FEBRUARY 16, 2012

AUDIT REPORT

REPORT NO. IG-12-010 (ASSIGNMENT NO. A-11-012-00)

OFFICE OF AUDITS

AUDIT OF NASA’S PURCHASE AND TRAVEL CARD 

PROGRAMS

OFFICE OF INSPECTOR GENERAL

National Aeronautics and 

Space Administration

 
REPORT NO. IG-12-010 

Final report released by:

Paul K. Martin

Inspector General

Acronyms 

CBA Centrally Billed Account 

FMOP Financial Management Operating Procedure

FTR Federal Travel Regulation

IBA Individually Billed Account

NEACC NASA Enterprise Applications Competency Center 

NPD NASA Policy Directive

NPR NASA Procedural Requirements

NSSC NASA Shared Services Center 

OMB Office of Management and Budget
FEBRUARY 16, 2012

REPORT NO. IG-12-010 

OVERVIEW

AUDIT OF NASA’S PURCHASE AND TRAVEL CARD PROGRAMS

The Issue

Like other Federal Government agencies, NASA uses purchase cards to reduce the 

administrative cost of processing small dollar purchases and travel cards to reduce the 

cost of official travel and for the convenience of the traveler. In addition, NASA receives 

rebates from the credit card issuer based on volume of activity and timeliness of 

payments. NASA’s approximately 15,500 travel and 2,200 purchase cardholders 

incurred $79 million and $82 million in charges, respectively, during fiscal year 2010. 

Because they allow the same individual to order, pay for, and receive goods and services, 

purchase and travel cards are at high risk for misuse, fraud, waste, and abuse. Moreover, 

the sheer number of cards in circulation opens NASA to the possibility of fraud. For 

example, NASA’s charge card issuer reported that from June 2010 through July 2011, 

36.5 percent of purchase cards and 3 percent of travel cards had been compromised in the 

sense that card information (e.g., card number, cardholder’s name) may have been 

obtained by an unauthorized source. Accordingly, if the internal controls governing 

NASA’s purchase and travel card programs are not sufficient, properly designed, and 

fully implemented, NASA will not be in the best position to detect and prevent fraudulent 

purchases or other improper use of the cards. 

For this audit, we examined transactions charged to NASA purchase and travel cards 

between October 1, 2009, and December 31, 2010, to determine whether NASA’s 

purchase and travel card programs were operating efficiently and whether internal 

controls were effective in preventing and detecting misuse, fraud, waste, or abuse by 

cardholders or third parties. See Appendix A for details of the audit scope and 

methodology. 

Results

Overall, we found that NASA’s purchase and travel card programs were operating 

efficiently and that internal controls appeared effective in detecting misuse, fraud, waste, 

and abuse. However, we believe NASA could further strengthen its controls by applying 

Office of Management and Budget (OMB) guidance and implementing, Agency-wide, 

practices used by several NASA Centers. For example, NASA should evaluate card 

usage and close or restrict accounts that are underutilized. We also believe that NASA 

should clarify its policy regarding the allowability of certain types of charges on its travel 

cards. In addition, we found that NASA was not in compliance with OMB policy 
OVERVIEW

ii REPORT NO. IG-12-010 

regarding the application of card rebates.1

Improper Application of Rebates. NASA did not properly return rebates earned from 

its charge card issuer, JPMorgan Chase & Co. (JPMorgan), to the appropriate 

appropriation or account, resulting in possible misapplication and augmentation of 

funds.

 Lastly, we found an inappropriately high 

number of employees had the ability to both authorize their own travel and approve their 

own travel reimbursement claims. 

2

Controls over the Travel Card Program, While Generally Effective, Could Be 

Strengthened. We found that while existing internal controls over NASA’s travel card 

program are generally effective in detecting misuse, fraud, waste, and abuse by 

cardholders, the Agency could further strengthen its controls. Specifically, we found that 

NASA issued an excessive number of travel cards and that the Agency could make better 

use of reports the card issuer already provides to help detect fraud and misuse. We also

believe that NASA should clarify its policy regarding the allowability of certain types of 

personal charges. 

 NASA received rebates of approximately $5 million from October 2006 to 

December 2010, with about $1.8 million received during our audit period of October 

2009 to December 2010. NASA applied these funds to its working capital fund, which

since 2006 has been managed by the NASA Shared Services Center (NSSC). However, 

OMB guidance requires that rebates be returned to the appropriation or account from 

which the funds for the purchases were expended. NASA’s rationale for applying the 

rebate to the working capital fund was that the rebate reduces the overall operating costs 

of the fund, with the resulting savings passed on to the users of NSSC’s services via a 

reduction in per-transaction charges. However, because NASA could not show that these

savings were allocated to particular appropriation accounts proportionate to the 

associated expenditures from those accounts, this practice results in possible 

misapplication and augmentation of appropriated funds. 

NASA’s Internal Controls for the Travel Card Program Are Generally Effective. We 

found that NASA was effectively monitoring travel card use, that NASA’s travel card 

policies and procedures are generally consistent with OMB guidelines, and that the 

Agency was providing employees with appropriate training. We also found that most 

NASA employees used their travel cards appropriately and paid their bills on time, and 

that NASA was effectively monitoring employee payments and reminding employees 

when their accounts were past due. 

NASA Should Reduce the Number of Travel Cards Issued. We found an excessive 

number of individuals at NASA with travel cards who do not need them. For example, 

 

1 OMB Circular A-123 Appendix B, “Improving the Management of Government Charge Card 

Programs,” January 2009.

2 Government Accountability Office (GAO). “Principles of Federal Appropriations Law, Third Edition, 

Volume II,” February 2006 (GAO-06-382SP), describes the concept of augmentation as a Government 

agency using funds derived from an outside source to finance the operation of a program beyond the 

level established by appropriation, without Congressional approval.
OVERVIEW

REPORT NO. IG-12-010 iii

909 travel cards, or 6 percent of all travel cards at NASA, had never been used. 

Additionally, we found that 28 cardholders had separated from NASA but still had active 

travel card accounts. NASA did not conduct periodic reviews of travel card accounts to 

determine if continued possession of a travel card was warranted (i.e., used for a 

minimum amount of travel) or have adequate policies and procedures to ensure that 

accounts of separated employees were closed. Allowing employees to maintain travel 

card accounts they are not using unnecessarily increases the risk of loss, fraud, abuse, and 

misuse of these cards.

NASA Should Clarify Internal Policy Regarding Travel Card Use and Implement 

Additional Controls. NASA has implemented various controls to prevent and detect the 

use of travel cards for other than authorized purposes, and we found these controls are

generally effective. Specifically, we tested 176 transactions and found 9 instances of 

improper or questionable use that had not been detected by NASA. In 4 of these 

instances, the cardholder had clearly used the card for personal or non-travel related 

expenses: a charge of $773 for personal travel; $63 to renew personal subscriptions to 

periodicals; $306 to pay for refreshments for an awards ceremony; and $114 to purchase 

snacks at a hotel gift shop. None of these employees sought reimbursement from NASA 

for these charges. In addition, we identified five instances where it was not clear whether 

charges were allowable because the Federal Travel Regulation (FTR) does not clearly 

prohibit certain types of expenses and NASA has not issued supplemental policy to 

clarify the FTR. For example, NASA policy does not address use of a travel card to 

purchase in-room movies when staying at a hotel on official travel, to pay for the meals 

of others who are on official travel, or for hotel expenses incurred for a personal stay that 

precedes or follows an official business trip. 

We also found that NASA could make better use of existing reports to help identify 

improper use of travel cards. For example, JPMorgan’s PaymentNet® system

(PaymentNet) generates a Cash Advance Report to help identify cash advances unrelated 

to Government travel. Although several NASA Centers consistently review this report, 

we found that others do not. 

NASA’s Policy and Practices Regarding Self-Approval and Self-Authorization of 

Travel Are Overly Broad. We found 45 NASA employees had the authority to “selfapprove” both travel authorizations and travel claims, meaning their authorizations and 

claims did not have to be reviewed and approved by a supervisor or approving official.3

 

3 To self-authorize, an employee agrees that their planned travel is to conduct appropriate and necessary 

official Government business without another’s prior documented consent. 

 

The number of self-approvers at NASA is exorbitant when compared with other Federal 

agencies such as the Department of Justice where only 2 positions out of more than 

116,000 employees have this type of authority. During our audit period, NASA selfapprovers incurred $552,000 in travel expenses charged to their individual credit cards. 

We also found that according to NASA’s written policy, 22 of these employees should 

have been able to authorize their own travel but required to obtain supervisory approval 

of travel-related expenses. Additionally, subordinate employees approved the travel 
OVERVIEW

iv REPORT NO. IG-12-010 

claims of their superiors in contravention of NASA policy. Finally, NASA’s policy 

designating who can self-authorize and self-approve is out of date and refers to positions 

that no longer exist at the Agency. All of these conditions increase the risk of fraud and 

abuse in NASA’s travel card program. 

Controls over the Purchase Card Program, While Generally Effective, Could Be 

Strengthened. We found that while the internal controls over the purchase card program 

are generally effective in detecting misuse, fraud, waste, and abuse by cardholders, we 

believe NASA could further strengthen its controls. We found that NASA had issued an 

excessive number of purchase cards that were rarely used. We also found instances of 

insufficient documentation for purchase requests and for the cost and approval of 

purchases. 

NASA’s Internal Controls for the Purchase Card Program Are Generally Effective. We 

found that NASA was effectively monitoring purchase card use, that NASA’s purchase 

card policies and procedures generally comply with OMB guidelines, and that the 

Agency was providing appropriate training to its employees. Additionally, we found that 

NASA employees used their purchase cards for authorized purchases and usually retained 

appropriate documentation supporting their purchases. However, we identified several 

areas for improvement. 

NASA Should Reduce the Number of Purchase Cards Issued. We found that 20 

cardholders at Ames Research Center had never used their cards and 90 others Agencywide had used their cards only one time between October 1, 2009, and December 31, 

2010. Allowing purchase cardholders to maintain purchase card accounts that are not 

needed on a recurring basis unnecessarily increases the risk of loss, fraud, abuse, and 

misuse of the cards. Based in part on our audit, NASA reviewed these accounts and 

closed 27. 

NASA Should Improve the Documentation and Approval Trail for Purchases. NASA has 

not developed sufficient policies and controls for documentation of purchase card 

purchases and approvals. Specifically, we found instances in which the individuals 

requesting and approving purchases could not be identified and transaction files 

contained no evidence of the cost of purchases. 

OMB guidance requires that purchase cardholders include a written request or at a 

minimum the requestor’s name in the transaction records and that prior approval be 

obtained before self-generated purchases are made. However, 39 of 203 purchase card 

transactions records we examined did not contain written requests from or otherwise 

identify the individual requesting the purchase. Of those 39 transaction records, 14 were 

self-generated purchases (i.e., purchases originating from the cardholders without a 

request from a third party) in which prior approval by a supervisor was not obtained.

Similarly, out of 97 transactions we sampled for control testing, we found 75 with 

inconclusive evidence of who approved the reconciliation of the transactions. NASA 

uses P-Card Web SolutionTM to track approval of purchase card reconciliations. An 
OVERVIEW

REPORT NO. IG-12-010 v 

approving officer can delegate their approval authority within P-Card Web Solution to a 

third party but when a designee reviews reconciliations, P-Card Web Solution records the 

user identification code of the approving official rather than the designee. 

For 10 of the 203 transactions we examined, we noted that the vendor invoice or other 

form of supporting documentation that validates the cost of items purchased was not 

received from the vendor and maintained in the purchase card transaction records. 

NASA’s policy does not incorporate the OMB recommended practice of requiring 

purchase cardholders to obtain an invoice or alternative form of evidence of costs such as 

a quote or a screen print for Internet purchases if one is not already provided by the 

vendor. By making greater use of recommended controls and best practices used at 

several NASA Centers, NASA could further reduce the risk of misuse, fraud, waste, and 

abuse of purchase cards.

Management Action

We recommended that the Chief Financial Officer:

• implement policies that ensure rebates are distributed to the appropriation or 

account against which the original charge was made or seek statutory 

authority to apply the rebates to the working capital fund; 

• improve controls over the travel card program by: 

o obtaining and cancelling the accounts of all individuals who separate 

from employment at NASA and conduct periodic reviews to ensure 

that such accounts have been cancelled; 

o implementing a policy requiring a minimum amount of anticipated 

travel before issuance or re-issuance of a travel card;

o requiring quarterly evaluations of cardholder accounts for minimum 

usage and recommend deactivating accounts or lowering the spending 

limits of underutilized cards; 

o enhancing controls to identify misuse of the travel card, such as 

developing a data-mining tool to identify suspicious activity or 

patterns of abuse or misuse of travel cards, to complement the tools 

available from JPMorgan; and 

o developing guidance to address when limited personal use of the travel 

card during official Government travel may be acceptable and 

reminding cardholders and supervisors of the proper uses of the card. 
OVERVIEW

vi REPORT NO. IG-12-010 

• develop policies and procedures to significantly decrease the number of 

positions permitted to self-authorize and/or self-approve their travel and 

ensure that appropriate supervisors are reviewing and approving travel claims. 

We recommended that the Assistant Administrator for Procurement: 

• develop a policy requiring a minimum amount of purchases or a demonstrated 

necessity before issuance or re-issuance of a purchase card and require 

recurring evaluations of cardholders for minimum usage and recommend 

deactivating cards or lowering the spending limits of underutilized cards; 

• require sufficient documentation for purchases, as required by OMB Circular 

A-123 Appendix B, including a written request for purchases or, at minimum, 

the requestor’s name, written approval prior to making self-generated 

purchases, and evidence supporting the costs of purchases such as an invoice 

or alternative evidence of costs such as a screen print; and

• work with the NASA Enterprise Applications Competency Center to make 

systems changes to P-Card Web Solution to enable the software to document 

the user identification code of the approving party and work with the Purchase 

Card Coordinator to develop an alternative documentation process for 

approvals until systems changes are made.

In response to a draft of this report, the Chief Financial Officer concurred with the 12 

recommendations addressed to her, stating that she plans to seek statutory authority to 

apply rebates to the working capital fund and, pending such legislative action, will 

implement a revised process to more clearly return rebates to the appropriation that 

funded the activity. In addition, she promised to improve policies and controls over the 

travel card program, including reducing the number of individuals with the authority to 

authorize and approve their own travel. We consider the Chief Financial Officer’s 

comments and proposed actions responsive; therefore, these recommendations are 

resolved and will be closed upon completion and verification of the proposed actions. 

The Assistant Administrator for Procurement concurred with our recommendation to 

properly document purchase approvers and proposed responsive corrective action. 

Accordingly, this recommendation is resolved and will be closed upon completion and 

verification of the proposed actions. However, the Assistant Administrator did not 

concur with our recommendations to develop a policy (1) requiring a minimum amount 

of purchases or a demonstrated necessity before issuance or re-issuance of a purchase 

card or (2) requiring a written request for purchases or, at minimum, the requestor’s 

name, written approval prior to making self-generated purchases, and evidence 

supporting the costs of purchases, stating that current policies adequately address these 

issues. 

With regard to the first of these recommendations, the Assistant Administrator noted that 

NASA’s current policy already requires approving officials to conduct a usage analysis of 
OVERVIEW

REPORT NO. IG-12-010 vii

cardholder accounts every six months. However, we found that this analysis was not 

effectively performed, which resulted in a high number of underutilized cards remaining 

active. Additionally, the existing policies are not clear in defining the need or 

prerequisite criteria for a card to be issued. Similarly, in our view NASA’s current policy 

for documenting purchase card purchases is inadequate. While the current policy 

requires cardholders to record information regarding items ordered, it does not 

specifically require inclusion of the requestor’s name. We believe that in the absence of 

such a requirement cardholders will continue to omit this information. Similarly, while 

cardholders may be trained to enter information related to special approvals in their order 

logs, we found no evidence that they are required to obtain and document evidence of 

approval for self-generated purchases. Finally, although we agree that current policy 

requires cardholders to include an invoice when the merchant provides one, the policy 

does not specify what evidence of cost is required when an invoice is not provided. 

Accordingly, these recommendations remain unresolved. Management’s comments can 

be found in Appendix D. 

FEBRUARY 16, 2012

REPORT NO. IG-12-010 

CONTENTS

INTRODUCTION

Background _________________________________________ 1 

Objective ___________________________________________ 4 

RESULTS

Improper Application of Rebates _________________________ 5 

Controls over the Travel Card Program, While Generally 

Effective, Could Be Strengthened ______________________ 8 

NASA’s Policy and Practices Regarding Self-Approval and 

Self-Authorization of Travel Are Overly Broad____________ 13

Controls over the Purchase Card Program, While Generally 

Effective, Could Be Strengthened _____________________ 18

APPENDIX A 

Scope and Methodology_______________________________ 25

Review of Internal Controls ____________________________ 26

Federal Laws, Regulations, Policies, and Guidance __________ 27

Prior Coverage ______________________________________ 28

APPENDIX B 

Sampling Methodology________________________________ 29

APPENDIX C 

Card Account Status and Transaction Data by NASA Location__ 31

APPENDIX D 

Management Comments ______________________________ 33

APPENDIX E 

Report Distribution___________________________________ 38

FEBRUARY 16, 2012

REPORT NO. IG-12-010 1 

INTRODUCTION

Background

Federal Government agencies use purchase cards to reduce the administrative costs

associated with processing small dollar purchases and travel cards to reduce the costs

associated with administering the official travel of their employees and for the 

convenience of the travelers. NASA’s purchase and travel card programs involve 

approximately 15,500 travel and 2,200 purchase cardholders who collectively incurred 

charges of $79 million and $82 million, respectively, in fiscal year 2010. Both programs 

also are intended to improve oversight of expenditures and take advantage of rebates 

from card issuers. However, charge card programs face a high risk of misuse, fraud, 

waste, and abuse. 

NASA obtains purchase and travel cards through the U.S. General Services 

Administration SmartPay2® program, which provides charge cards to U.S. Government 

agencies through master contracts with three major banks. One of these banks, 

JPMorgan Chase & Co (JPMorgan), has been NASA’s credit card service provider since 

2008. NASA receives rebates from JPMorgan based on the amount of money charged to 

the cards and the timeliness of payments. Rebates increase when payments are prompt 

but are reduced or eliminated when payments are delinquent or accounts with unpaid 

balances are canceled or “charged off.” 

Purchase and travel cards are at high risk for misuse or fraud because they allow the same 

individual to order, pay for, and receive goods and services. Moreover, the sheer number 

of cards in circulation opens NASA to the possibility of fraud. For example, JPMorgan 

reported that from June 2010 through July 2011, 36.5 percent of NASA purchase cards 

and 3 percent of travel cards were potentially compromised – meaning that card 

information (e.g., card number, holder’s name) may have been obtained by an 

unauthorized source as a result of the card being lost or stolen or through means of fraud. 

Office of Management and Budget (OMB) Circular No. A-123, Appendix B, sets forth 

the policies and procedures Federal agencies should use to maintain internal controls that 

reduce the risk of fraud, waste, and error in Government charge card programs.4

 The 

guidance also establishes minimum requirements and suggested best practices for card 

use. Supplemental NASA policy requires that travel and procurement cards be used only 

for the payment of authorized goods and services in support of Agency missions, 

operations, financial management, and institutional activities and assigns responsibility 

for the credit card programs within the Agency.5

 

4

 OMB Circular No. A-123, Appendix B, “Improving the Management of Government Charge Card 

Programs,” Revised January 15, 2009.

 Pursuant to the policy, the Chief 

5 NASA Policy Directive (NPD) 9070.2, “Government Charge Cards,” November 5, 2008. 
INTRODUCTION

2 REPORT NO. IG-12-010 

Financial Officer is the Agency-wide lead for the travel card program, the Assistant 

Administrator for Procurement is the lead for the purchase card program, and the 

Executive Director of the NASA Shared Services Center (NSSC) has administrative 

oversight and program responsibilities for both programs. 

Each NASA Center, Headquarters, and the Wallops Flight Facility have Center/Agency 

Program Coordinators (Coordinators) who manage the charge card activities for their 

locations. Coordinators are responsible for issuing and closing accounts, ensuring that 

cardholders and approving officials are fully trained and meet refresher training 

requirements, overseeing the processing and validation of transactions, and investigating

possible improper use or abuse of privileges by cardholders. The Coordinators are also 

responsible for conducting reviews of their locations’ charge card activities to ensure 

compliance with NASA and OMB requirements. In addition, NSSC designates an 

Agency Program Coordinator for each of the charge card programs to oversee the activity 

at the Agency level. All program participants, including cardholders and Coordinators, 

must be trained in charge card management.

Travel Card. The Travel and Transportation Reform Act of 1998 (P.L. 105-264) 

mandates that Government travel cards be used to pay for all expenses associated with 

official Government travel unless specifically exempted. The purpose of the Act is to 

reduce the overall administrative costs of travel for the Federal Government and take 

advantage of rebates offered by card issuers. 

In accordance with the Act, the General Services Administration issued the Federal 

Travel Regulation (FTR), which sets forth policies and procedures governing the use of 

Government travel cards and restricts their use to official travel expenses only. While all 

Federal agencies are bound by the FTR, they may also issue supplemental policies 

consistent with the FTR to further guide the conduct of their employees. NASA’s 

supplemental guidance is found in NASA Procedural Requirements (NPR) 9700.1.6

The NASA travel card program includes two types of accounts: centrally billed accounts 

(CBA) and individually billed accounts (IBA). Centrally billed accounts are corporate 

accounts through which the Agency charges expenses associated with the air, rail, and 

bus transportation of NASA employees. The bills for these accounts are received and 

paid directly by NASA. Individually billed accounts are opened for NASA employees

who charge expenses to the card attached to the account while they are on travel away 

from their official duty stations (e.g., meals, hotels, and taxis) and receive reimbursement 

from NASA after submitting their expenses via an expense report. The employees 

receive the statements associated with these individual accounts and are responsible for 

making the payments to JPMorgan directly. 

 

Data related to NASA’s travel card program is maintained in FedTraveler and in 

JPMorgan systems. FedTraveler is a comprehensive Electronic Government Travel 

 

6 NASA Procedural Requirements (NPR) 9700.1, “Travel,” September 30, 2008; specifically,

Appendix A. NASA Federal Travel Regulations Supplement.” 
INTRODUCTION

REPORT NO. IG-12-010 3 

Service Federal employees use to plan, book, track, approve, and request reimbursement 

for official Government travel. NASA makes FedTraveler available to Agency 

employees and requires them to use the system to initiate authorizations prior to 

embarking on travel and to request reimbursement for expenses upon their return. 

JPMorgan PaymentNet® provides cardholders and administrators access to data on 

spending and management reports. 

Purchase Card. NASA participates in the SmartPay Purchase Card program. The use 

of charge cards was introduced by the General Services Administration in 1984 to 

streamline the acquisition process across the Federal Government by allowing agencies to 

obtain certain supplies and services directly from vendors. The SmartPay Purchase Card 

program is intended to reduce the use of purchase orders and the associated 

administrative costs and improve the payment process by allowing for fully automated 

invoicing and payment processing. Additionally, the program further reduces overall 

costs by providing agencies the opportunity to receive rebates from issuers based on the 

dollar amount of transactions and the timeliness of payments. Like travel cards, purchase 

cards are issued to individual NASA employees; however, the associated accounts are 

billed to and paid directly by NASA.

NASA Federal Acquisition Regulation Supplement, Part 1813, “Simplified Acquisition 

Procedures,” provides guidance for purchase card use. NASA locations have 

implemented additional controls and assigned contract personnel to handle program 

administration, including development of internal operating procedures. The Coordinator 

at each location is responsible for overall management of the location’s purchase card 

program. Additionally, the approving official for each cardholder serves as a key internal 

control point in reviewing individual cardholder purchases. Other controls established 

include single purchase limits, monthly purchase limits, reconciliation of monthly 

invoices, monitoring and training by Coordinators, and supervisory review of purchase 

card statements.

NASA logs and tracks purchase card usage through P-Card Web SolutionTM. 

Cardholders must input detailed purchase information into an order log in P-Card Web 

Solution. The cardholder uses this information to reconcile the bills received from the 

issuer on a monthly basis. Supervisors/approving officers must approve monthly 

reconciliations within P-Card Web Solution. Further, JPMorgan PaymentNet provides 

cardholders and administrators access to data on spending and management reports. 

NSSC and the Working Capital Fund. The NSSC has administrative oversight and 

program responsibilities for the NASA purchase and travel card programs, acting as the 

liaison with JPMorgan for all aspects of the programs, monitoring account activity, 

updating and testing internal controls, and providing training. The NSSC was established 

in 2006 to consolidate into a single location multiple NASA business services that 

previously were provided by civil service and contractor personnel at each NASA Center. 

The NSSC is funded through a working capital fund, which in turn is funded primarily 

through “payments” made by NASA customers for NSSC services. NSSC calculates the 
INTRODUCTION

4 REPORT NO. IG-12-010 

fees it charges users by estimating the total expected costs to perform the services. For 

the past 5 years, NSSC has applied the rebates NASA receives from card issuers to the 

working capital fund, which according to NSSC personnel has reduced the pertransaction costs charged to users of NSSC services. Prior to establishment of the NSSC 

in 2006, the Lead Agency Program Coordinator at Langley had administrative oversight 

and program responsibilities for the NASA purchase and travel card programs and 

rebates were applied to Langley’s General and Administrative budget to help defray the 

costs of performing these coordinator functions. 

Objective 

Our objective was to determine whether NASA’s purchase and travel card programs were 

operating efficiently and in compliance with laws and regulations and whether its internal 

controls were effectively detecting misuse, fraud, waste, or abuse in the programs. See 

Appendix A for details of the audit’s scope and methodology; our review of internal 

controls, Federal laws, regulations policies, and guidance; and a list of prior audit 

coverage. 
RESULTS

REPORT NO. IG-12-010 5 

IMPROPER APPLICATION OF REBATES 

NASA did not return rebates earned from JPMorgan to the proper appropriation as 

required by OMB. This resulted in a possible misapplication and augmentation of 

appropriated funds. From October 1, 2009, to December 31, 2010, NASA received 

travel and purchase card rebates totaling approximately $1.8 million from JPMorgan. 

NASA applied these rebates to the working capital fund that supports the operations 

of the NSSC. According to NSSC personnel, applying the rebates to the working 

capital fund reduced the operating costs of the NSSC, and the NSSC passed these 

savings on to the users of its services through a reduction in per-transaction charges. 

However, NASA could not show that the savings were allocated to particular 

appropriation accounts proportionate to the associated expenditures from those 

accounts, as required by OMB guidance and appropriation law. 

Possible Misapplication and Augmentation of Funds 

NASA received quarterly travel and purchase card rebates totaling approximately 

$5 million from October 2006 to December 2010, with about $1.8 million received 

during our audit period of October 1, 2009, to December 31, 2010. Under the current 

JPMorgan contract, rebates are calculated based on two primary factors: the total dollar 

amount of purchases and the timeliness of payments. Rebate amounts rise with prompt 

payments and are reduced or eliminated by late payments, delinquencies, or charged-off 

accounts. 

Table 1: Rebates for NASA Purchase and Travel Cards,

October 2006 through December 2010

Fiscal Year

CBA Travel 

Cards

IBA Travel 

Cards

Purchase 

Cards Total 

2007 $88,255 $130,977 $566,614 $785,846

2008 108,506 150,072 686,976 945,554 

2009 269,200 412,544 774,836 1,456,580

2010 356,209 376,101 854,516 1,586,826 

2011 67,990 82,393 112,324 262,707

 Total $890,160 $1,152,087 $2,995,266 $5,037,513

Source: Bank of America & JPMorgan Rebate Checks

CBA, centrally billed accounts; IBA, individually billed accounts. 

OMB Circular A-123 Appendix B, paragraph 7.5, states, “Unless specific statutory 

authority exists allowing refunds to be used for other purposes, refunds must be returned 

to the appropriation or account from which they were expended, . . ..” However, NASA 
RESULTS

6 REPORT NO. IG-12-010 

applied the rebates not to the individual appropriation accounts from which the travel and 

purchase card funds were expended, but rather to the working capital fund that supports 

the overall operations of the NSSC. However, unlike other Federal Government 

agencies, NASA does not have specific statutory authority to apply the rebate directly to 

the working capital fund.7

However, NASA could not demonstrate that the savings were allocated to particular 

appropriation accounts proportionate to the associated expenditures from those accounts. 

For example, if its Science appropriation was due a $50,000 rebate credit based on its 

travel and purchase card transaction and payment history, NASA could not demonstrate 

that the appropriation received a corresponding discount on services performed by NSSC. 

Accordingly, some users may have received less than they were entitled to, while others 

may have received rebate credit in excess of their actual expenditures, which would have 

resulted in augmentation of the associated appropriations account.

 NSSC personnel told us that they believed this practice was 

consistent with OMB requirements because applying the rebates to the working capital 

fund reduced the per-transaction cost the NSSC charges users, thereby reducing costs for 

all users. 

8

Recommendation, Management’s Response, and Evaluation of 

Management’s Response

 

Recommendation 1. The Chief Financial Officer should implement policies that ensure 

rebates are distributed to the appropriation against which the original charge was made or, in 

the alternative, seek statutory authority to apply rebates to the working capital fund. If 

statutory authority is not obtained, this redistribution should be applied retroactively to 

remedy prior years’ misapplications. 

Management’s Response. The Chief Financial Officer concurred, stating that her office

has prepared a legislative proposal to apply rebates to the working capital fund. In the 

meantime, NASA is implementing a revised process to more clearly return rebates to the 

appropriation that funded the activity.

 

7 Unlike NASA, the Department of the Interior has received specific authority to apply credit card rebates 

to its working capital fund. P.L. 106-291, Department of the Interior and Related Agencies 

Appropriations Act, 2001 (Sec. 113) states “Refunds or rebates received on an on-going basis from a 

credit card services provider under the Department of the Interior’s charge card programs, hereafter may 

be deposited to and retained without fiscal year limitation in the Departmental Working Capital Fund 

established under 43 U.S.C. 1467 and used to fund management initiatives of general benefit to the 

Department of the Interior’s bureaus and offices as determined by the Secretary or his designee.”

8 Government Accountability Office (GAO), “Principles of Federal Appropriations Law, Third Edition, 

Volume II,” February 2006 (GAO-06-382SP) describes the concept of augmentation as a Government 

agency using funds derived from an outside source to finance the operation of a program beyond the 

level established by appropriation, without congressional approval.
RESULTS

REPORT NO. IG-12-010 7 

Evaluation of Management’s Response. Management’s proposed actions are 

responsive to the intent of the recommendation. The recommendation is resolved and 

will be closed upon completion and verification of the proposed actions. 
RESULTS

8 REPORT NO. IG-12-010 

CONTROLS OVER THE TRAVEL CARD PROGRAM,

WHILE GENERALLY EFFECTIVE, COULD BE 

STRENGTHENED

We found that NASA’s internal controls relating to its travel card program are 

generally effective in detecting misuse, fraud, waste, and abuse by cardholders. 

However, we believe NASA could further strengthen the controls over its program 

by taking a series of actions. First, NASA does not perform periodic reviews of 

travel card accounts to ensure that the accounts of separated employees are closed. 

Second, the Agency does not evaluate the accounts of new and current employees to 

determine if those employees need a travel card. Allowing employees to maintain 

travel card accounts when they have separated from NASA or when the employee 

rarely or never needs to travel for official purposes unnecessarily increases the risk 

of fraud, abuse, or misuse of the cards. Finally, we found several instances of 

employees using travel cards for personal charges and believe that NASA should 

clarify its policy regarding the allowability of certain types of these charges. 

NASA’s Internal Controls for the Travel Card Program Are 

Generally Effective

We found that NASA was effectively monitoring travel card use and was reporting 

improper card use to the employee, the employee’s supervisor, or to the Center 

Coordinator when detected. We also found that NASA’s travel card policies and 

procedures are generally consistent with OMB guidance. Moreover, NASA mandates 

that all cardholders take training to ensure they fully understand their responsibilities. 

Additionally, we found that most NASA employees used their travel cards appropriately 

and paid their bills on time and that NASA was effectively monitoring payments and 

reminding employees when their accounts were past due. However, we identified several 

areas where internal controls over the travel card programs could be strengthened by 

more closely adhering to OMB guidance and implementing practices used by several 

NASA Centers. 

NASA Should Reduce the Number of Travel Cards Issued 

We found that an excessive number of NASA employees have travel cards but do not 

need them. We identified separated employees with active cards and current employees

who had never used their cards. In addition, we also found that JPMorgan routinely

reissues cards as they expire without an evaluation by NASA regarding actual usage. 

This occurred because NASA has not developed a policy or procedure to verify whether 

cardholders are current NASA employees or whether employees’ duties warrant having a 
RESULTS

REPORT NO. IG-12-010 9 

travel card. Additionally, NASA has not issued sufficient guidance to help supervisors 

determine whether employees need travel cards. Allowing employees to maintain travel 

card accounts they do not need unnecessarily increases the risk of card loss or theft, as 

well as fraud, abuse, and misuse of the cards. 

Separated Employees with Travel Cards. We found 28 travel cardholders at Goddard 

(12), Glenn (11), Langley (4), and Headquarters (1) who had separated from NASA but 

still had active travel cards. NASA’s exit procedures require that travel cards be returned 

to supervisors and that the relevant Coordinator be notified so the card can be cancelled. 

Although none of the cardholders we identified had used their card after their separation, 

allowing cards to remain active after individuals leave NASA’s employ increases the risk 

of fraud or misuse of the cards. Apart from its standard exit procedures, NASA has not 

developed an ongoing process across the Centers of comparing cardholder accounts to 

current employee rosters. However, Marshall and Johnson perform such reviews 

quarterly, and we noted no instances of active accounts for separated employees at those 

two Centers. 

Employees with Unactivated Cards. FTR section 301-51.2, exempts employees who 

travel 5 times or less per year from mandatory use of the Government travel charge card, 

although Agencies may issue cards to such employees at their discretion. As of 

August 23, 2011, we found 909 travel cards, or 5.5 percent of all NASA travel cards, had 

never been activated or had been activated but never used by the cardholder. In our 

judgment, this calls into question the cardholders’ need for these cards. We found that 

NASA employees generally obtained cards with little or no assessment by their 

supervisors of their immediate or future travel needs. Further, 842 of these unused cards 

were issued in 2008 when NASA transferred its travel card program from Bank of 

America to JPMorgan but did not evaluate cardholder needs to determine if reissuance 

was necessary. 

Many of the JPMorgan travel cards issued in 2008 are now expiring and new cards are 

once again being issued without consideration of prior use. NASA does not have an 

official policy recommending a minimum amount of travel required before issuance or 

reissuance of a travel card, nor does it require an evaluation of new employees or their 

positions to determine if a travel card should be issued. Despite the absence of policy, we 

found that Goddard is taking steps to limit the number of unnecessary cards. 

Specifically, Goddard’s Chief Financial Officer recommended that cardholders who had 

not traveled within the last 6 months consider cancelling or lowering the credit limit on 

their cards. 

NASA Should Clarify Internal Policy Regarding Travel Card Use 

and Implement Additional Controls 

FTR sections 301-51.6 and 301-51.7 provide that travel cardholders may use their 

Government travel cards only for expenses directly related to official travel and may not 
RESULTS

10 REPORT NO. IG-12-010 

use them to pay for personal expenses or for expenses not related to official Government 

travel. NASA has implemented various internal controls intended to prevent and detect 

noncompliance with this rule. For example, as a preventive measure, NASA restricts 

purchases from certain types of vendors, such as dating and escort services or casinos. 

All vendors that accept charge cards have a merchant category code. NASA provides 

JPMorgan a list of these codes and indicates by code the vendors at which employees 

may not make purchases. We found no instances of charges made to prohibited vendors. 

Similarly, we found NASA’s efforts to detect misuse were generally effective. Of the 

176 transactions we examined, we found only 9 instances of improper or questionable use 

that had not been detected by NASA. Specifically, we found a charge of $773 for 

personal travel; $63 to renew personal subscriptions to periodicals; $306 to pay for 

refreshments for an awards ceremony; and $114 to purchase snacks at a hotel gift shop. 

None of the cardholders sought reimbursement from NASA for these charges. 

However, we also found that NASA could make better use of reports that JPMorgan 

already provides to help identify improper use of travel cards. For example, JPMorgan’s

PaymentNet system generates a Cash Advance Report to help identify cash advances that 

are not related to Government travel. Although several NASA Centers consistently 

review this report, we found that others do not. 

Lack of Clarity in Policy. In addition to the four instances of clearly improper use 

described above, we identified five instances in which it was not clear whether particular 

charges were allowable. We were unable to determine the appropriateness of these 

charges because the FTR does not clearly prohibit certain types of expenses and NASA 

has not issued a supplemental policy to clarify the FTR. For example, NASA policy does 

not address use of a travel card to pay for in-room movies when staying at a hotel on 

official travel, the meals of others who are on official travel, or hotel expenses incurred 

for a personal stay that precedes an official business trip. We found that other Federal 

agencies have issued guidance to address these types of issues. For example, the 

Department of Justice permits employees to charge their Government travel cards for 

in-room movies or personal nights at a hotel that precede or follow an official 

Government trip. 

Recommendations, Management’s Response, and Evaluation of 

Management’s Response

We recommended that the Chief Financial Officer take the following actions: 

Recommendation 2. Increase efforts to obtain the cards and cancel the accounts of all 

individuals who separate from employment at NASA and conduct periodic reviews to 

ensure that such accounts have been cancelled. 
RESULTS

REPORT NO. IG-12-010 11

Management’s Response. The Chief Financial Officer concurred, stating that her office

has developed a Financial Management Operating Procedure (FMOP) that includes a 

process for reviewing accounts of separated employees on a monthly basis. The 

anticipated date of issuance of the FMOP is March 31, 2012. 

Evaluation of Management’s Response. Management’s proposed actions are 

responsive; therefore, the recommendation is resolved and will be closed upon 

completion and verification of the corrective actions. 

Recommendation 3. Implement a policy requiring a minimum amount of anticipated travel 

required before issuance or re-issuance of a travel card.

Management’s Response. The Chief Financial Officer concurred, stating that new 

guidance will be added as part of the new FMOP, with an anticipated issuance date of 

March 31, 2012. 

Evaluation of Management’s Response. Management’s planned action is responsive; 

therefore, the recommendation is resolved and will be closed upon completion and 

verification of the corrective action.

Recommendation 4. Require a quarterly review of travel card usage and recommend 

deactivating accounts or lowering the spending limits of underutilized cards. 

Management’s Response. The Chief Financial Officer concurred, stating that new 

guidance will be added as part of the new FMOP, with an anticipated issuance date of 

March 31, 2012. 

Evaluation of Management’s Response. Management’s planned action is responsive; 

therefore, the recommendation is resolved and will be closed upon completion and 

verification of the corrective action.

Recommendation 5. Remind cardholders and supervisors that travel cards are to be used 

for official Government travel-related expenses only and should not be used for personal 

expenses while on official travel. 

Management’s Response. The Chief Financial Officer concurred, stating that this

requirement is currently addressed in the mandatory training for new cardholders and in 

refresher training, every 3 years, for current cardholders. However, to further reinforce 

this requirement, the NASA Shared Services Center updated both the Travel and Travel 

Card Customer websites with a reminder that travel cards are to be only used for official 

Government travel-related expenses.

Evaluation of Management’s Response. The recommendation is resolved and closed 

based on verification of management’s corrective action.
RESULTS

12 REPORT NO. IG-12-010 

Recommendation 6. Enhance controls to identify misuse of the travel card, such as 

developing a data-mining tool to identify suspicious activity or patterns of abuse or misuse of 

travel cards to complement the tools available from JPMorgan. 

Management’s Response. The Chief Financial Officer concurred, stating that new 

guidance will be added as part of the new FMOP, with an anticipated issuance date of 

March 31, 2012. 

Evaluation of Management’s Response. Management’s planned action is responsive; 

therefore, the recommendation is resolved and will be closed upon completion and 

verification of the corrective action. 

Recommendation 7. Develop guidance to address when personal use of the travel card may 

be acceptable, such as to purchase in-room movies while on official Government travel.

Management’s Response. The Chief Financial Officer concurred, stating that her office

will develop and issue appropriate guidance by March 31, 2012. 

Evaluation of Management’s Response. Management’s planned action is responsive; 

therefore, the recommendation is resolved and will be closed upon completion and 

verification of the corrective action. 
RESULTS

REPORT NO. IG-12-010 13

NASA’S POLICY AND PRACTICES REGARDING 

SELF-APPROVAL AND SELF-AUTHORIZATION 

OF TRAVEL ARE OVERLY BROAD

An inordinate number of NASA employees have authority to both authorize their 

official Government travel and approve the associated expenses for reimbursement. 

Specifically, we found that the travel authorizations and expenses for 45 NASA 

employees were not required to be reviewed or approved by a supervisor or 

approving official. These 45 individuals incurred more than a half million dollars in 

travel card expenses between October 1, 2009 and December 31, 2010. We also 

found that NASA had incorrectly applied its policy regarding which employees may 

self-authorize travel and self-approve expenses, and that subordinate employees were 

approving the travel expenses of five Center Directors. Finally, NASA’s policy 

designating which positions can self-authorize and self-approve travel is out of date 

and refers to positions that no longer exist at the Agency. Each of these conditions 

increases the risk of fraud and abuse in NASA’s travel card program. 

Excessive Number of Individuals Have Authority to Both SelfAuthorize Travel and Self-Approve Expenses 

NASA employees use FedTraveler to obtain authorization to undertake official travel and 

to gain approval for reimbursement of their expenses upon return to their duty stations. 

For most employees, there are four steps to the authorization process: 

1. Traveler submits travel authorization through FedTraveler.com, including 

estimated expenses. 

2. Fund Certifier reviews the authorization to ensure that the funds to pay for the 

travel are available. 

3. Supervisor reviews the authorization and, if he or she finds the travel allowable 

and the costs reasonable, authorizes the employee to travel. 

4. Travel Office completes final review for compliance with travel regulations. 

When an employee is designated as a self-authorizer, the supervisor approval step is 

eliminated. 

When an employee returns from official travel, a similar process is followed to secure 

reimbursement for the employee’s expenses: 

1. Traveler submits the claim with receipts. 
RESULTS

14 REPORT NO. IG-12-010 

2. Fund Certifier reviews the claim to ensure that funds are available. 

3. Supervisor reviews the claim and receipts and, assuming no issues are identified, 

approves the claim. 

4. NSSC completes payment processing. 

Once again, if the traveler is designated as a self-approver, the supervisory review step is 

not performed. 

We found that NASA permits an inordinate number of employees to both self-authorize 

travel and self-approve their travel expenses. NASA Policy Directive (NPD) 9710.1V 

designates more than 34 positions, including the Administrator, the Deputy Administrator, 

the Chief Financial Officer, Officials-in-Charge of Headquarters Offices, and Center 

Directors as both self-authorizers and self-approvers. Moreover, when we reviewed 

FedTraveler records, we found even more individuals had this authority than those 

identified in the policy. Specifically, we identified 42 active and 3 retired employees 

whose FedTraveler profiles allowed them to both authorize and approve their own travel, 

including several Associate and Assistant Administrators at Headquarters and office 

chiefs at Marshall Space Flight Center.

9

We compared NASA’s policy to policies at several Federal agencies and found NASA to 

be significantly more expansive. For example, out of more than 116,000 employees at 

the Department of Justice (approximately six times the number of NASA employee s), 

only the Agency’s Inspector General and individuals appointed as Independent Counsel 

have the authority to approve their own travel vouchers.

 Between October 1, 2009, and December 31, 

2010, these 42 active employees charged to their travel cards and were reimbursed 

approximately $552,000 – all with no review from a higher-level official. In addition, 

these employees incurred charges for airline or rail tickets billed to a central NASA 

account that similarly did not receive supervisory review. 

10

Moreover, according to NPD 9710.1V, 22 of the 45 individuals who were permitted to 

both self-authorize and self-approve (17 from Marshall and 5 from Headquarters) should 

have been designated in FedTraveler only as self-authorizers. Officials from the NASA 

Enterprise Application Competency Center (NEACC), which manages access to 

FedTraveler, told us that they have the ability to set the system so that employees have 

the ability to self-authorize but must obtain supervisory review of their expenses. 

 Also, no positions at the 

Department of Veterans Affairs have the authority to authorize or approve their own 

travel or travel expenses. 

 

9

 None of the former employees had used their cards since leaving the Agency and NASA reported that 

their access to FedTraveler.com had been disabled.

10 The number of cardholders at the Department of Justice as of December 31, 2010, as obtained from the 

General Services Administration (GSA) Smartpay Program Statistics. The Attorney General’s travel 

vouchers are reviewed and approved by the Deputy Attorney General or the Attorney General’s Chief of 

Staff. 
RESULTS

REPORT NO. IG-12-010 15

However, they said that Marshall and Headquarters failed to inform them that these 22 

employees should be designated only as self-authorizers. 

Finally, NPD 9710.1V, section 1, requires that travel be authorized and approved by an 

official at least one organizational level above the traveler and prohibits subordinates 

from authorizing or approving the travel of their supervisors.11 However, there is no 

automated method for preventing subordinates from authorizing or approving superiors’ 

travel claims in FedTraveler. Rather, NEACC relies on the NASA Centers to designate 

appropriate approving officials for employees.12

NASA’s current practice of allowing an inordinate number of employees to both 

authorize and approve their own travel increases the risk that NASA travel cards will be 

misused or abused. While NASA has some compensating controls in place, in our 

judgment these controls do not adequately substitute for supervisory review. For 

example, NASA officials pointed to the fact that a Funds Certifier reviews all travel 

authorizations and approvals. However, the Funds Certifier’s primary responsibility is to 

ensure that funds are available, not determine whether the travel is appropriate or 

warranted. In addition, Fund Certifiers are subordinates of the individuals with selfauthorization and self-approval authority and therefore may be hesitant to question their 

supervisor’s travel claims. 

 

NASA officials also noted that NSSC regularly audits all international travel claims and a 

sample of domestic travel claims. However, no audits or other procedures specific to 

self-approved or self-authorized travel are performed, and NASA does not consider 

whether travel has been self-authorized or self-approved when choosing audit samples for 

domestic travel claims. 

Out of Date Policies. NPD 9710.1V designates the positions at NASA that can authorize 

and approve their own travel including the Administrator, the Deputy Administrator, the 

Chief Financial Officer, Officials-in-Charge of Headquarters Offices, and Center 

Directors. According to NPD 1000.3D, “The NASA Organization w/Change 24,” 

paragraph 1.2.2, July 21, 2011, 24 positions are identified as “Officials-in-Charge.” In 

contrast, as of March 22, 2011, the NASA Headquarters Executive Secretariat website

listed 35 positions as Officials-in Charge, excluding the Administrator, the Deputy 

Administrator, the Chief Financial Officer, and the Center Directors. Additionally, 

several positions listed in NPD 1000.3, such as the Director of Program and Institutional 

Integration, no longer exist at NASA because of Agency reorganizations over the last 

several years. 

 

11 We found that in an attempt to avoid an appearance of impropriety, five Center Directors had assigned 

subordinates to authorize and approve their travel expenses. However, we found a significant variation 

in the positions assigned this responsibility, ranging from Senior Executive Service employees (such as a 

Center Chief Financial Officer and Special Assistant to the Center Director) to lower-graded employees 

such as a GS-13 Budget Analyst or Lead Accountant.

12 During the course of the audit, we found isolated instances of OIG employees approving the travel of 

supervisors or employees of equivalent rank. The OIG has taken steps to ensure that only supervisors 

approve travel claims. 
RESULTS

16 REPORT NO. IG-12-010 

Recommendations, Management’s Response, and Evaluation of 

Management’s Response

In order to decrease the risk of misuse of NASA travel cards, we recommended that the 

Chief Financial Officer take the following actions: 

Recommendation 8. Revise NPD 9710.1V to decrease the number of or eliminate entirely 

positions designated as “self-authorizers” for Government travel. To avoid confusion, 

NASA should identify the specific positions with this authority rather than referring to 

generic groups, such as “Heads of Center Mission Support Offices.” 

Management’s Response. The Chief Financial Officer concurred, stating that her office

will revise, vet, and publish for Agency review in NASA’s policy document management 

system a revised draft NPD 9710 by May 31, 2012, with a target date for an approved 

NPD of September 30, 2012. 

Evaluation of Management’s Response. Management’s planned action is responsive; 

therefore, the recommendation is resolved and will be closed upon completion and 

verification of the corrective action. 

Recommendation 9. Revise NPD 9710.1V to significantly decrease the number of 

positions designated as “self-approvers” for Government travel reimbursement. As part of 

this effort, the Agency should consider adopting a policy that requires travel expenses of all 

NASA employees with the exception of the Administrator and the Inspector General to 

undergo supervisory review before they are reimbursed. In addition, to avoid confusion the 

Agency should identify the specific positions with this authority rather than referring to the 

generic group “Officials-in-Charge.” 

Management’s Response. The Chief Financial Officer concurred with significantly 

decreasing the number of positions designated as “self-approvers.” However, NASA 

disagrees that group designations like “Officials-in-Charge” are so generic as to be 

confusing, as this term is precisely defined in NPD 1000.3, Section 1.2.2. When 

reviewing which positions should no longer be self-approvers, NASA will consider 

alternative terms or role descriptions that minimize any confusion and will also consider 

alternatives for supervisory review up to and including limiting self-approval to the 

Administrator and the Inspector General. The Office of the Chief Financial Officer will 

revise, vet, and publish for Agency review a revised draft NPD 9710 by May 31, 2012, 

with a target date for an approved NPD of September 31, 2012. 

Evaluation of Management’s Response. Management’s planned action is responsive to 

the intent of our recommendation. Therefore, the recommendation is resolved and will 

be closed upon completion and verification of the corrective action.
RESULTS

REPORT NO. IG-12-010 17

Recommendation 10. Ensure that roles in FedTraveler accurately reflect employees’ level 

of approval authority, for example, employees designated to only self-authorize travel 

requests should not also have the ability to self-approve travel claims. 

Management’s Response. The Chief Financial Officer concurred, stating that her office

and the NEACC will jointly lead an Agency review of roles to verify that only employees 

authorized by NPD 9710 as self-authorizers and/or self-approvers hold those roles in 

FedTraveler. The review will commence by May 31, 2012, with a target completion date 

of June 30, 2012. 

Evaluation of Management’s Response. Management’s planned action is responsive; 

therefore, the recommendation is resolved and will be closed upon completion and 

verification of the corrective action.

Recommendation 11. Develop a process to ensure enforcement or monitoring compliance 

with the policy that subordinates may not approve superiors’ travel expenses. 

Management’s Response. The Chief Financial Officer concurred, stating that her office, 

the NSSC, and the NEACC will jointly develop a process for monitoring compliance 

with the revised policy to coincide with the effective date of the revised NPD 9710. 

Evaluation of Management’s Response. Management’s planned action is responsive; 

therefore, the recommendation is resolved and will be closed upon completion and 

verification of the corrective action.

Recommendation 12. Perform an annual risk assessment by type of expense report (e.g., 

self-approved, conference-related, foreign travel) and increase the frequency of audits of 

expense reports submitted by self-approvers. 

Management’s Response. The Chief Financial Officer concurred, stating that her office

will develop an annual risk-assessment process and increase the frequency of audits of 

expense reports as necessary. The risk-assessment process will be developed by May 31, 

2012. 

Evaluation of Management’s Response. Management’s planned actions are

responsive; therefore, the recommendation is resolved and will be closed upon 

completion and verification of the corrective actions. 
RESULTS

18 REPORT NO. IG-12-010 

CONTROLS OVER THE PURCHASE CARD PROGRAM, WHILE GENERALLY EFFECTIVE, COULD BE 

STRENGTHENED

Overall, we found that NASA’s purchase card program was operating efficiently and 

internal controls appeared effective in detecting misuse, fraud, waste, and abuse by 

cardholders. However, we found several areas that could be strengthened. 

Specifically, NASA has an excessive number of underutilized purchase cards and 

does not require sufficient documentation for purchase requests, costs, and 

approvals. We found 110 cardholders had not used their cards or used their cards 

only one time during our audit period of October 1, 2009, to December 31, 2010. 

Additionally, NASA does not have effective internal controls for reviewing purchase 

card accounts to determine continuing need for the card. We also found transaction 

records often did not include information regarding who requested the purchases or 

evidence of the cost of the items purchased or approval of the purchases. Both of 

these conditions increase the risk of misuse, fraud, waste, or abuse of NASA 

purchase cards. 

NASA’s Internal Controls for the Purchase Card Program Are 

Generally Effective

We found that NASA was effectively monitoring purchase card use. We also found that 

NASA’s purchase card policies and procedures are generally consistent with OMB

guidance. Additionally, we found that NASA employees generally used their purchase 

cards appropriately and retained appropriate documentation supporting their purchases. 

Moreover, NASA mandates and cardholders participated in training about their 

responsibilities under the program. However, we identified several areas where internal 

controls over the purchase card programs could be strengthened by better adhering to 

OMB guidance and implementing practices used by several NASA Centers. 

NASA Should Reduce the Number of Purchase Cards Issued

We found that 110 purchase cardholders had never used their cards or had only used their 

cards once during our 15-month audit period. Specifically, 20 cardholders at Ames had 

never used their cards and 90 others located throughout NASA had used their cards only 

once. We considered these cards to be underutilized. 
RESULTS

REPORT NO. IG-12-010 19

Many Purchase Card Coordinators reported performing a regular review of cardholder 

accounts. However, we found that these reviews did not identify underutilized purchase 

cards. Based on our inquiries, NASA officials closed 27 of the 110 accounts we 

identified. NASA supervisors decided that the remaining cards were necessary in order 

to maintain a backup purchaser, for emergency use as part of the NASA Continuity of 

Operations Planning, and based on an expectation that usage was anticipated to increase

in the future.13

NASA Should Improve the Documentation and Approval Trail for 

Purchases

 

NASA has not developed sufficient policies and controls governing documentation of 

purchase card purchases and approvals. Specifically, we found instances where the 

individual requesting and/or approving the purchase could not be identified and where 

transaction files contained no evidence of the cost of purchases. 

Transaction Records Do Not Identify the Requestor. OMB Circular A-123, Appendix 

B, section 4.7, states: “To the maximum extent possible, agency personnel requesting a 

cardholder to acquire an item(s) with a purchase card should provide written requests to 

the purchase cardholder for the items.14

 

13 NASA Continuity of Operations Planning teams are responsible for ensuring that the Agency is prepared 

to maintain the operation of its critical mission essential functions or implement transfer of critical 

mission essential functions to alternate locations in the event of emergencies and disastrous events 

resulting in long-term disruptions of normal operations.

 If it is not possible for the requester to make the 

request in writing, the purchase cardholder should document in their file the requester’s 

name . . . and obtain prior approval before making self-generated purchases.” However, 

39 of the 203 purchase card transaction records we examined did not contain written 

requests from or otherwise identify the individual requesting the purchase. Additionally, 

14 OMB Circular A-123, Appendix B, incorrectly labeled two sections as 4.8 and no section as 4.7. The 

reference in this report is to the first section 4.8 that should have been labeled 4.7.

Goddard 

Space Flight 

Center, 16

Kennedy 

Space Center, 

8 

Ames 

Research 

Other NASA Center, 31

Locations, 11

Glenn 

Research 

Center, 7

Marshall 

Space Flight 

Center , 11

Langley 

Research 

Center, 26

Figure 1. Underutilized Purchase Cards by Location
RESULTS

20 REPORT NO. IG-12-010 

written requests to cardholders to make purchases were not maintained in the purchase 

card transaction records.15 Figure 2 shows the number of transaction records that did not 

identify the purchase requestor by Center. 

Of the 39 transaction records that did not contain information related to the requestor, we 

noted that 14 of those transactions were self-generated purchases in which prior approval 

by a supervisor was not obtained. These transactions were at the following Centers: 

Ames (2), Glenn (2), Goddard (9), and Marshall (1). NASA does not have a policy that 

requires prior approval for self-generated purchases and this omission increases the risk 

that inappropriate purchases may go undetected.

Insufficient Audit Trail for Approval of Purchase Reconciliations. We sampled 97 

transactions and found that 75 had inconclusive evidence of who approved the 

reconciliation of the transactions. NASA uses P-Card Web Solution to track the 

electronic approval of purchase card reconciliations. An approving officer can delegate 

their electronic approval authority within P-Card Web Solution to a third party. 

However, when designees review reconciliations, P-Card Web Solution records the user 

identification code of the approving official and not the designee. 

OMB Circular A-123, Part I, Introduction, section A, “Agency Implementation,” states: 

“management should have a clear, organized strategy with well-defined documentation 

processes that contain an audit trail, verifiable results, and specify document retention 

periods so that someone not connected with the procedures can understand the 

assessment process.” For the 97 transactions we examined, we tried to obtain proof of 

who approved the reconciliations (i.e., paper approval), but for 75 of the 97 transactions 

we found no alternative proof of the party completing approval of the reconciliations. 

Moreover, the system does not allow a user to authenticate who approved the 

reconciliation electronically (see Figure 3). Approving officials are only required to 

 

15 Although we were not provided written requests for some transactions, we had sufficient evidence to 

determine that the purchases were for official Government purposes. We assessed the appropriateness of 

these transactions by reviewing the item description and details and making inquiries regarding specific 

purchases. 

Glenn Research 

Center, 8

Marshall Space 

Flight Center, 3

Goddard Space 

Flight Center, 13

Other NASA 

Locations, 4

Johnson Space 

Flight Center, 3

Ames Research 

Center, 8

Figure 2. Number of Transaction Records that Did Not Identify the Requestor, 

by Center 
RESULTS

REPORT NO. IG-12-010 21

approve a reconciliation electronically in P-Card Web Solution per NASA FAR 

Supplement 1813.301. Some approving officials also physically sign the reconciliation

but this is not a required or consistent practice at NASA. 

NASA employees are not properly documenting the approval of reconciliations because 

NASA has inappropriately relied upon P-Card Web Solution to document who approved 

a transaction, and P-Card Web Solution software functionality does not accurately track 

this information when the responsibility has been delegated to a third party. 

Transaction Records Do Not Consistently Include Evidence of the Cost. We noted 

that the vendor invoice or other form of supporting documentation that validates the cost 

of items purchased was not received from the vendor and maintained in the purchase card 

transaction records for 10 of the 203 transactions we examined. NASA’s policy does not 

require the purchase cardholder to obtain an invoice or alternative evidence of costs such 

as a quote or a screen print for Internet purchases if one is not already provided by the 

vendor. 

Given this lack of cost documentation, NASA has not developed sufficient policies to 

meet minimum standards for requiring documentation for card purchases as required by 

OMB Circular A-123, Appendix B. Additionally, NASA inappropriately relied upon 

P-Card Web Solution to document the approval of transaction reconciliations. 

Insufficient approval or documented records to support purchase expenditures leads to an 

increased risk of misuse, fraud, waste, and abuse. By making greater use of 

recommended controls from OMB Circular No. A-123, Appendix B, and practices used 

at several NASA Centers, NASA could reduce the risk of misuse, fraud, waste, and abuse 

by purchase cardholders. 

5 

4 

13

11

12

7 

9 9 

4 

1 

0 

2 

4 

6 

8 

10

12

14

Ames Research 

Center

Dryden Flight 

Research Center

Glenn Research 

Center

Goddard Space 

Flight Center

Johnson Space 

Center

Kennedy Space 

Center

Langley Research 

Center 

Marshall Space 

Flight Center 

NASA Shared 

Service Center

Wallops Flight 

Facility

Figure 3. Number of Reconciliations without Identified Approver,

by Location 
RESULTS

22 REPORT NO. IG-12-010 

Recommendations, Management’s Response, and Evaluation of 

Management’s Response

We recommended that the Assistant Administrator for Procurement take the following 

actions: 

Recommendation 13. Develop a policy requiring a clear necessity for or a minimum 

amount of purchases before issuance or re-issuance of a purchase card. The policy should 

include that continued non-usage could result in a reduction of the credit limit or 

cancellation of the card.

Management’s Response. The Assistant Administrator for Procurement did not concur, 

stating that the requirement for conducting a transaction volume analysis is already 

contained in the NASA Federal Acquisition Regulation Supplement and the Internal 

Review Guide for Center/Agency Program Coordinators and hence additional policy is 

not required. However, NASA plans to send an e-mail to all cardholders, Coordinators, 

and approving officials reminding them of this requirement along with links to the 

guidance by March 1, 2012. 

Evaluation of Management’s Response. We consider management’s comments to be 

unresponsive and believe they do not adequately address the concerns that prompted our 

recommendation. While the current policy requires that a transaction volume analysis be 

conducted every 6 months, we found that this analysis was not effectively performed, 

which resulted in a high number of underutilized cards being active. Additionally, the 

existing policies are not specific or clear in defining the need or prerequisite criteria for a 

card to be issued, such as a required minimum usage or planned usage prior to issuance 

of a purchase card. Accordingly, we consider this recommendation unresolved. 

Recommendation 14. Work with the NASA Enterprise Applications Competency Center to 

make systems changes to P-Card Web Solution to enable the software to document the user 

identification code of the approving party and work with the Purchase Card Coordinator to 

develop an alternative documentation process of approvals until systems changes are made. 

Management’s Response. The Assistant Administrator for Procurement concurred, 

stating that approving officials will be required to document their names in the P-Card 

transaction comments field when they serve as an alternate and approve transactions on 

behalf of another approving official. By September 30, 2012, NASA will review the 

feasibility of making software code changes to the P-Card system.

Evaluation of Management’s Response. Management’s planned actions are

responsive; therefore, the recommendation is resolved and will be closed upon 

completion and verification of the corrective actions. 
RESULTS

REPORT NO. IG-12-010 23

Recommendation 15. Develop policies that require the purchase cardholder to: 

• include a written request for purchases or, at a minimum, the requestor’s name in 

the purchase card transaction records; 

• obtain approval prior to making self-generated purchases and include evidence of 

the approval in the log; and 

• obtain an invoice or alternative evidence of costs such as a quote or a screen print 

for Internet purchases if one is not already provided by the vendor. 

Management’s Response. The Assistant Administrator for Procurement did not concur, 

stating that NASA already has a policy in place to address these issues and that 

cardholders are trained to enter information related to special approvals in the P-Card 

order log comments field. The Assistant Administrator indicated that NASA’s Agency 

Program Coordinator will send an e-mail to all cardholders, Coordinators, and approving 

officials reminding them of this requirement along with links to the guidance by March 1, 

2012. 

Evaluation of Management’s Response. We consider management’s comments to be 

unresponsive, as they do not adequately address the concerns that prompted our 

recommendation. While the current policy requires cardholders to record information 

regarding items ordered, it does not specifically require inclusion of the requestor’s name. 

We believe that in the absence of such a requirement, cardholders will continue to omit

this information. Similarly, while cardholders may be trained to enter information related 

to special approvals in their order logs, we found no evidence that they are required to 

obtain and document evidence of approval for self-generated purchases. Finally, 

although we agree that current policy requires cardholders to include an invoice when the 

merchant provides one, the policy does not specify what evidence of cost is required

when an invoice is not provided. Accordingly, we consider these recommendations 

unresolved. 

APPENDIXES

REPORT NO. IG-12-010 25

APPENDIX A 

Scope and Methodology

We performed this audit from January 2011 through January 2012 in accordance with 

generally accepted government auditing standards. Those standards require that we plan 

and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and conclusions based on 

our audit objectives. 

Our objective was to determine whether the purchase and travel card programs were 

operating efficiently and internal controls were effective to help detect misuse, fraud, 

waste, or abuse by cardholders or others who attempt to manipulate the programs, and 

were operating in compliance with certain laws and regulations. We also examined a 

travel-related issue concerning employees who can self-authorize and self-approve travel 

and travel related-expenses. We identified and reviewed relevant Federal laws and 

regulations, NASA policies, procedures, plans, and guidance, and other criteria (see 

detailed list of items reviewed below). 

We conducted site visits at NASA Headquarters in Washington, D.C., NASA Shared 

Services Center in Mississippi, Goddard Space Flight Center in Maryland, Kennedy 

Space Center in Florida, and Marshall Space Flight Center in Alabama. During our 

fieldwork, we interviewed officials responsible for purchase and travel card programs to 

obtain an understanding of the process for issuing new cards, ensuring training of 

employees, monitoring of purchase and travel cardholders activities, the payment 

process, and the review and approval of purchase card transactions, travel authorizations, 

and travel claims. Further, we reviewed the training of 45 randomly selected individuals 

issued purchase and travel cards to ensure compliance with NASA training policies and 

procedures. 

In order to meet our primary objectives for this audit, we interviewed officials from each 

of the NASA Centers we visited. We also examined documentation and performed the 

following tasks among others: 

• reviewed copies of NASA policies, procedures, presentations, and trainings 

related NASA purchase and travel card programs to ensure that proper internal 

controls are documented;

• reviewed copies of JPMorgan reports on NASA purchase and travel card 

activities to determine whether any questionable charges had been made and 

identified by management;
APPENDIX A 

26 REPORT NO. IG-12-010 

• reviewed an electronic database from JPMorgan of NASA purchase and travel 

card accounts to determine the number of cardholders and review activity; 

• selected a statistical sample of purchase and travel card transactions and selected a 

sample of transactions via data mining procedures (See Appendix B for our 

sampling methodology);

• tested the controls over a statistical sample of purchase and travel card 

transactions (see the section titled “Review of Internal Controls” below for 

additional information); 

• tested the statistical and data mining samples to determine if the transactions were 

supported, approved, and an appropriate use of the Government purchase and 

travel card; 

• compared a list of all active cardholders to a list of terminated employees to 

ensure that their purchase and travel cards were cancelled; 

• reviewed activity of cardholders to determine if purchase and travel cards were 

actively used; and

• examined processes to self-authorize and approve travel transactions. 

Use of Computer-Processed Data. We obtained our data of purchase and travel card 

transactions from JPMorgan PaymentNet® (PaymentNet) and attempted to reconcile the 

data; however, we were unable to assess the overall completeness and reliability of 

purchase and travel card data from PaymentNet due to data limitations in 

FedTraveler.com and NASA’s financial management system, SAP. We did verify the 

accuracy of this data by tracing a sample of the transactions to source documents and a 

sample of source documents to transactions in PaymentNet. Although we were able to 

utilize PaymentNet to corroborate individual transactions and verify related payment 

information, we considered the data contained in SAP and PaymentNet to be of 

undetermined reliability in terms of completeness and accuracy. However, we concluded 

that the data was reliable for our purposes and did not weaken our analysis or lead us to 

an incorrect message. 

Review of Internal Controls 

We reviewed internal controls for the purchase and travel card programs. Any control 

weaknesses we identified are discussed in this report. Our recommendations, if 

implemented effectively, should correct the identified control weaknesses. 

Purchase Card. Our audit of key internal controls focused on whether NASA provided 

adequate documentation to substantiate that purchase card transactions appeared to be for 

official Government use, were properly authorized and supported, and goods and services 
APPENDIX A 

REPORT NO. IG-12-010 27

acquired with purchase cards were independently received and accepted. Furthermore, 

for purchases exceeding the micropurchase threshold of $3,000, we tested Federal 

Acquisition Regulation requirements that the cardholder use required vendors and 

promote competition by soliciting bids—or justify the departure from this requirement in 

writing. 

Travel Card. Our audit of key internal controls focused on whether NASA provided 

adequate documentation to substantiate that travel card transactions appeared to be for 

official Government travel, were properly supported, were for reasonable costs, and the 

related bill was paid on time. 

Federal Laws, Regulations, Policies, and Guidance

As part of our tests of internal controls, we reviewed applicable federal laws and 

regulations related to purchase and travel card uses. We also examined certain common 

problems identified in Council of Inspectors General on Integrity and Efficiency’s “A 

Practical Guide for Reviewing Government Purchase Card Programs” and “Review of 

Common Problems and Best Practices in Federal Agencies’ Travel Card Programs” and 

GAO’s “Audit Guide – Auditing and Investigating the Internal Control of Government 

Purchase Card Programs.” Additionally we reviewed NASA purchase and travel card 

policies and procedures. This review included, but was not limited to, the following:

Laws and Regulations 

Public Law 105–264, “Travel and Transportation Reform Act of 1998,” October 19, 

1998 

Circular No. A-123, Appendix B Revised, “Improving the Management of Government 

Charge Card Programs,” January 15, 2009 

Treasury Financial Manual Volume 1 Part 4 Chapter 4500 Government Purchase Cards 

Federal Acquisition Regulation 48 C.F.R. Part 13 

“Principles of Federal Appropriations Law” (The Red Book), Third Edition, Volume II, 

Page 6-162 (GAO-06-382SP, February 2006) 

The Simplified Acquisition Procedures Part 1813 

NASA Policy and Procedures

NPD 9070.2, “Government Charge Cards,” November 5, 2008 

NPD 9710.1V, “Delegation of Authority - To Authorize or Approve Temporary Duty 

Travel on Official Business and Related Matters,” December 9, 2009

NPR 9700.1, “Appendix A. NASA Federal Travel Regulations Supplement,” 

September 30, 2008 
APPENDIX A 

28 REPORT NO. IG-12-010 

NASA Procurement Information Circular 10-14, “Special Approvals for Purchase Card 

Transactions,” October 13, 2010 

Documents and Presentations

NASA Charge Card Management Plan, February 13, 2008 

Draft NASA Government wide Commercial Purchase Card Management Plan

NASA HQ Presents Essential Training about the Government Travel Card 

Prior Coverage

During the last 5 years, the NASA Office of Inspector General, the Government 

Accountability Office (GAO), and the Treasury Inspector General for Tax Administration 

have issued five reports of particular relevance to the subject of this report. 

NASA Office of Inspector General

“Internal Controls to Detect and Prevent Unauthorized and Potentially Fraudulent 

Purchase Card Transactions at Four NASA Centers Needed Improvement” (IG-07-012, 

March 29, 2007) 

Government Accountability Office

“GAO Travel Cards - Opportunities Exist to Further Strengthen Controls” (GAO\OIG11-1, December 7, 2010) 

“Government-wide Purchase Cards - Actions Needed to Strengthen Internal Controls to 

Reduce Fraudulent, Improper, and Abusive Purchases” (GAO-08-333, March 14, 2008) 

Treasury Inspector General for Tax Administration 

“Although Citibank Travel Rebates Have Significantly Increased, They Were Not 

Properly Allocated, Resulting in the Misappropriation of Funds” (2010-10-124, 

September 24, 2010) 

“Controls Over the Purchase Card Program Were Not Effective in Ensuring Appropriate 

Use” (2011-10-075, August 31, 2011)
APPENDIX B 

REPORT NO. IG-12-010 29

SAMPLING METHODOLOGY

For our audit, we used both statistical sampling and data mining sampling techniques to 

select our samples. To obtain our statistical sample, our methodology was attribute 

sampling by random selection. For our data mining sample, we used a nonstatistical 

sampling method known as judgmental sampling based upon multiple indicators of 

suspicious or inappropriate activity. We obtained access to the database containing 

purchase and travel card transactions for the 15-month audit period of October 1, 2009, to 

December 31, 2010, from JPMorgan. This database included transactions Agency-wide. 

Each of the following sites was subject to examination during the audit: 

• NASA Headquarters

• Ames Research Center

• Dryden Flight Research Center

• Glenn Research Center

• Goddard Space Flight Center 

• Johnson Space Center

• Kennedy Space Center

• Langley Research Center

• Marshall Space Flight Center

• NASA Shared Services Center

• Stennis Space Center 

• Wallops Flight Facility

Statistical Samples. We extracted three statistical (probability) samples of 97 purchase 

cards transactions, 97 travel cards transactions billed to individual cardholders (IBA), and 

59 travel card transactions centrally-billed (CBA) to NASA from our database of 

purchase and travel card transactions. 

Purchase Card Sample. The purchase card transaction universe was 146,929 

transactions valued at $96.6 million. We used Winstats (Ver. 1.0) to determine our 

sample size using a 90 percent confidence level, 10 percent estimated attribute error rate, 
APPENDIX B 

30 REPORT NO. IG-12-010 

and 5 percent desired precision rate or sampling error. We used EZ-Quant (Ver. 1.1.1) to 

randomly select our sample of 97 transactions. Based on our testwork, no projection of 

errors was necessary.

Travel Card IBA Sample. The travel card IBA transaction universe was 364,191 

transactions valued at $46.5 million. We used Winstats to determine our sample size 

using a 90 percent confidence level, 10 percent estimated attribute error rate, and 5 

percent desired precision rate or sampling error. We used EZ-Quant to randomly select 

97 transactions. Based on our testwork, the projection for errors was not significant to be 

included in this audit report. 

Travel Card CBA Sample. The travel card CBA transaction universe size was 288,532 

transactions valued at $48.9 million. We used Winstats to determine our sample size 

using an 80 percent confidence level, 10 percent estimated attribute error rate, and 5 

percent desired precision rate or sampling error. We used EZ-Quant to randomly select 

59 transactions. Based on our testwork, no projection of errors was necessary. 

Samples Selected Using Data Mining Techniques. Data mining was also conducted to 

identify high-risk transactions. We used the same database containing purchase and 

travel card transactions for the 15-month audit period of October 1, 2009, to 

December 31, 2010, from JPMorgan that used for the statistical samples. 

Purchase Card Sample. We analyzed purchase card data looking for higher risk 

transactions by examining the merchant category codes and vendor names that were more 

likely to offer goods, services, or both that are on NASA restricted/prohibited lists, 

personal in nature, of questionable Government need, or purchased with convenience 

checks or large dollar purchases. We identified over 58,000 transactions that were higher 

risk and selected 106 transactions for examination. 

Travel Card Sample. We analyzed all travel card data, for both CBA and IBA, looking 

for higher risk transactions by examining the merchant category codes and vendor names 

that were more likely to offer goods, services, or both that are inappropriate for 

Government travel expense, personal in nature, or were cash advances. We identified 

over 50,000 transactions that were higher risk and selected 79 transactions for 

examination.

We requested and reviewed supporting documentation for 106 purchase card transactions 

and 79 travel card transactions. We conducted additional inquiries and data analysis, 

when applicable. Our work was not designed to identify and we cannot determine the 

extent of fraudulent, improper, or abusive transactions occurring in the population of 

purchase card transaction. The results of our testwork included some errors over these 

transactions. Details are included within this audit report. 
APPENDIX C 

REPORT NO. IG-12-010 31

CARD ACCOUNT STATUS AND 

TRANSACTION DATA BY 

NASA LOCATION

Table 2 shows current card account status for travel and purchase cards held by NASA 

Headquarters and Centers staff, prepared from JPMorgan reports as of December 31, 

2010. 

Table 2: Number of Active NASA Purchase and Travel Card Accounts,

as of December 31, 2010

Location

Travel Card 

Accounts

Purchase Card 

Accounts

Total Active 

Card

Accounts 

Ames Research Center 1,003 266 1,269 

Dryden Flight Research Center 520 41 561

Glenn Research Center 1,505 289 1,794 

Goddard Space Flight Center 2,411 551 2,962

Headquarters 1,182 75 1,257 

Johnson Space Center 2,893 221 3,114

Kennedy Space Center 1,813 91 1,904 

Langley Research Center 1,605 348 1,953

Marshall Space Flight Center 2,144 266 2,410 

NASA Shared Services Center 126 17 143

Stennis Space Center 258 23 281 

Wallops Flight Facility 2 52 54

 Total 15,462 2,240 17,702

Source: JPMorgan data.
APPENDIX C 

32 REPORT NO. IG-12-010 

Table 3 shows the dollar amount and number of travel and purchase card transactions that 

occurred between October 1, 2009, and December 31, 2010 for NASA cardholders, per 

JPMorgan reports. We separated the accounts by location for improved analysis. 

Table 3: NASA Purchase and Travel Card Transactions

October 1, 2009 through December 31, 2010

 Transaction Amount

Number of 

Transactions 

Location

Travel 

Card

Purchase 

Card Total 

Travel 

Card

Purchase 

Card Total 

Ames Research Center $7,360,946 $11,887,755 $19,248,701 47,587 20,932 68,519

Dryden Flight Research Center 3,224,399 3,888,570 7,112,969 23,941 6,236 30,177

Glenn Research Center 8,210,877 11,566,057 19,776,934 55,775 20,368 76,143 

Goddard Space Flight Center 14,724,185 21,856,843 36,581,028 95,852 35,416 131,268

Headquarters 9,986,815 1,468,197 11,455,012 68,399 2,151 70,550

Johnson Space Center 19,165,494 6,832,546 25,998,040 122,371 10,774 133,145

Kennedy Space Center 8,322,312 3,143,045 11,465,357 62,681 4,843 67,524

Langley Research Center 10,643,054 12,603,662 23,246,716 71,749 21,016 92,765

Marshall Space Flight Center 11,875,842 8,953,420 20,829,262 89,158 12,814 101,972

NASA Shared Services Center 698,750 13,027,536 13,726,286 4,834 9,907 14,741

Stennis Space Center 1,189,859 311,939 1,501,798 9,841 625 10,466

Wallops Flight Facility 0 1,069,177 1,069,177 0 1,847 1,847

Unidentified 1,522 0 1,522 21 0 21

Total $95,404,055 $96,608,747 $192,012,802 652,209 146,929 799,138

Source: JPMorgan data. 
APPENDIX D

REPORT NO. IG-12-010 33

MANAGEMENT COMMENTS
APPENDIX D

34 REPORT NO. IG-12-010 
APPENDIX D

REPORT NO. IG-12-010 35
APPENDIX D

36 REPORT NO. IG-12-010 
APPENDIX D

REPORT NO. IG-12-010 37
APPENDIX E 

38 REPORT NO. IG-12-010 

REPORT DISTRIBUTION

National Aeronautics and Space Administration

Administrator

Deputy Administrator

Chief of Staff

Chief Financial Officer

Deputy Chief Financial Officer

Assistant Administrator for Procurement

Executive Director, NASA Shared Services Center

NASA Advisory Council’s Audit, Finance, and Analysis Committee 

Non-NASA Organizations and Individuals

Office of Management and Budget

Deputy Associate Director, Energy and Science Division

Branch Chief, Science and Space Programs Branch

Government Accountability Office 

Director, Office of Financial Management and Assurance

Director, Office of Acquisition and Sourcing Management 

Congressional Committees and Subcommittees, Chairman and 

Ranking Member

Senate Committee on Appropriations 

Subcommittee on Commerce, Justice, Science, and Related Agencies

Senate Committee on Commerce, Science, and Transportation 

Subcommittee on Science and Space

Senate Committee on Homeland Security and Governmental Affairs

House Committee on Appropriations 

Subcommittee on Commerce, Justice, Science, and Related Agencies

House Committee on Oversight and Government Reform 

Subcommittee on Government Organization, Efficiency, and Financial Management 

House Committee on Science, Space, and Technology 

Subcommittee on Investigations and Oversight 

Subcommittee on Space and Aeronautics
REPORT NO. IG-12-010 39

Major Contributors to the Report: 

Mark Jenson, Director, Financial Management Directorate

Michelle Robertson, Project Manager 

Deirdre Beal, Auditor 

GaNelle Flemons, Auditor 

Bruce Schmidt, Program Analyst 
FEBRUARY 16, 2012

REPORT No. IG-12-010 

OFFICE OF AUDITS

OFFICE OF INSPECTOR GENERAL

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