DHS Has Made Progress in 

Meeting DATA Act 

Requirements, But 

Challenges Remain 

August 13, 2020 

OIG-20-62 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Washington, DC 20528 / www.oig.dhs.gov

 August 13, 2020 

MEMORANDUM FOR:	 Troy Edgar 

Chief Financial Officer 

Department of Homeland Security 

FROM:	 Joseph V. Cuffari, Ph.D. 

Inspector General 

SUBJECT: DHS Has Made Progress in Meeting DATA Act 

Requirements, But Challenges Remain 

For your action is our final report, DHS Has Made Progress in Meeting DATA Act 

Requirements, But Challenges Remain. We incorporated the formal comments 

provided by your office. 

The report contains five recommendations aimed at improving the quality of the 

Department’s spending data. Your office concurred with all five recommendations. 

Based on information provided in your response to the draft report, we consider 

recommendations 1, 2, 4, and 5 to be open and resolved. Once your office has 

fully implemented the recommendations, please submit a formal closeout letter 

to us within 30 days accompanied by evidence of completion of agreed-upon 

corrective actions so that we may close the recommendations. 

Based on information provided in your response to the draft report, we consider 

recommendation 3 open and unresolved. As prescribed by the Department of 

Homeland Security Directive 077-01, Follow-Up and Resolutions for the Office of 

Inspector General Report Recommendations, within 90 days of the date of this 

memorandum, please provide our office with a written response that includes 

your (1) agreement or disagreement, (2) corrective action plan, and (3) target 

completion date for the third bullet of recommendation 3. Also, please include 

your responsible parties and other supporting documentation to inform us about 

the current status of the recommendation. Until your response is received and 

evaluated, the recommendation will be considered open and unresolved. Please 

send your response or closure request to OIGAuditsFollowup@oig.dhs.gov. 

Consistent with our responsibility under the Inspector General Act, we will 

provide copies of our report to congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We 

will post the report on our website for public dissemination. 

Please call me with any questions, or your staff may contact Sondra McCauley, 

Assistant Inspector General for Audits, at (202) 981-6000. 

www.oig.dhs.gov 
 

 

 

 

 

 

 

 

 

 

 

DHS OIG HIGHLIGHTS
 

DHS Has Made Progress in Meeting DATA Act 

Requirements, But Challenges Remain
 

August 13, 2020 

Why We Did 

This Audit 

The DATA Act required 

the Office of Inspector 

General to review a 

statistically valid sample 

of DHS’ fiscal year 2019 

first quarter (FY 2019/Q1) 

spending data posted on 

USAspending.gov, and 

submit to Congress a 

report assessing the 

data’s completeness, 

accuracy, timeliness, and 

quality, as well as DHS’ 

implementation and use 

of government-wide 

financial data standards. 

What We 

Recommend 

This report contains five 

recommendations aimed 

at strengthening DHS’ 

controls to improve its 

spending data quality. 

For Further Information: 

Contact our Office of Public Affairs 

at (202) 981-6000, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

Since our first audit in 2017, DHS has continued to make 

progress in meeting its Digital Accountability and Transparency 

Act of 2014 (DATA Act) reporting requirements. For example, 

DHS improvements included reducing misalignments in its 

procurement and financial assistance award data from nearly 

$1.9 billion (38 percent) in FY 2017/Q2 to $264 million 

(4 percent) in FY 2019/Q1. This occurred because DHS 

implemented a quarterly process that targeted such 

misalignments through spending data quality reviews. We 

nonetheless identified opportunities for DHS to strengthen its 

quarterly reviews and further reduce misalignments to enable 

more effective tracking of Federal spending. 

Using the Inspectors General Guide to Compliance under the 

DATA Act, we found the quality of DHS’ spending data was 

moderate for a statistically valid sample of 375 procurement 

and financial assistance awards. Specifically, the data was 

complete and accurate, but not timely. Due to system 

limitations, DHS did not report 67 percent of the sampled 

financial assistance award elements within 30 days of award 

date as required. Although DHS works to mitigate this risk 

through its quarterly review process, the timeliness of 

financial assistance reporting remains a recurring challenge. 

DHS generally implemented and consistently uses governmentwide data standards, but could improve reporting for certain 

data elements to fully achieve the DATA Act’s objective of 

making Federal spending information more transparent to the 

public. DHS developed a data quality plan to manage risks to 

data quality as required. 

DHS Response 

DHS concurred with all five recommendations. Appendix B 

contains the Department’s response in its entirety. All 

recommendations will remain open pending evidence to 

support completion of the corrective actions. 

www.oig.dhs.gov OIG-20-62 
 

 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

Background .................................................................................................... 2 

Results of Audit .............................................................................................. 7 

DHS Has Improved Alignment of Budgetary Data, But Challenges 

Remain .................................................................................................. 8 

DHS Has Improved Alignment of Award Data, But Additional 

Improvement Can Be Made .................................................................. 10 

DHS’ DATA Act Submission Was of Moderate Quality .......................... 12 

DHS Implemented and Used Government-wide Data Standards But 

Could Improve Reporting on Certain Data Elements............................. 16 

DHS Developed a Plan to Manage Risks to Data Quality ....................... 17 

Recommendations ......................................................................................... 19 

Appendixes 

Appendix A: Objectives, Scope, and Methodology ................................ 25 

Appendix B: DHS Response to the Draft Report ................................... 27 

Appendix C:Report Distribution .......................................................... 32 

Abbreviations 

CAP Corrective Action Plan 

CIGIE Council of the Inspectors General on Integrity and Efficiency 

DAIMS DATA Act Information Model Schema 

DAS DATA Act Solution 

DATA Act Digital Accountability and Transparency Act of 2014 

DQP Data Quality Plan 

FABS Financial Assistance Broker Submission 

FEMA Federal Emergency Management Agency 

FPDS-NG Federal Procurement Data System-Next Generation 

NFIP National Flood Insurance Program 

OIG Office of Inspector General 

OMB Office of Management and Budget 

RMT Resource Management Transformation 

SAO Senior Accountable Official 

www.oig.dhs.gov OIG-20-62 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background
 

On May 9, 2014, the President signed the Digital Accountability and Transparency 

Act of 2014 (DATA Act) into law to make information on Federal spending more 

easily accessible and transparent to the public. The DATA Act requires agencies 

to report spending data quarterly to USAspending.gov1 in accordance with 

government-wide financial data standards established by the Department of the 

Treasury (Treasury) and the Office of Management and Budget (OMB). These 

standards specify the data elements for reporting under the DATA Act and define 

what each element should include to ensure data is consistent and comparable. 

Agencies must disclose information linking spending activity to Federal 

programs in the President’s budget to effectively track government spending. 

Office of Inspector General Responsibilities under the DATA Act 

The DATA Act requires the Office of Inspector General (OIG) of each Federal 

agency to review a statistically valid sample of the agency’s spending data 

submissions to USAspending.gov in fiscal years 2017, 2019, and 2021. Also, 

the DATA Act requires each OIG to submit to Congress a report that assesses 

the completeness, accuracy, timeliness, and quality of the data sampled, and 

implementation and use of government-wide financial data standards in 

compiling the data. This is our second of three mandated reports on DHS’ 

implementation of the DATA Act. This report assesses the quality of DHS’ 

FY 2019, first quarter (FY 2019/Q1) spending data. 

The Council of the Inspectors General on Integrity and Efficiency’s (CIGIE) 

Federal Audit Executive Council released its Inspectors General Guide to 

Compliance under the DATA Act (CIGIE IG Guide) on February 14, 2019. The 

CIGIE IG Guide provides a common methodology and reporting approach for 

every OIG to use in performing work mandated by the DATA Act. 

DATA Act Submission 

Federal agencies submit their budgetary and award data to Treasury’s DATA 

Act Broker (Broker), a system that facilitates the collection, validation, 

certification, and submission of agencies’ quarterly spending data for publication 

on USAspending.gov. Agencies are required to upload to the Broker the files 

identified in table 1, containing data from their internal financial systems. 

1 USAspending.gov is a searchable database of information on Federal contracts and other 

Government assistance such as grants and cooperative agreements. 

www.oig.dhs.gov 2 OIG-20-62 
 

 

 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 1. Agency-Created DATA Act Files 

File Name Description Data Source Required

Frequency 

File A Appropriations 

Account 

Budget authority 

by appropriations 

account Agencies’ 

internal 

financial 

management 

systems 

Quarterly via 

DATA Act 

Broker 

Submission 

File B Object Class and 

Program Activity 

Obligations/outlays 

by object class and 

program activity 

File C Award Financial Financial award 

detail information 

Source: DHS OIG analysis of Treasury and OMB guidance 

After agencies upload their files, the Broker extracts spending data from 

government-wide award reporting systems containing data on Federal 

contracts, grants, and award recipients. Those systems include the Federal 

Procurement Data System-Next Generation (FPDS-NG) and the Financial 

Assistance Broker Submission (FABS). Agencies submit information on 

procurement awards to FPDS-NG and on financial assistance awards (grants, 

loans, insurance, and other assistance) to FABS. Using the extracted data, the 

Broker generates the files identified in table 2. 

Table 2. DATA Act Broker-Generated Files2 

File Name Description Data Source Required 

Frequency 

File D1 Procurement 

Award-level data for 

recipients of 

procurement awards 

FPDS-NG 

Within 3 days of 

contract award 

($10,000 or more) 

File D2 Financial 

Assistance 

Award-level data for 

recipients of financial 

assistance awards 

FABS 

Within 30 days of 

grant award 

($25,000 or more) 

File E 

Additional 

Awardee 

Attributes 

Personnel and other 

information about entities 

receiving Federal funds 

System for 

Award 

Management 

Data is uploaded 

daily to 

USAspending.gov 

File F Subaward 

Attributes 

Data and other information 

about entities receiving 

subawards made by 

recipients of federal funds 

Federal 

Subaward 

Reporting 

System 

Data is uploaded 

daily to 

USAspending.gov 

Source: DHS OIG analysis of Treasury and OMB guidance 

2 The award data in Files D1 to F are uploaded daily to USAspending.gov. The quality of the 

data in Files E and F is the legal responsibility of the award recipient, not DHS. Therefore, we 

did not audit these files. 

www.oig.dhs.gov 3 OIG-20-62 
 

 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

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The Broker applies a series of validation rules to test completeness and 

accuracy of the data elements and linkages between budgetary and award data. 

OMB guidance3 requires agencies to link budgetary and award data across 

different files using unique award numbers.4 Through its validation process, 

the Broker generates data warnings and critical errors based on the application 

of Treasury-defined rules. An example of a warning is when a unique award 

number exists in File C but does not exist in Files D1/D2. Errors can occur 

when certain data elements do not meet formatting requirements such as field 

length or character type. If any data in the agency submission generates 

critical errors, USAspending.gov will not accept that data for publication. By 

contrast, less severe discrepancies result in Broker-generated warnings that do 

not prevent this data from continuing through the publication process. For 

example, warning messages alert agencies to possible issues worth further 

review that may or may not be inaccuracies in the data. 

Once agency files successfully pass the Broker validations, OMB requires5 each 

agency’s senior accountable official (SAO) to certify the quarterly DATA Act 

submission. The SAO certification provides reasonable assurance that the 

agency’s internal controls support the validity and reliability of the budgetary 

and award data submitted to Treasury for publication on USAspending.gov. 

After the SAO completes the certification in the Broker, Treasury will publish 

the spending data on USAspending.gov. (See figure 1 for a flowchart of the 

DATA Act Broker’s Quarterly Submission Process.) 

Starting in FY 2019, each agency must develop a data quality plan (DQP) that 

identifies risks to the quality of Federal spending data and implement a control 

structure to manage such risks.6 Quarterly certifications by the SAO should be 

based on considerations and internal controls documented in the agency’s DQP. 

3 OMB Management Procedures Memorandum 2016-03, Additional Guidance for DATA Act 

Implementation: Implementing Data-Centric Approach for Reporting Federal Spending 

Information, May 3, 2016 4 For Federal procurement, the procurement instrument identifier serves as the linkage 

between financial and procurement systems. For financial assistance awards, the Federal award 

identification number serves as the linkage between financial and management systems. Each 

File C transaction should have a corresponding transaction in File D1/D2 associated with the 

same unique award number. 

5 OMB Memorandum M-17-04, Additional Guidance for DATA Act Implementation: Further 

Requirements for Reporting and Assuring Data Reliability, November 4, 2016 

6 OMB Memorandum M-18-16, Appendix A to OMB Circular No. A-123, Management of 

Reporting and Data Integrity Risk, June 6, 2018 

www.oig.dhs.gov 4 OIG-20-62 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figure 1. DATA Act Broker’s Quarterly Submission Process 

Source: GAO-20-75, Government Accountability Office analysis of Treasury guidance 

DHS Governance for Quarterly DATA Act Submission 

In FY 2015, DHS established a governance structure — an institutionalized set 

of policies and procedures — for the Department’s implementation of the DATA 

Act. DHS’ Deputy Chief Financial Officer serves as the Department’s SAO. The 

SAO sets the strategic direction for DHS’ approach to DATA Act implementation. 

DHS also created a Headquarters DATA Act Working Group with members from 

across its organizational units, including budget, accounting, procurement, and 

financial assistance. 

www.oig.dhs.gov 5 OIG-20-62 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

DHS is responsible for establishing the internal control processes necessary to 

achieve compliance with the DATA Act. DHS component DATA Act teams 

submit their spending data monthly to the Resource Management Transformation 

(RMT) Division within the Office of the Chief Financial Officer to comprise the 

Department’s consolidated quarterly submissions to USAspending.gov. 

Components must document and implement internal control procedures to 

ensure their spending data is complete, accurate, and timely. 

RMT developed an internal DATA Act Solution (DAS) system to collect and 

perform pre-check validations of DHS components’ spending data to ensure it 

meets Broker submission requirements. On a monthly basis, as shown in 

figure 2, RMT pulls the components’ budgetary data (Files A and B) from DHS’ 

Treasury Information Executive Repository and uploads it to the DAS, while 

components submit their award data (File C) directly to the DAS. Additionally, 

RMT downloads components’ procurement award data (File D1) and financial 

assistance award data (File D2) from the Broker and uploads it to the DAS. 

Figure 2. DHS DATA Act Solution Process 

Source: DHS DATA Act Data Quality Plan, March 15, 2019 

The DAS process mirrors the Broker’s validation of the alignment between the 

procurement and financial assistance award files and the budgetary files 

included in DHS’ quarterly submission. The DAS process also includes 

additional tests for DHS to ensure transactions eventually align and to 

www.oig.dhs.gov 6 OIG-20-62 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

determine how long they take to align. Throughout the quarter, DHS 

stakeholders work together to research and resolve Broker and DAS validation 

issues, such as missing financial information. Also, RMT conducts monthly 

Headquarters DATA Act Working Group and Component Implementation 

Working Group meetings to discuss guidance, processes, best practices, and 

data quality management efforts. 

Previous OIG DATA Act Review 

In 2017, we reported7 that DHS’ internal controls for its DATA Act processes 

were not sufficient to ensure the submission of complete, accurate, and timely 

spending data for FY 2017/Q2. We identified issues concerning data alignment, 

completeness, and accuracy that hindered the quality and usefulness of the 

information. We made six recommendations for DHS to strengthen its existing 

controls and apply additional controls for its DATA Act processes to ensure 

complete, accurate, and timely spending data. As of May 2019, all six 

recommendations were resolved and closed. 

Results of Audit 

Since our first audit in 2017, DHS has continued to make progress in meeting 

its DATA Act reporting requirements. For example, DHS improvements 

included reducing misalignments in its procurement and financial assistance 

award data from nearly $1.9 billion (38 percent) in FY 2017/Q2 to $264 million 

(4 percent) in FY 2019/Q1. This occurred because DHS implemented a 

quarterly process that targeted such misalignments through spending data 

quality reviews. We nonetheless identified opportunities for DHS to strengthen 

its quarterly reviews and further reduce misalignments to enable more effective 

tracking of Federal spending. 

Using the CIGIE IG Guide, we found the quality of DHS’ spending data was 

moderate for a statistically valid sample of 375 procurement and financial 

assistance awards. Specifically, the data was complete and accurate, but not 

timely. Due to system limitations, DHS did not report 67 percent of the 

sampled financial assistance award elements8 within 30 days of award date as 

required. Although DHS works to mitigate this risk through its quarterly 

review process, the timeliness of financial assistance reporting remains a 

recurring challenge. 

7 DHS’ Implementation of the DATA Act, OIG-18-34, December 29, 2017 

8 OIG sampled 191 financial assistance awards, which were all issued by the Federal 

Emergency Management Agency (FEMA). 

www.oig.dhs.gov 7 OIG-20-62 
 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

DHS generally implemented and consistently uses government-wide standards, but 

could improve reporting for certain data elements to fully achieve the DATA Act’s 

objective of making Federal spending information more transparent to the public. 

DHS developed a data quality plan to manage risks to data quality as required. 

DHS Has Improved Alignment of Budgetary Data, But Challenges 

Remain 

In comparison to the results of our 2017 audit, the alignment of DHS’ budgetary 

data with authoritative sources the Broker uses has improved, but DHS can do 

more to ensure full compliance. As previously discussed, OMB’s DATA Act 

implementation guidance9 requires agencies to quarterly report budgetary 

spending, including appropriations, object class, and program activity data. 

The following are requirements for aligning reported budgetary data with the 

authoritative sources the Broker uses for validation. Specifically: 

x Appropriations account data reported in File A must match the agency’s 

Standard Form 133, Report of Budget Execution and Budgetary Resources. 

Appropriations provide agencies budget authority to incur obligations 

and to make payments from the Treasury for specified purposes. 

x Object class codes reported in File B must match the codes defined in 

Section 83 of OMB Circular A-11, Preparation, Submission, and Execution 

of the Budget. Object class codes identify obligations by the types of 

goods or services purchased by the U.S. Federal Government. 

x Program activity names and codes reported in File B must match the 

agency’s program and financing schedule in the President’s budget. To 

ensure the data matches the President’s budget, OMB created a quarterly 

MAX Collect exercise for agencies to provide Treasury with their updated 

program activity lists. 

The Broker uses the agency’s Standard Form 133, OMB Circular A-11, and 

OMB’s Max Collect list as the authoritative sources to validate budgetary data. 

These validations ensure users can trace Federal spending to priorities in the 

President’s budget. 

Our analysis of DHS’ DATA Act submission for FY 2019/Q1 showed the 

budgetary data contained appropriations account and object class information 

matching their authoritative sources. Additionally, the program activity data 

was generally complete and accurate, but 1,312 records (15 percent) contained 

9 OMB Management Procedures Memorandum 2016-03 and OMB Memorandum M-17-04 

www.oig.dhs.gov 8 OIG-20-62 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

program activity data that did not match programs identified in the President’s 

budget. These records represented $3.4 billion in obligations (16 percent) and 

$3.7 billion in expenditures (16 percent) reported to USAspending.gov. In 

comparison, we previously reported that 74 percent of the records in DHS’ 

spending data from FY 2017/Q2 contained misaligned program activity data for 

39 percent of DHS’ total obligations and 57 percent of its total expenditures. 

The FY 2019/Q1 misalignments occurred because DHS officials were unaware 

that OMB had extended10 the deadline for agency updates through its MAX 

Collect exercise from January 10, 2019, to February 15, 2019. The quarterly 

MAX Collect exercise allows agencies to provide Treasury with updated program 

activity lists if changes to programs occur during the appropriations process. 

Through its validation process, the DATA Act Broker generated warnings for 

DHS’ budgetary spending data containing program activity information that did 

not match OMB’s MAX Collect list. Although RMT directed DHS components to 

research the warnings and components determined their reported data was 

legitimate, RMT did not take steps to ensure components properly updated 

their program activity lists through the OMB Max Collect exercise. 

Additionally, DHS components improperly assigned program activity code 

“0000” and name “Unknown/Other” to appropriation accounts including 

obligations or outlays. Of the 1,312 records in File B that received Broker 

warnings, 145 (11 percent) were part of this category. We attributed this issue 

to an ambiguity in Treasury’s implementation guidance. Specifically, according 

to Treasury’s DATA Act implementation guidance,11 agencies can report the 

“Unknown/Other” code if there are no obligations or outlays on the appropriation 

account in File B. However, the guidance did not explicitly prohibit agencies 

from using an unknown code in cases when appropriation accounts had 

obligations and outlays. Treasury issued revised guidance in September 2019 

clarifying that agencies should only use unknown program activity codes when 

there are no obligations or outlays associated with their appropriation accounts. 

Despite improving the alignment of its budgetary data, DHS needs to take 

additional steps to achieve full compliance with the DATA Act’s objective of 

making Federal spending information more transparent to the public.12 

Misaligned program activity data hinders transparency by not allowing the 

public to track Federal spending to priorities in the President’s budget. 

10 OMB Budget Data Request Memorandum 19-09, Revised, Preparation of the DATA Act 

Program Activity Validation List (FY 2019 Q1 Reporting), February 4, 2019 11 U.S. Department of the Treasury Bureau of the Fiscal Service, DATA Act Information Model 

Schema (DAIMS) Practices and Procedures For DATA Act Broker Submissions Version 1.3, June 

29, 2018 (Treasury DAIMS) 

12 Refer to OIG recommendation 1 and DHS’ response starting on page 19 for more information. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

DHS Has Improved Alignment of Award Data, But Additional 

Improvement Can Be Made 

To enable more effective tracking of Federal spending, OMB guidance13 requires 

agencies to link each Federal award across their different DATA Act submission 

files using unique award numbers. Agencies are responsible14 for ensuring 

controls are in place to manage risk in reporting data that achieves the 

reporting objective. Each SAO must15 provide a quarterly assurance statement 

that the alignments (linking unique award numbers) among the DATA Act files 

are valid and reliable. The SAO’s statement should include explanations for 

misalignments and legitimate differences. 

In 2017, we reported that DHS could not align nearly $1.9 billion (38 percent) 

of its total obligations associated with award transactions for FY 2017/Q2. In 

our opinion, DHS’ primary focus in the months leading up to its first quarterly 

submission was on resolving any critical data errors that could have prevented 

its spending data from being published on USAspending.gov. DHS did not 

focus its efforts on analyzing the award transaction misalignments until after 

successfully submitting the spending data to Treasury. Although the 

misalignments may be due to legitimate reasons16 associated with existing 

business processes, we were concerned that timing differences of 30 days or 

longer may not be legitimate. 

In comparison with the 2017 findings, our analysis from this audit showed 

DHS has improved the alignment of its total award obligations for FY 2019/Q1. 

We determined DHS could align17 almost $7 billion (96 percent) of its total 

obligations. Therefore, DHS reduced the amount of its misalignments from 

nearly $1.9 billion (38 percent) in FY 2017/Q2 to about $264 million (4 percent) 

in FY 2019/Q1. 

13 OMB Management Procedures Memorandum 2016-03 

14 OMB Memorandum M-18-16 

15 OMB Memorandum M-17-04 

16 Based on our analysis of the reporting schedules defined by financial, procurement, and 

financial assistance requirements, misalignments may be due to legitimate timing differences 

less than 30 days. Other misalignments may be explainable because agencies are not required 

to report certain types of awards in their financial or award management systems. 

17 Using the parameters of 3 months and within $1 of the obligation amount, we compared the 

absolute value of the total obligation amount for each unique award number from File C to File 

D1/D2. Misalignments were totaled for non-matching and matching award numbers. For 

example, a matching award of $2 million in File C compared to $1.9 million in File D1/D2 

would result in a $2 million misalignment because the difference was not within $1. 

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OFFICE OF INSPECTOR GENERAL 

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The improvement can be attributed to DHS’ implementation of a quarterly 

corrective action plan (CAP) process to target misalignments during its reviews of 

spending data quality. After processing components’ monthly spending data in 

the Department’s DAS system, RMT generated an automated Component DATA 

Act Checklist including feedback on the warnings, critical errors, and obligation 

dollars associated with award misalignments. Components researched the 

misalignments and developed a CAP to address the misalignments deemed 

unacceptable. The CAPs described reasons for the misalignments, corrective 

actions that would be taken to address them, and target dates for completing the 

actions. Components then resubmitted their corrected files as needed for 

reprocessing. RMT included the alignment results in the quarterly SAO 

Assurance Package with categorical explanations for each misalignment and 

legitimate differences. 

We nonetheless identified opportunities for DHS to strengthen its quarterly 

review procedures to further improve the spending data alignment. First, RMT 

guidance18 did not require components to research obligation dollar amount 

misalignments for awards where the award numbers matched between DATA 

Act files. Components were only required to research obligation misalignments 

when the award numbers did not match between DATA Act files. Of the 

$264 million associated with misalignments remaining after DHS completed its 

CAP process for FY 2019/Q1, we determined that $163 million (62 percent) was 

related to awards with matching award numbers. Researching and correcting 

such misalignments will enable more effective tracking of Federal spending. 

Second, components documented misalignments in their CAPs that did not clearly 

identify root causes with corrective actions for addressing them. For example, 

components entered “timing” as the reason to categorize nearly one-third of the 

non-matching awards between DATA Act files. Merely stating “timing” did not 

provide sufficient explanation for the cause of the misalignments. In other 

instances, components provided no reasons or corrective actions in their CAPs 

to address the misalignments. Also, RMT did not have a mechanism to track 

corrective actions needed to address misalignments until actions were completed. 

Clearly identifying root causes and tracking corrective actions through to 

completion should help prevent misalignments from occurring in subsequent 

submissions. 

Third, RMT did not require components to complete and submit CAPs for every 

month of the quarter. Although RMT provides an automated Component DATA 

18 RMT DATA Act, Component Corrective Action Planning (CAP) Operations Guide, October 23, 

2018, and File C Data Quality Report Production, December 7, 2018 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Act Checklist monthly, components only have to provide one CAP addressing 

misalignments for the first 2 months of the quarter. No CAP is required for the 

last month of the quarter. Quantifying the impact of this issue for the DHS’ 

FY 2019/Q1 DATA Act submission was difficult because the Federal 

Government shutdown in December 2018 disrupted its quarterly CAP process. 

Specifically, after the shutdown ended and Treasury extended the DATA Act 

reporting deadline, DHS completed its CAP process in the March 2019 timeframe. 

RMT disclosed that DHS Headquarters and FEMA successfully researched and 

corrected nearly $2.3 billion in financial assistance awards that were misaligned 

as of January 31, 2019. However, we determined that $816 million (35 percent) 

of these awards exceeded the 30 days allowed to report them before the 

shutdown occurred.19 

DHS has opportunities to strengthen its quarterly review procedures and 

further improve its spending data alignment in future DATA Act submissions.20 

Without strong data reconciliation controls in place, the Department risks not 

meeting its goal of achieving the highest possible data quality. 

DHS’ DATA Act Submission Was of Moderate Quality 

The CIGIE IG Guide defines quality in agency DATA Act submissions as data 

that is complete, accurate, and reported on a timely basis. According to the 

guide, these attributes are measured21 as follows: 

x Completeness is measured as the percent of required data elements 

reported in the appropriate file. 

x Accuracy is measured as the percent of properly reported data elements 

that match to source documentation such as contracts and grants. 

x Timeliness is measured as the percent of required data elements reported 

in accordance with the reporting schedules defined by the financial, 

procurement, and financial assistance requirements. 

19 The Federal Funding Accountability and Transparency Act of 2006 requires agencies to report 

financial assistance awards within 30 days of award date. We determined $816 million of the 

$2.3 billion was awarded prior to November 23, 2018. Therefore, DHS should have reported 

these awards prior to the government shutdown beginning on December 22, 2018. 

20 Refer to OIG recommendation 2 and DHS’ response starting on page 19 for more information. 

21 According to the CIGIE IG Guide, optional elements are considered not applicable for testing 

purposes if agencies do not report them. However, if agencies do report optional elements, the 

agency’s OIG will test the completeness, accuracy, and timeliness of these elements. 

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OFFICE OF INSPECTOR GENERAL 

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The DATA Act requires the OIG of each Federal agency to review a statistically 

valid sample of the agency’s spending data. The CIGIE IG Guide states that the 

attribute (i.e., completeness, accuracy, or timeliness) with the highest projected 

error rate in the sample determines the overall data quality of the agency’s 

DATA Act submissions. For example, if the attribute with the highest error rate 

in the sample is 20 percent or less, overall data quality for the sample is high. 

Table 3 provides the criteria for determining whether data quality level is high, 

moderate, or low based on the highest error rate. 

Table 3. Determination of Sample Data Quality 

Error Rate Quality Level 

0% – 20% High 

21% – 40% Moderate 

41% and above Low 

 Source: CIGIE IG Guide 

Using the CIGIE IG Guide, we found the quality of DHS’ spending data was 

moderate for a statistically valid sample of 375 procurement and financial 

assistance awards. Specifically, the data was complete and accurate, but not 

timely. The overall data quality was moderate because the timeliness attribute 

had the highest projected error rate in the total sample, and the error rate was 

between 21 and 40 percent. A breakdown of the projected error rates by 

attribute and the overall quality determination for each award type is provided 

in table 4. 

Table 4. Projected Error Rates and Data Quality Determination 

Attribute Procurement 

(184 Records) 

Financial 

Assistance 

(191 Records) 

Total Sample 

(375 Records) 

Completeness 0.68% 10.06% 5.46% 

Accuracy 6.58% 26.02% 16.48% 

Timeliness 6.53% 67.19% 37.43% 

Quality High Low Moderate 

Source: DHS OIG analysis of agency records 

www.oig.dhs.gov 13 OIG-20-62 
 

 

 

 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Procurement Data Elements Were High Quality 

As shown in table 4, sampled data elements for procurement awards were high 

quality for completeness, accuracy, and timeliness because DHS had sufficient 

policies, procedures, and internal controls to assess the quality of the data entered 

into FPDS-NG. For example, pursuant to OMB policy22 DHS conducts annual 

verification and validation reviews to ensure procurement award records are 

reported accurately and timely in FPDS-NG. Also, the DHS Office of the Chief 

Procurement Officer holds monthly meetings with component FPDS-NG experts to 

provide lessons learned and training. Based on the results of the Department’s 

FPDS-NG review completed for FY 2018, the DHS Chief Procurement Officer certified 

to OMB that its overall error rates for accuracy and timeliness were 3.1 percent and 

5.1 percent, respectively. The Department’s FY 2018 results were generally 

consistent23 with our audit results for DHS’ FY 2019/Q1 DATA Act submission. 

Financial Assistance Data Elements Were Low Quality 

Sampled data elements for financial assistance awards, as shown in table 4, were 

low quality because FEMA did not report 67 percent of its award elements to FABS 

within 30 days24 of the award date as required. Specifically, system limitations 

adversely affected the timeliness of reporting for awards associated with FEMA’s 

National Flood Insurance Program (NFIP), and a systems integration issue created 

delays in reporting on FEMA’s grant awards. These were the two most systemic, 

material issues impacting the timeliness of financial assistance reporting for DHS. 

FEMA’s Legacy NFIP System Had Significant Capability Gaps 

FEMA’s legacy system for managing daily NFIP business operations had 

significant capability gaps and no longer met the program’s existing needs. 

Examples of these gaps included, but were not limited to, the following: 

Processing NFIP award data could take up to 60 days because the legacy 

system lacked automation. FEMA receives NFIP data from numerous 

sources — insurance companies, vendors, and agents — comprising 

thousands of transactions including policy issuances, endorsements, and 

claims. FEMA had to manually export the data for further analysis. 

22 OMB Office of Federal Procurement Policy Memorandum, Improving Acquisition Data Quality 

for Fiscal Years 2009 and 2010, October 7, 2009 

23 Consistent with OMB policy, DHS reviews the accuracy of 25 data elements for statistically 

sampled procurement records as part of its annual verification and validation reviews. The 

CIGIE IG Guide requires OIG to review 15 of these 25 elements for DATA Act testing purposes. 

24 We did not include the 35 days associated with the government shutdown in assessing 

timeliness of the sampled financial assistance records. 

www.oig.dhs.gov 14 OIG-20-62 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

x The legacy system improperly aggregated NFIP awards for organizations 

and individuals. According to Treasury DAIMS guidance, aggregate 

records should only be used to avoid reporting a recipient’s personallyidentifiable information when the award is made to an individual. Awards 

to organizations should be fully reported in a non-aggregate form. 

x The legacy system did not allow stakeholders to upload and attach key 

documents to a specific insurance policy or claim. FEMA received 

documents through the mail or by email, and then uploaded them to a 

SharePoint site for manual review. Communications were not tracked to 

a unique policy or claim, resulting in an inefficient process. 

The DHS SAO assurance statement disclosed that FEMA’s NFIP award data 

reported for FY 2019/Q1 — $990 million — exceeded the 30-day timeliness 

standard. Also, FEMA could not provide source documentation for the 32 NFIP 

awards in our audit sample. Without source documentation, we were unable to 

validate the accuracy of the award dates, and we could not verify that these 

aggregate records complied with the Treasury DAIMS guidance. Therefore, we 

concluded the applicable elements were incomplete, inaccurate, and untimely. 

At the time of our audit in February 2020, FEMA was in the process of 

implementing a new system to replace its legacy NFIP system and address these 

system limitations. Key requirements for the new system include processing 

millions of NFIP transactions on a real-time basis, automating standard business 

processes, providing interfaces with key FEMA and NFIP systems to create 

financial reports, and being DATA Act compliant. The target date for testing the 

timeliness of the NFIP award data under the new system is FY 2020/Q3. 

Systems Integration Issue Impacted FEMA’s Grant Reporting 

While researching misalignments as part of DHS’ quarterly CAP process, FEMA 

discovered a systems integration issue that prevented the transfer of grant 

award data from the financial system to the grant management system. 

Specifically, the grant management system did not transfer and report data on 

awards occurring on the 1st and 16th of the month. Although the CAP process 

enabled FEMA to identify and correct more than $500 million in misalignments 

prior to the FY 2019/Q1 certification deadline, this issue still prevented FEMA 

from reporting the grant awards to FABS within 30 days of award date as 

required. Additionally, FEMA did not identify the systemic nature or the root 

cause of the systems integration issue until FY 2019/Q4. 

DATA Act submissions of moderate quality can lead users to inadvertently 

draw inaccurate information or conclusions from the data provided. Although 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

DHS mitigates this risk through its CAP and discloses known timeliness issues 

in its SAO assurance statement on USAspending.gov, more needs to be done to 

address these recurring challenges.25 

DHS Implemented and Used Government-wide Data Standards 

But Could Improve Reporting on Certain Data Elements 

In May 2015, OMB and Treasury published26 57 data standards (commonly 

referred to as data elements) and required Federal agencies to report financial 

data in accordance with them to fulfill DATA Act requirements. Treasury used 

these standards to develop the DAIMS, which provides technical guidance 

about what data to report in DATA Act files, including the authoritative sources 

and the submission format for the data elements. The standards are intended 

to help taxpayers and policy makers understand how Federal agencies spend 

taxpayer dollars and improve agencies’ spending oversight and decision making. 

To assess DHS’ implementation and use of the government-wide financial data 

standards, we reviewed the Department’s FY 2019/Q1 DATA Act submission to 

ensure all required elements were included and conformed with established 

standards. We found that DHS generally implemented and consistently used 

the data standards, but could improve its reporting for certain data elements to 

make information on Federal spending more transparent to the public. For 

instance, as discussed previously, DHS improperly assigned unknown program 

activity codes and improperly aggregated awards for organizations. 

Additionally, we identified data elements that had error rates greater than 

20 percent. Although the inaccuracies in these data elements did not 

materially impact the overall projected rate of sample accuracy, they 

represented inconsistencies in the implementation and use of the standards. 

Data elements that did not consistently comply with the standards included: 

Award Description. Agencies are required to report a brief description of 

the award purpose using plain English. However, DHS used shorthand, 

acronyms, or terminology that could only be understood by officials who 

made the award. Also, DHS described reasons for award modifications 

(e.g., “deobligate excess funds and closeout”) rather than the goods or 

services being procured. DHS officials believed the intent of this element 

was to inform the public of changes made rather than the original 

purposes of the awards themselves. 

25 Refer to OIG recommendation 3 and DHS’ response starting on page 19 for more information. 

26 The 57 data standards established by OMB and Treasury pursuant to the DATA Act can be 

found at https://portal.max.gov/portal/assets/public/offm/DataStandardsFinal.htm. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

x	 Place of Performance. Agencies are required to report the location where 

the work under contract award predominantly will be accomplished. For 

goods, this location is generally the principal plant or place of business 

where the items will be produced or supplied from stock. For services, 

this location is where the services will be performed. However, contracting 

personnel did not accurately report the location of award performance 

because they did not clearly understand the data definitions. 

x	 Unique Record Identifier. Agencies must not report the unique record 

identifier in lieu of the award modification number. Due to the cost to 

modify its legacy system to report modification numbers, FEMA used 

unique identifiers to link award records to comply with FABS validation 

rules. According to Treasury, this type of misuse hinders the public’s 

understanding of the data, and makes it difficult for Treasury to display 

data consistently on USAspending.gov. 

x	 Awardee or Recipient Legal Entity. Agencies must ensure the official 

entity information — legal business name and physical address — 

reported to USAspending.gov for financial assistance is identical to the 

System for Award Management at the time of award. Due to field 

limitations in FEMA’s financial system, these data elements were often 

truncated or combined across several fields. For instance, the address 

sometimes contained part of the legal entity name. FEMA also 

misreported the mailing address as the physical address. DHS officials 

did not view these as pervasive issues requiring corrective action. 

Inconsistencies in the implementation and use of the established standards 

undermines the DATA Act reporting objective of providing the public with 

quality and transparent data on USAspending.gov.27 

DHS Developed a Plan to Manage Risks to Data Quality 

OMB policy28 requires each agency to develop and maintain a DQP that achieves 

DATA Act objectives. The DQP must identify risks to data quality in Federal 

spending data while leveraging existing processes, and implement a control 

structure to manage such risks in accordance with OMB Circular A-123, 

Management’s Responsibility for Enterprise Risk Management and Internal Control. 

The DQP should address organizational processes that provide internal controls 

for spending reporting, a plan for testing high-risk reported data, and actions 

taken to manage identified risks. The agency must review and assess its DQP 

27 Refer to OIG recommendation 4 and DHS’ response starting on page 20 for more information. 

28 OMB Memorandum M-18-16 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

annually for 3 years, or until it determines sufficient controls are in place to 

achieve the reporting objective. 

DHS finalized the first version of its DQP on March 15, 2019. Our analysis 

showed the DQP complied with OMB Circular A-123 by documenting internal 

control processes relevant to DATA Act reporting. The DQP identifies roles and 

responsibilities of stakeholders involved in the data flow process, the 

governance structure, and the necessary steps to report complete, accurate, 

and timely data. Also, the DQP includes procedures to assess and identify 

high-risk spending data, including a plan for testing the completeness, 

accuracy, and timeliness of the high-risk data elements identified. 

Although DHS’ Risk Management and Assurance Division completed its risk 

assessment to identify high-risk data elements, components did not complete 

testing prior to the Department’s FY 2019/Q1 DATA Act submission. At the 

time of our audit in April 2019, components were testing the high-risk data 

elements. Upon completing this testing, DHS should update its DQP accordingly 

to ensure improvements are implemented. In addition, DHS should update the 

DQP as needed to address our audit findings and recommendations. 

It is important to note that DHS had processes and controls in place prior to 

the OMB DQP requirement, and it leveraged those controls to improve the 

quality of its data. These controls included annual reviews of procurement 

data by the Office of the Chief Procurement Officer, validation assessments of 

financial assistance data by the Financial Assistance Policy and Oversight 

Division, and quarterly CAP reviews of DATA Act submissions by the Office of 

the Chief Financial Officer. As the DQP matures, DHS should identify and 

eliminate duplicative and unnecessary processes that do not address risks. 

Successful implementation of the DQP should provide a comprehensive list of 

controls that all Department levels can implement to manage risks to the 

quality of Federal spending data and achieve DATA Act compliance.29 

Conclusion 

To enable more effective tracking of Federal spending, DHS must continue to 

take action to accurately align its budgetary data with the President’s budget, 

reduce award misalignments across DATA Act files, improve the timeliness of 

financial assistance reporting, implement and use government-wide data 

standards, and update its DQP to address risks to data quality. Without these 

actions, DHS will continue to experience challenges in meeting its goal of 

achieving the highest possible data quality for submission to USAspending.gov. 

29 Refer to OIG recommendation 5 and DHS’ response starting on page 20 for more information. 

www.oig.dhs.gov 18 OIG-20-62 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendations 

Recommendation 1: We recommend the Chief Financial Officer improve the 

alignment of DHS’ budgetary data with the authoritative sources that the 

Treasury Broker uses for DATA Act validation by: 

x updating the Department’s program activity data in the OMB’s MAX 

Collect list to align $3.4 billion in award obligations from DHS’ 

FY 2019/Q1 submission with the President’s budget; 

x issuing guidance clarifying that DHS components should only use program 

activity code “0000” and program activity name “Unknown/Other” when 

there are no obligations reported in the appropriation account; and 

x developing a solution to ensure DHS components maintain awareness of 

and comply with any changes the Office of Management and Budget 

makes to the reporting deadline for the quarterly MAX Collect exercise. 

Recommendation 2: We recommend the Chief Financial Officer strengthen 

the internal controls within DHS’ quarterly corrective action plan process by: 

x	 requiring DHS components to research and correct, as needed, matching 

award identification numbers with non-matching obligation amounts; 

x	 requiring DHS components to identify root causes for misalignments so 

the specific reasons for timing issues and the corrective actions needed 

to address them are clearly understood; 

x	 requiring DHS components to submit corrective action plans addressing 

misalignments on a monthly basis rather than once a quarter; and 

x	 developing an effective solution to continuously track misalignments 

from month to month until corrective actions are completed. 

Recommendation 3: We recommend the Chief Financial Officer improve the 

quality of the financial assistance award information reported in DHS’ DATA Act 

submissions for publication on USAspending.gov by: 

x	 implementing and testing the new system for managing and reporting 

National Flood Insurance Program (NFIP) awards until it addresses the 

limitations of the legacy system and becomes DATA Act compliant; 

www.oig.dhs.gov 19	 OIG-20-62 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

x developing standard operating procedures to document aggregation 

procedures for NFIP awards, including controls to ensure that awards to 

organizations are not aggregated with individuals, and data elements for 

aggregate awards are traceable to source documentation; and 

x correcting the root cause associated with the systems integration issue 

that resulted in more than $500 million in grant award misalignments 

within the Department’s FY 2019/Q1 DATA Act submission. 

Recommendation 4: We recommend the Chief Financial Officer develop and 

apply effective solutions to improve the implementation and use of the 

government-wide financial data standards for data elements associated with the 

award description, place of performance, unique record identifier, legal entity 

information, program activity data, and financial assistance aggregate reporting. 

Recommendation 5: We recommend the Chief Financial Officer strengthen 

the DHS Data Quality Plan to achieve the DATA Act reporting objective by: 

x	 completing testing of high-risk elements identified by the Risk 

Management and Assurance Division, and updating the control structure 

in the Data Quality Plan as necessary based on the test results; and 

x	 updating internal controls in the Data Quality Plan to address the audit 

findings and recommendations in this report. 

DHS Response and OIG Analysis 

DHS concurred with all five recommendations. Appendix B contains a copy of 

the Department’s response in its entirety. We also received technical comments 

and incorporated changes to the report where appropriate. A summary of the 

Department’s responses to the recommendations and our analysis follows. 

DHS Response to Recommendation 1: Concur. According to DHS, the 

Department’s data submitted in DATA Act File B (object class and program 

activity obligations and outlays) was complete and accurate for the first quarter 

of FY 2019. In addition, by July 31, 2019, the Department corrected the 

specific issues amounting to $3.4 billion we noted in the OMB MAX validation 

table. The DHS Office of the Chief Financial Officer’s RMT Division will 

enhance instructions to components’ budget units for verification and 

validation of the OMB MAX program activity table and crosswalk, which is used 

to derive OMB program activity data for the required DATA Act files. 

www.oig.dhs.gov 20	 OIG-20-62 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

However, the Department noted that circumstances not accounted for in the 

DAIMS guidance constrained DHS reporting related to: 1) accounts with less 

than $500,000 in obligations, 2) programs not reportable to the President’s 

Budget, and 3) expired accounts. Specifically, none of these scenarios have an 

established government-wide program activity mapping definition of current 

program activity. Consequently, using program activity code “0000” and name 

“Unknown/Other” is the only way DHS or any other department or agency can 

complete its submission when these scenarios arise. Furthermore, for DATA Act 

reportable obligations that are not reportable to the President’s Budget and other 

described scenarios, the DHS Office of the Chief Financial Officer staff will work 

with OMB examiners, as appropriate, to identify a satisfactory substitute code. 

The estimated completion date is September 30, 2020. 

OIG Analysis: The Department’s corrective action is responsive to the 

recommendation. The recommendation will remain open and resolved until the 

Department provides evidence to support that corrective actions are completed. 

DHS Response to Recommendation 2: Concur. According to the Department, 

on January 31, 2020, the DHS Data Act Team implemented an enhanced 

Component Corrective Action Plan process, documented in the DHS DATA Act 

File C: Component Guidebook and DHS DATA Act Data Quality Report Production 

Guide, that: 1) addresses researching and correcting matching award 

identification numbers with non-matching obligation amounts, 2) identifies the 

root causes of timing issue misalignments, and 3) continuously tracks 

misalignments until corrective actions are completed. As part of this process, 

the DHS Office of the Chief Financial Officer’s RMT personnel identify nonmatching awards and monitor component progress in addressing the root 

causes of misalignments on a monthly basis. DHS stated that it will provide 

the OIG copies of corroborating documentation supporting completion of the 

aforementioned actions under separate cover. DHS requested that we consider 

this recommendation resolved and closed, as implemented. 

OIG Analysis: The Department’s corrective action is responsive to the 

recommendation. The recommendation will remain open and resolved until the 

Department provides evidence to support that corrective actions are completed. 

DHS Response to Recommendation 3: Concur. The FEMA Headquarters’ 

DATA Act team will test the new NFIP system’s ability to: 1) provide files 

compliant with the DATA Act, and 2) review implementation of and update the 

existing FEMA DATA Act Validation Process and supplemental File C SOPs to 

ensure the procedures allow traceability to source documentation, as 

appropriate. The estimated completion date is December 31, 2020. 

www.oig.dhs.gov 21 OIG-20-62 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

OIG Analysis: The Department’s corrective action is partially responsive to the 

recommendation. Specifically, DHS’ response did not address correcting the 

root cause associated with the systems integration issue, which resulted in 

more than $500 million in grant award misalignments within the Department’s 

FY 2019/Q1 DATA Act submission. The recommendation will remain open and 

unresolved until the Department provides evidence to support that corrective 

actions are completed. 

DHS Response to Recommendation 4: Concur. DHS reported it is committed 

to providing high quality and transparent data to the public to facilitate more 

effective tracking of its spending. According to the Department, the DHS Office 

of the Chief Financial Officer and others are already taking actions to enhance 

implementation and use of government-wide financial data standards we 

recommended for selected data elements as described below: 

x	 Award Description. The award descriptions for both the base contract 

award and the modifications are complete and accurate and meet OMB 

and Treasury Department requirements for information posted publicly. 

For example, the award description data element on USAspending.gov 

clearly states the base award describes what is being purchased, and the 

modifications describe what is being altered. However, the DAIMS 

definition for award description should be clarified to include the 

requirements for base contract award and modifications. The DHS Office 

of the Chief Procurement Officer is working with the Government-wide 

Leveraging Data Strategic Asset-Policy Working Group to recommend a 

change to the DAIMS definition for this data element. This change is not 

for the general public or the agencies, but to clarify for the audit 

community what is required to be entered in this field for different 

contract actions. The estimated completion date is October 30, 2020. 

x	 Place of Performance. The DAIMS definition of place of performance is not 

clear or complete, as discussed in the Government Accountability Office 

report, DATA ACT: Quality of Data Submissions Has Improved but Further 

Action Is Needed to Disclose Known Data Limitations (GAO-20-75, 

November 8, 2019). The Government Accountability Office recommended 

that OMB and Treasury provide a clear definition of this data element to 

help agencies improve their data quality. As a follow-up to the 

Government Accountability Office recommendation, the DHS Office of the 

Chief Procurement Officer and Office of the Chief Financial Officer’s 

Financial Assistance and Policy Oversight Division will recommend that 

the Government-wide Leveraging Data Strategic Asset-Policy Working 

Group change the DAIMS definition for this data element. The estimated 

completion date is October 30, 2020. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

x	 Unique Record Identifier. According to the DAIMS “Practices and 

Procedures” in FY 2019 first quarter, for each unique financial assistance 

transaction, the Federal award identification number, unique record 

identifier, or a combination of these two elements from File C should 

match the information in File D2 or the Broker will generate a warning. 

Although this is not a best practice, it is permitted by the Treasury 

“Practices and Procedures” description, validation rules, and 

specifications listing modification numbers as optional. Personnel from 

the DHS Office of the Chief Financial Officer’s Financial Assistance and 

Policy Oversight Division are working with FEMA’s Headquarters DATA 

Act team to provide modification numbers on File D2 (financial 

assistance data), in addition to the unique record identifier. The 

estimated completion date is December 31, 2020. 

x	 Legal Entity Information. The DHS Office of the Chief Financial Officer’s 

Financial Assistance and Policy Oversight Division is working with the 

FEMA Headquarters DATA Act team to identify the root cause of the 

abbreviation, truncations, and concatenation issues in legal entity fields. 

The Department stated that the Financial Assistance and Policy 

Oversight Division will provide interim milestones under separate cover. 

The estimated completion date is March 31, 2023. 

x	 Program Activity Data. The DHS Office of the Chief Financial Officer’s 

RMT Division and the components’ budget divisions completed corrections 

on July 31, 2019, for specific issues identified in the draft report totaling 

$3.4 billion. Specifically, RMT addressed the major issues disclosed to 

the DATA Act Senior Accountable Official using procedures documented 

in the Department’s DATA Act Data Quality Report Production Guide. An 

ongoing reconciliation process is being performed quarterly between the 

RMT Division and the components’ budget divisions to fully align OMB’s 

MAX program activity table with DATA Act File B (object class and 

program activity obligations and outlays). RMT will provide the OIG 

copies of corroborating documentation supporting completion of the 

aforementioned actions under separate cover. 

x	 Financial Assistance Aggregate. FEMA’s Headquarters DATA Act team 

will develop procedures to ensure the new NFIP system aggregates to 

individuals when it is determined that individuals are the prime 

awardees. The estimated completion date is December 31, 2020. 

OIG Analysis: Although the Department’s corrective action is responsive to 

the recommendation, a statement in the management response regarding the 

award description element is not consistent with our audit findings. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Specifically, DHS stated that the award descriptions for both the base contract 

award and the modifications are accurate and meet OMB and Treasury 

requirements for information posted publicly. However, we concluded the award 

description element for the sampled procurement records had an accuracy 

error rate greater than 20 percent. DHS used shorthand, acronyms, or 

terminology that could only be understood by officials who made the award. 

Also, DHS described reasons for award modifications (e.g., “deobligate excess 

funds and closeout”) rather than the goods or services being procured. Our 

findings are consistent with the Government Accountability Office report, DATA 

ACT: Quality of Data Submissions Has Improved but Further Action Is Needed to 

Disclose Known Data Limitations (GAO-20-75, November 8, 2019). The 

recommendation will remain open and resolved until the Department provides 

evidence to support that corrective actions are completed. 

DHS Response to Recommendation 5: Concur. According to the Department, 

on September 30, 2019, DHS components completed testing of high-risk 

elements identified by the DHS Office of the Chief Financial Officer’s Risk 

Management and Assurance Division for FY 2019, and will continue this testing 

on an annual basis, as appropriate. Based on these test results, the DHS 

Headquarters DATA Act team will update the control structure of the Data 

Quality Plan to address the audit findings and recommendations in this draft 

report. The estimated completion date is March 31, 2021. 

OIG Analysis: The Department’s corrective actions are responsive to the 

recommendation. The recommendation will remain open and resolved until the 

Department provides evidence to support that the corrective actions are 

completed. 

www.oig.dhs.gov 24 OIG-20-62 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objectives, Scope, and Methodology 

Department of Homeland Security Office of Inspector General was established 

by the Homeland Security Act of 2002 (Public Law 107−296) by amendment to 

the Inspector General Act of 1978. 

The objectives of this audit were to assess the completeness, accuracy, 

timeliness, and quality of DHS’ FY 2019/Q1 spending data submitted for 

publication on USAspending.gov, and DHS’ implementation and use of the 

government-wide financial data standards. 

To answer our objectives we: 

x adopted the common methodology from CIGIE, Federal Audit Executive 

Council’s Inspectors General Guide to Compliance under the DATA Act; 

x reviewed guidance issued by OMB, Treasury, and DHS to understand 

any regulatory criteria related to DHS’ responsibilities for reporting 

budgetary and award data under the DATA Act; 

x interviewed officials from the DHS Office of the Chief Financial Officer’s 

Resource Management Transformation, Risk Management and Assurance, 

and Financial Assistance Policy and Oversight Divisions, as well as the 

DHS Office of the Chief Procurement Officer’s Acquisition Policy and 

Legislation Branch to gain an understanding of DHS’ implementation of 

the DATA Act and assess its DATA Act controls in place during FY 2019/Q1; 

x conducted site visits to interview the responsible personnel and test the 

internal controls for DATA Act implementation at nine DHS components 

including FEMA, United States Coast Guard, U.S. Customs and Border 

Protection, Cybersecurity and Infrastructure Security Agency, Federal 

Law Enforcement Training Centers, U.S. Citizenship and Immigration 

Services, Transportation Security Administration, U.S. Immigration and 

Customs Enforcement, and United States Secret Service; 

x reviewed and accessed KPMG’s FY 2018 opinion on DHS’ internal 

controls over agency source systems; 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

x selected a statistically valid sample30 of 375 procurement and financial 

assistance award records from DHS’ FY 2019/Q1 Files D1 and D2, 

certified and submitted for publication on USAspending.gov; and 

x obtained, reviewed, and tested documentation supporting the 375 

sampled records to assess (1) completeness, accuracy, timeliness, and 

quality of the spending data, and (2) DHS’ implementation and use of 

government-wide financial data standards. 

Regarding DHS’ internal controls, we limited the scope of our fieldwork to 

assessing the departmental and component-level controls supporting DHS’ 

DATA Act submission to Treasury for FY 2019/Q1. Specifically, we assessed 

the design, implementation, and operating effectiveness of the controls in place 

at both levels to extract, validate, and transmit the required spending data to 

achieve the intended outcomes of each objective. We also assessed the 

development and implementation of DHS’ data quality plan to identify and 

manage risks to data quality in Federal spending data. 

Based on an independent adverse opinion on DHS’ internal controls over its 

FY 2018 financial reporting, our professional judgment was that the internal 

control environment has not materially changed. As a result, we did not assess 

the internal controls over DHS’ or components’ financial reporting, including 

those over the information systems from which the required spending data was 

derived. 

We conducted this performance audit between March 2019 and April 2020 

pursuant to the Inspector General Act of 1978, as amended, and according to 

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 upon our 

audit objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based upon our audit objectives. 

30 Based on the CIGIE IG Guide, we selected a statistically valid sample using a confidence 

level of 95 percent, expected error rate of 50 percent, and a sample precision of 5 percent. 

www.oig.dhs.gov 26 OIG-20-62 
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Department of Homeland Security 

Appendix B 

DHS Response to the Draft Report 

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Department of Homeland Security 

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Department of Homeland Security 

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Department of Homeland Security 

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Department of Homeland Security 

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Department of Homeland Security 

Appendix C 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Under Secretary, Office of Strategy, Policy, and Plans 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

www.oig.dhs.gov 32 OIG-20-62 
Additional Information and Copies 

To view this and any of our other reports, please visit our website at: 

www.oig.dhs.gov. 

For further information or questions, please contact Office of Inspector General 

Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

Follow us on Twitter at: @dhsoig. 

OIG Hotline 

To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click 

on the red "Hotline" tab. If you cannot access our website, call our hotline at 

(800) 323-8603, fax our hotline at (202) 254-4297, or write to us at: 

Department of Homeland Security 

Office of Inspector General, Mail Stop 0305 

Attention: Hotline 

245 Murray Drive, SW 

Washington, DC 20528-0305