IG-00-061

AUDIT

REPORT INTERNAL CONTROLS OVER PROCESSING

DEOBLIGATIONS

September 29, 2000

National Aeronautics and

Space Administration

OFFICE OF INSPECTOR GENERAL
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Acronyms

CFO Chief Financial Officer

FMM Financial Management Manual

GAO General Accounting Office

HSF Human Space Flight

NPD NASA Policy Directive

OIG Office of Inspector General

OMB Office of Management and Budget

SAT Science, Aerospace, and Technology
W September 29, 2000

TO: A/Administrator

FROM: W/Inspector General

SUBJECT: INFORMATION: Internal Controls Over Processing Deobligations

 Report Number IG-00-061

NASA is responsible for ensuring that appropriated funds are used only within specified periods

and for the purposes and amounts authorized by Congress. Obligations management is one of the

fundamental internal controls designed to produce accurate and consistent financial data and to

ensure funds control. An essential part of managing obligations is ensuring that management can rely

on the validity of the recorded obligations.

This report is the third in a series of three reports1 focused on NASA’s management of obligations.

The objective of this audit was to evaluate internal controls for processing and documenting

obligations of appropriated funds. This report identifies conditions related to supporting

documentation for deobligations2 only. Audit work is ongoing for objectives related to obligations.

While financial management officials3 at Langley Research Center (Langley) and George C.

Marshall Space Flight Center (Marshall) processed deobligations in a timely manner, 41 of 78 (53

percent) transactions reviewed were not adequately documented. Neither the NASA Financial

Management Manual (FMM) nor the Center-specific financial procedures provide adequate

guidance for processing and documenting deobligations. Because supporting documentation was

not clear or readily available for examination, we could not attest to the validity and amount of

 

1

The first report, “Obligations Management – Recording Obligations and Adjustments” (Report number

IG-99-021) states that obligations and adjustments were not always promptly recorded. The second report,

“Matching Disbursements to Obligations” (Report Number IG-99-059) states that disbursements are not properly

matched to the originating obligations. Management nonconcurred with the latter report. Details on both

reports are included in Appendix A, under Prior Audit Coverage.

2A deobligation is a negative adjustment of a previously recorded obligation attributable to a contract

termination or modification, price revision or correction of amounts previously recorded, reprogramming, funds

transfer or distribution, or error correction. For purposes of this report, we considered all negative obligation

transactions in the accounting system to be deobligations.

3

Financial management officials include all personnel within the NASA and Center Offices of the Chief Financial

Officer including the accounting and resources functions.
2

deobligations valued at about $7.4 million. Due to the extent of the Centers’ documentation

deficiencies, we consider this deficiency to be a significant area of concern reportable to the

Agency’s Internal Control Council.4

Background

Because obligations management is key to the accuracy and reliability of Agency financial data,

NASA must ensure that both obligations and deobligations are adequately documented. The

General Accounting Office (GAO) established standards requiring that all transactions be promptly

recorded, properly classified, and supported by documentation that is clear and readily available for

examination.

We tested a sample of deobligation transactions at Langley and Marshall to determine whether

transactions were adequately documented and valid. The types of deobligating transactions

reviewed included contract modifications, funds transfers between programs and contracts, yearend

or cost accounting adjustments, and corrections in internal accounting records.

Recommendations

We recommended that criteria for processing and documenting deobligations be added to the

FMM and Center financial management procedures. We also recommended that the Centers

review the unsupported transactions identified in this report to ensure that they are valid and

adequately documented. Finally, we recommended that the Centers report the documentation

deficiencies as a significant area of concern to the Agency Internal Control Council.

Management’s Response and OIG Evaluation

Management concurred with the recommendation to publish Agency criteria in the FMM for

processing and documenting deobligations but partially concurred with the need to establish policy

at each Center. However, both Langley and Marshall management responded that additional

guidance would be established.

Financial management officials at Langley and Marshall concurred with the recommendation to

ensure that the unsupported transactions identified in this report were adequately documented and

valid. However, the Centers did not agree that existing data was inadequate. For example, Langley

stated that only one transaction reviewed was inadequately documented and that daily transaction

registers and internal Center correspondence adequately addressed the majority of the remaining

 

4

The Internal Control Council makes recommendations to the NASA Administrator on issues for NASA's annual

statement of assurance to the President and Congress, pursuant to the Federal Managers' Financial Integrity Act

and for incorporation into NASA's annual Accountability Report.
3

transactions. Marshall stated that one transaction was adequately documented but did not address

documentation for the remaining transactions. Both Langley and Marshall stated that all of the

transactions were valid.

We maintain that copies of general ledger printouts and noted explanations such as "to reflect

accuracy" and “to reflect correct charges" were inadequate to support deobligations and did not

meet the GAO standards for accounting transaction documentation. In addition, we do not agree

that reasons such as "to use expiring funds first" or "reduce uncosted carryover balances" are valid

deobligations. Deobligations should accurately reflect the results of NASA programs and

operations as specified in the Agency appropriation. Based on the Center's comments, we ask

management to reexamine these transactions and provide additional comments.

Management nonconcurred with the recommendation to report documentation deficiencies to the

Agency Internal Control Council, stating that the transactions in question were insignificant. The

Chief Financial Officer's (CFO's) plan to issue guidance in the FMM demonstrates support for our

recommendation to correct documentation deficiencies. However, Marshall's lack of addressing the

documentation deficiencies and Langley's comments that the majority of transactions were

adequately documented raises concern that detailed information will not be prepared and maintained

to support future deobligating transactions. We believe that a correct course of action would be to

determine whether similar documentation deficiencies exist at other Centers rather than minimize the

significance of the deficiencies at the two Centers reviewed. When controls such as adequate

documentation and proper management approvals are not in place, inaccurate financial information

and reporting can result. We ask management to reconsider its position on this issue and provide

additional comments based on our evaluation.

[original signed by]

Roberta L. Gross

Enclosure

Final Report on Audit of Internal Controls Over Processing Deobligations
FINAL REPORT

AUDIT OF INTERNAL CONTROLS OVER PROCESSING

DEOBLIGATIONS
W September 29, 2000

TO: B/Chief Financial Officer

106/Director, Langley Research Center

DA01/Director, Marshall Space Flight Center

FROM: W/Assistant Inspector General for Auditing

SUBJECT: Final Report on the Audit of Internal Controls Over Processing Deobligations

Assignment Number A0000900

Report Number IG-00-061

The subject final report is provided for your use and comments. Our evaluation of your

response is incorporated into the body of the report. Recommendations 1 and 2 will remain

open until corrective action is completed. Please notify us when action has been completed on

the recommendations, including the extent of testing performed to ensure that corrective actions

are effective. We consider management's responses to recommendations 3 and 4

nonresponsive. We request that management reconsider its position on those recommendations

and submit additional comments by November 28, 2000. The recommendations will remain

open for reporting purposes.

If you have questions concerning the report, please contact Mr. Chester A. Sipsock, Program

Director, Environmental and Financial Management Audits, at (216) 433-8960, or Ms. Linda

Wagner Anderson, Auditor-in-Charge, at (757) 864-3745. We appreciate the courtesies

extended to the audit staff. The final report distribution is in Appendix G.

[Original signed by]

Russell A. Rau

Enclosure
cc:

B/Comptroller

BF/Director, Financial Management Division

G/General Counsel

JM/Acting Director, Management Assessment Division

MSFC/RS01/Chief Financial Officer

LaRC/Chief Financial Officer
NASA Office of Inspector General

IG-00-061 September 29, 2000

 A0000900

Internal Controls Over

Processing Deobligations

Introduction

This report is the third in a series of three reports focused on NASA’s management of

obligations. The first report, “Obligations Management – Recording Obligations and

Adjustments” (Report number IG-99-021) states that obligations and adjustments were not

always promptly recorded. The second report, “Matching Disbursements to Obligations”

(Report Number IG-99-059) states that disbursements are not properly matched to the

originating obligations. Details on the two audit reports are in Appendix A.

The objective of this audit was to evaluate internal controls for processing and documenting

deobligations of appropriated funds. This report identifies conditions related to supporting

documentation for deobligations only. Details on the audit objectives, scope, and methodology

are in Appendix A. Audit work is ongoing for objectives related to obligations.

Results in Brief

Financial management officials at Langley and Marshall processed deobligations in a timely

manner. However, those officials did not adequately document deobligations for more than half

of the transactions reviewed. Because of the lack of documentation for the deobligations, we

were unable to attest to the validity and amount of deobligations, valued at about $7.4 million.

Due to the extent of inadequate documentation to support the financial transactions, we consider

this deficiency to be a significant area of concern at the two Centers, reportable to the Internal

Control Council in accordance with NASA Policy Directive (NPD) 1200.1A, “Internal

Management Controls and Audit Liaison and Followup,” dated June 1, 2000. Requirements

for evaluating and reporting on management controls are further described in Appendix B.
2

Background

Federal agencies may obligate and expend funds only in accordance with an appropriation.5

Obligations are the amount of orders placed or contracts awarded that represent a contractual

agreement by NASA to pay for the items or services when they are received. Deobligations

are downward adjustments of obligations, which may reduce or transfer prior obligations.

Some of the common reasons Langley and Marshall deobligated funds included:

• contract modifications, contract closeout, or reduction in contract scope;

• funds transfers between programs and contracts and from old to new contracts;

• yearend or other cost accounting adjustments;

• correction in internal accounting records;

• costing oldest or expiring funds first; and

• funds transfers to meet obligation and/or cost metrics.6

Because obligations management is key to the accuracy and reliability of Agency financial data,

NASA must ensure that both obligations and deobligations are adequately documented.

Criteria for accounting controls and documentation requirements for Federal agencies are

contained in various publications. Some of the current guidance includes:

• General Accounting Office (GAO), "Standards for Internal Control in the Federal

Government," dated November 1999.

• GAO’s, “Reliable Financial Information: A Key to Effective Program Management

and Accountability,” dated January 1997.

• Office of Management and Budget (OMB) Circular A-123, “Management

Accountability and Control,” dated June 21, 1995.

• OMB Circular A-127, “Financial Management Systems,” dated June 23, 1993.

Each publication requires that agency managers incorporate basic management controls in

policies and procedures governing their programs and operations. Further, to ensure an

effective system of internal controls, managers should clearly document systems, transactions,

and other significant events relative to the financial accounting data and ensure that the

documentation is readily available for examination.

 

5An appropriation is an authorization by an act of Congress that permits Federal agencies to incur

obligations and to make payments out of the U. S. Treasury for specified purposes.

6NASA established a means of measuring performance goals referred to as metrics. Budget submission

instructions for the Office of Life and Microgravity Sciences and Applications require that 83 percent of

obligation authority be obligated by the end of the first year of the 2-year period. The Office of Space Flight

and the Office of Life and Microgravity Sciences and Applications require that 100 percent be obligated by

the end of the first quarter of the second year. The NASA CFO Functional Leadership Plan requires that 70

percent of obligations be costed by the end of the first year of the 2-year period.
3

Supporting Documentation for Deobligations

Finding. Thirty-three (55 percent) of the total of 60 statistically sampled deobligations and 8

(44 percent) of the 18 judgmentally selected deobligations reviewed at Langley and Marshall

were not adequately documented to support the transactions. Neither the NASA FMM nor the

Center-specific financial procedures provide adequate guidance for processing and

documenting deobligations. As a result, we could not attest to the validity of 17 (28 percent) of

the 60 deobligations, valued at about $3.4 million. In addition, we could not attest to the

validity of two (22 percent) of the nine deobligations judgmentally selected at Marshall and

valued at $4 million. Due to the extent of the Centers’ documentation deficiencies, we consider

this deficiency to be a significant area of concern reportable to the Agency’s Internal Control

Council.

Internal Control Standards for Documentation

Sound management controls for recording and reporting obligations and deobligations must be

maintained to ensure appropriation integrity and compliance with fiscal law. Controls are to be

consistent with the "Standards for Internal Control in the Federal Government," which describe

the proper execution of transactions and events and state that the Government must assure that

only valid transactions to “exchange, transfer, use, or commit resources ... are initiated or

entered.” Specifically, the standards state:

Internal controls and all transactions . . . need to be clearly documented, and the

documentation should be readily available for examination. The documentation should

appear in management directives, administrative policies, or operating manuals and may

be in paper or electronic form. All documentation and records should be properly

managed and maintained.

.

The GAO standards also include specific management controls for recording and documenting

financial transactions:

Transactions should be promptly recorded, properly classified and accounted for in order

to prepare timely accounts and reliable financial and other reports. The documentation for

transactions, management controls, and other significant events must be clear and readily

available for examination.

Inaccurate or incomplete documentation to support transactions can result in unreliable financial

data and ultimately, noncompliance with appropriation law.

Adequate documentation is briefly defined in the “GAO Standards for Internal Controls in the

Federal Government.” However, the NASA FMM does not define adequate documentation.

In the absence of specific criteria, we believe that adequate documentation includes, but is not

limited to, documents such as contract modifications, purchase requests, or documents that

provide a complete, detailed narrative explanation of why the transaction is requested.
4

Supporting documentation should include evidence of management’s approval, the approval

date, and appropriate signatures.

Documentation for Deobligations

We reviewed the Langley and Marshall procedures for processing deobligations. Specifically,

we tested 39 transactions at each Center for a total of 78 transactions. The sampling

methodology and quantitative analysis is described in Appendixes A and C. We identified

documentation deficiencies in 29 transactions at Langley and 12 transactions at Marshall. The

results are summarized, by Center, as follows.

Summary of Results

Center Totals Documentation Validity

Adequate

Inadequate/

None Valid

Invalid/

Questionable

Langley 39 10 29 24 15

Marshall 39 27 12 35 4

Totals 78 37 41 59 19

Of 78 transactions, 37 were adequately documented and supported. We considered 36 of the

transactions to be valid and supported by contract modifications, purchase requests, or other

documented requests to correct internal accounting information or close out contracts. We

considered one transaction, valued at $34,000, to be invalid based on an interview with the

program analyst. The analyst stated that the deobligation was made to reduce the amount of the

uncosted obligations.7 By deobligating the funds, accounting personnel increased the ratio of

costed obligations to total obligations. In our opinion, deobligating funds to reduce uncosted

obligations is not a valid deobligation.

Of the 78 transactions, 41 were either not documented or inadequately documented. We found

no documentation to support 19 of the 41 transactions. Based on discussions with financial,

program, and budget personnel, we considered 13 of the 19 transactions to be valid (7 were

cost accounting adjustments, 5 were error corrections, and 1 was a duplicate transaction). We

could not validate the remaining six deobligations.

Although we identified documentation for 22 of the remaining 41 transactions, the

documentation did not fully support processing the deobligations. For example, we identified

written notes from accountants and program or budget analysts, requesting that accounting

personnel transfer funds from one financial record to another. However, some of the notes did

not include reasons for the transfer while others merely stated that the transfer of funds was “to

reflect accuracy.”

 

7An uncosted obligation is an obligation awaiting completion of work or accrual of costs.
5

Because the notes did not fully support the need for the transfers, we traced the transactions

back to the accountants, budget or program analysts, or NASA researchers associated with the

deobligation. Accountants, budget or program analysts, or NASA researchers stated that they

requested the transfers for the following reasons:

• to meet obligations and cost metrics,

• to fully obligate an expiring reimbursement from another Federal agency or an

expiring NASA appropriation,

• to distribute obligations and costs to benefiting activities,

• to correct prior transaction errors and changes in accounting codes, and

• to close out contracts.

For each of the remaining 22 transactions, the sources considered the deobligations valid.

Based on the limited documentation and subsequent interviews with applicable personnel, we

considered 10 of the deobligations to be valid. We could not determine the validity of the

remaining 12 transactions. As a result, compliance with the governing requirements for

deobligations could not be assured.

Documentation problems for the 41 transactions are summarized below:

Details of Center Documentation Problems

Documentation

Center

No Documentation at

Time of Review

Inadequate

Documentation

Total with Documentation

Problems

Langley 11 18 29

Marshall 8 4 12

Totals 19 22 41

Validity problems for the 19 transactions are summarized below:

Details of Center Validity Problems

Validity

Center Invalid

Could not Determine

Validity Due to No

Documentation

Could Not Determine Validity

Due to Inadequate

Documentation Totals

Langley 0 3 12 15

Marshall 1 3 0 4

Totals 1 6 12 19

We questioned one other deobligation that was not in our sample. On September 24, 1999,

budget and accounting personnel transferred funds ($2,875) for Langley contract NAS1 20342

from the FY 1999 Science, Aeronautics, and Technology (SAT) appropriation to the FY 1998
6

Human Space Flight (HSF) appropriation.8 The supporting documentation for this transaction

stated that the funds should be transferred to “reflect correct charges.” Since the

documentation was vague, we contacted the budget analyst to obtain additional support. The

budget analyst stated that additional contract funding was needed under the FY 1998 HSF

appropriation. Therefore, the analyst reduced the costs and obligations by $2,875 in the FY

1999 SAT appropriation and transferred the amount to the FY 1998 HSF appropriation. The

need for the deobligation was still unclear, so we contacted a NASA researcher associated with

the contract. The researcher in charge of the HSF funds was not aware that the project had

ever been in need of additional funding. Therefore, we were unable to determine why the funds

had been transferred. In our opinion, accounting and resources management officials

transferred the funds because of the impending expiration of the 1998 HSF appropriation.9

Langley financial managers stated that transferring funds between appropriations within the same

contract was proper. Appropriation law requires that obligations be recorded for the purpose

intended and in the period for which the obligation was incurred. The budget analyst’s

explanation did not indicate that the transfer of funds was to correct either the appropriation

used or the period (fiscal year) that the obligation was incurred. In the absence of more specific

documentation, we could not attest to the validity of the transaction.

Audit Results at Marshall and Langley

Of the 78 deobligations reviewed at Langley and Marshall, 41 were not adequately

documented. (Thirty-three deobligations were from the statistical sample, and eight were from

the judgmental sample.) Projecting the statistical sampling results to the transaction universe

(194 transactions) we estimated, with a 95-percent confidence level, that at least 86

deobligations, valued at about $13.2 million, are not adequately documented. The eight

judgmentally selected deobligations were valued at $5.9 million.

Agency Guidance for Documentation

The NASA FMM 9040 provides criteria for recording and reporting obligations. Although

chapter 9041-6 requires that all obligations be supported by documentary evidence, there is no

specific documentation requirement for deobligations. In addition, neither Langley nor Marshall

has Center-specific financial guidance for processing and documenting deobligations.

 

8Contract NAS1 20342 is funded by both the SAT and HSF appropriations. The contract is for Aircraft and

Spacecraft Guidance and Control and is a task order contract. The two accounting records involved a

movement of funds from Reusable Launch Vehicle Crew Module (Task 11, International Space Station

Operations Drivers for Guidance Navigation and Control Systems Control) to Dynamic Load Sensors (Task

31, Analysis of Mir Space Station Acceleration Environment).

9

The 1998 HSF appropriation was for 2 fiscal years and would expire on September 30, 1999; therefore, funds

would not be available for new obligations after this date.
7

Langley financial management personnel stated that the Center has an oral policy requiring

written requests for processing deobligations. Additionally, Langley issued a one-page report10

that identified suggested explanations for requested changes in the financial system. Some

suggested explanations included “to reflect correct charges, realignment of funds to reflect

accuracy, and to cost program’s old year funds first.” A copy of the report is in Appendix D.

In our opinion, the suggested explanations are unclear and inadequate because they do not fully

explain reasons for the funds transfers.

A Marshall financial management official stated that the Center has a policy requiring

procurement requests and contract modifications for obligations and deobligations. However,

Marshall has no written policy for making correcting entries, yearend transactions, and

miscellaneous adjustments.

Validity of Deobligations

For the deobligations that were adequately documented, we considered only one to be invalid.

We believe the personnel processed the invalid deobligation to meet Agency internal metrics for

obligations and funds management. Additionally, budget and program personnel cited metrics

as reasons for processing other deobligations we reviewed. We are concerned about Agency

managers using metrics as a means to control funds because of the potential impact on the

proprietary use of funds. Emphasis is needed to ensure that transactions are proper and well

supported and that they meet timeliness metrics. We will continue to review the use of metrics

in ongoing audit work.

Lack of adequate documentation to support financial transactions is an internal control

weakness that can result in inaccurate and unreliable financial data. For the deobligations at

Langley and Marshall, we were unable to attest to the validity of 17 statistically selected

deobligations, valued at about $3.4 million and 2 judgmentally selected deobligations, valued at

$4 million. Projecting the sample results to the transaction universe, we estimated, with a 95-

percent confidence level, that at least 32 deobligations from the universe of 194 deobligations

valued at about $4.7 million, may not be valid.11 Due to the extent of the Centers’

documentation deficiencies, we consider this deficiency to be a significant area of concern

reportable to the Agency’s Internal Control Council.

Recommendations, Management's Response, and Evaluation of

Response

 

10The Center Management Control Officer based the report, originally issued on September 24, 1998, on a

Center Chief Financial Officer internal review performed at Langley.

11We based projections on the statistical samples taken at Langley and Marshall for August and September

1999. We did not make projections for the judgmental selections taken from October 1999.
8

1. The NASA Headquarters CFO should establish criteria in the NASA FMM for

processing and documenting deobligations.

Management's Response. Concur. Management plans to publish appropriate FMM

guidance by November 30, 2000. The complete text of management's response is in Appendix

E. Management also provided extensive comments on the report, which we address in

Appendix F.

Evaluation of Response. Management's planned action is responsive to the recommendation.

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

corrective actions are completed.

The Center Directors at Langley and Marshall should:

2. Establish written policies requiring adequate documentation for all

deobligation transactions.

Management's Response. Partially concur. NASA management believes the FMM

guidance will be sufficient and additional Center-specific policies are not necessary. However,

Marshall plans to add criteria for documenting transactions for closing contracts, and Langley

has reviewed with financial personnel the need for clearer notes when accounting adjustments

and corrections are made (see Appendix E).

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

recommendation. The recommendation is considered resolved but will remain undispositioned

and open until the agreed-to corrective actions are completed.

3. Review the unsupported transactions identified in this report to ensure that

they are valid and adequately documented.

Management's Comments. Concur. The unsupported transactions identified in the report

have been reviewed to ensure they are valid and adequately documented. Management

included additional data that addressed the unsupported transactions (see Appendix E).

Evaluation of Response. Management's comments are not fully responsive to the

recommendation. Although management concurred with the recommendation, Center

management maintains that transactions were adequately documented and valid. Marshall

management did not address documentation, while Langley responded that only one transaction

reviewed was inadequately documented and that daily transaction registers and funding change

memorandums adequately addressed the majority of the remaining transactions. Based on our

reviews of accounting records and interviews with personnel, we maintain that the transactions

cited in this report were not adequately documented. In the majority of transactions, the

documentation presented during our review was not clear or readily available for examination,
9

both of which are required by the GAO standards. We have provided a detailed response to

management's comments regarding adequate documentation and validity in Appendix F, OIG

comment 3.

If Center management would agree to prepare and maintain documents with complete, detailed

explanations of why the transaction was processed and include evidence of management's

approval for the transaction, such actions would be sufficient to resolve this recommendation.

Regarding the validity of the cited transactions, Center management stated that reasons such as

"to reflect accuracy," "to reflect correct charges," "to use expiring funds first," and "to reduce

uncosted carryover balances" are valid deobligations. Such descriptions are overly vague. In

the case of using expiring funds first, a valid obligation is deobligated and a new obligation or

increase to an existing obligation is made against an expiring appropriation. Such transactions

must be properly documented to ensure compliance with fiscal statutes. Fiscal statues require

that Agency funds be used for a specific purpose and within specified timeframes. Transactions

deobligating existing year's funds to meet an Agency or program metric to reduce yearend

uncosted carryover balances should also be well-supported as part of a sound internal control

structure.

We maintain that the Centers have not fully addressed our audit concerns and request that

management reconsider its position and provide additional comments.

4. Report the documentation deficiencies as a significant area of concern to the

Agency Internal Control Council until adequate controls are in place and

operating effectively.

Management's Response. Nonconcur. Many of the transactions questioned in the audit

sample were minor infractions, such as adjustments to correct routine errors or close completed

contracts. Since the issue is simply ensuring that additional documentation is provided and

maintained, the issue is not significant, and reporting it would not be appropriate.

Evaluation of Management’s Response. Management's comments are nonresponsive to

the recommendation. Although management planned to revise the FMM, which will improve

the controls over deobligations, Center management either did not agree that existing

documentation was inadequate or did not fully address the issue. We believe management

should determine whether documentation deficiencies are more wide spread rather than

minimize the results reported at Langley and Marshall. Because the deobligations are reflected

in the Agency financial statements, "minor infractions" can have a significant cumulative impact

on both reported financial information and compliance with fiscal statutes. We maintain our

position that the documentation deficiencies are a significant area of concern and request that

management reconsider its position and provide additional comments.

 
10

Appendix A. Objectives, Scope, and Methodology

Objectives

The objective was to evaluate internal controls for processing and documenting deobligations of

appropriated funds. Specifically, we assessed the support for deobligations and the timeliness

of processing related transactions.

Scope and Methodology

We limited the audit universe to all negative obligation transactions (deobligations) exceeding

$25,000 for August, September, and October 1999 at Langley and Marshall. The total audit

universe for Langley consisted of 170 deobligations totaling $18,556,108. The Marshall

population consisted of 63 deobligations totaling $233,825,918. We examined the Centers

separately. We separated the audit universe into two subsets for each Center. Subset One

contained all deobligations identified for August and September 1999, and Subset Two

contained all October 1999 deobligations at each Center.

Subset One at each Center consisted of August and September 1999 deobligations and was

divided into three strata:12

• Stratum one contained all transactions that were greater than $900,000. We examined

all transactions in this stratum.

• Stratum two contained all transactions valued from $240,000 to $900,000. We

examined all transactions in this stratum.

• Stratum three contained all transactions valued from $25,000 to $240,000. We

selected a sample from this stratum.

Subset Two consisted of all deobligations that occurred during October 1999. We ranked the

deobligations in order of value, and we reviewed the largest nine at each Center. The largest

nine deobligations at Langley and Marshall represented 72 percent and 96 percent,

respectively, of the total October deobligations at each Center. Because we judgmentally

selected the October deobligations, we did not perform statistical projections on the findings for

this subset.

Appendix C contains a summary of our analysis and statistical projections for subsets one and

two.

A summary of the population of deobligations follows:

 

12We excluded from the population any deobligation valued at less than $25,000.
11

Appendix A

Summary of Audit Population by Center and Strata

Universe

Quantity

Universe

Amount

Sample

Quantity

Sample

Amount

Subset one

Langley

Stratum one 2 -$4,895,000 2 -$4,895,000

Stratum two 6 -$2,403,472 6 -$2,403,472

Stratum three 139 -$9,426,190 22 -$1,505,149

Subtotal 147 -$16,724,662 30 -$8,803,621

Marshall

Stratum one 4 -$218,864,000 4 -$218,864,000

Stratum two 8 -$2,972,523 8 -$2,972,523

Stratum three 35 -$2,971,602 18 -$1,573,548

Subtotal 47 -$224,808,125 30 -$223,410,071

Subset two

Langley

Stratum one 9 -$1,319,129 9 -$1,319,129

Stratum two 14 -$512,317

Subtotal 23 -$1,831,446

Marshall

Stratum one 9 -$8,658,968 9 -$8,658,968

Stratum two 7 -$358,825

Subtotal 16 -$9,017,793

Totals 233 -$252,382,026 78 -$242,191,789

Management Controls Reviewed

We reviewed procurement, financial, resource, and program management policies, procedures,

files, and reports, to determine whether:

• Funds reprogrammed were kept in the same congressional appropriation.

• Deobligations were supported by adequate documentation.

• Deobligations were processed in a timely manner.

• Yearend funds reprogramming resulting in new procurement actions were

adequately competed, defined, and negotiated.

• Deobligations were valid.

We considered documentation deficiencies to be a significant area of concern as discussed in

the finding and Appendix B.
12

Appendix A

Audit Field Work

We conducted field work from November 1999 through August 2000 at Langley and Marshall.

We performed the audit in accordance with generally accepted government auditing standards.

Prior Audit Coverage

The NASA Office of Inspector General (OIG) issued Audit Report IG-99-021, “Obligations

Management – Recording Obligations and Adjustments,” dated April 26,1999, based on work

performed at the John H. Glenn Research Center at Lewis Field, Goddard Space Flight Center

(Goddard), Lyndon B. Johnson Space Center, and Marshall. The report concluded that the

Centers accurately recorded obligations and adjustment transactions, but that timeliness and

documentation needed improvement. The Centers sometimes took more than 15 working days

to record obligations and in some cases, had limited or no documentation to support the posted

obligation. Also, the Centers did not always promptly record adjustments to obligations. In

cases in which costs and disbursements were reported in excess of obligations, adjustments

totaling $42 million remained uncorrected for 6 months or longer. As a result, NASA financial

records were not completely current for purposes of preventing overobligation and ensuring

fund availability for expenditures. We recommended that the NASA CFO implement and refine

processes to ensure obligations and adjustments to obligations are promptly recorded.

Management provided an acceptable alternative corrective action and agreed to add specific

metrics on timely recording of obligations and correction of errors to their Quality Assurance

Evaluation process.

The NASA OIG issued Audit Report IG-99-059, “Matching Disbursements to Obligations,”

dated September 30, 1999, based on work performed at NASA Headquarters, Goddard,

Langley, and the John F. Kennedy Space Center. The report concluded that financial

management personnel did not properly match contract disbursements to the originating

obligations. In accordance with fiscal law, NASA must ensure that appropriated funds are used

for the purposes authorized by Congress and must have effective management control over

obligations and disbursements in order to maintain appropriation integrity. Disbursements for

contract items and services received should be matched to the obligations citing funds

authorized to make the payments. Because disbursements were not properly matched to

obligations, appropriated funds may not have been used for their authorized purpose. We

recommended that (1) NASA contractors submit accounting information on their invoices, (2)

procurement offices provide payment instructions to NASA financial management activities, and

(3) require disbursements be properly matched to obligations. NASA management disagreed

with the audit recommendations and stated that they believed disbursements were properly

matched to obligations through the cost accrual process, which ensures that
13

Appendix A

disbursements are matched to the proper appropriation. NASA General Counsel supported

the CFO's conclusion that current processes ensure compliance with applicable law. The

recommendations are open and unresolved.
14

Appendix B. Requirements for Evaluating and Reporting

Management Controls

Title 31, United States Code, Section 3512(b), “Executive Agency Accounting and other

Financial Management Reports and Plans,” requires that each executive agency establish and

maintain a system of accounting and internal controls that provide, in part: (1) effective control

over, and accountability for, assets for which the agency is responsible, and (2) reliable

accounting results that are the basis for preparing budget requests, controlling budget resources,

providing financial information to the President,13 and integrating the agency accounting with that

of the Secretary of the Treasury.

To comply, each agency head must establish internal controls to reasonably assure that:

• obligations and costs comply with applicable law;

• all assets are safeguarded against waste, loss, unauthorized use, or

misappropriation; and

• revenues and expenditures are properly recorded and accounted for to ensure

reliable financial reporting and accountability of assets.

In consultation with the GAO, the OMB developed guidelines in Circular A-123, “Management

Accountability and Control,” dated June 21, 1995, for evaluating and reporting on agency

systems for accounting and internal controls. Specifically, the head of each executive agency

must evaluate internal controls to determine whether financial systems comply with section

3512(b) of the United States Code and must prepare a statement on the agency’s compliance.

Should an agency fail to comply, the statement shall identify material weaknesses in the systems

and plans for corrective actions. The annual statement and related reports are submitted to the

President and Congress.

NPD 1200.1A, “Internal Management Controls and Audit Liaison and Followup,” dated June

1, 2000, provides NASA guidance for evaluating and reporting on management controls.

Specifically, Agency managers must establish controls to provide reasonable assurance that:

• Activities achieve their intended purpose.

• Activities are protected from waste, fraud, unauthorized use, misappropriation, and

mismanagement.

• Resources are used consistent with NASA’s mission.

• Laws and regulations are followed.

• Reliable and timely information is obtained, maintained, reported, and used for

decisionmaking.

 

13Section 1104(e) of the code provides that the President has access to, and may inspect, records of an

agency to obtain information.
15

Appendix B

All NASA managers must continually evaluate and improve the effectiveness of the management

controls over existing operations and processes. Management’s ongoing evaluations should

provide the basis for Agency assessment of accounting and internal controls.

Although Agency managers have primary responsibility for assessing controls, they may rely on

other sources to supplement their assessment. Other sources include results of internal and

external reviews (such as International Organization for Standardization14 reviews, GAO and

OIG audits, evaluations, inspections, and assessments), functional self-assessments, and

financial reviews.

The Administrator must (1) submit the Annual Letter of Assurance to the President and

Congress, pursuant to section 3512 of the United States Code and OMB Circular A-123, and

(2) appoint the Agency Chair of the Internal Control Council and the Management Control

Manager. The Internal Control Council is responsible for recommending issues identified by the

committee for inclusion into the Administrator’s Annual Letter of Assurance.

Deficiencies must be identified when managers are unable to provide reasonable assurance for

any of the NPD requirements discussed earlier. The Internal Control Council must make a

determination as to the relative risk and significance of a deficiency. If the deficiency is

determined to be significant enough to be included in the Administrator’s annual statement, it

must be considered a material weakness.

Due to the extent of inadequate documentation, we could not attest to the validity of

deobligations reviewed during our audit. Therefore, we could not provide reasonable assurance

that Agency obligations were used in accordance with applicable law or that those obligations

were safeguarded from misappropriation. Therefore, we consider the inadequate

documentation to be a significant area of concern reportable to the Agency’s Internal Control

Council, in accordance with the NPD.

 

14The International Organization for Standardization (ISO) is a worldwide federation of national standards

bodies from about 130 countries. The mission of the ISO is to promote the development of standardization

and related activities in the world with a view to facilitating the international exchange of goods and services

and to developing cooperation in the spheres of intellectual, scientific, technological and economic activity.
16

Appendix C. Summary of Statistical Methodology

Subset One Population Statistics

The total population of Subset One consisted of 194 deobligations, from August and September

1999, with a total value of $241.5 million. We audited a total of 60 deobligations in this

population. We found that for 17 (28 percent) of our sample items, we could not determine

whether the transaction was valid. Further, we found inadequate documentation for 33 (55

percent) of the items audited. 

Only 20 deobligations in this population had a value greater than $240,000. We audited all 20

deobligations. For the remaining 174 deobligations, we took a random sample of 40 items

using the EZQuant random number generator.15 The results of our sample are summarized in

the table below.

Results of Audit by Strata

Stratum N

1 n2 Mean s3 Wt.4 r *(validity)5 r (documentation)5

One 6 6 37,293,167 83,274,867 0.031 0.167 0.333

Two 14 14 384,000 108,057 0.072 0.357 0.571

Three 174 40 71,252 49,907 0.897 0.275 0.575

1N is the population size of the stratum.

2

n is the sample size of the stratum.

3

σ is the standard deviation (or variability) of deobligation values in the stratum.

4Weight (Wt.) is the size of the stratum in relation to the total population size expressed as a percentage.

5

ρ is the number of failures in the sample expressed as a percentage. ρ is also the percent of sampled items

that were found to be invalid or inadequately documented.

We determined the standard error of our estimate for stratum three of Subset One by using

Equation One. Because we sampled all of strata one and two, the standard error for the first

two strata was zero.

 σρ = 

1

(1 )(1 )

−

− −

n

p p f

 Equation One*

*ρ equals the percent of sample items that failed, and "f" equals the sample size as a percent of

the population size.

Our results are summarized in the table that follows.

 

15The EZQuant random number generator is a statistical audit tool developed by the Defense Contract Audit

Agency for use by auditors.
17

Appendix C

Sample Stratum

Three

Standard Error

(sr )

Validity 0.063

Documentation 0.070

Population Standard Error

(sr )

Validity 0.0562

Documentation 0.0623

To obtain a 95-percent interval for ρ, we multiplied the standard error, σρ, by the Z-value16 of

1.96 (Equation Two). For projections to the population, we used the minimum of the

confidence interval obtained with Equation Two.

 ρ ± (1.96)(σρ) Equation Two

Using the minimum percentage established by the interval, we multiplied that percentage by the

total number of transactions in the population of stratum three to estimate the number of

transactions in stratum three that were not adequately documented and the number of

transactions we could not verify as valid. We then multiplied the number of transactions thus

obtained by the average cost of transactions for stratum three. Because we audited 100

percent of strata one and two, we did not need to estimate the value of those transactions that

were invalid or inadequately documented, but used the actual value.

Documentation Results for Subset One. We estimated, with a 95-percent confidence level,

that at least 86 deobligations, valued at about $13.2 million, are not adequately documented.

Validity Results for Subset One. We estimated, with a 95-percent confidence level, that at

least 32 deobligations, valued at about $4.7 million, may not be valid.

 

16The Z-value is a random variable that has a standard normal distribution. It identifies the cumulative area

(probability) distribution for an interval (range of values) and is expressed in standard deviations from the

mean.
18

Appendix C

Subset Two Population

Langley. We did not perform a statistical sample of October 1999 deobligations. Rather, we

audited the nine largest deobligations at Langley, totaling about $1.3 million. The nine

transactions represented 72 percent of the total 23 deobligations that occurred in October

1999.

At Langley, four (44 percent) of the nine October 1999 deobligations, valued at about

$.3 million, were not adequately documented. All nine October 1999 deobligations were valid.

Marshall. We did not perform a statistical sample of October 1999 deobligations. Rather, we

audited the nine largest deobligations at Marshall, totaling about $8.7 million. The nine

transactions represented 96 percent of the total 16 deobligations that occurred in October

1999.

At Marshall, four (44 percent) of the nine October 1999 deobligations, valued at about $5.6

million, were not adequately documented. We were unable to attest to the validity of two (22

percent) of the nine October 1999 deobligations, valued at $4 million.
19

Appendix D. Langley CFO Report
20

Appendix E. Management's Response
21

Appendix E
22

Appendix E

See Appendix F,

OIG Comment 1
23

Appendix E

See Appendix F,

OIG Comment 2
24

Appendix E
25

Appendix E
26

Appendix E

See Appendix F,

OIG Comment 3
27

Appendix E

See Appendix F,

OIG Comment 2

See Appendix F,

OIG Comment 4
28

Appendix E

See Appendix F,

OIG Comment 5

See Appendix F,

OIG Comment 6
29

Appendix E

See Appendix F,

OIG Comment 7
30

Appendix E
31

Appendix E

See Appendix F,

OIG Comment 3
32

Appendix E
33

Appendix E
34

Appendix E
35

Appendix E
36

Appendix F. OIG Comments on Management's Response

NASA management provided the following general comments in its response to our

draft report. Our responses to the comments are also provided. In response to

management's comments, we made minor changes to the report, and those changes are

not addressed in this appendix.

Management's Comments. It would be appropriate to add management's responses

to the previous reports referenced on page 1 of this report and to add in Appendix A of

this report management's position on audit report IG-99-059 (as described on page 66

of the 1999 NASA Accountability Report).

1. OIG Comments. We did not add management's position to page 1 of the report

because page 1 refers the reader to Appendix A for details. We added management's

position as stated in the 1999 NASA Accountability Report (page 66) to Appendix A

as requested by management.

Management's Comments. Both Langley and Marshall were concerned that the

audit scope and approach was too restrictive, resulting in misleading information.

Transactions reviewed at both Centers included entries that were adjustments or

corrections, resulting in no net effect to obligation amounts. Limiting the audit scope to

select credit entries does not provide a representative picture of obligations adjustments

and can lead to inaccurate conclusions. A more representative assessment would have

been possible if the scope had been broadened to include related entries.

2. OIG Comments. The scope of our review was not restricted and purposefully

included all negative transactions, including those that reduced obligations or corrected

entries that may have had no net effect on obligation amounts. When the supporting

documentation for the entries in the accounting system clearly referenced an "off-setting"

positive transaction, we concluded that the transaction was adequately documented and

valid. We questioned the validity of a transaction when sufficient documentation was

unavailable to determine why the transaction was recorded, whether the transaction

actually reduced an obligation, or had no net effect on recorded obligations. If the

credit adjustments had been properly documented, we would have been able to attest

to the transaction's validity. Therefore, we do not agree that limiting the scope to credit

transactions misrepresented the overall picture of obligations adjustments, but maintain

that the report conclusions are based on a sound auditing approach.

Management's Comments. Both Marshall and Langley reviewed the transactions

identified in the report and consider them adequately documented and valid. Auditors

should rely on the Centers' system-generated daily register to support the deobligations.

It is not necessary to provide additional documentation
37

Appendix F

for cost accounting changes or data entry errors. Further, if total obligations are not

reduced, those transactions do not need to be documented. Sometimes funds are

distributed to charge benefiting activities. As long as funds are used within the same

appropriation and program year, the transaction is valid. No further action is required,

and this recommendation should be closed.

3. OIG Comments. We did use the daily transaction register to research transactions.

However, system-generated printouts were not adequate to document transactions

because there was no explanation of why the transaction was processed and approved.

In many cases, the auditor used information from the accounting system and traced the

sample transactions back to several NASA accounting and resources personnel to

locate the originator of the transaction. In some cases, the auditor interviewed as many

as five people for a single transaction. Even though personnel were able to explain

many of the transactions processed, they did not prepare documentation to support the

transactions until the auditor's request during the review. In each of those cases, there

should have been clear documentation readily available for support and examination of

the transaction, as mandated by GAO requirements.

When changes were made because of the Contractor's Cost Report, cost accountants

explained why the transactions were processed. However, there was no documentation

available to support the transaction. Based on the GAO criteria, a third party should be

able to review the transaction with readily available documentation.

In other cases, when transactions were processed to correct errors and transfer funds,

personnel who originated the transactions no longer worked in the same position, and in

one case, the employee no longer worked for NASA. In those cases, neither adequate

documentation nor testimony to support the transaction was available.

We also found explanations for the transactions such as "to reflect accuracy," "to use

expiring reimbursable funding first," or "to distribute costs to benefiting programs."

Those explanations did not provide sufficient detail to support the transactions. For

example, if costs are redistributed to benefiting programs, there should be a method to

distribute the costs on an allocable basis; instead, the costs were distributed based on

the amount of unobligated funds available in each activity. In this example, the

transaction was not clearly and accurately documented, and without knowing the actual

cost allocations, we still cannot attest to the transaction validity.
38

Appendix F

Management's Comments. The word "deobligations" should be replaced with

"accounting transaction adjustments."

4. OIG Comments. We did not change the report. The suggested term, "accounting

transaction adjustments," does not apply to all of the transactions reviewed. We

maintain that the best approach was to use the term "deobligations" and define it in a

footnote.

Management's Comments. Auditors did not provide Langley officials a list of

unsupported transactions until August 23, and the draft report was issued on August 22.

The report could have been avoided if data had been provided in a timely manner.

5. OIG Comments. Auditors provided information to financial management personnel

throughout the review. For example, we provided a list of 21 unsupported transactions

to accounting officials at Langley on May 8, 2000, in an effort to locate supporting

documentation. The report would not have been avoided, because adequate

documentation was either not prepared or not readily available to support the

transactions processed during audit fieldwork.

Management's Comments. The term "financial management official" should not be

used. The audit report should indicate whether officials were accounting (financial

management) or resources (resources management) personnel.

6. OIG Comments. Financial management personnel include any NASA employee

within the NASA Headquarters or Center Office of the CFO, including

accounting/finance or resources management. We did not change the terminology in the

audit report, but added a footnote to define financial management personnel.

Management's Comments. Langley officials stated that it is good management to use

oldest funds first. Centers are allowed to change funds within a 3-digit

program code. Additionally, when multiple appropriations are used for a single

contract, it is allowable to move funds between appropriations and years where there is

a bona fide need for the procurement. Additionally, moving funds to reflect metrics is

appropriate and reflects sound program management decisions. All of the Langley

transactions are valid and in accordance with Appropriations Law.

7. OIG Comments. We maintain that obligations should be accurately recorded and

in response to a bona fide need for the procurement of goods and services. When

funds movements are not adequately documented, it is not possible to
39

Appendix F

determine whether the transaction is valid, accurate, or meets a bona fide need. We do

not believe that using the oldest funds first because they are available and pending

expiration meets the intent of Appropriations Law. Nor do we believe

that moving funds to increase metrics and reduce uncosted, carryover balances

accurately reflects the results of Agency operations. We believe that Centers should not

move funds between appropriations and years without proper analysis and approval to

ensure that the obligation is accurately recorded. Recording obligations under any other

approach does not reflect sound obligations management.
40

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

R/Associate Administrator for Aerospace Technology

S/Associate Administrator for Space Science

U/Associate Administrator for Life and Microgravity Sciences and Applications

NASA Centers

Chief Counsel, John F. Kennedy Space Center

Chief Financial Officer, Langley Research Center

Chief Financial Officer, 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

Associate Director, National Security and International Affairs Division, Defense

 Acquisitions Issues, General Accounting Office

Professional Assistant, Senate Subcommittee on Science, Technology, and Space
41

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
NASA Assistant Inspector General for Auditing

Reader Survey

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

Report Title: Internal Controls Over Processing Deobligations

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Major Contributors to the Report

Chester A. Sipsock, Program Director, Environmental and Financial Management Audits

Sandra A. Massey, Program Manager

Linda Wagner Anderson, Auditor-in-Charge

William R. Lester, Auditor

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