GAO Letter Outlines NASA’s Open Priority Recommendations

by Douglas Messier
Managing Editor

NASA has not implemented nearly one third of the recommendations for improvements that the Government Accountability Office (GAO) made to it four years earlier, the government watchdog agency said.

“In November 2018, we reported that on a government-wide basis, 77 percent of our recommendations made 4 years ago were implemented,” GAO said in an April 12 letter to NASA Administrator Jim Bridenstine.

“NASA’s recommendation implementation rate was 70 percent. As of February 2019, NASA had 51 open recommendations. Fully implementing these open recommendations could significantly improve NASA’s operations.” GAO added.

The letter noted NASA has implemented 10 of 18 open priority recommendations since the watchdog agency issued its last update on March 26, 2018.

In doing so, NASA took actions that will help to better align its strategic sourcing practices with those used by leading commercial companies, including updating guidance and overarching goals and metrics for savings.

NASA also took steps to improve controls over select high-impact information systems, including updating security assessment plans for selected systems to ensure they include the test procedures to be performed. As a result of these efforts, NASA is better positioned to leverage its buying power and achieve additional savings through strategic sourcing and improve its security defense over high-impact systems.

This year’s update urged the space agency to continue to focus on nine priority recommendations from the following six GAO audits:

  • Space Launch System: Resources Need to be Matched to Requirements to Decrease Risk and Support Long Term Affordability (3 Priority Recommendations);
  • Orion Multi-Purpose Crew Vehicle: Action Needed to Improve Visibility into Cost, Schedule, and Capacity to Resolve Technical Challenges;
  • NASA: Actions Needed to Improve Transparency and Assess Long-Term Affordability of Human Exploration Programs (2 priority recommendations);
  • NASA Commercial Crew Program: Plan Needed to Ensure Uninterrupted Access to the International Space Station;
  • NASA: Earned Value Management Implementation across Major Spaceflight Projects Is Uneven; and,
  • Federal Research Grants: Opportunities Remain for Agencies to Streamline Administrative Requirements.

This nine priority recommendations are shown below.

Space Launch System

Space Launch System and Orion spacecraft on Pad 39B. (Credit: NASA)

Space Launch System: Resources Need to be Matched to Requirements to Decrease Risk and Support Long Term Affordability
GAO-14-631, Jul 23, 2014
3 Open Priority Recommendations

Priority Recommendation

To provide the Congress with the necessary insight into program planning and affordability, and to decrease the risk of cost and schedule overruns, NASA’s Administrator should direct the Human Exploration and Operations Mission Directorate to take the following action: To promote affordability, before finalizing acquisition plans for future capability variants, NASA should assess the full range of competition opportunities and provide to the Congress the agency’s assessment of the extent to which development and production of future elements of the SLS could be competitively procured.

Comments: NASA agreed with this recommendation. NASA officials stated that it is in the process of identifying a procurement approach to manage procurement costs and provide flexibility in an environment of changing missions and flight manifests that may necessitate design changes and require procurement flexibility. Officials stated that NASA will implement an acquisition strategy for future missions in 2019. To fully implement this recommendation, this approach would have to assess the full range of competition opportunities for future elements of SLS that NASA plans to acquire, and report it to Congress.

Priority Recommendation

To provide the Congress with the necessary insight into program planning and affordability, and to decrease the risk of cost and schedule overruns, NASA’s Administrator should direct the Human Exploration and Operations Mission Directorate to take the following action: To allow for a continued assessment of progress and affordability, NASA should structure each future increment of SLS capability with a total cost exceeding the $250 million threshold for designation as a major project as a separate development effort within the SLS program. In doing so, NASA should require each increment to complete both the technical and programmatic reviews required of other major development projects, per the agency’s acquisition and system engineering policies.

Comments: NASA agreed with this recommendation. NASA stated that it will conduct appropriate element- and vehicle-level technical design and programmatic reviews and perform rigorous cost and schedule management. To fully implement this recommendation, however, NASA needs to structure each future increment of SLS capability with a total cost exceeding $250 million as a major project.

An artist rendering shows NASA’s Space Launch Systems (SLS) evolution from a Block 1 configuration to various configurations capability of supporting different types of crew and cargo missions. (Credit: NASA/MSFC)

Priority Recommendation

To provide the Congress with the necessary insight into program planning and affordability, and to decrease the risk of cost and schedule overruns, NASA’s Administrator should direct the Human Exploration and Operations Mission Directorate to take the following action: Provide decision makers with an informed basis for making investment decisions regarding the SLS program, NASA should identify a range of possible missions for each future SLS variant that includes cost and schedule estimates and plans for how those possible missions would fit within NASA’s funding profile.

Comments: NASA agreed with this recommendation. NASA officials stated that it is currently reviewing and updating its mission portfolio to align with Space Policy Directive-1. To fully address this recommendation, NASA will need to identify cost and schedule estimates for possible SLS missions beyond its first exploration mission, EM-1, and how its planned missions would fit within NASA’s funding profile.

Orion

Orion spacecraft (Credit: NASA)

Orion Multi-Purpose Crew Vehicle: Action Needed to Improve Visibility into Cost, Schedule, and Capacity to Resolve Technical Challenges
GAO-16-620, Jul 27, 2016
1 Open Priority Recommendation

Priority Recommendation

To provide the Congress and NASA a reliable estimate of program cost and schedule that are useful to support management and stakeholder decisions, the NASA Administrator should direct the Orion program to perform an updated JCL analysis including updating cost and schedule estimates in adherence with cost and schedule estimating best practices.

Comments: NASA partially agreed with this recommendation, stating that the agency reviewed, in detail, the Orion integrated cost/schedule and risk analysis methodology and determined the rigor to be a sufficient basis for the agency commitments. In September 2018, NASA officials reiterated previous statements that they have no plans to update the joint confidence level analysis for the Orion program. We maintain that NASA should update its analysis that informed its baseline because we found that the cost and schedule estimates underlying those baselines are not reliable, as they did not conform to best practices. Further, an updated analysis would be beneficial given numerous conditions and risks have changed since the analysis was completed, including delays for the first exploration mission.

Affordable Human Exploration Programs

Lunar Gateway concept. (Credit: NASA)

NASA: Actions Needed to Improve Transparency and Assess Long-Term Affordability of Human Exploration Programs
GAO-14-385, May 8, 2014
2 Open Priority Recommendations

Priority Recommendation

To provide the Congress with the necessary insight into program affordability, ensure its ability to effectively monitor total program costs and execution, and to facilitate investment decisions, the NASA’s Administrator should direct the Human Exploration and Operations Mission Directorate to establish a separate cost and schedule baseline for work required to support the SLS Block I Exploration Mission-2 (EM-2) and report this information to the Congress through NASA’s annual budget submission. If NASA decides to fly the SLS Block I beyond EM-2, establish separate life cycle cost and schedule baseline estimates for those efforts, to include funding for operations and sustainment, and report this information annually to Congress via the agency’s budget submission.

Comments: NASA partially agreed with this recommendation, stating that it defined and documented life-cycle costs for SLS to a first demonstrated capability, consistent with cost estimating best practices and NASA project and program management policy and that it would report costs associated with the second exploration mission via its annual budget submission. Best practices for cost estimating recognize that NASA’s evolutionary development approach for SLS helps reduce risk and provide capabilities more quickly, but reporting costs via the budget alone will not provide information about potential costs over the long term and progress cannot be assessed without a baseline that serves as a means to compare current costs against expected costs. To address this recommendation, NASA needs to establish separate cost and schedule baselines for work required to support SLS for EM-2.

Lockheed Martin engineers and technicians check fittings during installation of the heat shield to the Orion crew module July 25, 2018, inside the Neil Armstrong Operations and Checkout Building high bay at NASA’s Kennedy Space Center in Florida. Orion is being prepared for Exploration Mission-1 (EM-1), the first uncrewed integrated flight test atop NASA’s Space Launch System rocket. (Credit: NASA/Kim Shiflett)

Priority Recommendation

To provide the Congress with the necessary insight into program affordability, ensure its ability to effectively monitor total program costs and execution, and to facilitate investment decisions, because NASA intends to use the increased capabilities of the SLS, Orion, and Ground Systems Development and Operations efforts well into the future and has chosen to estimate costs associated with achieving the capabilities, the NASA’s Administrator should direct the Human Exploration and Operations Mission Directorate to establish separate cost and schedule baselines for each additional capability that encompass all life cycle costs, to include operations and sustainment. When NASA cannot fully specify costs due to lack of well-defined missions or flight manifests, forecast a cost estimate range — including life cycle costs — having minimum and maximum boundaries. These baselines or ranges should be reported to Congress annually via the agency’s budget submission.

Comments: NASA partially agreed with this recommendation, stating that it had established separate programs for SLS, Orion, and the ground systems and adopted a block upgrade approach for SLS. While NASA’s prior establishment of SLS, Orion, and the ground systems as separate programs lends some insight into expected costs and schedule at the broader program level, it does not meet the intent of the recommendation because cost and schedule identified at that level is unlikely to provide the detail necessary to monitor the progress of each block against a baseline. To address this recommendation, NASA needs to establish separate cost and schedule baselines for each additional SLS, Orion, and Ground Systems Development and Operations capability blocks that encompass all life-cycle costs, to include operations and sustainment.

Commercial Crew Program

Crew Dragon and Starliner at the International Space Station. (Credit: NASA)

NASA Commercial Crew Program: Plan Needed to Ensure Uninterrupted Access to the International Space Station
GAO-18-476, Jul 11, 2018
1 Open Priority Recommendation

Priority Recommendation

The NASA Administrator should develop and maintain a contingency plan for ensuring a presence on the ISS until a Commercial Crew Program contractor is certified. (Recommendation 2)

Comments: NASA agreed with this recommendation. NASA is considering contracting with the State Space Corporation “Roscosmos” for two seats on the Russian Soyuz spacecraft vehicle for one crewmember in the fall of 2019 and one crew member in the spring of 2020. To fully implement this recommendation, NASA needs to provide additional support regarding planning efforts to ensure uninterrupted access to the ISS if delays with the Commercial Crew Program contractors continue beyond these dates.

Improving Earned Value Management in Major Projects

Artist’s impression of James Webb Space Telescope. (Credit; NASA)

NASA: Earned Value Management Implementation across Major Spaceflight Projects Is Uneven
GAO-13-22, Nov 18, 2012

Priority Recommendation: To improve NASA management and oversight of its spaceflight projects, and to improve the reliability of project EVM data, the NASA Administrator should direct the appropriate offices to modify the NASA Procedural Requirements (NPR) 7120.5 to require projects to implement a formal surveillance program that: (1) Ensures anomalies in contractor-delivered and in-house monthly earned value management reports are identified and explained, and report periodically to the center and mission directorate’s leadership on relevant trends in the number of unexplained anomalies. (2) Ensures consistent use of work breakdown structures (WBS) for both the EVM report and the schedule. (3) Ensures that lower level EVM data reconcile to project level EVM data using the same WBS structure. (4) Improves underlying schedules so that they are properly sequenced using predecessor and successor dependencies and are free of constraints to the extent practicable so that the EVM baseline is reliable.

Comments: NASA partially agreed with this recommendation, stating that the reliability and utility of the EVM data needed to be improved but that it did not plan to implement a formal surveillance plan due to resource constraints. Since commenting on the report, in December 2018, NASA included an initiative in its Corrective Action Plan-a plan put in place in response to recent programmatic performance and NASA’s designation on GAO’s High-Risk List-to enhance EVM implementation. To fully implement this recommendation, NASA will need to take action and provide documentary support for several of its identified planned next steps to enhance EVM surveillance. Without implementing proper surveillance, NASA may be utilizing unreliable EVM data in its analyses to inform its cost and schedule decision making.

Federal Research Grants

Federal Research Grants: Opportunities Remain for Agencies to Streamline Administrative Requirements
GAO-16-573, Jun 22, 2016

Priority Recommendation

To further standardize administrative research requirements, the Secretary of Energy, the NASA Administrator, the Secretary of Health and Human Services, and the Director of NSF should coordinate through Office of Science and Technology Policy’s (OSTP) Research Business Models working group to identify additional areas where they can standardize requirements and report on these efforts.

Comments: As of December 2018, DOE, HHS, NASA, and NSF had participated in an interagency effort that was beginning to identify additional areas for standardizing administrative requirements for federal research grants. In particular, in January 2017, the American Innovation and Competitiveness Act was signed into law, requiring establishment of an interagency working group to reduce administrative burdens on federally funded researchers while protecting the public interest through the transparency of and accountability for federally funded research. In May 2018, the Research Business Models working group, which includes representatives from DOE, HHS, NASA, NSF and other research-funding agencies, issued its first annual report under the act. The report identified several potential areas for standardization or harmonization of requirements, such as the policy for what constitutes a financial conflict of interest.