NASA Lunar Programs: Opportunities Exist to Strengthen Analyses and Plans for Moon Landing

In March 2019, the White House directed NASA to accelerate its plans to return humans to the moon by 4 years, to 2024. To accomplish a lunar landing, NASA is developing programs including a small platform in lunar orbit, known as Gateway, and a lunar lander. NASA plans to use the Space Launch System and Orion crew capsule—two programs with a history of cost growth and schedule delays—to launch and transport crew to Gateway.

The House Committee on Appropriations included a provision in its 2018 report for GAO to review NASA's proposed lunar-focused programs, including the Gateway program. GAO's report assesses (1) how NASA updated its lunar plans to support the accelerated 2024 landing timeline; (2) the extent to which NASA has made initial decisions about requirements, cost, and schedule for its lunar mission and programs; and (3) the extent to which NASA analyzed alternatives for its lunar plans, including the Gateway program. GAO analyzed NASA lunar mission and program documents, assessed NASA studies that informed NASA's lunar plans, and interviewed NASA officials.

To support accelerated plans to land astronauts on the moon by 2024—four years earlier than planned—the National Aeronautics and Space Administration (NASA) quickly refocused its acquisition plans. In particular, NASA separated its lunar plans into two phases, with the first phase focused on the systems NASA identified to support the new timeline (see figure). One system, Gateway, includes three components—power and propulsion, habitation, and logistics—to form a small platform in lunar orbit.

NASA has begun making decisions related to requirements, cost, and schedule for programs, but is behind in taking these steps for the whole lunar mission:

NASA risks the discovery of integration challenges and needed changes late in the development process because it established some requirements for individual lunar programs before finalizing requirements for the overall lunar mission. NASA plans to take steps to mitigate this risk, such as by holding reviews to ensure that requirements align across programs, but has not yet defined these reviews or determined when they would occur.

NASA has made some decisions that will increase visibility into the costs and schedules for individual lunar programs, but does not plan to develop a cost estimate for the first mission. Cost estimates provide management with critical cost-risk information to improve control of resources. Without a cost estimate for this mission, Congress will not have insight into affordability and NASA will not have insight into monitoring total mission costs.

NASA conducted studies to inform its lunar plans, but did not fully assess a range of alternatives to these plans. GAO best practices state that analyzing alternatives provides a framework to help ensure that entities consistently and reliably select the alternative that best meets the mission need and justify agency decisions. Given NASA's schedule, conducting this analysis is no longer viable. Instead, NASA intends to create a summary of the studies that informed its lunar plans. However, it has not committed to a completion date. Without a documented rationale, NASA is ill-positioned to effectively communicate its decisions to stakeholders and facilitate a better understanding of its plans.

GAO is making a total of 6 recommendations to NASA, including to define and schedule reviews that align requirements across lunar programs; create a cost estimate for the first lunar mission; and commit to a completion date and finalize a cohesive document outlining the rationale for selecting its current lunar plans. NASA concurred with the recommendations made in this report.

The National Aeronautics and Space Administration (NASA) plans to  return U.S. astronauts to the surface of the Moon by the end of 2024. In  March 2019, the White House directed NASA to accelerate its plans for a  lunar landing from its original goal of 2028, in part to create a sense of  urgency in returning American astronauts to the Moon. To accomplish this  accelerated mission, known as Artemis III, NASA plans to develop a small  platform in lunar orbit called Gateway, acquire a Human Landing System,  and execute uncrewed and crewed demonstration missions of the Orion  Multi-Purpose Crew Vehicle (Orion) and the Space Launch System  (SLS). NASA plans to rely on SLS to launch and transport crew in the  Orion crew capsule—two programs that we have found have a history of  cost growth and schedule delays—to support a lunar landing.

Each of these human spaceflight programs represents a large, complex  technical endeavor that will require sound programmatic decision-making.  Achieving the Artemis III mission will also require extensive coordination  with a wide range of contractors to ensure systems operate together  seamlessly and safely. For example, NASA will need to ensure that the  lunar programs, once in operation, will be safe for crew and can operate  in a challenging deep space environment.

GAO has designated NASA’s management of acquisitions as a high-risk  area for almost three decades. In our March 2019 high-risk report, we  reported there was a lack of transparency in NASA’s major project cost  and schedules, especially for its human spaceflight programs. We  reported that the agency has not taken action on several  recommendations related to understanding the long-term costs of its  human exploration programs. For example, SLS and its associated  ground systems, Exploration Ground Systems, do not have cost and  schedule baselines that cover activities beyond the first planned  uncrewed flight, and Orion does not have a baseline beyond the second  planned crewed flight. We have previously reported that without  transparency into these estimates, NASA does not have the data to  assess long-term affordability and it may be difficult for Congress to make  informed budgetary decisions.

The House Committee on Appropriations included a provision in its 2018  report for GAO to review NASA’s proposed lunar-focused programs,  which includes the Gateway program. Our report assesses (1) how  NASA updated its lunar plans to support the accelerated 2024 lunar  landing timeline; (2) the extent to which NASA has established  requirements for its lunar mission and programs; (3) the extent to which  NASA has made initial decisions about cost and schedule estimating for  its lunar mission and programs; and (4) the extent to which NASA  analyzed alternatives for the lunar architecture, including the Gateway  program. This is our first report on NASA’s lunar programs. We plan to  conduct additional work in this area, which may focus on specific  programs or topics, such as safety.

To assess how NASA updated its lunar plans to support the accelerated  lunar landing timeline, we analyzed NASA program acquisition, budget,  requirements, and lunar architecture documents. The lunar architecture  refers to programs NASA plans to use to achieve its lunar landing  mission, as well as the dependencies and interfaces between these  programs. We analyzed these documents to determine which programs  are part of the architecture, the status and planned acquisition strategy of  those programs, and changes that NASA made to the architecture and to  programs after NASA received White House direction in March 2019 to  accelerate its lunar landing timeline. We also interviewed officials within  the relevant NASA mission directorates and programs.

To assess the extent to which NASA has established requirements for its  lunar mission and programs, we assessed lunar architecture and program  requirements documents. We compared NASA’s plans to set  requirements with the process outlined in NASA policy and guidance. We  also analyzed these documents to determine the extent to which NASA  has defined its architecture. We interviewed officials within the relevant  NASA mission directorates and the Gateway and Human Landing System  program offices to discuss the programs included in the lunar architecture  and the status of establishing requirements. We met with officials within  the Advanced Exploration Systems organization to discuss the status of  finalizing documents that define the lunar architecture and top-level  requirements. We also interviewed officials within the Office of the Chief  Engineer who are responsible for relevant NASA policies and guidance.

To assess the extent to which NASA has made initial decisions about  cost and schedule estimating for its lunar mission and programs, we  compared NASA plans to develop cost estimates and schedules with  NASA policy and guidance. Further, we conducted a more in-depth look  at the Gateway program’s acquisition plans because it is furthest along in  the acquisition lifecycle when compared to the other lunar programs, and  is a key program within the lunar architecture. We analyzed the Gateway  program and project acquisition and milestone documentation, and  compared Gateway plans against NASA systems engineering and  program and project management policies and guidance to determine the  extent to which the program is tailoring, or modifying, NASA policies and  guidance. We interviewed officials within the Human Exploration and  Operations Mission Directorate (HEOMD) and the Gateway and Human  Landing System program offices to understand NASA’s initial decisions  on developing cost and schedule estimates for the lunar mission and  programs and the status of making these decisions. We also interviewed  officials within the Office of the Chief Engineer and Office of the Chief  Financial Officer who are responsible for NASA’s policies and guidance  on cost and schedule estimating.

To assess the extent to which NASA analyzed alternatives for the lunar  architecture, including the Gateway program, we reviewed NASA systems  engineering and program and project management policies and guidance  to determine what requirements existed for analyzing alternatives, if any.  We used GAO best practices to identify the benefits of assessing  alternatives. We analyzed trade studies, briefings, white papers, and  other assessments provided to us by NASA to determine the extent to  which NASA analyzed alternatives for the lunar architecture. We also  interviewed HEOMD officials on the purpose of these trade studies,  briefings, white papers, and other assessments and officials within the  Office of the Chief Engineer and Office of the Chief Financial Officer who  are responsible for NASA policies and guidance related to assessing  alternatives.

We conducted this performance audit from January 2019 to December  2019 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.

NASA’s human spaceflight plans have changed focus three times over  the last 15 years. These plans have shifted back and forth between  conducting a human lunar landing in order to inform the longer-term goal  of human exploration of Mars and a mission that sends astronauts to an  asteroid boulder in orbit around the Moon but does not include a lunar  landing. Figure 1 highlights key events in NASA’s human spaceflight  plans from 2005 to 2019.

We have found that NASA has faced challenges developing systems  capable of transporting humans to space over the past two decades.  These include development efforts under NASA’s prior human spaceflight  program—the Constellation program—which was canceled in the face of  acquisition problems and funding-related issues. More recently, we have  found that NASA has struggled to complete its current human spaceflight  programs—Orion, SLS, and Exploration Ground Systems—within their  established cost and schedule baselines.

Establishing a sound business case to ensure resources align with  requirements includes following best practices for product development  and creating cost estimates and schedules. NASA’s prior human  spaceflight programs highlight challenges created when programs do not  establish a sound business case. For example:  In 2009, we found that NASA had not developed a solid business  case—including firm requirements, mature technologies, a realistic  cost estimate, and sufficient funding and time—needed to justify  moving the Constellation program forward into the implementation  phase. We found that the program had not developed a solid  business case because the program had a poorly phased funding  plan that increased the risk of funding shortfalls, among other  reasons. This resulted in the program not completing planned work to  support schedules and milestones, and ultimately the program was  canceled.

Over the past 5 years, we have issued several reports assessing the  progress of NASA’s Orion, SLS, and Exploration Ground Systems  programs relative to their agency baseline commitments and on  technical challenges facing the programs. In 2018, we found that all  three programs have been at risk of cost and schedule growth since  NASA approved their baselines, and have since experienced cost  growth and schedule delays. This was in part because NASA did not  follow best practices for establishing cost and schedule baselines for  these programs, including not updating cost and schedule analyses to  reflect new risks. As a result, NASA overpromised what it could  deliver from a cost and schedule perspective. Further, in 2019 we  found that NASA should enhance contract management and oversight  to improve SLS and Orion program outcomes. NASA’s past  approach in this area has left it ill-positioned to identify early warning  signs of impending schedule delays and cost growth or reap the  benefits of competition.

We have made 20 recommendations in prior reports to strengthen  NASA’s acquisition management of SLS, Orion, and Exploration Ground  Systems. NASA generally agreed with GAO’s recommendations, and has  implemented eight of the recommendations. Further action is needed to  fully implement the remaining recommendations. For example, in 2019,  we recommended that NASA direct the SLS and Orion programs to  reevaluate their strategies for incentivizing contractors and determine  whether they could more effectively incentivize contractors to achieve the  outcomes intended as part of ongoing and planned contract  negotiations. NASA agreed with the intent of this recommendation and  stated that the SLS and Orion program offices will reevaluate their  strategies for incentivizing contract performance as part of contracting  activities including contract restructures, contract baseline adjustments,  and new contract actions. We will continue to follow up on the actions the  agency is taking to address this recommendation.

NASA initiates space flight programs and projects to accomplish its  scientific or exploration goals. A NASA program has a dedicated funding  profile and defined management structure, and may or may not include  several projects. Projects are specific investments under a program that  have defined requirements, life-cycle costs, schedules, and their own  management structure. NASA uses the term “tightly coupled program” to  refer to a program that is composed of multiple projects that work  together to complete the program’s mission.

NASA policy states that programs and projects shall follow their  appropriate life cycle. The life cycle for programs and projects consists of  two phases:  1.  formulation, which takes a program or project from concept to  2.  implementation, which includes building, launching, and operating the  system, among other activities.

Senior NASA officials must approve programs and projects at milestone  reviews, known as key decision points (KDP), before they can enter each  new phase. The life cycle for a single program closely resembles the life  cycle for a spaceflight project. For example, the SLS program follows the  project acquisition life cycle because it is not composed of multiple  projects. Figure 2 depicts a notional NASA life cycle for a tightly coupled  program and for a project.

The formulation phase culminates in a review at KDP I for tightly coupled  programs and KDP C for projects. This decision point is also known as  confirmation, at which cost and schedule baselines are established and  documented in a decision memorandum. The decision memorandum  outlines the management agreement and the agency baseline  commitment. The management agreement can be viewed as a contract  between the agency and the program or project manager. The program or  project manager has the authority to manage the program or project  within the parameters outlined in the agreement. The agency baseline  commitment includes the cost and schedule baselines against which the  agency’s performance on a program or project may be measured.

To inform the management agreement and the agency baseline  commitment, each program and project with a life-cycle cost estimated to  be greater than $250 million must also develop a joint cost and schedule  confidence level (JCL). A JCL produces a point-in-time estimate that  includes, among other things, all cost and schedule elements from the  start of formulation through launch, and incorporates and quantifies  known risks, assesses the effects of cost and schedule to date on the  estimate, and addresses available annual resources. The results of a JCL  indicate the probability of a program or project’s success of meeting cost  and schedule targets.

Key Elements of NASA’s Planned Return to the Moon

NASA has initiated multiple programs to help the agency achieve its  Artemis III mission and longer-term lunar exploration goals. These  programs include a platform in the lunar orbit, a landing system to put  humans on the surface of the Moon, and robotic lunar landing services.

Gateway. The Gateway program aims to build a sustainable platform in  lunar orbit to support human lunar exploration and scientific experiments  by NASA and its commercial and international partners. NASA is planning  for Gateway to maneuver to different orbits around the Moon, which will  allow access to a variety of locations on the lunar surface.

The Gateway program is the first program NASA has designated as a  tightly coupled program. The program is composed of multiple projects,  which are responsible for executing portions of the Gateway mission.  Individual teams manage the projects and each project will have its own  cost estimate and launch readiness date. Gateway program management  is responsible for ensuring the overall integration of all the individual  projects. See figure 3 for a description of the three Gateway projects that  NASA has initiated.

In addition to Gateway, NASA initiated several other programs:  Human Landing System. The Human Landing System, or lunar landers,  is to provide crew transportation from Gateway to the lunar surface and  back and demonstrate capabilities required for deep space missions.  NASA anticipates that there will be three stages to the landers—a  descent, ascent, and transfer stage—but the number of stages may vary  depending on the contractors that NASA selects to develop the system.  NASA is planning for the descent stage to serve as a crew and cargo  lander; the ascent stage to bring crew back to Gateway from the lunar  surface; and the transfer stage to transfer the ascent and descent stages  from Gateway orbit to a lower lunar orbit for the landing.

Space Suits. NASA plans to update the design of its space suits, which  supply life support, including oxygen and water, among other things, to  astronauts. The updates include additional protection from extreme  temperatures and hazards in the lunar environment, such as dust;  increased mobility; and extended service life for lunar surface operations.

Commercial Lunar Payload Services. Under Commercial Lunar  Payload Services, commercial partners provide end-to-end commercial  payload delivery services to the surface of the Moon. The services  include integrating payloads onto a robotic lander, launching the lander,  and operating the lander and payloads. The payloads include science  instruments and technology demonstrations that will characterize the  lunar environment and inform the development of future landers and other  exploration systems needed for humans to return to the lunar surface.

Volatiles Investigating Polar Exploration Rover. NASA plans to  develop a robotic lunar rover for long duration operations to investigate  volatiles—which include water, carbon dioxide, and other chemicals that  boil at low temperatures—at the lunar South Pole that could be used to  support sustained human presence on the Lunar surface. NASA plans to  utilize landers from the Commercial Lunar Payload Services to deliver the  rover to the lunar surface.

Orion and SLS. Orion is the crew capsule to transport humans from the  Earth to Gateway and beyond. SLS is the vehicle NASA will use to launch  the Orion crew capsule and cargo beyond low-Earth orbit, including to  Gateway.

Figure 4 shows a notional configuration of Gateway, the first integrated  Human Landing System, and the Orion crew capsule. In this  configuration, the Human Landing System ascent stage, Gateway  Logistics and Power and Propulsion Element (PPE), and Orion crew  capsule are designed to dock with the Gateway Habitation and Logistics  Outpost.

The Advanced Exploration Systems organization is responsible for  overseeing the Gateway and Human Landing System programs and  reports to NASA’s Associate Administrator for Human Exploration and  Operations Mission Directorate (HEOMD). Another organization within  HEOMD—Exploration Systems Development—is responsible for the  development of the Orion crew capsule. The Office of the Chief Engineer  and Office of the Chief Financial Officer are responsible for NASA policies  and guidance related to the development of these systems.

NASA Adjusted Its Acquisition Plans to Support 2024 Lunar Landing

After the March 2019 announcement to accelerate the human lunar  landing to 2024, NASA acknowledged that it could not complete all of its  original plans under the new time frame. The original plans for a human  lunar landing in 2028 included an expanded Gateway and uncrewed  demonstrations of components of the Human Landing System. In  response to the new direction, NASA decided to execute its lunar plans in  two phases. Phase 1 focuses on systems NASA identified to support the  Artemis III mission in 2024. Phase 2 builds upon Phase 1 efforts and  focuses on establishing a long-term presence on the lunar surface  through future Artemis missions, and is not currently the focus of NASA’s  efforts (see figure 5).

NASA made several changes to its prior lunar plans to increase the  speed of developing the systems needed to meet the aggressive timeline  for the Artemis III mission. For example:

NASA reduced the scope of the Gateway program for Phase 1 by  deferring or eliminating components, and changing its configuration.  NASA removed a component that an international partner had  planned to contribute and deferred work on a habitation component  and other potential international contributions to Phase 2.  Acknowledging that some elements of Gateway had to be deferred or  eliminated for the first phase is a positive step NASA has taken to try  to achieve an aggressive schedule.

In some cases, NASA changed the acquisition strategy to increase  the speed of development work. For example, NASA had planned to  build the Habitation and Logistics Outpost in-house, but due to the  2024 acceleration announcement, now plans to award a contract for  its development. In addition, NASA changed its plans to acquire the  Human Landing System as an integrated system instead of by stage  to meet the accelerated timeline.

NASA developed a broad agency announcement for the Human  Landing System with the goal of awarding contracts by the end of  January 2020. NASA released a draft broad agency announcement  for the integrated system in July 2019, about 4 months after receiving  direction to land humans on the Moon by 2024. Human Landing  System program officials raised concerns about the program’s ability  to meet the 2024 timeline, but said they are trying to mitigate this risk  by incorporating input from prior studies and feedback from industry  into the program’s draft broad agency announcement.

See table 1 for the status of NASA’s lunar programs, including changes  NASA made to prior plans and timelines to meet the 2024 lunar landing  goal.

NASA is still considering the extent to which competition will be part of its  acquisition plans to meet the accelerated 2024 landing. Competition may  be a critical tool for achieving the best possible return on investment for  taxpayers, and can help improve contractor performance. In addition, in  2014, we found there were competition opportunities for future SLS  development work that may promote long-term affordability. We  recommended that NASA assess the extent to which the agency could  competitively procure development and production of future elements of  the SLS to promote affordability. NASA agreed with this recommendation.  However, NASA’s progress implementing it has been limited. For  example, NASA awarded a sole-source contract for the upper stage  engine, which further limits an opportunity for competition for the program.

For Gateway Logistics Services and the Human Landing System, NASA  officials stated that they are considering awarding multiple initial  contracts. If NASA does award multiple contracts, NASA officials stated  they would then be able to have the contractors compete for further  development of the components and possibly for specific missions.  Conversely, NASA does not plan to competitively award a contract for the  Gateway Habitation and Logistics Outpost, citing the aggressive Artemis  III schedule as a factor for this decision.

NASA Risks Integration Challenges Because Lunar Mission Requirements Have Not Yet Been Established

NASA has identified the components of its lunar architecture—such as  Gateway and lunar landers—but it has not fully defined a system  architecture or established requirements for its lunar mission. A system  architecture, among other things, defines the dependencies and  interfaces between the components. The NASA systems engineering  handbook states that defining the system architecture early enables  NASA to develop components separately from each other while ensuring  that they work together effectively to achieve top-level requirements. For  example, a system architecture for the Artemis III mission would describe  the relationships and interfaces between Gateway and the Human  Landing System, ensuring that after the two programs are completed,  they will work together properly to execute the mission. Figure 6 is an  illustration of how specific program and project requirements flow down  from NASA’s strategic goals and objectives.

NASA officials told us they started with defining individual program and  project requirements, and then plan to define the system architecture in  an architecture definition document and the lunar system requirements in  six separate HEOMD documents. These documents are in various  stages of completion. HEOMD officials said they expect to finalize the  overall architecture definition document at the end of 2019. They plan for  this document to include a description of the integrated architecture,  including the architecture’s components and high-level interfaces required  for initial human lunar surface missions. In addition, HEOMD has six other  documents that establish requirements for human space exploration  missions, among other things. Three of these documents are currently  outdated because they do not address lunar landings. HEOMD officials  stated that they do not expect the documents to be updated before the  end of 2019.

NASA officials told us that they did not start with these higher-level  architecture and all of the requirements documents because they thought  it was important to first establish requirements for individual programs and  review what contractors proposed for Gateway and the Human Landing  System, and incorporate industry input on what requirements are feasible.  The Human Landing System draft request for proposals contained a  notional architecture that has three stages, but the agency is open to  selecting contractors that do not follow this notional architecture.

In our work to develop a framework for assessing and improving  enterprise architecture management, we found that a mature architecture  should ensure that components of the architecture align their plans with  enterprise-level plans. Establishing such alignment is essential to  achieving goals and supporting solutions that are appropriately integrated  and compatible.

NASA’s approach of defining the lunar architecture and associated  requirements concurrently with programs setting their own requirements  presents the risk of mismatches of requirements across and within  programs. Such mismatches increase the risk of technical problems,  schedule delays, and cost overruns. For example, the Gateway program  is tracking the potential misalignment of requirements as a risk because  the PPE project finalized its requirements before the Gateway program  finalized corresponding requirements at the program level. PPE officials  stated they finalized their requirements first because they had started  work under a prior project and, as a result, moved quickly through early  development activities.

The Gateway program and PPE project officials said that when they  reviewed the PPE requirements with Gateway’s requirements, they found  two possible gaps. For example, NASA officials explained that there is a  difference in the amount of power the PPE contractor is required to  deliver for the PPE and Gateway’s requirements for power. The program  is working with the PPE project office and contractor to study the potential  gaps and determine how to resolve them if needed. The Gateway  program officials said they would continue to assess gaps and risks  related to requirements alignment for all projects.

HEOMD officials agreed that there is a risk of discovering integration  challenges across programs. NASA officials have taken action on one  strategy to minimize this risk, and are considering two other potential  mitigation strategies. To help ensure that the components of the lunar  architecture can work together, NASA included international  interoperability standards in its requests for proposals for the lunar  programs. For example, there are standards for how the components will  dock with each other. NASA officials said that including these standards  would help mitigate integration challenges.

The two other potential mitigation strategies are the following:

Establish a Lunar Exploration Control Board. NASA is in the  process of establishing a board that would act as an architecture  configuration management body. Configuration management is a  process used to control changes to top-level requirements. In our prior  work on developing and maintaining systems or networks, we found  that effective configuration management is a key means for ensuring  that additions, deletions, or other changes to a system do not  compromise the system’s ability to perform as intended. The board  could serve as a body to make decisions that affect multiple lunar  programs and ensure that changes to components of the lunar  architecture do not affect NASA’s ability to accomplish a successful  lunar landing.

Hold cross-program synchronization or integration reviews. To  help ensure that requirements are aligned across programs, a senior  HEOMD official said NASA plans to hold cross-program  synchronization or integration reviews. However, the official said  NASA has not defined at what level those reviews would occur, when  those reviews would occur, or what specific contractor data would be  reviewed. Ensuring the Lunar Exploration Control Board is involved in  these reviews will help the board in its role as a configuration  management body and inform decisions that affect multiple lunar  programs.

NASA’s system engineering handbook states that activities to integrate  systems throughout a system life cycle help to make sure that integrated  system functions properly. These activities include conducting analysis to  define and understand integration between systems. NASA is moving  quickly to develop individual programs and projects that must work  together as part of the broader lunar architecture. Delaying decisions  about how and when NASA plans to hold synchronization or integration  reviews risks discovery of changes late in the acquisition process. As  stated in NASA’s system engineering guidance, the later in the  development process changes occur, the more expensive they become.

NASA’s Initial Decisions for Cost and Schedule Estimating Include Benefits, but Limit Some Information for Decision Makers

NASA has taken positive steps to increase the visibility into the cost and  schedule performance of the Gateway program’s projects, but decisions  on analyses to support program-level cost and schedule are still pending.  In addition, the NASA Administrator has stated that Artemis III may cost  between $20 billion to $30 billion, but NASA officials stated that the  agency does not plan to establish an official cost estimate.

Gateway Structure Provides Increased Visibility for Project Cost and Schedule Performance, but Decisions on Program Reviews and Analysis Are Pending

As of October 2019, NASA was still defining its approach for developing  cost and schedule estimates for all programs and projects in the lunar  architecture, but we found NASA has made some decisions related to the  structure of the Gateway program that will provide visibility into cost and  schedule performance. In particular, NASA’s decision to structure the  Gateway program as a tightly coupled program means that the projects  that compose the Gateway—Power and Propulsion, Habitation and  Logistics Outpost, and Logistics—are to develop individual project cost  and schedule baselines by which performance will be measured. NASA  officials stated that they expect this will provide accountability for each  project to adhere to its cost and schedule baseline. This structure is a  positive step for NASA to improve management of large, complex  programs, and could have been beneficial to previous human spaceflight  programs. For example, cost and schedule baselines for key hardware  elements of the Space Launch System program—such as the core  stage—might have provided earlier warning signs of development  challenges affecting cost and schedule performance.

NASA policy requires tightly coupled programs with a life cycle cost  estimate greater than $250 million to conduct a program-level joint cost  and schedule confidence level (JCL) to inform an agency baseline  commitment. A JCL is a calculation that NASA uses to estimate the  probability of success of a program or project meeting its cost and  schedule baselines.

However, NASA decided to remove the requirement for the Gateway  program to establish an agency baseline commitment, and instead,  require the program to document its cost and schedule estimates for  phase 1 in a program commitment agreement. NASA officials explained  that the agency viewed requiring the Gateway program to conduct a JCL  to inform cost and schedule baselines as duplicative of analysis the  projects are required to conduct to inform their project level baselines. In  October 2019, Gateway program officials stated they have reconsidered  this direction and now plan to conduct a program-level JCL. However,  given that NASA officials previously determined they would not require  the Gateway program to establish a baseline that is informed by a  program-level JCL, the decision to conduct a JCL is subject to change  again.

NASA’s commitment to the program’s October 2019 decision to conduct a  program-level JCL would enhance oversight and management for  Gateway. NASA’s cost estimating handbook states that a JCL can serve  as a valuable management tool that helps enforce some best practices of  program planning and control, and potentially enhance vital  communication to various stakeholders. Having a program-level JCL  could help the program identify additional cost and schedule risks  associated with integration of, or dependencies across, Gateway  components that individual projects may not identify. As a tightly coupled  program, Gateway has project schedules that are dependent on one  another. For example, PPE provides power to subsequent Gateway  components, such as the Habitation and Logistics Outpost, and must be  launched and in lunar orbit for the outpost to dock with PPE. A program- level JCL would be able to quantify risk of delay across all dependent  activities, regardless of which individual project experiences the delay. It  would also provide NASA decision-makers and external stakeholders,  such as Congress, with the probability of the program meeting both its  cost and schedule commitments to support the Artemis III mission.

The Gateway program is also the program in the lunar architecture that is  the furthest along in developing a schedule aside from the SLS, Orion,  and Exploration Ground Systems programs. The program expects to  have an integrated master schedule in late 2019, but in the meantime has  developed a high-level notional schedule. We identified two challenges  with the Gateway program’s schedule that stem from decisions to meet  the program’s rapid pace of development.

Program and project technical reviews do not align. The NASA  program management handbook states that lower-level technical reviews,  such as project preliminary design reviews, are typically conducted prior  to the program-level reviews. In addition, GAO’s Schedule Assessment  Guide states that lower-level project schedules should be consistent with  upper-level program review milestones. This creates consistency  between program and project schedules, which enables different teams to  work to the same schedule expectations and ensures the proper  sequencing of activities.

The Gateway program obtained approval from the NASA Associate  Administrator to tailor its review schedule.  This includes the replacement  of traditional reviews with program sync reviews informed by project-level  technical reviews. The program has some of the project-level technical  reviews for its projects—PPE, Habitation and Logistics Outpost, and  Logistics—occurring after equivalent Gateway program-level reviews. The  Gateway program-level reviews are referred to as sync reviews, during  which information is assessed across all projects. For example, the  Logistics project plans to hold its preliminary design review after the  Gateway program preliminary design-informed sync review. Figure 7  shows the preliminary Gateway program schedule and identifies reviews  that differ from the notional tightly coupled program schedule found in  NASA guidance.

Without the results of project-level reviews, program officials may have  limited information to assess progress at program-level reviews. This  opens up the possibility of costly re-designs at later stages of the program  life cycle. Gateway program officials said as the program progresses,  they plan to assess the risk of holding a project-level review after a  program-level review against the risk of delaying a program-level review  to hold all the project-level reviews first. Officials added that they are still  reviewing their approach for the timing of the reviews. We will continue to  follow up through future work on the Gateway program’s risk  assessments related to the timing of the technical reviews.

Scheduling of key program milestone reviews after 2021 deferred.  The Gateway Program does not yet have key milestone reviews—known  as key decision points (KDP)—scheduled after 2021 (see figure 7).  Currently, the final key decision point scheduled for the program is KDP I  in 2021, which evaluates the completeness of the preliminary design,  including for projects, and determines the program’s readiness to begin  the detailed design phase. However, NASA policy requires the program to  conduct two other key decision points that the Gateway program has not  yet scheduled. Program officials told us that they want to determine the  need for subsequent decision points after the systems have matured  further in their development.

During the period between 2021 and 2024, the Gateway program plans to  launch and assemble its three components—PPE, Habitation and  Logistics Outpost, and the first logistics vehicle—and integrate with the  Human Landing System and Orion. It may be appropriate not to schedule  a KDP III—a decision point that evaluates the readiness of the program,  including its projects, for launch and early operations—for the Gateway  program since the projects will launch separately and conduct operations  on different timelines. However, not having a KDP II—a decision point  that evaluates the program’s readiness for assembly, integration, and  testing, prior to a system integration review—will limit information  available to senior leaders for decision-making. Without scheduling a  KDP II, NASA risks not having a formal mechanism to ensure that NASA  has identified and sufficiently addressed any integration issues across the  three projects.

NASA Does Not Plan to Develop a Lunar Mission Cost Estimate

The NASA Administrator made a public statement that the Artemis III  mission may cost between $20 billion and $30 billion, but NASA officials  told us they do not plan to develop an official cost estimate for the Artemis  III mission. A senior HEOMD official said that the agency developed a  cost estimate that included costs for the lunar mission to 2028 to support  budget submissions. However, the official said this life-cycle cost estimate  included costs outside of the Artemis III mission, such as for missions  later than Artemis III, and may not include integration and overall  management costs. NASA officials told us that it is complicated to  separate out costs for each mission and, as a result, do not plan to  develop an Artemis III cost estimate. In addition, senior NASA officials  stated that many of the programs needed to execute the mission are  currently in the early stages of acquisition, and therefore NASA has  limited cost information. Meanwhile, NASA requested an additional $1.6  billion in fiscal year 2020 above its initial budget request to support the  Artemis III mission.

Cost estimates provide management with critical cost-risk information to  improve the control of resources in the present and future. GAO’s Cost  Estimating and Assessment Guide states that a life-cycle cost estimate  enhances decision-making, especially in early planning of an  acquisition. Individual program cost estimates would not capture the  integration costs across programs. Without an Artemis III cost estimate,  NASA will not be able to effectively monitor total mission costs and  Congress would have limited insight into mission or program affordability  when making decisions about each year’s budget request.

NASA Conducted Studies to Inform Lunar Plans, but Did Not Fully Assess Alternatives

Given the breadth of activity and funding required for NASA to achieve a  human lunar landing, a number of stakeholders have advocated for NASA  to carry out this mission in a different way than NASA is pursuing. For  example, one advocate proposed alternative lunar architectures that do  not include the use of Orion, SLS, or Gateway, and instead rely on the  use of commercial vehicles, and a former NASA associate administrator  has promoted increased use of NASA’s current programs, including SLS.

Agencies can use the process of assessing alternatives to justify their  decisions and demonstrate careful planning. While NASA policy does not  require programs to analyze alternatives before starting work, GAO best  practices state that analyzing alternatives provides a framework to help  ensure that entities consistently and reliably select the alternative that  best meets the mission need based on selection criteria, such as safety,  cost, or schedule. Similarly, the Department of Defense, an agency that  also invests billions of dollars in acquisitions, considers an analysis of  alternatives a key input to defining a system’s capabilities and assessing  affordability. We previously found that analyzing alternatives is a key  element in establishing a sound business case for a new architecture or  program. Having a strong business case, including a formal assessment  of alternatives, would help NASA effectively communicate its decisions to  various stakeholders and facilitate a better understanding of its current  lunar plans.

NASA officials told us that they arrived at the current architecture and the  designs of its lunar programs by conducting numerous studies and  analyses over multiple decades. These studies looked at aspects of the  various lunar missions NASA has planned over time, including the prior  Constellation program and Journey to Mars effort. A HEOMD official  responsible for mission directorate analyses said that the studies ranged  from quick turn-around analyses to long-term, thorough studies. NASA  officials identified 12 studies completed since the conclusion of the  Constellation program in 2010 that informed their decision to build  Gateway and other aspects of the lunar architecture. The studies varied  in focus, ranging from a study on the overall framework for a mission to  Mars to a study exclusively on the human lunar landers.

We reviewed these 12 studies to determine the extent to which NASA  analyzed alternatives to inform its current lunar architecture. We found  that some of the studies contained detailed analyses, but had a narrow  scope. For example:

NASA conducted a study on the design of its human lunar landers  that identified several alternative designs for the lander configuration,  including two- and three-stage landers. The study provided an  analysis on each alternative in order to compare those alternatives,  given the physical constraints of SLS and commercial launch vehicles.

HEOMD reviewed prior studies on a cislunar habitation facility  conducted by internal and external partners that informed an  Assessment of Alternatives for the Gateway program. At the time the  mission directorate conducted this assessment, the concept was  focused on the Journey to Mars effort, and mentioned lunar landers  only as a potential secondary mission. The assessment analyzed  various alternative configurations that Gateway might use and  selected one of them based feasibility and schedule.

NASA conducted studies on the best orbit in which to place Gateway.

While these studies were robust, they did not more broadly analyze  whether Gateway was the best solution to meet the mission need  based on selection criteria.

The following are examples of topics that NASA could have addressed if  they had analyzed alternatives with a broader scope:

Assessing commercial alternatives to SLS and Orion for a  human landing on the Moon. Each of the studies assumes the use  of SLS and the Orion capsule in order to conduct the required  mission. A HEOMD official told us that they did not assess  commercial alternatives to SLS and Orion because commercial  alternatives are not available. If commercial technology to replace  SLS and Orion becomes available, the official said NASA can on- ramp those options if SLS and Orion are not delivered on time.

Assessing how a more capable SLS could have affected the  lunar architecture. NASA did not assess whether refocusing  investment on more capable versions of its current programs,  including SLS, might affect risk, cost, and schedule for a lunar landing  mission. For example, developing a more capable SLS earlier may  have enabled NASA to propose a different lunar lander design or to  launch components of the architecture in fewer launches. In the study  on the design of its human lunar landers, NASA assumed that a more  capable version of SLS would not be available until at least 2028, and  therefore did not assess using it as a part of its architecture. Further,  at the time of the study in 2018, NASA was unsure it would have  enough SLS core stages available to utilize them for any components  of the architecture other than to transport crew.

Identifying alternatives to a lunar landing without using Gateway.  All of the studies assumed the use of Gateway or similar capability as  opposed to a capability that would take astronauts directly to the lunar  surface. A HEOMD official told us that NASA did not assess  architectures without Gateway because they planned to utilize SLS  and Orion, and NASA did not design the Orion capsule for a direct-to- moon landing. However, a HEOMD official provided us with a quick  turn-around analysis that NASA conducted in 2019, after NASA  initiated the Gateway program, in response to questions about  alternative lunar architectures. This analysis compared a lunar landing  from Gateway to a landing without Gateway and found that NASA  would have to upgrade the Orion Capsule to have a direct-to-moon  landing, which would increase the cost and development time of the  program. As a result, the analysis concluded that a lunar landing  using Gateway was the superior option. Additionally, officials said  Gateway helped develop an architecture that was sustainable and  could contribute to a mission to Mars.

In addition, only one of the studies focused on a lunar landing mission  because NASA completed most of the studies prior to the December  2017 Space Policy Directive-1. NASA officials stated that this is because  they were told not to analyze a lunar landing during the previous  administration. As a result, none of these studies represents a  comprehensive assessment for NASA’s current plans to return to the  Moon and are, in total, missing information on potential alternatives.

While conducting a formal analysis of alternatives for the lunar  architecture is no longer viable given NASA’s schedule, by not having  such an analysis NASA is ill-equipped to consider other alternatives as  off-ramps if the current lunar architecture plans run into delays. Further,  none of the studies contained a life-cycle cost estimate and without this,  NASA does not know the costs of its architecture or of potential  alternatives.

In October 2019, NASA officials stated they had begun to develop an  Architecture Campaign Document, which would provide a summary of the  studies and analyses that have informed NASA’s lunar architecture.  However, this document was still in draft form at the time of our review  and officials did not commit to a completion date. Until NASA completes  this summary, it will not have a cohesive document outlining the rationale  for how it selected its current lunar architecture and lunar programs.

Lastly, the practice of formally assessing alternatives is a beneficial  practice for future architectures and programs. However, NASA policy  and guidance describe an analysis of alternatives as a tool, but does not  require officials to analyze alternatives prior to starting work to develop a  system architecture or initiating directed missions. NASA may analyze  alternatives for an architecture, program, project, or specific design or  capability, but conducting a formal analysis of alternatives is optional.  Without a requirement to conduct an analysis of alternatives prior to  NASA authorizing the initial planning of a program, NASA could miss  opportunities to move forward with a more viable architecture or program  to meet mission needs in the future. For a new architecture or large  programs that require a lot of investment, such as future exploration  efforts including Mars, conducting an analysis of alternatives would better  position NASA to build a sound business case, justify and document its  decisions, and advocate for its plans.

Effectively executing the Artemis III mission will require extensive  coordination within NASA and its commercial partners, and for each  individual program to meet aggressive development time frames. As  NASA continues to develop its architecture and program schedules, it will  be important that the agency use program management tools and  practices to set these new programs up for success. Ensuring that NASA  identifies points in time to conduct synchronization reviews, that the role  of the proposed Lunar Exploration Control Board in these reviews is  understood, and that programs are prepared with the necessary  information to make the reviews successful will help NASA mitigate the  risk of discovering integration challenges across the lunar programs. The  reviews could be a helpful checkpoint on the agency’s progress towards  meeting the aggressive timeline of the Artemis III mission. Further,  ensuring that the Gateway program has an integrated schedule early on  will help the program plan work to meet critical deadlines and avoid  unnecessary rework due to the misalignment of requirements or design  changes.

To date, NASA has provided decision makers with limited cost  information to inform decisions on the overall lunar investment. Without  an overall cost estimate for the Artemis III mission, NASA is asking  Congress to appropriate additional funding to meet a 2024 lunar deadline  without having information available on how much it will cost in total to  support such plans. Further, NASA senior leadership made a decision  that resulted in limiting information regarding the probability of the  Gateway program meeting cost and schedule estimates to support the  2024 lunar landing. Requiring the program to conduct a joint cost and  schedule confidence level analysis would help to determine whether  NASA can meet its lunar goal and whether it has resources to be able to  do so.

NASA will continue to have many stakeholders interested in its human  space exploration plans, which requires NASA to establish a lunar  architecture and programs that the agency can defend over time and to  demonstrate that it has a solid business case. However, NASA is ill- positioned to explain how it arrived at its current lunar architecture without  a comprehensive assessment that documents how NASA decided that its  current plans are the best way to meet the agency’s long-term lunar  exploration goals. NASA has taken a positive step by planning to create a  summary of the studies and analyses that informed its lunar architecture,  but has not committed to a date to finalize it. Finally, ensuring that NASA  conducts a formal analysis of alternatives for future strategic missions  and architectures, including as it further develops its plans for a human  mission to Mars, will better position the agency to consistently and reliably  select alternatives that best meet the mission need.

We are making the following six recommendations to NASA.

The NASA Administrator should ensure that the NASA Associate  Administrator for Human Exploration and Operations directs the  Advanced Exploration Systems division to define and determine a  schedule for synchronization reviews, including the role of the proposed  Lunar Exploration Control Board, to help ensure that requirements  between mission and program levels are reconciled. (Recommendation 1)

The NASA Administrator should ensure that the NASA Associate  Administrator for Human Exploration and Operations directs the Gateway  program to conduct a joint cost and schedule confidence level at the  program level for the Artemis III mission. (Recommendation 2)

The NASA Administrator should ensure that the NASA Associate  Administrator for Human Exploration and Operations directs the Gateway  program to update its overall schedule for 2024 to add a KDP II to occur  before system integration. (Recommendation 3)

The NASA Administrator should ensure that the NASA Associate  Administrator for Human Exploration and Operations creates a life-cycle  cost estimate for the Artemis III mission. (Recommendation 4)

The NASA Administrator should ensure that the NASA Associate  Administrator for Human Exploration and Operations directs the  Advanced Exploration Systems division to commit to a completion date  and finalize a cohesive document outlining the rationale for selecting its  current lunar architecture and lunar programs. (Recommendation 5)

The NASA Administrator should ensure that the Office of the Chief  Engineer determines under what conditions it is appropriate to complete  an analysis of alternatives, particularly when there are multiple  pathways—including architectures or programs—that NASA could pursue  in the future, and document the justification for not completing an  analysis. (Recommendation 6)

We provided a draft of this report to NASA for comment. In written  comments, NASA agreed with our six recommendations. NASA provided  estimated dates of completion for all of the recommendations ranging  from April 2020 to September 2021. The comments are reprinted in  appendix I. NASA also provided technical comments, which have been  addressed in the report, as appropriate.

We are sending copies of this report to the NASA Administrator and  interested congressional committees. In addition, the report is available at  no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-4841 or chaplainc@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made major contributions to  this report are listed in appendix II.

Appendix I: Comments from the National Aeronautics and Space Administration

Cristina T. Chaplain, (202) 512-4841 or chaplainc@gao.gov.

In addition to the contact named above, Molly Traci, Assistant Director;  Katie Bassion; Lorraine Ettaro; Laura Greifner; Anna Irvine, Erin  Kennedy; Jason Lee, Assistant Director; Jennifer Leotta, Assistant  Director; Ryan Lester; Dennis Mayo; Sylvia Schatz; Roxanna Sun; Jay  Tallon, Assistant Director; Alyssa Weir; and Tonya Woodbury made  significant contributions to this report.

In March 2019, the White House directed NASA to accelerate its plans to return humans to the moon by 2024—4 years earlier than NASA had planned.

To meet this new goal, NASA made some changes to its approach. But it is still pursuing an array of complex efforts, including a small platform in lunar orbit called the Gateway, where crew could transit to and from the moon. Some have questioned the path NASA is taking and NASA has not fully explained how it arrived at its plans. So we recommended that NASA document its rationale for these decisions.

We also recommended that NASA develop an official cost estimate for the 2024 lunar landing mission.


Border Security: U.S. Government Efforts to Strengthen Nonimmigrant Visa Security and Address High-Risk Air Travelers

Previous attempted and successful terrorist attacks against the United States have raised questions about the security of the U.S. government's screening and vetting processes for NIVs. State manages the visa adjudication process. DHS seeks to identify and interdict travelers who are potential security threats to the United States, such as foreign fighters and potential terrorists, human traffickers, drug smugglers and otherwise inadmissible persons, at the earliest possible point in time. DHS also has certain responsibilities for strengthening the security of the visa process. In 2017, the President issued executive actions directing agencies to improve visa screening and vetting, and establishing nationality-based visa entry restrictions, which the Supreme Court upheld in June 2018.

This statement addresses (1) data and information on NIV adjudications and (2) CBP programs aimed at preventing high-risk travelers from boarding U.S.-bound flights. This statement is based on prior products GAO issued in January 2017 and August 2018, along with selected updates conducted in December 2018 to obtain information from DHS on actions it has taken to address a prior GAO recommendation.

In August 2018, GAO reported that the total number of nonimmigrant visa (NIV) applications that Department of State (State) consular officers adjudicated annually increased from fiscal years 2012 through 2016, but decreased in fiscal year 2017 (the most recent data available at the time of GAO's report). NIVs are issued to foreign nationals, such as tourists, business visitors, and students, seeking temporary admission into the United States. The number of adjudications peaked at about 13.4 million in fiscal year 2016, and decreased by about 880,000 adjudications in fiscal year 2017. State refused about 18 percent of adjudicated applications during this time period, of which more than 90 percent were because the applicant did not qualify for the visa sought and 0.05 percent were due to terrorism and security-related concerns. In 2017, two executive orders and a proclamation issued by the President required, among other actions, visa entry restrictions for nationals of certain listed countries of concern. GAO's analysis indicates that, out of the nearly 2.8 million NIV applications refused in fiscal year 2017, 1,338 applications were refused specifically due to visa entry restrictions implemented per the executive actions.

In January 2017, GAO reported that the Department of Homeland Security's (DHS) U.S. Customs and Border Protection (CBP) operates predeparture programs to help identify and interdict high-risk travelers before they board U.S.- bound flights. CBP officers inspect all U.S.-bound travelers on those flights that are precleared at the 15 Preclearance locations at foreign airports—which serve as U.S. ports of entry—and, if deemed inadmissible, a traveler will not be permitted to board the aircraft. CBP also operates nine Immigration Advisory Program and two Joint Security Program locations, as well as three Regional Carrier Liaison Groups, through which CBP may recommend that air carriers not permit identified high-risk travelers to board U.S.-bound flights. CBP data showed that it identified and interdicted over 22,000 high-risk air travelers through these programs in fiscal year 2015 (the most recent data available at the time of GAO's report). While CBP tracked some data, such as the number of travelers deemed inadmissible, it had not fully evaluated the overall effectiveness of these programs. GAO recommended that CBP develop a system of performance measures and baselines to better position CBP to assess program performance. As of December 2018, CBP set preliminary performance targets for fiscal year 2019, and plans to set targets for future fiscal years by October 31, 2019. GAO will continue to review CBP's actions to address this recommendation.

GAO previously recommended that CBP evaluate the effectiveness of its predeparture programs. DHS agreed with GAO's recommendation and CBP has actions under way to address it.

I am pleased to be here today to discuss GAO’s body of work on U.S.  government activities related to screening and vetting nonimmigrant visa  (NIV) applicants, and identification and interdiction of international air  travelers who are potential security threats to the United States. Foreign  nationals who wish to come to the United States on a temporary basis  must generally obtain a NIV authorizing their travel to the United States.  In particular, from fiscal years 2010 through 2015, the Department of  State (State) issued more than 52 million visas for business travel,  pleasure, or for foreign student and cultural exchange programs, among  other things.

Previous attempted and successful terrorist attacks against the United  States have raised questions about the security of the U.S. government’s  screening and vetting processes for NIVs. For example, the December  2015 shootings in San Bernardino, California, led to concerns about NIV  screening and vetting processes because one of the attackers was  admitted into the United States under a NIV. Beginning in calendar year  2017, the President issued executive actions aimed at improving the  screening and vetting protocols and procedures associated with the visa  issuance process, including the imposition of visa entry restrictions for  certain categories of foreign nationals from designated countries.  Specifically, the President issued two executive orders and a presidential  proclamation that required, among other actions, visa entry restrictions for  nationals of certain countries of concern, a review of information needed  for visa adjudication, and changes to visa (including NIV) screening and  vetting protocols and procedures.

State is responsible for visa adjudication and issuance for foreign  nationals and is responsible for managing the consular officer corps and  its functions at over 220 visa-issuing posts overseas. The process for  determining who will be issued or refused a visa contains several steps,  including completing an online visa application and appearing for an in- person interview at a U.S. embassy or consulate, as shown in figure 1.

The various security checks NIV applicants undergo generally screen the  applicant’s information (biographic and biometric) against multiple U.S.  government databases to identify potential matches with records of  individuals who are known threats to the United States or other  derogatory information that could make the applicant ineligible. In  addition, biometric checks include running an applicant’s fingerprints and  full-face photograph against multiple government systems. Further, at  some locations overseas, Department of Homeland Security’s (DHS) Visa  Security Program uses the Pre-Adjudicated Threat Recognition and  Intelligence Operations Team check to identify national security, public  safety, and other eligibility concerns related to visa applicants. Prior to  adjudicating the visa application, consular officers must review all such  security check results. DHS also vets individuals with NIVs on a  recurrent basis, which has resulted in State revoking visas after they have  been issued when information was later discovered that rendered the  individual inadmissible to the United States or otherwise ineligible for the  visa.

In addition, DHS seeks to identify and interdict travelers who are potential  security threats to the United States, such as foreign fighters and  potential terrorists, human traffickers, drug smugglers, and otherwise  inadmissible persons, at the earliest possible point in the travel lifecycle.  In particular, DHS’s U.S. Customs and Border Protection (CBP) is tasked  with, among other duties, processing all travelers on U.S.-bound flights  and inspecting all people entering or applying for admission to the United  States. CBP’s National Targeting Center (NTC) conducts traveler data  matching, which assesses whether travelers are high-risk by matching  their information against U.S. government databases and lists, and rules- based targeting, which enables CBP to identify unknown high-risk  individuals. CBP operates multiple predeparture programs that use the  results of NTC’s analyses to help identify and interdict high-risk travelers  before they board U.S.-bound flights.

My testimony discusses: (1) data and information on NIV adjudications  and (2) CBP air predeparture programs. This testimony is based on our  prior reports, in particular, those published in January 2017 and August  2018. For these reports, we reviewed agency policies and procedures  for NIV screening and predeparture programs; conducted site visits to  selected locations to observe NIV operations and the predeparture  targeting process; and collected and analyzed data. Additional details on  the scope and methodology are available in our published reports. In  addition, this statement contains updates to selected information from  these reports. For the updates, we collected information from DHS on  actions it has taken to address findings and recommendations made in  prior reports on which this statement is based. All of our work was  conducted in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.

Number of NIV Adjudications and Refusal Rates Increased From Fiscal Years 2012 Through 2016, and Declined in Fiscal Year 2017

NIV Adjudications Increased Annually from Fiscal Years 2012 through 2016 and Declined in Fiscal Year 2017

We reported in August 2018 that the total number of NIV applications that  consular officers adjudicated (NIV adjudications) annually peaked at  about 13.4 million in fiscal year 2016, which was an increase of  approximately 30 percent since fiscal year 2012. In fiscal year 2017 (the  most recent data available at the time of our report), NIV adjudications  decreased by about 880,000 adjudications, or about 7 percent. Figure 2  shows the number of applications adjudicated each year from fiscal years  2012 through 2017.

Most NIV Applications Refused from Fiscal Years 2012 through 2017 Were for Reasons Other than Terrorism and Other Security-Related Concerns

As shown in figure 2, the percentage of NIVs refused—known as the  refusal rate—increased from fiscal years 2012 through 2016, and was  about the same in fiscal year 2017 as the previous year. The NIV  refusal rate rose from about 14 percent in fiscal year 2012 to about 22  percent in fiscal year 2016, and remained about the same in fiscal year  2017; averaging about 18 percent over the time period. The total number  of NIVs issued peaked in fiscal year 2015 at about 10.89 million, before  falling in fiscal years 2016 and 2017 to 10.38 million and 9.68 million,  respectively.

According to State data, while the majority of NIV refusals from fiscal  years 2012 through 2017 were a result of consular officers finding the  applicants ineligible, a relatively small number of refusals were due to  terrorism and other security-related concerns. State data indicate that  more than 90 percent of NIVs refused each year from fiscal years 2012  through 2017 were based on the consular officers’ determination that the  applicants were ineligible nonimmigrants—in other words, the consular  officers believed that the applicant was an intending immigrant seeking to  stay permanently in the United States, which would generally violate NIV  conditions, or that the applicant otherwise failed to demonstrate eligibility  for the particular visa he or she was seeking. For example, an applicant  applying for a student visa could be refused as an ineligible nonimmigrant  for failure to demonstrate possession of sufficient funds to cover his or  her educational expenses, as required. As we reported in August 2018,  our analysis of State data indicates that relatively few applicants— approximately 0.05 percent—were refused for terrorism and other  security-related reasons from fiscal years 2012 through 2017. As shown  in figure 3, in fiscal year 2017, State data indicate that 1,256 refusals (or  0.05 percent) were based on terrorism and other security-related  concerns, of which 357 refusals were specifically for terrorism-related  reasons.

Executive Actions Taken in Calendar Year 2017 Introduced New Visa Entry Restrictions and Requirements to Enhance Screening and Vetting, Including for NIVs

The President issued Executive Order 13769, Protecting the Nation from  Foreign Terrorist Entry Into the United States (EO-1), in January 2017.  In March 2017, the President revoked and replaced EO-1 with the  issuance of Executive Order 13780 (EO-2), which had the same title as  EO-1. Among other things, EO-2 suspended entry of certain foreign  nationals for a 90-day period, subject to exceptions and waivers. In  September 2017, as a result of the reviews undertaken pursuant to EO-2,  the President issued Presidential Proclamation 9645, Enhancing Vetting  Capabilities and Processes for Detecting Attempted Entry into the United  States by Terrorists or Other Public-Safety Threats (Proclamation), which  imposes certain conditional restrictions and limitations on the entry of  nationals of eight countries—Chad, Iran, Libya, North Korea, Somalia,  Syria, Venezuela and Yemen—into the United States for an indefinite  period. These restrictions, identified in table 1, are to remain in effect  until the Secretaries of Homeland Security and State determine that a  country provides sufficient information for the United States to assess  adequately whether its nationals pose a security or safety threat.  Challenges to both EOs and the Proclamation affected their  implementation and, while EO-2’s entry restrictions have expired, the  indefinite visa entry restrictions outlined in the Proclamation continued to  be fully implemented as of our August 2018 report.

We reported in August 2018 that our analysis of State data indicates that  out of the nearly 2.8 million NIV applications refused in fiscal year 2017,  1,338 were refused due to visa entry restrictions implemented in  accordance with the executive actions. To implement the entry  restrictions, in March 2017, State directed its consular officers to continue  to accept all NIV applications and determine whether the applicant was  otherwise eligible for a visa without regard to the applicable EO or  Proclamation. If the applicant was ineligible for the visa on grounds  unrelated to the executive action, such as having prior immigration  violations, the applicant was to be refused on those grounds. If the  applicant was otherwise eligible for the visa, but fell within the scope of  the nationality-specific visa restrictions implemented pursuant to the  applicable EO or Proclamation and was not eligible for a waiver or  exception, the consular officer was to refuse the visa and enter a refusal  code into State’s NIV database indicating that the applicant was refused  solely due to the executive actions. More than 90 percent of the NIV  applications refused in fiscal year 2017 pursuant to an executive action  were for tourist and business visitor visas, and more than 5 percent were  for students and exchange visitors.

CBP’s Air Predeparture Programs Interdict High-Risk Air Travelers, but CBP Has Not Fully Assessed the Programs’ Performance

CBP Identifies and Interdicts High-Risk Travelers before They Board U.S.-Bound Flights

As we reported in January 2017, CBP electronically vets all travelers  before they board U.S.-bound flights, and continues to do so until they  land at a U.S. port of entry. Through these vetting efforts, CBP seeks to  identify high-risk travelers from the millions of individuals who travel to the  United States each year. As we reported in January 2017, CBP’s vetting  and targeting efforts are primarily conducted by its NTC and entail (1)  traveler data matching and analysis, (2) rules-based targeting, and (3)  recurrent vetting. Specifically:

CBP’s primary method of identifying high-risk individuals is through  the comparison of travelers’ information (such as name, date of birth,  and gender) against records extracted from U.S. government  databases, including the Terrorist Screening Database (TSDB)—the  U.S. government’s consolidated terrorist watch list. Traveler data  matching focuses on identifying known high-risk individuals—that is,  individuals who may be inadmissible to the United States under U.S.  immigration law or who may otherwise pose a threat to homeland or  national security. CBP’s primary tool for vetting and targeting travelers  is the Automated Targeting System (ATS), which is a computer-based  enforcement and support system that compares traveler information  against intelligence and law enforcement data to identify high-risk  travelers. Traveler data matching occurs throughout the travel process  and, upon a positive or possible match, CBP officers can select these  individuals for further vetting, interviewing, and inspection.

CBP’s rules-based targeting efforts seek to identify unknown high-risk  travelers—that is, travelers for whom U.S. government entities do not  have available derogatory information directly linking them to terrorist  activities or any other actions that would make them potentially  inadmissible to the United States but who may present a threat and  thus warrant additional scrutiny. CBP identifies unknown high-risk  individuals by comparing their information against a set of targeting  rules based on intelligence, law enforcement, and other information.  NTC officials stated that these rules have identified potential high-risk  travelers, including potential foreign fighters. Rules-based targeting  evaluates travelers during the travel process and, in some cases, in  advance of the travel process. If a traveler is a rule “hit,” this individual  can be selected for further vetting, interviewing, and inspection.

CBP supports its traveler data matching and rules-based targeting  efforts through the use of recurrent vetting. NTC’s vetting, targeting,  and traveler data matching activities in ATS run 24 hours a day and 7  days a week and automatically scan updated traveler information,  when available. This process is to ensure that new information that  affects a traveler’s admissibility is identified in near real time.  Recurrent vetting occurs throughout the travel process and continues  until a traveler arrives at a domestic port of entry. For example, after  checking into a foreign airport, a traveler may have his or her visa  revoked for a security or immigration-related violation. Due to  recurrent vetting, CBP would be alerted to this through ATS and could  take action, as appropriate.

CBP’s Air Predeparture Programs Interdict High- Risk Travelers on U.S.- Bound Flights, but CBP Has Not Fully Evaluated Overall Effectiveness of These Programs

As we reported in January 2017, throughout the travel process, CBP’s  predeparture programs use the results of NTC’s efforts to identify and  interdict high-risk individuals destined for the United States while they are  still overseas; however, we found that CBP had not evaluated the  effectiveness of its predeparture programs as a whole, including  implementing a system of performance measures and baselines to  assess whether the programs are achieving their stated goals.

CBP operates three air predeparture programs that are responsible for all  U.S.-bound air travelers—(1) Preclearance; (2) the Immigration Advisory  Program (IAP) and Joint Security Program (JSP); and (3) the regional  carrier liaison groups (RCLG). As we reported in January 2017, CBP data  indicated that these programs identified and ultimately interdicted  approximately 22,000 high-risk air travelers in fiscal year 2015, the most  recent data available at the time of our review. Information on individuals  who the NTC identifies through traveler data matching or rules-based  targeting, including recurrent vetting, is compiled automatically through  ATS into a daily high-priority list (or, traveler referral list). CBP officers at  the NTC review the traveler referral list for accuracy and to remove, if  possible, any automatically generated matches determined to not be  potential high-risk individuals. After this review, CBP officers at the NTC  use ATS to send the traveler referral list to officers at each Preclearance,  IAP, JSP, and RCLG location, as shown in figure 4.

Preclearance. Preclearance locations operate at foreign airports and  serve as U.S. ports of entry. Preclearance operations began in 1952 in  Toronto to facilitate trade and travel between the United States and  Canada. As of March 2018, CBP operated 15 air Preclearance locations  in six countries. Through the Preclearance program, uniformed CBP  officers at a foreign airport exercise U.S. legal authorities to inspect  travelers and luggage and make admissibility determinations prior to an  individual boarding a plane to the United States. According to CBP  officials, an inspection at a Preclearance location is the same inspection  as an individual would undergo at a domestic port of entry, and officers  conducting Preclearance inspections exercise the same authority as  officers at domestic ports of entry to approve or deny admission into the  United States. As a result, travelers arriving at domestic air ports of  entry from Preclearance locations do not have to be re-inspected upon  entry. According to CBP data, in fiscal year 2015, CBP officers at  Preclearance locations determined that 10,648 air travelers were  inadmissible out of the approximately 16 million air travelers seeking  admission to the United States through a Preclearance location. In addition to requiring that all travelers undergo a primary inspection, CBP  officers in these locations also referred almost 290,000 individuals for  secondary inspection.

Immigration Advisory Program (IAP) and Joint Security Program  (JSP). IAP and JSP operated at nine and two foreign airports,  respectively, as of January 2017. According to CBP officials, under this  program, unarmed, plainclothes CBP officers posted at foreign airports  partner with air carriers and host country government officials to help  prevent terrorists and other high-risk individuals from boarding U.S.- bound flights by vetting and interviewing them before travel. According  to CBP program documentation, CBP established IAP in 2004 to prevent  terrorists, high- risk travelers, and improperly documented travelers from  boarding airlines destined to the United States. Building on the IAP  concept, CBP established JSP in 2009 to partner with host country law  enforcement officials to identify high-risk travelers. CBP officers at IAP  and JSP locations have the ability to question travelers and review their  travel documents. They are to act in an advisory manner to the air  carriers and host governments and do not have authority to deny  boarding to individuals on U.S.-bound flights or fully inspect travelers or  their belongings. IAP and JSP officers are authorized by CBP to make  recommendations to airlines as to whether to board or deny boarding  (known as a no-board recommendation) to selected travelers based on  their likely admissibility status upon arrival to the United States. The final  decision to board travelers, however, lies with the carriers. According to  CBP data, CBP officers at IAP and JSP locations made 3,925 no-board  recommendations in fiscal year 2015 for the approximately 29 million air  travelers bound for the United States from such locations. During this  same time period, CBP data indicated 1,154 confirmed encounters with  individuals in the TSDB, including 106 on the No Fly List.

Regional Carrier Liaison Groups (RCLG). RCLGs are located and  operate at three domestic airports—Miami International Airport, John F.  Kennedy International Airport, and Honolulu International Airport. CBP  established RCLGs in 2006 to assist air carriers with questions regarding  U.S. admissibility requirements and travel document authenticity.  According to CBP officials, RCLGs are responsible for coordinating with  air carriers on all actionable referrals from NTC on U.S.-bound travelers  departing from an airport without an IAP, JSP, or Preclearance presence.  Each RCLG is assigned responsibility for travelers departing out of a  specific geographic location. Similar to IAP and JSP, CBP officers in  RCLGs also make no-board recommendations, as appropriate, to air  carriers. CBP officers at RCLGs do not have authority to make  admissibility determinations about U.S.-bound air travelers, and the final  decision to board or not board a traveler lies with the carrier. We reported  in January 2017 that CBP officers working at the three RCLGs made  7,664 no-board recommendations in fiscal year 2015 for the  approximately 59 million travelers bound for the United States from  locations within the RCLGs’ spheres of responsibility. During this time  period, CBP data indicated that RCLGs also reported 1,634 confirmed  encounters with individuals in the TSDB, including 119 on the No Fly List.

In January 2017, we reported that CBP had not evaluated the  effectiveness of its predeparture programs as a whole, including  implementing a system of performance measures and baselines to  assess whether the programs were achieving their stated goals. We  reported that CBP had taken some initial steps to measure the  performance of these programs. Specifically, CBP officials told us that  they had collected a large quantity of data and statistics regarding the  actions of their predeparture programs and had done so since program  inception for all programs. However, due to changes in operational focus,  technology updates, and the use of separate data systems at program  locations, CBP had not collected consistent data across all of its  predeparture programs. As a result, CBP did not have baseline data on  which to measure program performance. Therefore, we recommended  that CBP develop and implement a system of performance measures and  baselines for each program to help ensure that these programs achieve  their intended goals. In response, as of March 2018, CBP has developed  three performance measures for its predeparture programs. On the basis  of our review of CBP documentation, as of December 2018, CBP has  collected the fiscal year 2018 data relevant to these measures, used  those data to set preliminary targets for fiscal year 2019, and plans to  analyze the fiscal year 2019 results and set targets for future fiscal years  by October 31, 2019. We will review documentation of CBP’s analysis of  the fiscal year 2019 results and future targets, when available, to  determine if CBP’s actions address our recommendation.

Chairwoman Rice, Chairman Rose, Ranking Members Higgins and  Walker, and Members of the Subcommittees, this concludes my prepared  statement. I would be pleased to respond to any questions that you may  have at this time.

For further information regarding this testimony, please contact Rebecca  Gambler at (202) 512-8777 or gamblerr@gao.gov. In addition, contact  points for our Offices of Congressional Relations and Public Affairs may  be found on the last page of this statement. Individuals who made key  contributions to this testimony are Kathryn H. Bernet, Assistant Director;  Eric Hauswirth; Thomas Lombardi; Sasan J. “Jon” Najmi; Erin O’Brien;  and Natalie Swabb.

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This testimony discusses our earlier findings on nonimmigrant visa applications as well as the Department of Homeland Security's predeparture programs.

About 2.8 million nonimmigrant visa applications were refused in fiscal year 2017—over 90% of which were because the applicant didn't qualify for the visa

0.05% of applications were refused for security-related concerns

1,338 visa applications were refused because of the President's visa entry restrictions for people from certain countries

In fiscal year 2015 DHS’s predeparture programs stopped 22,000 high-risk travelers from entering the country