Policy
Directive
Effective Date: November 01, 2024
Expiration Date: November 01, 2029
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NASA Policy Directive |
NPD 9910.1B Effective Date: November 01, 2024 Expiration Date: November 01, 2029 |
It is NASA's policy:
a. To establish a robust program for audit liaison, resolution, and follow-up to manage audit recommendations issued by the Government Accountability Office (GAO) and the NASA Office of Inspector General (OIG), and non-Federal auditors performing work on behalf of these audit organizations, in accordance with Office of Management and Budget (OMB) Circular A-50, Audit Follow-up.
b. To respond in a timely manner to draft and final audit reports issued by GAO and OIG in accordance with the requested or statutory due dates.
c. That all officials share responsibility in improving the effectiveness and efficiency of NASA's operations by taking responsive and effective corrective action on audit findings and recommendations consistent with GAO's "Standards for Internal Control in the Federal Government."
d. That agreed-upon corrective actions associated with audit recommendations are implemented in a timely manner, generally not to exceed one year from the issuance of the final audit report, dependent upon the complexity and scope of the corrective actions.
e. To recognize, support, and utilize GAO/OIG audits of NASA activities as an important element of NASA's management system, in accordance with OMB Circular A-123, Management's Responsibility for Enterprise Risk Management and Internal Control, and NPD 1200.1, NASA Internal Control.
f. That NASA personnel cooperate with and support the efforts of GAO and OIG representatives in the performance of all audits, evaluations, and reviews to provide an accurate, fair, and balanced representation of issues being evaluated.
g. That in those instances where a management decision on a GAO/OIG audit recommendation is not made within six months, the NASA Audit Follow-up Official (AFO) will convene an Audit Resolution Meeting with appropriate management and audit organization officials for the purpose of reaching a management decision. A final management decision made by the AFO or the NASA Administrator is final and is not contingent upon GAO or OIG approval.
h. That efforts will be made to resolve potential nonconcurrences on GAO and OIG audit recommendations at the lowest possible management level.
i. That Contracting Officers (COs) make the best possible use of contract audit advice.
a. This NPD is applicable to NASA Headquarters and NASA Centers, including their Component Facilities and Technical and Support Service Centers.
b. This NPD applies to audits, reviews, evaluations and assessments performed by the GAO and OIG and non-Federal auditors performing work on behalf of these audit organizations.
c. This NPD does not apply to criminal or administrative investigations conducted by the GAO, OIG, or other Federal law enforcement agencies.
d. This NPD does not apply to audit resolution and follow-up activities associated with audits of NASA's Exchange and Morale Support Activities or recipients of Federal awards required by the Single Audit Act of 1984, as amended, Public Law (Pub. L.) 98-502, and as implemented by Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 Code of Federal Regulations (CFR) Part (pt.) 200.
e. This NPD does not apply to audit resolution and follow-up for contract audits performed by the Defense Contract Audit Agency, other executive branch audit organizations, and non-Federal auditors; policy is found at NASA Federal Acquisition Regulation (FAR) Supplement, 48 CFR section 1842.7301.
a. Inspector General Act of 1978, as amended, 5 United States Code (U.S.C.) Chapter (Chap.) 4.
b. Federal Managers' Financial Integrity Act of 1982, Pub. L. No. 97-255, 96 Stat. 814 (1982).
c. Standards for Internal Control in the Federal Government, GAO-14-704G (September 10, 2014).
a. OMB Circular A-50, Audit Follow-up.
b. OMB Circular A-123, Management's Responsibility for Enterprise Risk Management and Internal Control.
c. NPD 1200.1, NASA Internal Control.
a. The NASA Administrator is responsible for the following:
(1) Ensuring the preparation of the annual Audit Follow-up Report, pursuant to 5 U.S.C. Chap. 4, and required reporting in conjunction with Good Accounting Obligation in Government Act, Pub. L. 115-414 .
(2) Appointing a top management official as the NASA AFO.
(3) Making final determinations on the release of information in conjunction with GAO and OIG audits.
(4) Making final management decisions on concurrences and non-concurrences not otherwise delegated to the AFO.
b. The AFO is responsible for:
(1) Making management decisions within six months of the issuance of a final audit report (unless reserved by the Administrator) when nonconcurrences cannot be resolved at lower levels between NASA management and the auditors.
(2) Ensuring that NASA's audit follow-up processes, management decisions concerning audits, and corrective actions comply with OMB Circular A-50 and all other applicable laws and regulations.
c. The Director, Office of the Executive Secretariat (or designee) is responsible for:
(1) Overseeing overall Agency implementation of audit liaison, resolution, and follow-up activities, including periodic assessments of recommendations and corrective action to identify trends or system-wide problems and to recommend solutions.
(2) Assigning an Office of Primary Responsibility to lead the audit liaison activities for the duration of an audit engagement.
(3) Ensuring significant and relevant activities, (e.g., entrance and exit conferences, requests for extension and their disposition of final actions, and the auditor's disposition of audit recommendations), are documented in a timely and accurate manner in NASA's Audit and Assurance Information Reporting System (AAIRS).
(4) Maintaining a comprehensive record of action taken on both monetary and nonmonetary findings and recommendations, as well as a follow-up action to ensure the completion of agreed-upon corrective actions.
(5) Ensuring that management decisions are made on audit recommendations issued by the GAO and OIG within six months of the issuance of the final report.
(6) Preparing: a) an annual report addressing the Agency's reporting requirements in 5 U.S.C. Chap. 4, as amended, and b) required reporting in Pub. L. 115-414.
(7) Ensuring the resolution and disposition of all audit reports are consistent with applicable laws, regulations, and Agency policy as provided by OMB Circular A-50.
(8) Requesting extensions to audit response timelines from the GAO or OIG on behalf of the Agency when necessary.
d. Officials-in-Charge (OIC) and Center Directors are responsible for:
(1) Establishing processes within its management systems to ensure prompt and proper management decisions and implementation of GAO/OIG audit recommendations.
(2) Ensuring timely Agency responses to draft and final audit reports, which are due typically 30 days after draft report issuance or 180 days after final issuance of a GAO report with a recommendation addressed to the Administrator. This includes obtaining input/agreement on the Agency audit responses with content-dependent formulation partners, as applicable.
(3) Ensuring implementation of agreed-upon recommendations as soon as practicable.
(4) Ensuring that audit disputes (nonconcurrences) are negotiated at the lowest possible management level.
(5) Reporting to higher management levels on unresolved audit recommendations requiring resolution action and their status.
(6) Appointing an Audit Liaison Representative (ALR) to implement and coordinate audit liaison, resolution, and follow-up activities within each organizational component and Center.
(7) Appoint or delegate to the ALR, a technical primary point of contact to represent management for each specific GAO or OIG audit for which the OIC or Center Director has been assigned as the Office of Primary Responsibility.
(8) Ensuring that GAO and OIG representatives have free and unfettered access to all files, documents, premises, and employees, except as limited by applicable laws.
e. ALRs represent their OICs and Center Directors in implementing and coordinating their respective audit liaison, resolution, and follow-up processes, and are responsible for:
(1) Ensuring accurate records are maintained of the status of audit reports and recommendations through the entire process from issuance of the audit announcement through implementation of final action.
(2) Facilitating management decisions on disagreements arising from audit reports and attempts to achieve initial resolution at the lowest level practicable.
(3) Establishing and maintaining continuous liaison and coordination among all parties throughout the entire audit process from issuance of the audit announcement through implementation of final action, particularly in those instances involving more than one program, installation, or organizational level.
(4) Coordinating Agency responses to draft and final audit reports, as applicable, to meet the auditors' requested due dates, which are typically 30 days after draft report issuance or 180 days after final issuance of a GAO report with a recommendation addressed to the Administrator.
(5) Monitoring the implementation status of agreed-upon recommendations and adherence to established estimated completion dates, as well as informing their OIC or Center Director of the status of implementing those agreed-upon recommendations.
(i) Once planned corrective actions have been completed, ALRs will request closure with appropriate rationale demonstrating completion and appropriate supporting documentation.
(ii) If corrective actions will not be completed prior to the agreed-upon estimated completion date, ALRs will request an extension from the audit organization with the basis for the extension and the new proposed estimated completion date.
(6) Supporting the preparation of periodic statutory reporting by providing required information, including accurate status updates and implementation timelines for unimplemented recommendations, as requested.
f. COs are responsible for:
(1) Ensuring the proper disposition and prompt recovery of disallowed costs in conjunction with contract audits.
(2) Making the best possible use of contract audit advice.
(3) Taking into full consideration the findings and recommendations made by auditors.
(4) Making prompt, proper, and sound management decisions in responding to audit reports and resolving the disputes between COs and contract auditors on the disposition of audit findings and recommendations.
(5) Ensuring expedient disposition, including fund recovery actions, of contract audit reports after resolution.
(6) Maintaining accurate records of the status of contract audit reports or recommendations through the entire process of resolution and corrective action in the contract file.
(7) Ensuring full documentation of significant differences between the audit recommendation and final action, including rationale for deviations from the audit recommendation.
(8) Establishing and maintaining continuous dialogue between contracting, audit, and audit follow-up personnel to achieve the most effective process possible.
g. NASA employees are responsible for:
(1) Reporting to the Office of OIG any concerns of fraud, waste, abuse, or mismanagement.
(2) Providing full and accurate responses to inquiries by the GAO and OIG subject to legal restrictions.
None.
None.
NPD 9910.1A, Government Accountability Office/NASA Office of Inspector General Audit Liaison, Resolution, and Follow-up Program dated June 28, 2006.
AFO - Audit Follow-up Official
AAIRS - Audit and Assurance Information Reporting System
ALR - Audit Liaison Representative
CFR - Code of Federal Regulations
CO - Contracting Officer
FAR - Federal Acquisition Regulation
GAO - Government Accountability Office
NPD - NASA Policy Directive
OIC - Officials-in-Charge
OIG - Office of Inspector General
OMB - Office of Management and Budget
pt. - Part
Pub. L. - Public Law
U.S.C. - United States Code
A.1 The Budget and Accounting Act of 1921 (Pub. L. 67-13, 42 Stat.20).
A.2 Single Audit Act of 1984, as amended, Pub. L. 98-502.
A.3 The Good Accounting Obligation in Government Act (P.L. 115-414).
A.4 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR pt. 200.
A.5 NASA Federal Acquisition Regulation (FAR) Supplement, 48 CFR section 1842.7301.
A.6 NPD 1000.3, The NASA Organization.
A.7 NPD 9800.1, NASA Office of Inspector General Programs.
A.8 GAO-19-55G, GAO's Agency Protocols.
None.
This document does not bind the public, except as authorized by law or as incorporated into a contract. This document is uncontrolled when printed. Check the NASA Online Directives Information System (NODIS) Library to verify that this is the correct version before use: https://nodis3.gsfc.nasa.gov.