NASA Procedural Requirements

NPR 9010.2B Effective Date: May 31, 2018 Expiration Date: June 30, 2024

Subject: The Continuous Monitoring Program of Financial Controls

Responsible Office: Office of the Chief Financial Officer

Chapter 1. Continuous Monitoring Program (CMP)

1.1 Overview

1.1.1 Financial data is important in making mission critical decisions. To ensure availability of the most accurate financial data, NASA has instituted the CMP, a rigorous and comprehensive financial data review and analysis process. This chapter sets requirements for CMP activities that NASA Centers shall perform for their Business Areas. These activities consist of the review and analysis of NASA's financial data to identify inaccuracies, abnormal balances, account relationship differences, and other financial reporting anomalies. Specific procedures and controls are provided in the NASA CMP Manual.

1.1.2 The Agency and Centers, including CFTSSC, shall perform financial control activities in accordance with the CMP Manual.

1.2 CMP Objectives

1.2.1 The CMP provides an overall framework of management activities to assess and evaluate:

a. The design and operation of internal controls over NASA financial data.

b. Compliance with Generally Accepted Accounting Principles (GAAP).

c. Evidence that balances and activity reported in financial statements are auditable, accurate, and complete.

1.2.2 The CMP helps ensure that there are ongoing management reviews and validations of financial data and internal controls so that errors and/or discrepancies are identified, tracked, and corrected in a timely manner. The NASA Centers, the NASA Shared Services Center (NSSC), and Agency Office of the Chief Financial Officer (OCFO) maintain supporting documentations for each control activity as evidence that the activity was performed. The documentation contains the source of the information provided, including the title of reports and report description when available. These documents are accessible on request.

1.3 CMP Manual Contents

1.3.1 The CMP Manual describes control activities for entire business processes for specific accounts. As a result, each chapter may address multiple related line items in the financial statements. Each chapter lists the proprietary and budgetary accounts that relate to the business process. For example, the accounts receivable chapter includes information regarding proprietary and budgetary receivables, revenues, and customer advances because these transactional events are generated within the accounts receivable business process.

1.3.2 The CMP Manual includes:

1.3.2.1 Financial statement line item reference. References the basic financial statement lines that are supported by the section.

1.3.2.2 General ledger accounts reference. Lists proprietary accounts with related budgetary accounts (the budgetary accounts are indented to show the relationships).

1.3.2.3 Management assertions. Management assertions for the financial statement line items are listed.

1.3.2.4 Control objective (for each section and entire document). The objective is provided to detect exceptions in significant financial statement/reporting assertions and Required Supplementary Stewardship Information.

1.3.2.5 Financial reporting objectives. The list includes the GAAP financial reporting objectives that the control activities support.

1.3.2.6 Control activities. Defines and sets standards for the control activities that collectively support the management assertions/control objective and financial reporting objective for the section. Each control activity is assigned a number related to the CMP chapter and a brief description. For details of each control activity, refer to CMP Manual.

1.3.3 Additional information on how to post transactions and execute reports is available through the Enterprise Performance Support System (EPSS).

1.4 Reporting Requirements

1.4.1 The Centers shall submit the Center CFO Certification, signed control sheets, fluctuation analysis, and the CMP Reporting Matrix (formats provided in the Appendix of the CMP Manual) for Center control activities to the Agency OCFO, Financial Management Division (FMD) via a secured system, the CMP Automation Tool Web site, by the 14th calendar day of each month (unless instructed otherwise by the Agency OCFO). The CMP Automation Tool Web site is an application used to support the Agency-wide CMP process. The CMP Automation Tool Web site can be accessed at https://cmp.nasa.gov/.

1.4.2 The CMP Reporting Matrix is a standard form used by Centers to report results of Center control activities and certify that the activities have been completed. The Matrix supports the Agency's efforts in validating the Centers' submissions. It also enables the Agency FMD to pinpoint issues where additional focus may be needed. These forms are analyzed and evaluated by both Headquarters and Center management. If, after these review/processes, the results are within performance measures and the control activities have been completed, then NASA will have demonstrated that it has management and internal controls that provide for reliable financial statements prepared in accordance with GAAP. The reconciliations and other procedures performed as part of each control activity also provide documentation of balances and activities needed for audit purposes.

1.5 CMP Roles and Responsibilities

1.5.1 The NASA Agency Deputy CFO (Finance) shall have overall responsibility for ensuring that the CMP is in place and functioning as intended.

1.5.2 The NASA Agency OCFO, FMD Director shall review and approve any updates to the CMP Manual.

1.5.3 The NASA Agency OCFO, FMD Director or designee shall perform the following for control activities executed by the Agency OCFO:

a. Provide CMP guidance.

b. Maintain and update the CMP Manual.

c. Ensure Centers complete and submit the monthly CMP certification on time.

d. Coordinate and monitor CMP submissions for completeness and accuracy.

e. Conduct periodic reviews of CMP activities and ensure supporting documentation is available to FMD upon request.

f. Analyze and evaluate the results of the monitoring activities through comparison to policy standards and performance metrics.

g. Ensure corrections identified through the control activities are corrected by the Agency OCFO and/or Centers in a timely manner.

h. Prepare a resolution response for exceptions and unreconciled differences that require an explanation.

i. Confirm that the resolution response is executed.

j. Complete the monthly Agency CMP Certification to ensure control activities have been performed and results are consistent with the standards set forth for each activity. The certification will confirm the following:

(1) Evidence exists that the financial data reviews and/or reconciliations described for the internal controls have been performed in accordance with CMP Manual instructions.

(2) Auditable support documentation exists at Agency OCFO for the reviews and reconciliations performed.

(3) Any resulting discrepancies that exceed the thresholds are listed as exceptions and include a narrative explanation of the root cause, an associated value determined for the discrepancy, and an estimated date of correction (if not done in the current period being reported on).

k. Ensure that CMP process stakeholders, to include the NASA Office of Procurement, have input into the development of the CMP Manual, where applicable, when updated. (The CMP Manual is a work driver for personnel outside of finance in that it sets guidance, timeframes, and thresholds for CMP inputs and Finance personnel need the help of outside organizations to comply. For example, the Office of Procurement should have input to the Chapter 10 - Purchase Orders/Obligations/Unobligated Balances portion of the manual as it requires Procurement input at certain levels and for specific timeframes.)

1.5.4 The NSSC, Chief FMD shall:

a. Establish responsibility for review and reconciliation of activities at the NSSC.

b. Ensure monthly completion and submission of periodic review and reconciliation of NSSC activities.

c. Ensure corrections identified through the control activities are corrected by the NSSC in a timely manner.

d. Prepare a resolution response for exceptions and unreconciled differences that require an explanation.

e. Confirm that the resolution response is executed.

f. Complete and submit a monthly NSSC CMP Certification to ensure required control activities have been performed and results are consistent with the standards set forth for each activity. The certification will confirm:

(1) Financial data reviews, analyses, and reconciliations have been conducted along with the reviews and/or reconciliations described for internal controls.

(2) Auditable support documentation exists for the reviews and reconciliations performed.

(3) Any resulting discrepancies that exceed the thresholds are listed as exceptions and include a narrative explanation of the root cause, an associated value determined for the discrepancy, and an estimated date of correction (if not done in the current period being reported on).

1.5.5 The NASA Center CFO shall:

a. Establish responsibility for review and reconciliation of activities at the Center.

b. Ensure monthly completion and submission of periodic review and reconciliation of Center activities.

c. Ensure corrections identified through the control activities are corrected in a timely manner.

d. Prepare a resolution response for exceptions and unreconciled differences that require an explanation.

e. Confirm that the resolution response is executed.

f. Complete and submit a monthly Center Certification to ensure required control activities have been performed and results are consistent with the standards set forth for each activity. The certification will confirm:

(1) Financial data reviews, analyses, and reconciliations have been conducted along with the reviews and/or reconciliations described for internal controls.

(2) Auditable support documentation exists for the reviews and reconciliations performed.

(3) Any resulting discrepancies that exceed the thresholds are listed as exceptions and include a narrative explanation of the root cause, an associated value determined for the discrepancy, and an estimated date of correction (if not done in the current period being reported on).

1.5.6 Centers and NSSC are expected to coordinate correction activities to ensure corrections are completed timely. Details regarding these correction activities are available in the introduction to the CMP Manual.

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