only addresses the three standard area categories used in planning and programming documents and related budget justifications. However, it should be noted that additional categories also may be used in internal facilities documents and practices; some Divisions include "net assignable" or "departmental gross" space categories as part of their facilities documents and daily practices, however, these internal categories are not an acceptable replacement for the recommended three standard categories.

Any exceptions to the provisions of this section as it pertains to building areas and spaces must be approved in writing by PSC/RLO/RPMS.

5.7.2 Guidance and Information

  1. Refer to the GSA National Business Space Assignment Policy (NBSAP) Space Assignment Room Name Application and Definitions.
    1. Grossing Factors

      Grossing factors are important in developing budgets for construction and determining planning efficiencies. The cost of a building is not based on the usable area but on the gross area of the building. Grossing factors are multipliers applied to usable area to plan and determine gross area. Grossing factors are based on internal circulation patterns, interior partitions, exterior walls, utility distribution, mechanical equipment configuration, etc. The following table synopsizes ranges of grossing factors used for HHS facilities and space.
Table 5-1: Grossing Factors for HHS Facilities and Space
Functional Area Grossing Factors
Administration/Office 1.25 -1.33
Cafeteria 1.33
Credit Union 1.33
Hospitals Inpatient Services Acute Care Nursing 1.50
Hospitals Inpatient Services Nursery 1.45
Hospitals Inpatient Services Intensive Care; Surgery; Labor/Delivery 1.55
Hospitals Inpatient Services Substance Abuse; Psychiatric Nursing 1.25
Hospitals Diagnostic Services Laboratory 1.30
Hospitals Diagnostic Services Radiology - Diagnostic Imaging 1.45
Hospitals Ambulatory Services Emergency and Urgent Care; Ambulatory Care 1.35
Hospitals Ambulatory Services Community Health 1.20
Hospitals Ambulatory Services Dental Clinic 1.30
Hospitals Ambulatory Services Pharmacy 1.25
Hospitals Ambulatory Services Physical Therapy; Respiratory Therapy 1.30
Hospitals Ambulatory Services Dialysis Treatment 1.25
Hospitals Administrative Services Administration 1.25
Hospitals Administrative Services Health Records 1.20
Hospitals Administrative Services Employee Facilities; Education and Consultation 1.15
Hospitals Administrative Services Public Facilities 1.15
Hospitals Support Facilities Medical Supply 1.15
Hospitals Support Facilities Building Services; Property and Supply 1.10
Hospitals Support Facilities Dietetics Unit 1.20
Hospitals Support Facilities Housekeeping and Linen 1.05
Hospitals Support Facilities Management 1.15
Hospitals Support Facilities Clinical Engineering 1.15
Hospitals Support Facilities Research Laboratory 1.54 - 2.00
Hospitals Support Facilities Special Purpose (Instrument) Laboratory 1.50
Hospitals Support Facilities Animal Research Facilities 1.80 - 2.00

5.8 Utilization Targets for Administrative Space

5.8.1 Policy

The section addresses the revised space planning policy that eliminates the practice of dedicating a seat for all employees regardless of how often the employee reports to the office. The space policy has been revised from 170 usable square feet (USF) per person to a maximum 170 USF per allowed seat as detailed in the 21st Century Workspace Planning Policy issued on February 18, 2022.

Maximum allowed seats are calculated based on the following table:

Table 5-2: 21st Century Workspace Planning Policy for Administrative Space
Category 6 or More Days in Office per Pay Period 5 or Less Days in Office Per Pay Period Full Time Telework (remote work)
Federal Staff 1 seat 0.5 seat 0 seats
Approved Vacancies 1 seat 0.5 seat 0 seats
Contractors 1 seat 0.5 seat 0 seats

Exceptions to the above table are guided by the policy. Any exceptions to the provisions of this section as it pertains to utilization must be approved in writing by PSC/RLO/RPMS.

Utilization targets for spaces other than administrative are found in the HHS Real Property Capital Plan.

5.8.2 Administrative Requirements

  1. Procedures
    1. Approval Process

      This policy establishes a maximum utilization rate of 170 USF per seat based on the frequency an employee reports to work.
      1. Office space requirements for all new or replacement leases or projects in HHS and GSA owned assets, including exceptions noted above, shall be submitted electronically to PSC/RLO/RPMS.
      2. The approval request will be in memorandum format from the Headquarters Facility Director for the HHS Division, explaining the space acquisition and transmitting the mission-based space requirements (housing plan) or program of requirements (POR). This includes the number of persons (see definition); persons added for growth need to be separately identified.
      3. The memorandum should state the current situation, usable and rentable square footage, current number of persons (see definition), lease costs, the lease expiration date, and any special space requirement needs that exist in the space. It is expected that the HHS Division will explain the need for the space, show the amount of new useable space being requested, the number of persons that will be accommodated in the space that will include separately any future planned persons, expected annual lease costs of the new space and finally what the UR for the space will be. See definitions for calculation of the UR.
      4. Upon receipt of the memorandum from the HHS Division, PSC/RLO/RPMS will forward the package to ASFR for concurrent review; approval or a response to the HHS Division will be within a reasonable period of time that will not adversely impact project award or occupancy. In most instances approval or comments will be provided within two weeks.
      5. For new or replacement leases, each HHS Division shall include a housing plan demonstrating the planned UR immediately upon completion of the POR. The POR may be provided in lieu of a separate housing plan if the required information is demonstrated in a summary format.
      6. For building projects in HHS-owned assets, each HHS Division shall include a housing plan demonstrating the planned UR as part of the supporting documentation included with the Facility Project Approval Agreement (FPAA) (HHS Form 300).
      7. If an approved mission requirement, POR or housing plan later requires additional space due to building characteristics discovered during design and layout, an updated memorandum will need to be electronically submitted and an approval granted by the SRPO and ASFR before acquiring, building out, or altering the space.
      8. Whenever an HHS Division knows that a project or building cannot meet the space utilization targets specified in Section 5.8 Utilization Targets for Administrative Space, the HHS Division must submit a waiver electronically to PSC/RLO/RPMS at [email protected] for any lease acquisition, new construction, or improvement project.
      9. Offices currently operating under 3,000 USF and wishing to acquire additional office space through a separate Occupancy Agreement (OA), or where the current OA will be amended to include additional office space must submit an approval memorandum to acquire the additional space when the total combined space exceeds 3,000 USF. Content provided by the HHS Division should follow the guidance in Item 3 of the Approval Process. The document should electronically be forwarded to the PSC/RLO/RPMS mailbox for review and approval.
      10. All like projects and expansions for a specific HHS Division, whether in one location or for contemporaneous or sequential development in several locations, shall be considered as one project. HHS Divisions may not split requirements to avoid obtaining a waiver request. If the UR is exceeded on any portion of a defined project, then a single waiver will be required for all space identified. Like projects and expansions that are necessary to reach a common goal or to support a mission must be presented as a single plan. The following are examples of like projects that should be considered as a single plan:
        1. An existing facility that is being replaced by more than one new facility (e.g., current operation split between current and new facility space); and
        2. Current operations expanding into contiguous available space.
      11. Upon occupancy of all space regardless of size or scope or whether a waiver is required, the HHS Divisions will forward to the PSC/RLO/RPMS mailbox an electronic a copy of the final OA, inter-agency or lease agreement and the office layout of the occupied space in pdf format. In instances where the office space is HHS owned, an office layout in pdf format must still be electronically forwarded. All pdf files should indicate a UR, and break down the types of space and how much space is allocated to each type, i.e., Office, Office Support, Joint Use, etc. The number of persons used for the calculation should be listed. Finally, the actual calculation used to derive the UR should also be included.
    2. Existing Office Asset Utilization
      1. Prior to May 20, 2010 UR Policy: Existing office assets that were considered utilized under the prior HHS UR standard of 215 USF per person shall continue to be considered utilized. Coding will be provided in the Automated Real Property Inventory System (ARIS) database to reflect these assets either met the 215 UR or one of the previous exceptions.
      2. Prior to July 14, 2003 UR Policy: Existing office assets that were acquired prior to adoption of the 215 UR shall be coded Pre-215 UR in the ARIS database.
      3. HHS Divisions shall update their ARIS database to ensure utilization is accurately captured.
      4. Please see ARIS guidance for additional details.
    3. Waiver Process
      1. A waiver is required for office and related space that exceeds the established HHS Utilization Policy. A waiver request will be limited to the following and related scenarios: an office asset with unique mission related space; or when there is only one option due to limited market availability; or where remaining in the existing space is more cost beneficial as demonstrated by a cost benefit analysis or business case analysis.
      2. To expedite an approval to a waiver, once it is known that this maximum UR target level cannot be achieved, a waiver shall be submitted by the HHS Division to the PSC/RLO/RPMS.
      3. The waiver request shall be in narrative format explaining why the utilization rate cannot be achieved, a cost analysis if applicable, and any extenuating circumstances that demonstrate the need or explains the rationale. An example would be remaining in existing space rather than moving to new space. A cash flow analysis showing the net present value of the alternative analyzed should be completed showing that remaining in the larger space is more cost beneficial than relocating or renovating to meet the current UR.
      4. When determining if a waiver request is required for locations where multiple HHS Divisions may be collocated, such as regional offices, the aggregate UR will be calculated first; and then the individual UR of each HHS Division within the aggregate will be evaluated. Each HHS Division exceeding the UR will be required to forward an individual waiver request for their Component's space. Waiver approvals will not be granted on an aggregate basis, each Component's request will be considered on a case- by-case basis.
      5. All waiver requests from regional, district or field units will be routed through the Headquarters Facility Director for the HHS Division to obtain concurrence before the request is routed to PSC/RLO/RPMS mailbox.
      6. Similar to the Approval Process, PSC/RLO/RPMS will forward waiver requests to ASFR for concurrent review. The Department's response to the HHS Division will be within a reasonable period that will not adversely impact project award or occupancy. In most instances concurrence or non-concurrence with comments will be provided within two weeks.

5.8.3 Guidance and Information

  1. General Considerations

    The 21st Century Workspace Planning Policy dated February 18, 2022 provides an avenue to maximize space utilization and significantly reduce rent and rent related costs. Utilizing shared workstations and offices for employees that predominantly telework but report to the office occasionally achieves the 170 USF per seat requirement.

    Space for Continuity of Operations Planning (COOP) should not be a separate area. Wherever possible, conference areas should function to support HHS Divisions COOP activities as emergencies arise. For those situations where HHS Divisions wish to have a separate space for intermittent COOP or emergency operations, a waiver request should be forwarded to the PSC/RLO/RPMS mailbox. COOP space used for daily mission critical operations does not require a waiver request, for example operations centers manned 24/7.

    Consider reducing Administrative Space needs by:
    • Using a reduced peak occupancy rate when calculating support space such as conference, training, and storage areas;
    • Build support space that can be used for multiple-tasks or operations such as a conference room that could serve as touchdown space or training area that can be partitioned at any time to reduce or increase room size; and
    • Review current telework and Alternate Work Schedule policies and where appropriate incorporate into planning process to reduce office space needs.
  2. Future Growth Rates

    Planned office space should not have a significant growth component over present day levels, unless demonstrated in budget documentation. Planned office or cubicle space reduction should align with the 21st Century Workspace Space Planning Policy.

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