Semiannual Report to Congress: April 1 – September 30 2019 1

November 2019

TEST

Independent Audit of the

U.S. Federal Election Commission’s Compliance with the

Digital Accountability and Transparency Act of 2014

Assignment No. OIG-19-02

OFFICE OF INSPECTOR GENERAL

O

Prepared by: Brown and Company
FEDERAL ELECTION COMMISSION

WASHINGTON, D.C. 20463

Office of Inspector General

FEC OIG 2020-11-002 

TRANSMITTAL MEMORANDUM

TO: The Commission 

FROM: Christopher Skinner

 Inspector General

SUBJECT: Final Audit Report – Brown and Company’s Audit of the Federal Election 

Commission’s (FEC) Compliance with the Digital Accountability and 

Transparency Act of 2014 (the DATA Act)1

DATE: November 8, 2019 

ENCLOSURE: (1) Independent Audit of the U.S. Federal Election Commission’s Compliance 

with the Digital Accountability and Transparency Act of 2014 

The OIG contracted with Brown & Company to conduct the FEC fiscal year (FY) 2019 DATA 

Act audit. As a result, the enclosed report provides four (4) findings and five (5) 

recommendations that, if adequately implemented, will improve the overall accuracy and 

timeliness of FEC’s data submissions.

This performance audit was conducted in accordance with the Government Auditing Standards 

issued by the Government Accountability Office (GAO) and modeled after the Council of 

Inspectors General for Integrity and Efficiency (CIGIE) IG Guide to Compliance under the 

DATA Act.

2 The primary objective of the engagement was to satisfy the OIG’s responsibilities 

under the DATA Act by assessing the: (1) completeness, timeliness, quality, and accuracy of 

financial and payment data submitted for publication on USASpending.gov; and (2) the FEC’s 

implementation and use of Government-wide financial data standards established by the Office of 

Management and Budget (OMB) and the Treasury. 

The OIG reviewed Brown & Company’s report and related documentation and provided the 

required oversight throughout the course of the audit. Our review is permitted to ensure the 

accuracy of the audit conclusions but not to express an opinion of its results. The OIG’s review 

indicated that Brown & Company complied with all required Government Auditing Standards. 

We conclude that the FEC properly implemented and made proper use of the Government-wide 

financial data standards. Additionally, we acknowledge that the FEC made significant 

improvements with the procurement data elements recorded in File D1. 

 

1 The DATA Act, Public Law 113-101, requires the establishment of Government-wide standards for 

information on spending by Federal agencies, and all agencies must report spending data in compliance 

with the DATA Act. The OMB Management Procedures Memorandum No. 2016-03, data reported by 

Federal agencies in the second quarter for FY 2017 will be displayed on USAspending.gov by May 2017.

2 The IG Guide to Compliance under the DATA Act presents a common methodological and reporting 

approach for the IG community to utilize in the conduct of its mandated assignments. 
2

Detailed award level testing was performed on 100% of the 26 records included in File D1 and of 

the records tested, we determined that:

• 95% of data elements were complete;

• 88% of the data elements were timely; and

• 93% of the data elements were accurate 

While the FEC’s DATA files included most of the required information, we identified one control 

deficiency which impacted the completeness, timeliness, and accuracy of File C3 and D1

submissions.

4

A copy of the final audit report will be provided to the appropriate Congressional oversight 

committees, the GAO, OMB, and the Treasury. In addition, the report will be posted to the 

OIG’s web page and Oversight.gov.

In accordance with FEC Directive 50, Audit Follow-Up, FEC management shall provide a draft 

corrective action plan (CAP) to the OIG no later than 30 days from the final report date. 

Subsequently, the OIG shall review and provide comments, if necessary, to the CAP within 15 

days of receipt. Management shall provide the OIG an electronic copy of the CAP once finalized.

The initial OIG follow-up meeting to discuss outstanding audit recommendations will be held six 

(6) months from the issuance of the final report date. 

We appreciate the collaboration and support from FEC staff and the professionalism that Brown 

& Company exercised throughout the course of the audit. If you have any questions concerning 

the enclosed report, please contact my office at (202) 694-1015. 

Thank you.

cc: John Quinlan, Chief Financial Officer

Alec Palmer, Staff Director/Chief Information Officer

Gilbert A. Ford, Director of Budget

Gena Braveboy, DATA Act Implementation Program Manager

 3 File C contains the financial information for procurement actions. 

4 Please see Finding one (1) of the enclosed report for additional information.
Potentially Sensitive But Unclassified

Potentially Sensitive But Unclassified

Independent Audit of the

U.S. Federal Election Commission’s Compliance with the 

Digital Accountability and Transparency Act of 2014

Fiscal Year 2019

FEC IG Report No. 

FEC-OIG-02

November 08, 2019

Prepared by

Brown & Company Certified Public Accountants and Management 

Consultants, PLLC

6401 Golden Triangle Drive, Suite 310 

Greenbelt, Maryland 20770
Potentially Sensitive But Unclassified

To: Mr. Christopher Skinner, Inspector General

Federal Election Commission

Office of Inspector General

1050 First Street, NE

Washington, DC 20463

From: Brown & Company CPAs and Management Consultants, PLLC

Subject: Memo to Transmit the Independent Accountant’s Report of the Audit of the Federal 

Election Commission’s Compliance with the Digital Accountability and 

Transparency Act of 2014 Submission Requirements, for Fiscal Year 2019

Date: November 8, 2019

Brown & Company CPAs and Management Consultants, PLLC (Brown & Company) was engaged 

to perform a performance audit of the U.S. Federal Election Commission’s (FEC) compliance with 

the Digital Accountability and Transparency Act of 2014 (DATA Act), for Fiscal Year 2019 as 

required by the Act. This memo serves as the transmittal memo to the Office of Inspector General 

(OIG), FEC. 

Brown & Company is providing the FEC’s management with this Final Report for review and 

comment. 

It was a pleasure working with the various individuals with the OIG’s office as well as the 

individuals at the FEC who provided the information included in the audit report.
Potentially Sensitive But Unclassified

U.S. Federal Election Commission

Independent Accountants’ Report on the Compliance with the 

Digital Accountability and Transparency Act of 2014 Submission 

Requirements for Fiscal Year 2019

TABLE OF CONTENTS

Independent Auditor’s Report....................................................................................................................... 1

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

Purpose.......................................................................................................................................................... 3

Objective....................................................................................................................................................... 3

Scope and Methodology ............................................................................................................................... 3

Summary Result of Testing .......................................................................................................................... 4

Audit Findings & Recommendations............................................................................................................ 8

Appendix A – Objectives, Scope, Methodology and Criteria..................................................................... 17

Appendix B – Summary of Results for Record-Level Data Elements........................................................ 20

Appendix C – CIGIE’s DATA Act Anomaly Letter .................................................................................. 22

Appendix D – Management Response........................................................................................................ 24

Appendix E – Glossary of Abbreviations and Acronyms........................................................................... 27
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Independent Auditor’s Report

Office of Inspector General for 

United States Federal Election Commission 

Washington, DC

The Office of Inspector General for United States Agency for the United States Federal Election 

Commission (FEC) contracted Brown & Company CPAs and Management Consultants, PLLC, to conduct 

a performance audit of FEC’s fiscal year (FY) 2019 first quarter financial and award data as of December 

31, 2018, in accordance with the Digital Accountability and Transparency Act of 2014 (DATA Act). To 

clarify the reporting requirements under the DATA Act, the Office of Management and Budget (OMB) 

and U.S. Department of Treasury (Treasury) published 57 data definition standards and required Federal 

agencies to report financial and award data on USASpending.gov.

The audit objectives were to assess (1) completeness, timeliness, quality, and accuracy of FEC’s FY 2019 

first quarter financial and award data submitted to Treasury for publication on USASpending.gov and (2) 

FEC’s implementation and use of the government-wide financial data standards established by OMB and 

Treasury. FEC’s management is responsible for reporting financial and award data in accordance with 

these standards, as applicable. 

We conducted our performance audit in accordance with generally accepted government auditing 

standards (GAGAS). 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. Our performance audit involves performing procedures to obtain evidence about the FY 2019 

first quarter financial and award data. The nature, timing, and extent of the procedures selected depend on 

our judgment, including an assessment of the risks of material misstatement of the FY 2019 first quarter 

financial and award data, whether due to fraud or error. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our audit objectives. 

We found that the FY 2019 first quarter financial and award data of FEC for the quarter ended December 

31, 2018, is presented in accordance with OMB and Treasury published 57 data definition standards, as 

applicable, for DATA Act reporting in all material respects. We found that the data FEC submitted 

generally complied with the requirements for completeness, timeliness, quality, and accuracy. To help 

strengthen FEC’s internal controls over its DATA Act reporting, we identified areas of improvement 

regarding completeness, accuracy and timeliness of reported data and made five recommendations.

The purpose of this report is solely to describe the scope of our testing and the results of that testing. 

Accordingly, the report is not suitable for any other purpose.

This report is intended for the information and use of the FEC management, OIG and the U.S. Congress, 

and is made available to the public.

Greenbelt, Maryland

November 8, 2019
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U.S. Federal Election Commission

Independent Accountants’ Report on the Compliance with the 

Digital Accountability and Transparency Act of 2014 Submission 

Requirements for Fiscal Year 2019

Background

U.S. Federal Election Commission 

The Federal Election Commission (FEC) administers and enforces federal campaign finance law. 

Established in 1974, opened in 1975, the mission of the FEC is to protect the integrity of the federal 

campaign finance process by providing transparency and fairly enforcing and administering 

federal campaign finance laws. The FEC ensures disclosure requirements are met for political 

funding efforts. 

The FEC is required to comply with the Accountability of Tax Dollars Act of 2002 (ATD Act) to 

have its financial statements audited annually, and the Digital Accountability and Transparency 

Act of 2014 (DATA Act) for FY 2019 and 2021 to improve the ability of Americans to track and 

understand government spending. The FEC Office of Inspector General (OIG) has oversight and/or 

reporting requirements that are mandated by these government-wide Acts. For this reporting 

period, the FEC OIG contracted out the mandated audit services to an independent public 

accounting (IPA) firm and performs oversight of these services and the contract terms.

The DATA Act

In 2006, Congress passed, and the President signed the Federal Funding Accountability and 

Transparency Act of 2006 (FFATA)

1

. The purpose of FFATA was to increase transparency and 

accountability surrounding federal contracts and financial assistance awards. In accordance with 

FFATA, in December 2007, Office of Management and Budget (OMB) established a federal 

government website, USASpending.gov that contains obligation data on federal awards and 

subawards.

The DATA Act was enacted May 9, 2014, to expand the reporting requirements pursuant to 

FFATA. The DATA Act, in part, requires Federal agencies to report financial and award data in 

accordance with the established government-wide financial data standards. In May 2015, OMB 

and U.S. Department of Treasury (Treasury) published 57 data definition standards (commonly 

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

accordance with these standards for DATA Act reporting in January 2017. Subsequently, and in 

accordance with the DATA Act, Treasury began displaying Federal agencies’ data on 

USASpending.gov for taxpayers and policymakers in May 2017. 

The DATA Act also requires Inspectors General (IG) to issue a report to Congress assessing the 

completeness, timeliness, accuracy, and quality of a statistical sample of spending data submitted 

by the agency and the agency’s implementation and use of the data standards. The Council of the 

Inspectors General on Integrity and Efficiency (CIGIE) identified a timing anomaly with the

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

 1 Public Law 113-101 (May 9, 2014)
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Congress in November 2016; however, federal agencies were not required to report spending data 

until May 2017. To address this reporting date anomaly, the IGs provided Congress with their first 

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

subsequent reports, each following on a 2-year cycle. On December 22, 2015, CIGIE’s chair issued 

a letter memorializing the strategy for dealing with the reporting date anomaly and communicated 

it to the Senate Committee on Homeland Security and Governmental Affairs and the House 

Committee on Oversight and Government Reform. See Appendix C for the CIGIE’s DATA Act 

Anomaly Letter.

Starting in FY 2019, OMB Circular A-123, Appendix A, Management of Reporting and Data 

Integrity Risk (M-18-16), established that agencies must develop a Data Quality Plan (DQP) to 

identify a control structure tailored to address identified risks. Quarterly certifications by the 

Senior Accountable Officials (SAO) should be based on the considerations of the agency’s DQP.

Purpose

The DATA Act, in part, requires Federal agencies to report financial and award data in accordance 

with the established government-wide financial data standards.

Objective 

The objectives of the audit of the FEC’s compliance with the DATA Act were to assess the (1) 

completeness, timeliness, accuracy, and quality of the FEC’s FY 2019 first quarter financial and 

award data submitted to Treasury for publication on USAspending.gov, and (2) the FEC’s 

implementation and use of the government-wide financial data standards established by the Office 

of Management and Budget (OMB) and Treasury.

Scope and Methodology

We followed guidance from the CIGIE’s Federal Audit Executive Council (FAEC)2. The FAEC 

guide documents a common methodological framework, developed in consultation with the U.S. 

Government Accountability Office (GAO), for IGs to conduct required DATA Act reviews. We 

also reviewed applicable laws, regulations, FEC policies and procedures, and other documentation 

related to the DATA Act. We examined the total population of 26 records in File D1 for FY 2019 

first quarter financial and award data submitted by the agency for publication on 

USAspending.gov. 

The scope includes examining DATA Act information reported in FEC’s FY 2019 first quarter 

financial and award data files listed below:

• File A: Appropriations Account,

• File B: Object Class and Program Activity,

• File C: Award Financial, and

• File D1: Award (Procurement).

 2 CIGIE FAEC Inspectors General Guide to Compliance under the DATA Act, February 14, 2019.
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We conducted our fieldwork from July 3, 2019 through October 23, 2019 in accordance with 

generally accepted government auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our audit objectives. 

Additional details on our scope and methodology are outlined in Appendix A.

Summary Result of Testing

Completeness and Timeliness of the Agency Submission

We evaluated FEC’s DATA Act submission to Treasury’s DATA Act Broker and determined that 

the submission was timely. We determined the timeliness of the agency submission by verifying 

the date of the certification of the submission in the Treasury DATA Act Broker within the 

established timeframe determined by the Treasury DATA Act Project Management Office (PMO), 

traditionally within 45 days of quarter end. Due to the government shutdown between December 

22, 2018 and January 25, 2019, the due date for agency submissions for FY 2019 first quarter data 

was March 20, 2019. FEC completed their DATA Act submission on March 20, 2019. 

To be considered a complete submission, we evaluated Files A, B, C, and D1 to determine that all 

transactions and events that should have been recorded were recorded in the proper period. We 

concluded that File A and B submissions are complete. However, FEC DATA Act submission for 

Files C and D1 are not complete due to the following:

 We identified 9 unique awards missing from File D1; 

 We identified 10 unique awards missing from File C; and 

 We identified 1 unique award that should not have been recorded in File C

Some of these errors were attributed to the Agency and some were attributed to the Federal Shared 

Service Provider (FSSP) not processing award transactions timely in the financial system. For 

more information, see the Audit Finding Section: Finding1 and summarized in Tables 3 and 4.

Based on our testing results listed above, we determined that File C was not complete nor suitable 

for detailed testing of award level spending data. 

Summary-Level Data and Linkages for Files A and B

We reconciled Files A and B to determine if they were accurate. Additionally, we tested the 

linkages between Files A and B to determine if the linkages were valid and to identify any 

significant variances between the files. Based on our testing, we determined that Files A and B are 

accurate and we did not identify significant variances between Files A and B.

Reconciliation and Linkages for Files C and D1

We reconciled Files C and D1 to determine if they were accurate, and tested the linkages between 

Files C and D1 to determine if the linkages were valid and to identify any significant variances 

between the files. Based on the number of discrepancies noted above for completeness, we 

conclude that Files C and D1 FY 2019 first quarter submissions are not accurate. For more 
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Potentially Sensitive But Unclassified

information, see Finding and Recommendations Section: Finding 1 and summary Tables 3 

and 4.

Record-Level Award Data and Linkages for Files C and D1

We examined the total population of 26 records in File D1 and tested 57 data elements (as 

applicable) for completeness, accuracy, and timeliness. 

Completeness of Data Elements

The projected error rate for the completeness of the data elements is 5.13%. A data element 

was considered complete if the required data element that should have been reported was 

reported.

Timeliness of the Data Elements

The projected error rate for the timeliness of the data elements is 11.90%. The timeliness 

of data elements was based on the reporting schedules defined by the procurement and 

financial assistance requirements (FFATA, Federal Acquisition Regulation (FAR), Federal 

Procurement Data System Next Generation (FPDS-NG), and DATA Act Information 

Model Schema (DAIMS)). 

We tested the timeliness of reporting records into FPDS-NG by comparing the contract 

date to the prepared date in FPDS-NG. We noted that 2 PIIDs listed in File D1 were not 

recorded within 3 business days after contract award in accordance with FAR Part 4.604.

For more details, see the Audit Findings and Recommendations Section: Finding 3 

and summarized in Table 7.

Accuracy of the Data Elements 

The projected error rate for the accuracy of the data elements is 6.89%. A data element was 

considered accurate when amounts and other data relating to recorded transactions were 

recorded in accordance with the DAIMS, Reporting Submission Specification (RSS), 

Interface Definition Document (IDD), and the online data dictionary, and agree with the 

authoritative source records. For more details, see the Audit Findings and 

Recommendations Section: Finding 2 and summarized in Table 6.

We acknowledge that the FEC has made considerable improvement in the accuracy of data 

elements recorded in File D1. While the overall accuracy of applicable data elements is 

93.11%, we noted significant discrepancies with some of the dollar-value related data 

elements (DE14 and DE15) and the agencies sourced records (see Table 1 below). 

We note that most if not all of these discrepancies are not attributable to the FEC. The 

totals for these applicable data fields are recalculated in FPDS-NG based on all 

modifications that are finalized in the system at a given point in time. Individual FPDSNG contract action reports show a “running total”, as of the current date, that may be 

different than the actual value at the time of the award for the sampled procurement award. 

As a result, data for the Current Total Value of Award (DE14) and Potential Total Value 

of Award (DE 15) will be inconsistent with the contract award selected for testing which 

may overstate the error rates for these elements.
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The following table displays the results of the accuracy of the data elements that are 

associated with a dollar value. The absolute value of errors by data elements are not 

projected to the population.

Table 1 - Analysis of the Accuracy of Dollar Value-related Data Elements

Accuracy of Dollar-Value Related Data Elements

PIID

/FAIN

Data 

Element

Accurate NotAccurateNotApplicableTotal

Tested

Error 

Rate

Absolute Value 

of Errors

PIID 11 26 0 0 26 0% $ 0

PIID 14 24 2 0 26 8% $ 553,047

PIID 15 21 5 0 26 19% $ 1,333,952

Total 71 7 0 78

Quality of the Data Elements

To assess the quality of the data elements, we used the midpoint of the range of the 

proportion of errors (error rate) for completeness, accuracy and timeliness. The highest of 

the three error rates was used as the determining factor of quality. Table-2 provides the 

range of error in determining the quality of the data elements.

Table 2 - Range of Error for Data Quality3

Highest Error Rate Quality Level

0% - 20% Higher

21% - 40% Moderate

41% and above Lower

Based on our test work and the highest error rate of 11.90%, we determined that the quality of 

FEC’s data is considered of “Higher” quality.

Implementation and Use of the Data Standards 

We have evaluated FEC’s implementation and use of the government wide financial data standards 

for spending information as developed by OMB and Treasury. FEC has fully implemented and are 

using those data standards as defined by OMB and Treasury. For the broker files tested, we 

generally found that the required elements were present in the file and that the record values were 

presented in accordance with the standards. For example, broker files contained such identifiers as 

main account code, subaccount code, and program activity. The summary of results for recordlevel data elements (Files C and D1) are shown in Appendix B.

 3 CIEGIE FAEC Inspectors General Guide to Compliance under the Data, provides a range of errors for determining 

the quality of the data elements. 
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Assessment of Internal Control over Source Systems

There are three systems used by FEC for DATA Act reporting: Comprizon.Buy a procurement 

management system for processing procurement awards; FPDS-NG a federal procurement data 

system for reporting procurement awards; and Pegasys a Financial Management System managed 

by United States Department of Agriculture (USDA) which is FEC’s FSSP.

FEC uses Comprizon.Buy and Pegasys as its source systems for processing and recording 

procurement and financial data respectively, and for generating its DATA Act submission. We 

performed procedures to determine whether internal controls over these systems, as they relate to 

its FY 2019 first quarter DATA Act submission, were properly designed, implemented, and 

operating effectively. Those procedures consisted of:

Gaining an understanding of the source systems used for recording procurement transactions and 

reporting under the DATA Act. 

• Reviewing USDA, Statement on Standards for Attestation Engagement No. 18 Report 

on Controls at National Finance Center for October 1, 2018 to July 31, 2019, for 

Pegasus and determining whether any issues were noted that could have an impact on 

the accuracy, timeliness, or quality of the DATA Act submission. 

• Obtaining an understanding of Complementary User Entity Controls (CUECs) required 

by the SOC report and implemented by FEC to determine whether gaps exist that might 

impact the accuracy, timeliness, or quality of the DATA Act submission. 

• Reviewing FEC’s FY 2018 Financial Statements to identify findings that could affect 

the reliability of the source system or data produced from it.

We found that FEC has designed and implemented effective internal controls over the applicable

source systems.

Assessment of Internal Controls over DATA Act Submission

We performed inquiry and reviewed control processes to determine whether internal controls over 

the DATA Act Submissions are adequate and operating effectively. Overall, we found that internal 

controls implemented over FY 2019 first quarter DATA Act submission has improved. However, 

they are not sufficient to ensure that discrepancies between Files C and D1 are identified and 

corrected prior to transmitting/certifying the data. Although the FEC DATA Act program team 

works to resolve warnings and errors in its DATA Act submission, all issues identified that require 

correction by the FSSP are not corrected timely. In addition, the FEC does not reconcile Files C 

and D1 prior to certifying the DATA Act submission to ensure completeness, accuracy and 

timeliness of reporting. For more information, see the Audit Findings and Recommendations

Section: Finding 1.

FEC has not developed a DQP. According to OMB Circular A-123, Appendix A, Management of 

Reporting and Data Integrity Risk (M-18-16), agencies were required to develop a DQP to help 

assess internal controls over data stating with the FY 2019 annual assurance process. For more 

information, see the Audit Findings and Recommendations Section: Finding 4.
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Audit Findings & Recommendations

Finding 1: FEC’s FY 2019 first quarter Files C and D1 submission were not complete, 

accurate, or timely and did not include all transactions and linkages. 

Condition: The DATA Act File C report is generated and submitted quarterly by the FSSP for 

FEC’s review prior to submitting to the Treasury Broker. The DATA Act File D1 Award and 

Awardee Attributes for Procurement requires the reporting of procurement award and awardee 

data. FEC records this data on a daily basis into Comprizon.Buy and FPDS-NG. File D1 data is 

imported to the USDA Repository on a quarterly basis and used to validate the Award ID/PIID in 

File C. The FEC has a process to periodically review Broker warning reports to research potential 

errors and determine if corrections are needed. However, the FEC does not reconcile Files C and 

D1 prior to certifying the submission. As a result, all discrepancies between File C and D1 were 

not identified and/or corrected timely. 

During our testing, we determined that FY 2019 first quarter File C submission did not include all 

transactions and linkages from File D1; and in addition, File D1 did not include all transactions 

and linkages from File C. As a result of follow-up performed, , we determined that File C was not 

complete or suitable for detailed testing. See Table 4 and 5 for detail of errors.

The difference between Files C and D1 are presented below.

Table 3 – Difference between Files C and D1

DATA Act File Amount

File C – Total Obligation Amount $ 2,265,622

File D1 – Federal Action Obligation $ 1,616,329

Difference $ 649,293

Table 4 – File D1 Errors

No. Award ID/PIID Records Amount

Error – Records not recorded in File D1 and the errors were attributable to FEC.

1 9531BP18G0002 1 (479,250.00) Not processed prior to 

submission

2 9531BP18P0008 1 3,516 Not processed prior to 

submission

3 9531BP19A0006 1 (5,000.00) Not processed prior to 

submission

4 FE9531BP17F0001 1 (4,186.00) Not processed prior to 

submission

5 9531BP19G0004 1 (15,000) Not processed prior to 

submission

6 9531BP19G0002 5 (14,700) Not processed prior to 

submission

Total 10 (514,620)
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No. Award ID/PIID Records Amount

Errors – Records recorded in File C and excluded in File D1 by the Agency

7 9531BP19L0002 1 (432,351.00) IAA /IGTs transactions 

8 9531BP19G0003 1 (30,000.00) IAA /IGTs transactions 

9 9531BP18P0026 8 (120,441) Other

Total 10 (582,792)

Grand Total 20 (1,097,412)

Table 5 – File C Errors

No. Award ID/PIID Records Amount

Error – Records recorded in File D1 and not recorded in File C. 

Errors were attributable to FSSP.

1

9531BP18F0007

1 58,516 Not processed prior to 

submission

2

9531BP19F5002

1 10,000 Not processed prior to 

submission

3

9531BP19F5004

1 16,873 Not processed prior to 

submission

4

9531BP19F5005

1 68,459 Not processed prior to 

submission

5

9531BP19F5006

1 31,474 Not processed prior to 

submission

6

9531BP19F5007

1 4,500 Not processed prior to 

submission

7

9531BP19F5008

1 93,093 Not processed prior to 

submission

8

9531BP19P0002

1 10,571 Not processed prior to 

submission

Total 8 293,486

Error- Records not recorded in File C and not submitted to FSSP timely.

The errors were attributable to the Agency.

9 FE15G004 1 68,006 Not recorded into financial 

system

10 9531BP19P0007 1 138,364 Not recorded into financial 

system

Total 2 206,370

Errors – Record recorded in File C but not submitted timely. The award was signed in FY 2018 Quarter 

4 and erroneously recorded in FY 2019. The error was attributable to the Agency.

11 9531BP18C0005 1 (51,738) FY18 Quarter 4 record 

processed in FY19

Total 1 (51,738)

Grand Total 11 448,118
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Cause: There are several causes which include:

• FEC’s does not have adequate control procedures to identify and correct discrepancies between 

Files C and File D1;

• FEC does not have a control process to ensure all award level transactions are included in the 

proper quarterly submission to the Treasury Broker; and

• FEC uses an internal management system to initiate, manage and approve awards in 

Comprizon.Buy; and thus, FEC enters awards into FPDS-NG which generates File D1. FEC 

relies on the FSSP to enter award data into Pegasys (financial management system) which 

generates File C. However, procurement award data is not always submitted and/or processed 

by the FSSP timely.

Effect: The inability to identify and correct data issues timely, increases the risk that data reported 

to USASpending.gov is not complete, accurate, and timely. This in turn decreases the reliability 

and usefulness of the data reported in the Federal spending.

Recommendation 1: We recommend the FEC OCFO document and implement a reconciliation 

process between File C and File D1 to ensure that discrepancies are identified and work with the 

FSSP to resolve File C errors prior to the SAO asserting to the completeness, timeliness and 

accuracy of DATA Act submission.

Recommendation 2: We recommend the FEC’s management ensure that any records missing 

from File D1 identified through the reconciliation process are corrected in a timely manner.

Management’s Response:

Management largely agrees with this finding and associated recommendations. The 

reduction in a number of issues from previous DATA Act reviews provides evidence of 

improvements due to the procedures instituted after those independent reviews. 

Additionally, FEC realizes DATA Act compliance challenges are visible throughout the 

government and with all shared service providers (SSP). In July 2019, GAO published a 

report number GAO-19-537 titled Customer Agencies' Experiences Working with Shared 

Service Providers for Data Submissions. GAO found that the 27 agencies that responded 

to its survey use SSP’s for various DATA Act services. Sixteen of the 27 SSP customer 

agencies reported that they experienced challenges.

The continuing existence of discrepancies in FEC’s DATA Act files, however, suggests that 

additional efforts are needed. The OCFO plans to institute a revised reconciliation 

procedure to identify discrepancies for quarter three of FY20 and will review tracking 

systems that assist in communication with the SSP to promote timely and accurate 

adjustments by the quarterly certification due dates. Additionally, we plan to review the 

procedures for processing procurement data to help reduce the number of discrepancies 

that arise during the reconciliation process. While we believe that these efforts can reduce 

discrepancies, ensuring that all discrepancies are resolved is likely an unrealistic 

standard, given the limited timelines and multiple data sets afforded by the DATA Act. 

Given this, in drafting a Data Quality Plan (NFR 2019-04), we plan to explore materiality 
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thresholds and high-risk areas for discrepancies. Our hope is that this approach will 

provide a framework for future independent reviews and lead to improvement in the 

underlying data submissions.

Management’s complete response is provided in Appendix D.

Auditor’s Evaluation of Management’s Response

Management’s response is appropriate to address the findings and recommendations. 

Documenting and implementing a reconciliation process between File C and File D1 

would help to ensure discrepancies are identified and resolved prior to the submission of 

DATA Act files and improve the quality of the FEC’s DATA Act reporting.

Finding 2: FY 2019 first quarter File D1 detail award-level spending data included 

inaccurate data elements.

Condition: OMB established data element requirements for compliance with the DATA Act. 

Treasury developed data schemas for reporting of this required data. The DATA Act File D1 

Award and Awardee Attributes for Procurement requires the reporting of procurement award and 

awardee data. The FEC record this data on a daily basis in the FPDS-NG. File D1 data is imported 

to the USDA DATA Act Repository (Repository) on a quarterly basis and used to validate the 

Award ID in File C. 

During our testing, we determined that FY 2019 first quarter File D1 included inaccurate data 

elements. We examined the total population of 26 records in File D1. For each sampled record, we 

evaluated whether standard data elements included in Files C and D1, were accurate. We examined 

contract documentation to determine the accuracy of the data and identified 20 data element errors.

See Table 6 below for details.
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Table 6 - Accuracy Results by Data Elements (Errors only)

PIID DE Description Errors

Errors in the Data Elements Not Attributable to FEC

9531BP19P0005 

9531BP19F5008

9531BP19F5004 3 Ultimate Unique Identifier 3

Unable to find the Ultimate 

Parent Unique identifier in 

D&B or SAM.

9531BP18P0027, 

(Mod 1 and 3) 14

Current Total Value of

Award

2 Data element per File D1

did not agree with sourced 

records

9531BP18P0027

(Mod 1 and 3)

9531BP17C002 

9531BP19F5008

FE15G004 15

Potential Total Value of

Award 5

Data element per File D1 

did not agree with sourced 

records

9531BP19F5006 30b & c

Primary Place of

Performance Address 1

Primary Place of

Performance Address is the 

awardee’s mailing address

Total 11

Errors in the Data Elements Attributable to FEC

9531BP19F5002 16 Contract Award Type 1

Contract award type not 

stated in the contract.

9531BP19P0002 26

Period of Performance Start 

Date 1

Period of Performance Start 

Date entered incorrectly 

FDPS-NG

9531BP17F0043 

9531BP17C002 

9531BP18P0034 27

Period of Performance 

Current End Date 3

Period of Performance 

Current End Date entered 

incorrectly FDPS-NG

9531BP17F0043 

9531BP17C002 

9531BP18F0007 

9531BP18P0034 28

Period of Performance 

Potential End Date 4

Period of Performance 

Potential End Date entered 

incorrectly FDPS-NG

Total 9

Grand Total 20

Cause: The total awards processed in FY 2019 first quarter had information included in File D1 

that did not agree with the agency’s underlying sourced records (e.g., contract, service agreement, 

modification) which were due to 1. Data entry errors; and 2. Errors (related to DE 14 and 15) 

attributable to how FPDS-NG is recalculating modifications that are finalized in the system at a 

particular point in time. Individual FPDS-NG contract action reports show a “running total”, as 

of the current date, that may be a different value than the actual value at the time of the award for 

the sampled procurement award. As a result, data for the Current Total Value of Award and 

Potential Total Value of Award elements will be inconsistent with the data reported File D1 which 

may overstate the error rates for these elements. 
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Effect: The inability to identify and correct data issues timely, increases the risk that data reported 

to USASpending.gov is not complete, accurate, or timely. This in turn decreases the reliability and 

usefulness of the data reported in the Federal spending.

Recommendation 3: We recommend that FEC’s management reinforce the control procedures 

and processes in place to ensure award level data is accurately entered into FPDS-NG and any 

DATA Act reporting errors are identified and corrected within three business days.

Management’s Response:

Management largely agrees with this finding and associated recommendation. The 

reduction of discrepancies to less than 10 percent of files represents improvement from 

previous reviews, but also indicates further improvements are needed. Additionally, over 

one-third of the remaining discrepancies result from known government-wide systems 

limitations. Given the number of records, DATA Act timelines and known systems based 

limitations, we believe the best approach is to c for discrepancies and institute a risk-based 

comparison with the source contract files. We intend to institute this by the third quarter 

of FY20. This process should reduce discrepancies, but likely will not ensure that all award 

level discrepancies are resolved. Similar to our response for NFR2019-1, we intend to 

explore materiality thresholds and high-risk areas for discrepancies in the development of 

the Data Quality Plan.

Management’s complete response is provided in Appendix D.

Auditor’s Evaluation of Management’s Response

Management’s response is appropriate to address the findings and recommendation. 

Implementing a process to ensure the accuracy and timeliness of award level data entered

into FPDS-NG would help improve the quality of the data reported to USASpending. 

Finding 3: FEC did not process two contract awards timely in FPDS-NG as required by FAR.

Condition: The DATA Act File D1 Award and Awardee Attributes for Procurement requires the 

reporting of procurement award and awardee data. The FEC records this data on a daily basis in 

the FPDS-NG. File D1 data is imported to the Repository on a quarterly basis and used to validate 

the Award ID in File C. If the two files do not match, the FEC works to reconcile the data.

We examined the total population of 26 records in File D1 for testing. We tested the timeliness for 

reporting records into FPDS-NG by comparing the contract date to the prepared date in FPDSNG. We noted that 2 of 26 recodes listed in File D1 were not recorded within 3 business days after 

contract award in accordance with FAR Part 4.604.

The exception for timeliness in File D1:
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Table 7 - Exceptions for Timeliness

PIID

Number 

of Days

9531BP17C002/ P00011 4

9531BP18F0007/ P00003 15

Criteria: CIGIE FAEC Inspectors General Guide to Compliance under the DATA Act, February 

14, 2019, defines Timeliness for the DATA Act as:

Reporting of the agency DATA Act submission to the DATA Act Broker is in accordance 

with the schedule established by the Treasury DATA Act Project PMO.

The guide states, “to assess the timeliness of the data elements:

• Award financial data elements within File C should be reported within the quarter in 

which it occurred. 

• Procurement award data elements within File D1 should be reported in FPDS-NG 

within 3 business days after contract award in accordance with the FAR Part 4.604.”4

Cause. The FEC’s control procedures are not adequate to ensure all procurement award data is 

entered in FPDS-NG within the timeframe to comply with the FAR.

Effect: There is a risk that untimely data reporting decreases the reliability and usefulness of the 

data reported in the Federal spending. In addition, increases the risk that the FEC may not be in 

compliance with applicable FAR requirements.

Recommendation 4: We recommend FEC’s management reinforce written policies and 

procedures and internal controls over reporting of procurement award data to ensure awards are 

entered into FPDS-NG within 3 business days.

Management’s Response:

Management agrees with this finding and recommendation. We are investigating an email 

notification reminder system for contract awards. The reminder system will help promote 

necessary data entry within three days to the FPDS system. In addition, we plan to explore 

a system for tracking instances where meeting the three-day timeframe is not possible due 

to system or other issues.

Management’s complete response is provided in Appendix D.

Auditor’s Evaluation of Management’s Response

Management’s response is appropriate to address the findings and recommendation. 

Implementing a process to ensure awards are entered into FPDS timely, would improve 

the timeliness and quality of FEC’s DATA Act reporting.

 4 FAR Subpart 4.6 - Contract Reporting, 4.604 Responsibilities.
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Finding 4: FEC did not develop a Data Quality Plan (DQP) to Improve Risk Management 

Over the DATA Act Process.

Condition: The FEC has not developed a DQP to reduce risk of misreported data. The FEC’s FY 

2019 first quarter DATA Act submission resulted in several exceptions. As noted in other Notice 

of Findings and Recommendations, the FEC has exceptions in completeness, accuracy, and 

timeliness for Files A, B, C and D1.

Starting in FY 2019, OMB Circular A-123, Appendix A, Management of Reporting and Data 

Integrity Risk (M-18-16), established that agencies must develop a DQP to identify a control 

structure tailored to address identified risks. 

Criteria: OMB18-16, “Appendix A to OMB Circular No. A-123, Management of Reporting and 

Data Integrity Risk,” June 6, 2018, requires DATA Act reporting agencies to develop and maintain 

a DQP effective fiscal year 2019. The OMB M-18-16 states:

Agencies that have determined they are subject to the DATA Act reporting must develop 

and maintain a Data Quality Plan that considers the incremental risks to data quality in 

Federal spending data and any controls that would manage such risks in accordance with 

OMB Circular No. A-123.

Quarterly certifications of data submitted by agency Senior Accountable Officials (SAO) 

should be based on the consideration of the data quality plan and the internal controls 

documented in their plan as well as other existing controls that may be in place, in the 

annual assurance statement process. Consideration of this plan must be included in 

agencies’ existing annual assurance statement over ICOR5 beginning in FY 2019 and 

continuing through the statement covering fiscal year 2021 at a minimum, or until agencies 

determine that they can provide reasonable assurances over the data quality controls that 

support achievement of the reporting objective in accordance with the DATA Act.

The Data Quality Plan should cover significant milestones and major decisions 

pertaining to:

• Organizational structure and key processes providing internal controls for spending 

reporting.

• Management’s responsibility to supply quality data to meet the reporting objectives for 

the DATA Act in accordance with OMB Circular No. A-123.

Cause: The FEC relied on other internal control policies and procedures to assess and monitor 

control over the DATA Act reporting requirements that did not ensure quality reporting.

Effect: The lack of a DQP increased the risk of misreported data, and decreases the reliability and 

usefulness of the data reported in the USAspending.gov.

Recommendation 5: We recommend the FEC’s management develop and implement a DQP to 

improve risk management over DATA reporting and to comply with OMB M-18-16.

 5 Internal control over reporting (ICOR)
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Management’s Response:

We agree with this finding and recommendation and intend to have a Data Quality Plan in 

place by the third quarter of FY 20. In response to the OMB guidance from June 6th, 2018 

and previous OIG DATA Act recommendations, management instituted a number of data 

checks and reviews. It did not, however, formalize these processes by October 2018 for use 

in the DATA Act sample. We intend to formalize these processes, and incorporate revised 

procedures as recommended by OIG where appropriate.

Management’s complete response is provided in Appendix D.

Auditor’s Response to Agency Comments

Management’s response is appropriate to address the findings and recommendation. 

Developing a DQP for DATA Act reporting will help to reduce the risk of misreported data 

and increase the reliability and usefulness of the data reported in the USAspending.gov.
APPENDIX A

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Appendix A – Objectives, Scope, Methodology and Criteria

Objectives

The objectives of the audit of the FEC’s compliance with the DATA Act audit were to assess the 

(1) completeness, timeliness, accuracy, and quality of the FEC’s FY 2019 first quarter financial 

and award data submitted to Treasury for publication on USAspending.gov and (2) FEC’s 

implementation and use of the government-wide financial data standards established by OMB and 

Treasury.

Scope

The scope of this engagement is the FEC’s FY 2019 first quarter financial and award data 

submitted for publication on USASpending.gov. Work performed was in accordance with 

generally accepted government auditing standards, relevant DATA Act guidance and policies

issued by the GAO, OMB, and CIGIE, including the Inspectors General Guide to Compliance 

under the DATA Act, dated February 14, 2019.

The scope includes examining DATA Act information reported in the FEC’s FY 2019 first quarter 

financial and award data files listed below:

• File A: Appropriations Account,

• File B: Object Class and Program Activity,

• File C: Award Financial, and

• File D1: Award (Procurement).

The FEC does not issue grants, therefore Files D2 and F do not apply. In addition, as data elements 

reported in File E are derived from a third party, we did not test File E. We determined that File C 

was not suitable for detailed testing, as such we used File D1 for testing of award-level data 

elements. As there were only 26 records included in File D1, we tested 100% if the population.

Testing Methodology

To accomplish our objectives, we:

• obtained an understanding of any regulatory criteria related to the FEC’s 

responsibilities to report financial and award data under the DATA Act. (See below for 

a list criteria); 

• assessed the internal and information system controls in place as they relate to the 

extraction of data from the source systems and the reporting of data to Treasury’s 

DATA Act Broker, in order to assess audit risk and design audit procedures; 

• assessed internal controls over financial reporting for the DATA Act

• reviewed and reconciled the FY 2019, first quarter summary-level data submitted by 

the FEC for publication on USASpending.gov; 

• assessed the FEC’s implementation and use of the 57 data elements/standards (as 

applicable) established by OMB and Treasury; and
APPENDIX A

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• assessed the completeness, timeliness, accuracy, and quality of the financial and award 

data sampled; this included testing the FEC’s submission of Files A through D1. 

To test the FEC’s DATA Act submission of Files A through D1, we:

• reviewed the FEC’s certification and submission process;

• determined the timeliness of the FEC’s submission;

• determined completeness of summary level data for Files A and B;

• determined whether File C is complete and suitable for sampling;

• tested the total population for File D1;

• tested detailed record-level linkages for Files C and D1;

• tested detailed record-level data elements for Files C and D1 for completeness, 

accuracy, timeliness, and quality; and

• analyzed results.

Criteria

During our audit, we obtained an understanding of the following criteria as applicable to the 

FEC. 

Table 8- List of Criteria

Criteria Title

1 Digital Accountability and Transparency Act of 2014 

2 Federal Funding Accountability and 

Transparency Act of 2006 

3 The Federal Financial Management Improvement Act of 1996 

4 The Federal Managers’ Financial Integrity Act of 1982 

5 OMB Circular No. A-123 

6 OMB Circular No. A-123, Appendix A 

7 OMB – Management Procedures Memorandum No. 2016-03 

8 OMB – M-17-04 Additional Guidance for DATA Act Implementation: Further 

Requirements for Reporting and Assuring DATA Reliability 

9 OMB M – 10-06, Open Government Directive 

10 OMB’s Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, 

and Integrity of Information Disseminated by Federal Agencies 

11 OMB: Open Government Directive – Framework for the Quality of Federal Spending 

Information 

12 DATA Act Information Model Schema (DAIMS) v 1.3 (includes Reporting 

Submission Specification (RSS) & Interface Definition Document (IDD))

13 DAIMS v 1.3 Practices and Procedures 

14 The DATA Act Online Data Dictionary 

15 The Data Exchange Standard 

16 Data Quality Playbook 

17 Federal Spending Transparency Data Standards 

18 DATA Act Broker Validation Rules 
APPENDIX A

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Criteria Title

19 DATA Act Broker Submission Practices and Procedures 

20 U. S. Digital Services Playbook 

21 GAO Financial Audit Manual, Volume 1,2,3 

22 Government Auditing Standards 

23 Electronic Government: Implementation of the Federal Funding Accountability and 

Transparency Act of 2006
APPENDIX B

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Appendix B – Summary of Results for Record-Level Data Elements

Summary of the results of the detailed record-level test of data elements for Files C and D1. The 

results are listed in descending order by data element number.

Table 9 - FEC’s results for Data Elements

FEC’s results listed in descending order by accuracy rate percentage.

Accuracy (A), Completeness (C), Timeliness (T)

Error Rate6

DE Data Element Name A C T

50 Object Class 38% 38% 38%

51 Appropriations Account 38% 38% 38%

53 Obligation 38% 38% 38%

56 Program Activity 38% 38% 38%

15 Potential Total Value of Award 19% 0% 8%

28 Period of Performance Potential End Date 15% 0% 8%

3 Ultimate Parent Unique Identifier 12% 0% 8%

27 Period of Performance Current End Date 12% 0% 8%

14 Current Total Value of Award 8% 0% 8%

16 Contract Award Type 4% 0% 8%

26 Period of Performance Start Date 4% 0% 8%

30 Primary Place of Performance Address 4% 0% 8%

1 Awardee or Recipient Legal Entity Name 0% 0% 8%

2 Awardee or Recipient Unique Identifier 0% 0% 8%

4 Ultimate Parent Legal Entity Name 0% 0% 8%

5 Legal Entity Address 0% 0% 8%

6 Legal Entity Congressional District 0% 0% 8%

7 Legal Entity Country Code 0% 0% 8%

8 Legal Entity Country Name 0% 0% 8%

11 Federal Action Obligation 0% 0% 8%

17 NAICS 0% 0% 8%

18 NAICS Description 0% 0% 8%

22 Award Description 0% 0% 8%

23 Award Modification Amendment Number 0% 0% 8%

24 Parent Award Id 0% 0% 8%

25 Action Date 0% 0% 8%

31 Primary Place of Performance Congressional District 0% 0% 8%

32 Primary Place of Performance Country Code 0% 0% 8%

33 Primary Place of Performance Country Name 0% 0% 8%

34 PIID 0% 0% 8%

 6 All estimates from the sample have a margin of error no greater than plus or minus 5 percentage points unless 

otherwise noted
APPENDIX B

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FEC’s results listed in descending order by accuracy rate percentage.

Accuracy (A), Completeness (C), Timeliness (T)

Error Rate6

DE Data Element Name A C T

36 Action Type 0% 0% 8%

38 Funding Agency Name 0% 0% 8%

39 Funding Agency Code 0% 0% 8%

40 Funding Sub Tier Agency Name 0% 0% 8%

41 Funding Sub Tier Agency Code 0% 0% 8%

42 Funding Office Name 0% 0% 8%

43 Funding Office Code 0% 0% 8%

44 Awarding Agency Name 0% 0% 8%

45 Awarding Agency Code 0% 0% 8%

46 Awarding Sub Tier Agency Name 0% 0% 8%

47 Awarding Sub Tier Agency Code 0% 0% 8%

48 Awarding Office Name 0% 0% 8%

49 Awarding Office Code 0% 0% 8%

29 Ordering Period End Date 0% 0% 0%

54 Unobligated Balance 0% 0% 0%

57 Outlay 0% 0% 0%
APPENDIX C

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Appendix C – CIGIE’s DATA Act Anomaly Letter
APPENDIX C

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APPENDIX D

24

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Appendix D – Management Response
APPENDIX D

25

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APPENDIX D

26

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APPENDIX E

27

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Appendix E – Glossary of Abbreviations and Acronyms

ATD Act Accountability of Tax Dollars Act of 2002

CIGIE The Council of the Inspectors General on Integrity and Efficiency

DAIMS DATA Act Information Model Schema

DATA Act The Digital Accountability and Transparency Act of 2014

DE Data Element

DQP Data Quality Plan

FAEC Federal Audit Executive Council

FAR Federal Acquisition Regulation

FEC Federal Election Commission

FFATA Federal Funding Accountability and Transparency Act of 2006

FPDS-NG Federal Procurement Data System Next Generation

FSR Financial System and Reporting Division

FSSP Federal Shared Service Provider

FY Fiscal Year

GAGAS Generally Accepted Government Auditing Standards

GAO Government Accountability Office

IDD Interface Definition Document

IG Inspector General

IPA Independent Public Accounting

OIG Office of Inspector General

OMB Office of Management and Budget

PIID Procurement Instrument Identifier for procurements

PMO Project Management Office

RSS Reporting Submission Specification

SAM System for Award Management

SAO Senior Accountable Official

Treasury The United States Department of the Treasury

USDA United States Department of Agriculture