NASA-HQ Response to private citizen

August 31, 2021
NASA Property in the Custodian of Contractors
Review of Notice 21-045
NASA Stated Purpose of Requested Review: Reduction in paperwork and
respondent burden associated with information collection.

NASA requested comments on the following:
1. Whether the proposed collection of information is necessary for the
property performance of the functions of NASA, including whether the
information collected has practical utility.
2. The accuracy of NASA’s estimate of the burden (including hours and cost)
of the proposed collection of information.
3. Ways to enhance the quality, utility, and clarity of the information to be
collected.
4. Ways to minimize the burden of the collection of information on
respondents, including automated collection techniques or the use of other
forms of information technology.

Reply:
1. Whether the proposed collection of information is necessary for the
property performance of the functions of NASA, including whether the
information collected has practical utility.
a. Yes, the proposed (perhaps more accurately stated as “the
continued”) collection of information related to the NASA property
accountable to NASA contracts is necessary for the performance of
the functions of NASA, especially considering no other alternative
data collection process is being proposed by NASA. In addition, the
information collected has practical utility.
i. It is a long established and accepted principle that Government
departments and agencies must know the quantity of and
dollar value of all property associated with their entity,
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including Government property accountable to contracts. The
detailed reasons for the need for such data are well
established by various models of business practices and the
history of those practices, and in business articles and
literature.
ii. The collection of the data in discussion is necessary in order to
ensure the accuracy of NASA’s reporting of accountable
property in their financial statement.
NASA HQ Response: The NF1018 is a NASA award requirement for the property in
the hands of NASA awardees. This activity should be accomplished all year round
as the property is received, stored, consumed, and excessed, etc. The prime
awardees are required to flow down the government requirements to their
additional awardees working under their prime NASA awards. Awardees and
anyone working under their awards should never wait until the last minute to
accomplish these tasks.

2. The accuracy of NASA’s estimate of the burden (including hours and cost) of
the proposed collection of information.
a. NASA’s estimate on the time per response of 1.5 hours (per NASA
Form 1018) and total annual burden hours of 1800 hours (to arrive at
the final 1018 product for submittal to NASA) and corresponding
total annual cost of $36,000, is highly inaccurate.
i. Based upon my personal experience having been the
contractor individual responsible for the submittal of the
1018’s for the NAS9-17540 (Boeing Shuttle Flight Equipment
Processing Contract) and NAS9-20000 (United Space Alliance
Space Shuttle Transportation Contract), I can attest to the
hundreds of hours necessary to arrive at the final submitted
Form 1018 to NASA.
1. Considering the time involved for the prime contractors
and for the hundreds of subcontractors and lower tier
subcontractors necessary to arrive at their data to
submit up the chain to the prime contractor, 1.5 hours
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per response is completely inaccurate. The process to
create an accurate 1018 is extremely labor intensive.
Contractors must validate/reconcile inventory listings
extracted from their property management databases as
of September 30 with the Balance End of Period (column
“d”) value which is mathematically derived on the 1018.
Based upon my experience simply submitting the 1018
as a prime contractor, I spent many nights at the office
the day before the 1018 was due attempting to gather
the necessary data and reconciling the data to ensure
the accuracy of our report. (In spite of good intentions,
actual submittal of the report was always on the last day
before the required due date.)
2. In addition to the actual time necessary to prepare the
actual 1018 form for submittal to NASA, sub and prime
contractors spend a multitude of hours (1) validating the
actual data reflected in their 1018 submittal, (2)
collecting and validating backup documentation to
support their data submittal, (3) training on how to
complete the 1018 report, (4) training in individual
computer systems established to collect the raw data,
and (5) in discussions with their NASA Government
Property Administrator concerning their 1018 prior to
submittal of the form and in support of subsequent
audits of the submitted 1018 report, in addition to
other related activities.
NASA HQ Response: The NF1018 is a NASA award requirement for the property in
the hands of NASA awardees. This activity should be accomplished all year round
as the property is received, stored, consumed, and excessed, etc. The prime
awardees are required to flow down the government requirements to their
additional awardees working under their prime NASA awards. Awardees and
anyone working under their awards should never wait until the last minute to
accomplish these tasks.

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3. Therefore, based on the above and the extensive
experience I personally experienced completing and
submitting the 1018 report for over ten years for two
major prime contracts, I must question the accuracy of
the values in 2a above and suggest that they need to be
increased. Regarding the stated purpose of this
requested review, in questioning the values in 2a above,
I am suggesting a sizable increase in the stated
respondent burden associated with that data collection
and submittal.
NASA HQ Response: The NF1018 is a NASA award requirement for the property in
the hands of NASA awardees. This activity should be accomplished all year round
as the property is received, stored, consumed, and excessed, etc. The prime
awardees are required to flow down the government requirements to their
additional awardees working under their prime NASA awards. Awardees and
anyone working under their awards should never wait until the last minute to
accomplish these tasks. The NF1018 reporting requirement is considered to be
part of the NASA awardees’ overall management systems and, as such, the cost of
reporting the NF1018 is included in the overhead or as General and Administrative
expenses charged indirectly to NASA awards.

3. Ways to enhance the quality , utility, and clarity of the information to be
collected.
a. I am unable to address this specific question. I have been retired
from NASA for five years and do not have current information on
information collection systems from which to formulate a reply.
4. Ways to minimize the burden of the collection of information on
respondents, including automated collection techniques or the use of other
forms of information technology.
a. I am unable to address this specific question. I have been retired
from NASA for five years and removed from the business world.
Therefore I do not have the most current information or knowledge
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of more efficient forms of current information technology from
which to formulate a logical and constructive reply.

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