oversight

NSF Could Improve Accountability for Its Vehicle Fleet and Recipient-titled Vehicles at Major Facilities

Published by the National Science Foundation, Office of Inspector General on 2020-05-21.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

NSF Could Improve Accountability for
Its Vehicle Fleet and Recipient-titled
Vehicles at Major Facilities




 May 21, 2020
 OIG 20-2-006
AT A GLANCE
NSF Could Improve Accountability for Its Vehicle Fleet and
Recipient-titled Vehicles at Major Facilities
Report No. 20-2-006
May 21, 2020

WHY WE DID THIS AUDIT
Senate Report 115-139, Federal Vehicle Fleet Management, dated July 27, 2017, requires Inspectors
General to conduct annual audits of their agency’s Federal vehicle fleet management practices. The
objective of the audit was to determine if NSF is managing its Federal vehicle fleet in accordance with
the Federal Management Regulation (FMR).

WHAT WE FOUND
NSF is generally managing its fleet in accordance with the FMR. However, NSF did not conduct a
complete vehicle allocation methodology because it did not have formal policies and procedures for
conducting one. Additionally, NSF could improve accountability for vehicles purchased with Federal
funds. Specifically, NSF was not aware of all vehicles it owned nor did it have a consistent process for
determining when NSF should retain title to vehicles at major facilities or when title should vest in
award recipients, resulting in different levels of accountability over these vehicles. As a result of this
audit, NSF established a working group to increase its ability to account for equipment, including
vehicles, and has begun taking other corrective actions.

WHAT WE RECOMMEND
We made three recommendations to improve NSF’s ability to account for vehicles in its fleet as well as
ones maintained by award recipients.

AGENCY RESPONSE
NSF agreed with our recommendations. NSF’s response is included in its entirety in Appendix A.


FOR FURTHER INFORMATION, CONTACT US AT OIGPUBLICAFFAIRS@NSF.GOV.
                          National Science Foundation • Office of Inspector General
                             2415 Eisenhower Avenue, Alexandria, Virginia 22314

MEMORANDUM

DATE:                 May 21, 2020

TO:                   Teresa Grancorvitz
                      Office Head and Chief Financial Officer
                      Office of Budget, Finance and Award Management

                      Wonzie Gardner
                      Office Head and Chief Human Capital Officer
                      Office of Information and Resource Management


FROM:                 Mark Bell
                      Assistant Inspector General
                      Office of Audits

SUBJECT:              Audit Report No. 20-2-006, NSF Could Improve Accountability for Its Vehicle
                      Fleet and Recipient-titled Vehicles at Major Facilities

Attached is the final report on the subject audit. We have included NSF’s response to the draft report as
an appendix.

This report contains three recommendations aimed at improving NSF’s accountability for its motor
vehicle fleet. NSF concurred with all of our recommendations. In accordance with Office of
Management and Budget Circular A-50, Audit Followup, please provide a written corrective action plan
to address the report recommendations. In addressing the report’s recommendations, this corrective
action plan should detail specific actions and associated milestone dates. Please provide the action plan
within 60 calendar days.

We appreciate the courtesies and assistance NSF staff provided during the audit. If you have any
questions, please contact Elizabeth Kearns, Director, Audit Execution, at 703.292.8483 or
ekearns@nsf.gov.


cc:            Fleming Crim           Christina Sarris       Allison Lerner           Ellen Ochoa
               Larry Rudolph          Peg Hoyle              Lisa Vonder Haar         Victor McCrary
               Mark Wilson            Peggy Gartner          Elizabeth Kearns         Karen Scott
               Matthew Hawkins        Jim Ulvestad           Philip Emswiler          Dan Buchtel
               Teresa Pierce          Ken Chason             Nacole White             Jamie French
               Patrick Breen          Jennifer Kendrick      John Veysey              Ann Bushmiller
TABLE OF CONTENTS
Background ......................................................................................................................................... 1
Results of Audit................................................................................................................................... 2
  NSF Could Improve Its Vehicle Allocation Methodology ........................................................... 2
  NSF Could Improve Titling and Tracking of Vehicles Purchased with Award Funds
  at Major Facilities ........................................................................................................................... 3
  NSF Was Not Titling Vehicles at Major Facilities Consistently................................................. 3
  NSF’s Property Management Office Was Not Notified of All Federally Owned Vehicles
  Purchased by Major Facilities Operators Using Federal Funds ............................................... 3
Recommendations ............................................................................................................................. 4
OIG Evaluation of Agency Response ............................................................................................... 4
Appendix A: Agency Response ......................................................................................................... 5
Appendix B: Objective, Scope, and Methodology .......................................................................... 6


ABBREVIATIONS
FAST                              Federal Automotive Statistical Tool
FMR                               Federal Management Regulation
GSA                               U.S. General Services Administration
VAM                               vehicle allocation methodology
Background
The National Science Foundation is an independent Federal agency created by Congress in 1950 “[t]o
promote the progress of science; to advance the national health, prosperity, and welfare; to secure the
national defense; and for other purposes” (Pub. L. No. 81-507). NSF is the only Federal agency that
funds basic non-biomedical research and education across all fields of science and engineering and at all
levels of education. Among other things, it funds advanced instrumentation and facilities; supports
Arctic and Antarctic research and science operations; and encourages research partnerships between
universities and industry and U.S. participation in international scientific efforts.

To accomplish its mission, NSF may purchase or lease equipment, including motor vehicles.
Additionally, a recipient organization may request funding to purchase property and equipment,
including motor vehicles, as part of its proposal for an award. In its FY 2017 Fleet Management Plan
and Budget Narrative for National Science Foundation, NSF reported 560 vehicles encompassing three
categories:

      1. Vehicles Operated by NSF Staff and Its Contractors — This included 2 vehicles located at
         NSF’s Headquarters in Alexandria, Virginia; 139 vehicles operated by NSF’s support contractor
         for the U.S. Antarctic Program; and 44 vehicles operated by contractors for NSF’s Arctic
         program in Greenland and Alaska.

      2. Vehicles Operated by Major Facility Award Recipients — NSF award recipients that operate
         major facilities, such as telescopes and observatories, may acquire a significant number of
         vehicles to meet their missions. NSF reported 373 vehicles at major facilities funded under
         assistance awards.

      3. Vehicles Operated by Other Award Recipients — NSF reported 2 vehicles held by an award
         recipient other than a major facility award recipient.

The Federal Management Regulation (FMR) governs the economical and efficient management and
control of motor vehicles that the Government owns, leases commercially, or leases through the U.S.
General Services Administration (GSA). 1 For example, the FMR requires agencies to annually report
vehicle information via GSA’s Federal Automotive Statistical Tool (FAST) and to use U.S. Government
license plates for all Government motor vehicles unless exempt. It also requires NSF to establish and
document a structured vehicle allocation methodology to determine the appropriate size, number, and
types of motor vehicles. After our audit began, the NSF Office of General Counsel assessed the
Foundation’s vehicle management practices and determined that NSF’s fleet should consist of vehicles
operated by NSF staff and its Federal Acquisition Regulation-based contractors. For purposes of this
report, we are using that definition.

Senate Report 115-139, Federal Vehicle Fleet Management, dated July 27, 2017, requires OIGs to
conduct annual audits of agency fleet management practices. We conducted this audit to determine if
NSF is managing its vehicle fleet in accordance with the FMR.

1
    §102-34.5


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Results of Audit
NSF is generally managing its fleet 2 in accordance with the FMR. However, NSF did not conduct a
complete vehicle allocation methodology (VAM) because it did not have formal policies and procedures
for conducting a VAM. Additionally, at the time of our audit, NSF did not have a consistent process for
titling vehicles purchased with award funds or for tracking vehicles at major facilities. As a result of our
audit, NSF established a working group to improve its ability to account for equipment, including
vehicles, and has begun taking other corrective actions.

NSF Could Improve Its Vehicle Allocation Methodology
According to the FMR, 3 Federal agencies must establish and document a structured VAM to determine
the appropriate number and size of motor vehicles needed to fulfill their mission requirements. GSA
Bulletin FMR B-30, Motor Vehicle Management, 4 provides guidance to executive branch agencies on
conducting their annual VAM, including the following steps:

    •    Establishing a baseline inventory of the agency’s fleet, including information about the size,
         type, and cost of individual vehicles.
    •    Developing utilization criteria to justify mission essential vehicles, such as frequency of use and
         ratio of employees to vehicles.
    •    Conducting a utilization survey to identify vehicles that meet utilization criteria. This includes
         collecting data about each vehicle, such as what tasks were accomplished while using the vehicle
         and how those tasks supported the agency’s mission.
    •    Determining optimal fleet inventory, including a comparison of the existing fleet composition to
         mission needs.

NSF established a baseline fleet inventory for its vehicles at Headquarters and its vehicles operated by
contractors in the Arctic and Antarctic. NSF also collected information such as the purpose and mileage
for each trip for its vehicles at its Headquarters facility and information such as mileage, hours of
operation, and replacement priorities for its vehicles operated by contractors in the Arctic and Antarctic.
However, NSF did not conduct a utilization survey for each of its vehicles. Additionally, NSF did not
identify a process or timeframe for conducting a VAM — including a utilization survey — in its policies
and Standard Operating Guidance or identify who is responsible for completing the VAM.

According to NSF, it plans to conduct an NSF-wide VAM utilization survey in 2020 and incorporate the
results in the agency’s treatment of federally owned vehicles.



2
  For the purposes of this report, NSF’s fleet consists of its Headquarters vehicles and its vehicles operated by Federal
Acquisition Regulation-based contractors.
3
  §102-34.50(b)
4
  GSA Bulletin FMR B-30, Motor Vehicle Management, dated August 22, 2011, applied during the first part of our audit
scope. It was replaced by GSA Bulletin FMR B-43, Motor Vehicle Management, dated March 20, 2017, which requires a
VAM study (utilization survey) every 5 years. B-43 applied during the remainder of our audit scope.


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NSF Could Improve Titling and Tracking of Vehicles Purchased with Award Funds
at Major Facilities

At the time of our audit, NSF did not have a consistent process for titling vehicles purchased with award
funds at major facilities or for tracking those vehicles.

NSF may vest title to equipment, including motor vehicles, either in the Government (i.e., NSF), making
it federally owned property, or in the award recipient. At the time of our audit, according to NSF policy,
title to equipment purchased by a for-profit organization vested in the Government. Unless otherwise
specified in the award terms, title to equipment purchased by a non-profit organization vests in the
award recipient. Generally, when NSF vests title in the award recipient, it reserves the right to transfer
the equipment to the Federal Government (including NSF) or another third party at any time during the
award or within 120 days after the award expires. Additionally, NSF can allow award recipients to keep
equipment purchased with award funds.

NSF Was Not Titling Vehicles at Major Facilities Consistently

In its FY 2017 Fleet Management Plan and Budget Narrative for National Science Foundation, NSF
reported 560 vehicles purchased with award funds; of these, we determined more than 500 were at major
facilities. In January 2020, as a result of our audit, an NSF working group analyzed NSF accountability
practices for vehicles purchased with award funds at major facilities and agreed with OIG that NSF was
inconsistently titling vehicles at major facilities. Although at most major facilities vehicles were titled to
the Government (i.e., NSF), at some, title vested in the award recipients.

To address this inconsistency, NSF has decided that title to vehicles purchased with award funds and
operated at major facilities should be vested in the award recipients, unless there is a specific reason to
vest title in the Government. Although award recipients are responsible for day-to-day operation of these
vehicles, NSF must still be aware of and able to account for the vehicles in case the agency transfers
operations of a major facility to a new recipient, consistent with NSF’s authority under the NSF Act.

NSF’s Property Management Office Was Not Notified of All Federally Owned
Vehicles Purchased by Major Facilities Operators Using Federal Funds
NSF’s Property Management Office (the office) relies on award recipients to report vehicles they
purchase with award funds when designated as federally owned. However, we found that recipients did
not always report these vehicles to the office when required, and the office did not have a process to give
confidence in the accuracy of reported vehicles. In FY 2017, one major facility recipient did not report
16 federally owned vehicles it purchased with award funds to the office. As a result, NSF was not aware
of the vehicles, which were operated by the award recipient, and could not adequately track them as
federally owned property. The office became aware of these vehicles when NSF transferred operation of
the major facility to a new award recipient, who reported the vehicles to the office in FY 2018.




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The Uniform Guidance 5 requires award recipients with conditional title to equipment to take a physical
inventory and reconcile the results with property records at least once every 2 years. As such, NSF could
request vehicle inventory information from major facility recipients to ensure adequate oversight of
vehicles purchased with Federal funds when a major facility transfers operations.

Recommendations
We recommend the Head of the Office of Budget, Finance and Award Management and the Head of the
Office of Information and Resource Management, National Science Foundation:

    1) Conduct a complete vehicle allocation methodology (VAM) for all vehicles in NSF’s motor
       vehicle fleet, and update NSF’s optimal fleet profile and minimum utilization criteria based on
       the results.

    2) Develop internal guidance to ensure that NSF regularly establishes and documents a VAM.
       Guidance should identify timelines for conducting a VAM, who is responsible for that exercise,
       and how NSF will conduct VAMs in the future.

    3) Complete Standard Operating Guidance for NSF staff. Guidance should include language and
       mechanisms to help ensure:

        a) NSF staff roles and responsibilities are clear;
        b) NSF has criteria to help its staff make determinations on whether a vehicle should be
           federally owned or recipient titled;
        c) NSF Property Management can identify and track all federally owned vehicles and NSF is
           aware of recipient-titled vehicles to ensure they can be transferred if a new recipient takes
           over operations of the facility; and
        d) NSF documents transfer of title determinations.



OIG Evaluation of Agency Response
NSF agreed with our recommendations. NSF’s response is included in its entirety in Appendix A.




5
 The Office of Management and Budget issued Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards (to non-Federal entities). The Uniform Guidance is codified in 2 CFR Part 200.


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Appendix A: Agency Response




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Appendix B: Objective, Scope, and Methodology
The objective of this performance audit was to determine if NSF is managing its Federal vehicle fleet in
accordance with the Federal Management Regulation.

We reviewed Federal regulations and guidance for agencies acquiring vehicles, including Part 102-34 of
the FMR on Motor Vehicle Management, and analyzed NSF’s policies and procedures related to the
management of its vehicle fleet. We interviewed staff from NSF’s Office of Information and Resource
Management, Division of Administrative Services, Property Management Section, who are responsible
for overseeing NSF vehicles. We also interviewed NSF program and award administration staff in the
Division of Acquisition and Cooperative Support and determined their roles in vehicle acquisition and
oversight.

We analyzed NSF’s FYs 2016, 2017, and 2018 FAST reports to determine the number, location, and
types of NSF-owned vehicles. We also interviewed NSF staff to determine how they gathered
information to report in FAST. We compared NSF’s FYs 2017 and 2018 FAST reports to identify
changes in the number of vehicles and determined the causes of the most significant changes.

To determine if NSF was identifying reportable vehicles on assistance awards, we selected a judgmental
sample of awards that were active as of October 31, 2018, or administratively closed between May 1,
2015, and October 31, 2018, whose terms and conditions contained the word “vehicle”; this resulted in a
universe of 32 awards. From this universe, we selected 8 awards and contacted the responsible NSF
Program Officers. We did not identify any additional vehicles that NSF should have reported in FAST
based on this test. Similarly, to test if contractors acquired vehicles that NSF did not report in FAST, we
selected a judgmental sample from a list of 406 contracts, which were active on March 27, 2019, based
on the contract value and whether the recipient may acquire a vehicle. From this universe, we selected 5
contracts and contacted the responsible Contracting Officer’s Representative. We did not identify any
additional vehicles that NSF should have reported in FAST based on this test.

To determine how NSF manages the vehicles at its Headquarters, we interviewed NSF staff responsible
for their accountability and usage. We analyzed vehicle use logs showing the trips and miles driven,
safety inspections, and an NSF analysis examining the need to acquire additional vehicles. Similarly, to
identify NSF accountability for vehicles contractors purchase, we reviewed FAST reports, interviewed
NSF staff, and identified the contract requirements. We determined how NSF and the contractors are
meeting requirements of the FMR, including tracking vehicles, handling vehicle maintenance, and
identifying vehicle replacement needs.

We also requested and reviewed additional information about select NSF vehicles in the Arctic and
Antarctic. Based on vehicle maintenance, acquisition cost, and mileage, we selected 11 of the 45
vehicles in the Arctic and 33 of the 139 U.S. Antarctic Program vehicles NSF reported in FAST in FY
2018. We requested NSF Program staff provide a VAM or other documentation supporting the
acquisition of these vehicles.

We conducted this performance audit between March 2019 and January 2020 in accordance with
Generally Accepted Government Auditing Standards. Those standards require that we plan and perform


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the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions, based on our audit objective. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions.

Key contributors to the report include Elizabeth Kearns, Director, Audit Execution; Philip Emswiler,
Audit Manager; Nacole White, Management and Program Analyst; Elizabeth Argeris Lewis, Executive
Officer and Communications Analyst; and Keith Nackerud, Independent Report Referencer.




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About NSF OIG
We promote effectiveness, efficiency, and economy in administering the Foundation’s programs; detect
and prevent fraud, waste, and abuse within NSF or by individuals who receive NSF funding; and
identify and help to resolve cases of research misconduct. NSF OIG was established in 1989, in
compliance with the Inspector General Act of 1978, as amended. Because the Inspector General reports
directly to the National Science Board and Congress, the Office is organizationally independent from the
Foundation.

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