Page 1 GAO-07-142R NASA Foreign Purchases 

United States Government Accountability Office

Washington, DC 20548 

November 9, 2006 

The Honorable Mark Udall 

Ranking Minority Member 

Subcommittee on Space and Aeronautics 

Committee on Science 

House of Representatives 

The Honorable Jerry F. Costello 

House of Representatives 

Subject: NASA’s System for Tracking Foreign Contracts and Subcontracts

The National Aeronautics and Space Administration (NASA) is the nation’s leading 

research and development organization in the fields of space and aeronautics. Each 

year, NASA spends almost 90 percent of its annual budget on the acquisition of 

supplies and services in order to fulfill the agency’s mission to pioneer the future in 

space exploration, scientific discovery, and aeronautics research. NASA purchases 

these supplies and services from both U.S. and foreign contractors. Although most 

contracts were awarded to U.S. contractors, NASA, in fiscal year 2004, also awarded 

contracts to vendors in 23 countries. 

The National Aeronautics and Space Administration Authorization Act of 20051

requires the NASA Administrator to annually report to Congress on NASA’s contracts 

and subcontracts performed overseas and purchases from foreign entities. The 

report should also indicate contracts and subcontracts and their dollar values for 

goods and services that are only available from foreign sources as well as items and 

their dollar values for which the Buy American Act was waived pursuant to 

obligations of the United States under international agreements. According to the 

reporting requirement, the first annual report is due no later than January 2007. 

Based on your interest in ensuring that NASA will have the data to meet the new 

reporting requirements, we examined how NASA will track contracts and 

subcontracts performed overseas, foreign purchases, and the use of Buy American 

Act exceptions. We also determined whether NASA collects and analyzes data to 

assess its supplier base. 

 

1

 Pub. L. No. 109-155, § 709. 
Summary 

NASA will not fully meet congressional reporting requirements on fiscal year 2006 

foreign purchases by January 2007 because it is not collecting all the data needed to 

do so. Currently, NASA can track its contracts performed overseas and purchases of 

foreign goods and services through information contained in the Federal 

Procurement Data System-Next Generation (FPDS-NG)—an upgrade to the 

governmentwide information system on federal procurement contracts. As NASA 

relies on FPDS-NG, which currently does not track information on subcontracts or 

Buy American Act exceptions used in foreign purchases, NASA officials stated that 

they cannot report on this information at this time. A recent change made to the 

FPDS-NG will allow NASA to start collecting Buy American Act data for its fiscal year 

2007 purchases, and NASA plans to work with the Office of Management and Budget 

(OMB) to collect subcontract information under a pilot program to be implemented 

by July 2007. However, NASA will not have this information available to meet the 

January 2007 reporting date. 

In addition, although NASA has collected supplier base data for its Space Shuttle 

program, it does not collect or analyze agencywide data on its suppliers. 

In view of NASA’s ongoing actions intended to address congressional reporting 

requirements, we are not making recommendations in this report. 

NASA Relies on FPDS-NG to Meet Reporting Requirements 

NASA officials told us that NASA relies on the FPDS-NG to meet its reporting 

requirements. Therefore, what NASA can report depends on whether the needed 

data are part of the data fields included in the FPDS-NG. If needed data are not 

included in the FPDS-NG, NASA could amend its FAR Supplement to collect the 

data. 

NASA Can Track Foreign Purchases through FPDS-NG

FPDS was established in 1978 to collect governmentwide information on federal 

procurement contracts. Executive agencies, including NASA, are required to submit 

data into the FPDS-NG on their procurements exceeding $3,000. The information 

includes contract types, dollar values and dates, purchaser information, product or 

service information, competition information, and contractor information. Federal 

agencies can query the data system to generate reports needed to meet reporting 

requirements, based on the data included in the system.

Through the FPDS-NG’s advanced search capability, NASA can create its own custom 

reports using the following three data elements currently in the system that would 

allow it to meet part of the congressional reporting requirements 

• Principal Place of Performance—the place where the work is being performed; 

• Vendor Country Code—the country code of the contractor’s address; and 

• Extent Competed—a code that represents the competitive nature of the contract. 

Page 2 GAO-07-142R NASA Foreign Purchases
NASA plans to query the Principal Place of Performance data field to compile a list of

contracts performed overseas and then further query the Vendor Country Code for 

contracts performed by foreign vendors in order to compile a list of foreign 

purchases. In addition, within the list of foreign purchases, NASA plans to use the 

Extent Competed data for a list of sole source contracts that would indicate that the 

items purchased were available only from a source outside the United States. While 

these data fields will enable NASA to report part of the information required by 

congressional requirements, we believe that the accuracy and consistency of the data 

will depend on NASA’s contracting office staff inputting accurate data into the system 

and contractors providing correct information. 

While FPDS-NG is intended to provide more timely and accurate data, enable users to 

generate their own reports, and provide easier user access to data, we recently found 

that the upgrade may have some limitations. Specifically, in September 2005, we 

reported that the FPDS-NG may not achieve its intended improvements. We 

recommended that the Office of Management and Budget (OMB) work with agencies 

that have not moved to an electronic data submission environment to connect to 

FPDS-NG via contract writing systems as soon as possible and develop a plan to 

improve the ease of use and access to data.2

 OMB concurred with the 

recommendations and is in the process of implementing them. 

NASA Unable to Track Foreign Subcontracts or Buy American Act Exceptions until 

Changes Made

Because not all the data needed to satisfy the congressional reporting requirements 

are currently included in the FPDS-NG, NASA has to either collect its own data or 

wait for changes to be made to the FPDS-NG. The following data are not being 

tracked by NASA but are needed to satisfy the congressional reporting requirements 

• subcontracts performed overseas, 

• subcontracts that are purchases from foreign entities, 

• subcontracts for which the goods or services are available only from a source 

outside the United States, and 

• foreign purchases for which the Buy American Act did not apply due to U.S. 

obligations under international trade agreements. 

The Federal Funding Accountability and Transparency Act of 20063

 enacted on 

September 26, 2006, requires OMB to establish a database containing, among other 

things, contract and subcontract data. The act requires OMB to commence a pilot 

program to collect subcontract data no later than July 2007. NASA plans to work 

with OMB to determine if the new system will satisfy NASA’s subcontract reporting 

requirements. If not, NASA will consider development of a supplemental subcontract 

database. 

 2

 GAO, Improvements Needed to the Federal Procurement Data System-Next Generation, GAO-05-

960R (Washington, D.C.: Sept. 27, 2005) 3

 Pub. L. No. 109-282. 

Page 3 GAO-07-142R NASA Foreign Purchases
In addition, in October 2006, a change was made to the FPDS-NG that will allow 

NASA to start collecting Buy American Act exception information for its fiscal year 

2007 purchases, in response to a fiscal year 2006 appropriations act4

 governmentwide 

reporting requirement. Also, in response to this reporting requirement, the Federal 

Acquisition Regulation (FAR) was changed on September 28, 2006, requiring offerors 

to provide “Place of Manufacture” data. According to agency officials, along with this 

information, contracting officers will be required to enter into the FPDS-NG the 

appropriate Buy American Act exception category for procurements of items that are 

manufactured outside of the United States—one of these categories being U.S. 

obligations under trade agreements. On October 6, 2006, NASA issued guidance to its 

contracting officers on how to enter Buy American Act exceptions data into the 

FPDS-NG. This information will enable NASA to collect the data needed to meet its 

reporting requirements. 

NASA procurement officials told us that contracting officers will need additional 

training to properly input new data elements, such as information on the Buy 

American Act exceptions, into the FPDS-NG. The FAR Acquisition Law Team, that 

participated in preparing the FAR changes, recommended that an on-line training 

module would be appropriate to assist contracting officers to understand how to 

determine the applicable exceptions to the Buy American Act. NASA plans to include 

training on Buy American Act exceptions as a part of its training planned for its 

contracting personnel when its new contract management system becomes 

operational in November 2006. 

NASA Supplier Base Assessment 

With the exception of the Space Shuttle program, NASA is not collecting or analyzing 

data for its agencywide supplier base. For the Space Shuttle program, NASA has 

identified its active supplier base and made analyses for planning purposes. Such 

information collected agencywide could allow NASA to make an assessment of its 

total supplier base. 

NASA officials told us that they do not track agencywide data on its suppliers, but 

that some individual NASA program offices may collect such data as needed. For 

example, NASA conducted a transition planning study5

 in 2005 for the phasing out of 

the Space Shuttle. As a part of the study, NASA collected supplier base data. The 

study, for example, identified 1,542 active suppliers spread across 43 states and 

analyzed a list of critical vendors on their capabilities and alternative sources. While 

a follow-on study was requested by the Space Shuttle Program supply chain manager 

 4 Transportation, Treasury, Housing and Urban Development, the Judiciary, the District of Columbia, 

and Independent Agencies Appropriations Act, 2006, Pub. L. No. 109-115, § 837 (2005). The Act 

requires each federal agency to report to Congress on the amount of acquisitions from entities that

manufacture the articles, materials, or supplies outside of the United States. The report should include 

the dollar value of any articles, materials, or supplies purchased that were manufactured outside of 

the United States, an itemized list of Buy American Act exceptions for these procurements, and a 

summary of the total procurement funds spent on goods manufactured in the United States versus 

funds spent on goods manufactured outside the United States. 5

 NASA, Integrated Space Operations Summit III, Enabling Exploration, ISOS Space Shuttle 

Program Transition Panel Final Report (Apr. 15, 2005).

Page 4 GAO-07-142R NASA Foreign Purchases
to study the viability of some of the suppliers, the official told us that the study was 

cancelled due to a lack of funding. 

Agency Comments 

We provided a draft of this letter to NASA for comment. NASA concurred with our 

report and had no comments. 

Scope and Methodology 

To assess how NASA will track contracts and subcontracts performed overseas, 

foreign purchases, and the use of Buy American Act exceptions, we met with NASA 

officials to obtain information on NASA’s FPDS-NG data tracking system; interviewed 

NASA officials on current tracking of foreign purchases and plans to collect data 

needed to meet reporting requirements; and met with other federal agency officials 

on proposed changes to the FAR and the FPDS-NG that would allow for the 

collection of foreign purchase and Buy American Act data. In addition, we analyzed 

contract files at NASA’s Goddard Space Flight Center to determine how Buy 

American Act exceptions are documented. 

To determine whether NASA collects and analyzes data to assess its supplier base, 

we interviewed NASA officials to determine what studies NASA has done to collect 

supplier base data and what type of data analysis has been conducted. 

We conducted our work from May 2006 to October 2006 in accordance with generally 

accepted government auditing standards. 

 - - - - - - - - 

As requested by your office, unless you publicly disclose the contents of this report, 

we plan no further distribution of it until 30 days from the date of this letter. At that 

time, we will send copies to NASA’s Administrator and interested congressional 

committees. We will also provide copies to others upon request. In addition, this 

letter will be available at no cost on the GAO Website at http://www.gao.gov. 

Should you or your staff have any questions on matters discussed in this report, 

please contact me at (202) 512-4841 or at ChaplainC@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on the last page 

of this report. Principal contributors to this report were John Neumann, Assistant 

Director; John Ting; and Kathryn Smith. 

Cristina Chaplain 

Acting Director, Acquisition and Sourcing Management 

(120536)

Page 5 GAO-07-142R NASA Foreign Purchases
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