Finding Text
Space Operations
Assistance Listing Number: 43.007
Federal Award ID Number: 80JSC018M0005 National Aeronautics and Space Administration 2023 Funding
Criteria:
Competitive Procurement: 2 CFR Section 200.320 and 48 CFR section 52.244-5 sets forth the
requirements for acquisition contracts awarded to vendors including the requirement to obtain price
or rate quotations from an adequate number of qualified sources and the circumstances in which
noncompetitive procurement methods can be used.
Also, CASIS’s procurement policy states that it is in both CASIS and NASA’s interest to compete
when it makes sense regardless of the threshold and can be achieved by obtaining three quotes,
i.e., comparative shopping. A minimum of 3 vendors are required to demonstrate competition.
CASIS may solicit a proposal from only one source in circumstances where one or more of the
following conditions apply (FAR Subpart 6.3):
(i) The item or service is available only from a single source.
(ii) An unanticipated exigency or emergency exists that requires the equipment, materials, supplies
or services to be procured immediately.
(iii) NASA specifically authorizes the use of noncompetitive proposals (directed source).
(iv) After consultation with a number of sources, competition is determined inadequate.
(v) The vendor is listed as a sole source provider under the Cooperative Agreement.
Vendor disbursements: 2 CFR section 200.214 and 2 CFR section 180.300 require non-federal entities
restrict awards, subawards, and contracts with parties that are debarred, suspended, or otherwise
excluded from or ineligible for participation in federal assistance programs or activities.
Internal controls: 2 CFR 200.303 provides that non-Federal entities must establish and maintain
effective internal controls to provide reasonable assurance of compliance with the Uniform
Guidance.
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Condition: Competitive quotes were not obtained for one expense, and sole source determination was
not documented for another expense. In addition, for one vendor there was no check performed to
ensure it was not debarred prior to the purchase approval.
Cause:
For one expense, CASIS did not obtain competitive quotes as required per their policy. CASIS had
used the venue for meetings in the past, and did not obtain additional quotes for this event. This
is a control and compliance deficiency.
For another expense tested in the sample, no documentation of this being a sole source purchase
prior to expending the funds. This expense is for a membership and essentially has a single
provider. This is a control deficiency, but not a compliance issue.
For one vendor, CASIS did not perform SAM check prior to approving the purchase. Vendor search at
SAM.gov, subsequent to year end, revealed that the vendor is not debarred. This is a control
deficiency, but not a compliance issue.
Effect: If CASIS cannot demonstrate that procurements were made with full and open competition,
properly sole sourced, and vendors are not debarred, it can result in questioned costs and funds
being returned to NASA.
Questioned Costs: Known questioned costs of $17,967, and likely questioned costs of $25,293.
Perspective: For open competition there were 2 out of 60 expenses selected that the control failed.
There was one vendor out of 10 selected that the debarment check was not performed.
Recommendation: Competitive quotes should be obtained and retained as specified in the procurement
policy. Non-competitive procurement should be documented and approved prior to incurring expenses.
Vendor debarment checks should be performed and documented prior to entering into covered
transactions.
Management Response: The audit uncovered a non-compliance with required competitive quotes for a
procurement of meeting services which did not comply with CASIS policy. The predecessor management
team had previously advised the responsible purchaser that these services did not require
competitive quotes. This matter is also complicated by the fact that the procurements are not just
for meeting space, logistics and meals, but also includes lodging, which is not subject to the
three quote rule. Management acknowledges that this was a process escapement and provides for the
following corrective action. Typically lodging expenses are included in the procurement because it
results in discounts that are unavailable if not included.
CASIS implemented a policy of requiring competitive quotes for purchases over $1,000 in the most
recent revision of the procurement policy. This change was made to assure compliance with Federal
Regulations. While the amount noted is within the limits established by Federal Micro-
purchase regulations, it did not comply with internal policies as noted.
Meeting space is a commonly used service that is highly competitive in pricing and most facilities
charge competitive rates, but most of the time those quotes are not useable given the time of year,
and more importantly the occupancy rate of the facility. Starting in 2024, we are requesting quotes from three facilities in the local area that will be valid for a period of one year. These rates will be updated manually and a single additional quote will be obtained to assure the “reasonableness” of the price. This process will represent an annual price survey that will satisfy the three quote rule of our procurement policy.
For rental of facilities outside of the local area, we will obtain a minimum of three quotes as required by our procurement policy.
Management also acknowledges the process escapement for SAM checks on new vendors. Our normal process is that annually, Finance performs a SAM check for all approved vendors. The agreement for Trust Factory came in late during the year resulting in this deficiency. When a new vendor is setup in our system, it will automatically trigger a SAM check.