ML25071A090
| ML25071A090 | |
| Person / Time | |
|---|---|
| Issue date: | 03/18/2025 |
| From: | Eleni Jernell Office of Administration |
| To: | |
| Shared Package | |
| ML25066A219 | List: |
| References | |
| OEDO-25-00097-ADM | |
| Download: ML25071A090 (1) | |
Text
Nuclear Regulatory Commission Data Quality Improvement Plan 03/31/25 1
Overview NRC does not own or lease any real property; each of the agencys locations are provided through Occupancy Agreements (OA) with the General Services Administration (GSA). NRC occupies 9 buildings in 6 geographic locations consisting of 3 Headquarters office locations, 4 Regional office locations, a small warehouse, and a technical training center. One Headquarters office location is owned by GSA, and the remainder are leased by GSA on NRCs behalf. NRCs relatively small real property portfolio allows for intimate knowledge of each location. In addition, the agency implements a robust and mature real property data quality program to inform real property decisions and ensure the accuracy, completeness, and continual improvement of the data the agency annually submits to the Federal Real Property Profile (FRPP) database (for entry by GSA).
In short, NRC has confidence regarding the accuracy of the agencys real property data and efficacy of its Real Property Data Program including the submissions to the FRPP.
Roles and Responsibilities The agency SRPO, CFO, and Budget Officer are jointly responsible for developing the capital planning process, integrating it into the agency's annual budget formulation cycle, monitoring its execution, and analyzing cost and performance information. The SRPO and CFO are jointly responsible for development of the capital planning process to maximize cost efficiency and mission effectiveness, and to ensure better real property information informs the annual budget formulation process. These three officials also jointly establish annual performance objectives/metrics for the plan to assess whether the agency is progressing towards portfolio optimization and eliminating identified gaps.
NRC Data Quality Program General Real Property Data Management Process The size of NRCs portfolio is small, all changes (reductions or acquisitions) are planned years in advance and effectively tracked across multiple offices. All requests for space acquisition or reductions at NRC headquarters and regional offices, or other changes to the portfolio and processes are reviewed and approved by the NRCs Senior Space Acquisition Manager (SAM) within the Division of Facilities and Security (DFS) under the guidance of the NRC Senior Real Property Officer (SRPO). The SAM verifies the reliability, accuracy, and completeness of space portfolio data by cross-referencing data sets such as the annual FRPP data, the NRCs automated space planning and management system (SPMS) data (powered by Archibus software), and the individual OAs and leases issued by GSA. Periodic reviews and exception processing are conducted by the SAM, additional staff within DFS, and support contractors, while updating utilization metrics and reviewing and approving the rent bill on a monthly basis.
Verification of FRPP Static Data Process All of NRCs real property is occupied via 11 OAs to review for the FRPP submission (9 related to physical building locations, 1 for land, and 1 for parking). The NRC uses several verification procedures to check accuracy and reliability of the data prior to reporting to the FRPP system.
Monthly rent bill data are reviewed and checked against OAs, previous bills, and institutional knowledge of the portfolio. Underlying anomalies are rare and are identified quickly and addressed. The SAM and DFS management meet bi-weekly to discuss a written agenda, which reports the status of all real property issues and projects including any proposed acquisitions or dispositions of excess or surplus properties. These meetings, supported by data from the agency space planning and management system, ensure continuous monitoring of space utilization and early identification of issues and/or opportunities regarding the release of excess or other related reductions. The NRC continues to work with its GSA regional contacts and the National Capital Region team to identify its space release and backfill opportunities. NRC will ensure these interactions with GSA continue to coordinate all space/disposal/backfill activities.
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Verification of Personnel Data and Space Planning and Management System The agency utilizes a variety of independent data sources to collect personnel data on an ongoing basis.
Physical verifications (regular walk-throughs) are conducted throughout the NRC headquarters to determine the occupancy status of each workstation and room. Ongoing space and staffing data are captured within the SPMS. Computer-aided design (CAD) floor plans, including drawings, are updated to reflect modifications to space and workstations, and updates are entered into the agency SPMS. SPMS is automated to collect and cross reference information from the Office of Chief Human Capital Officer (OCHCO) and badge swipe information regarding staffing counts, and workstation occupancy data. This information is entered into the SPMS by contract support, that receives, verifies, and schedules personnel moves on a daily basis or as needed. The Regional locations are considerably smaller than the headquarters location with far less turnover or moves. Regional walk-throughs are conducted periodically and prior to each FRPP submission, then cross referenced with SPMS data and OCHCO data.
List of Data Points and Validation and Verification Methodology As previously mentioned, NRC occupies 9 buildings in 6 geographic locations consisting of 3 Headquarters office locations, 4 Regional office locations, a small warehouse, and a technical training center. With a portfolio of that size, along with the more tangible validation methods (e.g.,
Rent on the Web (ROW), OAs/OASIS, and leases) the agency has intimate information and knowledge regarding its portfolio. NRC does not own or lease any real property; each of the agencys locations are provided through OAs with GSA, therefore the number of data points to be validated, verified, and entered into the annual FRPP submission to GSA are less extensive than that of landholding agencies. The data points provided for NRC to verify and corresponding cross-referencing tools and methodologies for verification and data entry are below:
FRPC Property Type - knowledge of portfolio FRPC Property Use - knowledge of portfolio Owned or Leased Indicator - knowledge of portfolio Location Code - ROW, Lease, and OA Building Name/Address/City/State - knowledge of portfolio and OA OA Number/Lease Number - ROW, Lease, and OA Expiration Date - OA and Lease Useable/Rentable Square Footage - ROW, Lease, and OA OA Annual Rent - ROW Reason for FASTA Disposal Exclusion - knowledge of portfolio Field Office - knowledge of portfolio Suitable for Collocation - knowledge of portfolio Can the Number of Federal Employees be Determined - data collection awareness Number Federal Employees - SPMS Data, Badge Swipes, OCHCO cross-reference Can the Number of Federal Contractors be Determined - data collection awareness Number Federal Contractors - SPMS Data, Badge Swipes Annual Operations Costs - Actual Data from Vendors and Contracts Data Driven Decisions NRC actively tracks its space utilization, occupied, and un-occupied workstations, (the same information annually provided to the FRPC and uploaded into max.gov by GSA on NRCs behalf) at the asset level. NRC uses this information to gauge the current space utilization and utilization rate of each location and to identify potential opportunities to consolidate, re-stack, and release additional space. Using this information, NRC has actively attempted to close the gap between the optimal utilization of space, current workspace design, and staff attrition. The current real property management objective is to reduce the size of the agencys portfolio by
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approximately 30 percent by the end of FY 2026 (as compared to the beginning of FY 2020, this reduction equates to over 320,000 USF) and close the gap between the current daily occupancy percentage and the goal of a minimum of 60 percent occupancy. This decrease in USF is being achieved by consolidating in place, releasing marketable blocks of space, changing the design of our workstations, and reducing the size of regional locations upon lease expirations. By the end of FY 2024, the NRC released over 272,000 USF as compared to FY 2020, with plans to release additional space USF in FY 2026. For example, in 2 of NRCs 4 regional locations the agency has converted space from primarily enclosed offices to a more contemporary cubicle-based design, which will reduce by approximately half both the real property footprint and related costs. The new procurements through GSA have delivered the space upon the termination of the existing leases. Coordination between the Office of the CFO (OCFO) and the SRPO begins two years in advance regarding the budgeting for renovations and the anticipated rent reduction over time.
Performance Goals and Metrics Included each year in the agencys Congressional Budget Justification (CBJ) and the Annual Performance Plan and Report is a section highlighting fiscal year accomplishments for each business line. Due to the NRCs objective to reduce real property costs, each fiscal year the NRC has included the reduction of space as one of the agencys performance metrics and goals. The goals have historically been measured in terms of square feet released, as compared to the prior year or other benchmark (the final size of the portfolio is measured and reported by GSA at the end of each fiscal year) and in compliance with the agencys real property and capital planning strategies.
Gap Analysis The NRC continually evaluates its real property portfolio for opportunities to improve space utilization. To optimize the utilization of space, the agency is actively reducing the gap between the existing number of workstations in comparison to its housing requirements. The NRCs former metric for the utilization rate for new construction was 200 useable square footage (USF) per person. However, the nature and trends of the workplace have changed. The new guidance regarding space utilization is 150 USF per person and to measure occupancy percentages with the overall goal of achieving a minimum average occupancy rate of 60 percent. Therefore, the agency is reassessing how to optimize space utilization while considering mission requirements, available workstations, and actual occupancy (utilizing daily badge swipe data).
Internal Controls All requests involving new leases, dispositions, acquisitions, expansions, or other changes in the agencys office and warehouse space portfolio are reviewed initially by the SAM to ensure compliance with Executive Memoranda and statutory requirements related to reducing the federal real property portfolio and guidance before recommending approval or disapproval to DFS and the SRPO. These reviews are reinforced by the NRCs reliance on GSA-issued OAs, collaboration with GSA, the agencys monthly review of GSA rent bills, and the SAMs review of the NRCs updates of office space occupancy rates.
Data Quality Integrity and Improvement The NRC uses multiple methods to characterize data quality improvements year-over-year to demonstrate improvement of data quality. Rent estimate data provided to GSA is comparatively tracked and evaluated. Data for an expanding list of space metrics is captured, tracked, and evaluated, including on-site employee and contractor staff, on-site occupancy and workstations, private office size and numbers, open workstation size and numbers, total and dedicated conference room size and numbers by building, and space utilization rates by headquarters, regions, and building. In addition, the agency will address and evaluate such items as space
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utilization, workstation standards, workstation configurations, adjacencies, alternative workspace solutions, the standardization of furniture, the enhanced use of technology, and additional energy saving technologies to adapt to the changing work environment.
Improvement Opportunities The primary program improvement opportunities are related to the agencys commitment to improve the utilization rates and percentage of occupancy for both the headquarters and regional office locations in relation to potential gaps that exist in its housing requirements and amount of occupied space. NRC will continue to evaluate the real property data to determine if the opportunity exists to further consolidate and reduce headquarters space in accordance with the Data Driven Decisions above. The NRC is also exploring opportunities to improve the utilization rates and percentage of occupancy in its regional offices through reconfiguration and space reductions as a result of a new more open designs and other right-sizing opportunities as the current leases expire.
Independent Review Due to the relative proportion of costs associated with NRCs real property portfolio in relation to the overall corporate budget, the SAM, DFS, and SRPO routinely collaborate with the OCFO on issues involving real property. Therefore, the independent review of NRCs Data Quality Plan was conducted by the OCFO senior budget analyst assigned to DFS and most familiar with NRCs real property portfolio and related costs.
Third Party Review Analysis In reviewing the NRCs Data Quality Program, the overall process in place appears robust and sufficient for the agency to have confidence in its data quality. However, there are two issues offered for consideration consistent with the feedback from the previous Data Quality Improvement Plan: 1) backup for the SAM and 2) More timely notification of stakeholders and staff. Given the importance of the SAMs role relative to the real property data quality and process, it would make sense to have a qualified backup in case of unexpected situations that might arise, causing the designated individual to be unavailable. Additionally, given that ADM and OCFO know about possible decisions that might affect the agencys staff (e.g., release of floors), it would make sense to add in additional time to involve and inform the senior management, staff, and other stakeholders who occupy the effected space (i.e., not waiting until a given fiscal years congressional budget justification is finalized) to expedite the process. This would allow time to communicate, prepare, and socialize planned changes and moves to the effected parties to avoid delay in moving forward with agency space planning efforts.
Eleni Jernell Acting Director Office of Administration Senior Real Property Officer Signed by Jernell, Eleni on 03/17/25
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SUBJECT:
UPDATED DATA QUALITY IMPROVEMENT PROGRAM GUIDANCE OEDO-25-00097-ADM, DATED:
DISTRIBUTION:
Public (if applicable)
ADM R/F RidsADMMailCenter Resource RidsEdoMailCenter Resource ADAMS Accession Number: ML25071A090 OFFICE ADM/DFS ADM/DFS/DD ADM/DFS/D ADM/D (A)
NAME BMohler BRowhani BThomson EJernell DATE 03/12/2025 03/12/2025 03/13/2025 03/17/2025 OFFICIAL RECORD COPY March 17, 2025