Audit Report

OIG-16-047

Treasury’s Government-wide DATA Act Implementation 

Continues, But Project Management Concerns Remain

June 22, 2016

Office of

Inspector General

Department of the Treasury

Contents

Treasury’s Government-wide DATA Act Implementation Continues,

But Project Management Concerns Remain (OIG-16-047)

Page i 

Audit Report

 

Results in Brief .............................................................................................. 2 

Background................................................................................................... 4 

 

Audit Results................................................................................................. 12

Progress in Implementing the DATA Act Continues But Key Products Are 

Delayed ............................................................................................... 12

All Federal Agencies Covered Under the DATA Act Need to Be Identified ......... 18

A Human Resource Plan Should Be Developed .............................................. 19

Stakeholder Questions Need to Be Addressed............................................... 21

Project Management Documentation Needs to Be Improved ........................... 22

Recommendations .......................................................................................... 24

Appendices

Appendix 1: Objectives, Scope, and Methodology .................................... 29

Appendix 2: Prior OIG DATA Act Recommendations and Status of Related 

Corrective Actions ............................................................. 33

Appendix 3: Management Response ....................................................... 34

Appendix 4: Major Contributors to this Report.......................................... 37

Appendix 5: Report Distribution.............................................................. 38

Abbreviations

CIGIE Council of Inspectors General for Integrity and Efficiency

DATA Act Digital Accountability and Transparency Act of 2014

ESC Executive Steering Committee

FFATA Federal Funding Accountability and Transparency Act of 2006

Fiscal Service Bureau of the Fiscal Service

GAO Government Accountability Office

IAC Interagency Advisory Committee

IG Inspector General

JAMES Joint Audit Management Enterprise System

OMB Office of Management and Budget

PMBOK Project Management Body of Knowledge

PMO Program Management Office

Recovery Act American Recovery and Reinvestment Act of 2009

 Recovery Board Recovery Accountability and Transparency Board

SAO Senior Accountable Official

Treasury Department of the Treasury
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This Page Intentionally Left Blank. 
OIG Audit

Report

The Department of the Treasury

Office of Inspector General

Treasury’s Government-wide DATA Act Implementation Continues, Page 1 

But Project Management Concerns Remain (OIG-16-047)

June 22, 2016 

David A. Lebryk

Fiscal Assistant Secretary

This report presents the results of our second audit in a series1

reviewing the Department of the Treasury (Treasury) efforts to 

meet its responsibilities under the Digital Accountability and 

Transparency Act of 2014 (DATA Act).

2 Our audit objectives were

to determine the sufficiency of plans and actions taken by Treasury 

and its Bureau of the Fiscal Service (Fiscal Service) to timely 

comply with DATA Act provisions to (1) establish Governmentwide financial data standards for Federal funds made available to or 

expended by Federal agencies and entities receiving Federal funds; 

(2) ensure that this financial data is accurately posted and 

displayed on USAspending.gov (or a successor system) by May 

2017; and (3) ensure the established data standards are applied to 

the data made available on the website by May 2018. 

To accomplish our objectives, we obtained an understanding of the 

current laws related to Treasury’s Government-wide responsibilities 

under the DATA Act and conducted interviews with Treasury 

personnel involved with the agency’s Government-wide 

implementation of the DATA Act. We reviewed recognized project 

management guidance;

3 Treasury and the Office of Management 

and Budget (OMB) DATA Act project management plans;

4 and 

other relevant documents, such as the President’s Fiscal Year 2016 

 

1

 On May 19, 2015, we issued our first audit report on Treasury’s efforts to meet its responsibilities 

under the DATA Act: OIG-15-034, Treasury Is Making Progress in Implementing the DATA Act But 

Needs Stronger Project Management. 2

 Public Law 113-101 (May 9, 2014). 3

 Our review included the Project Management Institute’s A Guide to the Project Management Body of 

Knowledge (PMBOK), Fourth Edition, 2008, a recognized industry standard. PMBOK defines a good 

practice as one where there is general agreement that the application of these skills, tools, and 

techniques can enhance the chances of success over a wide range of projects. We also reviewed the 

Government Accountability Office’s July 2012 report, Software Development Effective Practices and 

Federal Challenges in Applying Agile Methods (GAO-12-681), which describes good practices in 

applying agile methods for project management. 4

 The DATA Act designates Treasury and OMB to lead the implementation effort.
Treasury’s Government-wide DATA Act Implementation Continues, Page 2 

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budget request. We also determined Treasury and OMB’s DATA 

Act implementation status by reviewing progress-tracking metrics. 

We conducted our fieldwork principally from March through

November 2015. Appendix 1 contains a detailed description of our 

objectives, scope, and methodology. Appendix 2 provides the 

status of OIG recommendations and related corrective actions on 

our prior audit of Treasury’s Government-wide DATA Act 

implementation efforts.

Results in Brief

As of October 31, 2015, Treasury continued to make progress in 

implementing the DATA Act. However, we remain concerned that

Treasury’s project management practices could, if not addressed, 

hinder the timely, comprehensive, Government-wide 

implementation of the program. Subsequent to completion of our 

fieldwork, we noted that Treasury missed a project plan deadline

for finalizing critical agency guidance. As a result, timely 

completion of the system needed to submit agency spending data 

is at risk. 

Treasury and OMB engaged stakeholders on the implementation, 

issued guidance on DATA Act reporting requirements, identified the 

data elements requiring standardization, and published those 

standards. Treasury also published informational resources to help 

agencies develop their own implementation approach and Treasury 

began developing tools that agencies can use to submit and display 

data.

While these activities will assist in facilitating adoption of uniform 

standards by Federal agencies, we identified several risks to 

implementing the DATA Act on time: 

• Finalizing the standard data exchange, called the DATA Act 

Schema version 1.0, was delayed. Treasury originally 

planned to issue the Schema in December 2015; however, 

progress-tracking metrics showed the release of the Schema 

was ”at risk.” As of February 29, 2016 the Schema version 

1.0 has not been issued. A Treasury official told us that the 

issuance of the guidance was dependent on reaching a final 

policy decision on the reporting architecture, which was 
Treasury’s Government-wide DATA Act Implementation Continues, Page 3 

But Project Management Concerns Remain (OIG-16-047)

delayed but has now been resolved. The Schema version 1.0 

was issued on April 29, 2016. 

• Treasury’s production-ready broker5 and related

documentation for agencies are delayed. Treasury’s DATA

Act Implementation Playbook established February 2016 as

the Government-wide rollout date for the broker. However,

January 2016 progress-tracking metrics showed that this

date is “behind.” As of February 29, 2016, the productionready broker had not been issued. In April 2016, Treasury

released the alpha version of the production broker and

anticipates releasing the production-ready broker in Fall

2016.6

• Treasury and OMB cannot be sure that all Federal agencies

submitted DATA Act implementation plans as required by

OMB because Treasury and OMB have not determined the

entire population of agencies to which the DATA Act

applies.

• Treasury has not developed a human resource plan to define

the staffing needed to accomplish its strategic goal of

making financial management data accessible and reusable.

• Treasury and OMB lack controls to ensure prompt responses

to Federal agency DATA Act questions.

• Treasury has not ensured the accuracy of basic progress

metric reporting nor has it formally documented key

management decisions.

We are recommending that Treasury, working as needed with 

OMB: (1) finalize and release the production-ready broker to Federal 

agencies in an expeditious manner; (2) determine the population of 

Federal agencies required to comply with the DATA Act, and 

ensure that a Senior Accountable Official (SAO)7 has been 

5

 A broker is an information system that collects, maps, takes in, transforms, validates, and submits 

agency data into a format consistent with the proposed taxonomy. 

6

 The alpha release is a version of the production-ready broker that allows Treasury to test their 

product with a small group of actual users to, in part, (1) test the design approach, (2) test some 

technologies, and (3) allow users to gain some understanding of the service. 7

 An SAO is a high-level senior official who is accountable for the quality and objectivity of Federal 

spending information. 
Treasury’s Government-wide DATA Act Implementation Continues, Page 4 

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identified and a DATA Act implementation plan has been submitted 

to OMB for each agency in the population; (3) develop a 

comprehensive, documented human resource plan for Treasury’s 

DATA Act implementation efforts; (4) clear the backlog of 

unaddressed DATA Act stakeholder questions and develop 

standard operating procedures to ensure that stakeholder questions 

and feedback are accounted for and addressed in a timely manner; 

and (5) continue efforts to strengthen project management over the 

DATA Act implementation, ensuring that (a) progress metrics 

provide a consistent, accurate measure of task status and (b) key 

management decisions are documented. 

In a written response, Treasury management agreed with our

recommendations and outlined its corrective actions. The response 

described management’s (1) plan for the roll out of the productionready broker; (2) recently issued guidance to help Federal agencies

determine whether they are required to comply with the DATA Act; 

(3) development of a human resource plan for Treasury’s Program

Management Office (PMO); (4) policies and procedures to triage

stakeholder questions and set a goal to answer these questions in 

as timely a manner as possible; and (5) commitment to continue to 

improve project management documentation.

Overall, we found that management’s response meets the intent of 

our recommendations. However, management will need to record 

target dates for planned corrective actions in the Joint Audit 

Management Enterprise System (JAMES), Treasury’s audit 

recommendation tracking system. We have incorporated and 

evaluated management’s response in the recommendation sections 

of this report. Management’s response is provided as Appendix 3.

Background 

Signed into law May 9, 2014, the DATA Act has several purposes: 

(1) Expand the Federal Funding Accountability and Transparency 

Act of 2006 (FFATA)8 by disclosing direct Federal agency 

expenditures and linking Federal contract, loan, and grant 

spending information to programs of Federal agencies to 

8

 Public Law 109-282 (September 26, 2006).
Treasury’s Government-wide DATA Act Implementation Continues, Page 5 

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enable taxpayers and policymakers to track Federal spending 

more effectively. 

(2) Establish Government-wide data standards for financial data 

and provide consistent, reliable, and searchable Governmentwide spending data that is displayed accurately for taxpayers 

and policymakers on USAspending.gov (or a successor 

system that displays the data). 

(3) Simplify reporting for entities receiving Federal funds by 

streamlining reporting requirements and reducing compliance 

costs while improving transparency. 

(4) Improve the quality of data submitted to USAspending.gov 

by holding Federal agencies accountable for the 

completeness and accuracy of the data submitted. 

(5) Apply approaches developed by the Recovery Accountability 

and Transparency Board (Recovery Board)9 to spending 

across the Federal government.

To fulfill these purposes, the DATA Act imposes requirements on 

the Director of OMB, the Secretary of the Treasury, the Inspector 

General (IG) of each Federal agency, and the Comptroller General 

of the United States. 

Specifically, the DATA Act requires that (1) OMB and Treasury 

establish, by May 2015, Government-wide financial data standards 

for Federal funds made available to or expended by Federal 

agencies and entities receiving Federal funds; (2) Treasury, in 

consultation with OMB, ensure such financial data is accurately 

posted and displayed on USAspending.gov (or a successor system) 

by May 2017; and (3) OMB and Treasury ensure the data 

standards established are applied to the data made available on the 

website by May 2018.

The DATA Act requires the IG of each Federal agency to perform 

three reviews of a statistically valid sampling of the spending data 

submitted under the DATA Act by the Federal agency, and submit 

to Congress and make publically available a report assessing the 

 

9

 The Recovery Board was a Federal agency that oversaw spending under the American Recovery and 

Reinvestment Act of 2009 (Recovery Act) and managed Recovery.gov. Recovery.gov displayed 

Recovery Act spending information reported by recipient agencies. Pursuant to law, the Recovery 

Board ceased operations in September 2015.
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completeness, timeliness, quality, and accuracy of the data 

sampled and the implementation and use of data standards by the 

Federal agency. Under the Act, the first IG reports are due 

November 2016 with the other two following at 2-year intervals

(November 2018 and November 2020).

10 The DATA Act also 

requires the Comptroller General of the United States to submit to 

Congress reports assessing data completeness, timeliness, quality, 

and accuracy in November 2017, November 2019, and November 

2021. 

Under the DATA Act, Sec. 6(c), Treasury may also establish a data 

analysis center, or expand an existing service, to provide data 

analytic tools and data management techniques to support the 

prevention and reduction of improper payments by Federal agencies 

and improve efficiency and transparency in Federal spending. If 

elected, all assets identified by Treasury that support the 

operations and activities of the Recovery Board’s Recovery 

Operations Center11 relating to the detection of waste, fraud, and 

abuse in the use of Federal funds were to transfer to Treasury on 

or before September 30, 2015, the date the Recovery Board 

ceased operations. According to a July 21, 2015 memorandum 

from the Commissioner of Treasury’s Fiscal Service to the Fiscal 

Assistant Secretary, Treasury decided not to exercise its 

discretionary authority under Sec. 6(c). 

For a timeline of Treasury’s DATA Act requirements, authorities, 

and deadlines, see Figure 1.

 

10 The Council of the Inspectors General on Integrity and Efficiency (CIGIE) identified a timing anomaly 

with the oversight requirements contained in the DATA Act. That is, the first IG reports are due to 

Congress in November 2016; however, Federal agencies are not required to report financial and 

payment information in accordance with the data standards established under the DATA Act until 

May 2017. To address this reporting date anomaly, the IGs plan to provide Congress with their first 

required reports in November 2017, a 1-year delay from the statutory due date, with subsequent 

reports following on a 2-year cycle. Although CIGIE determined the best course of action was to 

delay the IG reports, CIGIE is encouraging IGs to undertake DATA Act “Readiness Reviews” at their 

respective agencies well in advance of the first November 2017 report. On December 22, 2015, 

CIGIE’s chair issued a letter memorializing the strategy for dealing with the IG reporting date anomaly 

and communicated it to the Senate Committee on Homeland Security and Government Affairs and 

the House Committee on Oversight and Government Reform. 11 The Recovery Board launched the Recovery Operations Center in November 2009 to provide a 

central data analytics service to support fraud detection and prevention related to Recovery Act 

awards. 
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Figure 1: Progress on Treasury DATA Act Requirements, Authorities, and Deadlines

May 

2014

May 

2015

Sept 

2015

May 

2017

May 

2018

Source: Treasury Office of Inspector General analysis of DATA Act requirements. 

DATA Act Governance Structure

An Executive Steering Committee (ESC), made up of Treasury’s 

Fiscal Assistant Secretary and OMB’s Controller, governs Treasury

and OMB DATA Act implementation efforts. Supported by an 

Interagency Advisory Committee (IAC), the ESC sets overall policy 

and guidance, oversees recommendations, and makes and enforces

decisions, as necessary. The ESC meets biweekly to monitor the 

implementation progress at a high level, discuss implementation 

and policy questions, and resolve issues as they arise. 

DATA Act 

signed into 

law 

OMB and Treasury: 

Establish Governmentwide financial data 

standards and issue 

guidance

Status: OMB and 

Treasury met this 

requirement. 

Treasury: Upon exercise of 

discretionary authority, 

establish a data analysis 

center, ensuring all assets 

that support the 

operations and activities of 

the Recovery Operations 

Center are transferred to 

Treasury

Status: Treasury elected 

not to take these actions.

Treasury, in consultation 

with OMB: Post financial 

data on 

USAspending.gov or a 

successor system

Treasury and OMB: Ensure 

standards are applied to 

Federal award data on 

USAspending.gov or a 

successor system
Treasury’s Government-wide DATA Act Implementation Continues, Page 8 

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The IAC provides recommendations to the ESC related to DATA 

Act implementation and leadership in obtaining stakeholder buy-in 

on recommendations. Its representatives include: 

• Budget Officers Advisory Council

• Chief Financial Officers Council

• Award Committee for E-Government

• Chief Information Officers Council

• Performance Improvement Council

• Chief Acquisition Officers Council

• Council on Financial Assistance Reform

• Office of Science and Technology Policy 

• General Services Administration

• OMB

• Treasury

• Several members of the IG community 

DATA Act Implementation Approach 

Treasury is using an agile approach12 to implement the 

requirements of the DATA Act, explained in its “White Paper: 

Implementing the Data Act” (Draft White Paper). This approach, 

typically used in software development, involves collaboration 

across public and private stakeholders, including the Federal 

community and is characterized by the execution of quick, smallscale pilots to test innovative concepts and strategies for 

implementation. Because some aspects of the implementation do 

not fit this approach, Treasury officials have been using a mix of 

agile and traditional project management practices.13 

Treasury proposed a “data-centric” technical approach rather than 

a “system-centric” solution that would collect, aggregate, and 

validate the format of data from agencies in a bulk file or central 

system. The data-centric approach focuses on managing existing 

data and seeks to avoid massive system changes across Federal 

agencies. Instead of requiring agencies to change existing 

 

12 Agile is a project management methodology that values individuals and interactions over processes 

and tools, working software over comprehensive documentation, customer collaboration over 

contract negotiation, and responding to change over following a plan. 13 Traditional project management methodology generally follows a step-by-step approach, moving the 

project through five stages: initiation, planning, execution, monitoring, and completion. Each stage is 

performed in chronological order, with one stage beginning after the preceding stage is complete.
Treasury’s Government-wide DATA Act Implementation Continues, Page 9 

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processes or system terms, the data-centric approach calls for 

agencies to map data from their existing systems to a standard 

taxonomy.14 Treasury anticipates that, once the data is mapped in

agency-specified data warehouses, financial systems, and/or mixed 

feeder systems15, the data will be submitted into a virtual 

repository maintained by Treasury. The data-centric approach is 

intended to minimize system changes and provide the necessary 

standards and format to enable users to query data across the 

government. 

DATA Act Implementation Structure

To execute the implementation plan envisioned in the Draft White 

Paper, Treasury and OMB created a four-part implementation 

structure shown in Figure 2 and described in detail below.

 

14 Taxonomy is a systematic classification of data elements that allows it to be shared and reused in 

different systems. 15 A mixed-feeder information system can support both financial and non-financial functions. Such 

systems may include those designed for property management, inventory, budget formulation, 

acquisition, and personnel and payroll.
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Figure 2: OMB and Treasury Governance and Implementation

Structure

Source: Fiscal Service

• Lead 

The DATA Act designates Treasury and OMB as leads for

the implementation effort, responsible for developing and 

guiding the implementation approach and strategy, 

coordinating and developing policies, providing program 

management functions, and conducting public and private

stakeholder outreach. 

• Design and Implement

Most of the hands-on implementation work occurs in this 

part, divided across five high-level workstreams based on the 

requirements of the DATA Act: (1) Data Definition 

Standards, (2) Blueprint/Roadmap between Data Elements, 

PMO Treasury, Program Management Office

OFFM

OFPP

BRD

RMO

EOP-OSTP

NSC

OMB, Office of Federal Financial Management

OMB, Office of Federal Procurement Policy

OMB, Budget Review Division

OMB, Resource Management Office

Executive Office of the President, Office of Science 

and Technology Policy

National Security Council
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(3) Data Exchange Standards, (4) Pilot to Reduce 

Administrative Reporting Burden,

16 and (5) Data Analytics.17

• Support

SAOs from Federal agencies are responsible for providing 

high-level feedback on the DATA Act implementation and 

workstream outputs, as directed by Treasury and OMB. 

• Consult 

The DATA Act requires Treasury and OMB to consult with 

public and private stakeholders to establish data standards 

and incorporate widely accepted common data elements, 

such as those developed and maintained by international 

standard-setting bodies and accounting standards 

organizations. Internal stakeholders include Federal 

departments and agencies and Federal councils, groups, and 

boards. External stakeholders include state, local, and tribal

governments; citizens; private industry; transparency 

advocacy groups; and academia. 

Agency Role

Federal agencies must work with Treasury and OMB to execute 

implementation within their agencies. This includes inventorying 

required data elements in existing systems, identifying gaps, and 

making system changes, as needed, to address these gaps; 

implementing established data standards; and implementing 

mechanisms needed to establish links between the data elements

and to submit the required data to Treasury.

 

16 OMB is solely responsible for this DATA Act requirement. Since Treasury IG does not oversee OMB, 

we did not evaluate the status of the Pilot to Reduce Administration Reporting Burden. 17 The focus of this workstream was on making a determination regarding the assets of the Recovery 

Operations Center. As mentioned previously in this report, Treasury elected not to exercise its 

discretionary authority under DATA Act, Sec. 6(c). Therefore, the Recovery Operations Center assets 

reference in Sec. 6(c) did not transfer to Treasury.
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Audit Results 

Finding 1 Progress in Implementing the DATA Act Continues But 

Key Products Are Delayed

Treasury, working together with OMB, continued to make progress 

with its Government-wide DATA Act implementation efforts. 

Treasury and OMB have engaged stakeholders on the 

implementation, issued guidance on DATA Act reporting 

requirements, identified the data elements requiring 

standardization, and rolled out those standards. Treasury published 

informational resources to help agencies develop their own 

implementation approaches and has begun developing tools that 

agencies can use to submit and display data. However, we noted 

that the release of certain key tools, the DATA Act Schema version 

1.0 and the production-ready broker, have been delayed. 

Guidance

On May 8, 2015, OMB issued guidance (OMB M-15-12, Increasing 

Transparency of Federal Spending by Making Federal Spending 

Data Accessible, Searchable, and Reliable) for Federal agencies on 

implementing Government-wide financial data standards required 

by the DATA Act and on their ongoing reporting responsibilities for 

USAspending.gov. In addition to requiring that agencies maintain 

current transparency reporting procedures for USAspending.gov, 

the guidance required Federal agencies to (1) make agency-level 

financial data available for publication, (2) implement data definition 

standards, (3) implement data exchange standards, and (4) ensure 

data quality and future reporting capabilities remain consistent with 

DATA Act implementation efforts. 

OMB M-15-12 also requires agencies to develop DATA Act 

implementation plans that (1) identify an SAO, (2) estimate 

resource requirements, (3) propose an implementation timeline, and

(4) identify foreseeable challenges and resolutions. Additionally, 

Federal shared service providers should include specific information 

about anticipated costs and timelines necessary to implement the 

memorandum. Treasury’s “DATA Act Implementation Playbook,” 

issued concurrently with OMB M-15-12, referenced a due date of 

September 2015, for Federal agencies to submit DATA Act

implementation plans to OMB. Treasury and OMB officials told us 
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that although most Federal agencies submitted agency DATA Act 

implementation plans by the due date, some did not. We noted that 

Treasury could not provide us with an inventory of agencies with 

outstanding implementation plans because they, along with OMB,

have not determined the population of agencies to which the DATA 

Act applies. This issue is discussed in greater detail in Finding 2 of 

this report.

Data Standards: Data Elements

The DATA Act requires the establishment of Government-wide 

financial data standards for Federal funds made available to or 

expended by Federal agencies and entities receiving Federal funds. 

Under FFATA, Federal agencies reported 259 data elements to

USAspending.gov. Subsequent to the enactment of the DATA Act, 

Treasury and OMB identified 57 data elements that required 

standardization, including 8 new data elements required by the 

DATA Act and 49 existing elements that OMB deemed 

controversial in nature and requiring standardization. However, 

Treasury was unable to provide us with documentation supporting 

how it was determined that only 49 of the existing 259 elements

required standardization. Once identified, Treasury and OMB 

undertook a process to engage public and private stakeholders and 

solicit public input to standardize these 57 data elements

Treasury and OMB released final data standards for the 57 data 

elements in phases during May–August 2015: 

• 15 on May 8

• 8 on June 26

• 4 on July 13

• 30 on August 31

As discussed in a January 2016 report on these data standards, 

the Government Accountability Office (GAO) found that most 

definitions adhered to leading practices derived from international 

standards for formulating data definitions.18 In this regard, 12 of 

the 57 definitions met all 13 leading practices and none met fewer 

than 9. However, GAO found several definitions that could lead to 

inconsistent reporting. For example, the “Primary Place of 

 

18 GAO, DATA Act: Data Standards Established, but More Complete and Timely Guidance Is Needed to 

Ensure Effective Implementation (GAO-16-261; issued January 29, 2016)
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Performance” definitions’ inclusion of the word “predominant“

leaves much open to interpretation. According to the GAO report, 

without more interpretive clarification, agencies run the risk of 

reporting data that cannot be aggregated Government-wide. 

Moving forward, Treasury and OMB plan to consider additional 

data elements for standardization based on feedback received from 

stakeholders. 

Data Standards: DATA Act Schema

As part of establishing Government-wide financial data standards, 

Treasury and OMB continued working to define the data exchange

standard to be used for DATA Act reporting. This standard, called 

the DATA Act Schema, will prescribe relationships between 

elements, as well as format and data reporting validation 

requirements for transmitting these elements between agencies and 

displaying the data to the public. The Schema is expected to 

leverage industry standards to structure financial and non-financial 

data with metadata (supplemental information) that describes, 

explains, locates, or otherwise makes it easier to retrieve and 

understand the data. 

In May 2015, Treasury and OMB released the draft DATA Act

Schema version 0.2, and have since released updated versions 

periodically. As of December 2015, draft version 0.7 was available

on the Federal Spending Transparency GitHub site.19 This version 

was intended to provide a comprehensive DATA Act Information 

Model Schema to represent all spending and related information 

anticipated, required, or available to support the additional Federal 

spending information required by the DATA Act. However, version 

0.7 did not include agency submission specifications regarding the 

file format, content scope, and file organization. Treasury had 

planned to issue the Schema version 1.0, which would include 

such detail, in December 2015. A Treasury official stated that the 

issuance of Schema version 1.0 was dependent on reaching a 

policy decision on the reporting architecture which was delayed. In 

the interim, Treasury continued to develop and iteratively release 

 

19 GitHub is a web-based, open-source collaboration tool based on the Git version control software, 

which allows users to make and track changes for software development projects. Treasury and 

OMB’s Federal Spending Transparency GitHub site is located at 

https://fedspendingtransparency.github.io/. 
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operational guidance to agencies as they implement the DATA Act. 

The DATA Act Schema version 1.0 was issued on April 29, 2016, 

subsequent to our fieldwork. Since the Schema version 1.0 is an 

essential roadmap for agencies to structure their data for 

submission to USAspending.gov, its delayed issuance could 

increase the risk that agencies cannot comply timely with the 

DATA Act.

DATA Act Implementation Playbook

On May 8, 2015, Treasury released the DATA Act Implementation 

Playbook. This Playbook describes eight key steps that, if followed 

together, should help agencies leverage existing capabilities to 

drive implementation of the DATA Act. Figure 3 depicts the eight 

steps. 

Figure 3: Agency 8-Step Plan

Source: DATA Act Implementation Playbook

 
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DATA Act Blueprint Guide

In March 2015, Treasury released the DATA Act Blueprint Guide. 

The guide contains models for major processes such as contracts, 

grants, loans, and finance. It is intended to assist agencies as they 

identify where data elements are reported, authoritative sources for 

the elements, and linkages and gaps between financial and 

management award systems.

Treasury’s DATA Act Pilots 

To test innovative concepts and strategies for implementation, 

Treasury deployed the Data Portal Pilot and DATA Act 

Implementation Pilot. The Data Portal Pilot is a beta website20 that 

visualizes and publishes financial management data in accordance 

with the DATA Act. The DATA Act Implementation Pilot is a proofof-concept21 effort designed to develop a data taxonomy necessary 

to map and reconcile agency management system data with 

agency financial system data. 

Treasury’s DATA Act Implementation Pilot, in part, is intended to 

inform Treasury’s perspectives on building a prototype broker and 

documentation that can be used by other agencies as a tool for

implementing the DATA Act requirements. In April 2015, while 

working with the General Services Administration’s 18F,

22 Treasury 

deployed this pilot using the Small Business Administration’s fiscal 

year 2014 grants data. Treasury and 18F use GitHub as a 

repository to upload DATA Act files from agencies, validate the 

data, and convert it to uniform data. In December 2015, Treasury 

began using a testing environment, called a “sandbox,” for Federal 

agencies to voluntarily test their data files using the prototype 

broker. The purpose of sandbox testing is to help agency’s further 

their implementation plans, gain an understanding regarding how 

the agency data submission process might work, and obtain early 

feedback from agencies. 

Treasury’s DATA Act Implementation Playbook established 

February 2016 as the rollout date for the broker. However, January 

 

20 A beta website is one that a target audience can use to test working software. Changes are 

implemented based on user behavior and feedback. 21 A proof-of-concept effort evaluates whether a business idea works. 22 18F is a team of system designers, developers, and product specialists inside the General Services 

Administration that serves as a civic consultancy for the government.
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2016 progress-tracking metrics showed this date is “behind.” As of 

February 29, 2016, the production-ready broker has not been 

issued. In April 2016, Treasury released the alpha version of the

production broker and anticipates releasing the production-ready

broker in Fall 2016. 

In November 2015, Treasury launched OpenBeta.USAspending.gov 

the future USAspending.gov site. The OpenBeta website provides 

an opportunity for the public to review, test, and provide feedback 

on data displayed and to search functionality components that will 

guide Treasury’s efforts to support the needs of data users. Over 

the next 2 years, Treasury plans to add new features and 

functionalities for the public to review on a rolling basis. While the 

OpenBeta site is available for public input, USAspending.gov will 

continue to be the official source for Federal spending data.23

DATA Act Stakeholder Outreach 

A critical component to implementing the DATA Act is the ability 

to conduct outreach to key public and private stakeholders. In fact, 

the DATA Act requires Treasury and OMB to consult with 

stakeholders in establishing data standards. Currently, Treasury and 

OMB engage and collect input from stakeholders and keep them 

informed about DATA Act requirements and resources through (1) 

monitoring agency implementation efforts through open source 

collaboration tools, such as Max.gov and GitHub; (2) publishing a 

“DATA Act Biweekly Digest” to keep SAOs and agency staff 

updated on recent and upcoming DATA Act activities and new 

developments; and (3) participating in transparency advocacy 

groups meetings and hosting a number of stakeholder outreach 

efforts, including agency implementation workshops and a weekly 

DATA Act “Office Hour.” The DATA Act Office Hour conference 

line provides an opportunity for agencies to share feedback on the 

implementation procession, seek answers to implementation issues, 

and raise Treasury and OMB’s awareness of challenges facing 

agencies.

23 In February 2014, OMB designated Fiscal Service as the agency responsible for operating and 

supporting USASpending.gov. Upon assuming this responsibility, Fiscal Service developed and 

executed a strategy to refresh USAspending.gov. In a 2015 audit report, we found that Fiscal 

Service needed to better manage user expectations because of continuing concerns with the quality 

of data presented on the website. DATA Act: USASpending.gov Refreshed, But Data Quality Issues 

Remain (OIG-16-023; issued December 23, 2015) 
Treasury’s Government-wide DATA Act Implementation Continues, Page 18 

But Project Management Concerns Remain (OIG-16-047)

Finding 2 All Federal Agencies Covered Under the DATA Act Need 

to Be Identified

The DATA Act requires Treasury, in consultation with OMB, to 

ensure the posting of information on USAspending.gov (or 

successor system), of any funds made available to, or expended 

by, a Federal agency or component of a Federal agency by May 

2017. The term “Federal agency” under FFATA, as amended by 

the DATA Act, has the meaning given the term “Executive 

agency,” under 5 USC 105. This means that the DATA Act applies 

to each Executive Department,24 Government corporation,

25 and 

each independent establishment in the executive branch (other than 

the United States Postal Service or the Postal Regulatory 

Commission) and the Government Accountability Office.

26

Additionally, the DATA Act requires Treasury and OMB to ensure 

that the data standards established are applied to the data made 

available on USAspending.gov (or a successor system) by May 

2018. As mentioned previously, OMB M-15-12 requires Federal 

agencies to develop DATA Act implementation plans that (1) 

identify an SAO, (2) estimate resource requirements, (3) propose 

an implementation timeline, and (4) identify foreseeable challenges 

and resolutions. Additionally, Federal shared service providers 

should include specific information about anticipated costs and 

timelines necessary to implement the memorandum. The DATA Act 

Implementation Playbook referenced OMB’s September 2015

deadline for agencies to submit these implementation plans to 

OMB. 

Treasury and OMB officials have told us that although most Federal 

agencies submitted agency implementation plans by the due date, 

some did not. Treasury, however, could not provide us with an 

inventory of agencies with implementation plans outstanding 

because they, along with OMB, have not determined the complete 

population of agencies to which the DATA Act applies.

 

24 According to 5 USC 101, the Executive Departments are the Departments of State, the Treasury, 

Defense, Justice, the Interior, Agriculture, Commerce, Labor, Health and Human Services, Housing 

and Urban Development, Transportation, Energy, Education, Veterans Affairs, and Homeland 

Security. 25 According to 5 USC 103, Government Corporation means a corporation owned or controlled by the 

Government of the United States. A “Government controlled corporation” does not include a 

corporation owned by the Government of the United States. 26 5 USC 104
Treasury’s Government-wide DATA Act Implementation Continues, Page 19 

But Project Management Concerns Remain (OIG-16-047)

Some agencies that have not submitted plans may, in fact, be 

exempt from compliance, but others may simply lack DATA Act 

awareness or may have incorrectly determined that the DATA Act 

was not applicable. A Treasury official told us that Treasury and 

OMB are working to research the issue and plan to develop 

guidance to assist agencies as they determine if they are required 

to comply with the DATA Act. Treasury will also continue to 

explore options to engage in agency outreach to help ensure 

Federal agencies are aware of their responsibilities to comply with 

the Act.

Additionally, Treasury’s listing of SAOs serving as the DATA Act 

point of contact is incomplete, with most gaps occurring among 

smaller Federal agencies. This may hamper the ability of Treasury 

and OMB to communicate with agencies, especially smaller ones, 

to facilitate compliance. Treasury officials told us that OMB plans 

to identify these points of contact in conjunction with their efforts 

to facilitate agency compliance with the DATA Act. 

Finding 3 A Human Resource Plan Should Be Developed

Treasury’s Government-wide DATA Act implementation effort may 

be vulnerable to delays caused by human resource constraints. 

Treasury has not developed a human resource plan to define the 

staffing needed to accomplish its strategic goal of making financial 

and payment data accessible and reusable. Additionally, the 

President’s budget request proposed, and Congress appropriated, 

$19.8 million in Fiscal Year 2016 for Treasury’s DATA Act 

implementation efforts. The budget request, however, did not 

include funds for additional full-time employees.27

In general, as a best practice, GAO has stated that agencies should 

determine the critical skills and competencies its workforce needs 

to achieve current and future agency goals and missions. Further, 

agencies should have succession plans in place for leadership and 

other critical positions.28 As it specifically relates to project 

management, human resource planning determines and identifies

human resources with the necessary skills for project success. 

According to the Project Management Body of Knowledge

 

27 Public Law 114-113, Consolidated Appropriations Act, 2016 (December 18, 2015). 28 GAO, Human Capital: Key Principles for Effective Strategic Workforce Planning (GAO-04-39; issued, 

December 2003).
Treasury’s Government-wide DATA Act Implementation Continues, Page 20 

But Project Management Concerns Remain (OIG-16-047)

(PMBOK), a human resource plan identifies and documents project 

roles, responsibilities, and reporting relationships. The plan also 

includes a staffing management plan, describing how human 

resource requirements will be met, and a timetable for staff 

acquisition and release. Staffing management plans typically 

describe necessary timeframes for project team members and 

document when acquisition activities, such as recruiting, should 

start.

The impact of not having a human resource plan became evident 

when the position of product owner for Treasury’s DATA Act

Implementation and Data Portal Pilots went unfilled. Treasury, an 

early adaptor of agile project methodology, detailed the product 

owner position to an individual from another agency with agile 

experience. The detailee was responsible for leading the pilots’ 

development efforts by conveying the vision to the team, outlining 

work in the product backlog,

29 prioritizing work based on business 

value, and developing a system for the end users. The term of the 

detail for the product owner expired before the development phase 

of both pilots finished.30 During fieldwork, a Treasury official told 

us that a successor had not been identified because of delays 

associated with the Federal hiring process and the difficulty of 

hiring the right person with the proper skill sets. In the meantime, 

this position’s workload is being performed by Treasury’s Deputy 

Assistant Secretary for Accounting Policy, who is also responsible 

for overall Government-wide DATA Act implementation efforts. 

Subsequent to our fieldwork, this position was filled in December 

2015 according to the Treasury official. 

In our prior audit, we reported that, as of October 2014, Fiscal 

Service’s Data Transparency Office, also referred to as the PMO, 

had two full-time employees assigned to DATA Act activities. As 

of October 2015, there were eight full-time employees and one

detailee assigned to DATA Act activities. A Treasury official stated 

that, although Treasury has not developed a human resource plan, 

the PMO has more staff than last year and has the basic team 

 

29 Backlog tracking is a list of features or technical tasks maintained by the team that, at a given 

moment, are known to be necessary and sufficient to complete a project. 30 The DATA Act Implementation and Data Portal Pilots product-owner position was filled with an 

individual who was detailed to Treasury from the Consumer Financial Protection Bureau for the 

period January through August 2015.
Treasury’s Government-wide DATA Act Implementation Continues, Page 21 

But Project Management Concerns Remain (OIG-16-047)

intact. According to the official, the departure of the product 

owner will not impact the pilot programs. 

Nevertheless, without a comprehensive, documented human 

resource plan, Treasury cannot demonstrate that it has given 

adequate consideration to the DATA Act implementation’s human 

resource needs. We believe Treasury should give prompt attention 

to staffing and succession planning. 

Finding 4 Stakeholder Questions Need to Be Addressed

In connection with their agency outreach efforts, Treasury and 

OMB solicit and receive agency questions on various aspects of the 

DATA Act, such as data standards, reporting requirements, 

implementation efforts, and technical issues. Agencies may submit 

questions by email or ask them during workshops, conference 

calls, and online discussion forums. 

In June 2015, Treasury and OMB began recording questions 

received from Federal agencies using the Agency DATA Act 

Questions document posted on Max.gov, making the information 

readily available to all agencies. Responses to some questions are 

immediately provided. However, other questions require additional 

policy analysis by Treasury and OMB before a response is 

formalized. We noted that the response time to some questions 

was lengthy, thereby limiting the effectiveness of this 

communication tool. Specifically, during June through September 

2015, agencies were provided the opportunity to submit questions 

to Treasury and OMB. In total, 60 questions were submitted by 

agencies. As of October 31, 2015, the end of our audit period, 25 

of the 60 questions had been answered. Treasury officials told us 

that there are no standard operating procedures covering the 

process to address questions, and a target timeframe for answering 

questions have not been set. 

Treasury and OMB provided a way (through the public GitHub site) 

for stakeholders to provide feedback during the process to 

standardize data elements. However, there is no methodology in 

place to document how feedback received on GitHub is considered 

and incorporated into DATA Act implementation efforts. We 

reviewed submissions on GitHub and noted that Treasury and OMB 

did not respond to stakeholder feedback on the site. When asked 
Treasury’s Government-wide DATA Act Implementation Continues, Page 22 

But Project Management Concerns Remain (OIG-16-047)

about this, a Treasury official explained that Treasury does not 

respond directly to the comments posted, but it does look at the 

feedback and forwards the submission to OMB.

Finding 5 Project Management Documentation Needs to Be 

Improved

In our prior report, we identified concerns with project management 

documentation, including the absence of key project management 

artifacts; the use of project management documents that did not 

fully reflect recognized artifacts, tools, and metrics for either an 

agile or traditional project management methodology; and

inconsistencies in the statuses reflected in tracking documents.

31

We recommended that Treasury strengthen project management 

over the DATA Act implementation efforts by ensuring that project 

management artifacts appropriate to the project methodology 

deployed are adopted and maintained. Treasury management 

concurred with our recommendation, stating that they had 

implemented a number of process improvements, and in November 

2014, filled the program manager position with an individual who 

had received formal training and was a Certified ScrumMaster©32, 

demonstrating proficiency in an agile project management 

methodology. We acknowledge that Treasury is making efforts 

toward implementing our prior recommendations described in 

Appendix 2. However, during our current fieldwork, we identified 

continuing concerns with Treasury’s project management 

documentation: 

• We identified inconsistencies and errors in project status 

reported on the Project Plan Master (Master Plan)33 and 

Executive Dashboard.

34 The PMO develops the Master Plan 

to track projects in detail and as a source for summary 

project information presented to the ESC on the Executive 

Dashboard. For example, we noted a task within the Master 

 

31 OIG, Treasury Is Making Progress in Implementing the DATA Act But Needs Stronger Project 

Management (OIG-15-034; issued May 19, 2015). 32 Scrum is an agile framework methodology. A Certified ScrumMaster© is a facilitator for a product 

development team who understands scrum methodology values, practices, and applications, and 

provides a level of knowledge and expertise above and beyond that of a traditional program manager. 33 The Master Plan is a project schedule of tasks, duration, and start/end dates. 34 The Executive Dashboard is a high-level summary of the status of the DATA Act implementation 

prepared by personnel within the PMO and used by members of the ESC to monitor the progress of 

the implementation.
Treasury’s Government-wide DATA Act Implementation Continues, Page 23 

But Project Management Concerns Remain (OIG-16-047)

Plan that was listed as 57 percent complete even though 

numerous sub-tasks had not been started. When we asked

about the reporting of this task, Treasury personnel told us 

that the percentages were updated based on projected start 

and end dates rather than an actual assessment of work 

completed and remaining. In another case, a known delay 

with awarding a contract for OpenBeta.USAspending.gov 

was not consistently reflected on the Executive Dashboard

status. A Treasury official stated that while the progress 

tracking metrics may contain errors, the PMO has always 

been transparent with the ESC regarding delays associated 

with DATA Act implementation efforts. In support of this 

statement, we noted that such delays were identified as 

potential risks.

• Records of key decisions made at ESC meetings were not 

formally documented and maintained. 

• As mentioned previously, Treasury was unable to provide us 

with documentation supporting how it determined which of 

the data elements to be reported under the DATA Act 

required standardization.

Treasury personnel told us that a contributing factor to 

inconsistencies and inaccuracies in project status reports was the 

use of traditional project management artifacts (Master Plan and 

Executive Dashboard) to track projects, such as the pilots, that 

were deployed using agile project management. A Treasury official 

acknowledged that project management artifacts need to be 

strengthened, but stated that updating the Master Plan and 

Executive Dashboard to correspond to an agile environment would 

be difficult. According to the official, the PMO had not documented

ESC meetings because of resource constraints, but planned to 

begin documenting the meetings in summer 2015. After 

completion of our fieldwork, we asked Treasury to provide us with 

ESC meeting notes for meetings held June through October 2015. 

Treasury was able to provide us with meeting notes for the ESC 

meetings held June through October 2015; however, these notes 

did not contain documentation to support all significant decisions 

made. Further, a Treasury official informed us that the meeting 

notes were not official minutes approved by the ESC. The Treasury 

official also stated that OMB was assigned the lead for selecting 

the data elements to be standardized and for maintaining the 

related documentation. However, we note the DATA Act assigns 
Treasury’s Government-wide DATA Act Implementation Continues, Page 24 

But Project Management Concerns Remain (OIG-16-047)

responsibility for standardizing data elements to Treasury and OMB 

jointly.

According to PMBOK, the key benefit of monitoring and controlling 

processes is to regularly and consistently observe and measure

performance and identify variances from the project management 

plan. Project status reports must be accurately maintained to 

provide project managers with the project information needed to 

timely identify risks and make appropriate decisions. Further, 

maintaining documentation is a fundamental tenet of government 

accountability and transparency. Accordingly, decisions made by 

project managers must be documented to provide the record of the 

conduct of government business.

35

Recommendations 

We recommend that the Fiscal Assistant Secretary, working with 

OMB where applicable: 

1. Finalize and release the production-ready broker to Federal 

agencies in an expeditious manner. 

Management Response 

Treasury agreed it is important to publish a stable productionready broker to facilitate agency compliance with DATA Act 

reporting requirements. On May 2, 2016, OMB, in collaboration

with Treasury, issued Management Procedures Memorandum 

No. 2016-03, which reflects the final policy decision on 

reporting architecture. In concert with this progress, Treasury 

released its stable DATA Act Information Model Schema version 

1.0. Treasury released its production-ready broker alpha release 

in April 2016, and updated the release to synch up with the 

requirements of Schema version 1.O at the end of May 2016. 

Agencies can test their Reporting Submission Specification data 

extractions, and plan for DATA Act implementation, using the 

production-ready broker alpha release. Consistent with its agile 

 

35 Treasury Directive 80-05, Records and Information Management Program, states that all program 

officials shall create and maintain adequate and proper documentation of the program for which they 

are responsible. This means a record of the conduct of government business that is complete and 

accurate to document the organization, functions, policies, decisions, procedures, and essential 

transactions to protect the legal and financial interests of the government.
Treasury’s Government-wide DATA Act Implementation Continues, Page 25 

But Project Management Concerns Remain (OIG-16-047)

implementation approach, Treasury will continue to roll out 

additional functionalities in the broker.

OIG Comment

Management’s response meets the intent of our 

recommendation. Management will need to record a target date 

for completing the corrective action in JAMES.

2. Determine the population of Federal agencies required to comply 

with the DATA Act, and ensure that an SAO has been identified

and a DATA Act implementation plan has been submitted to 

OMB for each agency in the population.

Management Response 

Treasury agreed it is important to provide guidance to Federal 

agencies on the DATA Act and on May 18, 2016, Treasury and 

OMB published guidance to help Federal agencies determine 

whether they are required to comply with the DATA Act. The 

guidance provides that any Federal agency submitting data that 

OMB posts on its SF 133 Report on Budget Execution and 

Budgetary Resources is required to comply with DATA Act 

reporting, which includes the 24 CFO Act agencies and many 

smaller agencies. The guidance lists examples of agencies that

meet the definition of Federal agency under the DATA Act and 

that submit data that OMB posts on its SF 133 Report. 

Establishing the SAO was OMB's lead role and OMB required 

agencies to submit implementation plans concurrent with 

budget formulation requests. Treasury will continue to assist 

OMB as needed on these requirements.

OIG Comment

Management’s response meets the intent of our

recommendation. Management will need to record a target date 

for completing the planned corrective action in JAMES.
Treasury’s Government-wide DATA Act Implementation Continues, Page 26 

But Project Management Concerns Remain (OIG-16-047)

3. Develop a comprehensive, documented human resource plan for 

Treasury’s DATA Act implementation efforts. 

Management Response 

Treasury agreed that developing a human resource plan is 

necessary for accomplishing its strategic goal of making 

financial and payment data accessible and reusable in the long 

term. To achieve its short-term goal of implementing the DATA 

Act, since October 2015, Treasury has hired three additional 

full-time employees and filled the product owner function with 

one fulltime employee and one detailee. In addition, Treasury 

has acquired the services of a contractor to support program 

management and technical development functions. To ensure 

sustainability in the long-term, Treasury is developing a 

comprehensive human resource plan for Treasury’s

PMO function.

OIG Comment

Management’s commitment to developing a comprehensive 

human resource plan for Treasury’s PMO function meets the 

intent of our recommendation. Management will need to record 

a target date for completing the corrective action in JAMES.

4. Clear the backlog of unaddressed DATA Act stakeholder 

questions and develop standard operating procedures to ensure 

that stakeholder questions and feedback are accounted for and

addressed in a timely manner.
Treasury’s Government-wide DATA Act Implementation Continues, Page 27 

But Project Management Concerns Remain (OIG-16-047)

Management Response

Treasury agreed that responding to stakeholder questions in a 

timely manner is an important component in engaging with 

stakeholders. Now that OMB and Treasury have made a final

policy decision on the DATA Act reporting architecture and the 

stable DATA Act Information Model Schema version 1.O has 

been released, the majority of outstanding agency stakeholder 

questions have been addressed. Treasury will post its [individual 

or aggregate] responses to the remaining stakeholder questions 

in the coming weeks. In addition, Treasury has developed 

standard operating procedures to triage stakeholder questions. 

Treasury's goal is to respond to stakeholder questions in as 

timely a manner as possible, although the response period may 

continue to be affected, on a case-by-case basis, by the time 

needed to make underlying policy or technical decisions.

OIG Comment

Management’s commitment to respond to all stakeholder 

questions in as timely a manner as possible meets the intent of 

our recommendation. Management will need to record a target 

date for completing the corrective action in JAMES. 

5. Continue efforts to strengthen project management over the 

DATA Act implementation, ensuring that (a) progress metrics

provide a consistent, accurate measure of task status and 

(b) key management decisions are documented. 

Management Response 

Treasury agreed it is important to have strong DATA Act project 

management. As noted in the draft report, Treasury and OMB 

established a governance structure for implementation in 

Summer 2014, shortly after the enactment of the law. Based on 

the governance structure, Treasury and OMB delineated lead 

roles and responsibilities for various workstreams, including the 

lead role for OMB for data definitions, and the lead role for 

Treasury for the data exchange (schema). Treasury recognizes 

the importance of documentation and will continue to work with

OMB to strengthen project management documentation, as 
Treasury’s Government-wide DATA Act Implementation Continues, Page 28 

But Project Management Concerns Remain (OIG-16-047)

appropriate. In addition, the Treasury PMO has worked to 

improve project management documentation by developing

standard operating procedures for certain PMO activities, 

including compiling and maintaining ESC meeting minutes. 

Treasury will continue to work to better document its agile 

development progress by improving project management 

artifacts and metrics.

OIG Comment

Management’s response meets the intent of our 

recommendation. Management will need to record a target date 

for completing the corrective action in JAMES.

* * * * * 

We appreciate the courtesies and cooperation provided to our staff 

during the audit. If you wish to discuss the report, you may 

contact me at (202) 927-6345 or Andrea Smith, Acting Director,

Fiscal Service Audit, at (202) 927-8757. Major contributors to this 

report are listed in Appendix 4. 

/s/

James L. Lisle, Jr.

Acting Deputy Assistant Inspector General for Audit
Appendix 1

Objectives, Scope, and Methodology 

Treasury’s Government-wide DATA Act Implementation Continues, Page 29 

But Project Management Concerns Remain (OIG-16-047)

Our audit objectives were to determine the sufficiency of plans 

and actions taken by the Department of the Treasury (Treasury) 

and its Bureau of the Fiscal Service (Fiscal Service) as of 

October 31, 2015, to timely comply with the Digital 

Accountability and Transparency Act of 2014 (DATA Act)

provisions to (1) establish Government-wide financial data 

standards for any Federal funds made available to or expended by 

Federal agencies and entities receiving Federal funds by May 

2015; (2) ensure that this financial data is accurately posted and 

displayed on USAspending.gov (or a successor system) by May 

2017; and (3) ensure the established data standards are applied to 

the financial data made available on the website by May 2018. 

This audit is the second of a series of audits on Treasury’s 

implementation of the DATA Act.

To accomplish our audit objective, we took the following actions:

• reviewed the Federal Funding Accountability and 

Transparency Act of 2006 (FFATA), which outlines 

requirements for the Office of Management and Budget 

(OMB) to establish a single searchable website to provide the 

public with access to data on Federal spending

• reviewed the DATA Act, which outlines the requirements for 

Treasury to establish Government-wide financial data 

standards and increase the availability, accuracy, and 

usefulness of Federal spending information

• reviewed the President’s Fiscal Year 2016 budget to 

determine funding requested to support Treasury’s

responsibilities under the DATA Act

• reviewed the Consolidated Appropriations Act, 2016 to 

determine the amount Congress appropriated to Treasury to 

fund activities related to DATA Act implementation efforts 

• reviewed the DATA Act Risk Register dated August 11, 2015 

• reviewed the Action Memorandum dated July 21, 2015, from 

Fiscal Service’s Commissioner to Treasury’s Fiscal Assistant 

Secretary regarding Treasury’s election not to assume the 

assets of the Recovery Operations Center

• reviewed the DATA Act Executive Steering Committee 

Meetings – Operating Process dated June 30, 2015
Appendix 1

Objectives, Scope, and Methodology 

Treasury’s Government-wide DATA Act Implementation Continues, Page 30 

But Project Management Concerns Remain (OIG-16-047)

• reviewed Treasury Directive 80-05, Treasury’s Records and 

Information Management Program (November 4, 2010) 

• reviewed OMB memorandums to evaluate Treasury’s role and 

responsibilities regarding principles of government 

transparency, including

o OMB M-10-06, Open Government Directive (December 8, 

2009)

o OMB M-15-12, Increasing Transparency of Federal 

Spending by Making Federal Spending Data Accessible, 

Searchable, and Reliable (May 8, 2015) 

• reviewed the following Government Accountability Office

(GAO) reports: 

o GAO-16-261, DATA Act: Data Standards Established, but 

More Complete and Timely Guidance Is Needed to Ensure 

Effective Implementation (January 29, 2016) to review 

GAO’s efforts to audit Treasury and OMB’s 

implementation of standardized data elements 

o GAO-04-39, Human Capital: Key Principles for Effective 

Strategic Workforce Planning (December 11, 2003) to 

establish criteria related to strategic workforce planning

o GAO-12-681, Software Development: Effective Practices 

and Federal Challenges in Applying Agile Methods (July 

27, 2012) to establish criteria related to agile project 

management

o GAO-11-50, Information Technology: Opportunities Exist 

to Improve Management of DOD’s Electronic Health 

Record Initiative (October 06, 2010) to establish criteria 

related to traditional project management

o GAO-14-704G, Standards for Internal Control in the 

Federal Government (September 2014)

o GAO 15-752T, DATA Act, Progress Made in Initial 

Implementation but Challenges Must be Addressed as 

Efforts Proceed (July 29, 2015) to obtain an 

understanding of GAO’s testimony before the U.S. House 

of Representatives Subcommittees on Information 

Technology and Government Operations, and Oversight 

and Government Reform, on the potential transfer of the 

Recovery Operation Center assets to Treasury 
Appendix 1

Objectives, Scope, and Methodology 

Treasury’s Government-wide DATA Act Implementation Continues, Page 31 

But Project Management Concerns Remain (OIG-16-047)

• reviewed Project Management Institute’s A Guide to the 

Project Management Body of Knowledge, Fourth Edition

(2008), to establish criteria related to traditional project 

management

• obtained an understanding of Fiscal Service’s Data 

Transparency Office structure and staffing by reviewing Fiscal 

Service 2014–2015 Tactical Priorities, the Data Transparency 

Office organizational chart, and a listing of project team 

members and their respective roles

• reviewed Treasury and OMB guidance related to the DATA 

Act implementation, including: 

o DATA Act Schema (several versions from May to 

December 2015) 

o DATA Act Blueprints (March 18, 2015) 

o DATA Act Implementation Playbook (June 2015) 

o Agency DATA Act Questions (June 26, 2015) and 

Agency DATA Act Questions (September 28, 2015) 

o DATA Act Elements Guidance Feedback Tracker 

(version 0.1.2, September 2015) 

• reviewed Treasury’s DATA Act implementation planning 

documents, including: 

o Draft “White Paper: Implementing the DATA Act,” (June 

26, 2014) 

o “Implementing the DATA Act: Treasury Roadmap,” 

presentation to the Chief Financial Officers Council (June 

1, 2015) 

o “DATA ACT Implementation—Roadmap” (June 1, 2015) 

o “DATA Act Implementation—Executive Dashboard” 

(November 4, 2014–October 20, 2015) 

o “DATA Act Project Plan Master” (as of June 11, 2015) 

o Memorandum of Understanding Between the U.S. Small 

Business Administration and The Department of The 

Treasury, Fiscal Service (DATA Act Implementation Pilot, 

March 26, 2015) 

o Draft version 3, Treasury Data Portal Pilot Rough Order of 

Magnitude (February 13, 2015) 

o Mid-implementation Pilot Update (June 3, 2015) 
Appendix 1

Objectives, Scope, and Methodology 

Treasury’s Government-wide DATA Act Implementation Continues, Page 32 

But Project Management Concerns Remain (OIG-16-047)

o Interagency agreement Between Fiscal Service and 

Treasury Franchise Fund/Shared Services Programs

(effective October 1, 2014) 

o Interagency Agreement between Fiscal Service and 

General Services Administration/Office of Citizen 

Services & Innovative Technologies/18F (effective 

January 1, 2015) 

o Spending Transparency Outreach Update and Plan (as of 

June 2, 2015) 

• reviewed agendas and minutes from meetings for the 

Interagency Advisory Committee (December 19, 2014–

August 5, 2015) 

• reviewed agendas from meetings for the Executive Steering 

Committee (August 12, 2014–June 2, 2015) 

• reviewed Senior Accountable Officials conference call notes 

(April 23, 2015–September 3, 2015) 

• interviewed personnel responsible for Treasury’s DATA Act 

implementation efforts

We performed our audit fieldwork principally from March through 

November 2015. 

We conducted this performance audit 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.
Appendix 2

Prior OIG DATA Act Recommendations and Status of Related Corrective Actions

Treasury’s Government-wide DATA Act Implementation Continues, Page 33 

But Project Management Concerns Remain (OIG-16-047)

Source: JAMES and Treasury Office of Inspector General analysis.

Prior OIG DATA Act 

Recommendations 

Status as Reported by Treasury in 

the Department’s Audit 

Management Tracking System 

(Joint Audit Management 

Enterprise System, or JAMES) Status Based on Current Audit

1. Strengthen project 

management over the DATA 

Act’s implementation efforts 

by defining the project 

management methodology 

being used for each 

significant workstream and 

ensure that project 

management artifacts 

appropriate to those 

methodologies such as 

project planning tools, 

progress metrics, and 

collaboration documentation 

are adopted and maintained.

(OIG-15-034) 

Closed –Treasury’s stated planned 

corrective actions were to:

• define the project methodology 

corresponding artifacts for each 

workstream; and 

• further develop project planning 

tools, progress metrics, and 

collaboration documentation.

Our current audit found that

Treasury has made progress in 

improving its project management 

practices. However, we continue to 

identify concerns such as those 

presented in Finding 5 of this report. 

Specifically, we identified continuing 

inconsistencies and errors in the 

project status reported on the 

Master Plan and Executive 

Dashboard, and found that records 

of key decisions made are not 

formally documented and

maintained. Further, in Finding 3 of 

this report we noted that Treasury 

has not developed a comprehensive 

human resource plan to define the 

staffing needed to accomplish its 

strategic goal of making financial 

management data accessible and 

reusable. In this report, we 

recommend that:

• Treasury continue efforts to 

strengthen project management 

over the DATA Act 

implementation, ensuring that 

progress metrics provide a 

consistent, accurate measure of 

task status, and key 

management decisions are 

documented.

• Treasury develop a 

comprehensive, documented 

human resource plan for 

Treasury’s DATA Act 

implementation efforts

2. Ensure the individual 

charged with program 

management has the 

requisite qualifications, 

resources, and 

understanding of project 

management methodologies 

used to effectively fulfill that 

role.

(OIG-15-034)

Closed - Treasury filled the role of 

program manager in November

2014. The individual, a Certified 

ScrumMaster®, had the requisite 

qualifications, to fulfil that role. 

Treasury’s corrective actions to hire 

a program manager with requisite 

qualifications addressed this 

recommendation.
Appendix 3

Management Response

Treasury’s Government-wide DATA Act Implementation Continues, Page 34 

But Project Management Concerns Remain (OIG-16-047)
Appendix 3

Management Response 

Treasury’s Government-wide DATA Act Implementation Continues, Page 35 

But Project Management Concerns Remain (OIG-16-047)
Appendix 3

Management Response 

Treasury’s Government-wide DATA Act Implementation Continues, Page 36 

But Project Management Concerns Remain (OIG-16-047)
Appendix 4

Major Contributors to This Report

Treasury’s Government-wide DATA Act Implementation Continues, Page 37 

But Project Management Concerns Remain (OIG-16-047)

Andrea D. Smith, Acting Director, Fiscal Service Audit 

Horace A. Bryan, Auditor-in-Charge

Maria M. McLean, Auditor

Avery L. Williams, Auditor

Fawntrella L. Thompson, Referencer

Jeffrey T. Dye, Referencer
Appendix 5

Report Distribution

Treasury’s Government-wide DATA Act Implementation Continues, Page 38 

But Project Management Concerns Remain (OIG-16-047)

Department of the Treasury

Deputy Secretary

Fiscal Assistant Secretary

Deputy Fiscal Assistant Secretary for Accounting Policy and 

Financial Transparency

Office of the Deputy Chief Financial Officer, Risk and Control 

Group

Office of Strategic Planning and Performance Management

 

Bureau of the Fiscal Service

Commissioner

Director, Finance and Internal Control Division

OIG Liaison

 

Office of Management and Budget

Controller

OIG Budget Examiner
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