NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

REPORT

PURSUANT TO

GOOD ACCOUNTING OBLIGATION IN GOVERNMENT ACT OF 2019 

(P.L. 115-414)

As of January 31, 2022
2

NASA’S REQUIRED REPORTING UNDER THE GOOD ACCOUNTING 

OBLIGATION IN GOVERNMENT ACT (P.L. 115-414)

Background

In 2019, the President signed into law the “Good Accounting Obligation in Government Act” 

(the Act). The Act was envisioned to improve transparency into long-standing audit 

recommendations issued by the Government Accountability Office (GAO) and federal Office of 

Inspectors General (OIG). By requiring agency reporting on the lack of progress towards 

implementation, the Congress postulated that Federal agencies would be held more accountable

and that the public can more readily assess agency funding requests in light of unfulfilled 

efficiency improvements that could potentially yield cost savings.

Section 2 of the Act imposes an affirmative requirement on Federal agencies to submit an annual

report on publicly issued GAO and OIG recommendations classified as “open” for more than one 

year from the date of the annual budget justification submission. Additionally, the Act also 

requires that agencies report on publicly issued GAO recommendations which were determined 

to “closed but not implemented.” For both categories of recommendations -- open, and closed 

but not implemented – Federal agencies are required to provide an explanation as to why final 

management action1 has not yet been completed. Finally, the Act also requires agencies perform 

a reconciliation of discrepancies between recommendations reported by GAO and OIGs, and 

Federal agencies. 

Reporting Methodology and Report Structure

This report includes GAO and OIG recommendations November 19, 2012 to January 27, 2021 

that remained unimplemented for one year or more from the planned fiscal year 2022 budget 

justifications submission date.

The report has four parts:

Appendix A: A report listing GAO recommendations and their implementation status.

Appendix B: A report listing OIG recommendations and their implementation status

Appendix C: A reconciliation of this report and the OIG’s Semi-Annual Report

Appendix D: A listing of acronyms used throughout this report

For purposes of NASA’s FY2022 reporting under the Act, the following definitions are provided 

in order to enhance the utility and readability of this report:

1 Final Management Action: The completion of all actions that the management of an establishment has concluded, 

in its management decision, are necessary with respect to the findings and recommendations included in an audit 

report; or, in the event that the management of an establishment concludes no action is necessary, final action occurs 

when a management decision has been made. Source: Inspector General Act of 1978 (as amended).
3

• Open: Final management action is pending/in-progress (includes recommendations for 

which final management action has been completed, but auditor verification/validation is 

pending/in-progress)

• Closed: Final management action and corresponding auditor verification/validation 

completed

• Closed/Not Implemented: Recommendation has been closed, however final 

management action has been partially completed, not completed, or action(s) not 

recommended have been taken. (Applicable only to GAO recommendations).
Appendix A: GAO Recommendations and Implementation Status

Report Number Report Date Report Title Responsible Org Name

Recom.

Number Recom. Description Im

GAO1322 11/19/2012 Earned Value Management Implementation

Across Major Spaceflight Projects Is Uneven

Chief Financial Officer 4 (Pri Rec) To improve the reliability of project EVM data, NPR 7120.5 should be modified to

require projects to implement a formal surveillance program that: a. Ensures anomalies in

contractor‐delivered monthly earned value management reports are identified and explained,

and report periodically to the mission directorate’s leadership on relevant trends in the

number of unexplained anomalies. b. Ensures consistent use of WBSs for both the EVM

report and the schedule. c. Ensures that lower level EVM data reconcile to project level EVM

data using the same WBS structure. d. Improves underlying schedules so that they are

properly sequenced using predecessor and successor dependencies and are free of

constraints to the extent practicable so that the EVM baseline is reliable.

NASA Action Completed. GAO review o

GAO1465 11/6/2013 Information Technology: Additional OMB and

Agency Actions Are Needed to Achieve Portfolio

Savings

Chief Information Officer 1 Reflect 100 percent of information technology investments in the agency's enterprise

architecture. (Report #35)

NASA Action Completed. GAO review o

GAO14385 5/8/2014 NASA Actions Need to Improve Transparency

and Assess Long‐Term Affordability of Human

Exploration Programs

Human Exploration and

Operations Directorate

1 (Pri Rec) Establish a separate cost and schedule baseline for work required to support the SLS

Block I EM‐2 and report this information to the Congress through NASA’s annual budget

submission. If NASA decides to fly the SLS Block I beyond EM‐2, establish separate life cycle

cost and schedule baseline estimates for those efforts, to include funding for operations and

sustainment, and report this information annually to Congress via the agency’s budget

submission.

Anticipated completion date: 04‐29‐202

GAO14385 5/8/2014 NASA Actions Need to Improve Transparency

and Assess Long‐Term Affordability of Human

Exploration Programs

Human Exploration and

Operations Directorate

2 (Pri Rec) Because NASA intends to use increased capabilities of the SLS, Orion and GSDO

efforts well into the future and has chosen to estimate costs associated with achieving

capabilities, establish separate cost and schedule baselines for each additional capability that

encompass all life cycle costs, to include operations and sustainment. When NASA cannot

fully specify costs due to lack of well‐defined missions or flight manifests, forecast a cost

estimate range – including life cycle costs – having minimum and maximum boundaries.

These baselines or ranges should be reported to Congress annually via the agency’s budget

submission.

Anticipated completion date: 04‐29‐202

GAO14631 7/23/2014 SPACE LAUNCH SYSTEM: Resources Need to be

Matched to Requirements to Decrease Risk and

Support Long Term Affordability

Human Exploration and

Operations Directorate

2 (Pri Rec) To provide decisionmakers with an informed basis for making investment decisions

regarding the SLS program, NASA should identify a range of possible missions for each future

SLS variant that includes cost and schedule estimates and plans for how those possible

missions would fit within NASA’s funding profile.

Anticipated completion date: 04‐29‐202

GAO14631 7/23/2014 SPACE LAUNCH SYSTEM: Resources Need to be

Matched to Requirements to Decrease Risk and

Support Long Term Affordability

Human Exploration and

Operations Directorate

3 (Pri Rec) To allow for a continued assessment of progress and affordability, NASA should

structure each future increment of SLS capability with a total cost exceeding the $250 million

threshold for designation as a major project as a separate development project within the SLS

program.

Anticipated completion date: 04‐29‐202

GAO15431 5/21/2015 Telecommunications: Agencies Need Better

Controls to Achieve Significant Savings on

Mobile Devices and Services

Chief Information Officer 2 A reliable inventory of mobile service contracts is developed and maintained. Report

recommendation #29

NASA Action Completed. GAO review o

GAO15431 5/21/2015 Telecommunications: Agencies Need Better

Controls to Achieve Significant Savings on

Mobile Devices and Services

Chief Information Officer 1 Ensure a complete inventory of mobile devices and associated services is established. Report

recommendation #28

NASA Action Completed. GAO review o

GAO15431 5/21/2015 Telecommunications: Agencies Need Better

Controls to Achieve Significant Savings on

Mobile Devices and Services

Chief Information Officer 3 Procedures to monitor and control spending are established agencywide. Specifically, ensure

that: procedures include assessing devices for zero, under, and over usage; personnel with

authority and responsibility for performing the procedures are identified; and the specific

steps to be taken to perform the process are documented. Report recommendation #30

NASA Action Completed. GAO review o

GAO16620 7/27/2016 ORION MULTI‐PURPOSE CREW VEHICLE: Action

Needed to Improve Viability into Cost Schedule,

and Capacity to Resolve Technical Challenges

Human Exploration and

Operations Directorate

1 (Pri Rec) To provide the Congress and NASA a reliable estimate of program cost and schedule

that are useful to support management and stakeholder decisions, GAO recommends the

NASA Administrator direct the Orion program to perform an updated JCL analysis including

updating cost and schedule estimates in adherence with cost and schedule estimating best

practices.

Anticipated completion date: 08‐30‐202

GAO16686 9/15/2016 Federal Chief Information Officers:

Opportunities Exist to Improve Roles and

Address Challenges to Authority

Chief Information Officer 1 Define the Senior Agency Information Security Officer (SAISO) role in agency policy of

contractor oversight system security for information systems that are operated by

contractors on the Agency's behalf.

NASA Action Completed. GAO review o

GAO1842 1/10/2018 Information Technology: Agencies Need to

Involve Chief Information Officers in Reviewing

Billions of Dollars in Acquisitions

Chief Information Officer 3 The Administrator of NASA should ensure that IT acquisition plans or strategies are reviewed

and approved according to OMB guidance (Report Rec 32).

NASA Action Completed. GAO review o

Page 1 of 4
Report Number Report Date Report Title Responsible Org Name

Recom.

Number Recom. Description Im

GAO18337 5/22/2018 NASA Information Technology: Urgent Action

Needed to Address Significant Management and

Cybersecurity Weaknesses

Chief Information Officer 3 (INITIAL NASA NONCONCUR) The Administrator should direct the Chief Information Officer

address, in conjunction with the Chief Human Capital Officer, gaps in IT workforce planning by

fully implementing the eight key IT workforce planning activities noted in this report. Non‐Concur. NASA non‐concurred with 

comprehensive, Agency‐wide assessme

optimally structured to achieve the NAS

Support Future Architecture Program w

decentralized model to an enterprise m

realignment with estimated completion 

Planning (SWP) project directed the cre

workforce needs five plus years into the 

workforce needed to meet future missio

other workforce segments; c) Includes b

Considers external changes, program lif

Agency demographics, and other enviro

the workforce. The data collection phas

currently analyzing the data to glean ins

GAO18337 5/22/2018 NASA Information Technology: Urgent Action

Needed to Address Significant Management and

Cybersecurity Weaknesses

Chief Information Officer 6 The Administrator should direct the Chief Information Officer to address weaknesses in

oversight practices and ensure routine oversight of all investments by taking action to

document criteria for escalating investments among governance boards and establish

procedures for tracking corrective actions for underperforming investments.

NASA Action Completed. GAO review o

GAO18337 5/22/2018 NASA Information Technology: Urgent Action

Needed to Address Significant Management and

Cybersecurity Weaknesses

Chief Information Officer 8 The Administrator should direct the Chief Information Officer to establish an agency‐wide

approach to managing cybersecurity risk that includes a cybersecurity strategy that, among

other things, makes explicit the agency’s risk tolerance, accepted risk assessment

methodologies, a process for consistently evaluating risk across the organization, response

strategies and approaches for monitoring risk over time, and priorities for risk management

investments.

Anticipated completion date: 12/30/202

GAO18337 5/22/2018 NASA Information Technology: Urgent Action

Needed to Address Significant Management and

Cybersecurity Weaknesses

Chief Information Officer 10 The Administrator should direct the Chief Information Officer to establish an agency‐wide

approach to managing cybersecurity risk that includes policies and procedures with well‐

defined roles and responsibilities that are integrated and reflect NASA’s current security

practices and operating environment.

Anticipated completion date: 12/30/202

GAO18466 6/14/2018 Cybersecurity Workforce: Agencies Need to

Improve Baseline Assessments and Procedures

for Coding Positions

Office of Chief Human Capital

Officer

1 (INITIAL NASA NONCONCUR) The Administrator of the National Aeronautics and Space

Administration should evaluate the level of preparedness for cybersecurity personnel not

currently holding professional certifications to take certification exams and report this

information to Congress (Report Rec 16).

Non‐Concur. NASA non‐concurred with 

currently no federal or Agency requirem

maintain a professional certification. W

of cybersecurity personnel to take certif

Congress in December 2016 and does n

GAO18476 7/11/2018 NASA COMMERCIAL CREW PROGRAM: Plan

Needed to Ensure Uninterrupted Access to the

International Space Station

Human Exploration and

Operations Directorate

4 After completing the agency certification review, NASA Chief Engineer and Chief Safety and

Mission Assurance, with support from the the NASA Associate Administrator for Human

Exploration and Operation and the Commercial Crew Program Manager, should document

lessons learned related to loss of crew as a safety threshold for future crewed spaceflight

missions, given the complexity of the metric.

Anticipated completion date: 05‐31‐202

GAO1893 8/2/2018 Federal Chief Information Officers: Critical

Actions Needed to Address Shortcomings and

Challenges in Implementing Responsibilities

Chief Information Officer 1 The Administrator of the National Aeronautics Space Administration should ensure that the

department's IT management policies address the role of the CIO for key responsibilities in

the 6 areas GAO identified (Report Rec 21).

Anticipated completion date: 01‐31‐202

GAO19144 3/12/2019 Cybersecurity Workforce: Agencies Need to

Accurately Categorize Positions to Effectively

Identify Critical Staffing Needs

Office of Chief Human Capital

Officer

2 (Pri Rec) Take steps to review the assignment of the "000" code to any positions in the 2210

IT management occupation series, assign the appropriate NICE framework work role codes

and assess the accuracy of the position descriptions (Report Rec 24).

NASA Action Completed. GAO review o

GAO19265 4/4/2019 Scientific Integrity Policies: Additional Actions

Could Strengthen Integrity of Federal Research

Chief Scientist 1 The Administrator of NASA should develop documented procedures for identifying and

addressing alleged violations of its scientific integrity policy (Report Rec 10).

NASA Action Completed. GAO review o

GAO19377 6/19/2019 NASA Human Space Exploration: Persistent

Delays and Cost Growth Reinforce Concerns

Over Management of Programs

Human Exploration and

Operations Directorate

3 The NASA Associate Administrator for Human Exploration and Operations direct the EGS

program to demonstrate design maturity by completing 3D product modeling of the basic and

functional design of the second Mobile Launcher prior to construction start.

NASA Action Completed. GAO review o

GAO19377 6/19/2019 NASA Human Space Exploration: Persistent

Delays and Cost Growth Reinforce Concerns

Over Management of Programs

Human Exploration and

Operations Directorate

4 Ensure that the AA/HEOMD direct the SLS and Orion programs to reevaluate their strategies

for incentivizing contractors and determine whether they could more effectively incentivize

contractors to achieve the outcomes intended as part of ongoing and planned contract

negotiations.

Anticipated completion date: 6/29/2022

GAO19384 7/25/2019 Cybersecurity: Agencies Need to Fully Establish

Risk Management Programs and Address

Challenges

Chief Information Officer 1 Update the agency’s policies to address an organization‐wide risk assessment and the use of

risk assessments to inform plan of action and milestones (POA&M) prioritization.(Recommendation #46 in the GAO final report)

NASA Action Completed. GAO review o

GAO19384 7/25/2019 Cybersecurity: Agencies Need to Fully Establish

Risk Management Programs and Address

Challenges

Chief Information Officer 2 (Pri Rec) Establish a process for conducting an organization‐wide cybersecurity risk

assessment. (Report Rec. 47)

NASA Action Completed. GAO review o

Page 2 of 4
Report Number Report Date Report Title Responsible Org Name

Recom.

Number Recom. Description Im

GAO2068 12/19/2019 NASA Lunar Programs: Opportunities Exist to

Strengthen Analyses and Plans for Moon

Landing

Human Exploration and

Operations Directorate

2 Ensure that the NASA Associate Administrator for Human Exploration and Operations directs

the Gateway program to conduct a joint cost and schedule and confidence level at the

program level for the Artemis III mission

Anticipated completion date: 04‐29‐202

GAO2068 12/19/2019 NASA Lunar Programs: Opportunities Exist to

Strengthen Analyses and Plans for Moon

Landing

Human Exploration and

Operations Directorate

3 Ensure that the NASA Associate for Human Exploration and Operations directs the Gateway

program to update its overall schedule for 2024 and add a KDP II before system integration.

Anticipated completion date: 04‐29‐202

GAO2068 12/19/2019 NASA Lunar Programs: Opportunities Exist to

Strengthen Analyses and Plans for Moon

Landing

Human Exploration and

Operations Directorate

4 (Pri Rec) Ensure that the NASA Associate Administrator for Human Exploration and

Operations creates a life‐cycle cost estimate for the Artemis III mission.

Anticipated completion date: 08‐31‐202

GAO2068 12/19/2019 NASA Lunar Programs: Opportunities Exist to

Strengthen Analyses and Plans for Moon

Landing

Human Exploration and

Operations Directorate

5 Ensure that the NASA Associate Administrator for Human Exploration and Operations direct

the Advanced Exploration Systems division to commit to a completion date and finalize a

cohesive document outlining the rationale for selecting its current lunar architecture and

lunar programs.

NASA Action Completed. GAO review o

GAO2068 12/19/2019 NASA Lunar Programs: Opportunities Exist to

Strengthen Analyses and Plans for Moon

Landing

Chief Engineer 6 Ensure that the Office of Chief Engineer determine under what conditions it is appropriate to

complete an analysis of alternatives, particularly when there are multiple pathways ‐ 

including architectures or programs ‐that NASA could pursue in the future , and document

the justification for not completing an analysis.

Anticipated completion date: 03‐31‐202

GAO2059 3/30/2020 Information Management: Selected Agencies

Need to Improve Adherence to Federal

Electronic Recordkeeping Requirements

Chief Information Officer 1 (Pri Rec) Establish a time frame to develop an inventory of electronic information systems

used to store Agency records that includes all of the required elements (Report Rec. 17)

NASA Action Completed. GAO review o

GAO20155 4/7/2020 Telecommunications: Agencies Should Fully

Implement Established Transition Planning

Practices to Help Reduce Risk of Costly Delays

Chief Information Officer 1 The CIO should update the telecommunications inventory to include all telecommunications

assets and services in use at the department and updates NASA processes for ongoing

maintenance of the inventory to include the complete inventory (Report Recommendation

21).

Anticipated completion date: 02‐28‐202

GAO20155 4/7/2020 Telecommunications: Agencies Should Fully

Implement Established Transition Planning

Practices to Help Reduce Risk of Costly Delays

Chief Information Officer 2 The CIO should complete efforts to identify the Agency’s future telecommunications needs

using a complete inventory of existing telecommunications services (Report Rec 22).

Anticipated completion date: 02‐28‐202

GAO20155 4/7/2020 Telecommunications: Agencies Should Fully

Implement Established Transition Planning

Practices to Help Reduce Risk of Costly Delays

Chief Information Officer 3 The CIO should identify telecommunications transition roles and responsibilities related to (1)

managing human capital during the planning and execution phases of the transition and (2)

providing legal expertise during the execution phase of the transition (Report Rec 23).

NASA Action Completed. GAO review o

GAO20155 4/7/2020 Telecommunications: Agencies Should Fully

Implement Established Transition Planning

Practices to Help Reduce Risk of Costly Delays

Chief Information Officer 4 The CIO should conduct an analysis to support the anticipated cost saving identified as part of

the Agency’s justification for its resource requests related to the hardware and software

upgrades for the telecommunications transition, and justifies its resource requests for

program management staff, conducts an analysis to identify staff resources needed for the

entire transition effort; and analyzes training needs for staff assisting with the transition

(Report Rec 24).

NASA Action Completed. GAO review o

GAO20155 4/7/2020 Telecommunications: Agencies Should Fully

Implement Established Transition Planning

Practices to Help Reduce Risk of Costly Delays

Chief Information Officer 5 The CIO should take into account the Agency’s mission critical systems and contingency plans

in NASA’s telecommunications transition timeline (Report Rec 25).

NASA Action Completed. GAO review o

GAO20464 6/29/2020 Small Business Subcontracting: Oversight of

Contractor Compliance with Subcontracting

Plans Needs Improvement

Small Business Programs 1 Ensure contracting officers fulfill the requirement that subcontracting reports are submitted

in a timely manner. For example, the Agency could require contracting officers to verify that

prior reports were submitted when reviewing current submissions. (Report Rec 4).

Anticipated completion date: 03‐30‐202

GAO20464 6/29/2020 Small Business Subcontracting: Oversight of

Contractor Compliance with SubcontractingPlans Needs Improvement

Small Business Programs 2 Ensure contracting officers compare subcontracting goals in contractor report submissions to

goals in the approved subcontracting plan and address any discrepancies. (Report Rec. 8).

Anticipated completion date: 03‐30‐202

GAO21164SU 10/27/2020 Information and Communications Technology:

Federal Agencies Need to Take Urgent Action to

Manage Supply Chain Risk

Chief Information Officer 2 Develop an agency‐wide ICT SCRM that makes explicit the agency's risk tolerance and

identifies how the agency intends to assess, respond to and monitor ICT supply chain risks

across the life cycle of ICT products and services, (Report #107)

NASA Action Completed. GAO review o

GAO21164SU 10/27/2020 Information and Communications Technology:

Federal Agencies Need to Take Urgent Action to

Manage Supply Chain Risk

Chief Information Officer 3 Establish a process to conduct agency‐wide assessments of ICT supply chain risks. (Report

#108)

Anticipated completion date: 09‐30‐202

GAO21164SU 10/27/2020 Information and Communications Technology:

Federal Agencies Need to Take Urgent Action to

Manage Supply Chain Risk

Chief Information Officer 4 Develop organizational ICT SCRM requirements for inclusion in contracts that are tailored to

the type of contract and business needs. (Report #109)

NASA Action Completed. GAO review o

GAO21164SU 10/27/2020 Information and Communications Technology:

Federal Agencies Need to Take Urgent Action to

Manage Supply Chain Risk

Chief Information Officer 5 Develop organizational procedures to detect counterfeit ICT products prior to their

deployment. (Report #110)

Anticipated completion date: 09‐30‐202

Page 3 of 4
Report Number Report Date Report Title Responsible Org Name

Recom.

Number Recom. Description Im

GAO21105 12/15/2020 NASA Human Space Exploration: Significant

Investments in Future Capabilities Require

Strengthened Management Oversight

Human Exploration and

Operations Directorate

2 The NASA Administrator ensure that the NASA Associate Administrator for Human

Explorations and Operations Mission Directorate directs the Exploration System Development

organization to include cost, schedule, and technical performance updates for SLS Block 1B,

SLS Block 2, Orion Docking System in its quarterly status program reviews in order to maintain

oversight of these development projects.

NASA Action Completed. GAO review o

GAO21105 12/15/2020 NASA Human Space Exploration: Significant

Investments in Future Capabilities Require

Strengthened Management Oversight

Human Exploration and

Operations Directorate

1 (Pri Rec) The NASA Administrator ensure that the NASA Associate Administrator for Human

Explorations and Operations Mission Directorate establish cost and baseline schedules for SLS

Block 1B, SLS Block 2, Orion Docking System at their preliminary design reviews or as soon as

practicable in advance of critical design reviews.

Anticipated completion date: 04‐29‐202

GAO21130 12/17/2020 Federal Research: Agencies Need to Enhance

Policies to Address Foreign Influence

Chief Financial Officer 1 The Administrator of the National Aeronautics and Space Administration should update the

agency's conflict of interest policy on non‐financial conflicts, such as those the one developed

by OSTP, and address those conflicts both foreign and domestic. (Report recommendation 7)

Anticipated completion date: 07‐31‐202

GAO21130 12/17/2020 Federal Research: Agencies Need to Enhance

Policies to Address Foreign Influence

Chief Financial Officer 2 The Administrator of the National Aeronautics and Space Administration should document

procedures, including roles and responsibilities, for addressing failures to disclose required

information, both foreign and domestic. (Recommendation 8).

Anticipated completion date: 07‐31‐202

Page 4 of 4
Appendix B: OIG Recommendations and Implementation Status

Report Number Report Date Report Title Responsible Org Name Recom. Number Recom. Description 

IG12017 8/7/2012 Review of NASA's Computer Security Incident

Detection and Handling Capability

Chief Information Officer 3 Ensure that annual exercises simulating loss of the SOC

include the transfer of incident detection responsibility to the

Centers.

Anticipated 

IG12017 8/7/2012 Review of NASA's Computer Security Incident

Detection and Handling Capability

Chief Information Officer 2 Develop more detailed procedures for transferring incident

detection responsibility to the NASA Centers in the event of a

SOC disruption.

Anticipated 

IG14026 7/22/2014 Audit of the Space Network’s Physical and

Information Technology Security Risks

Chief Information Officer 2 To eliminate confusion regarding when IT waivers are

required, the CIO should clarify the waiver process set forth in

NPR 2800.1B.

Anticipated 

IG16015 3/28/2016 Audit of the Spaceport Command and Control

System

Human Exploration and Operations

Directorate

1 The OIG recommends that the Associate Administrator for

Human Exploration and Operations commission an

independent assessment to evaluate the status of the SCCS

software development effort and determine the necessary

steps to reduce the risk of further cost, schedule, and

performance issues, including consideration of acquiring

commercial command and control software to replace some

or all of the system currently under development

NASA Actio

for closure 

IG17003 11/2/2016 NASA's Earth Science Mission Portfolio Science Mission Directorate 1 Update the Architecture Plan every 5 years to align with the

release of Earth Science Decadal Surveys and mid‐term

Surveys and account for portfolio changes

Anticipated 

IG17012 3/9/2017 NASA’s Management of Electromagnetic

Spectrum

Human Exploration and Operations

Directorate

2 The OIG recommend NASA’s Associate Administrator for

Human Exploration and Operations; incorporate the

“Spectrum Guidance for NASA Small Satellite Missions” into

formal NASA electromagnetic spectrum policies NPD 2570.5E,

“NASA Electromagnetic Spectrum Management ‐ Revalidated9/13/16,” and NPR 2570.1C, “NASA Radio Frequency

Electromagnetic Spectrum Management Manual.”

Anticipated 

IG17021 5/17/2017 Construction of Test Stands 4693 and 4697 at

Marshall Space Flight Center

Strategic Infrastructure 1 Perform a comprehensive review of Program‐funded

construction projects to ensure adequate analysis, including

all life cycle costs, is completed prior to project initiation.

Anticipated 

IG17021 5/17/2017 Construction of Test Stands 4693 and 4697 at

Marshall Space Flight Center

Strategic Infrastructure 2 Develop additional construction project guidance for

establishing unallocated construction reserves for program‐

direct construction facility projects to better account for

significant expected risks

Anticipated 

IG17021 5/17/2017 Construction of Test Stands 4693 and 4697 at

Marshall Space Flight Center

Human Exploration and Operations

Directorate

3 Ensure facility needs, such as construction of new facilities

and/or modification of existing facilities, are appropriately

included in program planning and scheduling and that testing

requirements are adequately understood prior to committingthe Agency to construction or modification of test facilities.

Anticipated 

IG18015 4/5/2018 NASA’s Management of the Goddard Institute

for Space Studies

Science Mission Directorate 8 To the extent practicable, implement the GAO’s best practices

for establishing partnerships, including the formalization of

agreements that outline the roles and responsibilities of each

agency in the performance and application of climate research

performed at GISS.

Anticipated 

Page 1 of 7
Report Number Report Date Report Title Responsible Org Name Recom. Number Recom. Description 

IG18017 5/14/2018 Audit of NASA’s Compliance with the

Improper Payments Information Act for Fiscal

Year 2017

Chief Financial Officer 3 Develop a process for tracking overpayments identified and

subsequently recovered through reductions in future billings

on existing contracts such as contract credits.

Anticipated 

IG19002 10/22/2018 Audit of NASA's Historic Property Communications 2 To improve NASA’s identification and management of heritage

assets, the OIG recommends that the Assistant Administrator

for Strategic Infrastructure, in coordination with the Associate

Administrator for Communications: Develop comprehensive

procedures for identifying and managing heritage assets,

including defining roles and responsibilities for the differentNASA entities responsible for evaluating what historic items

would most effectively be maintained by the Agency and

considered as heritage assets.

Anticipated 

IG19002 10/22/2018 Audit of NASA's Historic Property Communications 3 To improve NASA’s identification and management of heritage

assets, the OIG recommends that the Assistant Administrator

for Strategic Infrastructure, in coordination with the Associate

Administrator for Communications: Evaluate and justify the

existing list of NASA and contractor held heritage assets to

determine whether NASA is the most effective owner and

what property the Agency will retain because of its historical

value.

Anticipated 

IG19002 10/22/2018 Audit of NASA's Historic Property Strategic Infrastructure 5 To improve the use of funds generated from National Historic

Preservation Act (NHPA) leases, the OIG recommends the

Assistant Administrator for Strategic Infrastructure: Ensure

NASA policy and procedures for using the proceeds fromfacilities leased under NHPA authority appropriately aligns

with Agency goals to minimize excess facilities.

Anticipated 

IG19014 3/26/2019 NASA’s Engineering and Technical Services

Contracts

Procurement 1 NASA’s Assistant Administrator for Procurement: Develop an

Agency‐wide standardized set of metrics for contracts that can

be collected, tracked, and analyzed over time to identify

efficiencies resulting from a change in contract structure.

Anticipated 

IG19014 3/26/2019 NASA’s Engineering and Technical Services

Contracts

Procurement 2 NASA’s Assistant Administrator for Procurement: Require

Center Procurement Offices to formally collect, track, and

report data to the Headquarters Office of Procurement on

these metrics at least annually.

Anticipated 

IG19014 3/26/2019 NASA’s Engineering and Technical Services

Contracts

Procurement 3 NASA’s Assistant Administrator for Procurement: Develop a

community of practice to analyze what contract structurechanges lead to the greatest efficiencies and to share these

lessons learned with the Agency’s procurement community.

Anticipated 

IG19018 5/7/2019 NASA’s Heliophysics Portfolio Science Mission Directorate 2 To improve NASA’s management of its heliophysics portfolio,

we recommended the Associate Administrator for Science

Mission Directorate direct the HPD Director to: complete

implementation of 2015 NSWAP tasks in accordance with

SWORM subcommittee deadlines.

Anticipated 

Page 2 of 7
Report Number Report Date Report Title Responsible Org Name Recom. Number Recom. Description 

IG19018 5/7/2019 NASA’s Heliophysics Portfolio Science Mission Directorate 3 To improve NASA’s management of its heliophysics portfolio,

we recommended the Associate Administrator for Science

Mission Directorate direct the HPD Director to: reassess HPD’s

capabilities and resources and update the 2014 Roadmap for

implementing 2013 Decadal recommendations with expected

completion dates based on the Division’s updated budget and

priorities over the next 5 years.

Anticipated 

IG19018 5/7/2019 NASA’s Heliophysics Portfolio Science Mission Directorate 4 To improve NASA’s management of its heliophysics portfolio,

we recommended the Associate Administrator for Science

Mission Directorate direct the HPD Director to: establish a

formal mechanism to increase collaboration with DOD and the

commercial space industry regarding heliophysics research

and space weather modeling and forecasting efforts.

Anticipated 

IG19019 5/29/2019 Management of NASA's Europa Mission Science Mission Directorate 9 The OIG also recommends the Associate Administrator for

Science Mission Directorate in coordination with the Office of

the General Counsel: Reassess the process of isolating key

project personnel from instrument selection to balance their

additional insight in integration and cost estimation while

maintaining fairness in the announcement and mitigating

conflicts of interest risks.

Anticipated 

IG20001 10/21/2019 NASA’s Security Management Practices Protective Services 4 Evaluate Agency‐wide jurisdictions to determine if it is feasible

for all Centers to be under the same jurisdiction or at least to

determine if individual Centers should have all of their

property under the same type of jurisdiction

Anticipated 

IG20001 10/21/2019 NASA’s Security Management Practices Protective Services 5 Coordinate with the Office of the General Counsel to

standardize the carrying of firearms by NASA civil servants in

an Agency‐wide policy while also addressing the appropriate

situations when NASA contractors may carry their government‐

issued weapons off NASA property

Anticipated 

IG20004 11/7/2019 Review of NASA’s Fiscal Year 2019 Digital

Accountability and Transparency Act

Submission

Procurement 2 Incorporate a procedure into the existing Verification and

Validation process to verify that procurement data is entered

into FPDS‐NG within three business days after contract award

Anticipated 

IG20005 11/14/2019 NASA’s Management of Crew Transportation

to the International Space Station

Human Exploration and Operations

Directorate

2 Correct identified safety‐critical technical issues before the

crewed test flights, including parachute and propulsion

systems including launch abort systems testing to ensure

sufficient safety margins exist.

Anticipated 

IG20011 3/3/2020 NASA’s Management of Distributed Active

Archive Centers

Science Mission Directorate 1 NASA’s Associate Administrator for Science Mission

Directorate:in conjunction with ESDIS, once SWOT and NISAR

are operational and providing sufficient data, complete an

independent analysis to determine the long‐term financial

sustainability of supporting the cloud migration and operation

while also maintaining the current DAAC footprint

Anticipated 

IG20011 3/3/2020 NASA’s Management of Distributed Active

Archive Centers

Science Mission Directorate 3 In coordination with the OCIO, and during the next security

plan review cycle, ensure all applicable information types areconsidered during system categorization, that appropriate

premises are used when determining impact levels, and that

the appropriate categorization procedures are standardized

across ESDIS systems

NASA Actio

for closure 

Page 3 of 7
Report Number Report Date Report Title Responsible Org Name Recom. Number Recom. Description 

IG20012 3/10/2020 NASA's Management of Space Launch System

Program Costs and Contracts

Human Exploration and Operations

Directorate

2c This review shall include: c. determining reporting and

tracking procedures for setting cost and schedule

commitments, and monitoring progress throughout the entire

life cycle of the SLS Program (through at least 2030).

Anticipated 

IG20012 3/10/2020 NASA's Management of Space Launch System

Program Costs and Contracts

Human Exploration and Operations

Directorate

2b This review shall include: b. establishing methodologies and

processes to track and set cost commitments for Artemis II

Anticipated 

IG20012 3/10/2020 NASA's Management of Space Launch System

Program Costs and Contracts

Human Exploration and Operations

Directorate

5 Conduct a thorough review of each major SLS contract’s scope

of work and technical requirements needed to complete the

period of performance to assist in eliminating incremental

contract value increases to the contract and lessen contract

management burden, as in the case of the Boosters contract.

Anticipated 

IG20012 3/10/2020 NASA's Management of Space Launch System

Program Costs and Contracts

Human Exploration and Operations

Directorate

2 Review HEOMD and NASA program management policies,

procedures, and ABC reporting processes to provide greater

visibility into current, future, and overall cost and schedule

estimates for the SLS Program and other human space flight

programs. This review shall include the following: a.

rebaselining Artemis I costs to appropriately and transparentlytrack costs that include SLS development costs and activities

tied to the first SLS launch; b. establishing methodologies and

processes to track and set cost commitments for Artemis II;

and c. determining reporting and tracking procedures for

setting cost and schedule commitments, and monitoringprogress throughout the entire life cycle of the SLS Program

(through at least 2030).

Anticipated 

IG20013 3/17/2020 Audit of NASA’s Development of Its Mobile

Launchers

Human Exploration and Operations

Directorate

3 Ensure life‐cycle and milestone reviews incorporate

programmatic and technical risks and are conducted with the

Associate Administrator for Human Exploration and

Operations Directorate and other senior Agency officials.

Anticipated 

IG20013 3/17/2020 Audit of NASA’s Development of Its Mobile

Launchers

Human Exploration and Operations

Directorate

4 Require the ML‐2 project to develop an ABC separate from the

EGS Program.

Anticipated 

IG20016 4/10/2020 NASA’s Compliance with the Improper

Payments Information Act for Fiscal Year 2019

Chief Financial Officer 2 In accordance with OMB guidance, obtain a statistically valid

estimate of the annual amount of improper payments in the

SLS program for reporting in the FY 2020 AFR, and complete

the associated required reporting.

Anticipated 

IG20017 6/25/2020 Evaluation of NASA’s Information Security

Program under the Federal Information

Security Modernization Act for Fiscal Year

2019

Chief Information Officer 9 Develop and implement an effective process to ensure that all

IT security handbooks and other IT governance documents are

reviewed and updated at least annually in accordance with

NASA requirements.

Anticipated 

IG20018 7/16/2020 NASA’s Management of the Orion Multi‐

Purpose Crew Vehicle Program

Human Exploration and Operations

Directorate

2 To the extent practicable, adjust the production schedules for

Artemis IV and V to better align with the successful

demonstration of Artemis II to reduce schedule delays

associated with potential rework.

Anticipated 

IG20021 8/27/2020 Audit of NASA’s Policy and Practices

Regarding the Use of Non‐Agency Information

Technology Devices

Chief Information Officer 2 Incorporate into applicable IT policy and requirements

documents IT systems security controls for life cycle

management in accordance with National Institute of

Standards and Technology Special Publication 800‐124.

Anticipated 

IG20021 8/27/2020 Audit of NASA’s Policy and Practices

Regarding the Use of Non‐Agency Information

Technology Devices

Chief Information Officer 3 Define requirements and implement controls to monitor and

enforce the MDM business rules, including defining the office

responsible for performing monitoring and enforcement.

Anticipated 

Page 4 of 7
Report Number Report Date Report Title Responsible Org Name Recom. Number Recom. Description 

IG20021 8/27/2020 Audit of NASA’s Policy and Practices

Regarding the Use of Non‐Agency Information

Technology Devices

Chief Information Officer 4 Revise cybersecurity policy, guidance, and requirements to

provide OCIO with a level of direct oversight of

enterprise‐wide IT management to ensure consistent practices

across Centers.

Anticipated 

IG20021 8/27/2020 Audit of NASA’s Policy and Practices

Regarding the Use of Non‐Agency Information

Technology Devices

Chief Information Officer 5 Revise NASA Strategy to Improve Network Security to

implement controls to ensure adequate Senior Agency

Information Security Officer visibility into the cybersecurity

practices at the Centers.

Anticipated 

IG20023 9/16/2020 NASA's Planetary Science Portfolio Science Mission Directorate 2 In coordination with the Office of Chief Financial Officer,

engage relevant Centers and technical capability leaders to

identify budgetary and accounting system solutions within thecurrent budgetary and full cost accounting system to

adequately fund and sustain critical technical discipline

capabilities needed to support current and future projects.

Anticipated 

IG20023 9/16/2020 NASA's Planetary Science Portfolio Science Mission Directorate 3 In coordination with the Office of the Chief Human Capital

Officer, review and identify opportunities based on existing

NASA leading practices to foster and monitor mentoring to

ensure a robust pipeline for PSD‐related disciplines.

Anticipated 

IG20023 9/16/2020 NASA's Planetary Science Portfolio Science Mission Directorate 5 In coordination with the Space Technology Mission

Directorate, evaluate each Directorate’s respective roles in

basic research that may affect PSD projects and identify

opportunities to advance technologies through flight

demonstrations.

Anticipated 

IG20023 9/16/2020 NASA's Planetary Science Portfolio Science Mission Directorate 6 Reassess the NEOO Program’s priority in meeting the goal of

cataloging 90 percent of the NEOs larger than 140 meters,

establish cost and schedule estimate with proposed funding

profile to meet the NEOO’s goal of cataloging, and coordinate

with Congress and request funding to support the

implementation goal.

Anticipated 

IG20023 9/16/2020 NASA's Planetary Science Portfolio Science Mission Directorate 7 In coordination with the NASA Shared Services Center, comply

with the Federal Grant and Cooperative Agreements Act of1977 on the use of contracts to provide greater visibility into

partner operations and ensure that funding levels and

performance are commensurate with contract requirements.

Anticipated 

IG20023 9/16/2020 NASA's Planetary Science Portfolio Science Mission Directorate 8 Implement the National Academies recommendation to

establish a common interface for CLPS contractors between

instrument and spacecraft or to require that each commercial

provider supply a document that describes provider and

payload capabilities.

Anticipated 

IG20023 9/16/2020 NASA's Planetary Science Portfolio Science Mission Directorate 9 In coordination with CLPS contracting personnel, establish

procedures for evaluation, periodic re‐evaluation, and

monitoring of current and prospective CLPS contractors’ past

performance and financial capabilities risk, and steps to

mitigate those risks when applicable.

Anticipated 

IG20023 9/16/2020 NASA's Planetary Science Portfolio Science Mission Directorate 10 Comply with NASA policy to establish program/project quality

assurance surveillance plans, or its intent thereof, for all

applicable CLPS task orders.

Anticipated 

IG21004 10/1/2020 NASA's Management of the Gateway Program

for Artemis Missions

Human Exploration and Operations

Directorate

1 Baseline the Gateway requirements and specifications in

contract modifications prior to updating and awarding the PPE

and HALO fixed‐price contracts.

Anticipated 

IG21004 10/1/2020 NASA's Management of the Gateway Program

for Artemis Missions

Human Exploration and Operations

Directorate

2 Ensure PPE and HALO delivery and launch dates are realistic

by including sufficient schedule margin in their development

schedules.

Anticipated 

Page 5 of 7
Report Number Report Date Report Title Responsible Org Name Recom. Number Recom. Description 

IG21004 10/1/2020 NASA's Management of the Gateway Program

for Artemis Missions

Human Exploration and Operations

Directorate

3 Develop a HEOMD policy that establishes a reasonable

amount of recommended schedule margin by phase of

program or project.

Anticipated 

IG21004 10/1/2020 NASA's Management of the Gateway Program

for Artemis Missions

Human Exploration and Operations

Directorate

5 Work with the contractors to obtain a credit for the amount

already spent on launch services under the PPE contract.

Anticipated 

IG21004 10/1/2020 NASA's Management of the Gateway Program

for Artemis Missions

Human Exploration and Operations

Directorate

6 Take action to enforce NASA policy to definitize contracts

within 6 months of award.

Anticipated 

IG21004 10/1/2020 NASA's Management of the Gateway Program

for Artemis Missions

Human Exploration and Operations

Directorate

8 Ensure the maturity of system requirements are fully

understood before selecting the acquisition method and

contract type for future acquisition strategies supporting

Artemis and Mars missions by describing the state of the

program requirements in the acquisition strategymemorandum for each new acquisition.

NASA Actio

for closure 

IG21001 10/2/2020 Audit of NASA’s Compliance with the

Geospatial Data Act

Chief Information Officer 4 Collaborate with NARA to determine if there is value in

establishing affiliated data archive agreements for NASA’s

remote sensing/earth observing geospatial data assets.

Anticipated 

IG21001 10/2/2020 Audit of NASA’s Compliance with the

Geospatial Data Act

Science Mission Directorate 2 Develop a unified Strategy Implementation Plan or

“Roadmap” that defines detailed action items, milestones, and

responsibilities for geospatial data management in support ofmissions across NASA

Anticipated 

IG21001 10/2/2020 Audit of NASA’s Compliance with the

Geospatial Data Act

Chief Information Officer 3 Develop records schedules in coordination with NARA for

NASA’s historically significant geospatial data assets

Anticipated 

IG21002 10/27/2020 NASA’s Management of Its Acquisition

Workforce

Procurement 1 Finalize and fully implement the performance metrics

dashboard to measure acquisition performance

Anticipated 

IG21002 10/27/2020 NASA’s Management of Its Acquisition

Workforce

Procurement 2 Document contract assignments to COs, CORs, and

program/project managers in a centralized system for

inclusion in the performance metrics dashboard.

Anticipated 

IG21002 10/27/2020 NASA’s Management of Its Acquisition

Workforce

Procurement 4 Take action to ensure that active CORs that have not met

continuous learning requirements are removed from their

COR position in a timely manner.

Anticipated 

IG21006 12/3/2020 NASA’s Management of Hazardous Materials. Strategic Infrastructure 5 Assess various options for development and implementation

of an Agency‐wide hazardous materials information system

that tracks hazardous materials throughout the life cycle, and

ensure processes are in place to consistently maintain a

complete and accurate inventory

Anticipated 

IG21006 12/3/2020 NASA’s Management of Hazardous Materials. Safety & Mission Assurance 6 Develop and implement an Agency‐wide policy that

establishes a standard for storage spaces and facilities used to

house hazardous materials.

Anticipated 

IG21006 12/3/2020 NASA’s Management of Hazardous Materials. Safety & Mission Assurance 7 Require Center Directors to inspect and replace, as required,

laboratory hazardous material storage structures and improve

shelters that do not meet CDC or Agency requirements.

Anticipated 

IG21010 12/22/2020 Fiscal Year 2020 Federal Information Security

Modernization Act Evaluation – An Agency

Common System

Chief Information Officer 3 Assign the personnel resources necessary to ensure the

Agency’s security plans for systems that inherit the controlswithin the Agency’s new hybrid common controls system areupdated and that those hybrid controls are removed from the

ACS system security

Anticipated 

IG21010 12/22/2020 Fiscal Year 2020 Federal Information Security

Modernization Act Evaluation – An Agency

Common System

Chief Information Officer 4 Establish a process to ensure that cost estimates are

developed and included for all POA&Ms for the ACS system

prior to their establishment and approval in RISCS to ensure

that costs are properly captured and included in submissionsto OMB.

Anticipated 

Page 6 of 7
Report Number Report Date Report Title Responsible Org Name Recom. Number Recom. Description 

IG21011 1/27/2021 NASA’s Efforts to Mitigate the Risks Posed by

Orbital Debris

International & Interagency Relations 1 Lead national and international collaborative efforts to

mitigate orbital debris including activities to encourage activedebris removal and the timely end‐of‐mission disposal of

spacecraft

Anticipated 

IG21011 1/27/2021 NASA’s Efforts to Mitigate the Risks Posed by

Orbital Debris

International & Interagency Relations 2 Collaborate with Congress, other federal agencies, and

partners from the private and public sectors to adopt national

and international guidelines on active debris removal and

strategies for increasing global compliance rates for timely

removal of spacecraft at the end of a mission

Anticipated 

IG21011 1/27/2021 NASA’s Efforts to Mitigate the Risks Posed by

Orbital Debris

Space Technology Mission Directorate 3 Invest in methods and technologies for removing defunct

spacecraft. As part of this effort, conduct a study evaluating

the technical merit and cost to investing in active debris

removal systems and technologies

Anticipated 

IG21011 1/27/2021 NASA’s Efforts to Mitigate the Risks Posed by

Orbital Debris

Science Mission Directorate 4 Prioritize obtaining direct measurements needed to fill the 3

mm and smaller sized debris gap at the 600 to 1,000 km

altitude in LEO

Anticipated 

IG21011 1/27/2021 NASA’s Efforts to Mitigate the Risks Posed by

Orbital Debris

Safety & Mission Assurance 5 Explore alternative orbital debris radar assets to fill the data

gaps caused by the increased costs of utilizing existing radarsand the loss of legacy assets.

Anticipated 

IG21011 1/27/2021 NASA’s Efforts to Mitigate the Risks Posed by

Orbital Debris

Safety & Mission Assurance 6 Explore commercial alternatives to obtaining information on

debris smaller than 10 cm until Space Fence becomes fully

operational

NASA Actio

for closure 

IG21011 1/27/2021 NASA’s Efforts to Mitigate the Risks Posed by

Orbital Debris

Safety & Mission Assurance 7 Coordinate with Mission Directorate officials to develop and

document a formal signature process that clarifies needs and

expectations and supports the timely delivery of ODARs and

EOMPs prior to key decision point reviews

Anticipated 

Page 7 of 7
Appendix C: Reconciliation with NASA's OIGs' Semi‐Annual Report

Reports Reco

Total Public Reports and Recommendations as of 9/30/21 [per NASA OIG Semi‐

Annual Report] 42 

Minus: Public Reports and Recommendations Open Less than One Year But

Included in OIG Semi‐Annual Report 16 

Net Public Reports and Recommendations Open More than One Year (as of

9/30/19) 26 

Plus: Additonal Public Reports and Recommendations Open More Than One

Year as of 10/1/19 10 

Minus: Public Reports and Recommendations Open More than One Year on

9/30/19 but Closed During 10/1/21 ‐ 1/31/22 4 

Total Public Reports and Recommendations Open More than One Year

(as of 1/31/22) 40 

Reconciliation with OIG's September 30, 2021 Semi‐Annual Report

(As of 1/31/2022)

Page 1 of 1
Appendix D: Glossary of Abbreviations

Abbreviation Description

ABC Agency Baseline Commitment

ACS Agency Common System

AFR Agency Financial Report

CDC Center for Disease Control

CIO Chief Information Officer

CLPS Commercial Launch Provider Services

CO Contracting officers

COR Contracting officer’s representatives

DAAC Distributed Active Archive Centers

DOD Department of Defense

EGS Exploration Ground Systems

EOMPs End of Mission Plans

ESDIS Earth Science Data and Information System

EVM Earned Value Management

FPDS‐NG Federal Procurement Data System ‐ Next Generation

GAO Government Accountability Office

GISS Goddard Institute for Space Studies

GSDO Ground Systems Development and Operations

HALO Habitation and Logistics Outpost

HEOMD Human Exploration and Operations Mission Directorate

HPD Heliophysics Division

ICT Information and Communications Technology

IT Information technology

JCL Joint Confidence Level

KDP Key Decision Point

LEO Lower Earth Orbit

MDM Mobile Device Management

ML‐2 Mobile Launcher‐2

NARA National Archives and Records Administration

NASA National Aeronautics and Space Administration

NEOO Near‐Earth Object Observations

NHPA National Historic Preservation Act

NICE National Initiative for Cybersecurity Education

NISAR NASA ISRO Synthetic Aperture Radar

NPD NASA Policy Directive

NPR NASA Procedural Requirements

NSWAP National Space Weather Action Plan

ODARs Orbital Debris Assessment Reports

OIG Office of the Inspector General

OMB Office of Management and Budget

OSTP Office of Science and Technology Policy

POA&M Plan of action and milestones

PPE Power and Propulsion Element

PSD Planetary Science Division

Page 1 of 2
Abbreviation Description

RISCS Risk Information Security Compliance System

SAISO Senior Agency Information Security Officer

SCCS Spaceport Command Control System

SCRM Supply Chain Risk Management

SLS Space Launch System

SOC Security Operations Center

SWORM Space Weather Operations, Research, and Mitigation

SWOT Surface Water and Topography

WBS Work Breakdown Structure

Page 2 of 2