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					   NASA Office of Inspector
        General (OIG)
Oversight Plan for the American
Recovery and Reinvestment Act
    (Recovery Act) of 2009
                      Table of Contents


NASA Recovery Act Funds                              3
OIG Oversight Objectives                             4
Methodology for Oversight of Planning
  and Reporting                                      8
Methodology for Oversight of Internal Control
  Processes                                          10
Methodology for Oversight of Grant Awards            11
Methodology for Oversight of Contract Awards         13
Methodology for Oversight of the Risk Management
  Process                                            16
Methodology for Oversight of Programs and Projects   17



                                                          2
             NASA Recovery Act Funds

NASA was appropriated $1 billion distributed as follows:

  SCIENCE - $400,000,000 to accelerate earth science/climate research
   missions and to increase NASA’s supercomputing capabilities.
  AERONAUTICS - $150,000,000 for system-level research, development
   and demonstration activities related to aviation safety, environmental
   impact mitigation, and the Next Generation Air Transportation System.
  EXPLORATION - $400,000,000 to develop human and robotic
   exploration.
  CROSS-AGENCY SUPPORT - $50,000,000 to restore NASA-owned
   facilities damaged by natural disasters in 2008.

The OIG was appropriated $2 million, available through FY 2013, for
oversight of NASA’s $1 billion in Recovery Act funding.



                                                                            3
                OIG Oversight Objectives

The OIG has established a Recovery Act Oversight Team to provide
real-time monitoring of NASA’s implementation of the Act and the
requirements of OMB’s implementing guidance. Specifically, we will:
   1. Monitor NASA’s compliance with the accountability and transparency
   provisions of the Act and OMB’s implementing guidance.

   2. Review NASA’s processes for controlling Recovery Act Funds and
   awarding grants and contracts.

   3. Assess and identify risks associated with NASA programs and projects
   receiving Recovery Act funding and communicate the results to Agency
   officials for use in mitigating fraud, waste, abuse, and error.

   4. Review all programs and projects funded under the Recovery Act to
   assess cost, schedule, performance and compliance with requirements of
   the Act and OMB’s implementing guidance.


                                                                             4
                OIG Oversight Objectives
                                  (cont’d)

In addition, we will

 augment and enhance our fraud, waste, and abuse outreach program (in
  coordination with NASA’s Acquisition Integrity Program) with special
  emphasis on Recovery Act provisions.

 promptly investigate any allegations of gross mismanagement, fraud, waste,
  abuse, or any other concerns raised about specific investments using
  Recovery Act funding. Also, as required by the Recovery Act, within 180
  days, we will investigate allegations of retaliation against individuals for
  disclosing violations involving Recovery Act funds.

 coordinate with the Recovery Act Accountability and Transparency Board,
  the Government Accountability Office (GAO), and NASA’s Senior
  Accountability Official.



                                                                             5
             OIG Oversight Objectives
                                 (cont’d)


 develop an OIG reporting model, incorporating methods for
    • timely reporting on the status of funds provided by the Recovery Act;
    • communicating issues warranting management attention and
      corrective action; and
    • summarizing lessons learned.




                                                                              6
                OIG Oversight Objectives
                                  (cont’d)

The OMB Recovery Act implementation guidance identifies critical
accountability requirements, which include the following:
     Funds are awarded and distributed in a prompt, fair, and reasonable
      manner.
     The recipient and users of all funds are transparent to the public, and
      the public benefits of these funds are reported clearly, accurately, and
      in a timely manner.
     Funds are used for authorized purposes, and instances of fraud, waste,
      and abuse are mitigated.
     Funded projects avoid unnecessary delays and cost overruns.
     Program goals are achieved, including specific program outcomes and
      improved results on broader economic indicators.

Our oversight plan addresses all of the above OMB critical
accountability requirements.


                                                                             7
          Methodology for Oversight of
            Planning and Reporting
We will monitor NASA’s compliance with the accountability and
transparency provisions of the Act and OMB planning and reporting
requirements by ensuring that NASA
 establishes a Recovery Act Website in accordance with OMB
  requirements;
 posts all major communications to Recovery.gov in a timely manner with
  the required level of detail;
 includes in public notifications on the Website a description of the
  investment being funded, the purpose, the total cost, and a justification
  as to why the activity should be funded with Recovery dollars;
 submits properly authorized grant allocations to OMB in a timely manner;
 transmits weekly reports to OMB in a timely manner with the required
  level of detail;
 transmits monthly reports to Recovery.gov in a timely manner with the
  required level of detail;



                                                                         8
         Methodology for Oversight of
         Planning and Reporting (cont’d)

 posts award-level transaction data reports on USASpending.gov for
  contracts, grants, cooperative agreements, and other assistance in a
  timely manner with the required level of detail; and
 complies with the Paperwork Reduction Act as specified in the OMB
  Guidance.

In addition, recipients of Federal funding and 1st tier sub-contractors
and sub-grantees of these recipients are required to submit reports
detailing required information for Recovery Act contracts to NASA.
We will monitor NASA’s receipt and review of these reports to
ensure NASA posts this information on USASpending.gov in a
user-friendly format in a timely manner.




                                                                          9
          Methodology for Oversight of
           Internal Control Processes

We will determine whether NASA is separately identifying and
accounting for Recovery Act funds within internal financial systems.
Specifically, we will
  review NASA cost reports for Recovery Act funds on a sample basis;
  determine whether Recovery Act funds are being used to pay fixed and
   administrative support costs for projects and programs which have
   previously been funded by Congress; and
  determine whether adequate internal controls are in place for
   segregating, accumulating, accounting for and reporting Recovery Act
   funds.

We will determine whether NASA is using Inter-Agency Agreements
and, if so, that Recovery Act funds were properly identified. In
addition, we will ensure that NASA’s Inter-Agency Agreements that
involve Recovery Act funds are in compliance with OMB Recovery
Act guidance.

                                                                     10
           Methodology for Oversight
               of Grant Awards
We will determine whether NASA grants are awarded using
Recovery Act funds and whether those grant awards are in
compliance with relevant OMB Recovery Act guidance by ensuring
that

 grant funding opportunities are properly posted to NASA and
  Recovery.gov Websites;
 NASA structures grants to result in meaningful and measurable
  outcomes consistent with goals of the Recovery Act;
 all grants and award documents include clauses to clarify that recipients
  are obligated to meet Recovery Act requirements;
 Recovery Act grant funds are being tracked separately;
 grants are awarded in a timely manner;
 NASA has developed a monitoring program that provides additional
  oversight for grants;
 NASA is using appropriate internal control assessments to assess the
  risk of fraud, waste, and abuse for grants;


                                                                         11
           Methodology for Oversight
            of Grant Awards (cont’d)

 NASA requires that receipt of Recovery Act funds is contingent upon
  recipients meeting applicable reporting requirements;
 funding to existing grants is one-time funding only;
 NASA has policies and procedures for reporting false claims or other
  misconduct involving Recovery Act funds; and
 NASA award terms and conditions for grants meet Recovery Act
  requirements.




                                                                         12
           Methodology for Oversight
              of Contract Awards

We will determine whether NASA is complying with the
requirements of the Recovery Act and OMB guidance and properly
segregating Recovery Act funds for contracts by ensuring that

 all stimulus funds are separate from non-Recovery Act funds in the
  contract financial system;
 all contracts and award documents include clauses to clarify that
  recipients and sub-recipients are legally obligated to meet Recovery Act
  requirements; and
 a summary is prepared for each contract or task order worth more than
  $500,000.




                                                                        13
            Methodology for Oversight
            of Contract Awards (cont’d)

We will determine whether NASA is awarding contracts using
Recovery Act funds in accordance with OMB Recovery Act
guidance. Specifically, we will ensure NASA

 justifies the type of contract awarded and that the justification aligns
  contract objectives with Recovery Act goals;
 awards contracts according to Recovery Act regulations and
  requirements;
 monitors and tracks Recovery Act funds separately;
 award contracts in a timely manner;
 puts additional oversight in place when a Firm Fixed Price contract is
  not awarded;



                                                                             14
          Methodology for Oversight
          of Contract Awards (cont’d)

 posts a summary of any contracts that is other than competitively
  awarded to the Recovery Act Website;
 posts pre-solicitation and contract award notices to FedBizOps;
 defines contract requirements so that meaningful and measurable
  outcomes are consistent with NASA’s Recovery Act plans and goals;
  and
 implements internal controls to mitigate cost, schedule, and
  performance risk.




                                                                      15
         Methodology for Oversight of
        the Risk Management Process
We will identify and assess NASA’s risk management process for
Recovery Act funds. Specifically, we will
 summarize past audits and investigations that identified vulnerabilities in
  NASA’s financial management system, oversight of grants and
  contracts and programmatic issues related to programs receiving
  Recovery Act funds;
 validate that NASA is performing risk assessments on programs that
  receive Recovery Act funding;
 validate that NASA’s risk management process focuses on items that
  may negatively impact the achievement of programmatic objectives;
 ensure that NASA is identifying, prioritizing, and mitigating
  program-specific risks;
 ensure that NASA has developed a plan for monitoring and reassessing
  risk throughout the Recovery Act life-cycle; and
 ensure that NASA has included Agency-specific risks as part of the risk
  management process.
                                                                           16
             Methodology for Oversight of
               Programs and Projects
We will determine whether programs and projects funded under the
Recovery Act are executed in compliance with the Act and OMB’s
Guidance. Specifically, we will

 assess NASA’s readiness, priorities, and plans for investing in “shovel-
  ready” projects (facilities damaged by hurricanes);
 review program-specific Recovery Act plans to ensure that the objectives
  and goals of those programs align with NASA programs and activities;
 determine whether program outputs and outcomes are clear and
  measurable;
 ensure that Recovery Act funds are being used for authorized purposes and
  that instances of fraud, waste, abuse, and error are mitigated;
 assess whether NASA achieves its representations to legislators concerning
  the number of jobs created or saved through the expenditure of funds
  provided by the Act; and

                                                                         17
             Methodology for Oversight of
             Programs and Projects (cont’d)

 develop criteria for assessing the impact of funds provided to NASA by the
  Act on broader economic indicators.

We will determine whether programs and projects funded under the
Recovery Act are meeting cost, schedule, and performance criteria.
Specifically, was the program or project

 accomplished within its cost estimate and were the cost estimates reliable;
 completed within established schedule baselines; and
 accomplishing its’ stated goals and objectives.




                                                                            18

				
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