In accordance with internal control standards in the federal government of GAO, NASA`s directives and guidelines provide internal controls over certain aspects of the use and management of funded space act agreements, such as. B segregation of duties and delegation of powers. For example, NASA separates tasks related to the authorization, management, and verification of funded space act agreements. In accordance with internal control standards in the federal government of GAO, risk assessment is also an important control to ensure the achievement of programmatic objectives, and NASA guidelines and guidelines provide for different levels of risk assessment. The NASA Space Act Act Policy and guidelines provide controls for risk assessment with respect to the adequacy of cost estimates and whether or not a space act agreement is the appropriate legal instrument, but does not require specific documentation related to these assessments, as required by gao standards for internal control within the federal government. Other risks traditionally assessed in programmatic decisions, including safety and technical risks, are not covered by NASA`s Space Directive, for example. As soon as it is clear that the Agency will be able to properly use a funded space act agreement for a given initiative, it is not necessary, according to NASA, to assess such additional risks, given that they are borne by the contractor. While the proper use of a space act agreement funded on the basis of programmatic objectives is less definitive, NASA believes that additional risks such as security and technical risks will be addressed through the use of the agency`s strategic approach to procurement and related policies. However, it is not always clear when and if the objectives of a program determine the need to follow NASA`s strategic acquisition approach and assess additional programmatic risks. While federal internal control standards emphasize the importance of training for maintaining competence, NASA does not require or provide formal training to those responsible for managing funded space act agreements. For its Commercial Crew program, NASA has developed and documented a process to guide program officials through procedures related to their agreements. While the documented process is a positive step for the Commercial Crew program, the training could contribute to the successful execution of future agreements, given the uniqueness of funded space act agreements and the judgment that can be implemented by contract managers.

We recommend that NASA incorporate additional internal controls over documentation and training into its policies and guidelines for funded space act agreements and that NASA clarify whether, how and to what extent authorities should refer to NASA`s broader acquisition and risk management policies when considering the use of a funded space act agreement. . . .