NATIONAL AERONAUTICS AND SPACE ADMINISTRATION 

REPORT PURSUANT TO THE 

GOOD ACCOUNTING OBLIGATION IN GOVERNMENT ACT OF 2019 

(P.L. 115-414) 

As of December 31, 2023 
2 

Table of Contents

Background................................................................................................................................................... 3

Summary....................................................................................................................................................... 3

Reporting Methodology and Report Structure.............................................................................................. 3

Appendix A................................................................................................................................................... 5

GAO Recommendations Open One Year or More ................................................................................... 5

Open, Actions Completed..................................................................................................................... 6

Open, Actions In-Progress.................................................................................................................. 10

Open, Agency Non-Concurrence........................................................................................................ 24

Appendix B................................................................................................................................................. 27

OIG Recommendations Open One Year or More................................................................................... 27

Open, Actions Completed................................................................................................................... 28

Open, Actions In-Progress.................................................................................................................. 29

Appendix C................................................................................................................................................. 56

Reconciliation of Agency Records with NASA OIG Semiannual Report and GAO’s Database 

of Open Recommendations..................................................................................................................... 56

Appendix D................................................................................................................................................. 58

Glossary of Acronyms ............................................................................................................................ 58

 
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NASA’S REQUIRED REPORTING UNDER THE GOOD ACCOUNTING 

OBLIGATION IN GOVERNMENT ACT OF 2019 (P.L. 115-414) 

Background 

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

The Act was envisioned to improve transparency into long-standing audit recommendations 

issued by the Government Accountability Office (GAO) and Federal Offices 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 a year or 

more 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 be “closed, unimplemented.” For both categories of recommendations – open and closed, 

unimplemented – Federal agencies are required to provide an explanation as to why final action1

has not yet been completed. Finally, the Act also requires agencies perform a reconciliation of 

discrepancies between recommendations reported by GAO and their OIGs and the 

recommendations according to their agency records. 

Summary 

As of December 31, 2023, a combined total of 106 GAO and NASA OIG recommendations in 

45 public reports were open for one year or more. Of these recommendations, 39 were issued by 

GAO in 18 reports and 67 were issued by the NASA OIG in 27 reports. There were no 

recommendations in GAO reports that were closed, unimplemented that had not already been 

disclosed in prior reports issued in accordance with P.L. 115-414. NASA reconciled GAO’s 

online database of recommendations and the recommendations reported in OIG’s 2023 Fall 

Semiannual Report with its records. 

Reporting Methodology and Report Structure 

 

This report includes GAO and NASA OIG recommendations issued between May 8, 2014, to 

December 31, 2022, that remained unimplemented for one year or more from the planned fiscal 

year (FY) 2025 budget justification submission date in early calendar year 2024. 

1 Final Action: The completion of all actions that NASA management 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 

NASA management concludes no action is necessary, final action occurs when a management decision has been 

made. Source: 5 U.S.C. 405(a)(2). 
4 

This report contains four appendices: 

 Appendix A: GAO Recommendations Open One Year or More 

 Appendix B: OIG Recommendations Open One Year or More 

 Appendix C: Reconciliation of Agency records with NASA OIG Semiannual Report and 

GAO’s Database of Open Recommendations 

 Appendix D: Glossary of Acronyms 

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

to enhance the utility and readability of this report: 

 Open: Final action has either been completed and is pending auditor verification and 

validation or final action by NASA is pending/in-progress. 

 Closed: Final action and corresponding auditor verification and validation of completed 

necessary actions has been completed. 

 Closed, Unimplemented: Recommendation has been closed; however, final action has 

been partially completed, not completed, or action(s) not recommended have been taken. 

(Applicable only to GAO recommendations).

For recommendations NASA believes have been implemented, but the auditor has not yet 

completed its verification and validation of the corrective actions taken, this report indicates the 

status as “Open, Actions Completed.” For recommendations with which NASA and the auditors 

agreed with planned corrective actions, this report provides implementation status updates and 

timelines to complete planned corrective actions, as well as any budget implications to 

implementation for GAO recommendations. These recommendations are considered “Open, 

Actions In-Progress.” Recommendations are considered “Open, Agency Non-Concurrence” 

where NASA disagreed with the recommendation and does not plan to take corrective action; 

however, no decision by the auditor has been made yet to close the unimplemented 

recommendation. 

   
5 

Appendix A 

GAO Recommendations Open One Year or More
6 

Open, Actions Completed 

1. Report: Telecommunications: Agencies Need Better Controls to Achieve Significant 

Savings on Mobile Devices and Services (GAO-15-431; 5/21/2015) 

Recommendation: (28) To help the agency effectively manage spending on mobile 

devices and services, the Administrator of the National Aeronautics and Space 

Administration should ensure a complete inventory of mobile devices and associated 

services is established. 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of the Chief Information Officer 

Target Completion Date: n/a

2. Report: Telecommunications: Agencies Need Better Controls to Achieve Significant 

Savings on Mobile Devices and Services (GAO-15-431; 5/21/2015) 

Recommendation: (29) To help the agency effectively manage spending on mobile 

devices and services, the Administrator of the National Aeronautics and Space 

Administration should ensure a reliable inventory of mobile service contracts is 

developed and maintained. 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of the Chief Information Officer 

Target Completion Date: n/a

3. Report: Telecommunications: Agencies Need Better Controls to Achieve Significant 

Savings on Mobile Devices and Services (GAO-15-431; 5/21/2015) 

Recommendation: (30) To help the agency effectively manage spending on mobile 

devices and services, the Administrator of the National Aeronautics and Space 

Administration should ensure procedures to monitor and control spending are established 

Agency-wide. Specifically, ensure that (1) procedures include assessing devices for zero, 

under, and over usage; (2) personnel with authority and responsibility for performing the 

procedures are identified; and (3) the specific steps to be taken to perform the process are 

documented. 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of the Chief Information Officer 

Target Completion Date: n/a 

4. Report: Cybersecurity Workforce: Agencies Need to Accurately Categorize Positions to 

Effectively Identify Critical Staffing Needs (GAO-19-144; 3/12/2019) 
7 

Recommendation: (24) To complete the appropriate assignment of codes to their 

positions performing (information technology) IT, cybersecurity, or cyber-related 

functions, in accordance with the requirements of the Federal Cybersecurity Workforce 

Assessment Act of 2015, the Administrator of the National Aeronautics and Space 

Administration should take steps to review the assignment of the “000” code to any 

positions at NASA in the 2210 IT management occupational series, assign the 

appropriate National Initiative for Cybersecurity Education (NICE) framework work role 

codes, and assess the accuracy of position descriptions. 

Status:  NASA Action Completed 

Office of Primary Responsibility: Office of the Chief Human Capital Officer 

Target Completion Date: n/a

5. Report: NASA Lunar Programs: Opportunities Exist to Strengthen Analyses and Plans 

for Moon Landing (GAO-20-68; 12/19/2019) 

Recommendation: (6) The NASA Administrator should ensure that the Office of the 

Chief Engineer determines 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. 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of the Chief Engineer

Target Completion Date: n/a 

6. Report: Telecommunications: Agencies Should Fully Implement Established Transition 

Planning Practices to Help Reduce Risk of Costly Delays (GAO-20-155; 4/7/2020) 

Recommendation: (21) The Administrator of the National Aeronautics and Space 

Administration should ensure that the agency’s Chief Information Officer updates the 

telecommunications inventory to include all telecommunications assets and services in 

use at the agency, and updates NASA’s process for ongoing maintenance of the inventory 

to include the complete inventory. 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of the Chief Information Officer

Target Completion Date: n/a 

7. Report: Telecommunications: Agencies Should Fully Implement Established Transition 

Planning Practices to Help Reduce Risk of Costly Delays (GAO-20-155; 4/7/2020) 
8 

Recommendation: (22) The Administrator of the National Aeronautics and Space 

Administration should ensure that the agency’s Chief Information Officer completes 

efforts to identify the agency’s future telecommunications needs using a complete 

inventory of existing telecommunications services. 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of the Chief Information Officer

Target Completion Date: n/a 

8. Report: Telecommunications: Agencies Should Fully Implement Established Transition 

Planning Practices to Help Reduce Risk of Costly Delays (GAO-20-155; 4/7/2020) 

Recommendation: (23) The Administrator of the National Aeronautics and Space 

Administration should ensure that the agency’s Chief Information Officer identifies 

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. 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of the Chief Information Officer

Target Completion Date: n/a 

9. Report: Telecommunications: Agencies Should Fully Implement Established Transition 

Planning Practices to Help Reduce Risk of Costly Delays (GAO-20-155; 4/7/2020) 

Recommendation: (24) The Administrator of the National Aeronautics and Space 

Administration should ensure that the agency’s Chief Information Officer conducts an 

analysis to support the anticipated cost savings identified as part of the agency’s 

justification for its resource requests related to hardware and software upgrades for the 

telecommunications transition, and justifies its resource requests for transition 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. 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of the Chief Information Officer

Target Completion Date: n/a 

10. Report: Telecommunications: Agencies Should Fully Implement Established Transition 

Planning Practices to Help Reduce Risk of Costly Delays (GAO-20-155; 4/7/2020) 

Recommendation: (25) The Administrator of the National Aeronautics and Space 

Administration should ensure that the agency’s Chief Information Officer takes into 
9 

account the agency’s mission critical systems and contingency plans in NASA’s 

telecommunications transition timeline. 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of the Chief Information Officer

Target Completion Date: n/a 

11. Report: Federal Contracting: Senior Leaders Should Use Leading Companies’ Key 

Practices to Improve Performance (GAO-21-491; 7/27/2021) 

Recommendation: (10) The Administrator of NASA should ensure the NASA SPE uses 

a balanced set of performance metrics to manage the agency’s procurement 

organizations, including outcome-oriented metrics to measure (a) cost savings/avoidance, 

(b) timeliness of deliveries, (c) quality of deliverables, and (d) end-user satisfaction. 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of Procurement 

Target Completion Date: n/a

12. Report: Privacy: Dedicated Leadership Can Improve Programs and Address Challenges

(GAO-22-105065; 9/22/2022)

Recommendation: (48) The Administrator of NASA should incorporate privacy into an 

organization-wide risk management strategy that includes a determination of risk 

tolerance. 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of the Chief Information Officer

Target Completion Date: n/a

13. Report: Privacy: Dedicated Leadership Can Improve Programs and Address Challenges

(GAO-22-105065; 9/22/2022)

Recommendation: (49) The Administrator of NASA should fully define and document 

the role of the senior agency official for privacy or other designated privacy official in 

reviewing and approving system categorizations, overseeing privacy control assessments, 

and reviewing authorization packages. 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of the Chief Information Officer

Target Completion Date: n/a 
10 

Open, Actions In-Progress 

14. Report: NASA: Actions Needed to Improve Transparency and Assess Long-Term 

Affordability of Human Exploration Programs (GAO-14-385; 5/8/2014) 

Recommendation: (1) To provide the Congress with the necessary insight into program 

affordability, ensure its ability to effectively monitor total program costs and execution, 

and to facilitate investment decisions, the NASA’s Administrator should direct the 

Human Exploration and Operations Mission Directorate to establish a separate cost and 

schedule baseline for work required to support the SLS Block I Exploration Mission 2 

(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. 

Status: NASA successfully launched Artemis I and plans to use the Block 1 

configuration for Artemis II and III. The Artemis II baseline for the Orion capsule was 

rebaselined in 2021 and is up to date, with no indications that a cost-overrun will occur 

prior to launch. As a part of the budget submission process, both Space Launch System 

(SLS) and Exploration Ground Systems (EGS) programs will provide an update to the 

five-year operational cost estimate in spring 2024, which includes associated Artemis II 

costs. An update to the schedule for Artemis II launch readiness moving to September 

2025 was announced in January 2024 by the Agency. 

In October 2023, a separate Agency Baseline Commitment (ABC) was established for the 

SLS Exploration Upper Stage (EUS) and its Associated Capabilities (EUS + CAPS) 

upgrades supporting Block 1B. The SLS Block 1B configuration will begin flying on 

Artemis IV.

Budget Implications: None Known 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: March 15, 2024

15. Report: NASA: Actions Needed to Improve Transparency and Assess Long-Term 

Affordability of Human Exploration Programs (GAO-14-385; 5/8/2014)

Recommendation: (3) To provide the Congress with the necessary insight into program 

affordability, ensure its ability to effectively monitor total program costs and execution, 

and to facilitate investment decisions, because NASA intends to use the increased 

capabilities of the SLS, Orion, and Ground Systems Development and Operations efforts 

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

capabilities, the NASA’s Administrator should direct the Human Exploration and 

Operations Mission Directorate to establish separate cost and schedule baselines for each 

additional capability that encompass all life cycle costs, to include operations and 
11 

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. 

Status: The SLS Program successfully completed the SLS EUS + CAPS upgrades 

supporting Block 1B (described herein after as Block 1B) Key Decision Point (KDP) C 

milestone decision gate. This established an ABC for the SLS Block 1B approved by the 

Decision Authority (NASA Associate Administrator) in October 2023. 

Currently, the EGS program is preparing for the next key decision point for the Mobile 

Launcher 2 (ML-2), which will include setting an ABC covering both cost and schedule. 

Both SLS Block 1B and ML-2 are progressing to be ready for Artemis IV. As of 2022, 

SLS and EGS started reporting a yearly five-year operational cost estimate for the 

Block 1 and Mobile Launcher 1 (ML-1) costs; the next update is anticipated in spring 

2024 in conjunction with the budget process.

Budget Implications: None Known 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: June 30, 2024 

16. Report: Space Launch System: Resources Need to be Matched to Requirements to 

Decrease Risk and Support Long Term Affordability (GAO-14-631; 7/23/2014)

Recommendation: (2) To provide the Congress with the necessary insight into program 

planning and affordability, and to decrease the risk of cost and schedule overruns, 

NASA’s Administrator should direct the Human Exploration and Operations Mission 

Directorate to take the following action: 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 effort within the SLS program. In doing so, NASA should require 

each increment to complete both the technical and programmatic reviews required of 

other major development projects, per the Agency’s acquisition and system engineering 

policies. 

Status: In October 2023, an ABC was established for the SLS EUS + CAPS which will 

fly on Artemis IV. In accordance with NASA Procedural Requirements (NPR) 7120.5, 

NASA Space Flight Program and Project Management Requirements. Additionally, the 

SLS Program plans to establish a separate ABC for the SLS Block 2 variant no earlier 

than six months following the Block 2 Preliminary Design Review, currently slated for 

June 2025. The Agency will seek to close this recommendation. 

Budget Implications: None Known 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate
12 

Target Completion Date: March 15, 2024 

17. Report: Space Launch System: Resources Need to be Matched to Requirements to 

Decrease Risk and Support Long Term Affordability (GAO-14-631; 7/23/2014) 

Recommendation: (3) To provide the Congress with the necessary insight into program 

planning and affordability, and to decrease the risk of cost and schedule overruns, 

NASA’s Administrator should direct the Human Exploration and Operations Mission 

Directorate to take the following action: Provide decision makers 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. 

Status: The SLS Program successfully completed the SLS EUS + CAPS upgrades 

supporting Block 1B KDP-C milestone decision gate, which established an ABC for the 

SLS Block 1B approved by the Decision Authority in October 2023. Additionally, 

within the already noted life-cycle approach, the Program plans to establish the SLS 

Block 2 ABC no earlier than six months following the Block 2 Preliminary Design 

Review, currently slated for June 2025. 

As a part of the KDP-E Operational Readiness Review, five-year operational cost 

estimates were developed for steady state production and operations costs. These include 

labor, indirect costs, and variable costs such as procurement long-lead materials, 

production lead times, and minor development/obsolesce. This five-year rolling estimate 

is applicable to production and operations of the Block 1 variant for Artemis II and 

beyond. Excluded from the five-year rolling estimate are the major upgrades for Block 

1B, Block 2 and restart/recertification of RS-25 production line. The Agency will seek to 

close this recommendation.

Budget Implications: None Known 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate

Target Completion Date: March 15, 2024 

18. Report: NASA Information Technology: Urgent Action Needed to Address Significant 

Management and Cybersecurity Weaknesses (GAO-18-337; 5/22/2018) 

Recommendation: (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. 
13 

Status: The Enterprise Cybersecurity Risk Management Office has submitted a Strategy 

document that identifies that need to ensure that 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 are included. 

Budget Implications: None Known 

Office of Primary Responsibility: Office of the Chief Information Officer

Target Completion Date: February 29, 2024 

19. Report: NASA Commercial Crew Program: Plan Needed to Ensure Uninterrupted Access 

to the International Space Station (GAO-18-476; 7/11/2018)

Recommendation: (4) After completing the agency certification review, NASA’s Chief 

Engineer and Chief of Safety and Mission Assurance, with support from 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. 

Status: Boeing and NASA continue to make progress mitigating safety critical technical 

issues as we progress toward Crew Flight Test (CFT) planned for the 3rd Quarter of 

calendar year (CY) 2024. 

Boeing has removed and replaced a significant amount of flammable tape from the CFT 

spacecraft electrical wiring. Boeing’s Starliner spacecraft wiring now complies with CFT 

flight requirements. Likewise, Boeing and NASA have been mitigating previously 

identified spacecraft landing parachute issues. Parachute issue mitigation steps has 

recently culminated with a parachute drop test to gather critical safety information. Final 

data analysis is ongoing; however, an initial quick look indicates the test was successfully 

and planned safety data was collected. 

These efforts, along with continuing spacecraft, launch vehicle, and ground systems 

verification closure efforts continue to support a planned launch date by 3rd Quarter CY 

2024. A request for extension was submitted to GAO and approved. 

Budget Implications: None Known 

Office of Primary Responsibility: Space Operations Mission Directorate 

Target Completion Date: September 30, 2024 

20. Report: Scientific Integrity Policies: Additional Actions Could Strengthen Integrity of 

Federal Research (GAO-19-265; 4/4/2019) 
14 

Recommendation: (10) The Administrator of NASA should develop documented 

procedures for identifying and addressing alleged violations of its scientific integrity 

policy. 

Status:  A revised Scientific Integrity (SI) policy implementation handbook is to be 

released on or around February 12, 2024. NASA Policy Directive (NPD) 1920.1A, 

Scientific and Research Integrity – which underpins the implementation handbook – was 

approved in December 2023. The implementation handbook includes detailed processes 

for adjudicating and reporting potential SI violations.

Budget Implications: None Known 

Office of Primary Responsibility: Office of the Chief Scientist 

Target Completion Date: February 12, 2024 

21. Report: NASA Human Space Exploration: Persistent Delays and Cost Growth Reinforce 

Concerns over Management of Programs (GAO-19-377; 6/19/2019)

Recommendation: (3) We recommend the NASA Administrator ensure that 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. 

Status: The EGS Program completed the ML-2 Critical Design Review (CDR) Step 1 

(which focused on ML-2 Hardware and Programmatics) in accordance with NPR 7120.5 

and NPR 7123.1, NASA Systems Engineering Processes and Requirements, in January 

2024. The ML-2 Step 1 CDR demonstrated that the ML-2 architecture and engineering 

meets functional and performance requirements for SLS Block 1B (with provisions for 

Block 2) and is ready for full-scale fabrication, assembly, integration, and Verification 

and Validation testing. The ML-2 Project Team met all entrance criteria, including 

completion of all subsystem 90 percent design reviews and successful completion of the 

integrated critical design review (iCDR) in March 2023, which was a major milestone on 

the Bechtel contract. The 3D model “fly-thru” that was presented in the iCDR and the 

Step 1 CDR provided evidence of a complete 3D model of the ML-2 design. The 

Agency will request closure of this recommendation. 

Budget Implications: None Known 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: March 15, 2024

22. Report: NASA Lunar Programs: Opportunities Exist to Strengthen Analyses and Plans 

for Moon Landing (GAO-20-68; 12/19/2019) 

Recommendation: (2) The NASA Administrator should ensure that the NASA 

Associate Administrator for Human Exploration and Operations directs the Gateway 
15 

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

Artemis III mission. 

Status: A joint cost and schedule confidence level (JCL) analysis was performed to 

support the Gateway Program’s planned readiness for KDP-I. This was made possible 

due to the successful completion of Engineering Change Proposal 19 Technical 

Evaluations and the Preliminary Design Review technical closeout in December 2022. 

The Gateway Program transitioned from formulation to implementation after a successful 

KDP-I held in July 2023. The Agency will seek to close this recommendation.

Budget Implications: None Known 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate

Target Completion Date: March 31, 2024 

23. Report: NASA Lunar Programs: Opportunities Exist to Strengthen Analyses and Plans 

for Moon Landing (GAO-20-68; 12/19/2019) 

Recommendation: (3) The NASA Administrator should ensure that the NASA 

Associate Administrator for Human Exploration and Operations directs the Gateway 

program to update its overall schedule for 2024 to add a KDP-II to occur before system 

integration. 

Status: The Gateway Program transitioned from formulation to implementation after a 

successful KDP-I held in July 2023. The program is currently focused on preparing for 

its next major life-cycle review milestone, the Gateway CDR-Informed Sync Review, 

anticipated no earlier than late CY 2024. Consistent with the tailoring approach applied 

to the life-cycle management of Tightly Coupled Programs, Gateway must complete this 

next step before a plan and schedule for future reviews can be confirmed. Given that an 

ABC was established to include schedule commitment, we will be submitting a request 

for closure.

Budget Implications: None Known 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate

Target Completion Date: March 31, 2024 

24. Report: NASA Lunar Programs: Opportunities Exist to Strengthen Analyses and Plans 

for Moon Landing (GAO-20-68; 12/19/2019) 

Recommendation: (4) The NASA Administrator should ensure that the NASA 

Associate Administrator for Human Exploration and Operations creates a life-cycle cost 

estimate for the Artemis III mission. 
16 

Status: The Artemis implementation is unique from other NASA activities in that the 

flexible architecture is a guiding principle within the Artemis program, enabling NASA 

to adapt to changing requirements, leverage partnerships, and achieve sustainable and 

cost-effective human exploration of the Moon and beyond. By embracing flexibility and 

innovation, NASA aims to establish a robust infrastructure and lay the foundation for 

future exploration missions to Mars and beyond. The approach NASA is pursuing 

ensures that capabilities are developed to meet the needs of the architecture. These 

developments are consistent with NASA policy and follow the development process as 

documented in NASA command media (i.e., NPR 7120.5). NASA recognizes OIG’s 

critical role in promoting Artemis accountability and transparency; however, imposing a 

flight-by-flight cost assessment as a benchmark on individual Artemis missions can 

potentially hinder the success, innovation, and long-term sustainability of space missions. 

A more balanced approach that considers both short-term cost containment and long-term 

mission objectives is essential for achieving meaningful and impactful exploration and 

scientific discovery in space. 

NASA utilizes a range of management and reporting tools to ensure transparency and 

accountability at the mission level for all stakeholders. These tools include project-level 

cost and schedule joint confidence level informed development commitments (including 

for major developmental upgrades), independent review at major life-cycle reviews and 

associated KDPs, documented and configuration-controlled mission definition baselines, 

by-mission schedule risk assessments, life-cycle cost estimates in Phase E, five-year 

rolling estimates consistent with guidance provided in 7120.5F, independent Agency 

financial auditing (including a twelfth consecutive unmodified clean finding in 2023), 

annual Agency budget requests, Agency-led baseline performance and major program 

reviews, independent reviews by the NASA Advisory Council and Aerospace Safety 

Advisory Panel, and multiple ongoing reviews from the governmental oversight entities. 

The Agency will request closure of this recommendation. 

Budget Implications: None Known 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate

Target Completion Date: February 28, 2024 

25. Report: NASA Human Space Exploration: Significant Investments in Future Capabilities 

Require Strengthened Management Oversight (GAO-21-105; 12/15/2020) 

Recommendation: (1) We recommend that the NASA Administrator ensure that the 

NASA Associate Administrator for Human Exploration and Operations Mission 

Directorate establish cost and schedule baselines for SLS Block 1B, SLS Block 2, Mobile 

Launcher 2, and Orion Docking System at their preliminary design reviews or as soon as 

practicable in advance of critical design reviews. 

Status: In October 2023, a separate ABC was established for the SLS EUS + CAPS 

upgrades supporting Block 1B. Currently, the EGS program is preparing for the next 

KDP for the ML-2, which will include setting an ABC covering both cost and schedule. 
17 

Both SLS Block 1B and ML-2 are progressing to be ready for Artemis IV. Orion 

Rebaseline documentation (included NASA Docking System (NDS) under the Design 

Development Test and Evaluation (DDT&E) cost estimate). NDS has passed the design 

phase, and hardware delivery is scheduled for Spring 2024. NDS is an element in the 

Artemis III vehicle integration. The Agency will seek to close this recommendation. 

Budget Implications: None Known 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: December 31, 2024 

26. Report: NASA Human Space Exploration: Significant Investments in Future Capabilities 

Require Strengthened Management Oversight (GAO-21-105; 12/15/2020) 

Recommendation: (2) We recommend that the NASA Administrator ensure that the 

NASA Associate Administrator for Human Exploration and Operations Mission 

Directorate directs the Exploration Systems Development organization to include cost, 

schedule, and technical performance updates for SLS Block 1B, SLS Block 2, Mobile 

Launcher 2, and the Orion Docking System in its quarterly program status reviews in 

order to maintain oversight of these development projects. 

Status: To ensure transparency and accountability at the mission level for all 

stakeholders, NASA utilizes a range of management and reporting tools. These tools 

include independent review at major life-cycle reviews and associated KDPs, 

documented and configuration-controlled mission definition baselines, by-mission 

schedule risk assessments, life-cycle cost estimates in Phase E, five-year rolling estimates 

consistent with guidance provided in NPR 7120.5F, independent Agency financial 

auditing (including a twelfth consecutive unmodified clean finding in 2023), annual 

Agency budget requests, Agency-led baseline performance and major program reviews, 

independent reviews by the NASA Advisory Council and Aerospace Safety Advisory 

Panel, and multiple ongoing reviews from the OIG and GAO. 

The Orion Rebaseline in 2021 includes the NDS under the DDT&E cost estimate. NDS 

hardware delivery is scheduled for Spring 2024. NDS is an element in the Artemis III 

vehicle integration. In October 2023, a separate ABC was established for the SLS EUS + 

CAPS upgrades supporting Block 1B. The SLS Block 1B configuration will begin flying 

on Artemis IV. Additionally, the SLS Program plans to establish a separate ABC for the 

SLS Block 2 variant no earlier than six months following the Block 2 Preliminary Design 

Review, currently slated for June 2025. The Agency will seek to close this 

recommendation. 

Budget Implications: None Known 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: March 31, 2024 
18 

27. Report: Federal Research: Agencies Need to Enhance Policies to Address Foreign 

Influence (GAO-21-130; 12/17/2020)

Recommendation: (7) The Administrator of the National Aeronautics and Space 

Administration should update the agency’s conflict of interest policy to include a 

definition on non-financial conflicts, such as the one developed by OSTP, and address 

these conflicts, both foreign and domestic. 

Status: In December 2023, the Office of Procurement (OP) partially addressed 

Recommendations 7 and 8 in GAO-21-130 by implementing a new conflict of interest 

disclosure policy for NASA grant recipients. To address the remaining components of 

recommendations 7 and 8, OP has developed draft policy to address conflict of 

commitment (COC) disclosure requirements. However, before OP can finalize that 

policy, we will need to review and incorporate, as necessary, forthcoming guidance from 

the Office of Science and Technology Policy (OSTP) regarding standardized COC 

disclosure forms. Once the OSTP guidance is released, we intend to finalize and release 

NASA’s COC disclosure policy for grant recipients by August 2024.

Budget Implications: None Known 

Office of Primary Responsibility: Office of Procurement 

Target Completion Date: October 1, 2024 

28. Report: Federal Research: Agencies Need to Enhance Policies to Address Foreign 

Influence (GAO-21-130; 12/17/2020)

Recommendation: (8) The Administrator of the National Aeronautics and Space 

Administration should document procedures, including roles and responsibilities for 

addressing and enforcing failures to disclose required information, both foreign and 

domestic. 

Status: In December 2023, OP partially addressed Recommendations 7 and 8 in GAO21-130 by implementing a new conflict of interest disclosure policy for NASA grant 

recipients. To address the remaining components of recommendations 7 and 8, OP has 

developed draft policy to address COC disclosure requirements. However, before OP can 

finalize that policy, we will need to review and incorporate, as necessary, forthcoming 

guidance from OSTP regarding standardized COC disclosure forms. Once the OSTP 

guidance is released, we intend to finalize and release NASA’s COC disclosure policy for 

grant recipients by August 2024. 

Budget Implications: None known 

Office of Primary Responsibility: Office of Procurement 

Target Completion Date: October 1, 2024

29. Report: NASA Lunar Programs: Significant Work Remains, Underscoring Challenges to 

Achieving Moon Landing in 2024 (GAO-21-330; 5/26/2021)
19 

Recommendation: (2) The NASA Administrator should ensure that the NASA Office of 

the Chief Engineer develop guidance to mitigate risks associated with delaying the 

establishment of high-level requirements early in the acquisition process when using 

service-type contracts and incorporate it in its reference guide or a similar document. 

Status: Following the initial response to the recommendation, NASA established the 

Chief Program Management Officer (CPMO) and transitioned program management 

related functions previously under the Office of the Chief Engineer (OCE) to the CPMO. 

The NASA response to this recommendation will now be provided by the CPMO. 

The CPMO, in coordination with OCE, drafted a Commercial Oriented Partnership Guide 

in summer 2023 and completed the comments disposition process. The document is 

intended to serve as a reference guide regarding program and project management 

approaches for commercially oriented partnerships used by NASA for space flight 

programs and projects. It includes examples of tailoring approaches used by human 

space flight programs and projects that have implemented commercial partnerships. It 

also includes considerations based on key observations from the examples of how 

programs and project adapted their program management strategies to advance nontraditional commercial-oriented partnerships. The guide will contribute to mitigating 

risks associated with delaying the establishment of high-level requirements early in the 

acquisition process when using service- or commercial-type contracts. There is 

additional work to finalize prior to publication in the NASA Technical Report System 

library and may be updated with other examples and/or use the information to inform 

future policy revisions (e.g., NPR 7120.5). Work is slowed by personnel challenges 

including a loss of support contractors involved in the effort. 

Budget Implications: None Known 

Office of Primary Responsibility: Chief Program Management Officer

Target Completion Date: April 30, 2024

30. Report: NASA Lunar Programs: Significant Work Remains, Underscoring Challenges to 

Achieving Moon Landing in 2024 (GAO-21-330; 5/26/2021) 

Recommendation: (3) The NASA Administrator, in coordination with the Associate 

Administrator for the Human Exploration and Operations Mission Directorate, should 

ensure the Gateway program, in advance of the Power and Propulsion Element (PPE) 

project’s confirmation review, assesses the solar electric propulsion thrusters’ technical 

risks and determine whether off-ramps—such as reduced requirements for PPE—are 

needed or whether the project’s schedule should be reassessed. 

Status:  The Gateway PPE assessed the Advanced Electric Propulsion System (AEPS) 

Thruster technical risk and, as part of Gateway Initial Capability (GIC), successfully 

completed a GIC JCL analysis in support of setting its ABC as approved by the Agency 

Program Management Council (APMC) in July 2023. The cost and schedule risks for 

PPE were included in this JCL analysis. Coupled with the delivery of the AEPS 

Qualification Model, the start of both acceptance and wear testing, and continued 
20 

manufacturing of flight AEPS hardware, we will request closure of this 

recommendation. 

Budget Implications: None Known 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate

Target Completion Date: March 31, 2024 

31. Report: Research Reliability: Federal Actions Needed to Promote Stronger Research 

Practices (GAO-22-104411; 7/28/2022)

Recommendation: (6) The Administrator of NASA should take steps to collect 

information to determine whether current policies and requirements are adequate to 

achieve transparency by ensuring research results and data are findable, accessible, and 

usable, and implement programmatic or policy changes, if needed. 

Status: NASA continues to use longstanding policies requiring findability, usability, and 

accessibility of its funded scientific research. 

NASA’s policies for applying the Findability, Accessibility, Interoperability, and 

Reusability (FAIR) principles in its funded research are documented in NASA’s Science 

Information Policy, available at: https://science.nasa.gov/researchers/openscience/science-information-policy/. In turn, that document links to the Science Mission 

Directorate’s (SMD) Policy Document SPD-41a (at: https://science.nasa.gov/spd-41/), 

and together, the two documents provide complete details on the application of these 

policies and their timelines, including links to at least 15 other policy documents 

governing aspects of this implementation, including timelines. This set documentation 

runs to several dozen pages, and full details can be found at those links and the links they 

contain. 

NASA’s efforts in its Science Information Policies predate the GAO audit in question, 

including NASA’s Transition to Open Science initiative. These efforts mandate that 

NASA’s research products be findable, accessible, interoperable, and reusable. The 

SMD has been leading these efforts since at least 2021, with preparatory actions 

extending to at least 2019. These FAIR requirements explicitly address the intent of the 

GAO recommendation that “research results and data are findable, accessible and usable” 

by requiring these exact conditions. Accordingly, NASA’s status on this 

recommendation is that we are in full compliance as demonstrated in the documentation 

cited above. 

Budget Implications: None Known 

Office of Primary Responsibility: Office of the Chief Scientist 

Target Completion Date: December 31, 2023 
21 

32. Report: Leading Practices: Agency Acquisition Policies Could Better Implement Key 

Product Development Principles (GAO-22-104513; 3/10/2022)

Recommendation: (8) The NASA Administrator should ensure that the NASA Office of 

the Chief Engineer update NASA acquisition policies to fully implement the following 

principle throughout development: applying iterative design approaches. 

Status: The OCE, in collaboration with the Office of the Chief Information Officer 

(OCIO), completed an assessment of the recommendations for the application of iterative 

design approaches. There are two sub-principles in work based on the GAO 

recommendation. 

• GAO found that NASA policies did not fully implement the leading subprinciple of using modern design tools during both hardware and software 

development that enable multiple design iterations (sub-principle #2.1) because 

the policies did not reference modern design tools for hardware. 

• GAO found that and sub-principle 3.3 (iterative design and testing to identify a 

minimum product or initial capability followed by subsequent releases) is not 

implemented. NPR 7120.7A, Information Technology Program Requirements,

requires a proof of concept to be incorporated into later developments, but a 

proof of concept is not equivalent to an initial release of capability, which can be 

used to solicit user feedback and inform subsequent projects. 

OCE is continuing to work with OCIO to provide clarification to policy documentation. 

Both organizations are evaluating if there are impacts to key organizations ahead of the 

update to policy documentation. We anticipate the work to be complete by the fall of 

2024. 

Budget Implications: None Known 

Office of Primary Responsibility: Office of the Chief Engineer 

Target Completion Date: April 25, 2024 

 

33. Report: Leading Practices: Agency Acquisition Policies Could Better Implement Key 

Product Development Principles (GAO-22-104513; 3/10/2022)

Recommendation: (9) The NASA Administrator should ensure that the NASA Office of 

the Chief Engineer update NASA acquisition policies to fully implement the following 

principle throughout development: incorporating feedback from users of initial 

capabilities.

Status: The CPMO needs to coordinate with stakeholders to evaluate how GAO’s 

concerns can be mitigated within policy – or to more clearly identify existing policy that 

satisfies GAO’s recommendation. If it is determined that an update to policy is required 

that represents more than an administrative edit, a new Request for Extension may be 

submitted. CPMO believes NASA is already meeting the recommendation’s intent and 

will work to more clearly identify existing policy that substantiates within the requested 

extension period. Since our previous Request for Extension, more urgent short-term 

priorities (e.g., Mars Sample Return (MSR) Independent Review Board Response Team) 
22 

have delayed action on this effort. CPMO needs more time to address the noted 

recommendation. 

Budget Implications: None Known 

Office of Primary Responsibility: Chief Program Management Officer

Target Completion Date: April 1, 2024 

34. Report: NASA Lunar Programs: Improved Mission Guidance Needed as Artemis 

Complexity Grows (GAO-22-105323; 9/8/2022)

Recommendation: (1) The NASA Administrator should ensure that the Chief Financial 

Officer, in coordination with the mission directorates, develops Artemis mission-level 

schedule management guidance. 

Status: The Artemis Campaign Division (ACD) Schedule Management Plan was 

published in July 2022. The ACD Schedule Management Plan process was validated 

with the successful implementation of JCL analysis informing Gateway Program KDP-C, 

Human Landing System (HLS) KDP-C, and SLS EUS + CAPS KDP-C. Decision 

Memos for each of these KDPs were released on January 9, 2024. The Office of the 

Chief Financial Officer (OCFO) coordinated with ACD on lessons learned from ACD 

Schedule Management Plan, and OCFO is working on updating Agency Schedule 

Management Handbook to reflect these lessons. The estimated date of completion for 

updated Agency Schedule Management Handbook is March 15, 2024. Additional 

lessons learned, as applicable to complex multi-mission programs, from the recent 

Agency MSR Independent Review Board will also be incorporated in Schedule 

Management Handbook.

Budget Implications: None Known 

Office of Primary Responsibility: Office of the Chief Financial Officer 

Target Completion Date: April 30, 2024 

35. Report: NASA Lunar Programs: Improved Mission Guidance Needed as Artemis 

Complexity Grows (GAO-22-105323; 9/8/2022)

Recommendation: (2) The NASA Administrator, in coordination with the relevant 

mission directorates, should ensure that NASA conducts a schedule risk analysis for the 

Artemis II mission as close as possible to completion of the Artemis I mission and update 

it as needed to incorporate schedule updates and new risks. 

Status: An Artemis II preliminary schedule risk analysis (SRA) was performed post 

Artemis I mission as planned. This preliminary SRA used program data from January 

2023 and allowed the Exploration Systems Development Mission Directorate Schedule 

Analysis Team to validate its methods and identify critical path items. The preliminary 

SRA did not include a complete view of the Artemis II risk posture; however, it did 

identify the Orion Crew Module/Crew Service Module assembly, integration, and 
23 

production milestone through EGS integrated operations as the main critical path drivers 

for Artemis II. 

The preliminary SRA is a schedule management tool but does not represent the only 

source of data utilized to inform the new Artemis II launch readiness date. Following the 

completion of the preliminary SRA, the Moon to Mars (M2M) Programs continued to 

evaluate findings from the flight and ground testing which have led to additional work 

and scope required in support of Artemis II. NASA concluded that these items (e.g., 

Orion Heatshield) posed a large enough safety risk that the manifest date needed to move. 

Additionally, ML-1 is undergoing integrated testing that has taken longer than planned as 

well as upgrades for the new crew escape system and a new liquid hydrogen sphere at the 

pad. Ensuring crew safety is the primary driver for the Artemis II schedule change. The 

Agency announced an updated schedule for Artemis II in January 2024, moving the 

launch readiness to September 2025. The Agency will request closure for this 

recommendation.

Budget Implications: None Known 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: March 31, 2024 

36. Report: NASA Lunar Programs: Improved Mission Guidance Needed as Artemis 

Complexity Grows (GAO-22-105323; 9/8/2022)

Recommendation: (4) The NASA Administrator should ensure that the Office of the 

Chief Human Capital Officer develops guidance that identifies a regular and recurring 

process for long-term Artemis workforce scenario planning to address future 

uncertainties, at least 5 years beyond the existing 5-year workforce plans. 

Status: NASA’s Policy Directive on Strategic Workforce Planning was published in 

February 2022 and established NASA’s three strategic workforce planning interests. 

These interests are to: 1) Create agility in the workforce, 2) Become more demanddriven (versus supply-driven) to respond to changes in the mission, and 3) Strategically 

shape the workforce to meet both near- and long-term goals and objectives. In the winter 

of 2022-2023 the NASA Mission Directorates drafted guidance that provided additional 

information, particularly addressing long-term plans, beyond what is in the one-year 

budget submission to support conversations regarding outyear workforce planning. This 

was released to the Centers in February 2023. In April 2023, all NASA Centers had 

provided initial analysis of long-term Mission Directorate plans in terms of impacts to 

local workforce and addressed any change of workforce strategy if needed. NASA will 

continue to conduct this workforce analysis annually to effectively respond to both 

known and uncertain mission demand and will be strategically shaped to provide the mix 

of skills to support NASA’s unique work roles. We formally submitted our response to 

GAO in the summer of 2023, meeting GAO’s requirements. GAO informed us they 

would let us know if they had any follow up, but we have heard nothing as of January 

2024. 
24 

Budget Implications: None Known 

Office of Primary Responsibility: Office of the Chief Human Capital Officer 

Target Completion Date: September 30, 2023

Open, Agency Non-Concurrence 

37. Report: NASA Information Technology: Urgent Action Needed to Address Significant 

Management and Cybersecurity Weaknesses (GAO-18-337; 5/22/2018) 

Recommendation: (3) The Administrator should direct the Chief Information Officer to 

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. 

Comments: NASA did not concur with the recommendation as NASA was conducting a 

comprehensive, Agency-wide assessment that was designed to ensure that NASA mission 

support resources are optimally structured to achieve the NASA mission. 

Office of Primary Responsibility: Office of the Chief Information Officer

Target Completion Date: n/a 

38. Report: NASA Lunar Programs: Significant Work Remains, Underscoring Challenges to 

Achieving Moon Landing in 2024 (GAO-21-330; 5/26/2021) 

Recommendation: (1) The NASA Administrator, in coordination with the Associate 

Administrator for the Science Mission Directorate, should ensure the Volatiles 

Investigating Polar Exploration Rover (VIPER) project office includes relevant 

development costs from the Resource Prospector project and the cost of the Commercial 

Lunar Payload Services task order for the delivery of VIPER to the lunar surface into its 

cost baseline. 

Comments: NASA did not concur with the recommendation. The VIPER mission was 

confirmed to enter the development phase on February 23, 2021, at a total life-cycle cost 

of $433.5M. This amount is reported as the ABC and includes the full development and 

operations costs for VIPER. As GAO noted, this amount does not include early 

technology development investments made by NASA, nor does it include the 

Commercial Lunar Payload Services (CLPS) delivery costs. The NASA ABC for VIPER 

includes only costs that are managed by the VIPER project which is, therefore, 

accountable for meeting the project budget and schedule commitments. The VIPER 

mission, implemented within SMD, is a significantly different and much more capable 

design than the Resource Prospector concept which evolved, over time, under the Human 

Exploration and Operations Mission Directorate (HEOMD), Space Technology Mission 

Directorate (STMD), and Office of the Chief Technologist. Development costs from RP 

are analogous to early technology development investments which typically precede our 
25 

missions. Costs for early technology development and for prior flights of instruments, 

spacecraft bus design, antennae or lander designs, etc., often referred to as design 

heritage, are not carried into the baseline cost of a later mission. 

NASA’s CLPS initiative represents an innovative approach to delivering science and 

technology payloads to the Moon and is not directly analogous to other launch services 

procured by NASA for SMD missions. NASA’s technical project management control 

over the newly developed CLPS-provided lunar surface delivery is significantly different 

from standard launches as procured by NASA’s Launch Service Program; with CLPS, 

NASA procures the surface delivery as a service and inherently has less ability to shape 

and control the launch integration and process. In addition, the CLPS task orders (TO) 

are not managed by the delivered payload(s) teams, such as VIPER, under the Planetary 

Science Division’s management. Every CLPS TO is managed by the CLPS project office 

at the Johnson Space Center for the SMD Deputy Associate Administrator for 

Exploration. CLPS TOs often cover launch and delivery services for multiple payloads at 

a time, and the cost of the TO cannot be accurately allocated to individual payloads. For 

these reasons, SMD is not including the CLPS cost in the Project ABC. 

NASA is transparent that the CLPS delivery costs are in addition to the VIPER ABC and 

required to achieve mission success. The VIPER payload will be accommodated on 

CLPS TO 20A, which contracts Astrobotic to deliver the VIPER rover. This is clearly 

documented in VIPER’s KDP-C Decision Memorandum, acknowledging the CLPS TO 

cost to deliver VIPER as $226.5M above VIPER’s cost of $433.5M. 

The absence of RP development and CLPS delivery costs from VIPER’s baseline cost 

will not deter or prohibit measuring VIPER’s progress and tracking cost performance. 

On the contrary, it will allow the performance of VIPER’s direct scope, which is under 

the Project Manager’s control, to be measured and tracked. 

Office of Primary Responsibility: Science Mission Directorate 

Target Completion Date: n/a 

39. Report: Research Reliability: Federal Actions Needed to Promote Stronger Research 

Practices (GAO-22-104411; 7/28/2022)

Recommendation: (5) The Administrator of NASA should collect information on 

relevant indicators of rigor to assess the research projects the agency funds, and 

implement steps, as needed, to promote strong research practices in future work.

Comments: NASA did not concur with the recommendation. NASA is committed to 

ensuring research reliability in the research projects that it funds. NASA believes that the 

best way to ensure research reliability is the peer review process, which has long been the 

gold standard for scientific credibility. Accordingly, NASA relies on the peer review 

process in the scientific community to assess research rigor, quality, transparency, and 

relevance of science proposals submitted to NASA, as well as the scientific journal 

publications arising from NASA-funded research. Furthermore, NASA is aware of little 

to no evidence of weak research practices in the research the Agency funds. Finally, 
26 

while NASA values the recommendation’s goal of promoting strong research practices in 

NASA-funded research, NASA lacks the resources that would be necessary to collect 

information on indicators of rigor. 

Office of Primary Responsibility: Office of the Chief Scientist 

Target Completion Date: n/a 

 

   
27 

Appendix B 

OIG Recommendations Open One Year or More 

   
28 

Open, Actions Completed 

1. Report: NASA’s Construction of Facilities (IG-21-027; 9/8/2021) 

Recommendation: (3) In coordination with the Mission Directorates, institute a process 

to ensure facility requirements are identified and funding sources are specified during a 

program’s development and implementation phases. 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of Strategic Infrastructure 

Target Completion Date: n/a 

2. Report: NASA’s Volatiles Investigating Polar Exploration Rover (VIPER) Mission (IG-22-

010; 4/6/2022) 

Recommendation: (3) Update NPR 7120.8 to require major acquisition projects that 

cost over $250 million to complete a JCL analysis. 

Status: NASA Action Completed 

Office of Primary Responsibility: Chief Program Management Officer

Target Completion Date: n/a 

3. Report: NASA’s Volatiles Investigating Polar Exploration Rover (VIPER) Mission (IG-22-

010; 4/6/2022) 

Recommendation: (4) Update NPR 7120.8 to require major acquisition projects that 

cost over $250 million to implement Earned Value Management (EVM). 

Status: NASA Action Completed 

Office of Primary Responsibility: Chief Program Management Officer

Target Completion Date: n/a 

4. Report: NASA’s Management of the Mobile Launcher 2 Contract (IG-22-012; 6/9/2022) 

Recommendation: (5) Issue policy guidance to reinforce current FAR and NASA FAR 

Supplement regulatory guidance for stopping or withholding payments to a contractor for 

significant deficiencies in business systems, such as the Earned Value Management 

System (EVMS). 

Status: NASA Action Completed 

Office of Primary Responsibility: Office of Procurement
29 

Target Completion Date: n/a 

Open, Actions In-Progress 

5. Report: NASA’s Management of Electromagnetic Spectrum (IG-17-012; 3/9/2017) 

Recommendation: (2) Incorporate the “Spectrum Guidance for NASA Small Satellite 

Missions” into formal NASA electromagnetic spectrum policies NPD 2570.5E, “NASA 

Electromagnetic Spectrum Management - Revalidated 9/13/16,” and NPR 2570.1C, 

“NASA Radio Frequency Electromagnetic Spectrum Management Manual.” 

Status: Language was added on NASA small satellite missions to NPD 2570.5E. 

Additionally, NPR 2570.1C includes language applicable to Agency spectrum users. 

NASA believes it is compliant with the recommendation and any further alteration would 

make the document non-compliant and unacceptable according to NASA’s rules. 

Office of Primary Responsibility: Space Operations Mission Directorate 

Target Completion Date: January 17, 2024 

6. Report: Audit of NASA’s Historic Property (IG-19-002; 10/22/2018) 

Recommendation: (2) Develop comprehensive procedures for identifying and 

managing heritage assets, including defining roles and responsibilities for the different 

NASA entities responsible for evaluating what historic items would most effectively be 

maintained by the Agency and considered as heritage assets. 

Status: Per the recommendations from the OIG (IG-19-002, Audit of NASA’s Historic 

Property), NASA is continuing to develop a comprehensive process to identify and 

manage our heritage assets. To accomplish this, NASA held a process identification and 

improvement (Lean Six Sigma Kaizen) event in January 2023 with participation from the 

OCFO, Office of Communications (OCOMM), and Office of Strategic Infrastructure 

(OSI). During the event, NASA documented the current and future state of the heritage 

assets process. NASA also developed a Heritage Assets Implementation Plan which 

included action items that aligned to the future state and were assigned to the appropriate 

organizations with expected completion dates. NASA has continued to work on the 

action items and is currently revising the implementation plan with dates of completion 

scheduled for summer 2024. 

Office of Primary Responsibility: Office of Communications 

Target Completion Date: July 1, 2024 

7. Report: Audit of NASA’s Historic Property (IG-19-002; 10/22/2018) 
30 

Recommendation: (3) Evaluate and justify the existing list of NASA- and contractorheld heritage assets to determine whether NASA is the most effective owner and what 

property the Agency will retain because of its historical value.

Status: Per the recommendations from the OIG (IG-19-002), NASA is continuing to 

develop a comprehensive process to identify and manage our heritage assets. To 

accomplish this, NASA held a process identification and improvement (Lean Six Sigma 

Kaizen) event in January 2023 with participation from OCFO, OCOMM, and OSI. 

During the event, NASA documented the current and future state of the heritage assets 

process. NASA also developed a Heritage Assets Implementation Plan which included 

action items that aligned to the future state and were assigned to the appropriate 

organizations with expected completion dates. NASA has continued to work on the 

action items and is currently revising the implementation plan with dates of completion 

scheduled for summer 2024. 

Office of Primary Responsibility: Office of Communications 

Target Completion Date: July 1, 2024 

8. Report: Audit of NASA’s Historic Property (IG-19-002; 10/22/2018) 

Recommendation: (5) Ensure NASA policies and procedures for using the proceeds 

from facilities leased under National Historic Preservation Act (NHPA) authority 

appropriately aligns with Agency goals to minimize excess facilities. 

Status: NPR 8800.15C, Real Estate Management Program, has been updated to address 

the recommendation cited in this audit. Currently the NPR is in the review cycle at the 

NASA leadership level, and OSI is expecting routing and approval to be completed 

within the next few months. 

Office of Primary Responsibility: Office of Strategic Infrastructure 

Target Completion Date: June 30, 2024 

9. Report: Management of NASA’s Europa Mission (IG-19-019; 5/29/2019) 

Recommendation: (9) 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. 

Status: SMD has engaged in ongoing dialog with the OIG, Office of the General 

Counsel (OGC), NASA Office of Jet Propulsion Laboratory Management and Oversight 

(NOJMO) and other stakeholders and has reassessed the process of isolating key project 

personnel from instrument selection. As a result, a draft policy paper has been prepared 

and is currently being reviewed by appropriate SMD senior officials. 

Office of Primary Responsibility: Science Mission Directorate 

Target Completion Date: April 26, 2024 
31 

10. Report: NASA’s Security Management Practices (IG-20-001; 10/21/2019) 

Recommendation: (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. 

Status: NASA evaluated Agency-wide jurisdictions and made site specific 

determinations including Department of Defense jurisdiction, “Concurrent Jurisdiction,” 

split arrangement between “Federal Exclusive Jurisdiction” and “Concurrent 

Jurisdiction,” and “Proprietary Jurisdiction.” 

Office of Primary Responsibility: Office of Protective Services 

Target Completion Date: January 18, 2024 

11. Report: NASA’s Security Management Practices (IG-20-001; 10/21/2019) 

Recommendation: (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. 

Status: In 2018, the Office of Protective Services (OPS) coordinated with NASA OGC 

and obtained their legal opinion that enabled NASA and OPS to pursue an administrative 

modification to the Space Act which will allow NASA security officers to carry firearms 

in their official duty off-Center while protecting NASA personnel and/or property. A 

copy of the referenced OGC memorandum, dated July 6, 2018, has been provided to the 

OIG. NASA has endorsed and sent forward to the Office of Management and Budget 

(OMB) the legislative proposal created by OPS every year since 2018, and it has yet to be 

enacted into law. For the 2022 cycle, NASA and OPS once again resubmitted the 

legislative proposal for consideration by the 117th Congress of the United States; 

however, it was not enacted. The OPS Assistant Administrator was informed that the 

Office of Legislative and Intergovernmental Affairs (OLIA) will initiate conversations 

with congressional staffers in pushing the legislative proposal for consideration by the 

118th Congress. 

Office of Primary Responsibility: Office of Protective Services 

Target Completion Date: February 28, 2024 

12. Report: NASA’s Management of Crew Transportation to the International Space Station 

(IG-20-005; 11/14/2019) 

Recommendation: (2) Correct identified safety-critical technical issues before the 

crewed test flights, including parachute, propulsion, and launch abort systems, to ensure 

sufficient safety margins exist. 
32 

Status: A request for extension was submitted and approved by the OIG. We should be 

on track to close the recommendation by September 30, 2024. The new date for the 

Boeing CFT is the 3rd Quarter of CY 2024. 

Office of Primary Responsibility: Space Operations Mission Directorate 

Target Completion Date: September 30, 2024 

13. Report: NASA’s Management of Distributed Active Archive Centers (IG-20-011; 3/3/2020) 

Recommendation: (1) In conjunction with Earth Science Data and Information System 

(ESDIS), once NISAR and Surface Water and Topography (SWOT) 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 Distributed Active Archive Centers (DAAC) footprint. 

Status: At present, NASA-ISRO Synthetic Aperture Radar’s (NISAR) launch readiness 

date is March 30, 2024. The recommendations assessment can be initiated following 

operationalization of the mission and once sufficient data has been realized. 

Office of Primary Responsibility: Science Mission Directorate 

Target Completion Date: March 31, 2024 

14. Report: NASA’s Management of Space Launch System Program Costs and Contracts (IG20-012; 3/10/2020) 

Recommendation: (2a) 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: Rebaselining Artemis I costs to 

appropriately and transparently track costs that include SLS development costs and 

activities tied to the first SLS launch. 

Status: The approach NASA is pursuing ensures that capabilities are developed to meet 

the needs of the architecture. These developments are consistent with NASA policy and 

follow the development process as documented in NASA command media (i.e., NPR 

7120.5). Both the SLS and EGS programs successfully completed KDP-E, effectively 

transitioning these programs into the operations phase of their life cycle for the SLS 

Block 1 and EGS ML-1 configuration. Completion of KDP-E required the programs to 

provide an initial capability estimate to the Chief Financial Officer, as well as a five-year 

estimate for operational costs that are distinct from any ongoing development projects or 

upgrades. The five-year estimate is in work for 2024. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: March 15, 2024 
33 

15. Report: NASA’s Management of Space Launch System Program Costs and Contracts (IG20-012; 3/10/2020) 

Recommendation: (2b) 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: Establishing methodologies 

and processes to track and set cost commitments for Artemis II. 

Status: The Artemis implementation is unique from other NASA activities in that the 

flexible architecture is a guiding principle within the Artemis program, enabling NASA 

to adapt to changing requirements, leverage partnerships, and achieve sustainable and 

cost-effective human exploration of the Moon and beyond. By embracing flexibility and 

innovation, NASA aims to establish a robust infrastructure and lay the foundation for 

future exploration missions to Mars and beyond. The approach NASA is pursuing 

ensures that capabilities are developed to meet the needs of the architecture. These 

developments are consistent with NASA policy and follow the development process as 

documented in NASA command media (i.e., NPR 7120.5). NASA recognizes OIG’s 

critical role in promoting Artemis accountability and transparency; however, imposing a 

flight-by-flight cost assessment as a benchmark on individual Artemis missions can 

potentially hinder the success, innovation, and long-term sustainability of space missions. 

A more balanced approach that considers both short-term cost containment and long-term 

mission objectives is essential for achieving meaningful and impactful exploration and 

scientific discovery in space. 

NASA utilizes a range of management and reporting tools to ensure transparency and 

accountability at the mission level for all stakeholders. These tools include project-level 

cost and schedule JCL-informed development commitments (including for major 

developmental upgrades), independent review at major life-cycle reviews and associated 

KDPs, documented and configuration-controlled mission definition baselines, by-mission 

schedule risk assessments, life-cycle cost estimates in Phase E, five-year rolling estimates 

consistent with guidance provided in NPR 7120.5F, independent Agency financial 

auditing (including a twelfth consecutive unmodified clean finding in 2023), annual 

Agency budget requests, Agency-led baseline performance and major program reviews, 

independent reviews by the NASA Advisory Council and Aerospace Safety Advisory 

Panel, and multiple ongoing reviews from the governmental oversight entities. The 

Agency will request closure of this recommendation. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: March 31, 2024 

16. Report: NASA’s Management of Space Launch System Program Costs and Contracts (IG20-012; 3/10/2020) 
34 

Recommendation: (2c) 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: 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). 

Status: NASA has re-examined and revised its life-cycle review policies to ensure 

greater transparency into cost tracing and estimating and to enhance existing reporting 

practices for external stakeholders. Progress has been made for all major programs, 

particularly the SLS Program. After successfully completing an independently reviewed 

Operational Readiness Review (ORR) in September 2021, SLS brought the ORR data 

forward to the Decisional Authority (NASA Associate Administrator) to reach KDP-E, 

effectively transitioning into the operations phase of their life cycle for the SLS Block 1. 

As part of the KDP-E Operational Readiness Review requirements, five-year operational 

cost estimates were developed for steady state production and operations costs. These 

include labor, indirect costs, and variable costs such as procurement long-lead materials, 

production lead times, and minor development/obsolesce. This five-year rolling estimate 

is applicable to production and operations of the Block 1 variant for Artemis II and 

beyond. Excluded from the five-year rolling estimate are the major upgrades for Block 

1B, Block 2, and restart/recertification of RS-25 production line. 

In October 2023, SLS successfully completed the SLS EUS + CAPS upgrades supporting 

Block 1B KDP-C milestone decision gate, which established an ABC for the SLS Block 

1B approved by the Decision Authority. Additionally, within the already noted life-cycle 

approach, SLS plans to establish a separate ABC for SLS Block 2 no earlier than six 

months following the Block 2 Preliminary Design Review, currently slated for June 2025. 

The Agency will seek to close this recommendation. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: March 15, 2024 

17. Report: Audit of NASA’s Development of Its Mobile Launchers (IG-20-013; 3/17/2020) 

Recommendation: (3) Ensure life-cycle and milestone reviews incorporate 

programmatic and technical risks and are conducted with the Associate Administrator for 

Human Exploration and Operations Mission Directorate and other senior Agency 

officials. 

Status: The EGS program is preparing for the next KDP-C in the life cycle for the ML2, which will include setting an ABC. A JCL analysis that incorporates both 

programmatic and technical risk is being performed and will be used to inform the ABC. 

This milestone will take place spring 2024. The Agency will seek to close this 

recommendation after the ABC is established and ML-2 is approved at an Agency 

Program Management Council by the Decision Authority (NASA Associate 

Administrator) to proceed into phase C of its life cycle. 
35 

Separately, an ABC was approved for the following capability upgrades and programs in 

fall 2023: SLS Block 1B EUS + CAPS, the Gateway Program initial capability, and for 

the HLS initial capability. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: June 30, 2024 

18. Report: Audit of NASA’s Development of Its Mobile Launchers (IG-20-013; 3/17/2020) 

Recommendation: (4) Require the ML-2 project to develop an ABC separate from the 

EGS Program. 

Status: The EGS program is preparing for the next KDP for the ML-2, which will 

include setting an ABC covering both cost and schedule. Construction on the ML-2 

began in August 2023 and is progressing to be ready for Artemis IV. As of 2022, the 

EGS Program started reporting a yearly five-year operational cost estimate for the ML-1 

costs; the next update is anticipated spring 2024. The Agency will seek to close this 

recommendation after the ABC is set and ML-2 is approved to proceed into phase C of its 

life cycle. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: June 30, 2024 

19. Report: NASA’s Management of the Orion Multi-Purpose Crew Vehicle Program (IG-20-

018; 7/16/2020) 

Recommendation: (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. 

Status: An update to the Artemis mission planning manifest is currently under way to 

include the new mission dates announced on January 9, 2024, for Artemis II and Artemis 

III. Artemis IV and V mission readiness and related production schedules will be 

assessed in the FY 2026 budget formulation process and used to inform the Agency 

budget submission. A request for extension will be submitted to align with FY 2026 

President’s budget release. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: February 28, 2025 

20. Report: NASA’s Planetary Science Portfolio (IG-20-023; 9/16/2020) 
36 

Recommendation: (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 the current budgetary and full cost accounting system 

to adequately fund and sustain critical technical discipline capabilities needed to support 

current and future projects. 

Status: SMD has been formulating a coordinated response across the OCFO and other 

parties per recent guidance from the OIG. SMD is expanding on its previous work 

towards implementation of the OIG’s corrective action and closure of this 

recommendation. 

Office of Primary Responsibility: Science Mission Directorate 

Target Completion Date: July 22, 2024 

21. Report: Audit of NASA’s Compliance with the Geospatial Data Act (IG-21-001; 10/2/2020)

Recommendation: (2) Develop a unified Strategy Implementation Plan or “Roadmap” 

that defines detailed action items, milestones, and responsibilities for geospatial data 

management in support of missions across NASA. 

Status: SMD is continuing to support the OCIO in its efforts to develop the 

implementation plan and specific details for geospatial management to support missions 

across NASA. 

Office of Primary Responsibility: Science Mission Directorate 

Target Completion Date: October 30, 2024 

22. Report: NASA’s Management of Its Acquisition Workforce (IG-21-002; 10/27/2020)

Recommendation: (1) Finalize and fully implement the performance metrics dashboard 

to measure acquisition performance. 

Status: In October 2023, NASA rolled out the Metrics Dashboards. This includes 

procurement metrics, NASA At A Glance, Contract Performance Assessment Reporting 

System (CPARS), Contracting Benchmarks, Procurement Administrative Lead Time 

(PALT), and many others. The functionality for contract assignments for Contracting 

Officers (CO) and Contracting Officer’s Representatives (COR) is under contract and the 

planned pilot is scheduled for May 2024. OP will coordinate with the CPMO to address 

the Program Manager requirement. 

Office of Primary Responsibility: Office of Procurement 

Target Completion Date: May 30, 2024 

23. Report: NASA’s Management of Its Acquisition Workforce (IG-21-002; 10/27/2020)
37 

Recommendation: (2) Document contract assignments to COs, CORs, and 

program/project managers in a centralized system for inclusion in the performance 

metrics dashboard. 

Status: In October 2023, NASA rolled out the Metrics Dashboards. This includes 

procurement metrics, NASA At A Glance, CPARS, Contracting Benchmarks, PALT, and 

many others. The functionality for contract assignments for COs and CORs is under 

contract and the planned pilot is scheduled for May 2024. OP will coordinate with the 

CPMO to address the Program Manager requirement. 

Office of Primary Responsibility: Office of Procurement 

Target Completion Date: May 30, 2024 

24. Report: NASA’s Management of the Gateway Program for Artemis Missions (IG-21-004; 

11/10/2020) 

Recommendation: (2) Ensure PPE and HALO delivery and launch dates are realistic by 

including sufficient schedule margin in their development schedules. 

Status: The Gateway Program transitioned from formulation to implementation after a 

successful KDP-I held in July 2023. The baseline development schedules for PPE and 

Habitation and Logistics Outpost (HALO) were taken into consideration in the Gateway 

Initial Capability KDP-I. The Gateway Program successfully completed a JCL analysis 

in support of setting its ABC that was approved by the Decisional Authority (NASA 

Associate Administrator). The Agency will request closure for this recommendation. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: July 31, 2023 

25. Report: NASA’s Management of the Gateway Program for Artemis Missions (IG-21-004; 

11/10/2020) 

Recommendation: (3) Develop a HEOMD policy that establishes a reasonable amount 

of recommended schedule margin by phase of program or project. 

Status: The establishment of the M2M Program Office under the leadership of the 

Exploration Systems Development Mission Directorate has enabled NASA to improve 

our approach to implementing our architecture by strengthening our integration and risk 

management across the programs. In order to document the new governance structure 

and successfully accomplish our missions, the M2M Implementation Plan development is 

in work to document the programmatic and management functions associated with the 

effective implementation of M2M in support of Artemis mission. Specifically, as it 

relates to this recommendation, schedule management and schedule margin will be 

addressed in the M2M Schedule Management Implementation Plan. 
38 

Previously, the ACD Schedule Management Plan formalized the processes and 

procedures necessary to manage the Artemis Mission Schedules throughout the Artemis 

missions’ design, development, and execution phases. The ACD Schedule Management 

Plan was published in July 2022 and the process within was validated with the successful 

implementation of JCL analysis informing the Gateway Program KDP-C and HLS’ KDPC. Related KDP documentation and decision memos were released in January 2024 to 

the OIG. The completion and approval of the M2M Schedule Implementation Plan will 

be used to request closure of this recommendation. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: August 31, 2024 

26. Report: NASA’s Efforts to Mitigate the Risks Posed by Orbital Debris (IG-21-011; 

1/27/2021) 

Recommendation: (1) Lead national and international collaborative efforts to mitigate 

orbital debris including activities to encourage active debris removal and the timely endof-mission disposal of spacecraft. 

Status: Mitigating orbital debris continues with U.S. Government-wide implementation 

of the White House National Orbital Debris Research and Development plan and broad 

use by domestic regulators of the NASA-updated U.S. Government Orbital Debris 

Mitigation Standard Practices. Internationally, NASA experts brief United Nations 

forums annually on the debris environment and encourage adherence to international 

debris mitigation guidelines. We will proceed to close out this recommendation. 

Office of Primary Responsibility: Office of International and Interagency Relations 

Target Completion Date: June 30, 2022 

27. Report: NASA’s Efforts to Mitigate the Risks Posed by Orbital Debris (IG-21-011; 

1/27/2021) 

Recommendation: (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. 

Status: Mitigating orbital debris continues with U.S. Government-wide implementation 

of the White House National Orbital Debris Research and Development plan and broad 

use by domestic regulators of the NASA-updated U.S. Government Orbital Debris 

Mitigation Standard Practices. Internationally, NASA experts brief United Nations 

forums annually on the debris environment and encourage adherence to international 

debris mitigation guidelines. We will proceed to close out this recommendation. 

Office of Primary Responsibility: Office of International and Interagency Relations 
39 

Target Completion Date: June 30, 2022 

28. Report: NASA’s Efforts to Mitigate the Risks Posed by Orbital Debris (IG-21-011; 

1/27/2021) 

Recommendation: (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. 

Status: NASA has invested in methods and technologies for removing defunct 

spacecraft. Selected relevant current investments include: 1) Small Business Innovation 

Research - ongoing investments in main line, Ignite, and Sequentials sub-programs cover 

many orbital debris areas; 2) Small Satellite Technology - several ongoing investments 

including autonomous collision avoidance, propulsion, and debris inspection; 3) Space 

Technology Research Grants - just-in-time collision avoidance and space-laser-based 

remediation concepts and graduate research in debris mitigation, tracking, and 

characterization; 4) Tech Demo Missions - On-orbit Servicing, Assembly, and 

Manufactoring-1 - Rendezvous, proximity operations, and capture of a (controlled) nonprepared (legacy) spacecraft, including sensors, computer vision, robotics and tools 

(a full list of the STMD orbital debris investments (FY 2022-2024) can be provided). 

NASA’s Office of Technology, Policy, and Strategy is currently conducting a Cost and 

Benefit Analysis of Orbital Debris Remediation. The study is complete through Phase I 

and Phase II is under way. 

Office of Primary Responsibility: Space Technology Mission Directorate 

Target Completion Date: January 31, 2024 

29. Report: NASA’s Construction of Facilities (IG-21-027; 9/8/2021) 

Recommendation: (1) Develop and institute an Agency-wide process to prioritize and 

fund institutional and programmatic Construction of Facilities (CoF) projects that align 

with Agency-level missions and require business case analyses to be completed and 

considered as part of the process prior to the projects’ approval. 

Status: OSI is currently re-writing the NPR 8810.1A, Center Master Planning. The rewrite of the NPR 8810.1A will address the recommendation as it will reflect the 

prioritization process that was approved along with the Agency Master Plan in October 

2023. 

Office of Primary Responsibility: Office of Strategic Infrastructure 

Target Completion Date: December 30, 2024 

30. Report: NASA’s Construction of Facilities (IG-21-027; 9/8/2021) 
40 

Recommendation: (2a) Revise NASA Procedural Requirements 8820.2G to define and 

establish parameters for the use of institutional and programmatic CoF funds and 

establish a cost-sharing method for facilities that will have more than one user. 

Status: NASA updated NPR 8820.2H, Facility Project Requirements (Updated with 

Change 1), which added Section 1.4, Cost Sharing of CoF Renewal Projects and 2.2.6.1, 

Cost-Sharing Discussion for Renewal Projects. In addition, NPR 8820.2H (Updated with 

Change 1) added a reference to the newly added section 1.4 in Section 1.2.2, Renewal 

(also known as Recapitalization) Projects and Section 1.6.2, Agency CoF Program 

Management Responsibilities as well as corrected the flowchart in Appendix I, Local 

and/or Program Funded Project Flowchart. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: January 16, 2024 

31. Report: NASA’s Management of the Artemis Missions (IG-22-003; 11/15/2021) 

Recommendation: (1) Develop a realistic, risk-informed schedule that includes 

sufficient margin to better align Agency expectations with the development schedule. 

Status: M2M Program maintains integrated mission schedules that are mature and 

informed by contractor milestones. Recently, M2M leveraged multiple sources of data, 

including known and emerging risks, to inform the new Artemis II launch readiness date. 

Following the completion of a preliminary schedule risk assessment, the M2M Program’s 

continued to evaluate findings from the flight and ground testing which have led to 

additional work and scope required in support of Artemis II. NASA concluded that these 

items (e.g., Orion Heatshield) posed a large enough safety risk that the manifest date 

needed to move. Ensuring crew safety is the primary driver for the Artemis II schedule 

change. An update to the Artemis integrated schedules is under way to include the new 

mission dates announced on January 9, 2024, for Artemis II and Artemis III, which are in 

September 2025 and September 2026, respectively. 

Information from the recent KDP-C life-cycle milestones for SLS EUS + CAPS (Block 

1B), Gateway Program, and HLS is factored into the assessment for Artemis III and IV 

schedules. Related KDP documentation and decision memos were released in January 

2024 to the OIG. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: March 30, 2024 

32. Report: NASA’s Management of the Artemis Missions (IG-22-003; 11/15/2021) 

Recommendation: (3) Develop an Artemis-wide cost estimate, in accordance with best 

practices, that is updated on an annual basis. 
41 

Status: The Artemis implementation is unique from other NASA activities in that the 

flexible architecture is a guiding principle within the Artemis program, enabling NASA 

to adapt to changing requirements, leverage partnerships, and achieve sustainable and 

cost-effective human exploration of the Moon and beyond. By embracing flexibility and 

innovation, NASA aims to establish a robust infrastructure and lay the foundation for 

future exploration missions to Mars and beyond. The approach NASA is pursuing 

ensures that capabilities are developed to meet the needs of the architecture. These 

developments are consistent with NASA policy and follow the development process as 

documented in NASA command media (i.e., NPR 7120.5). NASA recognizes OIG’s 

critical role in promoting Artemis accountability and transparency; however, imposing a 

flight-by-flight cost assessment as a benchmark on individual Artemis missions can 

potentially hinder the success, innovation, and long-term sustainability of space missions. 

A more balanced approach that considers both short-term cost containment and long-term 

mission objectives is essential for achieving meaningful and impactful exploration and 

scientific discovery in space. 

NASA utilizes a range of management and reporting tools to ensure transparency and 

accountability at the mission level for all stakeholders. These tools include project-level 

cost and schedule JCL-informed development commitments (including for major 

developmental upgrades), independent review at major life-cycle reviews and associated 

KDPs, documented and configuration-controlled mission definition baselines, by-mission 

schedule risk assessments, life-cycle cost estimates in Phase E, five-year rolling estimates 

consistent with guidance provided in NPR 7120.5F, independent Agency financial 

auditing (including a twelfth consecutive unmodified clean finding in 2023), annual 

Agency budget requests, Agency-led baseline performance and major program reviews, 

independent reviews by the NASA Advisory Council and Aerospace Safety Advisory 

Panel, and multiple ongoing reviews from the governmental oversight entities. The 

Agency will request closure of this recommendation. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: March 31, 2024 

33. Report: NASA’s Management of the Artemis Missions (IG-22-003; 11/15/2021) 

Recommendation: (4) Maintain an accounting of per-mission costs to increase 

transparency and establish a benchmark against which NASA can assess the outcome of 

initiatives to increase the affordability of ESD systems. 

Status: The Artemis implementation is unique from other NASA activities in that the 

flexible architecture is a guiding principle within the Artemis program, enabling NASA 

to adapt to changing requirements, leverage partnerships, and achieve sustainable and 

cost-effective human exploration of the Moon and beyond. By embracing flexibility and 

innovation, NASA aims to establish a robust infrastructure and lay the foundation for 

future exploration missions to Mars and beyond. The approach NASA is pursuing 

ensures that capabilities are developed to meet the needs of the architecture. These 

developments are consistent with NASA policy and follow the development process as 
42 

documented in NASA command media (i.e., NPR7120.5). NASA recognizes OIG’s 

critical role in promoting Artemis accountability and transparency; however, imposing a 

flight-by-flight cost assessment as a benchmark on individual Artemis missions can 

potentially hinder the success, innovation, and long-term sustainability of space missions. 

A more balanced approach that considers both short-term cost containment and long-term 

mission objectives is essential for achieving meaningful and impactful exploration and 

scientific discovery in space. 

NASA utilizes a range of management and reporting tools to ensure transparency and 

accountability at the mission level for all stakeholders. These tools include project-level 

cost and schedule JCL-level informed development commitments (including for major 

developmental upgrades), independent review at major life-cycle reviews and associated 

KDPs, documented and configuration-controlled mission definition baselines, by-mission 

schedule risk assessments, life-cycle cost estimates in Phase E, five-year rolling estimates 

consistent with guidance provided in NPR 7120.5F, independent Agency financial 

auditing (including a twelfth consecutive unmodified clean finding in 2023), annual 

Agency budget requests, Agency-led baseline performance and major program reviews, 

independent reviews by the NASA Advisory Council and Aerospace Safety Advisory 

Panel, and multiple ongoing reviews from the governmental oversight entities. The 

Agency will request closure of this recommendation. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: March 31, 2024 

34. Report: NASA’s Management of the Artemis Missions (IG-22-003; 11/15/2021) 

Recommendation: (6) Develop a realistic funding profile and schedule given the 

underfunding of HLS in FY 2021, the selection of one HLS award, and the desire to 

compete a sustainability contract for future lunar missions. 

Status: The APMC met in November 2023 and evaluated the readiness of the HLS 

Program initial capability to proceed to Phase C of its life cycle as defined in NPR 

7120.5F. The initial capability supports Artemis III, the first Artemis lunar landing 

mission. The Decisional Authority (NASA Associate Administrator) approved the HLS 

Program Initial Capability to enter Phase C and an ABC was established for cost and 

schedule. 

The HLS Program revised the acquisition approach from Lunar Exploration 

Transportation Services to Sustaining Lunar Development (SLD), which led to the award 

of two Firm Fixed Price contracts under NextSTEP-2 Broad Area Announce: 1) SpaceX 

(Appendix H Option B) in November 2022 and 2) Blue Origin (Appendix P) in May 

2023. Within the SLD acquisition approach, the HLS Program will establish a separate 

ABC for the sustaining capability (Appendix H Option B and Appendix P), which is an 

upgraded capability to support subsequent missions and a sustained presence on the lunar 

surface. The Agency will request closure for this recommendation. 
43 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: March 31, 2024 

35. Report: NASA’s Management of the International Space Station and Efforts to 

Commercialize Low Earth Orbit (IG-22-005; 11/30/2021) 

Recommendation: (1) Ensure the risks associated with cracks and leaks in the Service 

Module Transfer Tunnel are identified and mitigated prior to agreeing to an ISS life 

extension. 

Status: The International Space Station (ISS) Program continues to address this 

recommendation in accordance with the approved testing plan. Based on where the ISS 

team currently is with the investigation, an extension is needed and has been submitted to 

the OIG . 

Office of Primary Responsibility: Space Operations Mission Directorate 

Target Completion Date: January 31, 2025 

36. Report: NASA’s Management of Its Astronaut Corps (IG-22-007; 1/11/2022) 

Recommendation: (3) At least 18 months prior to the planned Artemis II launch, 

coordinate with Artemis program offices to complete the development and chartering of 

the framework of Artemis boards and panels to ensure alignment with future mission 

training needs for new vehicles and missions, including Orion, next-generation 

spacesuits, HLS, and Gateway. 

Status: The M2M Program Office under the leadership of the Exploration Systems 

Development Mission Directorate has enabled NASA to improve its approach to 

implementing architecture by strengthening integration and risk management across the 

programs. M2M has begun to document the governance structure. The M2M 

Implementation Plan and all of the associated plans are in work to document the 

programmatic and management functions associated with the effective implementation of 

M2M in support of Artemis missions. The plans are also being expanded to address 

humans in space. Crew safety is, and will remain, our top priority. 

There are several implementation plans tied to the content of this recommendation, in 

particular, the M2M Mission Integration Implementation Plan will capture the M2M 

Flight Operations Implementation Plan. There are also governing documents established 

to capture the charters of supporting boards and panels. M2M, under Systems, 

Engineering, and Integration, is also tracking the overall review plan outlining the path to 

certification to flight readiness and post flight analysis which drive lessons learned for 

future missions. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 
44 

Target Completion Date: August 31, 2024

37. Report: NASA’s Insider Threat Program (IG-22-009; 3/14/2022) 

Recommendation: (2) Improve cross-discipline communication by establishing a 

Working Group that includes OPS, OCIO, Procurement, human resources officials, and 

any other relevant Agency offices to collaborate on wide-ranging insider threat related 

issues for both classified and unclassified systems. 

Status: OPS is piloting a NASA Insider Threat Working Group (InTWG). An overview 

of the new pilot concept of operations was established and authorized by the Associate 

Administrator. The InTWG pilot is anticipated to begin in February 2024 and run for one 

year. 

Office of Primary Responsibility: Office of Protective Services 

Target Completion Date: December 1, 2024 

38. Report: NASA’s Volatiles Investigating Polar Exploration Rover (VIPER) Mission (IG-22-

010; 4/6/2022) 

Recommendation: (1) Coordinate with the Chief Knowledge Officer to submit and at 

appropriate intervals document and publish lessons learned associated with using a CLPS 

provider, particularly on major acquisitions. 

Status: In May 2023, the Exploration Science Strategy and Integration Office completed 

compiling a set of CLPS formulation lessons learned and is in the process of formally 

updating NASA’s lessons learned data base. 

Office of Primary Responsibility: Science Mission Directorate 

Target Completion Date: July 22, 2024

39. Report: NASA’s Volatiles Investigating Polar Exploration Rover (VIPER) Mission (IG-22-

010; 4/6/2022) 

Recommendation: (2) Develop a VIPER mission cost estimate that includes all critical 

mission components and risks, specifically associated with the Astrobotic task order, and 

update the Major Program Annual Report (MPAR) accordingly. 

Status: In the letter response to the OIG recommendation, SMD completed its study on a 

reassessment of VIPER’s cost estimates in late fall 2023. Those results were provided to 

the OIG, which requested SMD continue to work towards implementation of this 

corrective action. Resultingly, SMD, in coordination with OCFO, is reassessing 

appropriate paths forward in response to this recommendation. 

Office of Primary Responsibility: Science Mission Directorate 

Target Completion Date: June 15, 2024
45 

40. Report: NASA’s Cost Estimating and Reporting Practices for Multi-Mission Programs (IG22-011; 4/7/2022) 

Recommendation: (3) Should NASA elect to estimate, track, and report life-cycle costs 

for major programs or activities that exceed $250 million by component rather than by 

mission, include estimates for each component in the MPAR and provide Congress a cost 

estimate, outside of the MPAR, for each Artemis mission currently planned, starting no 

later than Artemis III. 

Status: The Artemis implementation is unique from other NASA activities in that the 

architecture is built to be flexible and meet M2M Objectives over the long run, not as a 

monolithic multi-decade implementation that has static requirements. Mission 

requirements are evolved based on Lessons Learned from previous missions and the 

missions downstream are designed to be flexible. The reason the Agency has 

implemented a process to update the architecture annually is to account for this feature. 

The process is built to ensure that gaps are identified and change the architecture if 

necessary to ensure the M2M Objectives are met. 

The approach NASA is pursuing ensures that capabilities are developed to meet the needs 

of the architecture. These developments are consistent with NASA policy and follow the 

development process as documented in NASA command media (i.e., NPR 7120.5). 

Office of Primary Responsibility: Office of the Chief Financial Officer

Target Completion Date: March 31, 2024

41. Report: NASA’s Cost Estimating and Reporting Practices for Multi-Mission Programs (IG22-011; 4/7/2022) 

Recommendation: (4) Develop a formal process by which a risk-based probabilistic 

analysis is conducted to cover the global and interdependency risks of major programs 

and projects when those individual programs and projects are required for the successful 

implementation of a mission; regardless of how those programs and projects are 

categorized (i.e., tightly coupled, single-project program, etc.). 

Status: In NASA management response, the recommendation closure was determined to 

be demonstrated with the approval of ACD schedule management plan that formalized 

the process for accounting for integrated mission schedule. The ACD Schedule 

Management plan was published in July 2022. The ACD Schedule Management Plan 

process was validated with the successful implementation of JCL analysis informing 

Gateway Program KDP-C, HLS KDP-C, and SLS EUS + CAPS KDP-C. Decision 

Memos for each of these KDPs were released January 9, 2024. 

Office of Primary Responsibility: Office of the Chief Financial Officer

Target Completion Date: March 15, 2024 
46 

42. Report: NASA’s Cost Estimating and Reporting Practices for Multi-Mission Programs (IG22-011; 4/7/2022) 

Recommendation: (7) Establish procedural requirements for a risk posture analysis to 

ensure that major programs supporting multiple missions identify and estimate the cost 

and schedule impact of global and major interdependency risks. 

Status: With the release of ACD-50006, the Artemis Campaign Development Schedule 

Management Plan, on July 25, 2022, NASA formalized the inclusion of schedule risk 

assessments that include probabilistic analyses to identify margin and schedule risk to 

support management decisions and that capture interdependencies with or constraints to 

defined Artemis mission content. This content included in the Schedule Management 

Plan meets the intent of the best practices white paper. Recognizing Artemis is the only 

NASA campaign of missions that currently needs to consider global, interdependent risks 

as relating to specific missions, NASA determined that associated updates to the NASA 

Space Flight Program and Project Management Handbook is not applicable. A request 

for closure was submitted to OIG and is under consideration by the OIG. 

Office of Primary Responsibility: Chief Program Management Officer

Target Completion Date: December 31, 2023

43. Report: NASA’s Management of the Mobile Launcher 2 Contract (IG-22-012; 6/9/2022) 

Recommendation: (1) Evaluate Bechtel’s support for the updated estimate of cost and 

schedule at project completion and finalize negotiations for Bechtel’s currently proposed 

cost increases and NASA’s government-driven changes. 

Status: EGS and M2M Headquarters personnel participated in a two-month Integrated 

Baseline Review of EGS’s ML-2 development, culminating in face-to-face meetings with 

Bechtel in December 2023. The team reviewed ML-2 control accounts and schedules 

and participated in interviews with Bechtel Control Account Managers. The results of 

this review will inform the upcoming setting of an ML-2 ABC. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: June 30, 2024 

44. Report: NASA’s Management of the Mobile Launcher 2 Contract (IG-22-012; 6/9/2022) 

Recommendation: (2) Before completing and finalizing the ML-2 project-level ABC, 

update the JCL analysis to reflect realistic life-cycle cost and schedule estimates to ensure 

effective budgeting and management of the project. 

Status: The EGS program is preparing for the next KDP-C in the life cycle for the ML2, which will include setting an ABC. A JCL analysis is being performed and will be 

used to inform the ABC. This milestone will take place spring 2024. The Agency will 
47 

seek to close this recommendation after the ABC is established and ML-2 is approved to 

proceed into phase C of its life cycle. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: June 30, 2024 

45. Report: NASA’s Management of the Mobile Launcher 2 Contract (IG-22-012; 6/9/2022) 

Recommendation: (3a) To the extent that some or all of the Bechtel contract is 

converted to a fixed-price contract, ensure that the Critical Design Review has been 

completed in accordance with NASA’s life-cycle policies prior to conversion. 

Status: The EGS Program completed the CDR Step 1 (Hardware and Programmatic) in 

accordance with NPR 7120.5 and NPR 7123.1 in January 2024. The follow-on CDR 

Step 2, which will cover ground support equipment software and system-level validation 

and verification, will take place spring 2024. A request for closure will be submitted 

once the CDR has been fully closed out, anticipated for fall 2024. 

The Agency has elected to defer the decision on converting the existing contract with 

Bechtel to a firm-fixed price (FFP) for the foreseeable future. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: September 30, 2024 

46. Report: NASA’s Management of the Mobile Launcher 2 Contract (IG-22-012; 6/9/2022) 

Recommendation: (3b) To the extent that some or all of the Bechtel contract is 

converted to a fixed-price contract, ensure that an IGCE is established before entering 

into any new contractual agreements. 

Status: The Agency has elected to defer the decision on converting the existing contract 

with Bechtel to an FFP for the foreseeable future. Given that the Agency has decided to 

not pursue an FFP transition at this time, there is no opportunity to establish of a new 

independent government cost estimate (IGCE). NASA would like to offer other means of 

reasonable assurance that future contract work will continue to follow Federal 

Acquisition Regulation (FAR) and NASA FAR supplement regulations. A request for 

closure will be submitted. 

Office of Primary Responsibility: Exploration Systems Development Mission 

Directorate 

Target Completion Date: March 15, 2024 

47. Report: NASA’s Management of the Earth Science Disasters Program (IG-22-013; 

6/14/2022) 
48 

Recommendation: (1) Establish and document Program management requirements in a 

strategic plan and/or NPR 7120.8A project plan format for consistent messaging on 

ESDP priorities, objectives, and quantifiable performance metrics. 

Status: SMD is in the process of establishing and documenting program management 

requirements in a strategic plan and potentially an NPR 7120.8, NASA Research and 

Technology Program and Project Management Requirements, Project Plan to help ensure 

consistent messaging on Earth Science Disasters Program (ESDP) priorities, objectives, 

and quantifiable performance metrics. 

Office of Primary Responsibility: Science Mission Directorate 

Target Completion Date: May 31, 2024 

48. Report: NASA’s Management of the Earth Science Disasters Program (IG-22-013; 

6/14/2022) 

Recommendation: (2) Perform a funding analysis of ESDP to determine if current 

resources are adequate to manage, oversee, and administer Program goals and objectives 

in accordance with its strategic plan and/or project plan. 

Status: SMD is performing a funding analysis of ESDP to determine if current resources 

are adequate to manage, oversee, and administer Program goals and objectives in 

accordance with its strategic and project plans. 

Office of Primary Responsibility: Science Mission Directorate 

Target Completion Date: September 30, 2024 

49. Report: NASA’s Management of the Earth Science Disasters Program (IG-22-013; 

6/14/2022) 

Recommendation: (3) In accordance with the Stafford Act, coordinate with appropriate 

NASA offices to develop Memorandums of Understanding that facilitate reimbursement 

agreements with applicable federal agencies that request Agency support for disaster 

events. 

Status: ESDP reviewed options across NASA internally; specifically, OGC, Office of 

Interagency and International Relations, SMD Policy Branch, and other members of the 

SMD. In addition, discussions were held with the Federal Emergency Management 

Agency and the National Guard Bureau who liaises with state Offices of Emergency 

Management. ESDP determined while reimbursement is authorized by those provisions, 

it is not mandated. Further, the Federal Emergency Management Authority holds the 

ultimate decision for determining the requisitioned services to be approved for 

reimbursement and direct support from entities from state, territory, tribal, local 

government, and private nonprofits are given priority in awarding funds. 

Office of Primary Responsibility: Science Mission Directorate 

Target Completion Date: January 25, 2024 
49 

50. Report: NASA’s Compliance with the Payment Integrity Information Act for Fiscal Year 

2021 (IG-22-014; 6/28/2022) 

Recommendation: (3) Complete the OMB data call process for all programs with 

outlays over $10 million. 

Status: To address this recommendation, the Agency reported on all programs that have 

$10+ million in annual outlays in the Payment Integrity Information Act (PIIA) data call. 

The Agency briefed NASA OIG on this approach and is expecting closure of this 

recommendation at the conclusion of the current PIIA compliance audit in May 2024. 

Office of Primary Responsibility: Office of the Chief Financial Officer 

Target Completion Date: May 31, 2024

51. Report: NASA’s Compliance with the Payment Integrity Information Act for Fiscal Year 

2021 (IG-22-014; 6/28/2022) 

Recommendation: (4) Ensure that program outlays exclude any transactions that do not 

meet the outlay definition provided by OMB. 

Status: To address this recommendation, the Agency enhanced its risk assessment 

process to the use of evaluating gross outlays. 

The Agency has briefed NASA OIG on this approach and is expecting closure of this 

recommendation at the conclusion of the current PIIA compliance audit in May 2024. 

Office of Primary Responsibility: Office of the Chief Financial Officer 

Target Completion Date: May 31, 2024

52. Report: NASA’s Compliance with the Payment Integrity Information Act for Fiscal Year 

2021 (IG-22-014; 6/28/2022) 

Recommendation: (5) Revise the materiality risk calculation methodology and 

sampling and estimation methodology plan to include payment transactions only. 

Status: To address this recommendation, the Agency made further enchantments to the 

risk assessment process by evaluating gross outlays for both the materiality risk 

calculation and sampling and estimation methodology. 

The Agency has briefed NASA OIG on this approach and is expecting closure of this 

recommendation at the conclusion of the current PIIA compliance audit in May 2024. 

Office of Primary Responsibility: Office of the Chief Financial Officer 

Target Completion Date: May 31, 2024
50 

53. Report: NASA’s Compliance with the Payment Integrity Information Act for Fiscal Year 

2021 (IG-22-014; 6/28/2022) 

Recommendation: (7) Develop a detailed review process, such as a checklist or job aid, 

outlining the review procedures performed by the Quality Assurance Division within the 

reporting process for overpayments from sources other than recapture audits to ensure 

that the primary reviewer and the supervisory quality control reviewers are performing a 

thorough review of the aggregated submissions of overpayments. Necessary review steps 

include ensuring overpayments are not reported twice, capturing issues with 

overpayments submitted for the incorrect period, and tracking identified and collected 

portions that occur in different fiscal years for accurate reporting. 

Status:  To address this recommendation, the Agency developed detailed internal 

guidance. This is internal guidance has been broadly disseminated among the NASA 

Quality Assurance community as a part of the FY 2024 PIIA cycle. 

The Agency has briefed NASA OIG on this approach and has provided a copy of 

developed internal guidance. The Agency is expecting closure of this recommendation at 

the conclusion of the current PIIA compliance audit in May 2024. 

Office of Primary Responsibility: Office of the Chief Financial Officer 

Target Completion Date: May 31, 2024

54. Report: Ames Research Center’s Lease Management Practices (IG-22-015; 8/4/2022) 

Recommendation: (1) Conduct cyclical reviews (no less than every 5 years) of the 

Ames lease process to ensure compliance with federal and NASA requirements. 

Status: NPR 8800.15C has been updated to address the recommendation cited in this 

audit. Currently, the NPR is in the review cycle at the NASA leadership level and OSI is 

expecting routing and approval to be completed within the next few months. 

Office of Primary Responsibility: Office of Strategic Infrastructure 

Target Completion Date: June 30, 2024 

55. Report: Ames Research Center’s Lease Management Practices (IG-22-015; 8/4/2022) 

Recommendation: (2) Update applicable real estate policies and NASA-wide guidance 

to enhance requirements and procedures to comply with Enhanced Use Lease (EUL) 

authority and to require maintaining appropriate documentation, documenting decisions, 

and fostering transparent coordination and communication with internal and external 

stakeholders in a timely manner. 

Status: NPR 8800.15C has been updated to address the recommendation cited in this 

audit. Currently, the NPR is in the review cycle at the NASA leadership level and OSI is 

expecting routing and approval to be completed within the next few months. 

Office of Primary Responsibility: Office of Strategic Infrastructure 
51 

Target Completion Date: June 30, 2024 

56. Report: Ames Research Center’s Lease Management Practices (IG-22-015; 8/4/2022) 

Recommendation: (3) Update applicable real estate policies and NASA-wide guidance 

to enhance requirements and standardize applicable financial practices (such as benefit 

and cost analysis, life-cycle cost analysis, and audits of tenants’ books and records when 

required) associated with leases. 

Status: NPR 8800.15C has been updated to address the recommendation cited in this 

audit. Currently, the NPR is in the review cycle at the NASA leadership level and OSI is 

expecting routing and approval to be completed within the next few months. 

Office of Primary Responsibility: Office of Strategic Infrastructure 

Target Completion Date: June 30, 2024 

57. Report: Ames Research Center’s Lease Management Practices (IG-22-015; 8/4/2022) 

Recommendation: (4) Update applicable real estate policies and NASA-wide guidance 

to incorporate applicable security requirements and agreement clauses in leases. 

Status: NPR 8800.15C has been updated to address the recommendation cited in this 

audit. Currently, the NPR is in the review cycle at the NASA leadership level and OSI is 

expecting routing and approval to be completed within the next few months. 

Office of Primary Responsibility: Office of Strategic Infrastructure 

Target Completion Date: June 30, 2024 

58. Report: Ames Research Center’s Lease Management Practices (IG-22-015; 8/4/2022) 

Recommendation: (5) Implement written procedures in the lease process to ensure 

compliance with federal and NASA requirements applicable, but not limited to, timely 

involvement of the RPAO, competition, life-cycle cost analysis, fair market value 

assessments, certifications, and termination clauses as appropriate. 

Status: NPR 8800.15 is still in review with OSI. OSI provided a brief update to the 

Center Operations Integrators in December 2023. Additional comments were requested 

from Centers and Center Directors regarding the Real Property Accountable Officer 

(RPAO), competition, compliance with Federal and NASA requirements, and OSI 

updates to the Code of Federal Regulations. This is a potential topic at a Mission Support 

Program Management Council meeting. 

Office of Primary Responsibility: Ames Research Center 

Target Completion Date: September 30, 2024 
52 

59. Report: Ames Research Center’s Lease Management Practices (IG-22-015; 8/4/2022) 

Recommendation: (9) Within the next 3 years, conduct a Center-wide security 

vulnerability risk assessment, including the districts outside Ames Campus, to ensure 

compliance with federal and NASA requirements. 

Status: Ames Research Center (ARC) Protective Services Office (PSO) is not 

sufficiently staffed to complete this assessment by June 2025. ARC PSO advised prior 

to, during, and after the audit, that additional subject-matter expertise (SME) support 

would be required to complete a Center-wide security vulnerability risk assessment of 

this magnitude. ARC management committed to providing funds for a term full-time 

equivalent (FTE) with the required SME skills that PSO could dedicate to performing this 

assessment. To date, no funding has been received for this term FTE. ARC PSO, with 

its limited SME, is working to complete elements of this assessment for the Moffett 

Federal Airfield and NASA Research Park (NRP) in 2024. Elements of this assessment 

for the Ames Campus and Eastside could begin in 2025 contingent upon completion of 

the Airfield and NRP. Completion of the full assessment is contingent upon OPS having 

sufficient resources (personnel and funding). 

Office of Primary Responsibility: Office of Protective Services 

Target Completion Date: June 30, 2027 

60. Report: Ames Research Center’s Lease Management Practices (IG-22-015; 8/4/2022) 

Recommendation: (10) Identify and implement mitigation strategies and resource 

requirements to address security vulnerability assessment risks. 

Status: ARC PSO has identified minimum required mitigation strategies for the NRP 

and provided that information to ARC management. To date, studies and design work 

have been initiated but nothing has been implemented. A contributing factor impacting 

completion of this action is ARC management having not reached a decision on their 

desired end state for an “open campus” environment in the NRP. Implementation of 

identified minimum mitigation strategies and required mitigation strategies from the 

assessment is contingent upon both a defined end state for “open campus” and the OPS 

having sufficient resources (personnel and funding). 

Office of Primary Responsibility: Office of Protective Services 

Target Completion Date: June 30, 2027 

61. Report: NASA’s Compliance with the Geospatial Data Act for Fiscal Year 2022 (IG-23-001; 

10/5/2022) 

Recommendation: (1) Ensure the role of the Senior Agency Official for Geospatial 

Information (SAOGI) is strategically positioned within the Agency to have responsibility, 

accountability, and authority needed to meet Geospatial Data Act (GDA)-assigned 

agency responsibilities. 
53 

Status: Since the NASA OIG audit, OCIO has maintained reporting compliance in 

accordance with GDA mandates; however, the OCIO has not initiated the coordination 

with SMD and OSI for the assessment of the strategic placement of the NASA SAOGI. 

Since the audit recommendations required the organizational assignment and designation 

of the SAOGI to ensure the responsibility, accountability, and authority needed to meet 

the GDA-assigned Agency responsibilities were strategically placed, OCIO felt 

participation from the Chief Data Officer (CDO) was critical. The CDO, who had been 

filling the SAOGI role, left the Agency at the time of the audit, resulting in a delay with 

completing the recommendation in the original time frame. 

Office of Primary Responsibility: Office of the Chief Information Officer 

Target Completion Date: June 28, 2024 

62. Report: NASA’s Compliance with the Geospatial Data Act for Fiscal Year 2022 (IG-23-001; 

10/5/2022) 

Recommendation: (2) Ensure roles and responsibilities of the SAOGI and other key 

stakeholders are defined in both the Geospatial Data Strategy and its implementation 

plan. 

Status: The CDO initiated leadership decisions within OCIO and will lead collaboration 

with the other impacted NASA organizations. Unfortunately, due to these challenges, we 

have not engaged with stakeholders as originally intended. An extension will enable us 

to coordinate and ensure alignment before proposing corrective action. 

The Agency decision in question holds significant implications for our organization’s 

long-term growth and success. Given its magnitude, it is crucial that we allocate the 

necessary time to thoroughly evaluate strategic placement and make well-informed 

recommendations that will effectively position the NASA SAOGI. 

Office of Primary Responsibility: Office of the Chief Information Officer 

Target Completion Date: June 28, 2024 

63. Report: NASA’s Compliance with the Geospatial Data Act for Fiscal Year 2022 (IG-23-001; 

10/5/2022) 

Recommendation: (3) Ensure the implementation plan for the Geospatial Data Strategy 

contains detailed action items and milestones, including those for developing a complete 

and accurate inventory of the Agency’s geospatial data. 

Status: The CDO and the SMD will collaborate on the development of a unified 

geospatial data management plan across NASA. OLIA is assisting in the effort to ensure 

alignment with Geospatial Data Act of 2018 and Federal Geographic Data Committee 

objectives. 

Office of Primary Responsibility: Office of the Chief Information Officer 
54 

Target Completion Date: September 30, 2024 

64. Report: NASA’s Compliance with the Geospatial Data Act for Fiscal Year 2022 (IG-23-001; 

10/5/2022) 

Recommendation: (4) Ensure continued coordination with National Archives and 

Records Administration (NARA) to establish the appropriate level of scientific data for 

inclusion in NARA-approved records schedules. 

Status: Since the NASA OIG audit, OCIO has proposed internal retention rules for 

scientific data disposition in collaboration with SMD. The OCIO reorganization and 

operational issues with NARA’s new system, ERA 2.0, have caused delays in completing 

this recommendation. The OCIO is proposing a nine-month extension to finalize our 

coordination with NARA to establish NARA-approved records schedules for scientific 

data. 

Office of Primary Responsibility: Office of the Chief Information Officer 

Target Completion Date: June 28, 2024 

65. Report: Review of NASA’s Space Technology Mission Directorate Portfolio (IG-23-005; 

12/19/2022) 

Recommendation: (1) Reexamine its SPAR data system to ensure it provides as 

accurate and complete a picture of project costs as is practicable. 

Status: STMD has completed reexamination of its STMD Portfolio Analysis Resource 

(SPAR) data system to ensure it provides as accurate and complete a picture of project 

costs as is practicable. The following corrective actions have been taken: 1) For 

historical data, STMD has updated the process to pull in budget information from the 

official systems of record twice a year, 2) It has been noted in STMD procedures that 

SPAR should not be used for funding projections as SPAR does not contain embargoed 

data. 

Office of Primary Responsibility: Space Technology Mission Directorate 

Target Completion Date: January 31, 2024 

66. Report: Review of NASA’s Space Technology Mission Directorate Portfolio (IG-23-005; 

12/19/2022) 

Recommendation: (2) Update its STARPort data system with complete information on 

project alignment to STAR desired outcomes for all projects active in FY 2021 and 

beyond. 

Status: STMD has completed its update of the STARPort data system with complete 

information on project alignment to Strategic Technology Architecture Roundtable 

(STAR) desired outcomes for all projects active in FY 2021 and beyond. As of the end 
55 

of FY 2023, all active projects have been mapped to outcomes. STMD will continue to 

map new investments to their associated outcomes on a regular basis. 

Office of Primary Responsibility: Space Technology Mission Directorate 

Target Completion Date: January 31, 2024 

67. Report: Review of NASA’s Space Technology Mission Directorate Portfolio (IG-23-005; 

12/19/2022) 

Recommendation: (3) Complete efforts to develop additional outcome-based 

performance measures based on the transition, advancement, and infusion of 

technologies. 

Status: STMD has completed efforts to develop additional outcome-based performance 

measures based on the transition, advancement, and infusion of technologies. STMD has 

transitioned all metrics of early-stage technologies to outcome-based metrics and has 

added new metrics to cover the entirety of STMD’s early-stage portfolio. We continue to 

work across the Mission Directorate to improve performance metrics and remain 

committed to implementing outcome-based metrics across STMD. 

Office of Primary Responsibility: Space Technology Mission Directorate 

Target Completion Date: January 31, 2024 

   
56 

Appendix C 

Reconciliation of Agency Records with NASA OIG Semiannual Report 

and GAO’s Database of Open Recommendations    
57 

Reconciliation with NASA OIG’s Fall 2023 Semiannual Report 

Public Reports and Recommendations Open for One Year or More 

(As of 12/31/2023) 

 Reports Recommendations 

 

Total Open Public Reports and Recommendations as of 9/30/23 in Table 3 of 

OIG’s Fall 2023 Semiannual Report a

 31 94 

Less: Open Public Reports and Recommendations in Table 3 Issued Between 

1/1/23 and 3/31/23 b (3) (24)

Net Public Reports and Recommendations Open One Year or More 

in Table 3 28 70 

Less: Public Reports and Recommendations in Table 3 Closed 

Between 10/1/23 – 12/30/23 c (1) (3)

Total Public Reports and Recommendations Open One Year 

or More as of 12/31/2023 per Agency Records 27 67 

a Table 3, “Audit Recommendations Yet to be Implemented, Previous Semiannual Report” of NASA OIG’s 

semiannual report can be found at https://oig.nasa.gov/docs/SAR-2023-FALL.pdf

b Reports IG-23-004, 9 recommendations; IG-23-008, 6 recommendations; and IG-23-010, 9 recommendations. 

c Report IG-21-006, recommendations 5 and 7. Recommendation 1 of report IG-21-004 was also closed; however, 

recommendations 2 and 3 are still open so this report is not considered closed.

Reconciliation with GAO’s Database of Open Recommendations 

Public Reports and Recommendations Open for One Year or More 

(As of 12/31/2023) 

 Reports Recommendations 

 

Total Open Public Reports and Recommendations per Database of Open 

Recommendations a 21 43 

Less: Open Public Reports and Recommendations Issued Between 1/1/23 

and Present b (3) (4) 

Total Public Reports and Recommendations Open One Year 

or More as of 12/31/2023 per Agency Records 18 39 

a GAO’s Database of Open Recommendations provides status only as of the date of query. NASA queried the 

database January 22, 2024. The database is located at https://www.gao.gov/reports-testimonies/recommendationsdatabase. 

b Reports GAO-24-106225, 1 recommendation; GAO-24-105658, 1 recommendation; and GAO-24-105980, 

2 recommendations. 

   
58 

Appendix D 

Glossary of Acronyms 
59 

Acronym Description 

3D Three Dimensional 

ABC Agency Baseline Commitment 

ACD Artemis Campaign Division 

ACPM Artemis Campaign Planning Manifest 

ADR Active Debris Removal 

AEPS Advanced Electric Propulsion System 

AFR Agency Financial Report 

APMC Agency Program Management Council 

APS Application and Platform Service 

ARC Ames Research Center 

CAPS Associated Capabilities 

CDO Chief Data Officer 

CDR Critical Design Review 

CFT Crew Flight Test 

CLPS Commercial Lunar Payload Services 

CO Contracting Officers 

COC Conflict of Commitment 

CoF Construction of Facilities 

COR Contracting Officer’s Representative 

CPARS Contract Performance Assessment Reporting System 

CPMO Chief Program Management Officer 

CY Calendar Year 

DAAC Distributed Active Archive Centers 

DCD Design, Construction, and Demolition 

DDT&E Design Development Test and Evaluation 

EGS Exploration Ground Systems 

EM-2 Exploration Mission 2 

ESDIS Earth Science Data and Information System 

ESDP Earth Science Disasters Program 

EUL Enhanced Use Lease 

EUS Exploration Upper Stage 

EUS + CAPS EUS and its Associated Capabilities 

EVM Earned Value Management 

EVMS Earned Value Management System 

FAIR Findability, Accessibility, Interoperability, and Reusability 

FAR Federal Acquisition Regulation 

FFP Firm- Fixed Price 

FTE Full-Time Equivalent 

FY Fiscal Year 

GAO Government Accountability Office 
60 

Acronym Description 

GDA Geospatial Data Act 

GIC Gateway Initial Capability 

HALO Habitation and Logistics Outpost 

HEOMD Human Exploration and Operations Mission Directorate 

HLS Human Landing System 

iCDR Integrated Critical Design Review 

IGCE Independent Government Cost Estimate 

InTWG Insider Threat Working Group 

ISS International Space Station 

IT Information Technology 

JCL Joint Cost and Schedule Confidence Level 

KDP Key Decision Point 

M2M Moon to Mars 

ML-1 Mobile Launcher 1 

ML-2 Mobile Launcher 2 

MPAR Major Program Annual Report 

MSR Mars Sample Return 

NARA National Archives and Records Administration 

NASA National Aeronautics and Space Administration 

NDS NASA Docking System 

NHPA National Historic Preservation Act 

NICE National Initiative for Cybersecurity Education 

NISAR NASA-ISRO Synthetic Aperture Radar 

NOJMO NASA Office of Jet Propulsion Laboratory Management and Oversight 

NPD NASA Policy Directive 

NPR NASA Procedural Requirements 

NRP NASA Research Park 

OCE Office of the Chief Engineer 

OCFO Office of Chief Financial Officer 

OCIO Office of the Chief Information Officer 

OCOMM Office of Communications 

OGC Office of the General Counsel 

OIG Office of Inspector General 

OLIA Office of Legislative and Intergovernmental Affairs 

OMB Office of Management and Budget 

OP Office of Procurement 

OPS Office of Protective Services 

ORR Operational Readiness Review 

OSI Office of Strategic Infrastructure 

OSTP Office of Science and Technology Policy 
61 

Acronym Description 

PALT Procurement Administrative Lead Time 

PIIA Payment Integrity Information Act 

PPE Power and Propulsion Element 

PSO Protective Services Office 

RPAO Real Property Accountable Officer 

SAOGI Senior Accountable Official for Geospatial Information 

SI Scientific Integrity 

SLD Sustaining Lunar Development 

SLS Space Launch System 

SMD Science Mission Directorate 

SME Subject-Matter Expert 

SPAR STMD Portfolio Analysis Resource 

SRA Schedule Risk Analysis 

STAR Strategic Technology Architecture Roundtable 

STMD Space Technology Mission Directorate 

SWOT Surface Water and Topography 

TO Task Orders 

VIPER Volatiles Investigating Polar Exploration Rover