GENERAL SERVICES ADMINISTRATION
Washington, DC 20405
December 16, 2020
Revised
GSA Fitness Center Services Policy
SUBJECT: Fitness Center Services Policy
1. PURPOSE: This document replaces the previous Fitness Center Services Policy. It outlines the role of
customer agencies and GSA in establishing, operating and maintaining Fitness Center (FC) services in
GSA-controlled buildings. Federal agencies have the authority to provide health and wellness programs
for the benefit of their employees in accordance with the policies and guidance listed below. Contractors
are not federal employees, and therefore, may not use an agency-financed and operated FC.
The tenant agency determines the FC requirements and is responsible for all equipment costs. GSA only
assists with the build-out of the space and guiding the tenant agency or agencies through the process of
establishing an FC. However, when GSA is a tenant in a building and will be sharing Joint-Use (JU) of the
FC space, it should participate in the tenant-led FC Committee (Committee), if applicable, requirements
development, and may assist with equipment purchasing.
2. AUTHORITY: Authority to establish and operate physical fitness programs and facilities designed to
promote and maintain federal employee health:
a. 5 U.S.C. § 7901. Health Service Programs
b. 41 CFR 102-79. Elements Federal Agencies must address when establishing fitness programs
3. GUIDANCE & TOOLS:
a. Comptroller General Decision B-240371 (dated January 18, 1991), noting exception to 5 U.S.C. §
5946.
b. GSA Pricing Desk Guide. See pricing standards for Owned and Leased JU space.
c. Sample Fitness Center Tenant Agency Memorandum of Agreement*
d. Sample Fitness Center Waiver and Consent Form*
* Consult Regional Counsel before using these documents
4. ESTABLISHMENT:
a. Joint Use Fitness Centers (JUFCs)
Once agencies have established a need for a FC, a Committee should be established and a
chairperson designated. The Committee should consist of a representative from each participating
agency that has the authority to represent the agency in negotiations that may have a financial impact
on said agency. A Memorandum of Agreement (MOA) should be developed between participating
agencies to detail and assign responsibilities as described below in the Operation section of this
document. At a minimum, the MOA should address:
i. FC Management - To minimize risk to GSA, all JUFCs must be managed by an entity
other than GSA. This means that there must be a non-GSA organization/operator
(Operator) in charge of overseeing day-to-day operations for the FC. An Operator can be
a third-party Contractor hired by the Committee (i.e., Federal Occupational Health (FOH)
or a commercial contractor), an individual agency, or the Committee itself (not including
GSA).
FC Staffing - Although FCs must be managed
by an Operator, they are not required to
be staffed
. This means that the Operator might not be required to have staff
onsite/physically present at the FC during hours of operation. The Tenant Committee
must decide whether the FC will be staffed or non-staffed.
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ii. The Pay Structure - The Pay Structure refers to how tenant agencies will pay for all
associated operational expenses of the FC. The MOA should detail how agencies will
share costs and responsibilities and who will initiate and pay for the RWA including
custodial costs (if applicable), equipment purchases, repairs, and maintenance, above
standard services, etc.
Charges for “Other Services”, such as contracted FC management, exercise classes,
towel or water services, and above standard custodial duties (see attachment 1) are the
responsibility of individual members through dues, or are allocated to each agency
having access to the FC. The funding for “Other Services” is determined by the MOA
agreed upon by the FC Committee.
iii. Fee Structure - If FC users will be charged fees through membership, the MOA should
address the fee, how it will be collected, and how users will be charged.
iv. Compliance - All parties must agree to comply with all applicable federal regulations,
rules and policies, including those of the facility housing the FC. In the event of an
emergency, the FC may be subject to access restriction or closure consistent with these
requirements.
The Committee must present the draft MOA to the GSA Facility Manager for review prior to execution.
Before approving the draft MOA, the Facility Manager should review the MOA with the GSA Regional
FC representative to ensure that critical FC management needs (i.e., Managing Operator, operational
expenses, equipment, etc.) are addressed and to discuss and coordinate requirements, planning and
design of the new FC. Following the approval of the GSA Facility Manager each Committee member
should present the MOA to their respective manager (who has signature authority for final execution)
for approval. Once completed and approved by all parties, a copy of the signed MOA must be provided
to the GSA Facility Manager.
The size and scope of the FC services should be based on the willingness and ability of the
participating agencies to pay for the space, equipment, contractor support and ongoing operational
expenses. Federal Occupational Health (FOH) fitness experts can perform comprehensive analyses to
assist agencies in assessing whether proposed FC space will be adequate for projected population
needs. Once space has been designated, FOH can develop exercise programs and equipment space
plans that consider participant flow and equipment utilization. FOH can also offer assistance to groups
of agencies that want to create a single FC for multiple agency participants.
b. FC Rent Charges
Rent is charged to all federal tenants in the building, facility, or designated community directly in
proportion to each agency’s percentage of federal occupancy. The JU Rent charge consists of shell
rent, operating rent (which includes utilities and standard custodial costs), and amortized tenant
improvements. FCs are typically designated as JU space and the rent charges are reflected in the JU
Charges line of the rent bill. JU charges apply whether or not employees of the tenant agencies elect to
use the JU amenity. If a FC is for the exclusive use (assigned FC space) of a single tenant agency,
then the Rent is passed entirely onto that tenant agency as its assigned usable space.
5. OPERATION:
Table 1: All FCs operating in GSA-controlled buildings must meet the following requirements:
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Requirement
Who Is Responsible
(Either/Or)
Funding Source
Have controlled and secure access at the point
of entry to FC services. Limiting FC access to
those who have building access is not sufficient.
Contractors may not use an agency financed
and operated FC.
Non-staffed FC:
GSA responsible for installing an access
control system (i.e. Key card control,
combination pad, etc) at the request of
the tenant Agency or FC Committee.
Staffed FC:
FC Contractor or Committee oversees
admittance (i.e. front desk personnel
checking participants into the facility).
RWA
FC Contract
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At a minimum FCs must meet the requirements outlined in Table 1, but it is highly recommended that
FCs utilize a contracted fitness management company to operate the facility and ensure compliance with
this policy.
For further information on health and fitness facility standards and resources, please see the following
links:
1. The American College of Sports Medicine
2. OPM Employee Health Services Handbook
3. Sample Fitness Center Waiver and Consent Form*
* Consult Regional Counsel before using this document
6. EQUIPMENT PURCHASE AND MAINTENANCE: The purchase of equipment is the responsibility of
the participating agency or agencies. For JUFCs, equipment purchasing is not included in the GSA JU
charges and should be addressed in the FC MOA. Equipment may be acquired through individual
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Post signage advising participants that “All
Fitness Center Activities Are At Your Own Risk.
GSA assumes no liability for accidents or thefts
that may occur in FC space.”
FC Committee
OR
FC Contractor
RWA
FC Contract
Provide a telephone or another emergency calling
system adjacent to physical activity areas
GSA
RWA
Use informed consent statements to advise of
the benefits and risks of participation,
screenings, evaluations and fitness testing, and
physical activity. Examples can be found at:
Sample Fitness Center Waiver and Consent
Form
FC Committee
OR
FC Contractor
FC Committee
FC Contract
Post or distribute fitness facility rules and
regulations to participants.
FC Committee
OR
FC Contractor
FC Committee
FC Contract
Post manufacturers' instructions for all
equipment.
FC Committee
OR
FC Contractor
FC Committee
FC Contract
Provide a fitness facility orientation and review
manufacturers' written instructions on how to
safely use the facility and equipment
FC Committee
OR
FC Contractor
FC Committee
FC Contract
Post warning signs that identify dangerous
physical symptoms to watch for during exercise
(for example, nausea, dizziness, and pain in
chest) and relevant risks associated with the
use of specific equipment.
FC Committee
OR
FC Contractor
FC Committee
FC Contract
Maintain an equipment inventory. Ensure and
document ongoing inspection, maintenance,
and repair of the fitness facility and equipment,
and remove any broken or unsafe equipment in
accordance with GSA Excess/Disposal Facility
Process.
Equipment owner (FC Committee or
agency)
OR
FC Contractor
Process and costs
funded by the agency
that owns the equipment
or by the FC Committee
(as outlined in the MOA)
if all agencies
contributed to purchase
of equipment.
Funded through FC
Contract except for
excessing old
equipment, which is the
responsibility of the
equipment owner(s).
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agency procurements or through the FC Committee. GSA may assist in procurement of equipment
through an RWA (See GSA RWA Policy). The use of Federal Supply Schedules to purchase
equipment specifically designed for commercial use is strongly recommended. Commercial-Use
equipment is also available for lease or may be listed on the government surplus list.
Equipment maintenance should be addressed by the FC committee through the MOA, including
establishing a schedule and procedures for maintaining equipment through a warranty or an equipment
maintenance contract. The equipment owner(s) is responsible for maintenance and it is highly
recommended that an equipment maintenance log be kept.
7. LIABILITY AND RISKS ASSOCIATED WITH PHYSICAL FITNESS PROGRAMS: Providing health and
fitness activities for employees is not without risk to agencies, contractors or employee organizations
responsible for providing physical fitness programs, fitness equipment vendors, and private health clubs.
Although many accidents can be prevented through adequate supervision, staff training, appropriate
screening procedures, and proper facility and equipment maintenance, an employee may still sustain
personal injury. Depending on the particular facts and circumstances, an employee who is injured while
engaging in physical fitness activities may bring claims against the United States under the Federal
Employees' Compensation Act and the Federal Tort Claims Act and against non-federal groups for
personal injury. To minimize risk to GSA, all FCs in GSA-controlled space must be managed, preferably
by FOH, a Tenant Committee/Employee Association, or a third-party vendor. When contracting with
non-federal groups, agencies must require that the vendor carry general liability insurance.
Agencies are also encouraged to use waivers and informed consent forms for participation in
agency-sponsored fitness facilities or events. Although these waivers and informed consent forms
generally will not absolve an agency from liability for its own negligence, they are useful in outlining the
terms and conditions for using the facilities or participating in events, informing the participant of the
risks, and limiting liability exposure. Agencies are strongly encouraged to consult with their Office of
General Counsel to determine the need for a waiver or other informed consent form and to make sure
that the waiver or form conforms to all applicable laws.
Table 2: Four potential operational scenarios for JU space FCs
To minimize risk to GSA, unmanaged FCs are not allowed.
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Operational
Scenario
(a) Equipment Purchase
(b) Maintenance
(a) Staffing
(b) Access Control
(a) Custodial
(b) Membership Fees
Managed by
Federal
Occupational
Health (FOH)
(a) Assists agencies in
designing the FC and
procuring the
appropriate types and
amount of equipment
and provides equipment
maintenance resources.
(b) These services are
provided by FOH for a
fee. For more
information see
www.foh.hhs.gov
(c) Provides highly
qualified, fully certified
staff for group fitness
classes, instruction on
equipment usage, and
front desk access
control to ensure only
authorized users access
the FC.
(d) Provides and
manages liability
waivers and
membership
applications.
(a) Provides above standard
cleaning services such as
floor to ceiling mirrors, shower
curtains, shower gel, and
equipment as part of the
agreement with the fitness
contractor.
(b) FOH can collect employee
membership dues; however,
they must either operate
using 100% tenant agency
funds or 100% employee
membership dues but not
both. FOH is reimbursed for
staffing and management by
the tenant agencies using the
FC.
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Managed by FC
Committee or
an Employee
Association
(a) Purchase equipment
as outlined in the FC
MOA (i.e., through
agency RWA to
GSA).
(b) Establish equipment
maintenance
schedule and/or
contract.
(a) Staffed FC: Minimum
staffing would require
personnel at front desk
for access control.
Additional staffing
recommended for
equipment instruction as
well as persons trained
to respond to medical
emergencies.
(b) Non-staffed FC: If no
staff onsite then key
card access control is
required allowing
individuals access only
after signing liability
waiver. It is
recommended that
employee associations
contract with a qualified
fitness company for the
staffing and
management of the FC.
(a) Due to the expertise required
in this area, building custodial
staff is unable to perform
above standard/specialized
cleaning requirements (see
attachment I) for FC
equipment and therefore this
must be done by a separate
qualified Contractor.
Non-technical, above
standard cleaning such as
providing shower curtains,
shower gel, etc. can be
accomplished through an
RWA.
(b) Employee associations may
collect membership dues
from individual employees for
the operational costs of FC.
Managed by
Third-Party
Contractor
(a) Can assist agencies in
designing the FC and
procuring the
appropriate types and
amounts of equipment.
(b) Contract should
stipulate that the
contractor must maintain
and replace equipment
as needed.
(a) Staffed FC: Provides
highly qualified, fully
certified staff for group
fitness classes,
instruction on equipment
usage, and front desk
access control to ensure
only authorized users
access the FC.
Non-staffed FC:
Contractor manages the
FC overall, but does not
have full-time personnel
onsite to oversee the
space.
(b) Staffed FC: Minimum
staffing would require
personnel at front
desk for access
control. Provides and
manages liability
waivers and
membership.
applications.
Non-staffed FC: If no
staff onsite then key
card access control is
required allowing
individuals access
only after signing
liability waiver.
(a) Provides above standard
cleaning services such as
floor to ceiling mirrors, shower
curtains, shower gel, and
equipment as part of the
fitness contractor.
(b) Contractor collects employee
membership dues, usually on
a recurring monthly basis.
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8. ATTACHMENT 1: ABOVE STANDARD CUSTODIAL SERVICES
Refer to the current custodial contract of the building where the FC is or will be established to identify
standard and above standard cleaning services (for new custodial services see The National Custodial
Specification).
a. Standard Custodial Services - Cleaning standards for FCs are to be in accordance with the
cleaning and disinfection requirements of the custodial contract of the building. Standard custodial
services for JUFCs are paid for through JU charges to the tenant agencies in the building.
b. Above Standard Custodial Services - Above standard custodial services must be provided by a
company experienced in the specialized cleaning and disinfection requirements of a fitness facility
(i.e. cleaning pulleys and moving parts of fitness equipment or moving fitness equipment such as
treadmills to clean underneath). Above standard cleaning refers to tasks that are not included in
the building’s standard custodial service contract, thus, a system for providing and paying for them
needs to be described in the FC MOA. If the FC is managed by FOH or a third-party FC
Contractor, it is generally best to incorporate above standard cleaning services into the FC
contract. If the FC is managed by a Committee and an RWA will be utilized for above standard
cleaning services the MOA must specify who will initiate and pay for the RWA.
Due to the expertise required in this area, some custodial contractors are unable to perform specialized
FC cleaning services; therefore, a separate custodial contractor may be required. The GSA Facility
Manager should review any additional planned cleaning services to ensure it adequately addresses the
cleaning and disinfection needs of the space.
Examples of above standard cleaning service may include:
● Maintenance of group fitness room floor- if wood will require periodic stripping, buffing, and
waxing
● Cleaning, disinfecting, and dusting fitness equipment to include free weights, machines, mats,
steps, balls etc.
● Cleaning and disinfecting under equipment such as cardio-vascular equipment, free weights, and
circuit machines
● Cleaning and disinfecting FC floor to ceiling mirrors where ladders are required
● Cleaning and disinfecting inside lockers
● Providing shower gel
● Providing cloth towel service
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Managed by A
Single Tenant
Agency (i.e.
sole tenant,
lead or anchor
tenant)
(a) Tenant agency
purchases
equipment and
establishes a
maintenance
schedule as outlined
in FC MOA.
(b) GSA may assist in
procurement of
equipment through
an RWA, however
maintenance and
documentation of
services for
equipment must be
managed by
participating tenant
agencies as outlined
in the FC MOA.
(a) Minimum staffing would
require personnel at the
front desk for access
control. Additional
staffing recommended
for equipment instruction
as well as persons
trained to respond to
medical emergencies.
(b) If an agency does not
provide staffing then
access control measures
must be in place to limit
only authorized
employees the use of
FC after they sign a
liability waiver.
(a) Due to the expertise required
in this area, building custodial
staff is unable to perform
specialized cleaning
requirements (see
attachment 1) for FC
equipment and therefore this
must be done by a separate
qualified Contractor.
Non-technical, above
standard cleaning such as
providing shower curtains,
shower gel, etc. can be
accomplished through an
RWA.
(b) Federal agencies are not
allowed to collect
membership dues from their
employees except in special
circumstances. See OPM’s
guidance.
