Business Modernization: NASA's Integrated Financial Management Program Does Not Fully Address Agency's External Reporting Issues
Published: 2003-11-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In April 2000, the National Aeronautics and Space Administration (NASA) began its Integrated Financial Management program (IFMP), its third attempt at modernizing its financial management processes and systems. In April 2003, GAO reported that NASA's acquisition strategy has increased the risk that the agency will implement a system that will cost more and do less than planned. This report is one of a series of reviews of NASA's acquisition and implementation of IFMP, and focuses on the core financial module's ability to provide the information necessary for external financial reporting.
section_title: What GAO Found
paragraphs: The core financial module of IFMP provides NASA its first agencywide accounting system--a significant improvement over the 10 disparate systems previously used. However, to meet IFMP's aggressive implementation schedule, NASA deferred testing and implementation of many key requirements of the core financial module. Consequently, when NASA announced, in June 2003, that this module was fully operational at each of its 10 centers, about two-thirds of the financial events or transaction types needed to carry out day-to-day operations and produce external financial reports had not been implemented in the module. NASA officials acknowledged that, as part of their implementation strategy, they had not yet converted the module to support full-cost accounting. In addition, we found that NASA also deferred implementation of other key core financial module capabilities. Because NASA did not use disciplined processes for defining, managing, and testing key system requirements, or substantially reengineer its business processes prior to implementation, the core financial module, as implemented in June 2003, does not address several long-standing external reporting issues and has created some new problems. Long-standing external financial reporting issues have not been addressed. NASA has not used its implementation of the core financial module as an opportunity to drive needed changes in its management practices and business processes. Therefore, the system does little to address NASA's ability to properly account for $37 billion of reported property or certain aspects of the agency's $15 billion annual budget. New financial reporting problems have emerged. NASA went forward with its aggressive implementation plans even though agency managers knew of problems with the module's ability to properly process and record certain transactions. As a result, the module does not appropriately capture critical information on the cost of NASA's operations, such as certain accrued costs, accounts payable, and obligation transactions. In April 2003, GAO reported that the core financial module did not address key internal management information requirements. Now, GAO has found that the module cannot reliably provide key financial data needed for external financial reporting. Although NASA intends to address many of these issues, its implementation approach raises concerns over its ability to do so. These deferred external reporting capabilities, combined with the findings from our April 2003 report, indicate that NASA's June 2003 core financial module and related systems do not substantially comply with the requirements of Federal Financial Management Improvement Act (FFMIA). FFMIA addresses the need for agencies' financial systems to provide value to those who use financial data. NASA must address these issues if the core financial module and IFMP are to achieve the objective of providing reliable, timely financial information for both internal management decision-making and external reporting purposes.

section_title: Letter
paragraphs: For years, the National Aeronautics and Space Administration (NASA) has  cited deficiencies with its financial management systems as a primary  reason for not having the necessary data required to oversee its  contractors, accurately account for the full cost of its operations, and  efficiently produce accurate and reliable information needed for both  management decision-making and external reporting purposes.   Recognizing the importance of successfully implementing an integrated  financial management system, in April 2000, NASA began an effort known  as the Integrated Financial Management Program (IFMP).  When  completed, IFMP is planned to consist of nine modules that will support a  range of financial, administrative, and functional areas.  On June 23, 2003,  NASA announced that the core financial module—considered the  backbone of IFMP—was fully operational at each of NASA’s 10 centers.     The core financial module is intended to provide NASA’s financial and  program managers with timely, consistent, and reliable cost and  performance information for management decisions and external financial  reporting.
NASA has made two efforts in the recent past to improve its financial  management processes and systems but both of these efforts were  eventually abandoned after spending a total of 12 years and a reported   $180 million. Given the importance of NASA’s current effort, you asked us  to assess the program.  In April 2003, we issued our first report on IFMP to  alert you to concerns we had, based on our work to date.  In that report, we  provided you with, among other things, our assessment of the core  financial module’s ability to satisfy NASA’s internal management decision- making needs.
As agreed, we continued our review of IFMP in three areas to assess:  (1) whether NASA has been acquiring and implementing IFMP in the  context of an enterprise architecture, (2) the extent to which the core  financial module will address NASA’s external reporting requirements, and  (3) NASA’s life-cycle cost estimate and schedule for IFMP. We are  responding to the first and third issues in separate reports, and we have  summarized our findings on all three issues in a summary report.  This  report addresses the second issue—the extent to which the core financial  module, as completed in June 2003, will satisfy NASA’s key external  reporting requirements.  Specifically, we assessed whether the core  financial module, as of June 2003, provides the functionality needed to  (1) accurately account for property, plant, and equipment (PP&E) and  material, (2) properly account for the full cost of NASA’s projects and  programs, (3) capture and report certain key budgetary information,   (4) accurately record accounts payable, and (5) comply substantially with  the requirements of the Federal Financial Management Improvement Act  (FFMIA) of 1996.   FFMIA emphasizes the need for agencies to be able to  provide financial management information, including cost information, for  measuring the results of program performance on an ongoing basis.   FFMIA also requires that an agency’s independent auditor report on the  ability of agency financial management systems to comply substantially  with these requirements.
We performed our work from April 2003 through September 2003 in  accordance with generally accepted government auditing standards.   Details on our objective, scope, and methodology are in appendix I.
subsections: section_title: Background
paragraphs: From 1996 through 2000, NASA was one of the few agencies to be judged  by its independent auditor at that time, Arthur Andersen, as meeting all of  the federal financial reporting requirements.  That is, NASA was one of the  few agencies to receive an unqualified, or “clean,” opinion on its financial  statements, with no material internal control weaknesses noted, and no  indications that its financial management systems were not in substantial  compliance with the requirements of FFMIA.  FFMIA reflects the need for  agencies to have systems that produce reliable, timely, and accurate  financial information needed for day-to-day decision making by requiring  agencies to implement and maintain financial management systems that  substantially comply with (1) federal financial management systems  requirements, (2) the U.S. Government Standard General Ledger (SGL) at  the transaction level, and (3) applicable federal accounting standards.  Thus, the auditor’s report implied that NASA could not only  generate reliable information once a year for external financial reporting  purposes but also could provide the kind of information needed for day-to- day management decision making.
However, as we and others have reported, the independent auditor’s  reports did not provide an accurate picture of NASA’s financial  management systems and, instead, failed to disclose pervasive financial  management problems that existed at NASA.  For example, we have  identified NASA’s contract management function as an area of high risk  since 1990 because of NASA’s inability to (1) oversee its contractors and  their financial and program performance, and (2) implement a modern,  integrated financial management system, which is integral to producing  accurate and reliable financial information needed to support contract  management.  Also, in February 2002, NASA’s new independent auditor,  PricewaterhouseCoopers, further confirmed NASA’s financial management  difficulties and disclaimed an opinion on the agency’s fiscal year 2001  financial statements.  The audit report also identified a number of material  internal control weaknesses—primarily regarding PP&E and materials— and stated that, contrary to previous financial audit reports, NASA’s  financial management systems did not substantially comply with FFMIA.
While NASA received an unqualified opinion for its fiscal year 2002  financial statements, these results were achieved only through heroic  efforts on the part of NASA and its auditor and again, the audit report  identified a number of material internal control weaknesses and stated that  NASA’s financial management systems did not substantially comply with  FFMIA.  To its credit, in April 2000, NASA began an effort known as IFMP.   The schedule for implementing IFMP was originally planned for fiscal year  2008, but after NASA’s new Administrator came on board in fiscal year  2002, the timeline was accelerated to fiscal year 2006, with the core  financial module to be completed in fiscal year 2003.  NASA’s IFMP  includes nine module projects supporting a range of financial,  administrative, and functional areas.  According to NASA officials, of the  nine module projects, five are in operation, one is currently in  implementation, and three are future modules.  The five modules in  operation are resume management, position description management,  travel management, executive financial management information (called  Erasmus), and core financial; the one project in implementation is budget  formulation; and the three future module projects are human resources,  asset management, and contract administration.
The core financial module, which utilizes the SAP R/3 system, is  considered the backbone of IFMP and has become NASA’s standard,  integrated accounting system used agencywide.  The other IFMP module  projects will be integrated/interfaced with the core financial module, where  applicable.  The Joint Financial Management Improvement Program  (JFMIP) defines a core financial system (or module) as the backbone of  an agency’s integrated financial management system: It should provide  common processing routines, support common data for critical financial  management functions affecting the entire agency, and maintain the  required financial data integrity control over financial transactions,  resource balances, and other financial systems.  A core financial system  should support an agency’s general ledger, funds management, payment,  receivable, and cost management functions.  Also, the system should  receive data from other financial-related systems, such as inventory and  property systems, and from direct user input, and it should provide data for  financial statement preparation and for financial performance  measurement and analysis.
The scope of NASA’s core financial module includes the general ledger,  budget execution, purchasing, accounts receivable, accounts payable, and  cost management.  NASA completed implementation of the core financial  module at all 10 NASA centers in June 2003.  The pilot for the core financial  module—conducted at Marshall Space Flight Center—was implemented in  October 2002.  NASA then deployed the core financial module at the other 9  NASA centers in three “waves,” the last of which was completed in June  2003.
In April 2003, we issued our first report on IFMP in response to your  request.  At that time, we reported that NASA was not following key best  practices for acquiring and implementing the system, which may affect the  agency’s ability to fully benefit from the new system’s capabilities.   Specifically, we reported that NASA (1) did not analyze the relationships  among selected and proposed IFMP components, (2) had deferred  addressing the needs of key system stakeholders, including program  managers and cost estimators, and (3) did not properly manage and test its  system requirements prior to implementation of the core financial module.   As a result, we reported that:  NASA has increased its risks of implementing a system that will not  optimize mission performance, and will cost more and take longer to  implement than necessary;   the core financial module is not being designed to integrate the cost and  schedule data that program managers need to oversee the work of  NASA’s contractors; and    costly rework will likely be required to fix requirement defects not  identified prior to implementation.
section_title: Schedule-driven Approach Limits Transaction Processing Capabilities
paragraphs: Although NASA has met the core financial management module’s  implementation schedule, the system as implemented in June 2003 has  limited external financial reporting capabilities.  When NASA announced in  June 2003 that the core financial management module was complete, NASA  officials acknowledged that additional work remained, including the need  to develop and configure a cost-allocation structure within the system so  that it would accumulate the full cost of NASA’s programs and projects for  external financial reporting purposes.  However, to meet its  implementation schedule, we also found that NASA (1) deferred  requirements that require significant business process reengineering or  extensive software configuration and (2) continues to rely on manual  procedures for many transactions that should be automated in the new  system.  Consequently, only about one-third of the transaction types that  NASA uses in its business processes are currently implemented and fully  automated in the core financial module.
subsections: section_title: The Full Cost of NASA’s Programs Not Yet Available
paragraphs: As part of its implementation strategy, NASA delayed conversion to full- cost accounting until the core financial module was implemented at all  centers.  After completing implementation of the module in June 2003,  NASA began designing the agency’s new cost-allocation structure and  expected that full-cost accounting capabilities needed to provide the full  cost of its programs and projects for external financial reporting purposes  would be available through the core financial module by October 1, 2003.   Properly designing, configuring, and testing the cost-allocation structure is  key to capturing the full costs of all direct and indirect resources and  allocating them to NASA’s programs and activities.  However, on May 30,  2003, NASA’s Inspector General reported that NASA had not yet determined  how to allocate space shuttle program costs to programs that benefit from  space shuttle services or how to allocate civil service personnel costs to  benefiting programs and projects. Once these issues were resolved, NASA  would then have to configure the core financial module software to  accommodate the new allocation structure and properly test the new  configuration.  Consequently, NASA’s Inspector General expressed  concerns about NASA’s ability to meet its October 1, 2003, target date.  In  early October, we inquired about the status of full-cost accounting within  the core financial module and IFMP officials told us that this capability  would be fully implemented on October 26, 2003.  However, because of the  timing of this report, we did not verify whether this implementation date  was met.
If NASA is successful in implementing full-cost accounting, the new system  should link all of NASA’s direct and indirect costs to specific programs and  projects, and for the first time shed light on the full cost of these programs  for external financial reporting purposes.  As explained later, managerial  cost accounting goes beyond providing the full cost of programs and  projects and producing external financial reports, and is also critical for  producing the type of cost information needed to effectively manage and  oversee NASA’s programs.
section_title: Deferred Requirements Include Transactions Critical to NASA’s Business Operations
paragraphs: NASA did not adequately test key requirements or configure the core  financial module software to satisfy these requirements prior to  implementing the module. Adequately testing and configuring a system  prior to implementation helps assure the integrity and effectiveness of  transactions that will be processed through the system, thereby reducing  the likelihood of rejected transactions, labor-intensive manual  workarounds, and inaccurate data.  However, prior to implementation,  NASA tested only 120, or 53 percent, of the 225 unique financial events or  transaction types identified by NASA as critical for carrying out day-to-day  operations and producing external financial reports.  NASA deferred  implementation of the remaining 105 transaction types until after June 23,  2003, when the system would be implemented at all centers.
Ideally, all transactions should be thoroughly tested prior to implementing  a system.  However, to meet the agency’s implementation schedule, NASA  identified and deferred implementation of transactions that it determined  would not have a significant or immediate impact on operations.  For  example, 29 of the deferred transactions were related to year-end closing  procedures that would not be needed until September 30, 2003.  However,  other deferred transactions do have a significant and immediate impact on  NASA’s operations throughout the year.  For example, 40 transaction types  were related to upward and downward adjustments to prior year data,  many of which affected NASA’s ability to properly capture adjustments to  obligations.   Because NASA deferred implementing this capability, the  agency has continued to rely on ad hoc, manual processes and  “workarounds.”  As discussed later, these are the same cumbersome  manual processes that resulted in a $644 million error in NASA’s fiscal year  1999 financial statements.
NASA hoped to implement most of these deferred transactions by October  2003.  In mid-October, NASA officials told us that 75 of the 105 deferred  transaction types had been implemented, and the remaining 30 transaction  types would be implemented later in fiscal year 2004.  Until the remaining  transaction types are implemented, however, NASA must continue to  process them outside of the module using manual procedures.
section_title: Core Financial Module Relies Heavily on Manual Procedures
paragraphs: In addition to the 105 transaction types that NASA has deferred, NASA also  uses manual accounting entries to record 43, or 36 percent, of the 120  unique transaction types NASA considers implemented.  NASA considers  these 43 transaction types implemented because NASA has no current  plans to automate them in the core financial module.  Although manual  accounting entries are sometimes necessary to record unusual or  infrequent events, many of NASA’s manual entries are made to record  routine events that should be processed electronically.  For example, NASA  uses summary-level manual processes to record all transactions occurring  throughout the year related to its reported $37 billion of property.   Such a  large proportion of manual procedures runs contrary to the purpose of an  automated system and makes the agency more vulnerable to processing  errors and delays.  In fact, prior to implementation, NASA’s consultant  responsible for performing an independent compliance review of the core  financial module raised concerns about the excessive number of  transactions processed with manual journal voucher entries.  Despite these  concerns, NASA did not alter its implementation plan for the module.
section_title: Long-standing External Reporting Issues Not Addressed
paragraphs: The core financial module may provide some improvements to NASA’s  current accounting system environment by reducing the extensive amount  of time and resources currently required to consolidate NASA’s 10 different  reporting entities and close the books each accounting period. However,  NASA did not thoroughly test or implement key requirements prior to  implementation and has not used the new system as an opportunity to drive  needed changes in its management practices and business processes.   Therefore, the core financial module, as implemented in June 2003, does  not (1) properly capture, record, and account for PP&E and materials  balances or (2) provide key system requirements needed to prepare the  agency’s Statement of Budgetary Resources.
subsections: section_title: NASA Has Not Reengineered Processes to Properly Account for PP&E and Materials
paragraphs: The core financial module, as implemented in June 2003, does not  appropriately capture and record PP&E and material in the module’s  general ledger at the transaction level. According to SGL requirements and  NASA’s own accounting policy, recording PP&E and material in the general  ledger at the transaction or item level provides independent control over  these assets.  However, NASA currently updates the core financial module’s  general ledger using periodic summary-level manual entries.  Although  NASA plans to implement an integrated asset management module in 2005,  this alone will not ensure that transaction-level detail is used to update the  core financial module.
NASA’s PP&E and materials are physically located at many locations  throughout the world, including NASA centers, contractor facilities, other  private or government run facilities, and in space.  NASA’s most significant  challenge, with respect to property accounting, stems from property  located at contractor facilities, which accounts for almost $11 billion, or  about one-third, of NASA’s reported $37 billion of PP&E and materials and  consists primarily of equipment being constructed for NASA or items built  or purchased for use in the construction process.  NASA has not  reengineered the agency’s processes for capturing contract costs  associated with PP&E and material, though, and therefore, does not record  these property costs in the general ledger at the transaction level. Instead,  according to NASA officials, the agency plans to continue to (1) record the  cost of PP&E and materials as expenses when initially incurred,   (2) periodically determine which of those costs should have been  capitalized, and (3) manually correct these records at a summary level.
To illustrate, NASA’s contractors provide NASA with monthly contractor  cost reports, which contain accrued cost information for any work  performed during the month.  However, these reports do not contain  enough information for NASA to determine what portion of the reported  cost pertains to the construction or acquisition of property and therefore,  NASA initially records all costs reported by its contractors as an expense.   Then, on a quarterly or annual basis, NASA receives a property report  from its contractors that provides summary-level information on the  amount of property constructed or purchased and currently in the  contractor’s possession.  Based on these reports, NASA records the cost of  contractor-held assets in its general ledger and reverses the expense  previously recorded from the contractor cost reports. The problem with  NASA’s current process for capturing, recording, and accounting for  property in the possession of contractors is that it provides no way for  NASA to ensure that the money it spends on the construction of its  property is actually recorded as discrete property items.
Although NASA plans to implement an integrated asset management  module in 2005, the new system will not change the way NASA captures,  records, and accounts for property in the possession of contractors.  As  noted above, because this problem stems from NASA’s inability to link  accrued costs reported by its contractors with specific equipment items  being constructed, the problem will not be alleviated when physical  custody of the equipment is ultimately transferred to NASA and recorded in  NASA’s property records.
section_title: Key Requirements Deferred for Statement of Budgetary Resources
paragraphs: The core financial module does not capture and report certain key  budgetary information needed to prepare the agency’s Statement of  Budgetary Resources.  Although the software that NASA purchased for the  core financial module was certified by JFMIP as meeting all mandatory  system requirements, NASA may have relied too heavily on the JFMIP  certification.  JFMIP has made it clear that its certification, by itself, does  not automatically ensure compliance with the goals of FFMIA.  Other  important factors that affect compliance with Federal Financial  Management System Requirements (FFMSR) include how well the  software has been configured to work in the agency’s environment and the  quality of transaction data in the agency’s feeder systems.  When NASA  later tested specific requirements related to adjustments to prior year  obligations, the core financial module failed the test.  Consequently, NASA  deferred implementation of those requirements and opted to rely on  manual compilations, system queries, or other workarounds to compensate  for the system’s inadequacies. These workarounds are known to have  caused reporting problems in the past.
According to FFMSR, an agency’s core financial module should  automatically classify and record upward and downward adjustments of  prior year obligations to the appropriate general ledger accounts.   However, NASA’s core financial module, as implemented in June 2003, does  not provide this capability.  For example, if an upward adjustment is  required because an invoice includes costs not previously included on the  purchase order, such as shipping costs, the system erroneously posts the  upward adjustment to a prior year obligation instead of a current year  obligation.  Because the system does not properly capture and report these  adjustments, NASA must rely on manual compilations and system queries  to extract the data needed to prepare the agency’s Statement of Budgetary  Resources—just as it did using its legacy general ledger systems.  As we  reported in March 2001, this cumbersome, labor-intensive effort to gather  the information needed at the end of each fiscal year was the underlying  cause of a $644 million misstatement in NASA’s fiscal year 1999 Statement  of Budgetary Resources.
During its initial test of system requirements but prior to implementation at  Marshall Space Flight Center and Glenn Research Center in October 2002,  NASA became aware of the software’s limitations regarding upward and  downward adjustments to prior year obligations.  In order to meet its  schedule, NASA IFMP officials deferred further system modifications to  meet these requirements and opted to rely on a manual workaround to  satisfy the federal requirement for upward and downward adjustments.   NASA’s consultant responsible for performing an independent compliance  review of the core financial module raised concerns about this approach.   Despite these concerns, NASA went forward with its plans.  At the time,  NASA had hoped that a “patch” release or future software upgrade would  remedy the problem and then NASA could incorporate the fix into the  phased agency rollout of the core financial module.  However, the upgrades  incorporated after the initial implementation at Marshall and Glenn did not  resolve all of the issues related to upward and downward adjustments.  As  a result, NASA continued to face significant problems in this area.   According to NASA officials, the agency continued to work with the  software vendor to reconfigure the software as necessary to accommodate  adjustments to prior year obligations.  NASA expected a new software  patch to resolve any remaining problems by October 1, 2003.  However, in  mid-October, NASA officials acknowledged that it might be some time  before this issue would be resolved completely. Until then, NASA will  continue to rely on manual workarounds.
section_title: NASA’S Implementation of IFMP Has Created New Reporting Problems
paragraphs: NASA’s implementation of the core financial module has also created new  reporting issues.  Specifically, the core financial module does not  appropriately capture accrued costs and record the corresponding  liabilities as accounts payable.  In addition, the core financial module  records obligations to the general ledger before the obligations are legally  binding.  Although NASA knew about these problems prior to  implementation, the agency went forward with its implementation plans.
subsections: section_title: Accrued Costs and Accounts Payable Not Appropriately Captured and Reported
paragraphs: The core financial module, as implemented in June 2003, does not  appropriately capture and record accrued contract costs and accounts  payable information in accordance with federal accounting standards and  NASA’s own financial management manual.  Specifically, the core financial  module does not capture accrued costs or record accounts payable if  cumulative costs are in excess of obligations for a given contract.  As of  June 30, 2003, NASA had not processed approximately $245 million in costs  that exceeded obligations, nor recorded the corresponding accounts  payable, even though this amount represented a legitimate liability for  NASA.  Instead, these transactions are held outside of the general ledger in  suspense until additional funds can be obligated.  Thus, any report  containing information on NASA’s costs or liabilities would likely be  understated by the amount of costs held in suspense at the time of the  report.
Federal accounting standards and NASA’s own financial management  manual require costs to be accrued in the period in which they are incurred  and any corresponding liability recorded as an account payable, regardless  of amounts obligated.  Further, federal standards require that agencies  must disclose unfunded accrued costs—or costs in excess of obligations.   However, NASA has designed the core financial module such that it will not  post costs to the general ledger if they exceed the amount obligated.   According to NASA officials, this is intended to be a “red flag” or internal  control that alerts agency managers to potential cost overruns.
While we agree that NASA could benefit from information that provides an  early warning sign of possible cost or schedule problems, we disagree with  NASA’s approach.  Appropriately posting costs and accounts payable to the  general ledger does not preclude NASA from monitoring unfunded accrued  costs.  Further, as we reported in April 2003, to adequately oversee NASA’s  contracts, program managers need reliable contract cost data—both  budgeted and actual—and the ability to integrate this data with contract  schedule information to monitor progress on the contract.  However,  because program managers were not involved in defining system  requirements or reengineering business processes, the core financial  module is not being designed to integrate cost and schedule data needed by  program managers.
section_title: Core Financial Software Posts Obligations to the General Ledger Before They Are Binding
paragraphs: The core financial module was intended to streamline many of NASA’s  processes and eliminate the need for many paper documents.  However, in  some areas, the new system has actually increased NASA’s workload.   Specifically, because the core financial software allows obligations to be  posted to the general ledger before a binding agreement exists, NASA must  process purchase orders and contract documents outside the system until  they are signed, or otherwise legally binding.  At that point, NASA initiates  the procurement action in the system and repeats the steps that were  manually performed outside the system previously.
Federal law requires that no amount be recorded as an obligation unless it  is supported by documentary evidence of, among other things, a binding  agreement.   However, the processes that are embedded in the core  financial module for processing purchase orders and contract documents  do not accommodate this requirement.  To illustrate, authorized users  create electronic purchase requests in the system and release or forward  the request to the appropriate approving official for electronic signature.   Once signed, the purchase request is forwarded electronically to the  purchasing department where purchasing staff create an electronic  purchase order, secure a vendor, and place the order.   According to federal  appropriations law, a purchase order constitutes an obligation when the  order is placed and when all relevant parties sign the purchase order.    However, if a purchase order is entered into the system before it is  finalized, the module automatically records the obligation.  Similarly, if a  contract or contract modification is entered into the module before it is  signed and legally binding, the module automatically records the  obligation.  According to NASA officials, they are working with the  software vendor to develop a solution and expect that the new software  upgrade to be released on October 1, 2004, will alleviate this problem.  In  the meantime, they will manually process documents outside of the system  and monitor any documents that have been recorded without signatures to  ensure that obligations are not overstated at month-end.
section_title: Core Financial Module Does Not Substantially Comply With FFMIA
paragraphs: The system limitations discussed previously related to full-cost accounting,  property accounting, budgetary accounting, accrued costs, and accounts  payable—combined with the findings from our April 2003 report—indicate  that NASA’s new core financial module and related systems, as  implemented in June 2003, do not substantially comply with the  requirements of FFMIA.  This act provides agencies a blueprint for building  fully integrated financial management systems that routinely provide  decision makers with timely, reliable, and useful financial information.   FFMIA requires agencies to implement and maintain financial management  systems that substantially comply with (1) FFMSR, (2) the SGL at the  transaction level, and (3) applicable federal accounting standards.   Although NASA has made progress in addressing some of its financial  management system weaknesses, the agency’s core financial module does  not yet provide all the building blocks needed to achieve the ultimate goal  of FFMIA.
subsections: section_title: Noncompliance with FFMSR
paragraphs: The core financial module, as implemented in June 2003, does not comply  substantially with FFMSR.  To ensure that automated federal financial  management systems comply with this standard and provide the critical  information needed for decision making, JFMIP issued specific functional  requirements that core financial systems must meet in order to  substantially comply with FFMIA.  Compliance with this standard, at a  minimum, means the core financial module must be configured to   (1) ensure consistent and accurate processing, reporting, and tracking of  program expenditures and budgetary resources, and (2) ensure that  transactions are processed and recorded in accordance with laws and  regulations, and federal accounting standards.  However, the core financial  module—although it uses software certified by JFMIP—does not perform  all mandatory functions.  Specifically, the module:   does not capture and record upward and downward adjustments of  obligations incurred in prior fiscal years, and   posts obligations to the general ledger prior to approval.
Among other things, FFMSR requires federal financial management  systems to produce accurate and reliable information for budgetary  reports, including the Statement of Budgetary Resourcesand the Report  on Budget Execution and Budgetary Resources (Standard Form 133). As  previously discussed, the core financial module does not capture and  record upward and downward adjustments of obligations incurred in prior  fiscal years, which is essential for producing both the Statement of  Budgetary Resources and Standard Form 133 reports.  In addition, FFMSR  requires federal financial management systems to process transactions in  accordance with federal appropriations law, which states that no amount  may be recorded as an obligation unless it has been approved and is  supported by documentary evidence. As a result of system limitations we  have discussed, the core financial module erroneously posts obligations to  the general ledger prior to approval.
section_title: Noncompliance with SGL
paragraphs: The core financial module, as implemented in June 2003, does not  substantially comply with the SGL at the transaction level.  The SGL  requirements ensure consistency in financial transaction processing and  external reporting.   Compliance with this standard, at a minimum, means  that the core financial module must be configured such that  (1) reports  produced by the systems containing financial information can be traced  directly to general ledger accounts, (2) transaction details supporting  general ledger account balances are available and can be directly traced to  specific general ledger accounts, and (3) the criteria (e.g., timing,  processing rules/conditions) for recording financial events are consistent  with accounting transaction definitions and processing rules defined in the  SGL.
As discussed previously, the core financial module does not accumulate  transaction-based support for adjustments to prior year obligations, which  is essential for producing the Statement of Budgetary Resources and  Standard Form 133 reports.  Instead, NASA must rely on estimates, manual  compilations, and system queries to extract the data needed to prepare  these required budgetary reports.  As a result, key budgetary information  reported on the Statement of Budgetary Resources and Standard Form 133  cannot be traced directly to NASA’s general ledger accounts.  NASA also  does not properly record PP&E and materials as assets when they are first  acquired.  Instead, NASA initially records these items as expenses and then  later corrects these records using manual procedures.  Although this  manual process provides NASA a vehicle for reporting PP&E and material  costs for financial statement reporting, it is not sufficient for compliance  with the SGL.  Finally, NASA does not maintain transaction-level detail for  its contractor-held property.   Instead, it relies solely on its contractors to  maintain such records and to periodically report summary-level  information on these assets to NASA.  This situation has resulted in  material weaknesses over this property, as previously reported by NASA’s  current independent auditor.
section_title: Noncompliance with Federal Accounting Standards
paragraphs: The core financial module and related systems, as implemented in June  2003, do not substantially comply with federal accounting standards.  Compliance with these standards is essential to providing useful and  reliable financial information to external and internal users.   Federal  accounting standards are the authoritative requirements that guide  agencies in developing financial management systems, as well as preparing  financial statements.   However, as discussed previously, the core financial  module did not, as of June 2003, process and report financial information in  accordance with federal accounting standards.
The major reasons for the module’s noncompliance with federal accounting  standards are as follows.
The core financial module does not comply with SFFAS No. 1,  Accounting for Selected Assets and Liabilities.  This standard states that  a liability should be recognized and recorded as an account payable  when contractors construct facilities or equipment for the government.   The liability should be based on an estimate of work completed.   However, the core financial module does not capture accrued costs or  record accounts payable when the cumulative costs for a given contract  exceed obligations.  Instead, these transactions are held outside the  general ledger, in suspense, until additional funds are obligated, thus  understating NASA’s reported program costs and liabilities.
The core financial module does not yet provide full-cost accounting  capabilities in accordance with SFFAS No. 4, Managerial Cost  Accounting Standards.  This standard requires agencies to report the full  cost of their programs in their general-purpose financial reports.   However, as previously discussed, NASA, as of June 2003, had not  defined, configured, or tested the appropriate cost pools and cost  allocation structure, which are critical to implementing full-cost  accounting.
The core financial module does not comply with the broader objective  of SFFAS No. 4, Managerial Cost Accounting Standards.  The concepts  and standards included in SFFAS No. 4 are aimed at achieving three  general objectives: (1) providing program managers with relevant and  reliable information relating costs to program outputs, (2) providing  relevant and reliable cost information to assist the Congress and  executives in making decisions about allocating federal resources and  evaluating program performance, and (3) ensuring consistency between  costs reported in general purpose financial reports and costs reported to  program managers.  However, as we reported in April 2003, the core  financial module does not provide program managers, cost estimators,  or the Congress with managerially relevant cost information that they  need to effectively manage and oversee NASA’s contracts and programs.   As a result, NASA’s continuing inability to provide its managers with  timely, relevant data on the cost, schedule, and performance of its  programs is a key reason that GAO continues to report NASA’s contract  management as an area of high risk. Because this information is not  available through the core financial module, program managers will  continue to rely on hard copy reports, electronic spreadsheets, or other  means to monitor contractor performance.  Consequently, NASA risks  operating with two sets of books—one that is used to report information  in the agency’s general-purpose financial reports and another that is  used by program managers to run NASA’s projects and programs.
Compliance with federal accounting standards goes far beyond  receiving a “clean” opinion on financial statements.  A key indicator that  an agency’s financial management systems do not substantially comply  with federal accounting standards is the existence of material  weaknesses in the agency’s internal controls.  As noted earlier,  NASA  has not addressed material weaknesses in its internal controls and  processes over PP&E and materials, which make up nearly 85 percent,  or $37 billion, of NASA’s assets.  Instead, NASA plans to rely on existing  legacy systems and processes—including the extensive use of manual  accounting entries—that the agency’s independent auditor has found to  be inadequate for property accounting.   As a result, NASA faces serious  challenges in complying with these standards.
Although NASA plans to implement an integrated asset management  module in 2005, most of NASA’s issues related to property accounting have  little to do with the lack of an integrated system.  Instead, NASA faces two  key challenges with respect to property accounting: (1) reengineering its  processes for capturing and recording transaction-level detail in the core  financial module’s general ledger and (2) addressing material weaknesses  in its internal controls over property previously identified by NASA’s  independent auditors.   To date, NASA has yet to define specific  requirements for its asset management module or determine how it plans  to overcome the previously identified material weaknesses in NASA’s  internal controls over PP&E and material.
section_title: Conclusion
paragraphs: If NASA continues on its current track, the core financial module and IFMP  will fail to achieve the agency’s stated objective of providing reliable, timely  financial information for both internal management decision-making and  external reporting purposes.  Thus far, NASA has focused on deploying the  system on its established schedule, rather than ensuring that it satisfies the  agency’s internal management and external reporting requirements.  To  meet its schedule, NASA has put off addressing user requirements that  would necessitate significant business process reengineering or extensive  software configuration.  While NASA is meeting its implementation  milestones, it is only able to do so because the agency has deferred critical  system capabilities, such as the ability to properly capture, record, and  account for its PP&E and material; process budgetary accounting entries;  and provide managerially relevant cost information. Until, and unless, the  agency deals with these issues, NASA risks making a substantial  investment in a system that will fall far short of its stated goal of providing  meaningful information for both internal management and external  reporting purposes.
section_title: Recommendations
paragraphs: Based on the findings from this review, in conjunction with our April 2003  report, we reiterate our April 2003 recommendation that NASA:  engage stakeholders—including program managers, cost estimators,  and the Congress—in developing a complete and correct set of user  requirements; and   reengineer its acquisition management processes, particularly with  respect to the consistency and detail of budget and actual cost and  schedule data provided by contractors.
We also recommend that the NASA Administrator direct the Program  Executive Officer for IFMP to implement a corrective action plan in  coordination with NASA’s Chief Financial Officer that will produce  financial management systems that comply substantially with the  requirements of FFMIA, including capabilities to produce timely, reliable,  and useful financial information related to:   property, plant, equipment, and materials;  budgetary information including adjustments to prior year obligations;  accounts payable and accrued costs; and  the full cost of programs for financial reporting purposes.
This plan should include time frames and details on how any changes will  be monitored, tested, and documented.
section_title: Agency Comments and Our Evaluation
paragraphs: In written comments, reprinted in appendix II, NASA disagreed with all of  our conclusions and recommendations in part because we reviewed the  status of the core financial module as of June 23, 2003, instead of  September 30, 2003—the date used for FFMIA reporting. Although NASA  takes issue with the date of our review, it is important to note that we  selected June 2003 because NASA represented that the core financial  module was fully operational at all of its centers at that time. In making that  representation, NASA officials acknowledged that, as part of their  implementation strategy, they had not yet converted the system to support  full-cost accounting.  However, they did not disclose any other deferred  capabilities.
Moreover, NASA’s comments assert that for PP&E and budgetary reporting,  the manual processes or workarounds it has developed to produce year- end balances for the agency’s annual financial statements also satisfy the  requirements of FFMIA.  We disagree with this assertion.  The development  of significant manual workarounds in these areas masks the fact that  NASA’s core financial module is not designed to, and cannot, produce  timely and reliable PP&E and budgetary data with traceability to  transaction-based support.  The ability to produce reliable numbers once a  year for financial reporting purposes does not by itself constitute FFMIA  compliance.  In its written comments, NASA indicated that it has made  changes to the module since June and that the core financial module as  implemented in October 2003 has many of the capabilities that were  lacking in the June 2003 module.  Although we requested status updates  between June and October to track NASA’s progress, we did not reassess  the module’s capabilities as of October 2003.  However, with the possible  exception of full-cost accounting, which was planned for October 1, 2003,  the changes NASA has cited still involve manual workarounds for  producing year-end numbers.  FFMIA goes beyond producing auditable  financial statements once a year and requires financial systems that ensure  accountability on an ongoing basis throughout the year.
subsections: section_title: Reengineering Acquisition Management
paragraphs: In response to our April 2003 recommendation, which we have restated in  this report, to reengineer its acquisition management processes,  particularly with respect to the consistency and detail of budgeted and  actual cost and schedule data provided by contractors, NASA indicated  that it is in the process of addressing a number of our concerns.   Specifically, NASA stated that it (1) has extended the data structure  embedded in the core financial module to capture more detailed cost data,  (2) is currently assessing its contractor reporting requirements, and (3) is  evaluating the possibility of accommodating contract cost and schedule  data in an integrated environment.   While it is too early to assess the  significance or impact of NASA’s current effort, we are encouraged that  NASA is considering the possibility of reengineering its acquisition  management processes.  This would be an important first step toward  ensuring that NASA’s contractors provide the appropriate level and type of  cost data needed for both internal management and external reporting  purposes and that the core financial module is properly configured to  support the agency’s information needs. However, we continue to believe it  would have been more effective and efficient if NASA had conducted its  assessment of contractor reporting requirements as part of a larger  reengineering effort prior to configuration of the core financial module.
Further, any effort that falls short of end-to-end business process  reengineering will likely not result in a system that substantially improves  the data available for contract oversight or ensures consistency between  costs reported in general purpose financial reports and costs reported to  program mangers.
In its written comments, NASA also emphasized that the core financial  module alone cannot meet all of the functional requirements needed to  manage a program or to prepare cost estimates and asserts that  applications such as Erasmus, an executive-level program performance  reporting tool, will enable NASA to meet the full depth and breadth of user  requirements. We agree that the core financial module alone cannot meet  all of NASA’s information needs and that an executive-level reporting tool  such as Erasmus may provide NASA executives with greater visibility over  program performance.  However, Erasmus does little to help program  managers oversee contractor performance, and like the core financial  module, may contain cost data that are not consistent or reconcilable with  cost data used by program managers to manage contracts.  The underlying  problem, as we reported in April 2003, is that NASA uses one set of  contractor-reported cost data to update the core financial module while  program managers use a separate set of contractor-reported cost data that  resides outside the system to monitor contractor performance.   Consequently, the cost data maintained in the core financial module and  reported in NASA’s external financial reports are not consistent or  reconcilable with cost data used by program managers to manage  contracts.
Finally, NASA stated that the asset management module, scheduled for  implementation in 2005, will make a significant contribution to its program  management and cost estimating activities.  This module is primarily  intended to maintain detailed property records for NASA-held property.   Thus, we do not believe an asset management module would have any  impact on the cost, schedule, and performance data needed for program  management and cost estimating.
section_title: PP&E and Materials
paragraphs: NASA disagreed with our recommendation related to IFMP’s ability to  produce timely, reliable, and useful information for PP&E and materials in  accordance with FFMIA requirements.  NASA represented that its current  processes for capturing and recording property for financial statement  reporting purposes also meet the requirements of FFMIA because it has  begun requiring more frequent and detailed property reporting by its 55  largest contractors.  We disagree with NASA’s assertion.  Because NASA’s  current contractor cost-reporting processes do not provide the information  needed to distinguish between capital and non-capital expenditures, NASA  currently records as expenses all contractor costs as they are incurred and  then manually adjusts previous entries to record assets based on periodic  summary-level contractor property reports.  While this process may satisfy  NASA financial statement reporting needs, the development of significant  manual workarounds in this area masks the fact that NASA’s core module is  not designed to and cannot produce timely and reliable PP&E data with  traceability to transaction-based support.  The ability to produce reliable  numbers once a year for financial reporting purposes does not equate to  FFMIA compliance.
In accordance with FFMSR, federal accounting standards, and the SGL,  when an agency incurs costs for the purchase or construction of PP&E and  material, those costs should be recorded in both the agency’s asset  management system and its core financial management systems’ general  ledger.  The only difference for contractor-held property is that the asset  management system belongs to the contractor.  The asset management  system, whether NASA’s or its contractors’, would maintain the agency’s  detailed logistical property records for PP&E and materials—including  information related to asset location, date of purchase, useful life, quantity,  cost, and condition—and the core financial module’s general ledger would  maintain a cumulative balance of all purchased or constructed property  based on the cost incurred for individual items.  The ability to reconcile  detailed transactions in the asset management system with amounts  recorded in the general ledger provides an efficient way to maintain  independent general ledger control over these assets.  As mentioned above,  NASA first expenses all PP&E in the core financial module, and then later,  makes adjustments to record the costs of PP&E as assets at a summary  level.  There is currently no traceability from the core financial module  general ledger to the detailed logistical property records of PP&E and  materials.
NASA also stated that one of the objectives of the asset management  module, now in formulation, is to significantly improve reporting for  contractor-held property.  While it is our understanding that NASA’s new  asset management module, as planned, will maintain detailed property  records for NASA-held property and be integrated with other IFMP  modules, including the core financial module, we know of no plans to add  contractor-held property to this system. In fact, the Federal Acquisition  Regulation requires contractors to maintain the logistical property records  for government property in their possession and prohibits government  agencies from maintaining duplicate property records.  Under these  circumstances, as part of an overall effort to reengineer its acquisition  management process, we believe that NASA must capture the cost and  other information it needs from its contractors and develop traceability to  contractor logistical records to ensure accountability over its contractor- held property on an ongoing basis.
section_title: Budgetary Information
paragraphs: NASA disagreed with our recommendation regarding its ability to produce  reliable, timely, and useful budgetary information, including adjustments to  prior year obligations.  NASA stated that although it identified certain  transactional reporting limitations in its initial deployment of the core  financial module, it developed alternative or “workaround” procedures to  ensure the accurate and timely reporting of the identified transactions.   However, as stated previously, we do not believe that the manual processes  or workarounds NASA uses to produce year-end balances for the agency’s  annual financial statements satisfy the requirements of FFMIA. While  NASA’s written comments indicate that many of these deferred capabilities  were largely enabled by September 30, 2003, they also indicate that more  time will be required before the module can process adjustments to prior  year obligations.  As a result, NASA must use manual workarounds to  process these transactions related to fiscal year 2003 activity.  We note that  these are the same manual procedures used to compensate for deficiencies  in NASA’s legacy systems that resulted in the $644 million error in NASA’s  fiscal year 1999 Statement of Budgetary Resources.
section_title: Accrued Costs and Accounts Payable
paragraphs: NASA disagreed with our conclusion that its overall financial management  system does not properly capture and report all accrued costs and  accounts payable.  However, we did not report that the information was not  contained within the system; rather, we reported that it was not posted to  the general ledger.  We recognize that NASA records costs that exceed  current obligations in the IFMP business warehouse until additional funds  are obligated and in order to highlight or detect potential program cost  overruns.  While we encourage NASA’s effort to monitor costs in excess of  obligations, we do not believe its method for doing so is appropriate.  We  continue to believe that these costs should be properly recorded in the  general ledger in the period in which they are incurred.  The risk in NASA’s  method is that when costs and liabilities are not properly recorded in the  general ledger, these balances are likely to be understated in any financial  reports produced during the year, as well as at year-end.
It is also important to note that comparing costs with obligations will not  necessarily detect a cost overrun.  For example, this strategy would not  have alerted NASA to its largest cost overrun in recent years—the $5 billion  cost growth in the International Space Station program reported in 2001.   This overrun was not the result of incurring more costs than the funds  obligated.  Instead, it was due to the cost growth projected to occur in the  future—i.e., growth in the estimated costs to complete the program.  This  cost overrun went undetected for a long period of time because of NASA’s  deeply-rooted culture of managing programs based on current year budgets  rather than total costs.  As we reported in 2002, for NASA to manage its  program costs properly, it needs to focus on the total costs of a program  rather than just annual budgets.  Thus, NASA’s plan to hold costs in  suspense when they exceed obligations will not make such cost overruns  any easier to detect or manage.  Instead, as we reported in April 2003, to  adequately oversee NASA’s contracts, program managers need reliable  contract cost data—both budgeted and actual—and the ability to integrate  these data with contract schedule information to monitor progress on the  contract.  However, because program managers were not involved in  defining system requirements or reengineering business processes, the  core financial module was not designed to integrate cost and schedule data  needed by program managers.
section_title: Full-Cost Accounting
paragraphs: NASA also disagreed with our recommendation concerning its system’s  ability to account for the full cost of its programs and asserted that it  completed implementation of its full-cost accounting capability within  IFMP as of October 1, 2003.  However, IFMP management told us in early  October that this capability would not become operational until October  26, 2003, after NASA completed its year-end closing procedures.  Because  of our reporting time frame, we did not conduct the detailed procedures  that would have been necessary to determine whether or not this function  had begun operating.
As agreed with your offices, unless you announce its contents earlier, we  will not distribute this report further until 30 days from its date.  At that  time, we will send copies to interested congressional committees, the  NASA Administrator, and the Director of the Office of Management and  Budget.  We will make copies available to others upon request.  In addition,  the report will be available at no charge on the GAO Web site at  http://www.gao.gov.
If you or your staffs have any questions concerning this report, please  contact me at (202) 512-9505 or kutzg@gao.gov, Keith Rhodes at (202) 512- 6412 or rhodesk@gao.gov, or Diane Handley at (404) 679-1986 or  handleyd@gao.gov.  Key contributors to this report are acknowledged in  appendix III.
section_title: Comments From the National Aeronautics and Space Administration
section_title: Objective, Scope, and Methodology
paragraphs: The objective of this report was to assess whether the National Aeronautics  and Space Administration (NASA) Integrated Financial Management  Program’s (IFMP) core financial module, as implemented on June 2003,  would satisfy NASA’s external reporting requirements, such as reliable and  auditable financial statements, congressional information needs, and other  reporting requirements.  Specifically, we assessed whether the core  financial module (1) accurately accounts for Property, Plant, and  Equipment (PP&E) and materials and supplies, (2) properly accounts for  the full cost of NASA’s projects and programs, (3) captures and reports  certain key budgetary information, (4) accurately records accounts  payable, and (5) complies substantially with the requirements of the  Federal Financial Management Improvement Act (FFMIA) of 1996.  We did  not assess other aspects of the core financial module’s capabilities.
We interviewed officials from NASA’s financial management division and  the NASA Office of Inspector General to identify various reporting  requirements and weaknesses in meeting these requirements, and to  determine how the core financial module will provide the data needed to  meet these requirements.  We evaluated fiscal year 2002 internal control  weaknesses reported by PricewaterhouseCoopers, NASA’s independent  auditors, related to PP&E, material and supplies, and financial reporting.  However, for the purposes of this report we did not review the auditors’  underlying work paper support.  We also reviewed NASA’s process for  preparing the Statement of Budgetary Resources and reporting accounts  payable, and any related issues identified by auditors.
We reviewed applicable Treasury, Office of Management and Budget, and  NASA guidance, and related federal accounting standards as well as federal  financial management system requirements promulgated by the Joint  Financial Management Improvement Program.
At two NASA centers, we observed how transactions are recorded in the  general ledger within the core financial module and discussed these  processes with users of the system.  We reviewed nonrepresentative  selections of transactions for PP&E, materials, accounts payable, and  budgetary transactions.  We traced selected transactions to their source  documents, and also traced selected source documents to the general  ledger.  We assessed whether transactions were recorded consistently with  the Treasury Financial Manual.  We also observed and discussed how  information on contractor cost reports is recorded in the core financial  module.
We interviewed various officials from IFMP and its core financial project  design and implementation teams, including the  IFMP Deputy Program  Director, the Core Financial Project Manager, and the Core Financial  Deputy Project Manager to clarify our understanding of the core financial  module’s functions and obtain the most recent information on the status of  various implementation issues as of June 2003.   We also reviewed relevant  audit reports from the NASA IG and the results of an independent  compliance review on the core financial module performed by NASA’s  consultant.
We performed our work primarily at NASA headquarters in Washington,  D.C. and the two NASA centers—Marshall Space Center in Huntsville,  Alabama and Glenn Research Center in Cleveland, Ohio—where the core  financial module was implemented first.  Our work was performed from  April 2003 through September 2003 in accordance with generally accepted  government auditing standards.
We requested comments on a draft of this report from the NASA  Administrator or his designee.  Written comments from the NASA Deputy  Administrator are presented and evaluated in the “Agency Comments and  Our Evaluation” section of this report and are reprinted in appendix II.
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: Staff members who made key contributions to this report were Shawkat  Ahmed, Fannie Bivins, Kristi Karls, Chris Martin, and Maria Storts.
section_title: GAO’s Mission
paragraphs: The General Accounting Office, the audit, evaluation and investigative arm of  Congress, exists to support Congress in meeting its constitutional responsibilities  and to help improve the performance and accountability of the federal government  for the American people. GAO examines the use of public funds; evaluates federal  programs and policies; and provides analyses, recommendations, and other  assistance to help Congress make informed oversight, policy, and funding  decisions. GAO’s commitment to good government is reflected in its core values of  accountability, integrity, and reliability.
section_title: Obtaining Copies of GAO Reports and Testimony
paragraphs: The fastest and easiest way to obtain copies of GAO documents at no cost is  through the Internet. GAO’s Web site (www.gao.gov) contains abstracts and full- text files of current reports and testimony and an expanding archive of older  products. The Web site features a search engine to help you locate documents  using key words and phrases. You can print these documents in their entirety,  including charts and other graphics.
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subsections: section_title: Order by Mail or Phone
section_title: To Report Fraud, Waste, and Abuse in Federal Programs
section_title: Public Affairs