Key Controls NASA Employs to Guide Use and Management of Funded Space Act Agreements Are Generally Sufficient, but Some Could Be Strengthened and Clarified
GAO-12-230R November 17, 2011
In accordance with GAO's "Standards for Internal Control in the Federal Government," NASA policy and guidance provide internal controls for certain aspects of using and managing funded Space Act agreements, such as separation of duties and delegation of authority. For example, NASA separates duties associated with authorizing, managing, and reviewing funded Space Act agreements. According to GAO's "Standards for Internal Control in the Federal Government," risk assessment is also an important control for ensuring programmatic objectives can be met, and NASA policy and guidance provide for varying levels of risk assessment.
NASA's Space Act agreement policy and guidance provide controls for risk assessment related to reasonableness of cost estimates and whether or not a Space Act agreement is the appropriate legal instrument, but do not require specific documentation related to these assessments, as GAO's Standards for Internal Control in the Federal Government call for. Other risks that are traditionally assessed when making programmatic decisions, including safety and technical risks, for example, are not addressed in NASA's Space Act agreement policy.
According to NASA, once it becomes clear that the agency can appropriately use a funded Space Act agreement for a given initiative, it is not necessary to assess such additional risks because these are borne by the agreement partner. When appropriate use of a funded Space Act agreement is less definitive based on programmatic objectives, according to NASA additional risks such as safety and technical risks are addressed through use of the agency's strategic acquisition approach and related policies. It is not always clear, however, when and if the objectives of a program drive the need to follow NASA's strategic acquisition approach and assess additional programmatic risks.
Finally, though federal standards for internal control highlight the importance of training to maintaining competence, NASA does not require or offer formal training for individuals responsible for managing funded Space Act agreements. For its Commercial Crew program, NASA did develop and document a process to guide program officials through procedures associated with its agreements. Although the documented process is a positive step for the Commercial Crew program, given the unique nature of funded Space Act agreements and the judgment that can be executed by agreement managers, training could help ensure that future agreements are executed appropriately.
We are recommending that NASA incorporate additional internal controls relating to documentation and training in its policy and guidance for funded Space Act agreements, and that NASA clarify if, how, and to what extent agency officials should refer to NASA's broader acquisition and risk management policies when considering use of a funded Space Act agreement. Commenting on a draft of this report, NASA concurred with our recommendations.