In Search Of A CASIS Report Card

Keith's note: It is time to examine how NASA and CASIS have interacted since 2011. Little, if anything, has ever been publicly released with regard to how CASIS reports its progress to NASA or how NASA measures or responds to CASIS about their performance. The OIG and GAO have mentioned this matter in prior reports. Last week the NASA Advisory Council spent a lot of time trying (with little success) to figure out what CASIS does. So I just submitted a FOIA request.

Keith's update: Despite my voluminous FOIA request, NASA once again does not accept my claim to be news media even though they themselves granted me news media accreditation 16 years ago. See "NASA Refuses To Accept Its Own News Media Accreditation"

Despite their constant harping about the procedures that they have to follow the letter they sent me to deny my request was dated a year ago. So much for their attention to detail.

This FOIA request is long due to the fact that the last time I submitted a FOIA request in late 2015 NASA decided that I had to prove that I was a member of the news media after more than 15 years of being credentialed by NASA PAO and after having submitted multiple FOIA requests which were processed without incident for more than a decade. Indeed, some of my simple emails to PAO requesting information from NASA were converted into FOIA requests and then promptly processed as such without me even asking that they be considered as FOIA requests. The following is the full text of my FOIA request (click on the link below to read it all):

I am requesting the full text of NASA cooperative agreement NNH11CD70A between NASA and CASIS including any revisions, annexes, modifications, or associated contractual amendments made by NASA from the inception of this agreement with CASIS until the date of this FOIA request.

I am also requesting all progress and status reports and memos provided by CASIS to NASA from the onset of NASA Cooperative Agreement NNH11CD70A until the date of this FOIA request as well as all correspondence/memos from NASA to CASIS in response to CASIS progress and status reports from the onset of NASA Cooperative Agreement NNH11CD70A until the date of this FOIA request.

According to the 9 September 2011 NASA press release 11-294 "NASA Names CASIS To Manage Space Station National Lab Research" online at "NASA has finalized a cooperative agreement with the Center for the Advancement of Science in Space (CASIS) to manage the portion of the International Space Station that operates as a U.S. national laboratory."

According to the 26 February 2014 Center for the Advancement of Science in Space (CASIS) document "Request for Proposals NO. CASIS 2014-2 Enabling Technology To Support Science in Space For Life On Earth" online at "The Center for the Advancement of Science in Space (CASIS) is an IRC Section 501(c)(3) entity responsible for management of the International Space Station (ISS) U.S. National Laboratory under a Cooperative Agreement with NASA (NNH11CD70A)."

NASA has spent decades designing, building, and operating the International Space Station. This is the largest single project NASA has ever embarked upon. Due to the enormous expense and priority given the ISS how the agency obtains a return on this investment is of importance and interest to NASA, policy makers, and all American taxpayers. NASA will spend $15 million per year until 2020 on CASIS. Recent discussion by the NASA Advisory Council on 31 March 2016 and 1 April 2016 cite concerns with how CASIS is performing its tasks under its cooperative agreement with NASA.

None of the documents requested in this FOIA request have previously been made public. Making these documents publicly available in response to this FOIA request will allow a more thorough analysis of how well CASIS is or is not performing its tasks for NASA. Full and open disclosure of how CASIS is performing its tasks is in the public's best interest. Such disclosure is best done via investigative reporting. This information is being requested as part of an ongoing series on stories by and on NASA and CASIS. The resulting research will be published on and

The materials requested in his FOIA request are already in electronic form and should be within easy reach of the individual(s) at NASA who manage NASA's interactions with CASIS. As such these documents can easily be printed out or forwarded to the address listed on this FOIA request i.e. I am hereby requesting that this documentation be provided at no expense. Also, as noted below, it is highly likely that the NASA Advisory Council will also be requesting this information due to their recent interest in this topic. As such the responsible parties at NASA will already be looking to provide this information. and are online space news publications. has been published online continuously since 1996. has been published online continuously since 1999. and and their associated websites reach an average of over 500,000 unique visitors every month. Their combined social media reach exceeds 350,000 followers. Material published on and is regularly accessed by readers in Congress, The White House, GAO, space and general news reporters, NASA civil service and contractor employees, and NASA personnel on the 9th floor of NASA headquarters. I have been interviewed as a space journalist on every major U.S. television network as well as major international radio and television networks hundreds of times since 1996. I have been accredited as news media by NASA headquarters and NASA field Centers since 2000 per recommendations of the NASA Inspector General's Office and the House Science Committee. What I write is widely read. The material requested in this FOIA request will be similarly read by a wide audience.

Prior articles in this ongoing research by and into NASA and CASIS include:

"CASIS Had A Bad Week In Washington"
"CASIS Is Not The Best Way To Use a Space Station"
"CASIS Still Ignores Commercial Research on ISS"
"NASA and CASIS Chase Old Research Paradigms In Orbit"
"Sometimes NASA Has Technology SpinINs"
"Trying To Understand CASIS Press and Social Media Impact"
"Important Golf in Space Announcement from CASIS"
"Are CASIS Funding "Commitments" Just Smoke and Mirrors?"
"CASIS Has No Idea How To Raise Money - Only How To Spend It"
"Examining Staff and Board Member Salaries at CASIS"

Understanding how CASIS measures its progress, how it reports that progress to NASA, now NASA evaluates that progress, and how NASA directs CASA as a result of this progress is critical to the success of CASIS use of NASA-funded and provided resources. However CASIS has not met these basic requirements. According to NASA OIG report IG-13-019 ( 8 July 2013, page 20:

"FY 2013 Performance Metrics Are Not Clearly Defined. CASIS's general goals for FY 2013 are to award research grants from funds raised through donations and approve more self-funded investigations for the Station. CASIS's FY 2013 Program Plan states that it will work to better position individuals, educators, and corporations to conduct research on the ISS by leveraging its own growing network of experienced researchers, companies, and other potential users. While these goals are positive first steps toward developing a market for non-NASA research aboard the ISS, CASIS and NASA have yet to create specific, quantifiable metrics to measure CASIS's ability to meet these goals. NASA officials told us that establishing specific metrics were postponed until the fourth quarter of FY 2013 because CASIS's new Board of Directors wanted additional time to familiarize themselves with the organization before agreeing to such metrics. As a result, less than 3 months before NASA is scheduled to assess CASIS's performance for FY 2013 the metrics for each of the organization's goals is listed as "to be determined." Until NASA and CASIS establish precise metrics that reflect the degree to which CASIS is increasing non-NASA research on the ISS, it will be difficult to determine if CASIS is meeting the objectives of its agreement with NASA."

GAO concurs that CASIS has had ongoing issues with establishing metrics and reporting results to NASA. Moreover since the 2013 NASA OIG report the process whereby CASIS reports to NASA - and the process specified by NASA whereby CASIS reports - continues to have been ad hoc, inconsistent, and incomplete. According to "ISS: Measurable Performance Targets and Documentation Needed to Better Assess Management of National Laboratory" ( GAO-15-397, 27 April 2015:

"NASA performs an annual assessment of CASIS's performance consistent with its responsibilities in the cooperative agreement, but this assessment is not documented.15 The Cooperative Agreement Technical Officer (CATO) uses the metrics in CASIS's quarterly and annual reports to monitor CASIS's efforts. CASIS to propose an adjustment to the metrics if performance is not going to be met. However, without performance targets, CASIS cannot determine whether the metrics need to be adjusted. Further, without these targets, NASA and CASIS cannot conduct assessments that are measurable or conclusive and, therefore, the assessments are subjective. According to the CATO, during the annual program review, he assesses CASIS metrics for trends, looking for improvements over time and questioning any perceived lack of progress. The CATO added that he discusses any issues identified during the annual review with CASIS officials, NASA management, and stakeholders. CASIS officials concurred, and told us this discussion with NASA highlights areas for further refinement. For example, as a result of such discussion, CASIS is now more proactively engaging NASA technical expertise on available flight hardware, and has broadened business development efforts aimed at attracting new commercial users of the ISS National Laboratory. Both CASIS and NASA officials told us that NASA does not document its annual program review of CASIS performance. Federal standards for internal controls call for information to be recorded and communicated to management and others who need it to carry out their responsibilities. This type of documented information is important to support decision making and conduct assessments. CASIS officials have not asked for a formal summary of the results of NASA's annual program review because CASIS receives informal feedback on quarterly reports provided to NASA. CASIS also maintains minutes of regularly scheduled meetings with NASA where any issues that need to be discussed between CASIS and NASA are addressed. While NASA does not document this annual assessment, NASA officials told us that they were generally satisfied with CASIS performance. CASIS officials, however, said that the results of the annual review should be reported in some sort of formal manner to make the information more actionable. Because CASIS is allocated at least 50 percent of ISS research capacity, future success of the ISS as a research platform is partially dependent on the efforts CASIS has undertaken. However, without definitive and documented assessment factors, NASA will be challenged to take action in response to CASIS performance. For example, without documentation, NASA lacks support to terminate the cooperative agreement, if deemed necessary. Conversely, NASA also would have no record to justify extending the cooperative agreement to support a possible ISS life extension. The cooperative agreement will expire at the end of fiscal year 2020, but includes a provision for an extension."

The NASA Advisory Council was given a presentation by CASIS on 31 March 2016: According to "CASIS Had A Bad Week In Washington" ( published on 1 April 2016:

"... the NAC moved on to consider a second draft recommendation that dealt with examining how CASIS operates - especially how it set priorities, makes decisions, and measures results. This is the draft recommendation under consideration: "Recommendation: NASA should initiate a study by a qualified industrial development organization to inform CASIS of best practices in the development of new industries. Major Reasons for Proposing the Recommendation: The commercial development of Low Earth Orbit space is an integral part of NASA's vision. The CASIS organization has been developed to, among other goals, facilitate the development of commerce in Low Earth Orbit. During the CASIS presentation to the Council, it was not apparent that the goals of the organization are being effectively prosecuted. The Council believes that CASIS could be more effective if it were to receive the best advice possible from organizations which have been successful in related activities. Consequences of No Action on the Proposed Recommendation: The development of low cost facilities and transportation for NASA use in LEO may not be available in a timely manner to support the needs of NASA's Mars exploration activity." Some of the NAC membership felt that this recommendation was being a bit too proscriptive and that it should be watered down or not issued. Many more NAC members supported a firm stance on this issue. Given that there is a shrinking window whereby the ISS will be operation NAC members felt that it was important to review the situation and, if need be, make recommendations to NASA how to adjust things with CASIS."

As such it is abundantly clear that the manner with which CASIS conducts activities under its cooperative agreement with NASA is of importance to NASA and to the public as a whole. This topic is of intrinsic newsworthy value.

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This page contains a single entry by Keith Cowing published on April 5, 2016 11:17 AM.

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