IG-02-011

AUDIT 

REPORT INTERNATIONAL SPACE STATION 

SPARE PARTS COSTS 

March 22, 2002

 National Aeronautics and 

Space Administration

OFFICE OF INSPECTOR GENERAL
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Acronyms 

DCAA Defense Contract Audit Agency 

FAR Federal Acquisition Regulation 

FY Fiscal Year 

ISS International Space Station 

NMI NASA Management Instruction 

NPG NASA Procedures and Guidelines 

OIG Office of Inspector General 

OMB Office of Management and Budget 

PIO Provisioning Item Order 

PP&E Property, Plant, and Equipment 
March 22, 2002 

W 

TO: A/Administrator 

FROM: W/Counsel to the Inspector General 

SUBJECT: INFORMATION: Audit of International Space Station Spare Parts Costs 

 Report Number IG-02-011 

The NASA Office of Inspector General has completed an audit of International Space 

Station (ISS) Spare Parts Costs. We found that NASA generally did not properly acquire 

and account for ISS spare parts. Although NASA properly justified and approved 

noncompetitive contract modifications, it did not negotiate for separately priced spare 

parts or develop a pricing history for use in purchasing additional spare parts. As a 

result, NASA had no assurance that the prices it paid were fair and reasonable for the 

$334 million spent on ISS spare parts through fiscal year (FY) 2000 and may not be able 

to cost-effectively and competitively procure about $608 million in future ISS spare 

parts.

1

 Additionally, we found that The Boeing Company (Boeing) omitted contractor fee 

and indirect costs from the value of spare parts recorded on receiving reports it submitted 

to Johnson Space Center (Johnson). As a result, the Agency cumulatively understated in 

its annual financial statements the value of ISS spare parts by about $39 million from 

Program inception (FY 1995) through FY 2000. 

Background 

The Agency budgeted $831 million to acquire ISS spare parts through FY 2007. Johnson 

used noncompetitive contract modifications to issue provisioning item orders (PIO's) to 

acquire groups of line item spare parts from Boeing. The ISS contract stipulates that 

each deliverable item (line item spare part) should be priced and substantiated separately 

within the contractor's proposal. Further, Federal regulations require the Agency to pay 

fair and reasonable prices for ISS spare parts. 

 

1

The $608 million requirement was based on a seven-person crew. The current ISS core complete is based 

on a budget-limited three-person crew. Ultimately, the requirement may again be based on a seven-person 

crew. 
2 

The ISS contract incorporates the requirements of NASA Management Instruction 

(NMI) 5900.1B, "NASA Spare Parts Acquisition Policy," February 3, 1993,2

 which 

established Agency policy to ensure NASA spare parts are acquired at the lowest fair and 

reasonable cost. The NMI states that, if possible, each order should be on a firm 

fixed-price basis with individual items separately priced to provide a pricing history for 

later purchases. 

Boeing prepares the official ISS property records that include a value for spare parts. 

NASA uses these property records to establish the value of ISS property in its annual 

financial statements. Federal accounting standards and Agency regulation require that 

the unit value for property shall reflect total costs including applicable fees and indirect 

costs. 

Recommendations 

We recommended that Johnson require Boeing to propose, negotiate, track, and report 

individual prices for ISS spare parts and establish price histories. These actions will 

ensure NASA knows the prices it is paying for ISS spare parts. We also recommended 

that Johnson ensure Boeing includes contractor fee and indirect costs in the value of ISS 

spare parts recorded in the official property records. This action will help ensure that 

property records show all applicable costs and fees and that NASA reports the correct 

value for ISS spare parts in its annual financial statements. We further recommended that 

the Assistant Administrator for Procurement reestablish Agency procedures for acquiring 

spare parts and that the NASA Chief Engineer reference the procedures in the next 

revision of the NASA Procedures and Guidelines (NPG) 7120.5A, “NASA Program and 

Project Management Processes and Requirements” dated April 3, 1998. These actions 

will ensure the Agency has a uniform policy for future acquisitions of spare parts to 

support NASA's major systems. 

Management's Response 

Johnson concurred with the recommendations to require Boeing to propose and negotiate 

individual prices for spare parts and to include fee and indirect costs of spare parts on 

receiving reports submitted to NASA. Johnson did not concur with the recommendation 

to track and report individual prices for ISS spare parts. However, in subsequent 

discussions with us, the ISS Procurement Officer agreed to use the receiving reports to 

track prices and establish price histories for batteries3 and other high-dollar value spare 

 

2

Although the NMI was subsequently cancelled, it was still in effect at contract initiation in January 1995 

(see "Need for Guidance on Spare Parts Acquisition" in the finding section of this report). 

3

The nickel-hydrogen batteries cost NASA about $3.3 million each. The ISS is designed to operate with 

48 batteries. Additional details are in Finding A. 
3 

parts. NASA concurred with the recommendations to reestablish procedures for 

acquiring NASA spare parts and to reference the procedures in the next revision of 

NPG 7120.5A. 

OIG Evaluation of Management's Response 

Management’s comments and planned actions are responsive to the recommendations. 

Details on the status of the recommendations are in the recommendations section of the 

report. 

[original signed by] 

Francis P. LaRocca 

Enclosure 

Final Report on Audit of International Space Station Spare Parts Costs 
INTERNATIONAL SPACE STATION 

SPARE PARTS COSTS
March 22, 2002 

W 

TO: AE/Chief Engineer 

H/Assistant Administrator for Procurement 

M/Associate Administrator for Space Flight 

AA/Acting Director, Lyndon B. Johnson Space Center 

FROM: W/Assistant Inspector General for Audits 

SUBJECT: Final Report on the Audit of International Space Station Spare Parts Costs 

Assignment Number A-01-009-00 

Report Number IG-02-011 

The subject final report is provided for your information and use. Please refer to the 

Executive Summary for the overall audit results. Our evaluation of your response has 

been incorporated into the body of the report. We consider management’s proposed 

corrective actions responsive for recommendations 1 through 5. The recommendations 

will remain open for reporting purposes until corrective action is completed. Please 

notify us when actions have been completed on the recommendations, including the 

extent of testing performed to ensure corrective actions are effective. The final report 

distribution is in Appendix G. 

We appreciate the courtesies extended to the audit staff. If you have questions 

concerning the report, please contact Mr. Dennis E. Coldren, Program Director, Space 

Flight Audits, at (281) 483-4773, or Mr. Kenneth Sidney, Auditor-in-Charge, at 

(281) 483-0728. 

[original signed by] 

Alan J. Lamoreaux 

Enclosure 
2 

cc: 

AI/Associate Deputy Administrator 

AB/Associate Deputy Administrator for Institutions 

B/Acting Chief Financial Officer 

B/Comptroller 

BF/Director, Financial Management Division 

G/General Counsel 

JM/Director, Management Assessment Division 
Contents 

Executive Summary, i 

Introduction, 1 

Findings and Recommendations, 2

Finding A. Acquisition of Spare Parts, 2 

Finding B. Accounting for Spare Parts Costs, 7 

Appendix A – Objectives, Scope, and Methodology, 10 

Appendix B – International Space Station Contract, 11 

Appendix C – Procurement Requirements, 13 

Appendix D – Prior Audits and Other Reviews, 17 

Appendix E – Management’s Response, 19

Appendix F – OIG Comments on Management’s Response, 25

Appendix G – Report Distribution, 26
NASA Office of Inspector General 

IG-02-011 March 22, 2002 

 A-01-009-00 

International Space Station Spare Parts Costs 

Executive Summary 

Background. In January 1995, Johnson signed a $5.638 billion cost-reimbursable contract with 

Boeing for the ISS. As of February 2002, the contract value was $10.8 billion. The contract 

includes the design, development, manufacture, integration, test, verification, and delivery to 

NASA of the U.S. on-orbit segment of the ISS, including ground support equipment and support 

for ground and orbital operations. (Appendix B contains overall contract details.) Johnson is 

acquiring ISS prime spare parts4

 through noncompetitive contract modifications. Johnson 

estimated ISS prime spare parts would cost $831 million through FY 2007 and spent 

$334 million through FY 2000. NASA will likely purchase an additional $608 million in spare 

parts over the life of the ISS. 

Objectives. The overall objective was to determine whether NASA properly acquired and 

accounted for ISS spare parts. Specifically, we determined whether NASA appropriately 

justified and approved the acquisition of ISS spare parts through noncompetitive contract 

modifications, paid a fair and reasonable price for the spare parts, and adequately supported the 

value of the spare parts inventory that the Agency reported in its annual financial statements. 

Appendix A contains a detailed description of our objectives, scope, and methodology. 

Results of Audit. NASA generally did not properly acquire and account for ISS spare parts. 

Although NASA properly justified and approved noncompetitive contract modifications, it did 

not negotiate for separately priced spare parts or develop a pricing history for use in purchasing 

additional spare parts. As a result, Johnson had no assurance that the prices it paid were fair and 

reasonable for the $334 million spent on ISS spare parts and may not be able to cost-effectively 

and competitively procure an estimated $608 million in future ISS spare parts (Finding A). 

Also, Boeing did not include fee and indirect costs in the value of spare parts it reported to 

NASA. Consequently, the Agency's annual financial statements from FY's 1995 through 20005

cumulatively understated the value of spare parts by about $39 million (Finding B). 

Recommendations. NASA should require Boeing to properly price and account for ISS spare 

parts and should establish procedures for acquiring and provisioning spare parts. 

 4

ISS prime spare parts are all the spare parts that Boeing provides NASA under the ISS contract. They can be made 

by Boeing, acquired by Boeing from its subcontractors, or furnished by the Government to Boeing. 5

Using NASA Form 1018, "NASA Property in the Custody of Contractors," Johnson adjusted its official property

records for FY's 1998 through 2000 by adding calculated fees to the year-end balances reported for 4 of the 11 

property classification accounts. However, this adjustment did not show the amount of fees that pertained to ISS 

spare parts. 
Management's Response. Johnson agreed to require Boeing to propose and negotiate 

individual prices for spare parts and to record total costs, including fee and indirect costs, of 

spare parts on receiving reports submitted to NASA. Johnson did not concur with the 

recommendation to track and report individual prices for ISS spare parts. However, in 

subsequent discussions with us, the ISS Procurement Officer agreed to use the receiving reports 

to track prices and establish price histories for batteries and other high-dollar value spare parts. 

NASA concurred with the recommendations to reestablish procedures for acquiring spare parts 

and to reference the procedures in the next revision of NPG 7120.5A. Management also 

provided general comments on our findings. The complete text of management's response is in 

Appendix E. 

Evaluation of Management's Response. We consider NASA's comments and planned actions 

responsive. Our response to management's general comments on the findings is in Appendix F. 

ii
Introduction 

Federal Acquisition Regulation (FAR) 15.402 requires that a contracting officer purchase 

supplies and services from responsible sources at fair and reasonable prices. The ISS contract 

stipulates that each deliverable item should be priced and substantiated separately within each 

proposal. The contract also incorporates the requirements of NMI 5900.1B, "NASA Spare 

Parts Acquisition Policy," February 3, 1993. The NMI established a uniform policy for the 

acquisition and provisioning of NASA spare parts and for ensuring that the Agency acquires 

spare parts in the proper quantities and at the lowest fair and reasonable cost. Also, 

NMI 5900.1B stated that, if possible, each order should be on a firm fixed-price basis with 

individual items separately priced to provide a pricing history for later spare parts purchases. 

(Appendix C contains the procurement requirements.)

The NMI assigned the overall responsibility for the acquisition of NASA spare parts to the 

Assistant Administrator for Procurement. The policy delegates the authority for acquiring 

spare parts through Center Directors to cognizant contracting officers and assigned the 

responsibility for ISS spare parts management to the Associate Administrator for Space 

Flight. 

Boeing submits to the ISS Contracting Officer a cost proposal for each contract modification 

that includes direct cost, indirect cost, and fee for the spare parts listed in the PIO. The 

contracting officer obtains field pricing assistance from the Defense Contract Audit Agency 

(DCAA)6

 and the Defense Contract Management Agency7 to evaluate the proposal and to 

establish a pre-negotiation position for the Government. After the contracting officer 

evaluates the proposal, NASA and Boeing negotiate a total price for the contract modification 

that contains the PIO listing of spare parts. As of January 2001, Johnson had ordered8

 about 

$633 million in spare parts. 

 6

DCAA provides the latest approved or recommended direct labor rates that NASA should use to estimate the 

contractor’s direct labor costs. DCAA also provides the latest approved or recommended indirect rates that

NASA should use to estimate indirect costs. Further, DCAA reviews the proposed material costs to ensure that

escalation factors are reasonable and that the items agree with the Government’s bill of material. 7

Engineers from the Defense Contract Management Agency perform technical evaluations at the 

contractor/subcontractor sites and advise NASA on whether the proposed direct labor hours are reasonable. 8

NASA considers spare parts as ordered when it negotiates a contract modification with Boeing or otherwise 

authorizes the contractor to proceed (that is, the Agency issues an undefinitized contract action). 
Findings and Recommendations 

Finding A. Acquisition of Spare Parts 

Johnson did not negotiate separate prices or develop price histories for ISS spare parts. This 

occurred because Johnson did not perform those actions required by NMI 5900.1B, which the 

ISS contract incorporates by reference. As a result, Johnson did not know the prices, either 

individually or by PIO, that it paid Boeing for the $334 million spent on ISS spare parts 

through FY 2000 and, therefore, had no assurance the prices were fair and reasonable. Also, 

without knowing the prices paid, Johnson could not develop a price history with which to 

procure, on a competitive fixed-price basis, an additional $608 million in spare parts that may 

be needed over the life of the ISS. 

NASA’s Acquisition Strategy and Price Histories 

Lifetime Purchases. The ISS Program Office philosophy is that almost all procured spare 

parts can and will be repaired. Accordingly, Johnson's acquisition strategy has been to make 

lifetime purchases of sufficient spare parts hardware to support ISS performance and to 

procure no additional hardware other than for consumables9

 and re-procurement10 spare parts. 

Johnson calls this process spares acquisition integrated with production. For ISS spare parts 

that Boeing delivered to NASA through December 2000, we determined that less than 

5 percent of the items ordered were repetitive purchases.11 Although Johnson had generally 

implemented its acquisition strategy of making lifetime purchases rather than repetitive 

purchases of ISS spare parts, Johnson plans to make additional repetitive purchases in the 

future. 

Additional Spare Parts Requirements. The ISS Program recognizes that it will spend 

considerably more to acquire consumables and re-procurement spare parts for the ISS. 

Mainly, the consumables consist of nickel-hydrogen batteries, which cost about $3.3 million 

each and are designed to collect and store solar power aboard the ISS. 12 Also, Johnson may 

need to acquire re-procurement spare parts to resolve recently identified ISS power system

issues.13 Further, Johnson anticipates that as it accumulates more ISS operational data, the 

Program will need additional re-procurement spare parts to address changes in the predicted 

 9

Consumables are spare parts, such as batteries and filters, that have a limited shelf life. 10Re-procurement spare parts have previously been procured but need to be procured again because the 

development hardware did not perform as NASA had predicted it would perform. These additional spare parts 

acquisitions relate to the risk of needing more spare parts due to problems such as redesign issues and higher 

than anticipated failure rates. 11About 4 percent (584 of 15,113) of the unit spare parts and about 4.5 percent (35 of 782) of the line items

spare parts were repetitive purchases. 12Spare batteries will be kept on the ground and used to replace batteries that fail prematurely or have reached 

their 6-year life expectancy. The ISS is designed to operate with 48 batteries. 13NASA anticipates that, due to power system issues, it will need to re-procure two direct current switching units 

(three units were originally ordered), three battery charge/discharge units (three units were originally ordered), 

one pump module (three units were originally ordered), one photovoltaic radiator (one unit was originally

ordered), one high-resolution spectograph (one unit was originally ordered), and one electronics/environmental

control unit (two units were originally ordered). 

2 
failure rates and failure impacts.14 Therefore, in addition to the $831 million Johnson 

estimated for known spare parts, the ISS Program Office may spend another $110 million for 

re-procurement spare parts through FY 2007. The Program Office also estimated it will 

probably spend $300 million for batteries from FY's 2008 through 2017. 

Estimated Cost of Spare Parts. ISS spare parts may cost $1.241 billion over the life of the 

Program, of which $608 million remains to be ordered as shown below: 

ISS Program Office’s Estimated Costs of Spare Parts

(Millions)

Estimated Cost of Spare Parts Required 

 Through FY 2007 $ 831 

Potential Re-procurements 

 Through FY 2007 

 

 110 

Batteries Required (FY's 2008-2017) 300

Total Spare Parts Required $1,241 

 Less: 

 Spare Parts Ordered 

 Through January 2001 

 

 

(633)

Estimated Cost of Future Spare Parts $ 608 

To competitively acquire future spare parts from responsible sources at fair and reasonable 

prices that are most advantageous to the Government, Johnson should establish price histories 

as required by NMI 5900.1B. 

Price Reporting 

Proposing, Negotiating, and Reporting Prices. The ISS contract stipulates that each 

deliverable item (line item spare part) should be priced and substantiated separately within the 

contractor’s proposal. However, Boeing does not propose a price for each spare part listed in 

the PIO. Instead, the Boeing production facilities at Canoga Park, California; Huntington 

Beach, California; and Huntsville, Alabama, propose their spare parts costs by major cost 

elements (that is, direct labor, material, other direct costs, overhead, and general and 

administrative expenses). Boeing-Houston, Texas, Boeing's home office, proposes a total 

spare parts cost that it adds to each proposal submitted by the Boeing production facilities. 

The ISS contracting officer requested that Boeing not propose costs for individual spare parts 

because (1) proposing costs for individual spare parts would increase proposal costs to 

Johnson and (2) the ISS Program Office did not negotiate prices for individual spare parts. 

After the contracting officer completes each proposal evaluation, Johnson and Boeing 

negotiate a total price for all of the spare parts in the PIO. Boeing reports cumulative costs 

for 

 14Failure rate refers to the number of hardware failures per year requiring removal and replacement on orbit of 

the failed hardware items. Failure impact refers to the possibility that NASA will need to make additional spare 

parts purchases because the severity of the failure consequences is greater than NASA anticipated. 

3 
all spare parts each month on NASA Form 533M, "Monthly Contractor Forecast Report - 

Format 4," and on the Performance Measurement System Report.15 However, neither report 

identifies the costs for line item spare parts.

Line Item Spare Parts Prices. Boeing does not track and report individual spare parts prices 

to the ISS Program Office as NMI 5900.1B required. Consequently, Johnson did not 

establish a pricing history for later spare parts purchases. Also, Boeing could charge Johnson 

unreasonable prices for individual spare parts even though the total cost of a particular spare 

parts order appears reasonable. 

Need for Guidance on Spare Parts Acquisition 

NASA Cancelled NMI 5900.1B. The NASA Headquarters Procurement Systems Division 

issued NMI 5900.1B in February 1993. However, in a February 28, 1996, notice to the 

Manager, NASA Directives and Federal Regulations, the Associate Administrator for 

Procurement stated that NMI 5900.1B was no longer needed and was cancelled. Since then, 

NASA has had no policy on the acquisition and provisioning of spare parts. 

NMI 5900.1B applied to the acquisition of spare parts for nonexpendable major systems (such 

as the ISS) as defined by the Office of Management and Budget (OMB) Circular A-109, 

"Major Systems Acquisitions," April 5, 1976. NASA FAR Supplement Part 1834 states that 

NASA's implementation of OMB Circular A-109 is contained in NPG 7120.5A, "NASA 

Program and Project Management Processes and Requirements," April 3, 1998. The NASA 

Office of the Chief Engineer is responsible for NPG 7120.5A, which provides broad guidance 

on program and project management processes and requirements and which incorporates by 

reference more specific guidance. The NASA Headquarters Office of Procurement is 

responsible for developing specific guidance on spare parts acquisition and originally issued 

NMI 5900.1B. 

ISS Program Should Follow NMI 5900.1B. NMI 5900.1B was in effect when the Boeing 

contract was signed on January 13, 1995, and is incorporated by reference into the ISS prime 

contract. Therefore, the ISS Program should follow the instruction and negotiate separate 

prices and develop price histories for ISS spare parts to ensure that NASA pays fair and 

reasonable prices and competitively procures future ISS spare parts. 

Recommendations, Management's Response, and Evaluation of Response 

1. The Acting Director, Lyndon B. Johnson Space Center, should require Boeing to 

propose, negotiate, track, and report individual prices for ISS spare parts, as required 

by the ISS contract including NMI 5900.1B. 

 15NASA requires Boeing to report contract cost and schedule performance each month in the Performance 

Measurement System Report. The report provides NASA management with the primary data for determining 

current contract cost and schedule performance and the forecast of the estimated cost at completion.

4 
Management's Response. Concur. NASA is now requiring Boeing to negotiate and propose 

prices for individual spare parts. Also, management will track and report prices for each 

spare part when the actions are cost-effective to the Program. 

Evaluation of Response. Management's comments and planned actions are responsive to the 

recommendation. The recommendation is resolved but will remain open until agreed-to 

corrective actions are completed. 

2. The Acting Director, Lyndon B. Johnson Space Center, should direct the ISS 

Program Office to track prices paid for ISS spare parts to establish the price histories 

needed to facilitate future purchases on a firm fixed-price basis. 

Management's Response. Nonconcur. NASA estimated that $119 million of the 

$164 million remaining in the spare parts budget through FY 2007 will be spent on batteries. 

The remaining $45 million in the budget through FY 2007 is for spare parts reprocurement 

(other than batteries) due to changes in the failure rates and other program changes. NASA 

will not require Boeing to track prices for the reprocurements because Boeing’s estimated 

cost of $4.5 million to track individual prices for the $45 million reprocurement offsets any 

cost savings obtained by having a line item price history for uncertain future spare 

reprocurements. Also, because of a Program change from a seven-member crew to a 

three-member crew, NASA is no longer recognizing a $110 million threat for additional spare 

parts reprocurement through FY 2007. Regarding the use of fixed-price contracts for future 

spare parts purchases, the ISS Procurement Office will continue to acquire spare parts through 

Boeing, the prime contractor and integrator, using the type contract that makes good fiscal 

sense. After submission of management's written comments, the ISS Procurement Officer 

agreed to use receiving reports from Boeing to track prices and establish price histories for 

batteries and other high-cost spare parts. 

Evaluation of Response. Management's comments and planned alternative actions are 

responsive to the recommendation. We accept Johnson's rationale to not track and report 

individual prices for low-dollar value spare parts if it is not cost-effective. However, the 

possibility still exists that NASA will spend an additional $110 million for spare parts 

reprocurements through FY 2007 because the ISS Program could ultimately require a 

seven-member crew. The recommendation is resolved but will remain undispositioned and 

open until agreed-to corrective actions are completed. 

3. The Assistant Administrator for Procurement should reestablish procedures for 

acquiring and provisioning NASA spare parts. 

Management's Response. Concur. The NASA Office of Procurement will revise the NASA 

FAR Supplement to include appropriate procedures for acquiring and provisioning spare 

parts. 

Evaluation of Response. Management's planned actions are responsive to the 

recommendation. The recommendation is resolved but will remain undispositioned and open 

until agreed-to corrective action is completed. 

5 
4. The NASA Chief Engineer should incorporate by reference in the next revision of 

NPG 7120.5A the spare parts procedures discussed in Recommendation 3. 

Management's Response. Concur. The NASA Chief Engineer will reference the NASA 

FAR Supplement update in the next NPG 7120.5A revision. 

Evaluation of Response. Management's comment and planned action are responsive to the 

recommendation. The recommendation is resolved but will remain undispositioned and open 

until agreed-to corrective action is completed. 

6 
Finding B. Accounting for Spare Parts Costs 

Boeing did not include contractor fee and indirect costs in the value of the spare parts 

recorded on the receiving reports it submitted to NASA. This occurred because Boeing's 

accounting system was inadequate to determine the total unit costs of Government property16

as required by Federal Financial Accounting Standards and by the NASA FAR Supplement. 

As a result, the Agency's annual financial statements from Program inception (FY 1995) 

through FY 2000 cumulatively understated the value of ISS spare parts by about 

$39 million.17

Requirements to Record Unit Acquisition Costs 

Federal Financial Accounting Standards Guidance. Federal Financial Accounting 

Standards Number 6, "Accounting for Property, Plant, and Equipment (PP&E)," 18 effective 

June 1996, contains accounting standards for Federally owned PP&E. The accounting 

standards require that PP&E be recorded at cost. That cost shall include all costs to bring the 

PP&E to a form and location suitable for their intended use. 

NASA Guidance. For NASA property, NASA FAR Supplement 1845.7101-3, "Unit 

Acquisition Cost," requires the unit value (called the unit acquisition cost) to include related 

fees, or a pro rata portion of fees, paid by NASA to the contractor and indirect production 

costs (see Appendix C). 

Inclusion of All Applicable Costs in Spare Parts Values 

Boeing documents delivery of spare parts to NASA on Department of Defense DD Form 250, 

"Material Inspection and Receiving Report" (receiving report). On each receiving report, 

Boeing records a value for each spare part and uses the values from the receiving reports to 

prepare official property records and NASA Form 1018, "NASA Property in the Custody of 

Contractors." The Agency uses Form 1018 as the primary documentation in establishing the 

value of ISS property in its annual financial statements. 

Boeing judgmentally estimated the unit values for ISS spare parts made at its production 

facilities and used vendor invoices to value spare parts made by Boeing subcontractors. 

However, Boeing did not allocate indirect costs and applicable fee to the unit values of spare 

parts recorded on the DD Forms 250 and in the official property records. NASA adjusted its 

official property records for FY's 1998 through 2000 by adding fees to the property values 

reported for special test equipment, special tooling, Agency-peculiar equipment, and contract 

work-in-process.19 However, NASA could not determine the amount of fee that applied to 

 16Boeing also excluded fee and indirect costs in determining the value of ISS flight hardware. 17We could not determine the amount of the understatement for each fiscal year because only cumulative totals 

through FY 2000 were available for our use. 18The Federal Financial Accounting Standards define PP&E as tangible assets that have an estimated life of 2 or 

more years, are not intended for sale in the ordinary course of business, and are intended to be used or available 

for use by the entity. 

19Except for contract work-in-process, the Agency adjusted the three categories for property valued at 

$100,000 or more. 

7 
ISS spare parts. Because of Boeing’s omissions in the values for spare parts, NASA 

understated by about $39 million the aggregate spare parts values it reported in the Agency's

financial statements from FY’s 1995 through 2000. The $39 million represented about 

$27.6 million in fees and about $11.4 million in indirect costs that NASA paid to Boeing on 

the total cost of spare parts through FY 2000. 

DCAA Review of Contractor-Held Property 

Arthur Andersen LLP, an independent certified public accounting firm, audited NASA’s 

FY 2000 Financial Statements. At our request and in conjunction with NASA's FY 2000 

Financial Statement audit,20 DCAA collected information on NASA property in the 

possession of 10 major contractors, including Boeing. Regarding Boeing, DCAA reported in 

January 2001 that the contractor did not consistently value Government property in 

accordance with generally accepted accounting principles and NASA FAR Supplement 

1845.7101-3.21 In particular, Boeing had not included shipping and other material handling 

costs (indirect costs) when determining the unit cost for Government property. Also, Boeing 

had not accumulated actual costs for fabricated assets. Therefore, the asset value that Boeing 

reported to NASA each time Boeing delivered a fabricated asset was based on estimated 

costs. Further, DCAA reported that, due to shortcomings in Boeing's accounting system and 

property records,22 the associated costs such as engineering, testing, analysis, overhead, and 

fee were not readily available to determine the total unit acquisition cost. 

Independent Audit of NASA's FY 2000 Financial Statements 

In its February 6, 2001 audit report, Arthur Andersen issued an unqualified opinion on 

NASA’s financial statements (see Appendix D). Arthur Andersen found no material 

weaknesses23 in internal controls and no reportable conditions24 of noncompliance with the 

laws and regulations it tested. However, the public accountant identified one reportable 

condition involving controls over contractor-held property reporting. That is, DCAA, in 

conjunction with the Arthur Andersen audit, found internal control deficiencies regarding 

contractor-held property accounting procedures at Boeing’s sites at Canoga Park, California; 

Huntington Beach, California; and Huntsville, Alabama. 

 20We asked DCAA to collect information on NASA property in the possession of contractors to assist the 

Agency and Arthur Andersen in assessing the accuracy of contractor-held property as recorded in the financial 

records and to evaluate certain internal controls related to such property. 21DCAA issued Report No. 3521-2001B17800904, "Report on Application of Agreed-Upon Procedures, 

Government Property in the Possession of NASA Contractors," in January 2001 (see Appendix D). 22DCAA found that Boeing's policies and procedures lacked sufficient detail and specificity with respect to

establishing unit acquisition costs for Government property. 23A material weakness is a reportable condition in which the design or operation of one or more internal control

structure elements does not reduce to a relatively low level the risk that errors or irregularities in amounts that 

would be material in relation to the financial statements being audited may occur and not be detected within a 

timely period by employees in the normal course of performing their assigned functions. 24A reportable condition is a matter that, in the auditor's judgment, should be communicated because it 

represents a significant deficiency in the design or operation of internal control that could adversely affect the 

organization's ability to meet internal control objectives of reliable financial reporting, compliance with laws and

regulations, and reliable performance reporting. 

8 
Recommendations by DCAA and Arthur Andersen. To resolve the internal control 

deficiencies regarding contractor-held property reporting that were disclosed during the 

NASA FY 2000 Financial Statements audit, Arthur Andersen made several recommendations 

to NASA, and DCAA made a recommendation to Boeing. Specifically, in a February 2001 

management letter, Arthur Andersen recommended that NASA perform a comprehensive 

assessment of policies and procedures maintained and followed by contractors to ensure the 

policies and procedures are in accordance with the NASA FAR Supplement. When they are 

not in compliance with the NASA FAR Supplement and generally accepted accounting 

principles, NASA should reach a conclusion and document its acceptance of these deviations. 

Arthur Andersen also recommended that NASA perform periodic reviews of amounts 

reported on NASA Forms 1018 using consistent review criteria to ensure that Boeing is 

following policies and procedures. Additionally, in July 2001, DCAA recommended that 

Boeing production sites revise policies to specifically include all the costs described in NASA 

FAR Supplement 1845.7101-3 when determining the unit acquisition cost of Government 

property. NASA agreed with all the recommendations and is taking action to resolve 

deficiencies regarding contractor-held property reporting, such as providing training on 

NASA Form 1018 reporting to contractors at NASA Centers. Pricewaterhouse Coopers LLP, 

an independent certified public accounting firm, performed NASA’s FY 2001 financial 

statement audit and reviewed the corrective actions taken by NASA with the assistance of 

DCAA.25 Pricewaterhouse Coopers LLP determined that the FY 2000 financial statement 

audit recommendation on the reporting of contractor-held Government property was still open 

as of March 2002. Therefore, we are making the recommendation below for ISS spare parts. 

Recommendation, Management's Response, and Evaluation of Response

5. The Acting Director, Lyndon B. Johnson Space Center, should ensure Boeing 

includes fee and indirect costs in the value of ISS spare parts recorded on the receiving 

reports submitted to NASA, as required by NASA FAR Supplement 1845.7101-3.

Management's Response. Concur. Johnson directed Boeing to include total costs and fee in 

the spare parts value recorded on receiving reports submitted to NASA. Johnson is reviewing 

the property records to ensure total costs are reflected. 

Evaluation of Response. Management's comments are responsive to the recommendation. 

The recommendation is resolved but will remain undispositioned and open until the agreed-to 

corrective actions are completed. 

 25DCAA reviewed the records at three prime contractors (Boeing, Lockheed Martin, and United Space Alliance) 

and two subcontractors (Boeing-Huntington Beach, and Honeywell). 

9 
Appendix A. Objectives, Scope, and Methodology 

Objectives 

The overall objective was to determine whether NASA properly acquired and accounted for 

International Space Station (ISS) spare parts. Specifically, we determined whether NASA 

appropriately justified and approved the acquisition of ISS spare parts through 

noncompetitive contract modifications, paid a fair and reasonable price for ISS spare parts, 

and adequately supported the value of the spare parts inventory that the Agency reports in its 

annual financial statements. 

Scope and Methodology 

To satisfy our objectives, we reviewed the portions of the ISS contract (NAS15-10000) 

pertaining to spare parts acquisition. We interviewed personnel from NASA, Blackhawk 

Corporation (NASA's support contractor), and The Boeing Company regarding procedures for 

budgeting, acquiring, accounting for, and valuing spare parts. We reviewed applicable 

regulations including the NASA Management Instruction, Federal Acquisition Regulation 

(FAR), and NASA FAR Supplement regarding contracting and property accountability of 

spare parts as well as Federal law regarding reporting of spare parts in NASA’s financial 

statements. We reviewed Department of Defense DD Forms 250 on spare parts Boeing 

delivered to NASA to determine the basis for spare parts values in NASA’s property records 

and financial statements. Also, we determined the extent to which NASA made repetitive 

purchases. We did not assess the reliability of computer-processed data because we did not 

rely on it to achieve our objectives. 

Management Controls Reviewed 

We reviewed management controls relative to the acquisition of and accounting for ISS spare 

parts and property accountability and reporting in the NASA financial statements. We

determined that management controls needed to be strengthened to ensure that NASA 

complies with applicable policies and procedures on acquiring and accounting for spare parts 

(see Findings A and B). 

Audit Field Work

We performed the audit field work from January through June 2001 at the Lyndon B. Johnson 

Space Center. We performed the audit in accordance with generally accepted government 

auditing standards. 

Summary of Prior Audits and Reviews 

The Defense Contract Audit Agency and NASA's independent certified public accounting 

firm issued audit reports related to Boeing's accounting for Government property. The reports 

are summarized in Appendix D of this report. 

10 
Appendix B. International Space Station Contract 

Brief Description of the Statement of Work. The Statement of Work for the International 

Space Station (ISS) contract describes The Boeing Company’s (Boeing's) requirements for the 

design, development, manufacture, integration, test, verification, and delivery to NASA of the 

U.S. On-Orbit Segment26 of the ISS, including ground support equipment and for support for 

ground and orbital operations. The Statement of Work also requires that Boeing provide 

technical support and data for NASA's operation and utilization of the ISS and describes 

Boeing’s requirements to integrate the complete ISS System. 

Date Awarded and Price. NASA awarded the ISS contract (NAS15-10000) on 

January 13, 1995, for a total value of $5.638 billion. As of February 2002, the contract value 

was $10.8 billion. 

Major Modifications. On December 21, 1999, the ISS contract was restructured. The 

purpose of this restructuring was to definitize adjustments to the estimated costs and fees, 

change the contract type, and effect other contract actions. Boeing and the ISS Program

Office agreed that the modification provided a full equitable adjustment for all issues that 

were identified or known prior to October 1, 1999.27 Modification 1114, dated February 7, 

2002, added $934 million to the contract value and extended the station integration and 

operations work through the current period of performance, December 31, 2003.28 

Contract Type. The ISS contract initially was a cost-plus-award fee/incentive fee/fixed fee 

contract. When the contract was restructured, the fee structure was changed to a cost-plusaward fee/fixed fee contract. 

Estimated Completion Date. The ISS contract states that all work required under the 

contract shall be completed on or before December 31, 2003. Currently, the final On-Orbit 

Award Fee evaluation period is scheduled for 3 months after Flight No. UF5.29 The ISS 

Assembly Sequence, Revision F, June 2001, identifies the launch date for Flight No. UF5 as 

February 2005. 

 26The U.S. On-Orbit Segment is an Earth-orbiting facility that houses experiment payloads, distributes resource 

utilities, and supports permanent human habitation for conducting research and science experiments in a 

microgravity environment. 27Office of Inspector General Report Number IG-02-002, "Restructuring of the International Space Station 

Contract," November 8, 2001, further discusses the modification. 28This work has been planned and is contained in the budget estimates represented in the FY 2003 President’s 

budget. 29Flight No. UF5 provides for experiment delivery, resupply, and exchange for the ISS. Elements contained on 

the flight include a multipurpose logistics module, which carries inside experiment equipment racks, and an 

express pallet, which carries external experiment equipment.

11 
Appendix B

Contractor. The prime contractor for the ISS is Boeing. Boeing has four development sites 

at Huntsville, Alabama; Canoga Park, California; Huntington Beach, California; and Houston, 

Texas.

Costs Incurred to Date. As of February 2002, NASA had disbursed $9.787 billion on the 

ISS contract. 

Cost and Schedule Performance. Boeing’s Performance Measurement System Report, 

January 2002, indicates that since contract inception, Boeing has declared $1.1 billion in cost 

overruns. NASA estimated that the overrun will be $1.2 billion. 

12 
Appendix C. Procurement Requirements 

Federal Acquisition Regulation (FAR) 15.402, "Pricing Policy"

Contracting officers must (a) purchase supplies and services from

responsible sources at fair and reasonable prices.

NASA FAR Supplement 1845.7101-3, "Unit Acquisition Cost" 

(a) The unit acquisition cost shall include all costs incurred to bring the 

property to a form and location suitable for its intended use. For 

example, the cost shall include the following, as appropriate: 

(1) Amounts paid to vendors or other contractors. 

(2) Transportation charges to the point of initial use. 

(3) Handling and storage charges. 

(4) Labor and other direct or indirect production costs (for assets

produced or constructed). 

(5) Engineering, architectural, and other outside services for 

designs, plans, specifications, and surveys. 

(6) Acquisition and preparation costs of buildings and other 

facilities. 

(7) An appropriate share of the cost of the equipment and 

facilities used in construction work. 

(8) Fixed equipment and related installation costs required for 

activities in a building or facility. 

(9) Direct costs of inspection, supervision, and administration of 

construction contracts and construction work. 

(10) Legal and recording fees and damage claims. 

(11) Fair values of facilities and equipment donated to the 

Government. 

(12) Material amounts of interest costs paid. 

(b) Acquisition cost shall include, where appropriate, for contractor 

acquired Special Test Equipment, Special Tooling, AgencyPeculiar Property and Contract Work-In-Process, related fees, or a 

pro rata portion of fees, paid by NASA to the contractor. 

Situations where inclusion of fees in the acquisition cost would be 

appropriate are those in which the contractor designs, develops, 

fabricates or purchases property for NASA and part of the fees 

paid to the contractor by NASA are related to that effort. 

(d) The contractors shall report unit acquisition costs using records 

that are part of the prescribed property or financial control system

as provided in this section. Fabrication costs shall be based on 

approved systems or procedures and include all direct and indirect

costs of fabrication. 

13
Appendix C 

NASA Management Instruction (NMI) 5900.1B, "NASA Spare Parts Acquisition 

Policy"

This instruction established a uniform policy for the acquisition and provisioning of 

NASA spare parts: 

It is NASA policy to support its nonexpendable major systems by

applying sound management and engineering judgment to selecting and 

acquiring spare parts in the quantities and at the lowest fair and

reasonable cost, consistent with the program being supported. 

Breakout and competitive procurement, particularly of replenishment 

spares, are encouraged to the maximum extent practicable. 

Paragraph 6(a), “Initial Provisioning,” states: 

(1) Initial provisioning shall be accomplished during full-scale 

development of a major system. The contractor is required to:

(a) Develop a list of proposed spare parts and related quantities 

needed to support the major system during the initial 

provisioning period. The list should provide the basis for an 

assessment of the potential for breakout and competition. 

There must be for each item a unit price, an identification of 

the original equipment manufacturer (OEM), and a listing of 

the OEM’s most recent selling price to the next higher tier 

contractor. 

(b) Submit to NASA the list developed in subparagraph (a) and 

participate in an initial provisioning conference in which

NASA evaluates the contractor’s recommendations and the 

data upon which they are based and makes initial purchase 

and inventory-stocking decisions.

(2) The contractor makes recommendations only. The decisions (a) to

purchase or not purchase an individual item suggested by the 

contractor as a spare part and (b) on the quantity of each item to be 

purchased are made solely by NASA. Program managers shall

ensure that spares’ recommendations are processed and purchase 

decisions made in a timely manner in order to minimize 

procurement costs and have needed spare parts available prior to 

the first predicted usage of the system. 

(3) Program managers are responsible for assuring, as part of the 

initial provisioning process, that parts are screened for availability 

from Government sources and obtained from those sources if

available at a lower cost than other alternatives, providing that

traceability standards can be maintained. To the maximum extent 

14
Appendix C 

practicable, spares should be purchased directly from the actual

manufacturer, i.e., lowest-tier subcontractor, to eliminate the layers 

of support costs at each tier. Purchase requirements should be 

consolidated upon completion of NASA decisions on the 

contractor’s provisioning recommendations, and efforts should be 

made to identify and consolidate common hardware used in

various elements of the program. 

Paragraph 6(b), “Initial Provisioning Period,” states: 

(1) The basic contract should define an initial provisioning period. 

This period generally should cover test and evaluation, plus a short

period of operation, so that sufficient operational experience can 

be gained with the system to provide a basis for fully competitive 

acquisition of spare parts. 

(2) To provide a vehicle for ordering spare parts during this period, the 

contract shall include a separate line item, with a ceiling or not-toexceed amount, obligating the contractor to provide any parts 

identified during initial provisioning and ordered by the 

Government. Unless otherwise justified, prices shall be negotiated 

before the contractor begins work on an individual order. If 

possible, each order should be on a firm fixed-price basis with 

individual items separately priced (see paragraph f(1)). As 

experience is gained with the operational system, the items

selected as spare parts and the quantities needed may change. 

Individual item pricing will facilitate making those changes and

provide a pricing history for later purchases. 

(3) Early in the initial provisioning period, NASA typically orders 

spare parts exclusively from the major systems contractor. As 

experience is gained, however, opportunities to breakout items for 

competitive acquisition will become apparent. Before ordering

spare parts under the major systems contract, therefore, the 

contracting officer should examine the alternate sources that may

be available. 

Paragraph 6(f), “Pricing,” states: 

(1) Each purchase of spare parts must meet the criterion of a fair and 

reasonable price. Several different methodologies are used by

contractors to price spare parts. Certain of these can result in 

unrealistic and unreasonable prices for individual items even 

though the total cost of a particular spare parts order is reasonable;

e.g., distribution of overhead costs by prorating the costs equally

to each line item of the order without regard to the cost of the 

items involved. The concept of value added can help avoid this

pitfall. NASA personnel are cautioned, when selecting 

15
Appendix C 

and pricing spare parts, to use a value-based method of distributing 

costs to individual items of a spare parts order; i.e., ensure that unit

prices are in proportion to an item’s base cost (e.g., manufacturing 

or acquisition cost). 

(2) The Federal Acquisition Regulation (FAR), at 48 CFR

15.812-1(a), specifically prohibits any method of distributing costs 

to line items that distorts the unit prices. The FAR also

incorporates a contract clause of 48 CFR 52.215-26, Integrity of 

Unit Prices, that requires contractors, in certain circumstances, to 

identify items that they will not manufacture or to which they will 

not contribute significant value. Value added includes such items

as required quality assurance, calibration, and configuration

management; other activities, such as sustaining engineering,

provisioning, and cleaning, should be separately priced. Programs 

managers should use this information to determine when price 

distortions have occurred through overhead applications and what

resources to apply to breakout of the items. To assist in making 

these determinations, percentage-price-increase standards may be 

established for the program; e.g., item price increases of X percent 

over the original purchase price must be justified to and approved 

by the program manager. 

(3) If spare parts management and support are contracted out, special

care shall be taken by NASA personnel in pricing. In such 

situations, human resources associated with the acquisition of 

spares (sustaining engineering, procurement support, logistics, and 

so forth) and related overhead may be priced separately from the 

cost of the spare parts to the support contractor. If so, overhead, 

general and administrative expense, and fee charged directly 

against the spare parts prices shall be limited and checked for 

duplication to the maximum extent. Particular attention shall be

given to proposed overhead charges and whether the costs 

included therein are for value added and are incurred in specific 

support of the spare parts purchase. 

16
Appendix D. Prior Audits and Other Reviews 

Defense Contract Audit Agency Report 

Report No. 3521-2001B17800904, “Report on Application of Agreed-Upon 

Procedures, Government Property in the Possession of NASA Contractors,” 

January 5, 2001. 

The Defense Contract Audit Agency (DCAA) evaluated The Boeing Company’s 

practices for determining unit acquisition costs for NASA property additions for the 

period October 1, 1999, through September 30, 2000, on contract number NAS15-10000. 

DCAA reported that the contractor did not consistently value Government property in 

accordance with generally accepted accounting principles and NASA Federal Acquisition 

Regulation (FAR) Supplement 1845.7101-3. The evaluation determined that the 

contractor utilized purchase orders and invoices for contractor-acquired property, 

DD Forms 114930 for Government-furnished property, and estimates for fabricated 

property to determine acquisition cost. Boeing had not included shipping and other 

material handling costs (indirect costs) when determining the unit cost for Government 

property. Also, Boeing had not accumulated actual costs for fabricated assets at a 

sufficient level of detail necessary to determine actual costs. Therefore, the asset value 

that Boeing reported for fabricated assets was based on estimated costs. Additionally, 

due to Boeing's accounting system shortcoming, the associated costs (such as 

engineering, testing, analysis, and overhead) and fee were not readily available to 

determine the total unit acquisition cost. DCAA concluded that Boeing's accounting 

system and property records did not provide sufficient information and data to determine 

the unit acquisition costs for Government property. In July 2001, DCAA sent letters to 

Boeing production sites recommending that they revise their policies to specifically 

include all the costs described in NASA FAR Supplement 1845.7101-3 when 

determining the unit acquisition cost of Government property. 

Arthur Andersen LLP, An Independent Certified Public Accounting Firm 

NASA's FY 2000 Financial Statement Audit, February 6, 2001 

Arthur Andersen audited the NASA FY 2000 Financial Statements and issued an 

unqualified opinion. Arthur Andersen found no material weaknesses in internal controls 

and no reportable conditions of noncompliance with the laws and regulations it tested. 

However, the independent public accountant identified one reportable condition 

involving controls over contractor-held property reporting. Specifically, Arthur 

Andersen stated that as part of the 10 major contractor sites visited, DCAA, in 

conjunction with the financial statement audit, found internal control deficiencies 

regarding contractor-held 

 30DD Form 1149, “Requisition and Invoice/Shipping Document,” is a Department of Defense form used by 

the Federal Government to transfer property on loan. 

17
Appendix D 

property accounting procedures at Boeing’s sites at Canoga Park, California; Huntington 

Beach, California; and Huntsville, Alabama. In its Report of Independent Public 

Accountants on Internal Control, Arthur Anderson stated that NASA's internal controls 

for the reporting of contractor-held property required improvement to ensure that 

contractor-held property is reported in accordance with NASA and Federal accounting 

requirements. Specifically, NASA should enhance existing procedures designed to 

educate contractor personnel and NASA property administrators on property accounting 

and reporting requirements. Further, Arthur Andersen recommended that NASA perform

a comprehensive assessment of policies and procedures maintained and followed by 

contractors to ensure they are in accordance with the NASA FAR Supplement. When 

contractor policies and procedures are not in compliance with the NASA FAR 

Supplement and generally accepted accounting principles, NASA should reach a 

conclusion and document the acceptance of these deviations. NASA should also perform

periodic reviews of amounts reported on NASA Forms 101831 using consistent review 

criteria to ensure that its contractors perform contractor-held property reporting in 

accordance with NASA FAR Supplement requirements. 

 31The Agency uses NASA Form 1018, "NASA Property in the Custody of Contractors," as the primary

documentation in establishing the value of International Space Station property in NASA’s annual 

financial statements. 

18
Appendix E. Management’s Response 

19 
Appendix E 

 See Appendix F, 

 OIG Comment 1 

 See Appendix F, 

 OIG Comment 2 

20 
Appendix E 

See Appendix F,

OIG Comment 3

See Appendix F,

OIG Comment 1

21 
Appendix E 

22 
Appendix E 

23 
Appendix E 

24 
Appendix F. OIG Comments on Management’s Response 

The Johnson Space Center (Johnson) provided the following comments in its response to 

our draft report. Our responses to the comments are also presented. 

Management Comments. NASA does not agree that the approach for ISS spare parts 

procurements through FY 2000 resulted in the Government paying unfair or unreasonable 

prices. 

1. OIG Comments. We have reworded the finding to state that Johnson had no 

assurance that the prices it paid to Boeing were fair and reasonable. 

Management Comments. NASA Management Instruction (NMI) 5900.1B does not 

require contractors to track and report individual spare parts prices. 

2. OIG Comments. We agree that NMI 5900.1B does not explicitly state that 

contractors should track and report individual spare parts prices. However, the NMI 

states that, if possible, each order of spare parts should be on a firm fixed-price basis with 

individual items separately priced to provide a pricing history for later purchases. 

Therefore, The Boeing Company should track and report individual spare parts prices so 

that NASA can develop pricing histories. 

Management Comments. Change order accounting is not an effective method of 

achieving individual spare parts pricing because it applies only through the provisioning 

item order definitization period (about 6 months or less) and would be too costly. 

3. OIG Comments. We acknowledge that change order accounting may not be an 

appropriate method of achieving individual spare parts pricing and, accordingly, we have 

deleted all references to it. 

25 
Appendix G. Report Distribution 

National Aeronautics and Space Administration (NASA) Headquarters

A/Administrator 

AI/Associate Deputy Administrator 

AB/Associate Deputy Administrator for Institutions 

AE/Chief Engineer 

B/Acting Chief Financial Officer 

B/Comptroller 

BF/Director, Financial Management Division 

G/General Counsel 

H/Assistant Administrator for Procurement 

HK/Director, Contract Management Division 

HS/Director, Program Operations Division 

J/Assistant Administrator for Management Systems 

JM/Director, Management Assessment Division 

L/Assistant Administrator for Legislative Affairs 

M/Associate Administrator for Space Flight 

NASA Centers 

Acting Director, Lyndon B. Johnson Space Center 

Director, Kennedy Space Center 

 Chief Counsel, Kennedy Space Center 

Director, Marshall Space Flight Center 

Non-NASA Federal Organizations and Individuals 

Assistant to the President for Science and Technology Policy 

Deputy Associate Director, Energy and Science Division, Office of Management and 

 Budget 

Branch Chief, Science and Space Programs Branch, Energy and Science Division, Office 

 of Management and Budget 

Director, Acquisition and Sourcing Management Team, General Accounting 

 Office 

Senior Professional Staff Member, Senate Subcommittee on Science, Technology, and 

 Space 

26 
Appendix G 

Chairman and Ranking Minority Member – Congressional Committees and 

Subcommittees 

Senate Committee on Appropriations 

Senate Subcommittee on VA, HUD, and Independent Agencies 

Senate Committee on Commerce, Science, and Transportation 

Senate Subcommittee on Science, Technology, and Space 

Senate Committee on Governmental Affairs 

House Committee on Appropriations 

House Subcommittee on VA, HUD, and Independent Agencies 

House Committee on Government Reform

House Subcommittee on Government Efficiency, Financial Management, and 

 Intergovernmental Relations 

House Subcommittee on Technology and Procurement Policy 

House Committee on Science 

House Subcommittee on Space and Aeronautics 

Congressional Member 

Honorable Pete Sessions, U.S. House of Representatives 

27 
NASA Assistant Inspector General for Audits 

Reader Survey 

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or can be mailed to the Assistant Inspector General for Audits; NASA Headquarters, 

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