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Chapter 16 – Occupancy Agreements

Volume V - Assets

Date Approved: August 5, 2026

Financial Documents

Volume V - Assets

Chapter 16 – Occupancy Agreements

Questions concerning this policy chapter should be directed to:

1601 Overview

This chapter establishes the Department of Veterans Affairs’ (VA) financial policy for occupancy agreements (OAs).

Key points covered in this chapter:

  • VA will use OAs to document all financial terms and conditions associated with VA’s use of General Services Administration (GSA) controlled space;
  • All OAs must receive approval through the Strategic Capital Investment Planning (SCIP) process;
  • Office of Asset Enterprise Management (OAEM) will provide the Capital Asset Inventory (CAI) Real Property Unique Identifier (CRPUID) for OAs; and
  • VA will comply with the Statement of Federal Financial Accounting Standards (SFFAS) 54 and Office of Management and Budget (OMB) Circulars A-11 and A-136 as they relate to OAs.

1602 Revisions

SectionRevisionOfficeReason for ChangeEffective Date
VariousNew ChapterOFPTo provide financial guidance on occupancy agreementsJuly 2026

1603 Definitions

Accounting Classification Code (ACC) – A nine-digit character code defined in the Financial Management System (FMS) and established for each budget fiscal year. FMS contains information on standard ACCs used by more than one station and non-standard codes that are used by a single station. Users may identify the standard ACCs by an asterisk in the Station field.

Capital Asset Inventory (CAI) – VA’s enterprise-wide repository of information on the Department’s real property assets, including leases, Enhanced-Use Leases, agreements, buildings, land, structures, facility condition assessments data, and other asset information for the portfolio. Information in CAI is used by OAEM and other Staff Offices to record and track VA’s capital assets including real property agreements.

CAI Real Property Unique Identifier (CRPUID) – A unique identifier generated by OAEM used to track real property agreements and their associated costs. The unique ID begins with the prefix ‘LG’ for leases and OAs. The CRPUID is recorded and stored in the CAI database as the accounting classification code (ACC).

Federal Real Property Profile (FRPP) Management System – An online software application created in accordance with Executive Order 13327 “Federal Real Property Asset Management” to be the Federal Government’s centralized database of all real property under the custody and control of all executive branch agencies, except when otherwise required for reasons of national security.

G-Invoicing – Treasury’s long-term solution for buy/sell transactions, that will allow federal agencies to initiate payments and to manage the receipt and acceptance of General Terms and Conditions (GT&C), orders, and performance.

GSA Bureau Code – Also known as an Agency Bureau (AB) code, is a unique four-digit identifier assigned to each Federal agency and bureau by the GSA, used internally and by the Office of Management and Budget (OMB) for managing and tracking Government operations. All VA Bureau Codes begin with the prefix “36.”

Intragovernmental Lease – A lease, as defined by SFFAS 54, between Federal entities documented via an interagency agreement. Federal real property terms ‘Permit’ and ‘Occupancy Agreement’ are commonly used to describe interagency or intragovernmental leases. However, the term ‘Intragovernmental Lease’ is used throughout this policy chapter.

Intragovernmental Leasehold Reimbursable Work Agreements –Agreements whereby one reporting entity (the provider-lessor) acquires, constructs, improves, and/or alters an underlying asset that is or will be leased to another reporting entity (the customer-lessee) and the customer-lessee agrees to reimburse the provider-lessor for direct and indirect costs for the acquisition, construction, improvement, and/or alteration. These reimbursable costs are beyond what may be included in the tenant improvement allowances of the lease agreement for the related underlying asset.

Intra-Governmental Payment and Collection (IPAC) –Payment and collection mechanism for the transfer of funds across Federal Program Agencies (FPAs) for goods and services (i.e., buy/sell transactions), fiduciary transfers (i.e., investment and borrowing transactions), Federal employee benefits data and check aftermath activity.

Lessee – The entity that enters into a lease contract to obtain the right to use an underlying asset for a period of time in exchange for consideration. Also known as the tenant.

Lessor – The entity that enters into a lease contract to provide the right to use an underlying asset for a period of time to a lessee in exchange for consideration. Lessor is also known as the landlord.

Liability – A probable future outflow or other sacrifice of resources because of past transactions or events.

Occupancy Agreement (OA) – A written agreement descriptive of the financial terms and conditions under which GSA assigns, and a customer agency occupies, the GSA-controlled spaced identified therein with a unique OA number assigned by GSA. An OA is an administratively binding assignment of space. OAs can be either cancelable or non-cancelable.

Occupancy Agreement Space Inventory System (OASIS) – GSA’s Occupancy Agreement and Space Inventory System that replaces GSA’s legacy OA and drawing systems, as well as eOA, the system many customers used to view billing OAs. OASIS provides an integrated, trackable, and accessible process for GSA and customer agencies to manage, review and approve OAs, process releases of space, and access real time occupancy and rent data. OASIS provides customers with the ability to view and download rent data, view the modification history of OAs, submit questions to GSA about rent bills, and is the official process for submitting all release of space requests. OASIS also provides the ability to track the approval and timeline of the release of space requests.

Public Buildings Service (PBS) – GSA’s division that contracts for the design, construction, and operation of Federal civilian buildings. PBS provides workspace primarily with courthouses, land ports of entry, and Federal office buildings. It ranks among the largest holders of real estate in the United States.

Real Property –Land, buildings, facilities, or other structures, firmly attached, including integrated equipment (i.e., items permanently installed or attached that have become a part of the building or structure for the purpose of making the building habitable or usable). Executive Order 13327 defines Federal Real Property as any real property owned, leased, or otherwise managed by the Federal Government, including improvements on Federal lands irrespective of the property’s location.

Strategic Capital Investment Planning (SCIP) – A Department-wide annual process that integrates planning for major construction, minor construction, non-recurring maintenance (NRM) and leasing programs. The SCIP process results in two primary annual planning products: a comprehensive long-range action plan, consisting of specific capital investments necessary to address infrastructure performance gaps in safety, security, access, condition, utilization and space to improve the quality, access and cost-efficiency of the delivery of VA benefits and services over a 10-year period; and a prioritized list of projects used to create the fiscal year’s capital budget.

Tenant Improvements –The finishes and fixtures that transform space from its shell condition to a finished, usable condition.

1604 Roles and Responsibilities

Secretary of Veterans Affairs (SECVA), in accordance with VA Directive 7815, is responsible for approving VHA OAs that exceed the dollar threshold of “major medical facility lease” as defined in 38 U.S.C. § 8104 (a)(3)(b) and for the approval of space additions to the VA Central Office space inventory inclusive of OAs.

Assistant Secretary for Management/Chief Financial Officer (ASM/CFO) oversees management of all financial and capital asset activities.

Administrations and Staff Offices are responsible for identifying the need for leased space, submitting a business case to the Office of Asset and Enterprise Management (OAEM) for approval, for recording and monitoring occupancy agreement obligations in VA’s accounting system, and for coordinating with Financial Services Center for reconciliations of occupancy agreement transactions.

Deputy Assistant Secretary for Administration is delegated responsibility for acquisition and oversight of all VA Central Office space in the GSA National Capital Region, inclusive of OAs.

Office of Acquisition, Logistics and Construction (OALC) is responsible for the direction and oversight of construction and facilities management.

Office of Construction & Facilities Management (CFM), Office of Real Property (ORP) is responsible for managing VA’s real property leasing program in accordance with 38 U.S.C. § 312A. CFM ORP is also responsible for management and oversight of VA’s real property programs, including development of policies, providing oversight of real property services, executing non-delegated land management activities, serving as VA’s Leasing Head of Contracting Activity (HCA), and executing Mid-Level and Major Leases. ORP is an office within CFM that oversees administration of lease acquisition for medical, office and research facilities, assists General Services Administration (GSA) in the execution of leases, and reviews GSA’s lease documents for VBA leases.

Human Capital Services Center/Operations, Security, and Preparedness (HCSC/OSP), Office of Administration’s Space and Renovations Service is responsible for workspace assignments at VA’s Central Office and within the National Capital Region and for working with GSA to obtain the required space if a request for additional space cannot be accommodated in existing VACO leased space.

Office of Asset and Enterprise Management (OAEM) is responsible for overseeing the SCIP process, managing the Capital Asset Inventory (CAI) system, managing VA’s capital asset portfolio, acting as the liaison between VA’s contracting offices and GSA, and overseeing the delegation program with GSA. OAEM is the CAI system owner tracking all existing real property agreements. OAEM is responsible for assigning a CAI Real Property Unique Identifier (CRPUID) to every lease.

Director, Veterans Affairs Medical Center (VAMC), Veterans Integrated Service Network (VISN), or independent VA outpatient clinic, in accordance with VA Directive 7815, have the responsibility and authority to approve lease procurements meeting but not exceeding the dollar threshold of major level leases such as a “major medical facility lease” as defined in 38 U.S.C. § 8104. In addition, the director or appropriate designee will review and sign the Occupancy Agreement (OA).

Facility Manager/Engineer, or designee is responsible for entering and maintaining real property agreement data in the CAI database, requesting an ACC, revenue source code, or CRPUID from OAEM, coordinating with the local finance office to ensure that agreement information is processed in VA’s accounting system, and certifying on an annual basis that real property data in CAI is up-to-date and accurate.

Local Finance Offices are responsible for reviewing and confirming availability of funds to support a lease and associated build out costs, reviewing OAs, ensuring unique identifiers are correctly assigned to OAs, and for coordinating with local facilities management or engineering offices to update CAI for new and expiring leases.

Financial Services Center (FSC), in coordination with the applicable VA Administrations and Staff Offices, is responsible for the reconciliation of intragovernmental  transactions that include OAs meeting the definition of an intragovernmental lease per SFFAS 54.

1605 Policies

160501 General Policies

  1. In accordance with 38 U.S.C. § 8103, VA will execute occupancy agreements (OAs) for VA-controlled or leased space through the General Services Administration (GSA). VA will work with GSA to obtain space to support the effective management, utilization, and accountability of VA real property assets.
  2. VA will adhere to GSA requirements when obtaining leased space, those requirements include but are not limited to:
    • 41 CFR Part 102-85 – Ensure occupancy agreements are properly approved and executed, adhere to terms and conditions of the occupancy agreement, and report occupancy and utilization rates for leased space.
    • GSA Occupancy Agreement Space Inventory System (OASIS) Customer guide – Complete the GSA Public Buildings Service (PBS) OASIS Customer Access Request Form for new user access and be authorized by VA’s Internal Authorizing Official (CIAO) and comply with OASIS system rules (i.e., OASIS Users must maintain a valid Login.gov account, complete an annual recertification, and adhere to updates and notices to maintain system privileges);
  3. Administrations and Staff Offices will adhere to VA Directives 0011, 7815, and 7816 when a need arises for space.
  4. VA will ensure OAs include financial terms and conditions, are approved prior to execution, are recorded in VA’s systems of record and are necessary to accomplish its mission.
  5. VA will negotiate General Terms and Conditions at the Department level, for a period of performance of 10 years, and will modify or renew as needed.

160502 Identification and Approval of Occupancy Agreements

  1. In accordance with VA Directive 0011, Administrations and Staff Offices will identify space needs through the Strategic Capital Investment Program (SCIP) process, which provides a structured methodology for creating business cases (the set of reasons, benefits, and strategic advantages that justify the need) for space and prioritizes VA’s capital projects annually.
  2. Administrations and Staff Offices will ensure the following occurs prior to space requests being initiated with GSA:
    • SCIP approval or documented OAEM out-of-cycle approval (for project gaps or needs outside of what was initially planned); and
    • Completion of GSA Standard Form 81 (SF-81), Request for Space.
  3. A request for space will be entered into the GSA Occupancy Agreement Space Inventory System (OASIS) by the Administration or Staff Office needing the space.
  4. Requests for space, in OASIS, must be approved by the VA individual who is authorized to execute OAs under the appropriate GSA VA Bureau Code, which will begin with the prefix “36,” and is designated as an “Ordering Official” (an approver) in OASIS.
  5. After VA approves the OASIS request, GSA will find, assign and release space to VA.
  6. In accordance with the lease agreement, space will incur a charge (rent) that will be billed through OASIS for approved/executed OAs.
  7. When a space request is approved in OASIS, VA must fund any rent due for the current fiscal year or continuing resolution period. For future fiscal years, VA must make a good faith effort to obtain funding for approved OAs through the budget and appropriations processes.
  8. Fully executed OAs will be forwarded to the FSC for review and entry into the agreement repository, CAI. For additional information on how VA enters OAs in CAI and coordinates these agreements, refer to Appendix A: Entering and Coordinating Occupancy Agreements.

160503 Recording Occupancy Agreements

  1. VA will record obligations for OAs, in accordance with 31 U.S.C. § 1341 and OMB Circular A-11. For additional information on obligations, see Volume III, Chapter 2 – Obligations. Specifically, individual OA obligations will be established and funded for each fiscal year covered by the agreement. VA will not record a lump sum covering the entire agreement amount in any single fiscal year regardless of funds availability.   
  2. In accordance with SFFAS 54, VA will record OAs as intragovernmental leases, whereby a contract or agreement occurs within or between another Federal entity as defined by SFFAS 47.
  3. In accordance with SFFAS 54, VA will recognize prepaid rent or a payable for rent due as an asset or liability, respectively, and an expense should be recognized in the appropriate reporting period based on the specifics of the occupancy agreement provisions.
  4. Administrations and Staff Offices that have OAs will monitor occupancy agreement obligations and payment transactions and adjust/correct them as required.
  5. VA (as the lessee) will not recognize amortization expenses related to a leased asset or interest expense on a lease liability.
  6. VA will use CAI to track and manage OAs. OAEM assigns every OA a CRPUID that is used to track OAs in CAI. The CRPUID will begin with “LG” for every OA where VA is the lessee.
  7. VA will record the CRPUID in the Accounting Classification Code (ACC) field within the Financial Management System (FMS) and in the Lease Agreement Number field in the Integrated Financial and Acquisition Management System (iFAMS). For additional information on how occupancy agreements are tracked in VA’s accounting systems, refer to Appendix B: Tracking Occupancy Agreements in FMS and Appendix C: Tracking Occupancy Agreements in iFAMS.

160504 Intragovernmental Leasehold Reimbursable Work Agreement or Reimbursable Work Authorization (RWA)

  1. VA may incur additional costs associated with OAs under an intragovernmental leasehold reimbursable work agreement or Reimbursable Work Authorization (RWA).
  2. In accordance with FASAB Technical Bulletin 2023-1, SFFAS 6, and SFFAS 54 paragraph 27, VA will recognize an intragovernmental reimbursable work asset for the amount payable for reimbursable work acquisition, construction, improvement, and/or alteration costs for RWAs as a prepaid rent asset.
  3. In accordance with FASAB Technical Bulletin 2023-1, VA will, when capitalization requirements are met, amortize the intragovernmental reimbursable work asset in a systematic and rational manner over the shorter of (a) the remainder of the lease term or (b) the useful life of the underlying asset acquired/constructed, or improvements/alterations thereto associated with the reimbursable work.
  4. VA will obligate RWA costs on a fiscal year basis and will ensure RWAs are tied to the applicable OA using the CRPUID. All RWAs will be forwarded to the FSC for review and entry into the agreement repository.

160505 Payments for Occupancy Agreements

  1. In accordance with SFFAS 54, as the lessee, VA will recognize OA rent payments made to GSA as expenses.
  2. VA will record Intragovernmental lease OAs expenses in the period incurred using the budget object class codes 2311 for FMS and 231001 for iFAMS. See Volume XIII, Chapter 2 – Budget Object Class Codes for additional information.
  3. VA will commence monthly or annual lease payments only after:
    • The completion of any build outs and leasehold improvements are substantially complete and operationally functional; and
    • The completion of a walk through with GSA before the space is accepted as substantially complete.
  4. VA will use G-Invoicing to establish agreements and account for and pay OA related rental fees. See Volume XI, Chapter 7 – Buy/Sell Transactions (G-Invoicing) and Treasury Financial Manual Volume I, Part 2, Chapter 4700, Appendix 8 for more information.
  5. GSA will submit a bill for rental fees monthly through G-invoicing. VA will review the monthly bill and will provide updates and corrections to GSA within 7 days.
  6. VA will recognize OA payments, including related operating costs (for example, maintenance, utilities, taxes, etc.) paid to GSA, as expenses.

160506 Occupancy Agreements Reporting

  1. VA will report OAs with GSA as intragovernmental leases for financial reporting purposes in accordance with OMB Circular A-136.
  2. VA will present and disclose OAs as intragovernmental leases in accordance with SFFAS 54 and OMB Circular A-136.
    • Applicable information included for note disclosure will be provided by OAEM such as:
      • The number of existing OAs VA has with GSA;
      • The number of VA cancellable and non-cancellable agreements;Information regarding VA’s heritage asset data; and
      • Other numbers or counts regarding real property data that would change from year to year.
  3. See Volume V, Chapter 10 – Accounting for Leases for further information on financial reporting and disclosure of lease activities.
  4. VA will provide required OA data to GSA for Federal Real Property Profile Management System reporting by December 15th of each year.

1606 Authorities and References

1607 Rescissions

None.

Appendix A: Previous Policy Revisions

None.

Appendix B: Entering and Coordinating Occupancy Agreements

  1. VA will enter OAs into CAI as follows:
    1. The VA entity, usually the Organization (i.e., station), will enter the OA into CAI and ensure the terms of the agreement are accurately captured and that the proper VA GSA Bureau Code is being assigned.
    2. Once the agreement has been fully executed and then uploaded into CAI, CAI will generate a unique identifier number (CRPUID) for the OA.
    3. A copy of the fully executed agreement and the CRPUID will be provided to the Local Finance Office for entry into VA’s accounting system.
    4. When OAs are not active or operational, it is the responsibility of the Organization (i.e., station) to update the Agreement’s status from “Operational” to “Inactive” in CAI.
  2. VA will coordinate GSA’s OAs for non-VACO spaces as follows:
    1. VA entities (i.e., non-medical space is needed) approved by the SCIP process will first seek availability of GSA managed space.
    2. The VA entity will initiate the space request directly with GSA by completing and submitting Standard Form 81 (SF-81), Request for Space.
      1. In accordance with 38 U.S.C. § 8104, the Under Secretary, Assistant Secretary, or Other Key Official may approve the GSA SF-81 form and transmit to GSA for non-VHA space with a cost under the major medical facility lease threshold. The Under Secretary for Health has delegated this authority to Directors of the VAMC, VISN and independent VA outpatient clinic for VHA.
      2. In accordance with 38 U.S.C. § 8104, for space in excess of the major medical facility lease threshold, the Executive Director of Construction & Facilities Management (CFM) will approve all GSA SF-81s.
    3. The OA authorizes GSA to obtain space through a space assignment from Federal buildings within GSA’s inventory or to arrange for a lease of commercial space not owned by GSA.
    4. GSA will assign space to the requesting entity and both parties will sign the OA after obtaining approval.
    5. The OA will be signed by the VA individual with the appropriate authority to execute the document, or designee.
    6. The local finance office will coordinate with the local facilities management or engineering offices to update Capital Asset Inventory (CAI) with all pertinent agreement information including the OA number, and the CRPUID as the unique identifier and will upload a copy of the fully executed OA into CAI.
    7. All fully executed OAs will be forwarded to FSC. FSC will review and load OAs into the agreement repository.
    8. VA will record an obligation with GSA once an OA has been signed by GSA and VA using the OA number as the unique identifier for VA’s  accounting system.
    9. VA will reimburse GSA when space is used during non-standard working hours (evenings and weekends), which may result in additional charges to operate the facility. The VA office occupying the space is required to establish a RWA with GSA to cover those additional costs. Those costs may include utilities, security or other costs deemed necessary to operate the space during non-standard hours.
  3. VA will coordinate OAs for VACO space in the National Capital Region as follows:  
    1. VACO Offices approved for additional space through the SCIP process will submit an approval request to the Office of Administration, Space and Renovations Services.
    2. Space and Renovation Services has the responsibility to work with GSA to obtain the required space if a request for additional space cannot be accommodated in existing VACO leased space.
    3. All additions to the VACO space inventory will be approved by SECVA and if the lease meets designated thresholds, VA will obtain Congressional approval and notification. 
    4. Space and Renovations Services will coordinate with the VACO Offices to update CAI with all pertinent agreement information, including the OA number, to upload the fully executed OA into CAI and to continuously update the use of space by VA Administrations and Staff Offices within CAI for each OA.

Appendix C: Tracking Occupancy Agreements in FMS

  1. VA’s Financial Management System (FMS) uses CRPUIDs to track OAs. The following steps will be used to assign the CRPUID to OAs:
    1. The ACC is the FMS data attribute that serves as the unique identifier for all OAs in FMS. OAEM assigns a unique CRPUID, entered into FMS as the ACC, that begins with “LG” for every OA where VA is the lessee.
    2. All new and existing OAs for Administrations using FMS must have a CRPUID which will remain the same throughout the life of the occupancy agreement term and any extensions.
    3. The local finance office, budget office or equivalent, of the leasing entity will submit CRPUID request forms to OAEM through the centralized VA Lease ACC mailbox via leaseac.codes@va.gov.
    4. OAEM will review OAs ACC request forms and assign a CRPUID to each individual lease.
    5. Once the CRPUID is established, the local finance office will coordinate with Facilities Management (or the engineer) who has the responsibility to input the remaining asset data into the Capital Asset Inventory (CAI) database.
    6. Each individual lease is an asset and is tracked by OAEM within CAI.
  2. Facilities Manager/Engineer or designee updates and maintains the real property agreement status by following the steps below:
    1. If there are any amendments, the amendments will be uploaded into CAI.
    2. When an OAs is no longer active or operational the agreement’s status will have to be changed from “Operational” to “Inactive” in CAI.
    3. A copy of the real property termination amendment will be provided to the local finance office when an OA is no longer active or operational.
  3. VA will use BOC code 2311, Real Prop Rental – GSA, when recording charges for OAs in FMS.

Appendix D: Tracking Occupancy Agreements in iFAMS

  1. For Administrations using VA’s new accounting system, iFAMS, VA is responsible for monitoring and managing OAs by following the steps below:
    1. The Organization (i.e., station), will enter the OA into CAI and ensure the terms are accurately captured in CAI. The CRPUID is the agreement number generated within CAI once the agreement has been fully executed.
    2. The Facilities Manager/Engineer or designee is not required to upload the Agreement in CAI.
    3. The agreement number/CRPUID will be provided to the local finance office for entry into iFAMS.
    4. A copy of the fully executed agreement will be provided to the local finance office.]
  2. Facilities Manager/Engineer or designee updates and maintains the real property agreement status by following the steps below:
    1. If there are any amendments, the amendments will be uploaded into CAI.
    2. When an OA is no longer active or operational, the agreement’s status will be changed from “Operational” to either “Closed/Expired” or “Terminated” if the OA has been cancelled prior to its expiration date in CAI.
    3. A copy of the real property termination document will be provided to the local finance office and uploaded to the CAI record when an OA is no longer active or operational but prior to the status change from “Operational” in CAI.
  3. VA will use BOC code 231001, Real Property Rental – GSA, when recording charges for OAs in iFAMS.

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