Title: Operations Management Council Internal Control Quarterly Status
1Operations Management Council Internal Control
Quarterly Status
- Thursday, February 15, 2007
- NASA Headquarters
- Room 7C61
2Internal Control Quarterly Status AgendaFebruary
15, 2007
- Opening Remarks Action Status Ms. Dominguez
5 min. - HQ Management Systems Status Ms. Cline 10 min.
-
- Status of Current Internal Control Deficiencies
40 min. - Owner Recommendation
- Asset Management (MW) OCFO no change
- Financial Management System (MW) OCFO no
change - Financial Management Data Integrity (MC) OCFO no
change - Financial Mgmt. Policy Procedures (MC) OCFO no
change - Financial Management Staffing (MC) OCFO no
change - Full Cost Integration (MC) OCFO no change
- Information Technology Security (MW) OCIO no
change - NASA Declassification Program (MC) OSPP close
- Mission Management Aircraft (MC) OIM no change
- Acquisition Management (OW) OPII no change
- Undefinitized Contract Actions (MC) OIM close
Key Material Weakness (MW) Other Weakness
(OW) Management Challenge (MC)
3Action from 7/28/06 Internal Control Meeting
- The Office of Infrastructure and Administration
(IA) will analyze the process for updating key
Agency documents, determine the cause of delays,
and make recommendations to the Deputy
Administrator on ways to improve accountability
for completion of required actions. Due October
6, 2006. - Status Closed per presentation to the Deputy
Administrator on February 9, 2007
4Classification of Internal Control Deficiencies
- Material Weakness (MW) a deficiency in
internal controls that is significant enough to
be reported outside the Agency. - May jeopardize the Agencys mission
- Violates statutory or regulatory requirements
- Significantly weakens safeguards against waste,
loss, unauthorized use, mismanagement of funds,
property, other assets - Other Weakness (OW) a deficiency in internal
controls that should be reported and monitored
internally. - Management Challenge (MC) a concern about a
challenge to management. There is insufficient
information to confirm a serious systemic
internal control weakness in this area. It may
pertain to issues that are outside managements
control or factors that may create an adverse
condition. Close monitoring is required.
5Summary
6NASA Headquarters Audit StatusPresentation to
theOperations Management Council
Management Systems Division Office of
Infrastructure and Administration
- Lynn F. H. Cline
- Deputy Associate Administrator, Space Operations
- Mission Directorate
- Headquarters Executive Management Representative
(EMR) - February 15, 2007
7Activity since last status
- Internal Audit conducted September 18-22, 2006
- External Surveillance audit conducted by National
Quality Assurance, Inc. November 8-10, 2006
8Results
- There is one major finding of nonconformance as a
result of surveillance audits - The Quality Systems Manual is still not updated
(Carry-over for past three assessments) - This has been in work for some time, and is now
at the step where comments received in NODIS have
been dispositioned and official signature package
in process. Document must be signed out by
Deputy Administrator. If not approved by next
surveillance audit, it will be a significant
issue. - The Quality Systems Manual was signed on November
26, 2006 and verification will be confirmed
during the May 2007 External Surveillance Audit. - There is one minor nonconformance finding
- Management Review input shall include information
on, results of audits, customer feedback, process
performance and product conformity, status of
preventive and corrective actions, follow up from
previous reviews, changes affecting the QMS and
recommendations for improvement. - There is currently no document that clearly
describes how this management review activity is
conducted. It is presented as a complex, multi
layered approach to reporting, with information
reported in various venues, but there is no clear
document specifying how this is to occur. (This
should be considered a significant issue.) - Updating NPD 1000.0 and NPD 1000.3 should resolve
this issue.
9Focus Area
- Look at causes of hindrances to timely review and
approval of Quality Manual and other documents. - Previous action discussed by Olga Dominguez
should be adequate, if properly implemented, to
address this on-going HQ Management System
concern - Next surveillance audit will review the status
and concurrency of Agency top level policy and
requirements documents - NPD 1000.0, Strategic Management and Governance
Handbook - NPD 1001.0, NASA Strategic Plan
- NPD 1000.3, NASA Organization
10Future Activities
- Internal Audit March 12-16, 2007
- Surveillance Audit May 2-3, 2007
- Core Requirements (Management Review, Internal
Audit, Corrective Action, Preventive Action,
Customer Satisfaction, Continual Improvement) - Resource Management (6.1, 6.2, 6.3, 6.4)
- Verification of Major Nonconformance corrective
action
11Back Up Charts
12HQ Quality Management System
- The Headquarters (HQ) Quality Management System
(QMS) is a process-based management system that
controls the quality of HQ customer products and
mission requirements - Implements the HQ quality policy (which is also
NASAs policy) as stated in the 2006 NASA
Strategic Plan - HQs customer products are
- NASA Strategic Plan,
- Annual Budget and the Annual Performance Plan (as
represented in the Integrated Budget and
Performance Document), and - Annual Performance and Accountability Report
- The scope of the HQ QMS is mission and mission
support management of the Vision for Space
Exploration, aeronautics and science. - The Deputy Administrator, as the
official-in-charge of the HQ QMS, provides the
resources to implement, maintain, and improve the
QMS - The scope of the Operations Management Council
encompasses all activities conducted by NASA,
including the review of the HQ QMS - The Executive Management Representative has
day-to-day responsibility for the HQ QMS - Supported by the Office of Infrastructure and
Administration
13Asset Management
- Office of the Chief Financial Officer
- Terry Bowie
- February 15, 2006
14BackgroundAsset Management
- The OMC and NASAs independent financial auditors
designated asset management (Property, Plant, and
Equipment) as a Material Weakness. Asset
Management includes Contractor-held and
NASA-held property. - Currently, the OCFO is sharing responsibility for
this Material Weakness with the Programmatic
Internal Control Team (PICT) and the
Institutional Internal Control Team (IICT). - Corrective Action Plans have been developed to
address auditor recommendations from both the FY
2005 and FY 2006 financial statement audits.
These plans define the goal, objectives,
strategies, and actions for improving NASAs
internal controls over Property, Plant, and
Equipment.
15IssueAsset Management
- NASA needs to improve its management controls for
the financial reporting of Property, Plant and
Equipment, and materials including Theme Assets
(formerly Assets-in-Space), Contractor-held
property, spare parts and assets under
construction. Lack of proper management controls
can result in inconsistent financial recording
practices that can misstate asset values and
period expenses. - Root cause
- NASAs policies and procedures are not fully in
conformance with federal requirements. - NASAs obligation documents and disbursements are
not coded to identify whether they relate to
acquisition of property. - Updates Since Last Quarter
- Provided revisions to Agency-wide policy/process
documents - 7120.5D Establishes the requirement for Project
Managers to determine Alternative Future Use for
projects and identify capital acquisitions from
project inception - 7120.7 Establishes WBS Level 2 requirements for
Internal Use Software projects - Financial Management Requirements (FMR), Volume
6, Chapter 4, Plant, Property and Equipment - 7120.X (Research and Technology) - Establishes
the requirement for Project Managers to determine
Alternative Future Use for projects and identify
capital acquisitions from project inception - Provided Business Process Requirements for the
IEMP Integrated Asset Management PPE Module - Met with OPII, OCE, PAE, Policy, Procurement,
and Mission Directorates to discuss proposed
changes to the Contractor Cost Reports (NF533)
and WBS changes - Created a system change request to have a capital
asset indicator added to both SAP and MdM, which
will allow for flagging of costs from inception - Met with Procurement and Logistics
representatives to integrate property management
practices.
16Critical Milestone StatusAsset Management
17Planned Actions for Next QuarterAsset Management
- Continue working with the AAPC and FASAB to
finalize guidance on the accounting treatment of
our Agencys space exploration projects
(mission-related projects) - Continue work on PPE Implementation plan tasks
to include revising and documenting business
process, policy and procedural changes - Meet with the Mission Directorate Business
Analysts community to communicate their roles and
responsibilities in the management of PPE - Prototype financial property solution with
existing project - Continue working with the Offices of Program and
Institutional Integration, Policy, Procurement,
Chief Engineer and Mission Directorates, to
ensure revisions to the contractor cost reporting
process are developed by all stakeholders. - Continue working with the Procurement and
Logistics communities to integrate property
management practices. - Continue working with the IEMP IAM Project Team
members on the blueprinting of the PPE Module to
ensure revised business processes are
implemented. - Continue to work with MdM and Competency Center
staff to ensure requested system changes are
configured - Work with OCE to ensure asset related changes are
incorporated into final issuance of 7120.5D,
7120.7 and 7120.X - Through the Senior Assessment Team (SAT),
continue to work with the Institutional Internal
Control Team (IICT), the Programmatic Internal
Control Team (PICT), and the Financial Management
Internal Control Team (FMICT) to integrate
policy, procedures, and internal controls
18RecommendationAsset Management
- Asset Management should continue to be carried as
a Material Weakness
19Financial Management System
- Office of the Chief Financial Officer
- Terry Bowie
- February 15, 2007
20BackgroundFinancial Management System
- In 2005, the OMC designated Financial Management
System as a Material Weakness. Financial
Management System captures challenges related
to - Confirming configuration
- Validating the accounting
- Validating construction of the financial reports
- Currently, the OCFO is sharing responsibility for
this Material Weakness with the Office of the
Chief Information Officer and the Integrated
Enterprise Management Program (IEMP) Office. - Corrective Action Plans have been developed to
address auditor recommendations from both the FY
2005 and FY 2006 financial statement audits.
These plans address improvements required for
NASAs financial management system and ensure
that processes achieve accurate, reliable, and
timely financial information.
21Issue Financial Management System
- Since the completion of the rollout of the new
system, challenges in system processing,
configuration, and capabilities have surfaced and
the current version of the SAP system has some
capability limitations which have required the
definition and implementation of compensating
controls. - Root cause
- Conversion from 10 disparate legacy financial
systems supported by over 120 subsidiary systems,
along with over a decade of historical data, to a
single integrated financial management system
highlighted long-standing data and process
issues. - Updates Since Last Quarter
- Implemented SAP Version Update system
improvements - Continued to generate and review monthly
reconciliations - Continued to execute compensating procedures to
analyze Business Warehouse data on a quarterly
basis to ensure that liabilities are
appropriately recorded
22Critical Milestone Status Financial Management
System
23Planned Actions for Next Quarter Financial
Management System
- Review funds control processes and submit to OMB
for certification - Continue to prepare monthly financial statements
within 30 days of period close - Continue to generate monthly management reports
24Recommendation Financial Management System
- Financial Management System should continue to be
carried as a Material Weakness.
25Financial Management Data Integrity
- Office of the Chief Financial Officer
- Terry Bowie
- February 15, 2007
26Background Financial Management Data Integrity
- In 2005, the OMC designated Financial Management
Data Integrity as a Material Weakness.
Financial Management Data Integrity captures
challenges related to - Environmental Liabilities
- Fund Balance with Treasury (FBWT)
- Currently, the OCFO is sharing responsibility for
this Material Weakness with the Offices of
Infrastructure and Administration, Procurement,
and the Integrated Enterprise Management Program
(IEMP). - The FY 2006 financial statement audit removed
Environmental Liabilities and Fund Balance with
Treasury (FBWT) as reportable conditions. - Corrective Action Plans have been developed to
address auditor recommendations from both the FY
2005 and FY 2006 financial statement audits.
These plans address validating the tools and
methodology used to prepare the unfunded
environmental liability estimates and ongoing
monitoring and control of financial accounts,
including Fund Balance with Treasury. - In 2006, the OMC lowered the significance level
of Financial Management Data Integrity to a
Management Challenge
27Issue Financial Management Data Integrity
- NASA needs to continue to improve its current
procedures to ensure that all reconciling items
are thoroughly researched, resolved timely, and
reviewed by appropriate center and headquarters
OCFO personnel. NASA needs to improve existing
environmental liability procedures and implement
needed internal controls to assure the improved
procedures are adhered to and followed. - Root cause
- Relates to issues from data conversion system
processing in the early stages of production
operation. - Updates Since Last Quarter
- Monitored metrics monthly
- Conducted on-going monitoring to ensure monthly
reconciliations are performed and appropriate
corrective actions are taken - Continued to conduct on-going review and
monitoring of compliance with Fund Balance with
Treasury policies, procedures, and practices
28Critical Milestone Status Financial Management
Data Integrity
29Planned Actions for Next Quarter Financial
Management Data Integrity
- Review existing guidance for account
reconciliation and analyses - Continue to monitor metrics monthly
- Continue to conduct on-going monitoring to ensure
monthly reconciliations are performed
30Recommendation
- Financial Management Data Integrity should
continue to be carried as a Management Challenge.
31Financial Management Policy and Procedures
- Office of the Chief Financial Officer
- Terry Bowie
- February 15, 2007
32Background Financial Management Policies and
Procedures
- In 2005, the OMC designated Financial Management
Policies and Procedures as a Management
Challenge. This challenge is related to
completion of the Financial Management
Requirements (FMR).
33IssueFinancial Management Policies and Procedures
- NASA needs to continue to improve its current
policy to ensure improvement of existing
procedures and implement needed internal controls
to assure the improved procedures are adhered to
and followed. - Root cause
- NASAs policies and procedures are not fully in
conformance with federal requirements - Implementation of the Integrated Enterprise
Management Program required revision of policies
and procedures - Updates Since Last Quarter
- Implemented monthly financial reporting,
including Center compliance with monitoring and
controls requirements - Performed/performing A-123 and monitoring reviews
at Centers
34Critical Milestone Status Financial Management
Policies and Procedures
35Recommendation Financial Management Policies and
Procedures
- Financial Management Policies and Procedures
should continue to be carried as a Management
Challenge.
36Financial Management Staffing
- Office of the Chief Financial Officer
- Terry Bowie
- February 15, 2007
37BackgroundFinancial Management Staffing
- In 2005, the OMC designated Financial Management
Staffing as a Management Challenge. Financial
Management Staffing captures challenges related
to - Staffing Levels
- Personnel Skill Mix
- Workforce Development
- Currently, the OCFO is sharing responsibility for
this Management Challenge with the Office of
Institutions and Management. - Corrective Action Plans have been developed to
address auditor recommendations from both the FY
2005 and FY 2006 financial statement audits. The
plans include actions to address workforce
development.
38Issue Financial Management Staffing
- NASA needs to ensure adequate staffing for
financial management functions across
Headquarters and the Centers and to continually
provide additional handson training for
financial personnel to ensure that they
understand their roles in financial reporting. - Root cause
- With the implementation of the Integrated
Enterprise Management Program (IEMP), additional
training was required due to new processes. - The implementation of the IEMP Core Financial
module represented a major transformation of
NASA's financial management systems and
processes. - Updates Since Last Quarter
- Made minimal progress in hiring this quarter
- Vacancy announcements were posted for GS9-14
Accountants, Budget Analysts and GS-15
Accountants - Fourth quarter of 2006 5 candidates accepted
offers 7 staff members resigned - Currently 24 vacancies (8 managerial positions)
- 3 Budget Analyst and 1 Administrative Officer
positions announced and candidates selected
offer pending outcome of external assessment - 2 Supervisory Budget Analyst positions pending
outcome of external assessment - Submitted an OCFO Reorganization Proposal on
September 1, 2006 - Developed a Workforce Assessment (Sep 06) and a
Workforce Plan (Oct 06) - Workforce Plan includes career development,
forecasting, performance measurement, and
recruiting/retention - Training Provided to OCFO Staff
- Appropriation Law
- Budget Analysts Essential Guide to Formulation,
Justification and Execution - U.S. Standard General Ledger
39Critical Milestone Status Financial Management
Staffing
40Planned Actions for Next Quarter Financial
Management Staffing
- Gain approval for proposed reorganization
- Finalize FTE ceilings and establish hiring
targets for needed skills, consistent with
workforce analysis - Continue hiring to approved ceiling
- Design training program to address the needs of
the organization, consistent with workforce
analysis
41Recommendation Financial Management Staffing
- Financial Management Staffing should continue to
be carried as a Management Challenge.
42Full Cost Integration
- Office of the Chief Financial Officer
- Terry Bowie
- February 15, 2007
43BackgroundFull Cost Integration
- In 2005, the OMC designated Full Cost
Integration as an Other Weakness. Full Cost
Integration addresses challenges related to a
lack of understanding of full cost policies and
procedures. - In the past, the emphasis of full cost activity
was focused on full cost accounting. Today,
emphasis is needed on cost information tailored
to science/engineering and institutional program
decision making. - In 2006, the OMC reduced the significance level
of Full Cost Integration to a Management
Challenge.
44IssueFull Cost Integration
- Full Cost concepts need to be better integrated
into NASA operations. Despite implementing a Full
Cost accounting system and many Full Cost
processes, NASA still lacks the level of cultural
change needed to fully transition to Full Cost
management. - Root cause
- Insufficient stakeholder training
- Unintended consequences and behaviors realized
from initial full cost approaches - Some policies and planned processes were based on
insufficient experience and need to be refined to
reflect lessons learned - Updates Since Last Quarter
- Cost Objectives Study completed by independent
cost experts - Cost Objectives Working Group assessing those
study findings - Clarify objectives for full cost management
- Develop/prioritize specific cost information
improvement actions - Develop plan of action and milestones
- Support Agency requirement for simplified cost
management - Center Management and Operations (CMO) in place
for FY07
45Critical Milestone Status Full Cost Integration
46Planned Actions for Next QuarterFull Cost
Integration
- Complete Cost Objectives Working Group report
- Plan for implementation of near-term
recommendations in 4th quarter
47RecommendationFull Cost Integration
- Full Cost Integration should continue to be
carried as a Management Challenge.
48Information Technology Security
- Office of the Chief Information Officer
- Scott Santiago
- February 15, 2007
49Background
- The current audits of NASAs IT Security Program
by the NASA OIG are identifying similar
deficiencies that had been identified and
addressed in previous OIG audits and through NASA
corrective actions. - Impacts
- Effect on mission accomplishment puts the
integrity, availability and confidentiality of
all NASAs critical data at risk. - Cost impact potential loss of ITAR and SBU
information that costs NASA billions to develop
or acquire. - Compliance impact noncompliant with the Federal
Information Security and Management Act. - Budgets and schedule Corrective Action Plan
requires reallocation of mission resources to
bring Agency IT systems into compliance,
potentially impacting mission budgets and
schedules, - Operating efficiency collaboration across
Centers is seriously hampered due to
inconsistencies in the way security solutions
have been implemented at Centers. - All NASA organizations are at risk.
50Issue
- Description of deficiency In order to properly
protect NASAs information and Information
Technology (IT), the NASA IT Security Program
needs more effective implementation, monitoring,
verification and validation and enforcement. - Root cause Current ITS Review established to
determine root cause. On schedule to be completed
February 2007. - Updates since last quarter
- New IT Security clause - Completed Feb. 2007
- Completed NASA IT Security review, finalizing
report and corrective action plan. Scheduled for
completion end of February 2007. - Established interim FISMA corrective action plan
in December 2006
51Deficiency Milestone Status
52Planned Actions for Next Quarter
- Review completed January 2007, the final report
with recommendations and corrective action plan
due February 2007.
53Recommendation
- Continue as a Material Weakness until corrective
actions are implemented and they begin to
demonstrate to NASA management the required
results to assure that risk is being managed at
an acceptable level - All Centers have demonstrated that all updated or
new ITS Plans comply with existing NASA Policy. - NASA computers and devices have mitigated known
vulnerabilities based on accepted risk levels. - NASA intrusion response
- Intrusion detection covers all network
demarcation points between NASA networks and
external networks. - NASA is capable of investigating all potential
compromised devices immediately following
detection.
54NASA Declassification ProgramManagement
Challenge (MC)
- Office of Security and Program Protection
- Steve Peyton
- February 15, 2007
55Background
- NASA had a significant backlog of permanent
records containing classified national security
information (CNSI) that needed to be reviewed for
continued classification pursuant to EO 12958
amended.
56Issue
- Deficiency Description
- NASA faced a December 2006 deadline to insure
that all permanent records containing CNSI that
are 25-years old or older are subjected to
classification review. Poor past records
management practices prevented the identification
of records subject to Section 3.3 of EO 12958
amended, resulting in NASAs inability to
identify its total universe to be considered for
declassification. The identified root causes
significantly impeded the classification review
programs efforts. EO 12958 as amended contains
a sliding-window requirement for NASA to conduct
yearly classification reviews of permanent
records containing CNSI. - Root Causes
- Insufficient staffing
- Historically poor records management
- Insufficient funding
- Lack of Declassification Guides
- Insufficient resident expertise to perform
classification reviews for older programs - Insufficient support from senior management
(commitment of resources) - Corrective Action Plan (CAP)
- A comprehensive CAP was developed and distributed
to the OMC, OIG, all Mission Directorates, and
Center Security Offices on August 1, 2005. - Update Since Last Quarter
- 661,000 pages reviewed (goal was 500,000)
57Deficiency Milestone Status
58Planned Actions for Next Quarter
- Begin to review documents to meet December 31,
2007 deadline. - Review the number of Referrals received from
Other Government Agencies to meet December 31,
2009 deadline. - Review Special Media requirements that are
required to be reviewed by December 31, 2011.
59Recommendation
- This deficiency should be removed as a Management
Challenge (MC). - The lessons learned and the established teams
will enable us to keep the Declassification
process moving forward. - Request the Mission Directorates and Center
Directors continue to provide their support to
this continued declassification effort.
60Mission Management Aircraft
- Infrastructure and Administration
- Joe Walker
- February 15, 2007
61Background
- GAO audit of Agencys FY03 and FY04 Mission
Management Aircraft (MMA) operations highlighted
control deficiencies with respect to management
of NASAs MMA. - MMA operations were also questioned in several
prior GAO and NASA IG audit reports.
62Issue
- Inadequate documentation and periodic review of
MMA mission requirements Resolved - A-76 cost comparisons of all alternatives to
government ownership of MMA have been completed - Insufficient HQ oversight - Resolved
- Lack of integrated IT system to capture and
report aircraft cost utilization Resolved - MMA downgraded from an Other Weakness to a
Management Challenge at the October 2006 OMC
Meeting.
63Deficiency Milestone Status
64Planned Actions for Next Quarter
- Respond to recommendations from OIG audit of A-76
Cost Comparison studies
65Recommendation
- Mission Management Aircraft should remain a
Management Challenge until completion of the OIG
audit of the A-76 Cost Comparison studies
66Acquisition Management
- Office of Program and Institutional Integration
(OPII) - Rita Svarcas
- February 15, 2007
67Background
- The Inspector General (IG) and the GAO (via its
High Risk List) assert that NASA is not providing
proper acquisition oversight. This is a
long-standing deficiency. OCE, OP, OGC, OCFO,
IEMP, and OPII are working together, and with the
OIG and the GAO, to address the concerns and
correct the deficiency. - Major activities include
- 16 May 06 SMC approved Agency Strategic
Acquisition Approach that enables informed
decisions earlier in the acquisition process. - 18 July 06 OCE briefed Deputy Administrator on
recommended approach that addresses IGs concerns
and GAOs High Risk rating. - 28 July 06 Based on OCE briefing, Acquisition
Management deficiency designated as an Other
Weakness, with OPII as the POC. - 15 September 06 OCE presented draft
implementation documents to OPII for review and
finalization. - 21 November 06 Team of HQ representatives
presented status of related activities to GAO
team, with OIG in attendance. - 31 January 07 GAO issued High-Risk Update,
re-stating concerns and necessary improvements.
68Issue Description of Deficiency
- Weak link between financial management and
program management decisionmaking - hinders Agencys ability to effectively
- Estimate costs
- Perform contract oversight
- Analyze contractor performance, including EVM
- Establish strong integrated business processes
and associated tools
69Issue Root Cause
- GAO High-Risk (May 19, 2004)
- Weak link between financial management and
program management decision-making - Financial management culture that has not fully
acknowledged nature and extent of financial
management difficulties - GAO High-Risk (January, 2005)
- Lack of modern, fully implemented integrated
financial management system - Undisciplined cost estimating processes in
project development - Inability to obtain information needed to assess
contract progress - GAO High-Risk (Jan 31, 2007)
- Calls for re-engineering of cost reporting
process - Lack of cost and performance data
- To develop credible estimates
- To compare BCWP to ACWP
- Lack of analytical tools
- Lack of trained staff for cost analysis and EVM
70Updates Since Last Quarter
- Planned Actions were
- Finalize list of policies requiring modification.
- Accomplished.
- Establish case study criteria, review current
candidates, and obtain approval of senior
management. - Revised approach contemplates joint case studies
addressing both this Weakness and the IEMP
program/project management study (regarding
requirements and data gaps). - Research relevant Agency analyses and
initiatives, including IEMP and other tools. - Accomplished. Reviewed related studies and
identified new Management/Business Systems
Integration Group (M/BSIG) as a key venue for
addressing business process issues in a
cross-functional manner.
71Deficiency Milestone Status
72Planned Actions for Next Quarter
- Prepare Corrective Action Plan to resolve High
Risk area - Involving multiple organizations OCFO, OP,
PAE, OCE, IEMP (M/BSIG), OPII - Plan will ultimately involve
- GAO agreement
- Deputy Administrator correspondence
- Tracking progress to completion (GAO
concurrence) - Continue modifying policies to incorporate
ASP/ASM/PSM - Establish case study plan in conjunction with
IEMP and the M/BSIG
73Recommendation
- This deficiency should continue to be carried as
an Other Weakness.
74Undefinitized Contract Actions (UCAs)
- Office of Procurement
- Deborah ONeill
- February 15, 2007
75Background
- UCAs are used when there is an urgent need to
- - initiate work by contractors to meet
schedules or - - turn off contractor performance in order to
stop their incurrence of costs before a final
price or estimated cost and fee have been
negotiated and mutually agreed upon by NASA and
the contractor. - When used appropriately, UCAs are a legitimate
- procurement tool.
76Issue
- Description of Deficiency
- - GAO audits identified in early 1990s large
dollar amount of UCAs (6.6 billion) which
resulted in their appearing as part of GAO
Contract Management High Risk. This remained the
case until the GAO 2007 update when UCAs were no
longer identified as part of the Contact
Management High Risk. - Root cause
- - Use of UCAs has fluctuated over time due to
the temporary need to expedite certain
activities. Problems may occur if they are
inappropriately used, there are no dollar
limitations on the amount of a UCA, and UCAs are
not definitized in a reasonable period of time.
77Deficiency Milestone Status
78Planned Actions for Next Quarter
- Continue to require prior approval
- - Head of Contracting Activity for UCAs gt 100K
- - Center Procurement Officer for UCAs lt 100K
- - AA for Procurement for Letter Contracts gt
Center - Master Buy Plan threshold or 10M (ESMD
and - SOMD)
- - Center Procurement Officer for all other
Letter - Contracts
- Continue to monitor and follow up with Centers on
UCA activity on a monthly basis - Dollars
- Number of actions
- Time it takes to definitize (within 180 days)
79Planned Actions for Next Quarter(Continued)
- Continue to review as part of each Center
Procurement Management Survey, self-assessments,
and Center Procurement Officer one-on-one
meetings with Assistant Administrator for
Procurement
80Recommendation
- This deficiency should be closed because UCAs are
actively being managed and reported resulting in
the dollar amount having declined from 6.6
billion in the early 1990s to less than 500
million. This has been recognized by GAO with
the deletion of UCAs from its January 2007
updated High Risk Series report.
81Backup
82Total NASA UCAs Actions by Age January 31, 2007
83(No Transcript)
84(No Transcript)
85Summary
86Governance of Internal Controls at
NASAChristyl JohnsonTerry BowieCharles
ScalesFebruary 15, 2007
87Background
- Agency must comply with updated OMB Circular
A-123, Managements Responsibility for Internal
Control, Dec. 2004 - Provide assurances of internal controls
- Separate assurance on internal controls over
financial reporting - Report on identified material weaknesses and
corrective actions - Assessment of internal controls must include
programmatic, financial, and institutional
management, and must be conducted as effectively
and efficiently as possible
88Need for Modification to Current Approach
- In 2006, it became obvious that supporting
documentation and evidence for the annual
statement of assurance was severely lacking.
Financial evidence was documented, but the
programmatic and institutional components were
not. - NASA relied upon external audit bodies to
identify weaknesses, instead of actively
identifying, managing and correcting weaknesses
internally. - Perception existed that internal controls is
strictly financial
89Need for Modification to Current Approach
- OMC was tasked with the responsibility of
reviewing and monitoring all reported internal
control deficiencies. This proved to be an
arduous task, and not an efficient role for the
OMC. The Senior Assessment Team (SAT) was not
functioning as reviewing body. - An Internal Controls workshop with representation
from programmatic, financial, and institutional
components revealed a stovepiped approach to
managing internal controls. The SAT was not
effectively integrating internal controls as a
consequence, risk to NASA increased both for
internal management effectiveness and external
audits.
90Previous Responsibilities of the Senior
Assessment Team
- Promote effective Agency-wide internal controls
- Identify who will perform assessments
- Document performance requirements and guidance
- Approve assessment objectives, scope, and other
relevant requirements and communicate these to
assessable units - Monitor the progress of internal control
assessments
91New Responsibilities of the Senior Assessment Team
- Ensures adequate resources are devoted to the
internal control evaluation process and NASAs
compliance with the requirements of OMB Circular
A-123 (identifying key controls, developing a
testing plan, documenting test results, and
reporting on the effectiveness of the controls) - Ensures Senior Assessment Team decisions are
documented - Advises the Operations Management Council on the
content of the Administrators Annual Statement
of Assurance, and submits to the Administrator a
statement on whether there is reasonable
assurance that NASAs internal controls over
programs, institutions, and financial reporting
are achieving their intended objectives.
92Proposed Responsibilities of the Senior
Assessment Team
- Integrates and coordinates internal controls and
policies across programmatic, financial, and
institutional management for improved efficiency
and effectiveness of Agency internal management
controls - Provides oversight of the design and
implementation of an effective and comprehensive
Agency-wide internal control program - Leads Agency prioritization of internal control
requirements for the current year and develops
plans for prioritization in the out-years
consistent with Agency vision and mission - Monitors and assesses Agency material weaknesses
for the OMC recommends action as appropriate
93Proposed Responsibilities of the Senior
Assessment Team
- Reports material weaknesses to OMC for further
action - Tracks progress of Agency-wide corrective action
resolution - Supports OMC and the establishment of an
integrated set of metrics to measure the Agencys
progress towards its goals - Compiles supporting documentation for the
Administrators Statement of Assurance from HQ
Offices and Centers - Promotes continuous internal controls evaluation
and monitors the progress of assessments
throughout the Agency
94Previous Governance Structure
Operations Management Council (OMC)
95New Governance Structure
Operations Management Council (OMC)
96Justification for Change to Chair of the SAT
- Under the new governance structure, the Office of
Program and Institutional Integration (OPII) is
the manager of Agency-level integration of
programmatic and institutional functions and
activities, and is best positioned to recognize
internal management control deficiencies across
programmatic, institutional, and financial
entities - The SAT will enhance the OPII role as focal point
for programmatic requirements and as the
integrator of functional policy requirements by
providing current information on the state of
internal management controls to meet those
requirements across the Agency
97Justification for Change to Chair of the SAT
- The OPII, as SAT Chair, is best positioned to
coordinate the development of an Integrated
Internal Control Plan and determine appropriate
assessable units for review and analysis - The OPII as SAT Chair, is best positioned to
identify internal control deficiencies within the
Agency management systems and recommend
appropriate action - The OPII, as SAT Chair, is best positioned to
render decisions in the overall best interests of
the Agency, with no dominant programmatic,
institutional or financial filter
98Previous Execution of Internal Controls Functions
OFFICE OF
INSTITUTIONS AND MANAGEMENT
OFFICE OF THE ASSOCIATE ADMINISTRATOR FOR
INSTITUTIONS AND MANAGEMENT
OFFICE OF DIVERSITY AND EQUAL OPPORTUNITY
OFFICE OF
OFFICE OF HUMAN CAPITAL MANAGEMENT
INFRASTRUCTURE
AND
ADMINISTRATION
OFFICE OF SMALL BUSINESS PROGRAMS
OFFICE OF SECURITY AND PROGRAM PROTECTION
NASA SHARED
OFFICE OF PROCUREMENT
SERVICES CENTER
In accordance with law, the offices of
Diversity and Equal Opportunity and Small
Business Programs maintain reporting
relationships to the Administrator and Deputy
Administrator.
99New Execution of Internal Controls Functions
OFFICE OF
INSTITUTIONS AND MANAGEMENT
OFFICE OF THE ASSOCIATE ADMINISTRATOR FOR
INSTITUTIONS AND MANAGEMENT
OFFICE OF INTERNAL CONTROLS AND
MANAGEMENT SYSTEMS
OFFICE OF INFRASTRUCTURE AND ADMINISTRATION
OFFICE OF DIVERSITY AND EQUAL OPPORTUNITY
OFFICE OF HUMAN CAPITAL MANAGEMENT
OFFICE OF SMALL BUSINESS PROGRAMS
OFFICE OF SECURITY AND PROGRAM PROTECTION
NASA SHARED SERVICES CENTER
OFFICE OF PROCUREMENT
In accordance with law, the offices of
Diversity and Equal Opportunity and Small
Business Programs maintain reporting
relationships to the Administrator and Deputy
Administration.
100Justification for New Office Reporting to AA, IM
- The new Office will
- Help ensure compliance with Federal objectives
and requirements for internal management controls
- Provide focused leadership to assess and
integrate a comprehensive internal management
control program consistent with the Agency
governance structure - Acquire and administer the resources necessary to
identify key management controls, develop a
testing plan, document testing results, and
report on the effectiveness of the Agencys
internal controls - Provide the daily oversight of the Agency
internal control program including establishing
controls, performing assessments, identifying and
reporting deficiencies, and monitoring corrective
actions
101Justification for New Office Reporting to AA, IM
(cont.)
- Creation of this new Office demonstrates
NASAs commitment to a comprehensive and
integrated internal management control program
and emphasizes the importance of internal
management controls and risk assessment to the
NASA community in support of the Agencys mission
102Office of Internal Controls and Management
Systems Responsibilities
- Executive Leadership for Internal Controls
- Support for the Senior Assessment Team (SAT)
- Operational leadership of the Institutional
responsibilities of the SAT - Support for correction of internal control
deficiencies - Mission Support Plan (MSP) Maintenance and
Oversight - Progress reporting against MSP objectives and
goals - Updates of MSP and process enhancements
- Audit Liaison
- Primary point-of-contact for GAO/OIG audit
activities - Reporting on audit recommendations and corrective
actions - Management Systems
- Support for internal and external assessments
- Directives Management and NASA Online Directives
Information System (NODIS)
103Next Steps
- Move current management systems function from IA
to a new office for Internal Management Controls,
which reports directly to the AA for Institutions
and Management - Update Charter with approved roles and
responsibilities - Finalize an Organizational Implementation Plan
- Finalize an Integrated Internal Controls Plan
- Update Internal Control policy documents
- Implement Plan in FY07 (2nd Quarter)