IG-00-046

AUDIT

REPORT NASA SETTLEMENT OF

DCAA’S INCURRED COST AUDITS AT GODDARD

SPACE FLIGHT CENTER

September 18, 2000

National Aeronautics and

Space Administration

OFFICE OF INSPECTOR GENERAL
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Acronyms

ACO Administrative Contracting Officer

DCAA Defense Contract Audit Agency

DoD Department of Defense

FAR Federal Acquisition Regulation

FY Fiscal Year

GAO General Accounting Office

NPG NASA Procedures and Guidelines

OIG Office of Inspector General

OMB Office of Management and Budget
W September 18, 2000

TO: A/Administrator

FROM: W/Inspector General

SUBJECT: INFORMATION: NASA Settlement of DCAA's

Incurred Cost Audits at Goddard Space Flight Center

Report Number IG-00-046

The NASA Office of Inspector General has completed an audit of NASA Settlement of

Defense Contract Audit Agency’s (DCAA’s) Incurred Cost Audits at Goddard Space Flight

Center (Goddard). NASA policies and procedures for resolution and disposition of contract

audit findings and recommendations comply with Office of Management and Budget (OMB)

Circular A-50 requirements.1 However, the follow-up and settlement of DCAA’s incurred cost

audits at Goddard can be improved. Specifically, we found the Goddard contract audit followup system did not include complete records of actions taken on findings and recommendations

for 14 of 16 sampled DCAA audit reports for which the resolution and disposition authority had

been delegated to the Department of Defense (DoD). As a result, Goddard procurement

personnel may not be able to ensure that audit findings and recommendations were resolved in a

timely manner and that the resolutions were in NASA’s best interest.

In addition, Goddard did not meet Federal Acquisition Regulation (FAR) guidelines on closing

out 10 physically completed contracts. The average time awaiting closeout for the 10 contracts

was about 55 months. Delays in contract closeout can result in excess unliquidated obligations

that could be used for other NASA programs. In addition, the delays can directly affect the

success of Government negotiations and result in increased workload for contractors and

contracting officers.

 

1

 OMB Circular A-50, “Audit Followup,” requires all agencies, including NASA, to establish audit follow-up systems

“to assure the prompt and proper resolution and implementation of audit recommendations.”
2

Background

NASA uses the services of other Federal agencies to perform audits of contractors, educational

institutions, and nonprofit organizations receiving NASA grants and contract

awards. In fiscal years (FY’s) 1997 and 1998, NASA spent $32 million ($16.5 million and

$15.6 million, respectively) on contract audit services provided by the DCAA. Of the $32

million, NASA paid about $6 million for audit services performed for NASA contracts at

Goddard.

To improve the effectiveness and efficiency of Government operations, the OMB issued

Circular A-50, which addresses establishing audit follow-up systems. Resolution should occur

within a maximum of 6 months after issuance of a final report, and corrective action should

proceed as rapidly as possible. The Circular requires that the follow-up systems provide for a

complete record of action taken on both monetary and nonmonetary findings and

recommendations. Furthermore, the Circular establishes 11 standards that follow-up systems

must meet, including assuring that “performance appraisals of appropriate officials reflect

effectiveness in resolving and implementing audit recommendations.”

As part of its oversight duties, the NASA Headquarters Office of Procurement conducts

surveys at NASA installations that address, in part, contract audit follow-up of reportable

contract audit (RCA) reports.2

We have completed audits of NASA’s Contract Audit Follow-up System at Marshall Space

Flight Center (Marshall) 3 and Johnson Space Center (Johnson).4 NASA management

concurred with all the recommendations in the final audit reports and is taking corrective actions.

Because of the prior audits, we limited our review at Goddard to the NASA follow-up process

for DCAA incurred cost audits.

Recommendations

We recommended that the Associate Administrator for Procurement issue guidance to

contracting officers on participating in final indirect cost negotiations for those contractors

 

2 DCAA Contract Audit Manual 7640.1, Section 15-603.2, “Reporting Requirements,” defines reportable contract

audit reports as: (1) reports containing findings and recommendations covering estimating system surveys, accounting

and related internal control system reviews, defective pricing reviews and cost accounting standards matter; (2) reports

covering operations audits, incurred costs, settlement of final indirect cost rates, final pricing submissions, termination

settlement proposals and claims, if reported costs or rates questioned or unsupported/qualified equal $100,000 or more;

and (3) reports on audit-determined final indirect cost rates when the auditor cannot reach an agreement with the

contractor.

3

 NASA OIG issued final audit report number IG-00-010, “NASA Contract Audit Follow-up System at Marshall

Space Flight Center,” on March 6, 2000.

4

 NASA OIG issued final audit report number IG-00-032, “NASA Contract Audit Follow-up System at Johnson Space

Center,” on May 19, 2000.
3

for which NASA has a major financial interest as required by NASA FAR Supplement

1842.705. In addition, the Director, Goddard Space Flight Center, should monitor the

effectiveness of the actions planned and taken to improve Goddard’s efforts to close physically

completed fixed-price contracts and contracts needing settlement of indirect cost rates within

the time frames specified by the FAR.

During prior audits of the NASA Contract Audit Follow-up System at Marshall and Johnson,

we recommended that NASA management take corrective actions regarding (1) communication

with DoD administrative contracting officers who have been delegated activities on NASA

contracts and (2) resolution of contract audit report recommendations within 6 months of

issuance of the final audit report. Because management concurred with the recommended

actions, we made no further recommendations on these issues in this report.

Management Response

Management generally concurred with the recommendations. NASA management will clarify

NASA FAR Supplement 1842.705 for contracting officers on participating in final indirect cost

rate negotiations for which NASA has a major financial interest and will discuss with DoD its

role in this process. The Director, Goddard Space Flight Center, has taken corrective actions

to reduce and better manage overaged unliquidated obligations and contract closeouts.

The actions planned or taken by management are responsive to the recommendations. Details

on the status of the recommendation are in the recommendation section of the report.

[original signed by]

Roberta L. Gross

Enclosure

Final Report on Audit of NASA Settlement of DCAA's Incurred Cost Audits at

Goddard Space Flight Center
FINAL REPORT

AUDIT OF NASA SETTLEMENT OF

DCAA'S INCURRED COST AUDITS AT

GODDARD SPACE FLIGHT CENTER
September 18, 2000

W

TO: H/Associate Administrator for Procurement

100/Director, Goddard Space Flight Center

FROM: W/Assistant Inspector General for Auditing

SUBJECT: Final Report on Audit of NASA Settlement of DCAA's

Incurred Cost Audits at Goddard Space Flight Center

Assignment Number A0002900

Report Number IG-00-046

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 is incorporated into the

body of the report. Management comments were responsive to the recommended corrective

actions. Management's actions are sufficient to close Recommendation 2 for reporting

purposes. Recommendation 1 will remain open for reporting purposes until corrective actions

are completed. Please notify us when actions have been completed on the recommendation,

including the extent of testing performed to ensure corrective actions are effective.

If you have questions concerning the report, please contact Mr. Lorne A. Dear, Program

Director, Procurement Audits, at (818) 354-3360; Mr. Tony A. Lawson, Audit Program

Manager, at (301) 286-6524; or Ms. Lydia C. Lin, Auditor-in-Charge, at (281) 483-0741.

We appreciate the courtesies extended to the audit staff. The final report distribution is in

Appendix G.

[original signed by]

Russell A. Rau

Enclosure
 2

cc:

AO/Chief Information Officer

B/Chief Financial Officer

B/Comptroller

BF/Director, Financial Management Division

G/General Counsel

JM/Acting Director, Management Assessment Division
Contents

Executive Summary, i

Introduction, 1

Findings and Recommendations, 2

Finding A. Adequacy of Monitoring Incurred Cost Audits When

NASA Delegated Resolution Authority, 2

Finding B. Timeliness in Closing Contracts after Physical

 Completion, 6

Appendix A - Objectives, Scope, and Methodology, 11

Appendix B – Incurred Cost Audits, 13

Appendix C – Audit Reports for Which NASA Delegated Resolution

and Disposition Authority, 14

Appendix D – Summary of Prior Coverage, 15

Appendix E – Contracts Physically Completed and in Closeout, 18

Appendix F – Management's Response, 19

Appendix G – Report Distribution, 25
NASA Office of Inspector General

IG-00-046

 A0002900 September 18, 2000

NASA Settlement of DCAA's Incurred Cost Audits at

Goddard Space Flight Center

Executive Summary

Background. NASA uses the services of other Federal agencies to perform audits of

contractors, educational institutions, and nonprofit organizations receiving NASA grants and

contract awards. In FY’s 1997 and 1998, NASA spent $32 million ($16.5 million and $15.6

million, respectively) on contract audit services provided by the DCAA. Of the $32 million,

NASA paid about $6 million for audit services performed for NASA contracts at Goddard.

To improve the effectiveness and efficiency of Government operations, the OMB issued

Circular A-50, which requires all agencies, including NASA, to establish audit follow-up

systems “to assure the prompt and proper resolution5 and implementation of audit

recommendations.” Resolution should occur within a maximum of 6 months after issuance of a

final report, and corrective action should proceed as rapidly as possible. FAR Subpart 4

requires firm fixed-price contracts to be closed within 6 months after the date on which the

contracting officer receives evidence of physical completion. The FAR subpart also requires

contracts needing settlement of indirect cost rates to be closed within 36 months. The Circular

requires that the follow-up systems provide for a complete record of action taken on both

monetary and nonmonetary findings and recommendations. Furthermore, the Circular

establishes 11 standards that follow-up systems must meet, including assuring that “performance

appraisals of appropriate officials reflect effectiveness in resolving and implementing audit

recommendations.”

As part of its oversight duties, the NASA Headquarters Office of Procurement conducts

surveys at NASA installations that address, in part, contract audit follow-up of RCA reports.

We have completed audits of NASA’s Contract Audit Follow-up System at Marshall and

Johnson. NASA management concurred with all the recommendations in the reports on those

audits and is taking corrective actions. Because of the prior audits, we limited our review at

Goddard to the NASA follow-up process for DCAA incurred cost audits.

 

5

 Resolution is the point at which the audit organization and agency management or contracting officials agree on action

to be taken on reported findings and recommendations; or in the event of disagreement, resolution is the point at which

the audit follow-up official determines the matter to be resolved.
ii

Objectives. The overall objective was to evaluate the adequacy of NASA’s settlement of the

DCAA's incurred cost audits at Goddard. Additional details on the objectives, scope, and

methodology are in Appendix A.

Results of Audit. NASA policies and procedures for resolution and disposition of contract

audit findings and recommendations comply with OMB Circular A-50 requirements. However,

the follow-up and settlement of DCAA’s incurred cost audits at Goddard can be improved.

• The system did not include complete records of action taken on findings and

recommendations for 14 of 16 sampled DCAA audit reports for which the resolution and

disposition authority had been delegated to the DoD. As a result, Goddard procurement

personnel may not be able to ensure that audit findings and recommendations were resolved

in a timely manner and that the resolutions were in NASA’s best interest (Finding A).

• Goddard did not meet FAR guidelines on closing out 10 physically completed6 contracts.

Five of 23 Goddard contracts covered by the 16 sampled DCAA incurred cost audit

reports were awaiting closeout. In addition, Goddard procurement personnel identified five

additional contracts that were not delegated to DoD and were not covered by the sampled

audit reports. The five additional contracts were also awaiting closeout. The average time

awaiting closeout for all 10 contracts was about 55 months. Delays in contract closeout can

result in excess unliquidated obligations that could be used for other NASA programs. In

addition, the delays can directly affect the success of Government negotiations and result in

increased workload for contractors and contracting officers (Finding B).

Recommendations. We recommended that the Associate Administrator for Procurement

issue guidance to contracting officers on participating in final indirect cost negotiations for those

contractors for which NASA has a major financial interest as required by NASA FAR

Supplement 1842.705. In addition, the Director, Goddard Space Flight Center, should monitor

the effectiveness of the actions planned and taken to improve Goddard’s efforts to close

physically completed fixed-price contracts and contracts needing settlement of indirect cost

rates within the time frames specified by the FAR.

During prior audits of the NASA Contract Audit Follow-up System at Marshall and Johnson,

we recommended that NASA management take corrective actions regarding (1) communication

with DoD administrative contracting officers who have been delegated activities on NASA

contracts and (2) resolution of contract audit report recommendations within 6 months of

 

6

FAR Subpart 4.804-4, “Physically completed contracts,” states that a contract is physically completed when (1) the

contractor has completed the required deliveries and the Government has inspected and accepted the supplies; (2) the

contractor has performed all services and the Government has accepted these services; and (3) all options, if any, have

expired.
iii

issuance of the final audit report. NASA management concurred with the recommended

actions; therefore, we are making no other related recommendations on these issues.

Management's Response. Management generally concurred with the recommendations. NASA

management will clarify NASA FAR Supplement 1842.705 for contracting officers on

participating in final indirect cost rate negotiations for which NASA has a major financial

interest, and will discuss with DoD their role in this process. The Director, Goddard Space

Flight Center, has taken corrective actions to reduce and better manage overaged unliquidated

obligations and contract closeout. The complete text of the response is in Appendix F.

Evaluation of Management's Response. Management's actions are responsive to both

recommendations. We consider recommendation 2 dispositioned and closed for reporting

purposes. We are monitoring recommendation 1 concerning the requirements to jointly

participate in the DoD negotiations where NASA has a major financial interest.
Introduction

Policies and procedures concerning NASA contract audit follow-up systems are contained in

NASA FAR Supplement 1842.73017 and NASA Procedures and Guidelines (NPG) 1200.1.8

The policies and procedures require that NASA contract audit follow-up systems track all

contract and OMB Circular A-1339 audits for which NASA has resolution and disposition

authority and that audit recommendations be resolved as expeditiously as possible within 6

months of the issuance of the final audit report. NASA FAR Supplement 1842.7301 also

requires that, when contract administration is delegated, NASA contracting officers should at

least semiannually review and document in the contract files the status and resolution of

significant audit findings.

DCAA usually performs incurred cost audits on a contractor-wide basis. This approach (see

Appendix B) recognizes the efficiency of addressing the adequacy of management and financial

systems and controls combined with transaction testing across all business activities as opposed

to contract-by-contract audits. The primary objective for incurred cost audits is to determine

whether the incurred costs are reasonable, applicable to the contract, and not prohibited by the

contract, statute, or regulations.

 

7

 NASA issued FAR Supplement 1842.7301, “NASA external audit follow-up system,” on

January 26, 1998.

8

 NASA issued NPG 1200.1, “Management Accountability and Control, Audit Liaison, and Audit Follow-up,” on

October 8, 1997.

9

 OMB issued Circular A-133, “Audits of States, Local Governments, and Non-Profit Organizations,” on June 24,

1997.
2

Findings and Recommendations

Finding A. Adequacy of Monitoring Incurred Cost Audits When

NASA

Delegated Resolution Authority

The Goddard contract audit follow-up system did not include complete records of action on

incurred cost audit findings and recommendations for 14 of the 16 sampled DCAA audit

reports for which NASA delegated resolution and disposition authority to DoD. Goddard

procurement personnel did not (1) maintain adequate dialogue with the DoD administrative

contracting officers (ACO’s) who have been delegated activities on NASA contracts, (2)

document the status and resolution of significant audit findings in the contract files, or (3)

participate jointly with DoD ACO’s in final overhead determination procedures as required by

NASA FAR Supplement 1842.705. As a result, Goddard could not ensure that audit findings

and recommendations were resolved in a timely manner and that recovered questioned costs

were appropriately distributed to NASA contracts.

OMB, NASA, and FAR Guidance

OMB Circular A-5010 requires that agencies establish contract audit follow-up systems “to

assure the prompt and proper resolution and implementation of audit recommendations.” The

Circular requires follow-up systems to provide “complete records of action taken on both

monetary and nonmonetary findings and recommendations.”

To fulfill the requirements of the Circular, NASA FAR Supplement 1842 requires NASA

contracting officers to communicate with DoD ACO’s who have been delegated activities on

NASA contracts. The NASA contracting officers are required to conduct a review of

reportable contract audit reports under NASA cognizance, no less frequently than semiannually

and to document in their contract files the status and disposition of significant DCAA audit

findings.

In addition, FAR 42.70511 states that contracting officers of Federal agencies having significant

dollar interest in a contractor’s final indirect cost rate proposal should be invited to participate in

the negotiation and in the preliminary discussion of critical issues. To fulfill FAR requirements,

NASA FAR Supplement 1842.70512 states that NASA's policy is to participate jointly with

DoD for those companies for which NASA has a major financial interest.

 

10 OMB revised Circular A-50, “Audit Follow-up,” on September 29, 1982.

11 FAR 42.705, “Final Indirect Cost Rates,” sets forth contracting officer determination procedure.

12 NASA FAR Supplement 1842.705, “Final Indirect Cost Rates,” implemented FAR 42.705 requirements.
3

NASA Delegation of Resolution and Disposition Authority

NASA delegated to DoD the authority for resolution and disposition of the findings in the 16

reports reviewed (Appendix C lists the reports). However, Goddard procurement personnel

generally did not monitor the status and resolutions of the report findings delegated to DoD

ACO’s, did not always document the resolution of such reports in contract files, and were often

unaware of DoD actions that affected their contracts for 14 of the 16 reports. Consequently,

NASA could not ensure that audit findings and recommendations were resolved on a timely

basis and that the resolutions were in NASA's best interest. Further, NASA's contract audit

follow-up systems did not track the status of incurred cost audit reports DoD is responsible for

resolving.

Questioned costs for seven DCAA reports totaled more than $10 million as illustrated below:

• Two reports on one contractor's incurred costs included $11.6 million and $14 million,

respectively, in questioned costs. The ACO sustained (recovered) $4.8 million and $9.5

million of the questioned costs, respectively. NASA’s share of the sustained questioned

costs was $675,000 of the $4.8 million and $1.4 million of the $9.5 million. The Goddard

contract file had no record of the recovered costs.

• Three reports on one contractor's incurred costs for 1994, 1995, and 1996, identified

questioned costs of $14 million, $10.2 million, and $14.6 million, respectively. The ACO

sustained $3.3 million, $5 million, and $3.6 million respectively. NASA’s share of the

recovered questioned costs was $52,000 of the $3.3 million, $429,000 of the $5 million,

and $74,000 of the $3.6 million. The Goddard contract file had no record of the recovered

costs.

In addition, questioned costs for 3 of the 16 DCAA reports were for contracts for which

Goddard had a major financial interest. NASA’s share of the sustained questioned costs for

each of the three reports was 47 percent or higher (see Appendix C). The percentage of

sustained questioned costs generally represents an agency’s percentage of cost in the

contractors’ indirect cost allocation base used to allocate costs between the Government and

other contracts. In our opinion, such high percentages indicate a major financial interest. For

example:

• One report had sustained questioned costs of $2.8 million and NASA’s share was $2.6

million (that is, 95 percent of the total). The questioned costs were related to Goddard

contract NAS5-29500.

• One report had sustained questioned costs of $1.1 million and NASA’s share was

$530,000 (that is, about 47 percent of the total). The questioned costs were related to

Goddard contracts NAS5-30800 and NAS5-32631.
4

NASA delegated to DoD ACO’s the authority to resolve and disposition the audit findings.

NASA Form 1430, “Letter of Contract Administration Delegation, General,” requires the DoD

ACO’s, among other things, to (1) obtain DCAA audit reports as requested and submit the

reports to the NASA contracting officer; (2) make secondary delegations as necessary and

provide copies of the delegations to the NASA contracting officer; (3) provide immediate input

to the NASA procurement office of significant program issues or problems; and (4) provide

input to the monthly report that includes the contractor’s systems, significant findings related to

these systems, and issues that could affect NASA contracts. For both of the reports discussed,

we would expect the ACO to inform NASA of the basis for the resolutions granted and the

allocations among NASA and other contracts. NASA contracting officers were not aware of

the basis for the resolutions granted or the allocations.

NASA Participation in Final Indirect Cost Rate Determination Procedures

NASA did not participate jointly with DoD ACO in final indirect cost rate determination

procedures. NASA contracting officers were not aware of the NASA FAR Supplement

1842.705 requirement, which states that NASA’s policy is to participate jointly with DoD for

those companies for which NASA has a major financial interest. NASA contracting officers

indicated that once the administrative function has been delegated to the ACO, the ACO is

responsible to conduct the contract negotiation.

Although NASA's policy is to optimize the use of contract administration services of other

Government agencies, NASA contracting officers must fulfill their oversight responsibilities.

Increased monitoring of DoD's audit resolution activities would allow NASA to (1) determine

the current status of all significant unresolved audits, (2) evaluate the appropriateness of the

audit resolution actions taken by DoD personnel, (3) ensure that recovered questioned costs

were appropriately distributed to NASA contracts, and (4) better understand the quality of their

contractors' business operations.

Corrective Actions To Be Taken by Management

We identified similar findings during our audits of the NASA Contract Audit Follow-up System

at Marshall and Johnson (Appendix D summarizes prior coverage) and made a

recommendation to the Associate Administrator for Procurement. The Associate Administrator

for Procurement concurred with the finding and agreed to reemphasize to all contracting officers

the NASA FAR Supplement 1842.7301(d) (3) requirements to (1) maintain a dialogue with

DoD ACO’s who have been delegated resolution authority on NASA contracts and (2)

conduct semiannual reviews and document the status and resolution of audit findings. Further,

contracting officers will require that delegated DoD ACO’s provide NASA with detailed

information on the resolution and disposition status of DCAA audit findings and

recommendations.
5

NASA has since issued Procurement Information Circular 00-06 and a letter to the Team

Leader, Procurement Management Survey Team, to include the "Audit Follow-up Process" in

all future procurement surveys. Circular 00-06 reemphasizes that it is important for contracting

officers to maintain a dialogue with the DoD ACO and to document the status and disposition of

significant audit findings accordingly in the contract file. Further, the Agency has revised NASA

Form 1430 to require the DoD ACO to specifically furnish to NASA detailed information on

DCAA audit reports. Therefore, we are making no other recommendation for corrective action

on this issue.

Recommendation, Management's Comments, and Evaluation of

Response

1. The Associate Administrator for Procurement should issue guidance to contracting

officers on participating in final indirect cost rate negotiations for those contractors

for which NASA has a major financial interest as required by NASA FAR

Supplement 1842.705.

Management's Response. Concur with intent. Management did not concur with the specific

method recommended. The Associate Administrator for Procurement will (1) clarify to all

Center procurement personnel the requirement for NASA to jointly participate in final indirect

rate negotiations with DoD ACO’s where NASA has a major financial interest, as required by

NASA FAR Supplement 1842.705, and (2) discuss with DoD management its role in this

process in order to ensure that DoD ACO’s are complying with the FAR.

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

recommendation. We consider Recommendation 1 resolved but undispositioned and open until

the agreed-to actions are completed.
6

Finding B. Timeliness in Closing Contracts after Physical Completion

Goddard has not met FAR guidelines on closing out 10 contracts (see Appendix E) after they

were physically completed. This occurred for various reasons including Goddard's large

closeout workload, decentralization of the contract closeout function, low priority of closeout

tasks, and contracts being litigated. As a result, contracts awaiting closeout encumbered

unliquidated obligations that could be used for other NASA programs. Delays can increase the

administrative burden on contractors and contracting officers and can weaken the Government’s

negotiating position in cases of employee turnover or other loss of first-hand knowledge of

contractor performance.

Federal Acquisition Regulation

FAR Subpart 4 sets time standards for closing out contract files as follows:

• Files for firm-fixed-price contracts, other than those using simplified acquisition13

procedures, should be closed within 6 months after the date on which the contracting officer

receives evidence of physical completion.

• Files for contracts requiring settlement of indirect rates should be closed within 36 months of

the month in which the contracting officer receives evidence of physical completion.

• Files for all other contracts should be closed within 20 months of the month in which the

contracting officer receives evidence of physical completion.

In addition, FAR Subpart 4 states that quick closeout procedures should be used, when

appropriate, to reduce administrative costs and to enable deobligation of excess funds.

Large Closeout Workload and Decentralized Closeout Function

Goddard has more contracts in closeout than any other NASA center (that is, about 53 percent

of the total contract closeouts in the Agency). Goddard’s large closeout workload and

decentralized closeout function has contributed to contracting officers not meeting FAR

guidelines on closing out 10 physically completed contracts (see Appendix E for contract

details). A Goddard contract closing administrator14 indicated that 150 contracts are awaiting

closeout.

 

13 FAR 2.1, “Definitions,” defines “simplified acquisition procedures,” as the methods prescribed in FAR Part 13 for

making purchases of supplies and services not to exceed $100,000. The purpose of the methods includes reducing

administrative costs and promoting efficiency and economy in contracting.

14 Many of Goddard’s branch-level procurement offices have a contract closing administrator who is responsible for

performing various tasks to help the contracting officer promptly close out contracts.
7

The contract closeout function has been decentralized, and the contract closing administrators

were limited in the amount of effort they could devote to the closeout task. From 1974 until

June 1997, a centralized contract closeout office processed all contract closeouts. Since June

1997, each procurement branch has been responsible for complete contract administration.

Procurement supervisors routinely assign a wide variety of tasks on active contracts to contract

closing administrators and have considered closeout tasks a low priority in comparison to

competing tasks.

The 10 contracts physically completed but not closed out are described below:

• One cost-plus-award-fee contract was physically completed in January 1993. The $23

million contract was for Gamma Ray Remote Sensing Spectrum. The closing

administrator resumed closeout responsibility after the decentralization of the closeout

function. As a result, the contracting officer did not request the final DCAA audit until

June 1997, 4 years after the contract was physically completed. DCAA completed the

final audit in September 1999, 2 years after the request. As of April 2000, the contract

is still awaiting closeout.

• Three contracts that were physically completed in 1995 and 1996 are still awaiting

closeout. The delay occurred because of the decentralized closeout function and limited

time closing administrators could devote to closeout tasks. Two contracts have

unliquidated obligations of $33,000 and $77,000. The remaining contract has no

unliquidated obligations.

• One fixed-price contract was physically completed in December 1993. The $81 million

contract was for a National Oceanic and Atmospheric Administration project. The

delay of contract closeout was due to the contractor’s dispute,15 which was settled on

April 6, 2000. The closing administrator requested DCAA's contract audit closing

statement on April 7, 2000. DCAA has not submitted a contract audit closing

statement to NASA because it is waiting for the contractor to submit the final incurred

cost proposal.

• Five additional contracts that were not from our sample reports were physically

completed from 1995 through 1997. Three contracts were closed out from 47 to 60

months after they were physically completed, and two contracts are awaiting closeout.

 

15 A contractor initiated dispute over about $900,000 in reimbursable costs from NASA as a result of the failure of one

of the satellites.
8

NASA Procurement Management Survey

NASA conducted a procurement management survey at Goddard during November and

December 1998. The survey team identified two areas of concern on closing out contracts:

• Goddard did not use a system or database to track the entire Goddard closeout inventory.

The Procurement Officer should establish a closeout status reporting system that monitors

the closeout function and measures performance. The system must be comprehensive and

include all award instruments and must be capable of generating information on closeout

performance at the Center.

• Goddard had no comprehensive plan to monitor and manage the closeout workload. The

Procurement Officer should require the establishment of formal closeout policies and

standards as well as a comprehensive plan to address the closeout issues in the

decentralized environment.

Contract Closeout Process Improvements

We discussed with Goddard the following management actions taken to improve the contract

closeout process:

• As of the end of 1998, Goddard had (1) developed a monthly Closeout Inventory Report

for tracking and measuring closeout performance, (2) implemented a plan to address the

closeout issues and unliquidated obligations, and (3) developed a closeout manual for

Goddard procurement personnel.

• In January 1999, Goddard’s Center Director submitted a plan to the Associate

Administrator for Earth Science to substantially reduce or eliminate Goddard’s unliquidated

obligations. The plan had four major components: (1) a Goddard Task Team to review

progress, solve problems and ensure application of closeout techniques; (2) Office of

Procurement intervention with DoD elements (including DCAA) to provide an Agency-wide

focus to monitor progress on all of NASA’s major cost reimbursement contracts awaiting

closeout; (3) an increase in procurement staffing; and (4) additional Goddard and

Headquarters Financial Management Division resources.

• The Associate Administrator for Procurement issued to NASA’s Administrator a Contract

Management Status report, which stated that Goddard’s unliquidated obligations and

closeouts improved from “needs to do better” to “doing okay” during the semi-annual

period ending March 31, 2000.

• Goddard is currently evaluating the use of an Agency-wide contract to assist with contract

closeouts. NASA Ames Research Center would administer the contract.
9

Maintaining Unliquidated Obligations

Goddard had unliquidated obligations on many of the contracts awaiting closeout. Appendix E

shows the amount of unliquidated obligations for each of the 10 contracts. We identified another

contract16 during our review that has not exceeded the 36-month FAR requirement (it has been

32 months) since contract completion, but has $436,376 of unliquidated obligations.

Goddard contracting officers stated that DCAA incurred cost audit findings are generally settled

just prior to closing out contracts. DCAA incurred cost findings and DoD ACO’s sustained

questioned costs amounts would not be reflected in Goddard’s contract files until contract

closeout. In addition, any funds due to NASA would not be recovered until contracts are closed

out.

Recommendation, Management's Comments, and Evaluation of

Response

2. The Director, Goddard Space Flight Center, should monitor the effectiveness of the

actions planned and taken to improve Goddard’s efforts (1) to close firm-fixed-price

contracts within 6 months after receipt of evidence that the contract is physically

completed and (2) to close contracts needing settlement of indirect cost rates within

36 months after receipt of evidence that the contract is physically completed as

required by the FAR.

Management's Response. Concur. The Director, Goddard Space Flight Center submitted a plan

on January 29, 1999, to the Associate Administrator for Earth Science to substantially reduce

overaged, unliquidated obligations and, therefore, decrease the closeout inventory. Specifically,

Goddard instituted the following measures:

• A monthly closeout inventory is provided to Procurement Managers to aid them in the management

of their closeout activities.

• A task team was assembled to periodically assess our progress and evaluate improved methods to

expedite the closeout process.

• Procurement professionals responsible for closeout activities now have a manual providing guidance

on the documentation and steps necessary for the timely disposition of physically complete files.

• Goddard is evaluating the use of NASA’s Agency-wide closeout contract to assist with Goddard’s

closeout activities.

 

16 Contract NAS5-29370 with Ball Aerospace was completed September 15, 1997, and has an unliquidated obligations

amount of $436,376.
10

• The Division Chief for Procurement Operations reports monthly during Goddard’s Executive

Council and Headquarters Institutional General Management Status Review on the progress of

unliquidated obligations and closeout activities.

Evaluation of Management's Response. The actions taken by management are responsive to the

recommendation. We consider the recommendation dispositioned and closed for reporting

purposes.
11

Appendix A. Objectives, Scope, and Methodology

Objectives

The overall objective was to evaluate the adequacy of NASA’s settlement of the DCAA

incurred cost audits at Goddard Space Flight Center. Specifically, we determined whether:

• NASA contracting officers appropriately settled the incurred cost audits in a timely

manner and in accordance with the FAR; NASA FAR Supplement; and OMB

Circular A-50, "Audit Follow Up," September 29, 1982, when NASA has final

indirect cost rate determination authority.

• NASA has adequately monitored DCAA audits to be resolved by the Department

of Defense (DoD) and has jointly participated in the negotiation/settlement process

when DoD has final indirect cost rate determination authority.

We did not assess the adequacy of the administrative contracting officers’ (ACO's) resolutions

of audit findings.

Scope and Methodology

We performed the detailed audit work at Goddard Space Flight Center, Greenbelt, Maryland.

We reviewed OMB Circular A-50 requirements; NASA’s policies, including NASA FAR

Supplement 1842.705, Procurement Notice 97-2, and NPG 1200.1; and other agencies’

policies referenced in NASA guidelines such as DoD Directive 7640.217 and the DCAA

Contract Audit Manual. We interviewed Goddard and DoD contracting officers to determine

whether audit findings and recommendations were resolved and dispositioned promptly and

effectively.

To determine whether NASA’s settlement of DCAA's incurred cost activities ensure the

prompt and effective resolution and disposition of incurred cost audit recommendations, we

selected the DCAA audit reports containing findings and reviewed the audit recommendations

with the applicable Goddard contracting officers. We reviewed all 7 reports with more than

$10 million in questioned costs each and randomly selected 1018 out of 164 DCAA incurred

audit reports with findings that were issued during FY’s 1997 and 1998. We also performed

limited reviews (1) of 5 additional contracts for which NASA retained resolution authority and

that were physically completed and (2) of 13 of the 20 audits that were included in the DCAA

June 1997 billing data to Goddard. We reviewed the 13 reports to determine whether NASA

should have categorized the reports as reportable contract audit reports.

 

17 DoD issued Directive 7640.2, “Policy for Follow-up on Contract Audit Reports,” on August 16, 1995.

18 We selected 17 DCAA audit reports for review. NASA did not delegate resolution and disposition authority to DoD

for 1 of the 10 randomly selected reports. Therefore, we evaluated 16 audit reports for which NASA delegated

resolution and disposition authority to DoD.
12

Appendix A

FY’s 1997 and 1998 Audit Reports Reviewed

Fiscal

Year

Number of Audits

With Questioned

Costs

Audits With More

Than $10 Million Each

in Questioned Costs

Number of Other

Randomly

Selected Audits

1997 89 2 5

1998 82 5 5

Total Reviewed 7 10

Management Controls Reviewed

We examined Goddard policies and procedures concerning the settlement of DCAA's incurred

cost audit process. We also reviewed Goddard practices to track contract audit reports and to

follow up on audit recommendations for timely resolution and disposition where DoD has final

indirect rate determination.

We considered management policies and procedures to be adequate. However, controls need

to be strengthened to ensure that contracting officers maintain a dialogue with the DoD ACO’s

(Finding A) and promptly close out within 36 months contracts that were physically completed

as required by FAR Subpart 4 (Finding B).

Audit Field Work

We performed audit field work from April through June 2000. We conducted the audit in

accordance with generally accepted government auditing standards.
13

Appendix B. Incurred Cost Audits

DCAA Contract Audit Manual, Volume 1, Chapter 6-102.1; July 1999, describes the incurred

cost audit objectives and approach as:

The auditor’s primary objective is to examine the contractor’s cost representation, in whatever form

they may be presented (such as interim and final public vouchers, progress payments, incurred

cost submissions, termination claims and final overhead claims), and to express an opinion as to

whether such incurred costs are reasonable, applicable to the contract, determined under generally

accepted accounting principles and cost accounting standards applicable in the circumstances, and

not prohibited by the contract, by statute or regulation, or by previous agreement with, or decision

of, the contracting officer. In addition, the auditor must determine whether the accounting system

remains adequate for subsequent cost determinations, which may be required for current or future

contracts. The discovery of fraud or other unlawful activity is not the primary audit objective;

however, the audit work should be designed to provide reasonable assurance of detecting abuse or

illegal acts that could significantly affect the audit objective. If illegal activity is suspected, the

circumstances should be reported in accordance with 4-700.

Audit Approach

a. Incurred cost audits are usually performed on a contractor-wide basis. This approach

recognizes the efficiency of addressing the adequacy of management and financial systems

and controls combined with transaction testing across all business activities as opposed to

contract-by-contract audits. Only in certain low-risk situations would DCAA audit

individual contracts, such as an audit of a small-dollar contract at a multi-million dollar

corporation where the small contract represented the company's only business with the

government.

b. For major contractors and contractors with significant negotiated firm-fixed price

contracts, reviews of relevant accounting and management systems will be performed on a

cyclical basis and form the foundation for determining the nature and extent of transaction

testing necessary on individual incurred cost audits. See Chapter 5 for guidance on

reviews of contractor's internal controls.

c. For non-major contractors, separate audits and reports on individual contractor

accounting and management systems may not be necessary. An understanding of the

contractor's internal control structure may be gained at the time of the final overhead audit

or during individual contract audits. The auditor's understanding of the internal control

structure gained from these audits should be documented in the permanent file. (See 5-

111 for further guidance on reviewing internal controls at nonmajor contractors.)

d. Regardless of the audit approach, in all audits emphasis will be on determining the overall

acceptability of the contractor's claimed costs with respect to

(1) reasonableness of nature and amount;

(2) allocability and capability of measurement by the application of duly promulgated

Cost Accounting Standards and generally accepted accounting principles and practices

appropriate to the particular circumstances; and

(3) compliance with applicable cost limitations or exclusions as stated in the contract or

the FAR.
14

Appendix C. Audit Reports for Which NASA Delegated Resolution and

Disposition Authority ($ in $000)

DCAA Report

Number

Date of

Report Contract

Questioned

Costs

Sustained

Cost

NASA's

Share

Resolution

Date

Disposition

Date

3131-97K10150001 09/25/97 NAS5-29360

NAS5-26836

NAS5-30689

$13,879 $3,320 $52 3/18/98 3/18/98

4901-95P10150001 09/27/96 NAS5-26555

NAS5-31459

NAS5-32626

$11,611 $4,819 $675 06/30/97 06/30/97

3131-97K10150002 03/27/98 NAS5-29360

NAS5-26836

NAS5-30689

$10,244 $4,966 $429 06/04/99 06/04/99

3131-97K10150003 06/25/98 NAS5-29360

NAS5-26836

NAS5-30689

$14,561 $3,564 $74 12/31/99 12/31/99

4901-96P10150001 02/27/98 NAS5-26555

NAS5-31459

NAS5-32626

$13,889 $9,469 $1,420 12/06/99 12/06/99

4901-97K10150003 11/13/97 NAG5-3077

NAG5-3102

NAS5-30386

NCC5-95

$14,354 $6,495 $637 8/10/98 8/10/98

6631-97L10150001 06/25/98 1$27,757 Not

Resolved

Not

Dispositioned

4291-97J10150001209/30/97 NAS5-29500 $4,430 $2,779 $2,640 12/16/97 03/26/98

4901-97V10250004 06/09/97 3$369 $369 $68 07/02/97 07/02/97

2211-97B10150230 06/24/97 NCC5-82

NCC5-34

$435 $435 $13 06/24/97 06/24/97

3121-98H10150002 09/30/98 NAS5-31808

NAS5-20370

NAS5-32864

$1,044 $-0- $-0- 07/21/99 08/27/99

6501-97U10250201 04/29/97 NAS5-28000

NAS5-28666

$1,141 $1,507 $226 09/23/97 09/23/97

3521-98S10250001 07/31/98 NAG5-1981

NAS5-31724

NAG5-2258

$2,046 $2,046 $266 07/31/98 07/31/98

6311-97C10250479 12/31/96 NAS5-32513 $5 $5 $2 01/06/97 01/06/97

4281-97B10150009401/30/98 NAS5-32811 $16 $16 $12 01/30/98 01/30/98

4361-96B10150002504/30/97 NAS5-30800

NAS5-32631

$3,016 $1,128 $530 12/23/98 12/23/98

Totals $118,797 $40,918 $7,044

1

The report was for the contractor’s Corporate Home Office Expenses and Facilities Capital. The report did not identify a

specific Goddard contract.

2 NASA’s share of sustained costs for this report represented 95 percent of the total sustained costs.

3 The ACO made a decision to apply questioned costs to contractor’s forward pricing rates. The report did not identify a

specific Goddard contract.

4 NASA’s share of sustained costs for this report represented 75 percent of the total sustained costs.

5 NASA’s share of sustained costs for this report represented 47 percent of the total sustained costs.
15

Appendix D. Summary of Prior Coverage

The NASA Office of Inspector General (OIG), DoD Office of Inspector General, and the General

Accounting Office (GAO) have issued reports relating to the use of audit services provided by

DCAA and to NASA’s audit follow-up process. The reports are summarized below. (Copies of

the NASA OIG reports are available at www.hq.nasa.gov/office/oig/hq/issuedaudits.html.)

NASA

“NASA Contract Audit Follow-up System at Johnson Space Center,” Report Number IG00-032, May 19, 2000. The system did not include complete records of action taken on findings

and recommendations for which resolution and disposition authority had been delegated to DoD

ACO. As a result, Johnson procurement personnel could not ensure that audit findings and

recommendations were resolved in a timely manner and that the resolutions were in NASA’s best

interest. We identified a similar finding during our audit of the NASA Contract Audit Follow-up

System at Marshall. Therefore, we did not make a recommendation for corrective action on this

issue. Also, Johnson procurement personnel did not track and report certain reportable contract

audit reports and did not resolve or disposition reports’ findings and recommendations within 6

months after report issuance pursuant to OMB Circular A-50. Consequently, audit findings were

not resolved in a timely fashion, and NASA funds that should have been disallowed, withheld, or

reduced could not be reallocated to other NASA programs. Management concurred with the two

recommendations and issued Procurement Information Circular (PIC) 00-06 and a letter to the

Team Leader, Procurement Management Survey Team, to include the "Audit Follow-up Process" in

all future procurement surveys.

“NASA Contract Audit Follow-up System at Marshall Space Flight Center,” Report

Number IG-00-010, March 6, 2000. The system did not include complete records of action taken

on findings and recommendations for which resolution and disposition authority had been delegated

to DoD ACO. As a result, Marshall procurement personnel could not ensure that audit findings and

recommendations were resolved in a timely manner and that the resolutions were in NASA’s best

interest. Also, Marshall procurement personnel did not track and report certain reportable contract

audit reports and did not resolve or disposition reports’ findings and recommendations within 6

months after report issuance pursuant to OMB Circular A-50. Consequently, audit findings were

not resolved in a timely fashion and NASA funds that should have been disallowed, withheld, or

reduced could not be reallocated to other NASA programs. Management concurred with the four

recommendations and issued Procurement Information Circular (PIC) 00-06 and a letter to the

Team Leader, Procurement Management Survey Team, to include the "Audit Follow-up Process" in

all future procurement surveys.
16

Appendix D

“Review of NASA’s Use of Audit Services Provided by the Defense Contract Audit

Agency,” Report Number P&A-98-001, September 30, 1998. NASA needs to improve its

oversight of the use, benefits, and effectiveness of DCAA services. Also, NASA’s audit follow-up

system needs improvement to ensure that all reports, including those sent to DoD

for follow-up and resolution, are properly accounted for and resolved. This condition occurred

because NASA tracked only reportable DCAA audit reports, the Centers did not have a centralized

point to receive and track audit reports, and NASA did not monitor the status of DCAA audit

reports sent to DoD for follow-up and resolution. The OIG made six recommendations to NASA.

Management partially concurred with the recommendations and plans to coordinate on information

available from DCAA to improve NASA’s oversight of the use of DCAA services. However,

procurement management believes the present systems at NASA Headquarters and its Centers are

sufficient for tracking DCAA workload and reports.

“NASA Audit Follow-up Process: HQ Center,” Report Number HQ-94-009,

May 26, 1994. NASA did not have an effective follow-up system to closely monitor contract

audits and ensure timely and complete resolution. This occurred because NASA Headquarters

procurement officials did not have an active role in routinely monitoring actions taken on the reports;

instead procurement officials relied on the individual contracting officer to resolve and implement the

audit recommendations. Also, the procurement and contracting officers at the Centers did not have

clear and formal performance standards to promote effective contract audit follow-up. The NASA

Contract Pricing and Finance Division concurred with the OIG recommendation to participate in the

resolution and disposition process at the Center procurement offices and to include contract audit

follow-up standards in the contracting officers’ performance plans.

DoD Inspector General

“The Air Force Contract Audit Follow-up System,” Report Number 00-003,

October 4, 1999. The Air Force contracting officers experienced delays in settling contract audit

reports. As a result, contracting officers sustained a significantly lower percentage of questioned

costs. Also, contracting officers did not issue demand letters on defective pricing settlements in

contract overpayments and interest. Consequently, overpayments and associated interest were not

collected in a timely manner in all cases. The DoD Inspector General made two recommendations;

however, the Air Force did not comment on the draft report and was requested to provide

comments on the final report.

“Settlement of Contractor Incurred Indirect Cost Audits,” Report Number 99-057,

December 21, 1998. The Navy and Defense Contract Management Command did not maintain

and report accurate contract audit follow-up data. As a result, component management was not

able to effectively determine whether their contract audit follow-up systems were adequate and

resulted in timely and appropriate disposition of audit reports. The DoD Inspector General made

one recommendation; the Navy concurred and took corrective
17

Appendix D

actions. The Defense Logistics Agency partially concurred and will issue a letter to the Contract

Audit Follow-up monitors addressing this concern.

“Defense Contract Audit Agency Audits of Indirect Costs at Major Contractors,” Report

Number PO 98-6-016, August 6, 1998. DCAA did not always perform sufficient transaction

testing in conjunction with the internal control system review, and those reviews can be performed

less frequently than every 3 years. Therefore, the internal control review results that DCAA relies on

to assess audit risk may be outdated and inaccurate. Also, DCAA audits of indirect costs for

allowability, allocability, and reasonableness often did not provide a sufficient in-depth analysis to

conclude that the costs were acceptable for reimbursement. The audit procedures used for selecting

or sampling transactions for review were frequently not the most effective means to review indirect

costs. Consequently, DoD may be paying contractors for costs that should not or need not be

reimbursed, thereby increasing the overall cost for DoD programs. The DCAA nonconcurred with

DoD’s recommendation, however, management did agree that the internal control system review of

indirect costs should be completed by the end of FY 1998 for all major contractor entities.

GAO

“NASA Contract Management: Improving the Use of DCAA’s Auditing Services,” Report

Number GAO/NSIAD-94-229, September 30, 1994. The GAO raised many concerns related to

NASA contractors’ unallowable cost claims, the status of contractors’ business systems, NASA’s

involvement in DCAA’s audit planning process, timeliness of contract closeout, and contract audit

tracking and follow-up systems. The GAO made six recommendations. Two of the

recommendations dealt with NASA’s untimely tracking and following up on contract audit reports,

monitoring audit findings and recommendations that are resolved by DoD ACO’s, and documenting

the status and disposition of the audit findings in contract files. NASA management agreed that its

audit tracking and reporting systems need improving, but was concerned that the GAO

recommended that NASA track the status of audit reports that DoD also tracked and was

responsible for resolving. The GAO’s response was: “We do not want NASA to duplicate DoD’s

work. Our point is that NASA should understand and evaluate the adequacy of the service it is

receiving in this area.” 
18

Appendix E. Contracts Physically Completed and in Closeout

Contract

Number Contractor

Contract

 Value (in

$000)

Contract

Type

Completion

Date

Months After

Completion*

Unliquidated

Obligation

NAS5-29360 Lockheed Martin

Corporation/Astronautics $22,912 Cost 1/31/93 88 -0-

NAS5-31459 California Institute of

Technology $7,305 Cost 9/30/95 56 -0-

NAS5-30386 Stanford University $59,491 Cost 3/31/96 49 $33,000

NAS5-28000 Lockheed Martin

Corporation/Astrospace $80,600

Fixed

Price 12/31/93 77 -0-

NAS5-32602 Ogden Logistics Services $17,786 Cost 5/21/96 48 $77,000

NAS5-32619 Computer Sciences

Corporation $ 69 Cost 6/4/96 47 -0-

NAS5-32608 Lockheed Martin

Corporation

Missile & Space

$ 32 Cost 5/2/95 60 -0-

NAS5-32363 Aerodyne Research Inc. $387 Cost 5/16/97 36 $4,197

NAS5-32357 LNK Corporation $ 90 Cost 4/18/97 37 $1,508

NAS5-32694 Science Application

International Corporation $368 Cost 3/31/96 49 -0-

Average

Months After

Completion

55

*As of May 200, we identified 10 contracts physically completed; however, closeout has not yet occurred. The months

after completion column shows the time from contract completion date to our June 2000 field work completion date. We

rounded the time as appropriate.
19

Appendix F. Management’s Response
20

Appendix F
21

Appendix F
22

Appendix F
23

Appendix F
24

Appendix F
25

Appendix G. Report Distribution

National Aeronautics and Space Administration (NASA) Headquarters

A/Administrator

AI/Associate Deputy Administrator

B/Chief Financial Officer

B/Comptroller

BF/Director, Financial Management Division

G/General Counsel

H/Associate Administrator for Procurement

HK/Director, Contract Management Division

HS/Director, Program Operations Division

J/Associate Administrator for Management Systems

JM/Acting Director, Management Assessment Division

L/Associate Administrator for Legislative Affairs

M/Associate Administrator for Space Flight

NASA Centers

Director, Lyndon B. Johnson Space Center

Director, Marshall Space Flight Center

Director, John F. Kennedy Space Center

Chief Counsel, John F. Kennedy Space 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

Associate Director, National Security and International Affairs Division, Defense

 Acquisitions Issues, General Accounting Office

Professional Assistant, 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 Management, Information, and Technology

House Subcommittee on National Security, Veterans Affairs, and International Relations

House Committee on Science

House Subcommittee on Space and Aeronautics, Committee on Science

Congressional Member

Honorable Pete Sessions, U.S. House of Representatives
27

NASA Assistant Inspector General for Auditing

Reader Survey

The NASA Office of Inspector General has a continuing interest in improving the usefulness of

our reports. We wish to make our reports responsive to our customers’ interests, consistent

with our statutory responsibility. Could you help us by completing our reader survey? For your

convenience, the questionnaire can be completed electronically through our homepage at

http://www.hq.nasa.gov/office/oig/hq/audits.html or can be mailed to the Assistant Inspector

General for Auditing; NASA Headquarters, Code W, Washington, DC 20546-0001.

Report Title: Audit of NASA Settlement of DCAA's Incurred Cost Audits at

Goddard Space Flight Center

Report Number: Report Date:

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objectives, scope, and methodology.

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28

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Thank you for your cooperation in completing this survey.
Major Contributors to the Report

Lorne A. Dear, Program Director, Procurement Audits

Tony A. Lawson, Audit Program Manager

Lydia C. Lin, Auditor-in-Charge

Nancy C. Cipolla, Report Process Manager

Betty Weber, Operations Research Manager

Debra Schuerger, Program Assistant