DATA ACT

As Reporting 

Deadline Nears, 

Challenges Remain 

That Will Affect Data 

Quality

Report to Congressional Addresses

April 2017

GAO-17-496

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-496, a report to 

congressional addressees

April 2017

DATA ACT

As Reporting Deadline Nears, Challenges Remain 

That Will Affect Data Quality

What GAO Found

Internal control weaknesses and other challenges pose risks to data 

quality. Material weaknesses and significant deficiencies reported in agencies’ 

financial audits and other challenges reported in Inspectors General (IG) 

readiness review reports show several widespread and longstanding issues that 

present risks to agencies’ abilities to submit quality data as required by the 

Digital Accountability and Transparency Act of 2014 (DATA Act). These issues 

fall into three categories: (1) accounting and financial management, (2) financial 

management systems, and (3) information technology security and controls. 

GAO has also reported weaknesses and challenges in government-wide 

financial management systems used for DATA Act reporting.

Challenges with guidance will impact data quality. Challenges related to how 

agencies report certain intragovernmental transactions, reconcile recipient 

address information, and align required DATA Act files with missing data 

continue to present risks to the quality of data displayed on USASpending.gov. 

The Office of Management and Budget (OMB) and the Department of the 

Treasury (Treasury) have stated that they do not expect to resolve these 

challenges before the May 2017 reporting deadline. Unresolved challenges 

affecting data quality could lead policymakers and the public to draw inaccurate 

conclusions from the data. This challenge underscores the need for OMB to 

address GAO’s open recommendation that it provide agencies with additional 

guidance to address data quality issues. GAO will continue to assess how OMB, 

Treasury, and agencies address data quality issues moving forward.

Limitations exist with data quality assurance processes. OMB guidance 

directs senior accountable officials at each agency to rely on existing assurance 

processes when they certify that their agencies’ DATA Act submissions are valid 

and reliable. However, GAO identified concerns regarding some existing 

assurance processes. For example, OMB directed agencies to use a General 

Services Administration assurance statement attesting to the quality of data in 

two source systems, but the assurance statement focuses on data security 

rather than data quality, and it is unclear whether it applies to both procurement 

and financial assistance data. OMB is aware of these issues and expects to 

finalize the assurance process in time for the May 2017 reporting deadline. 

Accordingly, GAO is not making a recommendation at this time but will assess 

the quality of the assurance process in future work.

Efforts to establish a data governance structure are still at an early stage. 

OMB has taken some actions to improve its data governance framework, but 

efforts to establish a fully functioning data governance structure are at an early 

stage with many specifics yet to be worked out. OMB formally chartered the Data 

Standards Committee as an advisory body in November 2016 to focus on 

clarifying existing data element definitions and identifying needs for new 

standards. The charter states that the committee will promote transparency by 

making the topics and outcomes of its proceedings public, but OMB has not kept

records of the committee’s meetings nor has the committee produced a work 

plan for moving forward. Public information about the committee’s activities and

outcomes would facilitate consultation with stakeholders, as required by the act. 

View GAO-17-496. For more information, 

contact J. Christopher Mihm (202) 512-6806 

or MihmJ@gao.gov and Paula M. Rascona 

(202) 512-9816 or RasconaP@gao.gov

Why GAO Did This Study

Across the federal government, 

agencies are making final preparations 

to submit the required data by the 

DATA Act’s May 2017 deadline. This 

represents the culmination of almost 3

years of effort by OMB, Treasury, and 

federal agencies to address many 

policy and technical challenges. 

Moving forward, attention will 

increasingly focus on another critical 

goal of the act: improving the quality of 

the data produced. 

Consistent with GAO’s mandate under 

the act, this is the latest in a series of 

reports reviewing the act’s 

implementation. This report examines 

(1) risks to data quality related to 

known material weaknesses and other 

deficiencies previously identified by 

GAO, IGs, and external auditors; (2) 

risks to data quality related to 

challenges in operationalizing policy 

and technical guidance; (3) agencies’ 

assurances of the quality of their data 

submissions; and (4) efforts taken to 

establish a data governance structure. 

GAO reviewed DATA Act 

implementation documents and 

auditors’ reports on known challenges 

and interviewed staff at OMB, 

Treasury, and other agencies.

What GAO Recommends

GAO recommends that the Director of 

OMB ensures that the Data Standards 

Committee publicly releases 

information about the topics of its 

proceedings and any resulting 

outcomes. OMB generally agreed with 

GAO’s recommendation. 
Page i GAO-17-496 Risks to Data Quality

Letter 1

Background 4

Internal Control Material Weaknesses, Significant Deficiencies, 

and Other Challenges Pose Risks to Federal Spending Data 

Quality 8

Reporting Challenges Related to Implementing DATA Act 

Guidance Will Affect Data Quality 16

OMB Guidance Directs Agencies to Leverage Existing Assurance 

Processes Despite Known Limitations 22

Efforts to Establish Data Governance Structure Are Still at an 

Early Stage 24

Conclusions 26

Recommendation for Executive Action 27

Agency Comments and Our Evaluation 27

Appendix I Objectives, Scope, and Methodology 30

Appendix II Status of GAO’s Recommendations Related to the DATA Act and Data 

Transparency 35

Appendix III Deficiencies Reported in CFO Act Agencies’ Fiscal Year 2016 Financial 

Reports that May Affect Data Quality 42

Appendix IV GAO Contacts and Staff Acknowledgements 44

Related GAO Products 45

Table

Table 1: Deficiencies Auditors Reported in Chief Financial Officers 

Act of 1990 (CFO Act) Agencies’ Fiscal Year 2016 

Financial Reports That May Affect Data Quality 42

Contents
Page ii GAO-17-496 Risks to Data Quality

Abbreviations

ASP Award Submission Portal

CIGIE Council of the Inspectors General on Integrity and

 Efficiency

DAIMS DATA Act Information Model Schema

DATA Act Digital Accountability and Transparency Act of 2014

FAR Federal Acquisition Regulation

FFATA Federal Funding Accountability and Transparency Act of

 2006

FFMIA Federal Financial Management Improvement Act of 1996

FPDS-NG Federal Procurement Data System-Next Generation

FSRS Federal Funding Accountability and Transparency Act

 Subaward Reporting System

GPRAMA GPRA Modernization Act of 2010

GSA General Services Administration

HHS Department of Health and Human Services

IQA Information Quality Act

OFPP Office of Federal Procurement Policy

IG Office of Inspector General

OMB Office of Management and Budget

SAO senior accountable official

SAM System for Award Management

SBA Small Business Administration

Treasury Department of Treasury

USDA United States Department of Agriculture

USPS United States Postal Service

USSGL United States Standard General Ledger

VA Department of Veterans Affairs

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-17-496 Risks to Data Quality

441 G St. N.W.

Washington, DC 20548

April 28, 2017

Congressional Addressees:

In the 3 years since the Digital Accountability and Transparency Act of 

2014 (DATA Act) became law, the Office of Management and Budget 

(OMB), the Department of the Treasury (Treasury), and federal agencies 

have taken significant steps in preparing to make more complete and 

accurate federal spending data available to the public in May 2017. The 

DATA Act requires OMB and Treasury to increase the types and 

transparency of spending data available to agencies, Congress, and the 

public by establishing standards to enable the reporting and tracking of 

government-wide spending at multiple points in the spending lifecycle.1

The DATA Act also requires agencies to report the data in accordance 

with those standards on USASpending.gov and requires federal 

inspectors general (IG) to assess how their respective agencies 

implement and use data standards, as well as the completeness, 

timeliness, and accuracy of the data their agencies submit.

Consistent with our mandate under the act, this is the latest in a series of 

GAO reports reviewing DATA Act implementation. Our prior reviews have 

identified several challenges related to OMB’s and Treasury’s efforts to 

standardize data element definitions and develop a technical schema to 

facilitate agency reporting. If unaddressed, these challenges could 

increase the risk of inconsistent and incomparable reporting. Our previous 

work has also identified concerns including inadequate guidance, tight 

time frames, competing priorities, a lack of funding, and system 

integration issues reported by agencies that could impede effective and 

timely implementation as well as the need for OMB to establish a data 

governance structure to help ensure the integrity of the standards over 

time.2

This review focuses on what is already known about existing challenges 

that affect the quality of agency financial data as well as issues that will 

affect data quality as agencies begin to report under the act. More 

 1

Pub. L. No. 113-101, 128 Stat. 1146 (May 9, 2014). The DATA Act amended the Federal 

Funding Accountability and Transparency Act of 2006 (FFATA). Pub. L. No. 109-282, 120 

Stat. 1186 (Sept. 26, 2006), codified at 31 U.S.C. § 6101 note. 

2

For a list of related GAO products, see page 45.

Letter
Page 2 GAO-17-496 Risks to Data Quality

specifically, this report addresses the following: (1) risks to data quality 

related to known material weaknesses and other deficiencies, including 

internal controls over financial reporting, that have been identified in 

selected previous audits, reviews, and reports conducted by GAO, IGs 

and external auditors; (2) risks to data quality related to challenges in 

operationalizing DATA Act policy and technical guidance; (3) approaches 

that agencies will use to provide assurances of the quality of their data 

submissions and any associated limitations; and (4) efforts taken to 

establish a data governance structure. We also update the status of 

OMB’s and Treasury’s efforts to address our previous recommendations 

related to DATA Act implementation, 9 of which remain open.

To assess potential risks to data quality related to known material 

weaknesses3 and other significant deficiencies,4 including internal 

controls over financial reporting, that have been identified in selected 

previous audits, reviews, and reports by us, IGs, and external auditors, 

we examined: (1) the extent to which agencies’ independent auditors 

have reported material weaknesses, significant deficiencies, and other 

challenges, and (2) the extent to which we previously reported issues with 

government-wide financial management systems used to report spending 

data to USASpending.gov. We reviewed the Chief Financial Officers Act 

of 1990 (CFO Act) agencies’ fiscal year 2016 Performance and 

Accountability Reports (PAR) and Agency Financial Reports (AFR) to 

identify material weaknesses, significant deficiencies, and other 

challenges that could affect the quality of the data submitted by agencies.

We also reviewed these agency reports for any auditor-identified 

noncompliance with the Federal Financial Management Improvement Act 

of 1996 (FFMIA) to identify factors that may increase the risk to reporting 

 3

A material weakness is a deficiency, or a combination of deficiencies, in internal control 

over financial reporting such that there is a reasonable possibility that a material 

misstatement of the entity’s financial statements will not be prevented, or detected and 

corrected, on a timely basis. A deficiency in internal control exists when the design or 

operation of a control does not allow management or employees, in the normal course of 

performing their assigned functions, to prevent, or detect and correct, misstatements on a 

timely basis.

4

A significant deficiency is a deficiency, or a combination of deficiencies, in internal control 

that is less severe than a material weakness, yet important enough to merit attention by 

those charged with governance.5

Pub. L. No. 104-208, div. A., title VIII, §§ 801-808, 110 

Stat. 3009, 3009-389 to 3009-393 (Sept. 30, 1996) codified at 31 U.S.C. § 3512 note.
Page 3 GAO-17-496 Risks to Data Quality

quality data.5 We reviewed readiness review reports issued by IGs to 

identify reported issues and challenges related to DATA Act 

implementation and to ensure we had a comprehensive understanding of 

IG-identified issues and challenges that could affect the quality of 

spending data reported under the DATA Act.6 In addition, we reviewed 

our previous reports to identify reported deficiencies in government-wide 

systems that could affect the quality of spending data submitted to 

USASpending.gov. Although the conditions observed in these reports 

may not be present in all federal agencies and systems, they illustrate 

conditions that increase the risk and effects to agency data quality.

To assess the potential risks to data quality related to challenges in 

operationalizing DATA Act policy and technical guidance while 

implementing the act, we examined (1) the extent to which the two 

selected agencies have been able to submit, validate, and certify their 

data submissions to the DATA Act broker and any challenges they 

reported; and (2) the steps OMB and Treasury have taken to address 

known reporting challenges. We reviewed technical documentation 

related to the schema version 1.01 and the broker to understand the 

reporting structure, broker functionality, and validation processes. We 

selected two agencies—the Department of Health and Human Services 

(HHS) and the U.S. Department of Agriculture (USDA)—to examine their 

experiences reporting data. We selected these agencies based on 

whether they were in compliance with existing federal requirements for 

federal financial management systems; the type of federal funding 

provided (such as grants, loans, or procurements); and their status as 

federal shared service providers for financial management. Although the 

agencies’ experiences are not generalizable, they illustrate different 

conditions and challenges under which agencies are implementing the 

act.

We reviewed our past reports to identify data quality issues related to 

DATA Act implementation, and we reviewed OMB policy guidance 

intended to facilitate agency reporting. We interviewed OMB staff and 

Treasury officials to understand any steps they have taken to respond to 

previously identified challenges, agency requests for clarification on 

 5

Pub. L. No. 104-208, div. A., title VIII, §§ 801-808, 110 Stat. 3009, 3009-389 to 3009-393 

(Sept. 30, 1996) codified at 31 U.S.C. § 3512 note.

6

For additional information on our review of inspectors general readiness reviews, see 

GAO, DATA Act: Office of Inspector General Reports Help Identify Agencies’ 

Implementation Challenges, GAO-17-460 (Washington, D.C.: Apr. 26, 2017).
Page 4 GAO-17-496 Risks to Data Quality

reporting requirements, and any plans for additional guidance. We also 

met with OMB staff and Treasury officials to obtain information on the 

status of efforts to address our previous recommendations related to 

providing policy and technical guidance.

To assess the approach that agencies will use to assure the quality of 

their data submissions and any associated limitations we (1) reviewed 

relevant OMB policy guidance; (2) spoke with HHS and USDA officials, 

and requested and reviewed documentation—where applicable—to 

understand any concerns they have or challenges they are facing or 

expect to face during the assurance process; and (3) interviewed OMB 

staff and Treasury officials to better understand the assurance process, 

and asked about plans for additional guidance. To describe OMB’s and 

Treasury’s efforts to establish a data governance structure, we reviewed 

documentation provided by OMB and met with OMB staff and Treasury 

officials.

We also met with representatives of organizations with expertise in data 

governance to obtain additional information about how key practices 

described in our December 2016 report have been implemented in data 

governance frameworks. Additional details regarding our objectives, 

scope, and methodology are provided in appendix I.

We conducted this performance audit from January 2017 to April 2017 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.

Signed into law on May 9, 2014, the DATA Act expanded on previous 

federal transparency legislation by requiring the disclosure of federal 

agency expenditures and linking agency spending information to federal 

program activities so that both policymakers and the public can more 

effectively track federal spending. The DATA Act requires governmentwide reporting on a greater variety of federal funds, such as budget and 

financial information, as well as tracking of these funds at multiple points 

in the federal spending lifecycle. To improve the quality of these data, the 

act requires that agency-reported award and financial information comply 

with new data standards established by OMB and Treasury. These 

standards specify the items to be reported under the DATA Act and 

define and describe what is to be included in each element with the aim of 

Background
Page 5 GAO-17-496 Risks to Data Quality

ensuring that information will be consistent and comparable. The act 

identifies OMB and Treasury as the two agencies responsible for leading 

government-wide implementation.

Two key components of ensuring the accuracy, completeness, and 

consistency of federal spending data are OMB releasing policy guidance 

and Treasury developing technical guidance for the agency submissions 

and publication of the data required under the act. Toward that end, OMB 

has taken a number of steps to help agencies meet their reporting 

requirements, including establishing 57 standardized data element 

definitions for reporting federal spending information, issuing guidance to 

operationalize selected standards and clarify agency reporting 

requirements, and meeting with agencies to assess their readiness to 

meet the reporting requirements under the act. Specific actions include 

the following:

• In May 2015, OMB issued initial guidance to federal agencies on 

reporting requirements pursuant to the Federal Funding Accountability 

and Transparency Act (FFATA) as well as the new requirements that 

agencies must employ pursuant to the DATA Act.7 The guidance also 

directs agencies to (1) implement data definition standards for 

collecting and reporting agency-level and award-level data by May 9, 

2017; (2) implement a standard data exchange format for providing 

data to Treasury to be displayed on USASpending.gov or a successor 

site; and (3) link agency financial systems with award systems by 

continuing to use specified unique identification numbers for financial 

assistance awards and contracts.

• In May 2016, OMB released guidance on reporting financial and 

award information required under the act.8 This guidance addresses 

(1) reporting financial and award level data, (2) linking agency award 

and financial systems using a unique award identifier, and (3) 

assuring that data submitted to Treasury for publication on 

USASpending.gov are sufficiently valid and reliable.

• In November 2016, OMB issued additional guidance in response to 

questions and concerns reported by agencies. This guidance 

 7

OMB, Increasing Transparency of Federal Spending by Making Federal Spending Data 

Accessible, Searchable, and Reliable, OMB Memorandum M-15-12 (May 8, 2015).

8

OMB, Additional Guidance for DATA Act Implementation: Implementing a Data Centric 

Approach for Reporting Federal Spending Information, Management Procedures 

Memorandum No. 2016-03 (Washington, D.C.: May 3, 2016).
Page 6 GAO-17-496 Risks to Data Quality

specifies DATA Act reporting responsibilities for intragovernmental 

transactions, explains how to report financial assistance awards with 

personally identifiable information, and clarifies the senior accountable 

official (SAO) assurance process over the data submitted to the DATA 

Act broker, a system to standardize data formatting and assist 

reporting agencies in validating their data prior to submission.9

• The May and November 2016 guidance also directs agency SAOs to 

leverage existing data quality and management controls established 

in statute, regulations, or federal policy when submitting their 

assurance over the data.

In addition to issuing policy guidance to help agencies meet their 

reporting requirements under the act, OMB’s Controller and Treasury’s 

Fiscal Assistant Secretary conducted a series of meetings with CFO Act 

agencies to obtain information on any challenges that could impede 

effective implementation and assess agencies’ readiness to report 

required spending data in May 2017.

Treasury also led efforts to develop the technical guidance and reporting 

systems to facilitate agency reporting. In April 2016, Treasury released 

the DATA Act Information Model Schema (DAIMS), or schema version 

1.0, which provides information on how to standardize the way financial 

assistance awards, contracts and other financial and non-financial data 

will be collected and reported under the DATA Act.10 A key component of 

the reporting framework laid out in the schema is the DATA Act broker.

According to Treasury guidance documents, agencies are expected to 

submit three files sourced from their financial management systems to the 

broker. The broker is also expected to extract award and sub-award 

information from existing award reporting systems that currently supply 

award data (covering federal assistance including grants and loans, as 

well as procurements) to USASpending.gov.

These award reporting systems—including the Federal Procurement Data 

System-Next Generation (FPDS-NG), System for Award Management 

(SAM), the Award Submission Portal (ASP), and the FFATA Subaward 

Reporting System (FSRS)—compile information submitted by agencies 

 9

Treasury’s DATA Act Implementation Playbook requires agencies to identify an SAO who 

is responsible for their agency’s implementation of the DATA Act and who is an executive 

officer with enough seniority and expertise to manage a project across multiple offices and 

federal spending communities.

10Department of the Treasury, DATA Act Information Model Schema v1.0 (Apr. 29, 2016).
Page 7 GAO-17-496 Risks to Data Quality

and award recipients to report, among other things, procurement and 

financial assistance award information required under FFATA.11 A more 

detailed discussion of the broker and the agency file submission process 

can be found in our August 2016 correspondence.12 In addition to 

developing the schema version 1.0 and the broker, Treasury also issued 

an implementation playbook that outlines 8 steps and a recommended 

timeline for agency implementation, and hosted multiple meetings, 

including weekly office hour calls and monthly technical workshops, to 

help agencies prepare and test their data for submission to the broker.

To help improve the quality of the data, the act also requires agencies’

IGs and GAO to assess and report on the completeness, timeliness, 

quality, and accuracy of spending data submitted by federal agencies. 

The first IG reports were due to Congress in November 2016. However, 

agencies are not required to submit spending data in compliance with the 

act until May 2017. As a result, the IGs did not report on the spending 

data in November 2016. The Council of the Inspectors General on 

Integrity and Efficiency (CIGIE) developed an approach to address what it 

describes as the IG reporting date anomaly and maintain early IG 

engagement with the agencies.13

CIGIE encouraged but did not require the IGs to undertake assessments 

of their respective agencies’ readiness to submit spending data in 

accordance with DATA Act requirements and delayed issuance of the 

mandated audit reports to November 2017. The Federal Audit Executive 

Council DATA Act Working Group—established by CIGIE to assist the IG 

community in understanding and meeting its DATA Act oversight 

requirements—issued the DATA Act Readiness Review Guide (version 

2.0) on June 2, 2016, to guide IGs in conducting their readiness reviews. 

 11The information displayed on USASpending.gov is derived from several sources. 

Procurement data are imported from FPDS-NG, which collects information on contract 

actions. SAM is the primary database for information on potential government business 

partners in which those wishing to do business with the federal government must register. 

ASP is the platform used by federal agencies to report financial assistance data. FSRS 

provides data on first-tier sub-awards reported by prime recipients.

12GAO-16-824R.

13CIGIE is an independent entity established within the executive branch to address 

integrity, economy, and effectiveness issues that transcend individual government 

agencies and aid in establishing a professional, well-trained, and highly skilled workforce 

in Offices of Inspectors General. CIGIE’s mission includes identifying, reviewing, and 

discussing areas of weakness and vulnerability in federal programs with respect to fraud, 

waste, and abuse.
Page 8 GAO-17-496 Risks to Data Quality

According to the review guide, the main objectives of the IG readiness 

reviews are to assess whether an agency’s DATA Act implementation 

plan or process is “on track to meet the requirements of the DATA Act,”

and to provide, as needed, recommendations or suggestions on how to 

improve the agency’s likelihood of compliance with the requirements of 

the DATA Act.

As of February 2017, 22 of the 24 CFO Act agencies had issued annual 

financial reports for fiscal year 2016 and 19 of the 22 CFO Act agencies’

auditors reported material weaknesses and/or significant deficiencies in 

internal control over financial reporting in their audit reports that may 

affect the quality of information reported under the DATA Act. In addition, 

as of February 2017, 20 of the 24 CFO Act agencies’ IGs had issued 

readiness review reports. Of these, 16 IGs identified a range of issues 

and challenges which may affect agencies’ abilities to produce quality 

data for submission to Treasury as part of the DATA Act reporting 

requirements.

Further, 9 of the 22 CFO Act agencies’ auditors reported agencies’

financial management systems did not substantially comply with Section 

803(a) of FFMIA, which may limit an agency’s ability to provide reliable 

and timely financial information for managing day-to-day operations and 

to produce reliable financial statements, maintain effective internal 

control, and comply with legal and regulatory requirements, including the 

DATA Act.

Our analysis of material weaknesses, significant deficiencies, and other 

challenges reported in agency annual financial reports and agency IGs’

DATA Act readiness reviews identified data quality issues and challenges 

in three broad areas that increase the risk agencies may not be able to 

Internal Control 

Material Weaknesses, 

Significant 

Deficiencies, and 

Other Challenges 

Pose Risks to Federal 

Spending Data 

Quality

Financial Audits and 

Readiness Reviews 

Indicate That Agencies 

Face Data Quality Issues 

in Three Broad Areas
Page 9 GAO-17-496 Risks to Data Quality

report complete, timely, and accurate data as required under the DATA 

Act by May 2017.

These issues and challenges relate to internal controls over financial 

reporting and financial management operations, properly recorded and 

reconciled accounting balances and transactions, and other issues 

related to the proper use of accounting practices in accordance with U.S. 

generally accepted accounting principles. Fourteen of the 22 CFO Act 

agencies’ auditor’s reports noted material weaknesses and significant 

deficiencies, and 14 of the 20 IG readiness reviews reported issues or 

challenges related to accounting and financial management. See 

appendix III for a list of agencies that had deficiencies in this area.

According to some of the auditor’s reports, issues in this area could result 

in misstatements in budgetary balances, obligations, and undelivered 

orders—which are part of the information to be posted on 

USASpending.gov. Some examples include the following:

• One agency’s auditor reported a material weakness in controls over 

financial management related to the maintenance of accounting 

records, recording obligations at the transaction level, and accounting 

and internal controls over obligations and undelivered orders. The 

auditor also reported a significant deficiency related to ineffective 

monitoring and reviewing, and inappropriate certification as to the 

validity of obligation balances, which resulted in invalid obligations 

remaining open. According to the auditor, these deficiencies restrict 

the availability of funding authority, and increase the risk of misstating 

obligation balances as of year-end. These types of issues increase 

the risk that quarterly obligation amounts reported by agencies under 

DATA Act requirements may be inaccurate or incomplete.

• Another agency’s IG readiness review reported that the various layers 

of data validation and reconciliation involved in the agency’s DATA 

Act implementation are complex and require coordination with each 

reporting bureau. According to the agency’s IG, the complexities of 

performing reconciliations of reported data to source systems 

presents a challenge to the agency’s ability to ensure the quality and 

validity of data reported.

This set of issues included longstanding challenges with disparate or 

antiquated financial management systems that affect financial reporting. 

These challenges include system infrastructure and integration issues 

such as systems that do not consolidate transaction level financial data or 

do not capture required data elements such as award identifiers used to 

Accounting and Financial 

Management

Financial Management 

Systems
Page 10 GAO-17-496 Risks to Data Quality

link financial and non-financial data. Five of the 22 CFO Act agencies’

auditors’ reports noted material weaknesses and significant deficiencies, 

and 14 of the 20 IG readiness reviews reported issues or challenges 

related to financial management systems. See appendix III for a list of 

agencies that had deficiencies in this area.

According to the auditors’ reports, issues in this area may cause 

ineffective application of controls used to identify and resolve differences 

in financial information with source systems to help ensure complete, 

accurate, and timely financial information for DATA Act reporting. Also, 

according to the IG readiness reviews, issues with agency financial 

management systems resulted in test file submissions being rejected by 

the DATA Act broker due to validation errors. Only data that have passed 

the broker validation and been approved by the SAO is included in 

USASpending.gov. Data that have not passed the broker validation will 

not be included, therefore increasing the risk of incomplete or misleading 

information. Some examples include the following:

• One agency’s annual financial audit report stated that the agency had 

not enabled the full functionality of its accounting systems to capture 

all budgetary accounting events and to automate budgetary reporting 

procedures. As a result, the agency made numerous manual 

adjustments related to budgetary resources amounts that were not 

supported and not properly recorded to the correct general ledger 

accounts. According to the auditor, manual adjustments increase the 

risk (1) that budgetary adjustments were unsupported or 

inconsistently recorded, and (2) of the likelihood of errors in the 

financial statements. These deficiencies increase the risk that 

budgetary information that will be submitted to USASpending.gov may 

be incomplete and inaccurate.

• Another agency’s IG readiness review reported that the agency faced 

challenges due to legacy and current financial systems using different 

technologies and data elements. Limited resources, such as lack of 

financial resources and human capital necessary to implement the 

act’s requirements, was also cited as a challenge. The IG also 

reported that the agency had been unable to resolve data quality 

issues that have impeded the complete and accurate reporting of 

departmental contract, grant, loan, and other financial assistance 

awards in USASpending.gov.

Finally, according to the auditor’s reports, 9 of the 22 CFO Act agencies’

auditors reported agencies’ financial management systems did not

substantially comply with 1 or more of the 3 requirements found in section 
Page 11 GAO-17-496 Risks to Data Quality

803(a) of FFMIA. Section 803(a) of FFMIA requires: (1) federal financial 

management systems requirements; (2) applicable federal accounting 

standards; and (3) the U.S. Standard General Ledger (USSGL) at the 

transaction level.14

Eight of 22 agencies did not comply with federal financial management 

system requirements, which consist of reliable financial reporting; 

effective, efficient, and cost effective financial operations; safeguarding 

resources; and internal controls over financial reporting and financial 

system security. Four of 22 agencies did not comply with federal 

accounting standards, which provide guidance to improve federal 

financial reporting and are essential for public accountability and the 

effective and efficient functioning of government. Five of 22 agencies did 

not comply with the USSGL at the transaction level which means that 

each time an approved transaction is recorded in the financial 

management system it will generate the appropriate general ledger 

accounts for posting the transaction in accordance with the rules defined 

in USSGL guidance. By not implementing effective internal controls over 

financial management systems and not adequately implementing 

requirements in section 803(a) of FFMIA, agencies will be challenged to 

provide consistent financial and non-financial information across 

component entities and functions, which increases the risk that agencies 

may not be able to submit quality data for DATA Act reporting.

The third area consists of issues involving security over information 

technology (IT) systems; improper access controls to limit users to 

systems and functions needed for their work; and system configurations 

such as outdated system software, patch management, and lack of 

compliance with internal policies. Issues involving IT security and 

ineffective controls could limit management’s ability to provide assurance 

over the completeness and accuracy of recorded transactions. Eighteen 

of the 22 CFO Act agencies’ auditors’ reports noted material weaknesses 

and significant deficiencies related to IT security and controls. See 

appendix III for a list of agencies that had deficiencies in this area. The IG 

readiness reviews, which primarily focused on other steps taken by 

 14In the agency’s PAR or AFR, the auditor also reports on the agency’s compliance with 

Section 803(a) of FFMIA. FFMIA builds on the CFO Act by emphasizing the need for 

agencies to have financial management systems that can generate timely, accurate, and 

useful information with which to make informed decisions and to ensure accountability on 

an ongoing basis.

Information Technology 

Security and Controls
Page 12 GAO-17-496 Risks to Data Quality

agencies to implement the DATA Act, did not specifically mention 

challenges or issues related to IT security and controls.

According to the auditors’ reports, issues in this area increase the risk 

that unauthorized and/or inappropriate changes made either accidentally 

or intentionally to financial IT systems may go undetected by 

management, increasing the risk of misstatement due to fraud and 

disruption of critical financial operations, as well as increasing the risk that 

the reliability and integrity of agencies’ data could be compromised and 

adversely affect the agencies’ ability to provide complete, accurate, and 

timely information for DATA Act reporting. One example iss the following:

• One agency’s annual financial audit report stated that controls over 

access to programs and data and audit logs were not designed 

properly, consistently implemented, or fully effective. The auditor 

found that database and operating system patches were not 

documented, authorized or tested prior to implementation into the 

production environment, a complete and accurate listing of operating 

system patches could not be generated, and a feeder system was 

configured incorrectly to assign incorrect invoice acceptance date 

data, among other things. According to the auditor, these deficiencies 

increase the risk that unscrupulous, unauthorized, or inappropriate 

activity could be performed and not detected, which could lead to a 

compromise and/or security risk to the confidentiality, integrity, and 

availability of the data and systems. These issues also increase the 

risk that financial and non-financial information that will be submitted 

to USASpending.gov may be incomplete, inaccurate, and untimely.

We have previously reported weaknesses, issues, and other challenges 

in key DATA Act award systems which increase the risk that the data that 

will be submitted to USASpending.gov may not be complete, accurate, 

and timely. The DATA Act broker is expected to extract award and subaward information related to federal spending, such as federal 

assistance—including grants, loans, and procurements—directly from 

four award systems. The four award systems and related issues that we 

have previously identified are described below. Unlike the data submitted 

by agencies directly from their financial systems to the DATA Act broker, 

the award and sub-award information extracted from these four systems 

are not subject to any validations in the broker.

Our Previous Work Has 

Identified Data Limitations 

in the Award Systems That 

Provide Data to 

USASpending.gov
Page 13 GAO-17-496 Risks to Data Quality

Since 1978, FPDS-NG has been the primary government-wide central 

repository for procurement data, and feeds certain data to 

USASpending.gov—a searchable database of information on federal 

contracts and other government assistance such as grants and 

cooperative agreements. Individuals and entities awarded contracts over 

the micro-purchase threshold must submit detailed contract information to 

FPDS-NG. FPDS-NG includes information about the product or service, 

agency and vendor information, contract start and expiration dates, and 

location of contract performance, among other elements. According to 

Treasury officials, the DATA Act broker will extract procurement award 

and awardee information such as award description, amount, and 

awardee unique identifier from FPDS-NG to be reported on 

USASpending.gov.

In our past work, we found that FPDS-NG often contains inaccurate or 

incomplete data as agencies do not always input or document required 

information. For example, in September 2016, our review of the 

Department of Veterans Affairs (VA) contracting policies and procedures 

found that total obligations balances reflected in VA’s subsidiary 

accounting records did not match what was recorded in FPDS-NG.15 We 

also identified inaccurate data in FPDS-NG such as misclassified 8(a)16

firms and incorrect obligations balances in our March 2016 review of the 

Small Business Administration’s (SBA) 8(a) Business Development 

Program.17

Further, our prior work on FPDS-NG also found data limitations with the 

system’s inability to identify more than one type of service purchased for 

each contract action.18 According to some of the IG reports we reviewed, 

these data quality issues were the result of human error, the lack of 

departmental internal controls to reasonably assure required procurement 

 15GAO, Veterans Affairs Contracting: Improvements in Policies and Processes Could 

Yield Cost Savings and Efficiency, GAO-16-810 (Washington, D.C.: Sept. 16, 2016).

16The Small Business Administration (SBA) helps socially and economically 

disadvantaged small businesses gain access to federal contracting opportunities through 

its 8(a) program.

17GAO, Alaska Native Corporations: Oversight Weaknesses Continue to Limit SBA’s 

Ability to Monitor Compliance with 8(a) Program Requirements, GAO-16-113 

(Washington, D.C.: Mar. 21, 2016).

18GAO, Defense Acquisitions: Continued Management Attention Needed to Enhance Use 

and Review of DOD’s Inventory of Contracted Services, GAO-13-491 (Washington, D.C.: 

May 23, 2013).

Federal Procurement Data 

System-Next Generation 

(FPDS-NG)
Page 14 GAO-17-496 Risks to Data Quality

information is properly recorded in departmental systems and FPDS-NG, 

and limitations with the FPDS-NG functionality such as the inability to 

change incorrect data identified in FPDS-NG. These issues increase the 

risk that data reported from FPDS-NG to the Treasury data store will not 

be complete, accurate, and timely.

SAM is the primary U.S. government repository for prospective federal 

awardee and federal awardee information, and the centralized 

Government system for certain contracts and grants. All entities that wish 

to do business with the government are to maintain an active registration 

in SAM unless exempt. As part of this registration, awardees register a 

name, unique identifier, address, and executive compensation 

information—all of which are required DATA Act standardized data 

elements. SAM also populates the entity name and address (street, city, 

state, congressional district, ZIP Code, and country) in FPDS-NG and 

certain executive compensation and other sub-awardee information is 

prepopulated from SAM to FSRS prior to the prime awardee’s reporting.

We have previously identified data limitations with SAM that may affect 

DATA Act reporting. For example, in January 2017, we found that SAM 

did not contain information on lessors that listed physical or mailing 

addresses in China. Our work also found that certain information 

disclosed in SAM is not validated. If the addresses for foreign awardees 

are not recorded in SAM, then they will not be displayed in 

USASpending.gov for access by the public, resulting in incomplete and 

inaccurate awardee data for DATA Act reporting. We further noted that 

prior to November 1, 2014, the General Services Administration (GSA) 

was not required to collect certain information from lessors through SAM, 

such as the parent, subsidiary, or successor entities to the lessor.19

In addition, our June 2014 review of USASpending.gov found that ZIP 

Code information for awardees—which is provided by SAM—was one of 

the data elements that were significantly inconsistent with information in 

agency records.20 In that report, we recommended clarified guidance on 

agency maintenance of authoritative records adequate to verify the 

accuracy of required data reported for use by USASpending.gov to 

 19GAO, Federal Real Property: GSA Should Inform Tenant Agencies When Leasing HighSecurity Space from Foreign Owners, GAO-17-195 (Washington, D.C.: Jan. 3, 2017).

20GAO, Data Transparency: Oversight Needed to Address Underreporting and 

Inconsistencies on Federal Award Website, GAO-14-476 (Washington, D.C.: June 30, 

2014).

System for Award 

Management (SAM)
Page 15 GAO-17-496 Risks to Data Quality

improve the completeness and accuracy of data submissions. Although 

some progress has been made by the related agencies, the 

recommendations related to this report remain unresolved. These data 

limitations increase the risk that federal agencies may not submit quality 

awardee data for DATA Act reporting.

ASP is the system used by federal agencies to report financial assistance 

data (e.g., grants) to USASpending.gov. According to Treasury, the DATA 

Act broker will extract financial assistance award information from the 

ASP—including awardee unique identifier, award characteristics, awards 

amount, awardee legal identify name, and address for financial 

assistance—all of which are required by the DATA Act to be reported.

In December 2016, we reported that the DATA Act broker will not validate 

the accuracy of data extracted from the ASP and that according to 

Treasury officials ASP does apply some validation checks to the data 

submitted by federal agencies.21 In addition, ASP rejects individual 

records that fail 10 percent of the validation requirements. ASP also 

rejects entire file submissions if more than 10 percent of the records in 

the file submission fail validation checks. However, ASP partially accepts 

the file submission if less than 10 percent of the records in a file 

submission fail validation checks. The effectiveness of this validation 

process to prevent the submission of erroneous records raises concerns 

regarding the quality of awardee data that can be submitted for DATA Act 

reporting.

FSRS allows prime grant award and prime contract recipients to report 

sub-award activity including executive compensation, and provides data 

on first-tier sub-awards reported by prime recipients. FSRS was created 

as a result of FFATA and became active in July 2010. Prime awardees 

must register and report sub-award information for first-tier sub-awardees,

including award and entity information, such as Data Universal 

Numbering System (DUNS) identification numbers. FSRS contains the 

small business status of some subcontractors, but only for limited types of 

small businesses. The sub-awardee provides all of the information 

required for reporting to the prime awardee. This includes sub-awardee 

entity information, sub-awardee unique identifier, and relevant executive 

 21GAO, Data Act: OMB and Treasury Have Issued Additional Guidance and Have 

Improved Pilot Design but Implementation Challenges Remain, GAO-17-156 (Washington, 

D.C.: Dec. 8, 2016).

Award Submission Portal 

(ASP)

FFATA Subaward Reporting 

System (FSRS)
Page 16 GAO-17-496 Risks to Data Quality

compensation data, if applicable. These are also DATA Act standardized 

data elements required to be reported.

In June 2014, we reported that we could not verify the subcontract data in 

FSRS as agencies frequently do not maintain the records necessary to 

verify the information reported by the awardees.22 We also found 

inconsistencies in the reporting of 20 of 21 data elements caused by 

errors in data entry, missing data, or lack of clear guidance. In our report, 

we recommended clarified guidance on agency maintenance of 

authoritative records adequate to verify the accuracy of required data 

reported for use by USASpending.gov. Our recommendation on this issue 

remains unresolved. These issues increase the risk that federal agencies 

may not submit complete, accurate, and timely sub-award data for DATA 

Act reporting.

As agencies prepare to submit required financial and award information in 

May 2017, they have identified a number of reporting challenges that will 

affect the quality of data posted on USASpending.gov. Both OMB and 

Treasury acknowledged that these challenges are unlikely to be resolved 

before the first statutory deadline when data are collected in compliance 

with the act. Included in these challenges is how agencies are to report 

certain intragovernmental transactions that result from financial activities 

between federal government agencies. Specifically, in order to properly 

present the financial balances and activities of the federal government, 

 22 GAO-14-476

Reporting Challenges 

Related to 

Implementing DATA 

Act Guidance Will 

Affect Data Quality

OMB Issued Guidance on 

Reporting 

Intragovernmental 

Transactions
Page 17 GAO-17-496 Risks to Data Quality

the reciprocating balances and activities between the agencies should be 

offset and result in a zero balance.23

Reconciling intragovernmental transactions for financial reporting 

purposes is a longstanding and government-wide challenge. Federal 

accounting standards, laws, regulations, and policies govern the 

accounting, reporting, and business rules for each of the categories and 

subcategories of intragovernmental transactions. Our annual audits of the 

U.S. government’s consolidated financial statements have identified the 

federal government’s inability to adequately account for and reconcile 

intragovernmental activity and balances between federal entities as an 

impediment that has prevented us from rendering an opinion on the 

federal government’s accrual-based consolidated financial statements for 

many years. Our most recent audit found that the amount of unmatched 

funds from intragovernmental transactions amounted to hundreds of 

billions of dollars. In response to our previous recommendations, 

Treasury has continued to actively work with federal agencies and 

improve its processes to resolve intragovernmental transactions.24

However, the guidance OMB developed on how agencies are to report 

intragovernmental transactions does not appear to leverage the existing 

processes that Treasury has put in place to resolve on a quarterly basis 

the differences in intragovernmental transactions between federal 

agencies.25 Treasury has implemented a new initiative for identifying and 

monitoring systemic root causes of intragovernmental differences, in 

addition to other enhancements to its processes for reporting various 

aspects of agencies intragovernmental differences between agencies, 

including the composition of the differences by agency and category of 

intragovernmental transaction.

USDA officials (one of our case example agencies) expressed concern 

about OMB’s guidance on intragovernmental transactions. Specifically, 

they told us that without a standard approach for reporting 

 23For example, when one agency purchases goods or services (buyer) from another 

agency (seller), the reciprocating accounts payable (buyer) and the accounts receivable 

(seller) should eliminate or net to zero. See U.S. Department of the Treasury, Agency 

Reporting Requirements for the Financial Report of the United States Government, 

Treasury Financial Manual, Chapter 4700 (July 2016). 

24GAO-17-283R.

25OMB, Additional Guidance for DATA Act Implementation: Further Requirements for 

Reporting and Assuring Data Reliability, M-17-04 (Washington, D.C.: Nov. 4, 2016).
Page 18 GAO-17-496 Risks to Data Quality

intragovernmental transactions—meaning whether the funding or 

awarding agency reports them—it is not appropriate for a funding agency 

to certify award data maintained in an awarding agency’s systems, a 

DATA Act reporting method allowed after the first data submission. HHS 

officials (our other case example agency) also expressed concern, and 

told us that although they will be prepared to report in a manner 

consistent with the current OMB guidance, they believe that OMB should 

revisit the guidance because it differs from other reporting requirements.

Treasury officials told us that they are aware of these challenges, but they 

do not expect that these issues will be resolved before the May 2017 

reporting deadline. These officials also told us that efforts to address 

longstanding challenges related to reporting intragovernmental 

transactions are under way, and that they plan to communicate data 

quality limitations to the public on USASpending.gov. The officials could 

not provide us with specifics on how they would communicate the 

limitations but indicated that it would likely be part of the SAO assurance 

process. OMB officials told us in January 2017 that they are unaware of 

any outstanding issues on this topic that would require an OMB policy 

response, and therefore OMB has no plans to issue additional 

implementation guidance at this time.

Another reporting challenge identified by agencies involves missing or 

incorrect ZIP+4 information.26 OMB guidance requires agencies to 

validate federal assistance recipient information, including the recipient’s 

address and ZIP code, against the information in the System for Award 

Management (SAM) before they submit it to the DATA Act broker.27 This 

guidance requires agencies to ensure that award-level data in their 

systems for financial assistance recipients matches the recipients’

information in SAM. Consistent with OMB guidance, financial assistance 

recipients are required to register in SAM prior to submitting an 

application for an award, and OMB staff told us recipients are also 

required to provide accurate information as part of the terms and 

conditions of their award agreements.28 However, according to agency 

 26ZIP+4 refers to the 9-digit ZIP code system used by the United States Postal Service 

(USPS). 

27OMB, Additional Guidance for DATA Act Implementation: Implementing Data-Centric 

Approach for Reporting Federal Spending Information, Management Procedures 

Memorandum (MPM) No. 2016-03 (Washington, D.C.: May 3, 2016).

28MPM No. 2016-03.

Missing or Incorrect ZIP+4 

Information Will Lead to 

Inconsistent Reporting
Page 19 GAO-17-496 Risks to Data Quality

officials, because SAM does not enforce the use of ZIP+4 and agencies’

eligibility procedures may not flag incorrect or missing ZIP+4 information, 

some recipient records are incomplete or incorrect. In addition, some rural 

communities do not have ZIP+4 because the U.S. Postal Service (USPS) 

only assigns 5-digit ZIP codes in those areas.

As a result of the requirement that ZIP+4 information be consistent with 

the USPS address database, Treasury officials told us some agencies are 

unable to validate their financial assistance award information in the 

DATA Act broker. For example, USDA officials told us in January 2017 

that instituting the ZIP+4 validation rule in the broker as a fatal error rather 

than just a warning would cause a large number of their financial 

assistance records to fail and ultimately not be included in data that are

displayed on USASpending.gov. In February 2017, Treasury 

implemented the ZIP+4 validation rule as a fatal error. Treasury officials 

told us that this was done in an effort to enforce existing requirements 

and improve data quality.

Treasury officials said that they examined the scope and seriousness of 

the problem and determined that it is not significant enough at this time to 

warrant the policy change that would be required to address it prior to 

May 2017. According to a Treasury analysis, SAM records that are 

missing ZIP+4 information represent about 1 percent of the total dollar 

value of all the awards in SAM. In addition, according to Treasury, SAM 

records that are missing ZIP+4 because the address has not been 

assigned a ZIP+4 by USPS represent less than 0.5 percent of the total 

dollar value of all the awards in SAM.

Treasury officials acknowledged that missing or invalid ZIP+4 information 

is a longstanding data quality issue with agency records, but believe that 

it is one best addressed at the agency level. In March 2017, Treasury 

officials told us that although they planned to continue to enforce the 

ZIP+4 requirement through the DATA Act broker, they were developing a 

workaround for agencies encountering problems.

Agencies have also reported challenges linking their financial and award 

data using the unique award identifier. OMB guidance requires agencies 

to link their agency financial and award data using the unique award 

Challenges Exist Linking 

Financial and Award Data
Page 20 GAO-17-496 Risks to Data Quality

identifier.29 As our work in 2016 showed, agencies continue to report 

challenges related to integrating their financial and award systems to 

report under the DATA Act.30 Some agencies, according to OMB staff, are 

unable to record unique award identifiers in their financial systems, and 

may not be able to link financial and award data. This linkage should help 

policymakers and the public track spending more effectively—one of the 

objectives of the DATA Act.

HHS and USDA officials reported in their DATA Act implementation plan 

updates and confirmed with us that they are using short-term solutions to 

link their financial and award data to generate and submit a required file 

by May 2017.31 They both confirmed they will link their financial and 

award systems with the unique award identifier when they implement 

long-term system solutions.

OMB staff told us that five agencies—the Departments of Defense, 

Housing and Urban Development, the Interior, and Veterans Affairs, and 

the Environmental Protection Agency—indicated that they will not fully 

meet the May 2017 reporting requirements, in part because some of their 

components have been unable to record unique award identifiers in their 

financial systems. OMB staff told us that these agencies would be able to 

report some data, but not all of the award financial information required 

for agency submissions. Treasury officials told us that they are aware of 

this issue and have structured the broker so that after providing a warning 

it will accept agency data submissions, even if they contain significant 

gaps.

OMB staff and Treasury officials told us they are creating a mechanism in 

the broker that will allow agencies to explain reporting anomalies in their 

 29Specifically, OMB M-15-12 requires all federal agencies to carry the unique award 

identifier (Award ID) so that award-level and financial data may be linked for each federal 

award. In order to begin displaying linked data beginning May 2017, agencies should have 

the Award ID linkage in their financial and management systems no later than January 1, 

2017.

30GAO-17-156.

31In June 2016, OMB directed agencies to update information in the DATA Act 

implementation plans that they submitted to OMB in 2015. The agencies were directed to 

update information on timelines and costs to implement the DATA Act, as well as 

challenges the agencies face in meeting DATA Act requirements and mitigation strategies. 

(OMB, Request for Updated DATA Act Implementation Plans by August 12, 2016, OMB 

Memo to All CFO Act Agencies DATA Act Senior Accountable Officials (Washington, D.C.: 

June 15, 2016). 
Page 21 GAO-17-496 Risks to Data Quality

data displayed on USASpending.gov. According to Treasury officials, the 

broker will include a text box for agencies to explain any reporting 

anomalies related to the data they are submitting and certifying before it 

is displayed on USASpending.gov. In addition, OMB staff told us they 

plan to provide agencies with standard language to explain certain 

reporting discrepancies, such as data that are not aligned as a result of 

the time it takes between when an agency completes a transaction and 

when it is recorded in its financial system. OMB staff explained that the 

purpose of the text boxes is not to provide qualifications about data 

quality, but to communicate what they believe are legitimate data 

discrepancies that could be perceived as data quality issues by the 

public.

One of the purposes of the DATA Act is to provide consistent, reliable, 

and searchable government-wide spending data that are displayed 

accurately for taxpayers and policymakers on USASpending.gov (or a 

successor system). Longstanding issues related to agency financial 

information, systems and internal controls, and reporting challenges 

related to agency DATA Act report submissions underscore the need for 

OMB to address our open recommendation to provide additional 

guidance to address potential clarity, consistency, or data quality issues 

and for OMB to implement a process for communicating data quality 

limitations to the public.32 Information Quality Act (IQA) standards specify 

that data should have full, accurate, and transparent documentation 

where appropriate and should identify and disclose data quality issues.33

Similarly, OMB’s Policies for Federal Agency Public Websites and Digital 

Services requires that agencies be transparent about the quality of the 

information that they disseminate and take reasonable steps where 

practicable to inform users about the quality of disseminated content.34

 32 GAO, DATA Act: Data Standards Established, but More Complete and Timely 

Guidance Is Needed to Ensure Effective Implementation, GAO-16-261 (Washington, D.C.: 

January 29, 2016).

33GAO-16-261. The statutory provisions commonly known as IQA require agencies to 

adopt standards for information quality and to review information disseminated to ensure 

that it meets those standards. Consolidated Appropriations Act, 2001, Pub. L. No. 106-

554, app. C, § 515, 114 Stat. 2763A-153 to 2763A-154 (Dec. 21, 2000) codified at 44 

U.S.C. § 3516 note. For more on this, see GAO, Information Quality Act: Actions Needed 

to Improve Transparency and Reporting of Correction Requests, GAO-16-110 

(Washington, D.C.: Dec. 21, 2015). 

34See Office of Management and Budget, Policies for Federal Agency Public Websites 

and Digital Services, M-17-06 (Washington, D.C.: Nov. 8, 2016).
Page 22 GAO-17-496 Risks to Data Quality

We will continue to monitor the implementation of the DATA Act and how 

OMB, Treasury, and agencies communicate reporting anomalies and 

data quality limitations.

Another area of risk to data quality is the agency senior accountable 

official (SAO) assurance process that leverages assurance processes of 

existing source systems with known data quality challenges. OMB 

guidance directs agency SAOs to leverage existing processes when 

providing assurances over required data submissions. However, during 

this review we have identified a number of concerns related to the 

effectiveness of some of these processes.

OMB guidance directs agencies to match the procurement award data 

generated in the broker with data in the agency procurement award 

systems.35 The guidance also directs agencies to leverage the 

assurances provided in their annual Federal Procurement Data SystemNext Generation (FPDS-NG) Data Verification and Validation reports 

submitted to OMB.36 Despite the requirement for agencies to conduct 

annual verification and validation reviews of the data contained in FPDSNG, our prior work found that some award data reported on 

USASpending.gov contained information that was not fully consistent with 

agency records or was unverifiable due to gaps in agency records.37

OMB guidance also directs agencies to match financial assistance award 

data generated in the broker against data in their financial assistance 

 35D1 files are generated in the broker from data extracted from USASpending.gov. 

Contract data displayed on USASpending.gov are imported from the Federal Procurement 

Data System-Next Generation (FPDS-NG), which collects information on contract actions.

36Pursuant to Federal Acquisition Regulation (FAR) Part 4.604 and OMB guidance,

Improving Federal Procurement Data Quality - Guidance for Annual Verification and 

Validation (Washington, D.C.: May 31, 2011), Agency Senior Procurement Executives are 

required to certify the completeness, timeliness, and accuracy of agency data in FPDS. 

Completeness and timeliness are measured by the percent of agency contract actions 

captured by the required deadline. Accuracy is measured by reviewing a random sample 

of records for a selected number of data elements. Since 2011, agencies have also been 

required to verify that they have the policies, procedures, and internal controls to address 

qualitative and contractor provided procurement data. See Federal Government 

Procurement Data Quality Summary: Fiscal Year 2015 For Agency Data in the Federal 

Procurement Data System, available at 

https://www.usaspending.gov/about/Pages/TheData.aspx.

37GAO-14-476. 

OMB Guidance 

Directs Agencies to 

Leverage Existing 

Assurance Processes 

Despite Known 

Limitations
Page 23 GAO-17-496 Risks to Data Quality

award management systems for all award-level data and in SAM for 

prime awardee information (i.e., subrecipient executive compensation 

data).38 Although OMB guidance directs agencies to leverage existing 

assurance processes for other file submissions, there is no certification or 

assurance processes for the financial data submitted to the ASP. OMB 

guidance specifies that OMB is reviewing opportunities to enhance 

assurances over these data. However, as of March 2017, OMB has not 

established a timetable for this activity, so it is unclear whether new 

procedures will be in place in time for agencies to leverage these 

assurances for their May 2017 report submissions.

GSA has posted on its website an assurance statement that provides 

assurance that the risk to federal agency operations, data, and assets 

resulting from the operation of the common controls of SAM and FSRS 

information systems are acceptable and meet all the security controls 

required for DATA Act reporting. According to OMB staff, agencies can 

rely on data from SAM and FSRS for DATA Act reporting. However, our 

review of the assurance statement posted on GSA’s website found that 

the statement focuses on security controls rather than data quality and 

appears to apply specifically to procurement management. The extent to 

which this assurance statement will be used by SAOs to provide 

assurances over the quality of the data for both procurement and financial 

assistance award information is uncertain. We will continue to monitor this 

issue moving forward.

HHS officials told us they are still assessing the GSA assurance 

statement and its alignment to HHS’s overarching SAO certification. 

Since the requirements for SAM and FSRS are driven by both the FAR 

and Title 2 of the Code of Federal Regulations, officials said that HHS is 

interested in having GSA confirm that the assurance statement covers 

both procurement and financial assistance. OMB staff told us that 

agencies should leverage this assurance when certifying their data from 

these source systems. OMB staff also noted that the agencies are 

ultimately responsible for the quality of their data submissions. 

Furthermore, these staff stated that the quality of the information reported 

directly by awardees to SAM and FSRS is the responsibility of the 

awardee in accordance with the terms and conditions of their award 

agreements. The extent to which the GSA assurance statement regarding 

 38The D2 files are generated in the broker by extracting financial assistance award data 

from the Award System Portal.
Page 24 GAO-17-496 Risks to Data Quality

data integrity in SAM and FSRS will be used by agency SAOs when 

assuring the quality of their data submissions for May 2017 is unclear 

since some SAOs were still in the process of making that determination in 

March 2017. We will revisit this issue after May 2017 once agencies have 

made their determinations and will examine potential effects for data 

quality.

OMB staff explained that the intent of OMB guidance on the SAO 

assurance process is to hold agency SAOs accountable for the reliability 

and validity of the data they submit. As discussed in OMB guidance, the 

SAO assurance process is also intended to leverage existing controls, 

processes, and procedures outlined in existing policies, regulations, and 

statutes, such as the internal control requirements outlined in OMB 

Circular A-123.39 However, questions regarding these assurance 

processes raise concerns about whether they will be effective in 

preventing or detecting data quality issues. They also increase the risk 

that SAO assurances over agency data quality will be unreliable. OMB 

staff told us that they are aware of these issues and are still finalizing the 

SAO assurance process, which they expect to do in time for the May 

2017 reporting deadline. Accordingly, we are not making a 

recommendation at this time but will assess the quality of the assurance 

process in our future work.

OMB has taken some actions to improve its data governance framework, 

but efforts to establish a fully functioning data governance structure are at 

an early stage with many specifics yet to be worked out. In July 2015, we 

reported that OMB and Treasury had begun standardizing data elements, 

but had not established a clear set of institutionalized policies and 

processes for enforcing data standards or adjudicating necessary 

changes to existing standards.40 Establishing a formal framework for 

providing data governance throughout the lifecycle of developing and 

implementing standards is key for ensuring that the integrity of data 

standards is maintained over time. In that report, we recommended that 

OMB, in collaboration with Treasury, establish a set of clear policies and 

procedures for developing and maintaining data standards that are 

consistent with leading practices. OMB and Treasury generally agreed 

with our recommendation. However, the recommendation remains open.

 39See MPM 2016-03 and M-17-04. 

40GAO-15-752T. 

Efforts to Establish 

Data Governance 

Structure Are Still at 

an Early Stage
Page 25 GAO-17-496 Risks to Data Quality

In September 2016, OMB established a Data Standards Committee to 

focus on clarifying existing data element definitions and identifying the 

need for new standards. OMB approved a charter for this committee in 

November 2016. According to the charter, the committee will make 

recommendations on these topics to OMB, the DATA Act Executive 

Steering Committee, and federal communities such as the Chief 

Acquisition Officers Council and the Chief Information Officers Council. 

The charter states that the committee is an advisory body that is not 

responsible for approving or operationalizing the data standards. The 

committee’s membership includes representatives of OMB, Treasury, 

GSA’s Integrated Award Environment Program Management Office, and 

federal communities and councils representing various areas of 

responsibility and expertise.41 OMB staff told us that the Data Standards 

Committee will be solely focused on maintaining and updating data 

standards, including standards used by federal communities but not 

specifically required under the DATA Act.

According to OMB staff, the Data Standards Committee has held several 

meetings and plans to produce operating procedures to guide its work but 

has not yet done so. OMB staff told us that although the committee has 

reviewed specific data standards, the committee has not made any 

recommendations regarding these standards, nor has it produced a work 

plan or timetable for addressing known challenges related to any data 

standards. While these staff also said that the committee has begun to 

develop processes and procedures to guide its reviews of data standards, 

no details or documentation were available beyond the six-page charter.

Although the charter states that the committee will seek to promote 

transparency by making information on the topics of its proceedings and 

resulting outcomes available to the public, it has not yet done so. As we 

have previously reported, one component of good data governance 

involves establishing a process for consulting with and obtaining 

agreement from stakeholders, including non-federal stakeholders 

potentially affected by changes in data standards.42 Moreover, standards 

 41According to the charter, the committee’s membership consists of representatives from 

OMB, Treasury, GSA’s Integrated Award Environment Program Management Office, the 

Chief Acquisition Officers Council, the Council on Financial Assistance Reform, the 

Budget Officers Advisory Council, the Chief Financial Officers Council, the Chief 

Information Officers Council, the human resources community, and the performance 

improvement community. 

42GAO-15-752T.
Page 26 GAO-17-496 Risks to Data Quality

for internal control in the federal government state that management 

should communicate quality information to external parties so that these 

parties can help the entity achieve its objectives and address related 

risks.43 The DATA Act requires that OMB and Treasury consult with public 

and private stakeholders in establishing data standards. The charter 

states that the committee is to make publicly available both the topics of 

its proceedings and the resulting outcomes. Doing so could allow public 

and private stakeholders not represented on the committee to provide 

better informed opinions on new data standards or revisions. Without 

publicly available information about the committee, these stakeholders 

may not be able to direct their input toward standards that are under 

review. OMB staff told us that the committee has not kept records and 

therefore has no information about its proceedings available to release.

Keeping records of the Data Standards Committee’s activities and 

releasing them publicly could facilitate consultation with stakeholders. 

Actions beyond recordkeeping and public release of information about the 

committee are needed to address our 2015 recommendation that OMB 

and Treasury establish a data governance structure consistent with 

leading practices. The Data Standards Committee may provide a useful 

forum for collecting stakeholder input. However, additional steps need to 

be taken to build a data governance structure that fully reflects leading 

practices.

Across the federal government, agencies are making final preparations to 

submit the data required by the DATA Act’s May 2017 deadline. This 

represents the culmination of almost 3 years of effort by OMB, Treasury, 

and federal agencies to address the many policy and technical challenges 

presented by the act’s requirements including the need to standardize 

data elements across the entire federal government, link data contained 

in agencies’ financial and award management systems, and expand the 

type and amount of data to be reported. Their submissions will provide an 

important initial test of the efficacy of this endeavor.

Looking forward, attention will increasingly focus on another critical goal 

of the act—improving the quality of the data being produced and the 

mechanisms and assurances needed to communicate such information to 

users. An important component of this will be the first round of mandated 

 43GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sept. 10, 2014).

Conclusions
Page 27 GAO-17-496 Risks to Data Quality

reviews agency IGs will conduct later this year, which will include 

sampling and testing of data quality. However, prior audits and reviews 

have already identified much about the challenges agencies face in 

producing quality data. These reviews have identified material 

weaknesses and significant deficiencies reported in agencies’ financial 

audits and identified several widespread and longstanding issues that 

present risks to agencies’ ability to submit quality data for DATA Act 

reporting. In addition, specific challenges related to the operationalization 

of the act’s requirements also represent potential risks to data quality. 

Because of this, it is especially important for the quality assurance and 

data governance frameworks established by OMB to be robust, 

transparent, and effective. Users will need such mechanisms to make 

informed decisions about the nature and limitations of the data being 

reported. This is essential to the full implementation of the DATA Act and 

its promise of improving the usefulness of those financial data to 

Congress, federal managers, and the American people.

To promote transparency in the development and management of data 

standards for reporting federal spending, the Director of the Office of 

Management and Budget should ensure that the Data Standards 

Committee makes information about the topics of the committee’s 

proceedings and any resulting outcomes available to the public.

We provided a draft of this report to the Secretaries of the Departments of 

Agriculture, Health and Human Services, and Treasury, and the Director 

of the Office of Management and Budget for review and comment. OMB 

generally agreed with our recommendation. In addition, OMB, USDA, and 

Treasury provided technical comments which we incorporated as 

appropriate. HHS had no comments on the draft report.

Recommendation for 

Executive Action

Agency Comments 

and Our Evaluation
Page 28 GAO-17-496 Risks to Data Quality

We are sending copies of this report to the Secretaries of the 

Departments of Agriculture, Health and Human Services, and Treasury, 

and the Director of the Office of Management and Budget, as well as 

interested congressional committees and other interested parties. This 

report will be available at no charge on our website at http://www.gao.gov.

If you or your staff has any questions about this report, please contact J. 

Christopher Mihm at (202) 512-6806 or Mihmj@gao.gov or Paula M. 

Rascona at (202) 512-9816 or Rasconap@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of our report. Key contributors to this report are listed in 

appendix IV.

J. Christopher Mihm

Managing Director, Strategic Issues

Paula M. Rascona

Director, Financial Management and Assurance
Page 29 GAO-17-496 Risks to Data Quality

List of Congressional Addressees

The Honorable Ron Johnson

Chairman

The Honorable Claire McCaskill

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Jason Chaffetz

Chairman

The Honorable Elijah E. Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives

The Honorable Mark Meadows

Chairman

The Honorable Gerald E. Connolly

Ranking Member

Subcommittee on Government Operations

Committee on Oversight and Government Reform

House of Representatives

The Honorable Will Hurd

Chairman

The Honorable Robin Kelly

Ranking Member

Subcommittee on Information Technology

Committee on Oversight and Government Reform

House of Representatives

The Honorable Thomas R. Carper

United States Senate

The Honorable Mark R. Warner

United States Senate
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-17-496 Risks to Data Quality

This review is part of our ongoing effort to provide reports on the progress 

being made in implementing the Digital Accountability and Transparency 

Act of 2014 (DATA Act). 1 This review focuses on what is already known 

about existing challenges that affect the quality of agency financial data 

as well as issues that will affect data quality as agencies begin to report 

under the act. More specifically, it addresses the following: (1) risks to 

data quality related to known material weaknesses and other deficiencies, 

including internal controls over financial reporting, that have been 

identified in selected previous audits, reviews, and reports conducted by 

GAO, inspectors general (IG), and external auditors; (2) risks to data 

quality related to challenges in operationalizing DATA Act policy and 

technical guidance; (3) approaches that agencies will use to assure the 

quality of their data submissions and any associated limitations; and (4) 

efforts taken to establish a data governance structure. We also update 

the current status of the Office of Management and Budget’s (OMB) and 

the Department of the Treasury’s (Treasury) efforts to address our open 

recommendations related to DATA Act implementation in appendix II.

To assess potential risks to data quality related to known material 

weaknesses2 and other significant deficiencies,3 including internal 

controls over financial reporting, that have been identified in selected 

previous audits, reviews, and reports conducted by us, IGs, and external 

auditors, we examined: (1) the extent to which agencies’ independent 

auditors have reported material weaknesses, significant deficiencies, and 

other challenges, and (2) the extent to which we previously reported 

issues with government-wide systems.

To describe the extent to which agencies’ independent auditors have 

disclosed material weaknesses, significant deficiencies, and other 

 1

Pub. L. No. 113-101, § 3, 128 Stat. 1146, 1151–1152 (May 9, 2014). The DATA Act 

amended the Federal Funding Accountability and Transparency Act of 2006 (FFATA). 

Pub. L. No. 109-282, 120 Stat. 1186 (Sept. 26, 2006), codified at 31 U.S.C. § 6101 note.

2

A material weakness is a deficiency, or a combination of deficiencies, in internal control 

over financial reporting such that there is a reasonable possibility that a material 

misstatement of the entity’s financial statements will not be prevented, or detected and 

corrected, on a timely basis. A deficiency in internal control exists when the design or 

operation of a control does not allow management or employees, in the normal course of 

performing their assigned functions, to prevent, or detect and correct, misstatements on a 

timely basis.

3

A significant deficiency is a deficiency, or a combination of deficiencies, in internal control 

that is less severe than a material weakness, yet important enough to merit attention by 

those charged with governance.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-17-496 Risks to Data Quality

challenges, we reviewed 22 of the 24 Chief Financial Officers Act of 1990 

(CFO Act) agencies’ Performance and Accountability Reports (PAR) or 

Agency Financial Reports (AFR) for fiscal year 2016 to identify material 

weaknesses and significant deficiencies reported by independent 

auditors. Two agencies had not issued a PAR or AFR prior to our cutoff 

date of February 28, 2017, and therefore were not included in our review. 

We categorized the material weaknesses and significant deficiencies 

reported by the independent auditors that could affect the quality of the 

data submitted by agencies under the DATA Act. We also reviewed these 

agency reports for any auditor-identified noncompliance with the Federal 

Financial Management Improvement Act of 1996 (FFMIA) to identify 

factors that may increase the risk to reporting quality data.4 In addition, 

because the DATA Act requires IGs and GAO to assess and report on the 

completeness, timeliness, quality, and accuracy of data submitted by 

federal agencies, we reviewed readiness reviews issued by IGs to identify 

reported issues and challenges that could affect the quality of spending 

data reported under the DATA Act. Four agency IGs did not conduct a 

readiness review or their reports were not issued prior to our cutoff date 

of February 28, 2017, and therefore were not included in our review. To

ensure we had a comprehensive understanding of these material 

weaknesses, significant deficiencies, and other challenges, we analyzed 

these reported issues to determine the extent to which they may hinder 

the entities’ abilities to submit complete and accurate spending data and 

categorized them.

In our analysis of agencies’ material weaknesses, significant deficiencies, 

and other challenges reported by independent auditors, we identified 

three overall categories that could affect data quality: (1) Accounting and 

Financial Management, (2) Financial Management Systems, and (3) 

Information Technology (IT) Security and Controls. We reviewed the 

auditor reports, PARs, AFRs, and readiness reviews using a data 

collection instrument to document our assessment of the extent to which 

the issues identified in these reports fit into the aforementioned 

categories.

To describe the extent to which independent auditors have reported 

issues with government-wide systems, we reviewed our previous reports 

to identify reported deficiencies in government-wide systems that could 

 4

Pub. L. No. 104-208, div. A., title VIII, §§ 801-808, 110 Stat. 3009, 3009-389 to 3009-393 

(Sept. 30, 1996) codified at 31 U.S.C. § 3512 note.
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-17-496 Risks to Data Quality

affect the quality of spending data submitted to USASpending.gov. 

According to Treasury, the source systems include: (1) the Federal 

Procurement Data System-Next Generation, (2) System for Award 

Management, (3) the Award Submission Portal, and (4) the Federal 

Funding Accountability and Transparency Act Subaward Reporting 

System. Although the conditions observed in these reports may not be 

present in all federal agencies and systems, they illustrate conditions that 

increase the risks and effects to agency data quality.

To assess the risks to data quality related challenges in operationalizing 

DATA Act policy and technical guidance during implementation of the act 

we examined (1) the extent to which selected agencies have been able to 

submit, validate, and certify their data submissions to the DATA Act 

broker and any challenges they reported, and the (2) the steps OMB and 

Treasury have taken to address known reporting challenges.

To understand the extent to which agencies have been able to submit, 

validate, and certify their data submissions we reviewed technical 

documentation; reviewed experiences at two agencies; interviewed 

knowledgeable officials from OMB, Treasury, and selected federal 

agencies; and reviewed past GAO reports to identify data quality issues 

related to DATA Act implementation. The review of technical 

documentation included material related to the schema version 1.01 to 

understand reporting structure, and the broker to understand its 

functionality and validation processes. We obtained technical 

documentation from the Federal Spending Transparency public website.

For the examination of experiences at agencies, we selected two 

agencies based on whether they were in compliance with existing federal 

requirements for federal financial management systems; the type of 

federal funding provided (such as grants, loans, or procurements); and 

their status as federal shared service providers for financial management. 

Based on these selection factors, we chose the U.S. Department of 

Health and Human Services (HHS), and the U.S. Department of 

Agriculture (USDA). Although the agencies’ experiences are not 

generalizable, they illustrate different conditions and challenges under 

which agencies are implementing the act. These two agencies were also 

selected for our January and December 2016 reports.

To understand the steps OMB and Treasury have taken to address 

known reporting challenges, we reviewed OMB policy guidance intended 

to facilitate agency reporting. We also interviewed OMB staff and 

Treasury officials to obtain information about steps they have taken to 
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-17-496 Risks to Data Quality

respond to previously identified challenges, agency requests for 

clarification on reporting requirements, and any plans for additional 

guidance. We also met with OMB staff and Treasury officials to obtain 

information on the status of efforts to address our previous 

recommendations related to providing policy and technical guidance.5

To assess the approach that agencies will use to assure the quality of 

their data submissions and any associated limitations we (1) reviewed 

relevant OMB policy guidance; (2) spoke with relevant agency officials; 

and (3) examined experiences at our two case study agencies, HHS and 

USDA. We reviewed OMB policy guidance to understand the assurance 

process agency senior accountable officials (SAO) should follow, 

including the authoritative sources for each file to be submitted in the 

DATA Act reporting process. We spoke with OMB staff and Treasury 

officials to understand the purpose and rationale of parts of the assurance 

process, and asked about plans for additional guidance. We spoke with 

HHS and USDA officials, and requested and reviewed documentation 

where applicable, to understand any concerns they have or challenges 

they are facing or expect to face during the assurance process.

To determine the current status of OMB’s and Treasury’s efforts to 

implement a data governance structure for the DATA Act, we met with 

OMB staff and Treasury officials to obtain information on the status of 

their efforts to address our previous recommendation that they establish 

such a structure.6 We reviewed documents provided by OMB, including 

policy memorandums and the charter of the Data Standards Committee, 

an advisory body established by OMB as part of its data governance 

efforts. We also met with representatives of organizations with expertise 

in data governance to review the key practices we described in our 

 5

GAO, DATA Act: OMB and Treasury Have Issued Additional Guidance and Have 

Improved Pilot Design but Implementation Challenges Remain, GAO-17-156 (Washington, 

D.C.: Dec. 8, 2016); DATA Act: Data Standards Established, but More Complete and 

Timely Guidance is Needed to Ensure Effective Implementation, GAO-16-261 

(Washington, D.C.: Jan. 29, 2016) and DATA Act: Progress Made in Initial Implementation 

but Challenges Must be Addressed as Efforts Proceed, GAO-15-752T (Washington, D.C.: 

July 29, 2015). 

6 GAO-15-752T.
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-17-496 Risks to Data Quality

December 2016 report and obtain additional information about how these 

key practices have been implemented in data governance frameworks.7

We conducted this performance audit from January 2017 to April 2017 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.

 7

GAO, DATA Act: OMB and Treasury Have Issued Additional Guidance and Have 

Improved Pilot Design but Implementation Challenges Remain, GAO-17-156 (Washington, 

D.C.: Dec. 08, 2016).
Appendix II: Status of GAO’s 

Recommendations Related to the DATA Act 

and Data Transparency

Page 35 GAO-17-496 Risks to Data Quality

Report Recommendations Implementation Status 

GAO-14-476 

Data Transparency: 

Oversight Needed to 

Address 

Underreporting and 

Inconsistencies on 

Federal Award 

Website 

(June 2014)

1. To improve the completeness and 

accuracy of data submissions to the 

USASpending.gov website, the 

Director of the Office of Management 

and Budget (OMB), in collaboration 

with the Department of the Treasury's 

(Treasury) Fiscal Service, should 

clarify guidance on (1) agency 

responsibilities for reporting awards 

funded by non-annual appropriations; 

(2) the applicability of 

USASpending.gov reporting 

requirements to non-classified 

awards associated with intelligence 

operations; (3) the requirement that 

award titles describe the award's 

purpose (consistent with our prior 

recommendation); and (4) agency 

maintenance of authoritative records 

adequate to verify the accuracy of 

required data reported for use by 

USASpending.gov.

Open. OMB and Treasury are working to implement the Digital

Accountability and Transparency Act of 2014 (DATA Act), which 

includes several provisions that may address these 

recommendations once fully implemented. 

1) OMB staff said they continue to agree with GAO that 

additional guidance is needed regarding agency responsibilities 

for reporting awards funded by non-annual appropriations but 

have not yet developed this guidance.

2) OMB staff stated that they believe a memorandum issued in 

November 2016 (M-17-04) addresses the applicability of 

USASpending.gov reporting requirements to non-classified 

awards associated with intelligence operations. We reviewed 

the memorandum and determined that additional guidance is still 

needed to ensure complete reporting of unclassified awards as 

required by FFATA. 

3) OMB staff have agreed that it will be important to clarify 

guidance on how agencies can report on award titles to

appropriately describe the award’s purposes and noted that they 

are working on providing additional guidance to agencies as part 

of their larger DATA Act implementation efforts. 

4) OMB released policy guidance in May 2016 (Management 

Procedures Memorandum (MPM) No. 2016-03) and November 

2016 (M-17-04) that identifies the authoritative sources for 

reporting procurement and award data. However, our review of 

this policy guidance determined that it does not address the 

underlying source that can be used to verify the accuracy of nonfinancial procurement data or any source for data on assistance 

awards. This recommendation was included in priority 

recommendation letters sent to OMB by the Comptroller General 

in July 2016 and Spring 2017.

Appendix II: Status of GAO’s 

Recommendations Related to the DATA Act 

and Data Transparency
Appendix II: Status of GAO’s 

Recommendations Related to the DATA Act 

and Data Transparency

Page 36 GAO-17-496 Risks to Data Quality

Report Recommendations Implementation Status 

2. To improve the completeness and 

accuracy of data submissions to the 

USASpending.gov website, the 

Director of OMB, in collaboration with 

Treasury's Fiscal Service, should 

develop and implement a 

government-wide oversight process 

to regularly assess the consistency of 

information reported by federal 

agencies to the website other than 

the award amount.

Open. As part of their DATA Act implementation efforts, OMB 

issued policy guidance in May 2016 (MPM 2016-03) and 

November 2016 (M-17-04) that identifies authoritative systems 

to validate agency spending information. The guidance also 

directs the DATA Act senior accountable officials (SAO) to 

provide quarterly assurance over the data reported to 

USASpending.gov and specifies that this assurance should 

leverage data quality and management controls established in 

statute, regulation, and federal government-wide policy and be 

aligned with the internal control and risk management strategies 

in Circular A-123. In addition, the DATA Act broker will provide a 

set of validation rules to further ensure the proper formatting of 

data submitted to USASpending.gov. In addition, OMB staff 

stated that they have reviewed reports from agency inspectors 

general (IG) on DATA Act implementation and plan to use future 

IG reports on data quality as part of a government-wide 

monitoring plan. 

However, OMB has not documented this monitoring plan. OMB 

staff noted that OMB and Treasury had prioritized linking 

financial data to award data as a means of addressing the issue 

of unreported awards we previously identified. We agree that 

linking financial and award data can help agencies identify gaps 

in reporting. However, other than citing agencies’ responsibility 

to certify the accuracy of their data, OMB did not identify any 

new or revised processes aimed at addressing the accuracy 

concerns we addressed. This recommendation was included in 

priority recommendation letters sent to OMB by the Comptroller 

General in December 2015, July 2016, and Spring 2017.

GAO-15-752T

DATA Act: Progress 

Made in Initial 

Implementation but 

Challenges Must be 

Addressed as Efforts 

Proceed

(July 2015) 

1. To ensure that federal program 

spending data are provided to the 

public in a transparent, useful, and 

timely manner, the Director of OMB 

should accelerate efforts to determine 

how best to merge DATA Act 

purposes and requirements with the 

GPRAMA requirement to produce a 

federal program inventory.

Open. OMB staff told us that they do not expect to be able to 

identify programs for the purposes of DATA Act reporting until 

sometime after May 2017. However, they said that they are 

studying a program definition and alignment to identify a more 

consistent framework for defining federal agency programs with 

the aim of improving government-wide comparability and tying 

programs to spending. The effort is supported by a working 

group comprised of representatives from the Chief Financial 

Officers (CFO) community and other federal communities. OMB 

staff stated that they are incorporating ongoing feedback from 

this group into OMB’s efforts to identify a framework for defining 

federal agency programs. This was identified as a high priority 

recommendation in letters sent from the Comptroller General to 

the Director of OMB in December 2015, July 2016, and Spring

2017.
Appendix II: Status of GAO’s 

Recommendations Related to the DATA Act 

and Data Transparency

Page 37 GAO-17-496 Risks to Data Quality

Report Recommendations Implementation Status 

2. To ensure that the integrity of data 

standards is maintained over time, 

the Director of OMB, in collaboration 

with the Secretary of the Treasury, 

should establish a set of clear 

policies and processes for developing 

and maintaining data standards that 

are consistent with leading practices 

for data governance.

Open. OMB and Treasury have taken some initial steps to build 

a data governance structure including conducting interviews with 

key stakeholders and developing a set of recommendations for 

decision-making authority. In September 2016, OMB and 

Treasury took another step toward establishing a data 

governance structure by creating a new Data Standards 

Committee that will be responsible for advising OMB and 

Treasury on new data elements and revisions to established 

standards. According to OMB staff, the committee has held 

several meetings but has not yet provided recommendations to 

OMB. 

However, more remains to be done. As part of our ongoing 

feedback to OMB, we shared five key practices that we believe 

should inform their plans to develop a data governance 

framework moving forward. This was identified as a high priority 

recommendation in letters sent from the Comptroller General to 

the Director of OMB in December 2015 and to the Director of 

OMB and the Secretary of the Treasury in July 2016 and Spring 

2017.

GAO-16-261 

DATA Act: Data 

Standards 

Established, but More 

Complete and Timely 

Guidance Is Needed 

to Ensure Effective 

Implementation 

(January 2016)

1. To help ensure that agencies report 

consistent and comparable data on 

federal spending, we recommend that 

the Director of OMB, in collaboration 

with the Secretary of the Treasury, 

provide agencies with additional 

guidance to address potential clarity, 

consistency, or quality issues with the 

definitions for specific data elements 

including Award Description and 

Primary Place of Performance and 

that they clearly document and 

communicate these actions to 

agencies providing this data as well 

as to end-users.

Open. In May 2016, OMB issued additional guidance for 

implementing the DATA Act entitled Implementing the DataCentric Approach for Reporting Federal Spending Information

(Management Procedures Memorandum No. 2016-03). This 

memorandum provided guidance on new federal prime award 

reporting requirements, agency assurances, and authoritative 

sources for reporting. In November 2016, OMB followed this with 

additional guidance intended to provide clarification on how 

agencies should: (1) report financial information for awards 

involving Intragovernmental Transfers (IGTs); (2) report financial 

assistance award records containing personally identifiable 

information (PII); and (3) provide agency SAO assurance 

regarding quarterly submissions to USASpending.gov. OMB 

staff also stated that they sent an email announcement to 

agency senior accountable officials to clarify that information 

submitted to USASpending.gov is subject to plain language 

requirements. 

Despite these positive steps, additional guidance is needed to 

facilitate agency implementation of certain data definitions (such 

as "primary place of performance" and "award description") in 

order to produce consistent and comparable information. We 

continue to have concerns about whether the guidance provides 

sufficient detail in areas such as the process for providing 

assurance on data submissions. This was identified as a high 

priority recommendation in letters sent from the Comptroller 

General to the Director of OMB and the Secretary of the 

Treasury in July 2016 and Spring 2017.
Appendix II: Status of GAO’s 

Recommendations Related to the DATA Act 

and Data Transparency

Page 38 GAO-17-496 Risks to Data Quality

Report Recommendations Implementation Status 

2. To ensure that federal agencies are 

able to meet their reporting 

requirements and timelines, we 

recommend that the Director of OMB, 

in collaboration with the Secretary of 

the Treasury, take steps to align the 

release of finalized technical 

guidance, including the DATA Act 

schema and broker, to the 

implementation time frames specified 

in the DATA Act Implementation 

Playbook.

Closed–Implemented. OMB and Treasury issued the finalized 

technical guidance (DATA Act Information Model Schema, 

version 1.0) in April 2016 intended to provide a stable base for 

agencies and enterprise resource planning (ERP) vendors to 

develop data submission plans. Treasury also released an alpha 

version of the broker in April 2016 and a beta version of the 

broker in June 2016. On September 30, 2016, Treasury released 

its latest version of the broker, which it stated was fully capable 

of performing the key functions of extracting and validating 

agency data. Following this release, Treasury continued to 

release broker updates approximately every 2 weeks. The 

software patches developed by ERP vendors, intended to help 

agencies submit required data to the broker, were all released 

by the end of December 2016. This was identified as a high 

priority recommendation in letters sent from the Comptroller 

General to the Director of OMB and the Secretary of the 

Treasury in July 2016.

GAO-16-438

DATA Act: Section 5 

Pilot Design Issues 

Need to Be 

Addressed to Meet 

Goal of Reducing 

Recipient Reporting 

Burden

(April 2016)

1. To enable the development of 

effective recommendations for 

reducing reporting burden for 

contractors, the Director of OMB 

should ensure that the procurement 

portion of the pilot reflects leading 

practices for pilot design.

Closed-implemented. 

Our review of the revised design for the procurement portion of 

the Section 5 Pilot updated in January 2017 found that it largely 

reflected all 5 leading practices for effective pilot design. For 

example, in the revised design OMB provides additional details 

regarding its assessment methodology, includes a data analysis 

plan to evaluate pilot results, describes a strategy for two-way 

stakeholder outreach, and includes additional details on 

scalability of the pilot design. As a result we are closing this 

recommendation as implemented.
Appendix II: Status of GAO’s 

Recommendations Related to the DATA Act 

and Data Transparency

Page 39 GAO-17-496 Risks to Data Quality

Report Recommendations Implementation Status 

GAO-16-698

Improvements 

Needed in Reviewing 

Agency 

Implementation Plans 

and Monitoring 

Progress

(July 2016)

1. To help ensure effective governmentwide implementation and that 

complete and consistent spending 

data will be reported as required by

the DATA Act, the Director of OMB, 

in collaboration with the Secretary of 

the Treasury, should establish or 

leverage existing processes and 

controls to determine the complete 

population of agencies that are 

required to report spending data 

under the DATA Act and make the 

results of those determinations 

publicly available.

Open. As we previously reported, OMB stated that each agency 

is responsible for determining whether it is subject to the DATA 

Act. To help agencies make that determination, OMB published 

guidance in the form of frequently asked questions and stated 

that the agencies may consult with OMB for additional counsel. 

In response to our recommendation, OMB staff told us they have 

reached out to federal agencies to identify which agencies have 

determined that they are exempt from reporting under the DATA 

Act and prepared a list of such agencies. However, OMB has not 

provided us the list or the procedures for reviewing agency 

determinations and compiling the results. In addition, OMB has 

not established procedures for ensuring non-exempt agencies 

are reporting spending data as required. Finally, OMB has not 

stated whether it will make the results of the determinations 

publicly available.

Further, additional clarification would improve the usefulness of 

the frequently asked questions. For example, they state “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.” However, the SF 

133 Report for the third quarter of 2016 includes entities such as 

the Postal Service which are not required by the DATA Act to 

report financial and payment information. In explaining the 

frequently asked questions to us, OMB officials clarified that they 

meant that an entity is required to report if its data appears on 

the SF 133 and it meets the applicable statutory definition of 

agency. The frequently asked questions document does not 

clearly communicate this two-prong approach. Additionally, 

OMB’s verbal clarification when meeting with us does not 

account for those entities that meet the statutory definition of 

agency and are required by the DATA Act to report financial and 

payment information but do not appear on the SF 133. This was 

identified as a high priority recommendation in a letter sent from 

the Comptroller General to the Director of OMB in Spring 2017.

2. To help ensure effective governmentwide implementation and that 

complete and consistent spending 

data will be reported as required by 

the DATA Act, the Director of OMB, 

in collaboration with the Secretary of 

the Treasury, should reassess, on a 

periodic basis, which agencies are 

required to report spending data 

under the DATA Act and make 

appropriate notifications to affected 

agencies.

Open. OMB does not have plans to reassess, on a periodic 

basis, which agencies are required to report spending data 

under the DATA Act. We continue to believe action on this 

recommendation is important to effectively implement the DATA 

Act. This was identified as a high priority recommendation in a 

letter sent from the Comptroller General to the Director of OMB 

in Spring 2017.
Appendix II: Status of GAO’s 

Recommendations Related to the DATA Act 

and Data Transparency

Page 40 GAO-17-496 Risks to Data Quality

Report Recommendations Implementation Status 

3. To help ensure effective 

implementation of the DATA Act by 

the agencies and facilitate the further 

establishment of overall governmentwide governance, the Director of 

OMB, in collaboration with the 

Secretary of the Treasury, should 

request that non-Chief Financial 

Officers Act of 1990 (CFO Act)

agencies required to report federal 

spending data under the DATA Act 

submit updated implementation 

plans, including updated timelines 

and milestones, cost estimates, and 

risks, to address new technical 

requirements.

Open. On June 15, 2016, OMB directed CFO Act agencies to 

update key components of their implementation plans by August 

12, 2016. The requirement did not extend to non-CFO Act 

agencies. OMB stated that it is monitoring non-CFO Act 

agencies by providing feedback to non-CFO Act agencies 

through workshops instead of requesting updated 

implementation plan information. According to OMB officials, 

OMB has not followed-up with non-CFO Act agencies or 

requested updated implementation plan information because 

they are working with the CFO Act agencies which comprise 

approximately 90 percent of federal spending. In addition to 

these outreach efforts, OMB has worked with Treasury to 

engage with small and independent agencies through weekly 

phone calls and other forms of communication. However, the 

DATA Act applies to most federal agencies, and we believe that 

it is important to monitor smaller agencies’ implementation plans 

as well as large agencies. This was identified as a high priority 

recommendation in a letter sent from the Comptroller General to 

the Director of OMB in Spring 2017.

4. To help ensure effective 

implementation of the DATA Act by 

the agencies and facilitate the further 

establishment of overall governmentwide governance, the Director of 

OMB, in collaboration with the 

Secretary of the Treasury, should 

assess whether information or plan 

elements missing from agency 

implementation plans are needed and 

ensure that all key implementation 

plan elements are included in 

updated implementation plans.

Closed–Implemented. On December 8, 2016, OMB testified 

that OMB had reviewed implementation plan updates from the 

24 CFO Act agencies, which enabled them to track and assess 

agency progress toward successful implementation and identify 

areas where subsequent action was needed. OMB also 

conducted in-person follow-up meetings with nine agencies that 

reported significant issues to better understand their challenges. 

We determined that these actions meet the intent of our 

recommendation.
Appendix II: Status of GAO’s 

Recommendations Related to the DATA Act 

and Data Transparency

Page 41 GAO-17-496 Risks to Data Quality

Report Recommendations Implementation Status 

GAO-17-156

DATA Act: OMB and 

Treasury Have Issued 

Additional Guidance 

and Have Improved 

Pilot Design but 

Implementation 

Challenges Remain 

(December 2016)

1. In order to ensure that the 

procurement portion of the Section 5 

Pilot better reflects leading practices 

for effective pilot design, the Director 

of OMB should clearly document in 

the pilot's design how data collected 

through the centralized certified 

payroll reporting portal will be used to 

test hypotheses related to reducing 

reporting burden involving other 

procurement reporting requirements. 

This should include documenting the 

extent to which recommendations 

based on data collected for certified 

payroll reporting would be scalable to 

other Federal Acquisition Regulationrequired reporting and providing 

additional details about the 

methodology that would be used to 

assess this expanded capability in 

the future.

Closed–implemented. In response to our recommendation, 

OMB has made some revisions to the procurement portion of the 

pilot design including adding additional explanatory language. 

Our review of the revised design for the procurement portion of 

the Section 5 Pilot updated in January 2017 found that it largely 

reflected all 5 leading practices for effective pilot design. As a 

result we are closing this recommendation as implemented.

GAO-17-460

DATA Act: Office of 

Inspector General 

Reports Help Identify 

Agencies’ 

Implementation 

Challenges 

(April 2017)

1. We recommend that the Director of 

OMB and the Secretary of the 

Treasury establish mechanisms to 

assess the results of independent 

audits and reviews of agencies’ 

compliance with the DATA Act 

requirements, including those of 

agency Offices of Inspectors General, 

to help inform full implementation of 

the act’s requirements across 

government.

Open. OMB stated that it generally concurred with our 

recommendation, but noted that OIG readiness reviews are just 

one of its agency engagement efforts, which also includes

reviewing agency implementation plans, holding numerous 

meetings with the agencies, and requesting regular progress 

updates on the agencies’ implementation efforts. We recognize 

that OMB’s efforts to engage regularly with agencies are helpful 

for monitoring agencies’ implementation. However, it is also 

important to use information in independent audits and reviews 

to validate agencies’ progress. This was identified as a high 

priority recommendation in a letter sent from the Comptroller 

General to the Director of OMB in Spring 2017.
Appendix III: Deficiencies Reported in CFO Act 

Agencies’ Fiscal Year 2016 Financial Reports 

That May Affect Data Quality

Page 42 GAO-17-496 Risks to Data Quality

Table 1: Deficiencies Auditors Reported in Chief Financial Officers Act of 1990 (CFO Act) Agencies’ Fiscal Year 2016 Financial 

Reports That May Affect Data Quality

Agency Deficiency category

Accounting and Financial 

Management

Financial Management 

Systems

Information Technology 

Security and Controls

Department of Agriculturea  — 

Department of Commerce — — 

Department of Defenseb — — —

Department of Education — — 

Department of Energyc — — —

Department of Health and Human 

Servicesa   

Department of Homeland Securitya   

Department of Housing and Urban 

Developmentb — — —

Department of the Interior  — 

Department of Justicec — — —

Department of Labor — — 

Department of Statea   

Department of Transportationa  — 

Department of the Treasurya   

Department of Veterans Affairsa   

Environmental Protection Agency  — 

General Services Administration  — 

National Aeronautics and Space 

Administration

— — 

National Science Foundation — — 

Nuclear Regulatory Commissionc — — —

Office of Personnel Managementa  — 

Small Business Agency  — 

Social Security Administration  — 

U.S. Agency for International 

Developmenta  — —

Total 14 5 18

Legend: 

— = not applicable.

= Significant deficiency or material weakness identified in deficiency category.

Source: GAO analysis of CFO Act agencies' performance and accountability reports or agency financial reports for fiscal year 2016. | GAO-17-496

Appendix III: Deficiencies Reported in CFO 

Act Agencies’ Fiscal Year 2016 Financial 

Reports That May Affect Data Quality
Appendix III: Deficiencies Reported in CFO Act 

Agencies’ Fiscal Year 2016 Financial Reports 

That May Affect Data Quality

Page 43 GAO-17-496 Risks to Data Quality

a

Agency auditor determined noncompliance with Section 803(a) of the Federal Financial Management 

Improvement Act of 1996 (FFMIA).

b

Agency did not issue its performance and accountability report or agency financial report by 

February 28, 2017, therefore it was not included in our review.

c

Auditors did not report any material weaknesses or significant deficiencies relevant to Digital 

Accountability and Transparency Act of 2014 (DATA Act) reporting.
Appendix IV: GAO Contacts and Staff 

Acknowledgements

Page 44 GAO-17-496 Risks to Data Quality

J. Christopher Mihm, (202) 512-6806 or mihmj@gao.gov and Paula M. 

Rascona, (202) 512-9816 or rasconap@gao.gov

In addition to the above contacts, Peter Del Toro (Assistant Director), 

Michael LaForge (Assistant Director), Kathleen Drennan (Analyst-inCharge), Theodore Alexander, Maria C. Belaval, Thomas Hackney, 

Charles Jones, Kirsten Leikem, Robert L. Gebhart, Carroll M. Warfield, 

Jr., James Skornicki, Sophie Geyer, Mark Canter, James Sweetman, Jr., 

Andrew J. Stephens, Carl Ramirez and Jenny Chanley made major 

contributions to this report. Additional members of GAO’s DATA Act 

Internal Working Group also contributed to the development of this report.

Appendix IV: GAO Contacts and Staff 

Acknowledgements

GAO Contacts

Staff 

Acknowledgments
Related GAO Products

Page 45 GAO-17-496 Risks to Data Quality

DATA Act: Office of Inspector General Reports Help Identify Agencies’ 

Implementation Challenges. GAO-17-460. Washington, D.C.: April 26, 

2017.

DATA Act: Implementation Progresses but Challenges Remain. 

GAO-17-282T. Washington, D.C.: December 8, 2016.

DATA Act: OMB and Treasury Have Issued Additional Guidance and 

Have Improved Pilot Design but Implementation Challenges Remain.

GAO-17-156. Washington, D.C.: December 8, 2016.

DATA Act: Initial Observations on Technical Implementation.

GAO-16-824R. Washington, D.C.: August 3, 2016.

DATA ACT: Improvements Needed in Reviewing Agency Implementation 

Plans and Monitoring Progress. GAO-16-698. Washington, D.C.: July 29, 

2016.

DATA Act: Section 5 Pilot Design Issues Need to Be Addressed to Meet 

Goal of Reducing Recipient Reporting Burden. GAO-16-438. Washington, 

D.C.: April 19, 2016.

DATA Act: Progress Made but Significant Challenges Must Be Addressed 

to Ensure Full and Effective Implementation. GAO-16-556T. Washington, 

D.C.: April 19, 2016.

DATA Act: Data Standards Established, but More Complete and Timely 

Guidance Is Needed to Ensure Effective Implementation. GAO-16-261. 

Washington, D.C.: January 29, 2016.

Federal Spending Accountability: Preserving Capabilities of Recovery 

Operations Center Could Help Sustain Oversight of Federal 

Expenditures. GAO-15-814. Washington, D.C.: September 14, 2015.

DATA Act: Progress Made in Initial Implementation but Challenges Must 

be Addressed as Efforts Proceed. GAO-15-752T. Washington, D.C.: July 

29, 2015.

Federal Data Transparency: Effective Implementation of the DATA Act 

Would Help Address Government-wide Management Challenges and 

Improve Oversight. GAO-15-241T. Washington, D.C.: December 3, 2014.

Related GAO Products
Related GAO Products

Page 46 GAO-17-496 Risks to Data Quality

Government Efficiency and Effectiveness: Inconsistent Definitions and 

Information Limit the Usefulness of Federal Program Inventories.

GAO-15-83. Washington, D.C.: October 31, 2014.

Data Transparency: Oversight Needed to Address Underreporting and 

Inconsistencies on Federal Award Website. GAO-14-476. Washington, 

D.C.: June 30, 2014.

Federal Data Transparency: Opportunities Remain to Incorporate 

Lessons Learned as Availability of Spending Data Increases.

GAO-13-758. Washington, D.C.: September 12, 2013.

Government Transparency: Efforts to Improve Information on Federal 

Spending. GAO-12-913T. Washington, D.C.: July 18, 2012.

Electronic Government: Implementation of the Federal Funding 

Accountability and Transparency Act of 2006. GAO-10-365. Washington, 

D.C.: March 12, 2010.

(101319)
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