JULY 26, 2012

AUDIT REPORT

REPORT NO. IG-12-018 (ASSIGNMENT NO. A-12-004-00)

OFFICE OF AUDITS

AUDIT OF NASA GRANTS 

AWARDED TO THE PHILADELPHIA 

COLLEGE OPPORTUNITY RESOURCES FOR EDUCATION

OFFICE OF INSPECTOR GENERAL

National Aeronautics and 

Space Administration

 
REPORT NO. IG-12-018 

Final report released by:

Paul K. Martin

Inspector General

Acronyms 

C.F.R. Code of Federal Regulations

CORE College Opportunity Resources for Education 

GIC Grant Information Circular

NASA National Aeronautics and Space Administration

NPR NASA Procedural Requirements

NSSC NASA Shared Services Center

OIG Office of Inspector General

OMB Office of Management and Budget

PMS Payment Management System 
JULY 26, 2012

REPORT NO. IG-12-018 

OVERVIEW

AUDIT OF NASA GRANTS AWARDED TO THE PHILADELPHIA 

COLLEGE OPPORTUNITY RESOURCES FOR EDUCATION

The Issue

In September 2011, the National Aeronautics and Space Administration (NASA) Office 

of Inspector General (OIG) reported that NASA did not have an adequate system of 

controls in place to ensure proper administration and management of its grant program 

and that as a result some grant funds were not being used for their intended purposes.1

Founded in 2003, CORE is a not-for-profit organization that provides college 

scholarships to high school seniors who reside and attend high school in Philadelphia, 

Pennsylvania; plan to attend a Pennsylvania college or university full time; and have a 

financial need. NASA awarded CORE a $1 million grant on September 27, 2009, and a 

second grant, also for $1 million, on August 5, 2010. In addition to NASA, CORE 

receives grants from other Federal agencies and other sources. As of September 2011, 

CORE had awarded $28.3 million in college scholarships to 23,666 students. 

 

As a follow-on to our September 2011 report, we are conducting a series of audits 

examining specific NASA grants. In this report, we present the results of our review of 

two $1 million grants NASA made to the Philadelphia College Opportunity Resources for 

Education (CORE) in 2009 and 2010. 

The objective of this audit was to determine whether CORE used NASA’s grant funds for 

their intended purpose and whether the costs associated with the grants were allowable, 

reasonable, and in accordance with applicable laws, regulations, guidelines, and the terms 

and conditions of the grants. Specifically, we reviewed CORE’s (1) program 

performance and accomplishments, (2) accounting and internal control environment, 

(3) budget management and control, and (4) reporting. 

Results

We found that CORE fulfilled the stated goals and objectives of the grants by awarding 

approximately $1.8 million from NASA funds in scholarships to eligible high school 

students. However, we identified a number of deficiencies in CORE’s accounting and 

internal control environment, as well as areas where NASA can improve its policies and 

procedures over grant management. Specifically, CORE failed to obtain a required audit 

of its operations for 2010, inaccurately recorded and reported certain financial 

 

1 NASA OIG, “NASA’s Grant Administration and Management” (IG-11-026, September 12, 2011).
OVERVIEW

ii REPORT NO. IG-12-018 

information, charged $60,511 in unallocable or unallowable expenditures, and failed to 

maintain appropriate time and attendance documentation to support personnel charges 

totaling $156,409. We also found that CORE failed to file or was late in filing required 

financial and inventory reports. In addition, CORE inappropriately displayed NASA’s 

name and insignia on its website. 

Management Action

To remedy the deficiencies identified, we recommended that the Assistant Administrator 

for Procurement strengthen NASA’s policies and procedures to ensure that grantees 

obtain required audits, update the NASA Grant and Cooperative Agreement Handbook 

(Grant Handbook) to reflect the current practice of the NASA Shared Services Center 

(NSSC) regarding inventory reports, and work with the Associate Administrator for 

Communications to clearly delineate in the Grant Handbook and award documentation 

the requirements for use of NASA’s logo and insignia. We also recommended that the 

NSSC Executive Director and the Associate Administrator for Education work together 

to ensure that CORE remedies the $156,409 in unsupported costs and $60,511 in 

unallocable or unallowable expenditures identified, verify that CORE did not charge 

expenditures to both NASA and Department of Education grants, and ensure that CORE 

submits all required reports for the 2009 and 2010 grants. Finally, we recommended that 

prior to awarding any future grants to CORE the Executive Director and the Associate 

Administrator ensure that CORE has strengthened and formally documented its internal 

controls to comply with NASA and Office of Management and Budget (OMB) 

requirements.

In response, the Assistant Administrator stated that NSSC has already taken corrective 

action that addresses our recommendation to ensure that grantees obtain required audits. 

In addition, the Assistant Administrator stated that he advised NSSC to rescind its

memorandum regarding the submission of final property inventory reports and to work 

with the Headquarters Office of Communications to develop formal written procedures 

for approving the use of the NASA seal, insignia, logo, program identifiers, or flags. The 

Executive Director stated that NSSC would request that the Office of Naval Research 

conduct incurred cost audits for unsupported, unallocable, or unallowable expenditures 

and verify that CORE did not charge certain expenditures to both NASA and Department 

of Education grants. Additionally, the Executive Director stated that NSSC would notify 

CORE by July 31, 2012, to revise its internal controls to address OMB and Grant 

Handbook Financial Management requirements and will review the revisions for 

compliance before awarding any new grants to the organization. Finally, NSSC will 

request that CORE submit final inventory reports by July 31, 2012. 

We consider the Agency’s proposed actions responsive to our recommendations. 

Accordingly, we have resolved the recommendations and will close them upon receipt 

and verification of supporting documentation.
JULY 26, 2012

REPORT NO. IG-12-018 

CONTENTS

INTRODUCTION

Background _________________________________________ 1 

Objectives __________________________________________ 2 

RESULTS

Findings and Recommendations__________________________ 3 

APPENDIX A 

Scope and Methodology_______________________________ 19

Review of Internal Controls ____________________________ 22

Prior Coverage ______________________________________ 22

APPENDIX B 

Table of Questioned Costs _____________________________ 24

APPENDIX C 

Agency Comments ___________________________________ 25

APPENDIX D 

Grantee Comments __________________________________ 29

APPENDIX E 

Report Distribution___________________________________ 40

JULY 26, 2012

REPORT NO. IG-12-018 1 

INTRODUCTION

Background

The National Aeronautics and Space Administration (NASA) faces the ongoing challenge 

of ensuring that the approximately $500 million in grants it awards annually are 

administered appropriately and that grantees are accomplishing stated objectives. In 

September 2011, the NASA Office of Inspector General (OIG) reported that NASA did

not have an adequate system of controls in place to ensure proper administration and 

management of its grant program and that as a result some grant funds were not being 

used for their intended purposes.2

As a follow-on to our September 2011 report, we are conducting a series of audits 

examining particular NASA grants. In this report, we present the results of our review of 

two $1 million grants NASA made to the Philadelphia College Opportunity Resources for 

Education (CORE) in 2009 and 2010.

 

3

Table 1. Philadelphia CORE Grants Reviewed

 

Grant Award Start Date End Date Award Amount

NNX09AQ33G 9/27/2009 9/30/2010 $1,000,000

NNX10AH59G 8/5/2010 9/30/2011 1,000,000

Total $2,000,000

Source: NASA grant award files

Founded in 2003, CORE is a not-for-profit organization that provides college 

scholarships to high school seniors who reside and attend high school in Philadelphia, 

Pennsylvania; plan to attend a Pennsylvania college or university full time; and have a 

financial need. In addition to NASA, CORE also receives grants from other Federal 

agencies and other sources. As of September 2011, CORE had awarded $28.3 million in 

college scholarships to 23,666 students. 

The NASA Grant and Cooperative Agreement Handbook (Grant Handbook) contains the 

policies and procedures NASA procurement and technical officers and grantees must 

 

2 NASA OIG, “Audit of NASA’s Grant Administration and Management” (IG-11-026, September 12, 

2011). 

3 Both grants were funded as a result of congressional earmarks. We judgmentally selected these grants for 

review based on dollar value and other factors. 
INTRODUCTION

2 REPORT NO. IG-12-018 

follow in the pre-award, post-award, and closeout phases of grant management.4

Objectives

 The 

Grant Handbook serves as a reference manual and assists grantees in meeting their 

fiduciary responsibility to safeguard grant funds and ensure they are used appropriately 

and consistently with the terms and conditions of the award. By accepting NASA 

awards, CORE agreed to comply with the financial and administrative requirements set 

forth in the Grant Handbook. 

The overall objective of this audit was to determine whether CORE used NASA funds as 

intended and whether associated expenditures were allowable, reasonable, and in 

accordance with applicable laws, regulations, guidelines, and the terms and conditions of 

the grants. Specifically, we reviewed CORE’s (1) program performance and 

accomplishments, (2) accounting and internal control environment, (3) budget 

management and control, and (4) reporting. 

To accomplish our audit, we conducted interviews with representatives from NASA 

Headquarters Office of Procurement, NASA grant and technical officers, and CORE’s

Executive Officer.5 We also visited CORE’s office to document accounting, 

procurement, and project management processes and internal controls. Finally, we 

reviewed laws, regulations, and documentation pertinent to our audit. Additional details 

of the audit’s scope and methodology, our review of internal controls, and prior audit 

coverage are in Appendix A. 

 

4 NASA Procedural Requirements (NPR) 5800.1, “Grant and Cooperative Agreement Handbook,” is 

codified in the Code of Federal Regulations (C.F.R.) at Part 1260. NASA issues Grant Information 

Circulars to disseminate guidance internally and issues Grant Notices to publicize regulatory changes not 

yet incorporated in the current version of the Grant Handbook.

5 The grant officers for the grants reviewed were located at NSSC and the technical officer for both grants 

was located at the Ames Research Center.
RESULTS

REPORT NO. IG-12-018 3 

FINDINGS AND RECOMMENDATIONS

We determined that CORE adequately fulfilled the stated goals and objectives of the 

two grants we reviewed. Specifically, CORE awarded approximately $1.8 million in

scholarships to eligible high school students using NASA funds. However, we 

identified a number of deficiencies in CORE’s accounting and internal control 

environment. Specifically, CORE failed to obtain a required audit of its operations 

for 2010, inaccurately recorded and reported certain financial information, failed to 

maintain appropriate time and attendance records to support personnel charges 

totaling $156,409 and charged $60,511 in unallocable or unallowable expenditures. 

We also found that CORE failed to file or was late in filing required financial and 

inventory reports to NASA. In addition, CORE inappropriately displayed NASA’s 

name and insignia on its website. Finally, we identified areas where NASA can 

improve its policies and procedures over grant management. 

Program Performance and Accomplishments 

The overarching goal of the two NASA CORE grants was to provide scholarships to 

needy high school seniors in Philadelphia, Pennsylvania. To determine whether CORE

met this goal, we interviewed CORE’s Executive Director and reviewed supporting 

documentation. 

We confirmed that CORE funded approximately $1.8 million in scholarships with NASA 

grant funds over the 2-year period covered by the grants and spent the remaining 

$200,000 on administrative expenses associated with the program. We examined the 

administrative expenditures and, with the exceptions discussed below, determined they 

were reasonable. 

Accounting and Internal Controls

According to the Grant Handbook, grant recipients are required to establish and maintain 

accounting and internal control systems to account for the funds awarded to them. To 

test the adequacy of CORE’s systems, we requested copies of CORE’s required outside 

audit (“Single Audit”) report, interviewed CORE’s Executive Director, and reviewed 

CORE’s accounting activities. 

We found that CORE had knowledgeable and experienced staff responsible for the areas 

we reviewed and that staff and management openly communicated regarding CORE’s 

mission and goals. We also found that financial duties were reasonably segregated 

between CORE’s staff, bookkeeper, and Board of Directors. However, we noted that 

CORE had not formally documented many of its operating procedures. 
RESULTS

4 REPORT NO. IG-12-018 

Single Audit. According to the Office of Management and Budget (OMB) Circular 

A-133, “Audits of States, Local Governments, and Non-Profit Organizations,” June 26, 

2007, any grantee that expends more than $500,000 in Federal funds in any given year 

must obtain an outside audit of its operations. These Single Audits review the grantee’s 

financial statements, internal controls, and compliance with laws and regulations and may 

identify questioned costs and make recommendations for corrective action. The Circular 

requires grantees to submit Single Audit reports to the Federal Audit Clearinghouse 

within 30 days of completion or 9 months after the end of the audit period, whichever is 

earlier.6

In 2009, CORE did not expend more than $500,000 in Federal funds, so no Single Audit 

was required. In 2010, CORE expended $1.7 million in Federal funds, triggering the 

Single Audit requirement. However, CORE did not obtain a Single Audit for 2010. 

According to the Executive Director, she was not aware of the requirement to obtain a 

Single Audit. After we brought the matter to her attention, she engaged an independent 

public accounting firm to perform the audit.

 

7

Financial Management. According to the Grant Handbook, grantees’ financial 

management systems should provide accurate, current, and complete disclosure of 

financial results and records that adequately identify the source and application of funds 

used for federally sponsored activities. Grantees should also have effective controls over 

and accountability for all funds, property, and other assets and adequately safeguard and 

ensure such assets are used solely for authorized purposes. Additionally, grantees’ 

accounting records should be supported by source documentation. 

 

To record its financial operations, CORE uses a commercial off-the-shelf software 

package that tracks expenditures and revenues by grant program. We reviewed 14 

personnel transactions CORE had charged to the NASA grants – 5 from 2009 and 9 from 

2010 – and found the amounts recorded in CORE’s general ledger were not consistent 

with the supporting documentation. Specifically, CORE’s 2009 general ledger reflected 

$12,641 in personnel costs, but the associated payroll documentation totaled $16,103. 

Similarly, CORE’s 2010 general ledger reflected $17,885 in expenses, but the associated 

payroll documentation totaled $21,654. The Executive Director was initially unable to 

explain these discrepancies. However, immediately prior to the issuance of the draft 

report, the Executive Director provided documentation supporting that the discrepancies 

identified in CORE’s 2009 general ledger resulted from the salary of two individuals 

being recorded under a separate grant awarded by another Federal agency, with only a 

portion of the benefits associated with those two payroll transactions being recorded 

under NASA’s grant. While we believe that similar circumstances may also explain the 

discrepancies identified in CORE’s 2010 general ledger, we received no supporting 

documentation to confirm that this was the case. As a result, while we no longer take 

 

6 The Federal Audit Clearinghouse disseminates audit information, supports OMB oversight and 

assessment of Federal audit requirements, assists Federal oversight agencies in obtaining A-133 data, and 

helps minimize the reporting burden of complying with A-133 audit requirements.

7 The Single Audit was not complete as of March 2012. 
RESULTS

REPORT NO. IG-12-018 5 

issue with the 2009 discrepancies, the 2010 discrepancies remain of concern. Because 

CORE prepared its financial reports based on its general ledgers, these reports also 

understated CORE’s personnel costs reported to NASA. 

Grant Drawdowns.8

For the two grants reviewed, NASA disbursed a total of $2 million. We compared 

drawdowns with grant expenditures and found that CORE generally based its drawdowns 

on the expenditures reflected in its general ledger and made drawdowns in accordance 

with the requirements of the Grant Handbook (see Table 2 for details). We identified one 

instance in which CORE withdrew $3,925 in excess of expenditures and did not invest 

the excess funds in an interest bearing account. However, because this amount would not 

have generated more than $250 in interest over the life of the grant, there was no loss to 

the Government due to CORE’s action. 

 The Grant Handbook establishes the procedures by which NASA 

makes payments to grantees. Pursuant to the Handbook, grantees should draw down the 

minimum funds needed to cover expenditures. In addition, they are required to invest 

any funds that exceed expenses in an interest bearing account and remit any interest over 

$250 to the Department of Health and Human Services’ Payment Management System 

(PMS) for return to the Treasury. 

Table 2. Philadelphia CORE Drawdowns

Grant Award

Amount of 

Drawdown per 

PMS

Grant Expenditures 

per the 

General Ledgers 

Expenditures in 

Excess of 

Drawdown

NNX09AQ33G $ 465,900 $ 616,201 $150,301

465,900 311,674 (154,226)

68,200 90,760 22,560

Grant total $1,000,000 $1,018,635 $ 18,635

NNX10AH59G $ 471,900 $ 878,916 $407,016

373,925 173,620 (200,305) 

116,491 3,123 (113,368) 

37,684 301 (37,383) 

Grant total $1,000,000 $1,055,960 $ 55,957

Source: PMS and CORE’s general ledgers

 

8 The term “draw down” refers to the action in which the grantee withdraws funds from the U.S. 

Department of Health and Human Services’ Payment Management System, which NASA and other 

Federal agencies use. 
RESULTS

6 REPORT NO. IG-12-018 

Grant Expenditures. To determine the accuracy and allowability of costs charged to the 

grants, we reviewed a sample of CORE’s expenditures, including personnel expenditures 

for CORE staff working on the grants; non-personnel expenditures such as rent and 

supplies; and scholarship payments. In total, we reviewed $594,833 in grant transactions, 

or 30 percent of the total amount expended for the two grants. Of that amount, we 

questioned $216,920, as discussed below and shown in Appendix B.

Personnel Expenditures

We tested 14 personnel transactions totaling $30,526 (out of a total of $156,409) for 

compliance with OMB requirements. We found that: 

. OMB Circular A-122, “Cost Principles for Non-Profit 

Organizations,” August 31, 2005, states that charges to awards for salaries and wages will 

be based on documented payrolls approved by a responsible official of the organization 

that reflect the distribution of activity of each employee whose compensation is charged 

to awards. Each report must account for the total activity for which employees are 

compensated in fulfillment of their obligations to the organization. A responsible 

supervisory official having first-hand knowledge of the activities performed by the 

employee must sign the reports.

• CORE employees did not prepare time and attendance reports consistently 

documenting the total number of hours worked each day; 

• signatures of both the preparer and the responsible supervisory official were not 

consistently provided; and 

• although the reports described specific work activities, they did not identify the 

grant to which those activities applied. 

In light of the deficiencies identified in our sample, we asked the Executive Director 

whether there was additional documentation to support the personnel expenditures CORE 

charged to the NASA grants. The Executive Director advised us that she believed the 

time and attendance reports were adequate and that she did not have any other supporting 

documentation. Because we found the time and attendance reports deficient, we question 

the $156,409 in total personnel expenditures charged to the grants. 

Non-Personnel Expenditures

We found CORE inappropriately charged $58,000 in expenditures for computer 

support/maintenance services that were not allocable to the grants, and $2,760 in 

unallowable expenditures for items such as duplicate payroll, bank fees, and late fees. 

. We reviewed 110 non-personnel transactions totaling 

$564,307, or 28 percent of total expenditures for the two grants reviewed. These 

transactions included payments for computer support/maintenance services, rent, office 

supplies, and contractor expenses. We compared the transactions with the NASAapproved budget and traced them to supporting documentation to determine whether they 

were properly authorized, classified, and supported. 
RESULTS

REPORT NO. IG-12-018 7 

See Table 3 for a complete list of the $60,511 in unallocable or unallowable costs that we 

identified. 

Table 3. Questioned Costs to the NASA Grants * 

Type of Cost

Number of 

Transactions Questioned Amount

Computer support/maintenance 

(2009) 1 $43,000

Computer support/maintenance 

(2010) 1 15,000

Duplicate payroll 1 1,036 

Late fees 3 465

Sales tax 5 361

Bank fees 9 322

Vendor invoice calculation errors 3 169

Duplicate storage fees 1 158

Total 24 $60,511

* Excludes unsupported personnel costs previously discussed in the report.

Source: CORE’s 2009 and 2010 general ledgers

Charges for late fees, sales tax, and bank fees are unallowable expenses in accordance 

with both OMB Circular A-122 and the direction provided to CORE by the NASA grant 

officer. Further, the computer support/maintenance fees of $43,000 are not allocable to 

the NASA awards, as they related to a contract for “continuing” services that CORE 

entered into on May 19, 2009, more than 90 days before NASA awarded the 2009 grant 

to CORE.9,10

 

9 An allocable cost, according to OMB Circular A-122, is cost that can be allocated as a particular cost 

objective, such as a grant, contract, project, service, or other activity, in accordance with the relative 

benefits received. A cost is allocable to a Federal award if it is treated consistently with other costs 

incurred for the same purpose in like circumstances. Further, any cost allocable to a particular award or 

other cost objective under these principles may not be shifted to other Federal awards to overcome 

funding deficiencies or to avoid restrictions imposed by law or by the terms of the award.

 When we asked the Executive Director about this charge, she indicated the 

expenses should have been charged to a Department of Education grant rather than the 

NASA grant. In October 2011, CORE retroactively adjusted its general ledger relating to 

this entry. 

10 We also noted that CORE did not record this expense in its general ledger until September 1, 2009, 

almost 3 months after paying for the services. 
RESULTS

8 REPORT NO. IG-12-018 

For the 2010 award, NASA was again charged for computer support/maintenance, which 

was $30,000. However, according to the 2010 grant budget, this cost should have been 

split equally between NASA and the Department of Education. The Executive Director 

could not explain why this expense was charged only to NASA. Accordingly, we 

question $15,000 of the charge as unallocable. 

Finally, we noted that in December 2011 CORE made three additional retroactive 

adjustments to its accounting records to apply expenses for scholarship awards totaling 

$24,500 to the NASA grant. The Executive Director subsequently advised that additional 

adjustments were made, amounting to a grand total of $43,000 in retroactive entries to the 

general ledger. Because these adjustments and the $43,000 adjustment discussed above 

were made after we concluded our fieldwork in that area, we were not able to determine 

whether they were appropriate or supported by adequate documentation. However, we 

are concerned that CORE made these adjustments without NASA’s knowledge and after 

the 2009 grant had been closed. Moreover, because CORE’s Federal Financial Reports 

reflect the original entries and we have not reviewed the legitimacy of the retroactive 

adjustments, we cannot be certain that the filed reports accurately reflect the NASA grant 

activity. 

Scholarship Awards. CORE awarded a total of $1.8 million in scholarships using 

NASA grant funds. CORE paid the scholarships directly to the Pennsylvania colleges

and universities attended by the student recipients. We reviewed scholarship payments 

issued to six educational institutions totaling $430,975 and compared the amounts 

recorded in CORE’s general ledgers with the amounts issued. In addition, we reviewed 

the individual student scholarship awards obtained from CORE’s scholarship system and 

compared them with the amounts issued. We found that CORE had adequate 

documentation to support the payments and that data in the scholarship system aligned 

with the transactions included in the general ledgers. 

Budget Management and Control

According to the Grant Handbook, the budget plan is the financial expression of the 

project or program as approved during the award process. Although NASA assumes no 

responsibility for budget overruns, recipients may spend grant funds without strict 

adherence to individual allocations within proposed budgets, except when they relate to 

the acquisition of property, awarding of subcontracts, or certain revisions to budget and 

program plans. In addition, NASA may, but is not required to, restrict a grantee’s ability 

to transfer funds among direct cost categories or programs, functions, and activities for 

awards that exceed $100,000 when the cumulative amount of such transfers exceeds or is 

expected to exceed 10 percent of the total NASA-approved budget. NASA did not place 

any such restrictions on CORE. 

As we noted in our September 2011 report reviewing NASA’s overall grant management, 

allowing grant recipients such broad discretion to deviate from approved budgets in our 
RESULTS

REPORT NO. IG-12-018 9 

view increases the risk that they may incur unauthorized or unallowable costs or 

expenditures unrelated to the purpose of the grant. In this audit, we examined the extent 

to which CORE adhered to the NASA-approved budgets by comparing the amounts 

CORE expended in each general ledger category with the approved budgets. 

We did not identify any instances in which CORE failed to conform to the requirements 

of the Grant Handbook. Nevertheless, we are concerned about several instances in which 

CORE deviated from the approved budget or otherwise failed to comply with direction 

from NASA. First, for the reasons discussed above, we question $43,000 and $15,000 in 

computer support and maintenance expenses CORE charged to the NASA grants in 2009 

and 2010 respectively. Second, the NASA grant officer disapproved six items totaling 

$32,765 in CORE’s proposed 2009 budget and one item in CORE’s proposed 2010 

budget and instructed CORE to reallocate these items to other cost categories. However, 

we found items recorded in CORE’s general ledgers in the initial, disallowed categories. 

Finally, we identified several expenditures in the general ledger that exceeded the 

budgeted amount approved by NASA, which CORE covered by tapping into other 

approved cost categories. See Tables 4 and 5 for more details.
RESULTS

10 REPORT NO. IG-12-018 

Table 4. CORE Budget and Expenses for the 2009 Grant

Expenditure Category

Approved Grant 

Budget

General Ledger 

Expenditures

Expenditure in 

Excess of Budget

Scholarship awards $ 885,110 $ 886,000 $ 890

Personnel 53,550 51,251 (2,299)

Scholarship system 

software & support 21,500 43,000 21,500

Office supplies 19,250 1,380 (17,870)

Office equipment 2,700 3,768 1,068

Publishing & printing 1,690 0 (1,690)

Postage & delivery 1,800 968 (832)

Telephone, fax, & Internet 750 841 91

Subscriptions 450 470 20

Travel 1,200 168 (1,032)

Systems development 12,000 0 (12,000)

Fiscal management, 

customer services* 0 15,357 15,357

Rent* 0 12,633 12,633

Insurance* 0 1,576 1,576

Storage* 0 975 975

Bank fees* 0 248 248

Total $1,000,000 $1,018,635 $18,635

* As previously discussed, these items were in the CORE proposed budget; however, the NASA Budget 

Memorandum identified these items as unapproved and NASA directed CORE to reallocate them to 

other cost categories.

Source: NASA grant award file and CORE’s 2009 general ledger
RESULTS

REPORT NO. IG-12-018 11

Table 5. CORE Budget and Expenses for the 2010 Grant

Cost Category

Approved 

Budget

General Ledger 

Expenditures

Amount in 

Excess of Budget

Scholarship awards $ 860,465 $ 894,900 $34,435

Personnel 100,000 105,157 5,157

Scholarship system 

software & support 15,000 30,000 15,000

Rent 10,000 10,992 992

Development officer, 

consultant 7,500 7,620 120

Office supplies 2,000 2,028 28

Telephone, fax, & Internet 2,000 2,744 744

Postage & delivery 1,000 1,018 18

Storage 960 316 (644)

Subscriptions 750 898 148

Travel 125 126 1 

Bank fees* 200 161 (39)

Total $1,000,000 $1,055,957 $55,957

* The NASA Budget Memorandum for the 2010 grant award identified bank fees as unapproved in 

the proposed budget. The grantee was directed to reallocate the bank fees to another cost 

category.

Source: NASA grant award file and CORE’s 2010 general ledger

In our September 2011 report, we recommended that the Assistant Administrator for 

Procurement revise the Grant Handbook to require a minimum threshold for all grantee 

budget deviations (excluding categories already requiring approval) and that technical 

officers approve budget deviations in excess of such threshold prior to the expenditure of 

grant funds. The Assistant Administrator for Procurement concurred with our 

recommendation and proposed corrective action. Accordingly, we are not making a 

recommendation concerning this issue in this report. 

Grant Reporting

The Grant Handbook requires grantees to submit quarterly and final Federal Financial 

Reports and final performance and inventory reports to NASA. The Federal Financial 

Reports show grantees’ expenditures and drawdowns for the reporting period. 

Performance reports provide information on the progress of the work effort, and 

inventory reports document NASA-provided equipment and property valued at more than 

$5,000 and equipment and property purchased by the grantee for $1,000 or more. 
RESULTS

12 REPORT NO. IG-12-018 

Financial Reports. The Grant Handbook requires grantees to submit quarterly Federal 

Financial Reports to PMS following the end of each fiscal quarter (December 31, 

March 31, June 30, and September 30). For the 2009 award, CORE’s quarterly reports 

were due 15 days after the end of the quarter. For the 2010 award, NASA changed the 

reporting requirements so that the quarterly reports were due within 30 working days of 

the end of the quarter. Grantees are required to report expenditures and drawdowns 

online for each calendar quarter of the award period. Grantees are also required to submit 

a final Federal Financial Report within 90 days of the award’s completion date. 

According to OMB Circular A-110, Federal agencies are required to use Federal 

Financial Reports to monitor cash advanced to recipients and to obtain disbursement 

information. 

We analyzed the quarterly and final Federal Financial Reports for the two grants we

reviewed. As shown in Table 6, we found that the majority of CORE’s Federal Financial 

Reports were late or not submitted at all. For the 2009 grant, three quarterly reports were 

never submitted and the fourth was 46 days late. For the 2010 grant, one quarterly report 

and the final report were never submitted and one quarterly report was 23 days late. 

CORE’s Executive Director stated that the first report for the 2009 grant was not 

submitted because she could not access PMS and did not withdraw any grant funds 

during that period. However, the Grant Handbook requires reporting even when no funds 

have been withdrawn. The Executive Director said the other 2009 reports were not 

submitted because she inadvertently failed to complete a step in the submission process 

requiring her to certify the reports’ accuracy. The Executive Director acknowledged 

missing one quarterly report for the 2010 grant. She said she did not submit the final 

reports because NASA had disabled the reporting functionality following the close of the 

grant period. However, as previously mentioned, the grant award documents and the 

Grant Handbook allowed the recipient 90 days after award completion to submit the 

required reports. 
RESULTS

REPORT NO. IG-12-018 13

Table 6. Timeliness of CORE Financial Reports

Number Report Period Ending Due Date Date Submitted Days Late

1 December 31, 2009 1/25/10 not submitted — 

2 March 31, 2010 4/21/10 not submitted — 

3 June 30, 2010 7/23/10 not submitted — 

4 September 30, 2010 10/22/10 12/29/10 46

5 2009 Award – Final Report 12/29/10 12/15/10 0 

6 December 31, 2010 2/15/11 2/9/11 0 

7 March 31, 2011 5/12/11 not submitted — 

8 June 30, 2011 8/12/11 9/15/11 23

9 September 30, 2011 11/16/11 10/26/11 0 

10 2010 Award – Final Report 12/29/11 not submitted — 

Source: Grant Handbook requirements for Federal Financial Reports; CORE’s submitted reports

According to PMS support staff, the system should suspend a grantee’s account when a 

report is not received within 90 days of the reporting deadline. However, this control was 

not entirely effective for the CORE grants and CORE was able to continue withdrawing 

funds despite having failed to submit the required reports. According to PMS officials, 

the system was corrected in September 2011. 

NASA policy requires that the Finance Office of the NASA Shared Services Center 

(NSSC) use PMS and the quarterly Federal Financial Reports to monitor grantees’ 

drawdown activity and to ensure that the timing and amount of drawdowns are as close as 

administratively feasible to actual disbursements.11

Performance Reports. The Grant Handbook and the terms of each of the grants we 

reviewed required CORE to submit annual performance reports to NASA 60 days prior to 

the grant anniversary date and a final performance report no later than 90 days after the 

completion of each grant. 

 However, we found that NSSC does 

not consistently review the timeliness or accuracy of NASA grantees’ Federal Financial 

Reports, instead relying on PMS to oversee the submission of the reports and suspend 

accounts as appropriate. In this case, this complete reliance on PMS resulted in a 

noncompliant grantee repeatedly receiving drawdowns of NASA grant funds. 

Both CORE grants had a 1-year period of performance, so only final reports were 

required. In both instances, CORE submitted timely final reports. 

 

11 NPR 9680.1, “NASA’s Management of Grants and Cooperative Agreements,” October 31, 2008.
RESULTS

14 REPORT NO. IG-12-018 

Inventory Reports. According to the grant award documents and the Grant Handbook, 

CORE was required to submit final inventory reports to NASA 60 days after the 

completion of each grant. However, CORE did not submit inventory reports for either 

grant. According to the Executive Director, she did not file the reports because she was 

not able to identify the individual at NASA to which the reports needed to be submitted. 

NASA closed out the 2009 grant and is in the process of closing out the 2010 grant in the 

absence of these reports. 

According to a 2009 NSSC memorandum, NSSC’s closeout process will no longer 

require inventory reports when it is clear that no Government inventory was provided to 

the grantee. However, NASA has not updated the Grant Handbook to reflect this change. 

Other Matters of Interest

During the course of our review, we learned that the grantee was using NASA’s acronym 

and insignia on its public website in a manner inconsistent with applicable laws and 

regulations. 

Image from CORE’s Webpage

Source: CORE’s S2P2 webpage as of 

February 24, 2012

The National Aeronautics and Space Act of 1958 provides that no person may knowingly 

use the letters “NASA” as a business name in a manner reasonably calculated to convey 

the impression that the business has some connection with, endorsement of, or 

authorization from NASA that does not exist or in connection with any product or service 

being offered or made available to the public that conveys the impression that NASA 

authorizes, supports, or endorses the product or service.12 In addition, Federal 

regulations limit the use of the NASA insignia to certain specified purposes and prohibit 

other uses of the insignia without the express approval of NASA.13

The CORE Executive Director told us she was not aware that CORE’s use of the NASA 

name and insignia on the website was inappropriate, and the NASA technical officer 

 CORE’s use of the 

insignia did not fall into any of the authorized categories, and CORE did not have 

approval from NASA to use its name or insignia on CORE’s website. 

 

12 Public Law 85-568, “National Aeronautics and Space Act of 1958,” July 29, 1958. 

13 14 C.F.R. §1221.110. 
RESULTS

REPORT NO. IG-12-018 15

responsible for oversight of the CORE grant said she was not aware of the legal 

restrictions on the use of this information.14

Recommendations, Management’s Response, and Evaluation of 

Management’s Response

 Once we notified the grantee of the 

restrictions, the grantee removed the NASA reference and insignia from its website. 

Recommendation 1. We recommended that the Assistant Administrator for Procurement

strengthen policies and procedures to ensure that grantees obtain A-133 Single Audits or 

program-specific audits when they expend more than $500,000 in Federal awards. 

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

stating that NSSC implemented procedures and documented them in policy dated April 6, 

2012. NSSC obtains quarterly reports from NASA’s accounting system to identify 

recipients with drawdowns equal to or greater than $500,000 for the fiscal year. Once 

identified, NSSC notifies recipients of the OMB Circular A-133 Single Audit 

requirement. NSSC also revised its standard award letter to remind recipients of this

requirement. 

Evaluation of Management’s Response. Notifying NASA recipients of the A-133 

Single Audit requirement when they have drawdowns that are equal to or greater than 

$500,000 for the fiscal year is responsive to our recommendation. Therefore, we 

consider the recommendation resolved and will close it upon receipt and verification of 

supporting documentation. 

Recommendation 2. We recommended that the Assistant Administrator for Procurement 

update the Grant Handbook to reflect current practice regarding inventory reports. 

Management’s Response. The Assistant Administrator for Procurement agreed that the 

Grant Handbook should reflect current practice, but stated that by issuing the 2009 

memorandum NSSC did not intend to waive the requirement for a final property 

inventory report. Accordingly, the NSSC memorandum was rescinded on July 2, 2012, 

and the Grant Handbook accurately reflects current practice. 

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

recommendation. Therefore, we consider the recommendation resolved and will close it 

upon receipt and verification of supporting documentation. 

Recommendation 3. We recommended that the Assistant Administrator for Procurement 

work with the Associate Administrator for Communications to clearly delineate the 

 

14 The only discussion of use of the NASA name or logo in the Grant Handbook is a requirement that 

grantees that disseminate research produced using NASA funds include in their reports an 

acknowledgement of NASA’s support and the grant number.
RESULTS

16 REPORT NO. IG-12-018 

requirements surrounding the use of NASA’s logo and insignia in the Grant Handbook and 

on award documentation. 

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

stating that a new grant and cooperative agreement provision for the use of the NASA 

seal, insignia, logo, program identifiers, or flags will be added to the Grant Handbook. 

The Assistant Administrator also stated that NSSC will work with the Associate 

Administrator for Communications to develop formal written procedures for review of 

requests to use NASA’s seal, insignia, logo, program identifiers, or flags.

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

responsive to our recommendation. Therefore, we consider the recommendation resolved 

and will close it upon receipt and verification of supporting documentation. 

Recommendation 4. We recommended that the NSSC Executive Director, in conjunction 

with the Associate Administrator for Education, ensure that CORE remedies the $156,409 in 

unsupported payroll expenditures. 

Management’s Response. The NSSC Executive Director concurred, stating that by 

July 31, 2012, NSSC will request that the Office of Naval Research conduct an incurred 

cost audit on these expenditures and will seek remedy from CORE as appropriate within 

60 days of receipt of the audit report. 

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

responsive to our recommendation. Therefore, we consider the recommendation resolved 

and will close it upon receipt of supporting documentation. 

Recommendation 5. We recommended that the NSSC Executive Director, in conjunction 

with the Associate Administrator for Education, ensure that CORE remedies the $60,511 in 

unallocable or unallowable expenditures. 

Management’s Response. The NSSC Executive Director concurred, stating that by 

July 31, 2012, NSSC will request that the Office of Naval Research conduct an incurred 

cost audit on these expenditures and will seek remedy from CORE as appropriate within 

60 days of receipt of the audit report. 

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

responsive to our recommendation. Therefore, we consider the recommendation resolved 

and will close it upon receipt of supporting documentation. 
RESULTS

REPORT NO. IG-12-018 17

Recommendation 6. We recommended that the NSSC Executive Director, in conjunction 

with the Associate Administrator for Education, work with CORE to verify that the 

expenditures charged to the NASA grants that CORE claims should have been charged to 

Department of Education grants were not charged to both grants. 

Management’s Response. The NSSC Executive Director concurred, stating that by 

July 31, 2012, NSSC will request the Office of Naval Research to conduct an incurred 

cost audit to verify that the expenditures were charged to the appropriate grants and will 

seek remedy from CORE as appropriate within 60 days of receipt of the audit report. 

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

responsive to our recommendation. Therefore, we consider the recommendation resolved 

and will close it upon receipt of supporting documentation. 

Recommendation 7. We recommended that the NSSC Executive Director, in conjunction 

with the Associate Administrator for Education, ensure that CORE submits all required 

reports for the 2009 and 2010 grants. 

Management’s Response. The NSSC Executive Director partially concurred, stating 

that the Department of Health and Human Services’ Payment Management System does 

not allow grantees to submit late quarterly Federal Financial Reports. Instead, grantees 

must reflect financial information from late quarterly reports on subsequent reports. The 

Executive Director stated that NSSC will request that CORE submit the final inventory 

reports for each of the two audited grants. 

Evaluation of Management’s Response. We consider the proposed action responsive to 

our recommendation. Therefore, we consider the recommendation resolved and will 

close it upon receipt and verification of supporting documentation. 

Recommendation 8. We recommended that prior to awarding any future grants to CORE, 

the NSSC Executive Director and the Associate Administrator for Education ensure that 

CORE has strengthened and formally documented its internal controls to ensure compliance 

with NASA and OMB requirements. 

Management’s Response. The NSSC Executive Director concurred, stating that NSSC

will designate CORE as requiring additional special conditions per the Grant Handbook 

and request that CORE revise its internal controls to address OMB Circulars and Grant 

Handbook Financial Management requirements. The Executive Director added that 

NSSC will review CORE’s revised controls before awarding any new grants to the 

organization. 

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

responsive to our recommendation. Therefore, we consider the recommendation resolved 

and will close it upon receipt and verification of supporting documentation. 

APPENDIXES

REPORT NO. IG-12-018 19

APPENDIX A 

Scope and Methodology

We performed this audit from October 2011 through June 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 overall audit objective was to determine whether NASA’s grant funds were being 

used for their intended purpose and whether the Agency was compliant with established 

laws, regulations, and NASA-specific requirements in its administration and management 

of the grants. To accomplish our objective, we interviewed key personnel at NSSC and 

at CORE involved in the grant administration, management, and award processes. We 

also identified and reviewed relevant Federal laws and regulations and NASA policies, 

procedures, and requirements. The methodology we used for the review is described 

below. 

Grant Selection. We judgmentally selected the two grants awarded to CORE for 

substantive testing based on the dollar value and the number of supplements awarded. 

Both grants were funded as a result of congressional earmarks and were awarded by 

NSSC. 

Grant Award File Documentation. We reviewed grant award documentation including 

proposal, budget, technical review reports, and summary financial reporting 

documentation. We interviewed NASA grant officers and the NASA technical officer

responsible for the CORE grants.

Grantee Site Visits. We visited the grantee’s location in Philadelphia, Pennsylvania. 

We interviewed grantee officials and performed the substantive transaction testing 

necessary to validate whether NASA grant funds were used for their intended purpose 

while assessing the sufficiency of grantee performance.

Testing Conducted. We tested compliance with what we considered the most important 

conditions of the grant. Unless otherwise stated in our report, the criteria we audited 

against included Federal requirements, the Grant Handbook, and the terms and conditions 

of the grants. In conducting our audit, we employed judgmental sampling designed to 

obtain broad exposure to numerous facets of the grants reviewed, such as dollar amounts 

or expenditure category. This non-statistical sample design does not allow projection of 

the test results to the universes from which the samples were selected. 
APPENDIX A 

20 REPORT NO. IG-12-018 

Specifically, we tested the grantee’s:

• Program Performance and Accomplishments to determine whether the grantee 

met or is capable of meeting the grant objectives and whether the grantee 

collected data and developed performance measures to assess accomplishment of 

the intended objectives. 

• Accounting and Internal Controls to determine whether the grantee had 

sufficient accounting and internal controls to identify and report expenditures and 

reimbursements. This included testing: 

o Grant Drawdowns to determine whether grant drawdowns were 

adequately supported and whether the grantee was managing grant 

receipts in accordance with Federal requirements; and

o Grant Expenditures to determine the accuracy and allowability of costs 

charged to the grant.

• Budget Management and Control to determine the amounts budgeted and the 

actual costs for each approved cost category and to determine whether the grantee 

deviated from the approved budget and, if so, whether the grantee received the 

necessary approval.

• Grant Reporting to determine whether the required reports were submitted on 

time and accurately reflected grant activity. 

We also performed limited work and confirmed that CORE did not generate or receive 

program income, did not have any property or equipment that was reportable to NASA, 

was not required to contribute any local matching funds, did not have any subgrantees to 

monitor, and did not have any indirect costs associated with the grants we reviewed. We 

therefore performed no testing in these areas. 

We identified and reviewed the following criteria as applicable to our audit objectives: 

Federal Laws, Regulations, Policies, and Requirements 

Public Law 111-8, ‘‘Omnibus Appropriations Act, 2009,’’ March 11, 2009 

Public Law 111-116, “Consolidated Appropriations Act, 2010,’’ December 16, 2009 

Code of Federal Regulations (C.F.R.), Title 2, Part 215, “Uniform Administrative 

Requirements for Grants and Agreements with Institutions of Higher Education, 

Hospitals and Other Non-Profit Organizations (OMB Circular A-110),” January 1, 2006 

2 C.F.R. Part 230, “Cost Principles for Non-Profit Organizations (OMB Circular 

A-122),” August 31, 2005 
APPENDIX A 

REPORT NO. IG-12-018 21

14 C.F.R. Part 1260, “Grants and Cooperative Agreements,” Subpart A, October 19, 

2000, with subsequent amendments 

14 C.F.R. Part 1260, Subpart B, “Uniform Administrative Requirements for Grants and 

Cooperative Agreements with Institutions of Higher Education, Hospitals, and Other 

Non-Profit Organizations,” October 19, 2000, with subsequent amendments 

Title 31, United States Code, Chapter 63 (31 U.S.C. 63), “Using Procurement Contracts 

and Grant and Cooperative Agreements,” January 7, 2011 

OMB Circular A-133, “Audits of States, Local Governments, and Non-Profit 

Organizations,” June 26, 2007

NASA Policies, Procedures, and Circulars 

NASA Policy Directive 1200.1E, “NASA Internal Controls,” July 21, 2008 

NASA Procedural Requirements (NPR) 5800.1, “Grant and Cooperative Agreement 

Handbook,” Section A, June 13, 2008 and Section B, April 20, 2007 

NPR 9010.3, “Financial Management Internal Control,” September 30, 2008 

NPR 9680.1, “NASA’s Management of Grants and Cooperative Agreements,” October 

31, 2008 

Grant Information Circular (GIC) 05-03, “Additional Guidance Related to the Processing 

of Unsolicited Proposals, Successor Proposals and Congressional Interest Items 

(Earmarks),” April 7, 2005 

GIC 08-01, “Ensuring Only Allowable, Reasonable, and Necessary Costs in the Award of 

Grants and Cooperative Agreements,” February 14, 2008 

GIC 09-02, “Guidance On Processing Congressionally Directed Items (Earmarks) for 

Fiscal Year (FY) 2009,” July 23, 2009 

GIC 09-04, “Substitution of Standard Form (SF) 425 for Standard Form (SF) 272: Class 

Deviation from the Requirements at C.F.R. 1260.26 and Exhibits D & G of 14 C.F.R. 

Part 1260,” October 27, 2009 

GIC 11-01, “Implementation of the Federal Funding Accountability and Transparency 

Act (FFATA) of 2006,” January 24, 2011 

GIC 11-02, “Requirements for Non-Competitive Agency Grant and Cooperative 

Agreement Actions, Exclusive of those Actions Prescribed by 14 C.F.R. 1260.17, 

Evaluation and Selection of Unsolicited Proposals,” May 24, 2011 
APPENDIX A 

22 REPORT NO. IG-12-018 

Use of Computer-Processed Data. We relied on NASA computer-processed data to 

determine the NASA grants universe and to provide financial data. While we obtained 

grant drawdown data and the Federal Financial Reports used during the audit from the 

Department of Health and Human Services’ PMS, we did not perform any substantive 

testing of PMS to validate the completeness or accuracy of the data. As a result, we 

placed limited reliance on the accuracy of the data obtained from PMS. Further, we also 

placed limited reliance on the information obtained from the grantee’s financial system to 

perform detailed transaction testing on the grantee’s financial records. 

Review of Internal Controls 

We reviewed internal controls for the grantee’s administration and management of grants, 

including the adequacy of CORE’s policies and procedures. The control weaknesses we 

identified are discussed in this report. Our recommendations, if implemented, should 

correct the identified control weaknesses. 

Prior Coverage

During the last 6 years, NASA and the GAO have issued the following reports and 

testimony that are of particular relevance to the subject of this report. Unrestricted 

reports can be accessed over the Internet at http://oig.nasa.gov/audits/reports/FY12/

(NASA OIG) and http://www.gao.gov (GAO).

“NASA’s Grant Administration and Management” (IG-11-026, September 12, 2011) 

NASA Office of Inspector General

“Audit of NASA’s Recovery Act Procurement Actions at Johnson Space Center, 

Goddard Space Flight Center, Langley Research Center, and Ames Research Center” 

(IG-10-017, July 27, 2010) 

“Final Memorandum on Review of Wheeling Jesuit University Cost Proposals” 

(IG-09-020-Redacted, August 3, 2009) 

“Final Memorandum on Audit of NASA Education and Training Grants” (IG-07-029-R, 

September 18, 2007) 

“Audit of NASA’s Management and Funding of Fiscal Year 2006 Congressional 

Earmarks” (IG-07-028, August 9, 2007) 

“Final Memorandum Regarding Duplicate Grant Funding,” August 10, 2006 

(http://oig.nasa.gov/audits/reports/FY06/A-06-006.pdf) 
APPENDIX A 

REPORT NO. IG-12-018 23

“Federal Grants – Improvements Needed in Oversight and Accountability Processes” 

(GAO-11-773T, June 23, 2011) 

Government Accountability Office

“Opportunities to Reduce Potential Duplication in Government Programs, Save Tax 

Dollars, and Enhance Revenue” (GAO-11-318SP, March 2011) 

“Grants Management – Attention Needed to Address Undisbursed Balances in Expired 

Grant Accounts” (GAO-08-432, August 2008) 

“Grants Management – Grantees’ Concerns with Efforts to Streamline and Simplify 

Processes” (GAO-06-566, July 2006) 
APPENDIX B 

24 REPORT NO. IG-12-018 

TABLE OF QUESTIONED COSTS

The following table shows the questioned costs identified during our audit and discussed 

in this report (see page 6 for the discussion of unsupported personnel costs; the discussion 

of unallowable non-personnel costs begins on page 6).

Questioned Costs* Amount

Unsupported costs:

 Personnel Costs $156,409

Unallocable costs:

 Computer support/maintenance (2009) $43,000

 Computer support/maintenance (2010) $15,000

Total unallocable costs $58,000

Unallowable costs:

 Duplicate Payroll 1,036

 Late fees 465

 Sales tax 361

 Bank fees 322

 Vendor invoice calculation errors 169

 Duplicate Storage fees 158

Total unallowable costs $2,511

Total $216,920

* Questioned costs are expenditures that are questioned by the OIG because they are an 

alleged violation of legal, regulatory, or contractual requirements; are not supported by 

adequate documentation at the time of the audit; or are unauthorized or unallowable. 
APPENDIX C

REPORT NO. IG-12-018 25

AGENCY COMMENTS
APPENDIX C

26 REPORT NO. IG-12-018 
APPENDIX C

REPORT NO. IG-12-018 27
APPENDIX C

28 REPORT NO. IG-12-018 
APPENDIX D

REPORT NO. IG-12-018 29

GRANTEE COMMENTS
APPENDIX D

30 REPORT NO. IG-12-018 
APPENDIX D

REPORT NO. IG-12-018 31
APPENDIX D

32 REPORT NO. IG-12-018 
APPENDIX D

REPORT NO. IG-12-018 33
APPENDIX D

34 REPORT NO. IG-12-018 
APPENDIX D

REPORT NO. IG-12-018 35
APPENDIX D

36 REPORT NO. IG-12-018 
APPENDIX D

REPORT NO. IG-12-018 37
APPENDIX D

38 REPORT NO. IG-12-018 
APPENDIX D

REPORT NO. IG-12-018 39
APPENDIX E 

40 REPORT NO. IG-12-018 

REPORT DISTRIBUTION

National Aeronautics and Space Administration

Administrator

Deputy Administrator

Chief of Staff

Associate Administrator for Education

Assistant Administrator for Procurement 

Associate Administrator for Communications 

NASA Advisory Council’s Audit, Finance, and Analysis Committee 

Director, Ames Research Center

Executive Director, NASA Shared Services Center

Non-NASA Organizations and Individuals

Executive Director, Philadelphia College Opportunity Resources for Education 

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-12-018 41

Major Contributors to the Report: 

Laura Nicolosi, Director, Mission Support Directorate

Joseph Shook, Project Manager

Bobbie Wells, Lead Auditor 

Lynette Westfall, Senior Auditor

Frank Mazurek, Associate Counsel, Office of Inspector General

Annette Huffman, Program Assistant 
JULY 26, 2012

REPORT No. IG-12-018 

OFFICE OF AUDITS

OFFICE OF INSPECTOR GENERAL

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Visit http://oig.nasa.gov/audits/reports/FY12/ to obtain additional copies of this report, or contact the 

Assistant Inspector General for Audits at 202-358-1232. 

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Ideas and requests can also be mailed to:

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