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

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

2. 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

3. 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.

4. 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.

5. 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.

6. 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.

7. 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.

8. 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;

9. 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.

10. 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.

11. 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;

12. 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.

13. 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.

14. 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;

15. 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.

16. 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.

17. 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

18. 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.