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 5, 2021 

ENCLOSURE: 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) 2021 

DATA Act audit. Based on the results of the statistical and non-statistical testing for the 

FEC’s DATA Act audit for FY 2021 Quarter 1 (Q1), the FEC scored 90.15 points out of 

100, which is a quality rating of “Higher.”2

The enclosed report provides one finding and two recommendations that would improve the 

overall accuracy and timeliness of FEC’s data submissions. FEC management did not 

concur with the recommendations during the audit period. Accordingly, the enclosed report 

includes both the auditors’ and management’s respective opinions. 

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.3 The primary objective of the engagement was to satisfy the OIG’s 

responsibilities under the DATA Act by assessing the: (1) completeness, timeliness, quality, 

 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 This represents the second highest quality level rating, as further detailed in Appendix II of the enclosed report.

3 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. 
FEC OIG 2022-11-001

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 ensures the accuracy of 

the audit conclusions but may not express an opinion of the audit’s results. The OIG’s 

review determines that Brown & Company complied with all required Government Auditing 

Standards. 

We conclude that the FEC properly implemented and made proper use of the Governmentwide financial data standards. Additionally, we acknowledge that the FEC made significant 

improvements in their reconciliation and certification procedures to identify and correct 

errors. However, there is still an opportunity to improve the collaboration and coordination 

with the federal shared service provider (USDA) to ensure errors and missing records from 

File C are corrected prior to submitting files to the DATA Broker. 

The auditors performed detailed award level testing on 100% of the 22 records included in 

File D1, which determined that:

• 96.2% of data elements were complete;

• 96.2% of the data elements were timely; and

• 96% of the data elements were accurate 

The OIG will provide a copy of the final audit report to the appropriate Congressional 

oversight committees, the GAO, OMB, and the Treasury. In addition, the OIG will post the 

report to its website and to 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 final CAP. 

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

held six 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 Ms. Shellie Purnell-Brown at (202) 694-1019. 

Thank you. 

cc: John Quinlan, Chief Financial Officer 

Alec Palmer, Staff Director/Chief Information Officer

Gilbert A. Ford, Director of Budget 

Sheri Haynes, DATA Act Program Manager
Federal Election Commission

Independent Auditor’s Report on the Compliance with the 

Digital Accountability and Transparency Act of 2014 

Submission Requirements for Fiscal Year 2021

November 5, 2021

Prepared by:

Brown & Company Certified Public Accountants and 

Management Consultants, PLLC

6401 Golden Triangle Drive, Suite 310

Greenbelt, Maryland 20770
Independent Auditor’s Report

Federal Election Commission (FEC) 

Office of Inspector General for Federal Election Commission

Washington, DC

The Office of Inspector General (OIG) for Federal Election Commission (FEC) contracted Brown & 

Company CPAs and Management Consultants, PLLC, to conduct a performance audit of FEC’s fiscal year 

(FY) 2021 first quarter (Q1) financial and award data as of December 31, 2020, 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 59 data definition standards and required Federal agencies to report financial and 

award data on USAspending.gov.

The audit objectives were to assess (1) completeness, accuracy, timeliness, and quality of FEC’s FY 2021

Q1 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 2021

Q1 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 2021 Q1 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 conclude that FEC complied with the requirements of the DATA Act. We found that the FY 2021 Q1

financial and award data of FEC for the quarter ended December 31, 2020, is presented in accordance with 

OMB and Treasury published 59 data definition standards, as applicable, for DATA Act reporting in all 

material respects. We found that the FEC data submission substantially complied with the requirements for 

completeness, accuracy, timeliness, and quality. However, there is opportunity to improve collaboration 

and coordination with FEC’s Federal Shared Service Provider (USDA) to ensure any errors or missing 

records are identified and corrected timely. To strengthen the accuracy and completeness with FEC’s 

DATA Act reporting, we made two recommendations. 

This report is for the purpose of concluding on the audit objectives described above. Accordingly, this 

report is not suitable for any other purpose. 

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

and is made available to the public.
Federal Election Commission

Independent Auditor’s Report on the Compliance with the 

Digital Accountability and Transparency Act of 2014 Submission Requirements 

for Fiscal Year 2021

TABLE OF CONTENTS

I. Background........................................................................................................................................... 1

II. Overall Audit Results............................................................................................................................ 2

III. Statistical Results.................................................................................................................................. 2

IV. Data Standards...................................................................................................................................... 3

V. Non-Statistical Results.......................................................................................................................... 3

VI. Other Report Content............................................................................................................................ 4

VII. Status of Prior Period Findings and Recommendations........................................................................ 5

VIII.Notice of Finding and Recommendations............................................................................................. 6

IX. Status of Prior Period Recommendations ........................................................................................... 10

X. Auditor’s Comment to Management Response .................................................................................. 10

Appendix I – Objective, Scope and Methodology...................................................................................... 11

Appendix II – FY 2021 FEC DATA Act Q1 Quality Scorecard ................................................................ 13

Appendix III – FY 2021 FEC Computation of the Error Rates.................................................................. 14

Appendix IV – FY 2021 FEC Data Element Analysis ............................................................................... 15

Appendix V – FY 2021 and FY 2019 FEC Comparative Results Table .................................................... 17

Appendix VI – CIGIE’s DATA Act Anomaly Letter................................................................................. 19

Appendix VII – Management’s Response .................................................................................................. 21

Appendix VIII – Glossary of Abbreviations and Acronyms ...................................................................... 23
``

Federal Election Commission 

Independent Auditor’s Report on the Compliance with the 

Digital Accountability and Transparency Act of 2014 Submission Requirements 

for Fiscal Year 2021

I. Background

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 2017, 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 reporting requirements that are 

mandated by these government-wide Acts. 

There are three systems used by FEC for DATA Act reporting: 

• Comprizon.Buy a procurement management system for processing awards; 

• Federal Procurement Data System – Next Generation (FPDS-NG) a federal procurement data 

system for reporting procurement awards; and 

• Pegasys a Financial Management System managed by the United States Department of 

Agriculture (USDA) which is the FEC’s Federal Shared Service Provider (FSSP).

The FSSP is responsible for compiling and uploading the DATA Act Files A-C to the DATA Act Broker. 

File D1 is generated from the DATA Act Broker (DAB) using data extracted from the FPDS-NG. Per the 

FEC’s data quality plan (DQP), the FEC follows a risk-based approach in reviewing the processes used to 

compile the data and assess the existence of risks.

The DATA Act

The Digital Accountability and Transparency Act of 2014 (DATA Act) was enacted May 9, 2014, to expand 

the reporting requirements pursuant to Federal Funding Accountability and Transparency Act of 2006 

(FFATA)1. The DATA Act, in part, requires that Federal agencies report financial and payment data for

publication on USAspending.gov in accordance with Governmentwide financial data standards established 

by the U.S. Treasury and the Office of Management and Budget. The DATA Act also requires the Office 

of Inspector General of each Federal agency to report on its agency’s DATA Act submission and

compliance in the form of three reviews. Subsequently, and in accordance with the DATA Act, Treasury 

began displaying federal agencies’ data on USAspending.gov for taxpayers and policymakers in May 2017. 

1 Public Law 113-101 (May 9, 2014)
2

In April 2020, Office of Management and Budget (OMB) issued M-20-21, Implementation Guidance for 

Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19), which made 

changes to DATA Act reporting. Since the FEC did not receive COVID-19 relief funds, we did not perform 

testing of COVID-19 relief funds data elements and outlays.

The Office of Inspector General (OIG) contracted with Brown & Company CPAs and Management 

Consultants, PLLC (Brown & Company), an independent certified public accounting firm, to conduct this 

performance audit to assess FEC’s compliance under the DATA Act. The audit objective, scope, and 

methodology are presented in Appendix I.

II. Overall Audit Results

We found that the FEC implemented and used the governmentwide financial data standards as established 

by OMB and Treasury, as applicable, and that the required data elements were presented in accordance 

with the standards. We would also like to acknowledge the significant improvement in FEC’s internal 

controls around the monthly reconciliation and certification process. The applicable controls implemented 

resulted in reductions in error rates related to detailed award level data elements.

Overall Determination of Quality

Based on the results of our statistical and non-statistical testing for the FEC’s DATA Act audit for FY 2021

Q1, the FEC scored 90.15 points out of a 100, which is a quality rating of Higher. The FY 2021 FEC DATA 

Act Q1 Quality Scorecard is presented in Appendix II.

III. Statistical Results 

Data Element Analysis and Results of detailed award level testing

The Data Element Analysis results from our detailed award level testing are presented below and listed in 

Appendix III - FY 2021 FEC Computation of the Error Rates and Appendix IV - FY 2021 FEC Data 

Element Analysis. 

Selections for detailed award level testing was taken from File D1 as File C was deemed not suitable for 

testing and the FEC does not issue grants and thus File D2 is not applicable. As there were only 22 records 

reported in FEC’s FY 2021 Q1 File D1, 100% of the population was tested. As a result, statistical sampling 

was not used and results reported below will be based on actual error rates instead of projected error rates. 

The audit results are substantially consistent with the risks identified in the FEC’s DQP. We also like to 

note that all errors identified were either attributed to third party errors or based on the four PIIDs missing 

from File C.

Completeness of the Data – Actual Error Rate

The actual error rate for the completeness of the data elements is 3.80%. A data element was considered 

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

Accuracy of the Data – Actual Error Rate

The actual error rate for the accuracy of the data elements is 3.80%. A data element was considered accurate 

when amounts and other data relating to recorded transactions were recorded in accordance with the 

DAIMS RSS, IDD, and the online data dictionary, and agree with the originating award 

documentation/contract file. The auditor issued a “Notice of Finding and Recommendation” to address the 

accuracy of the data.
3

Timeliness of the Data - Actual Error Rate

The actual error rate for the timeliness of the data elements 3.80%. The timeliness of data elements was 

based on the reporting schedules defined by the financial, procurement, and financial assistance 

requirements (FFATA, FAR, FPDS-NG, FABS, and DAIMS).

IV. Data Standards

Implementation and Use of the Data Standards

We have evaluated the FEC’s implementation of the government-wide financial data standards for award 

and spending information and determined the FEC is using the standards as defined by OMB and Treasury. 

The FEC linked by common identifiers (e.g., PIID, FAIN), all of the data elements in the FEC’s 

procurement, and financial, as applicable. For the Treasury’s DATA Act 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. 

V. Non-Statistical Results 

Completeness of the Agency DATA Act Submission

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

submissions were complete with the exception of File C (for more details see Results of Linkages from File 

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

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

Timeliness of the Agency DATA Act Submission

We evaluated the FEC’s FY 2021 Q1 DATA Act submission to Treasury’s DATA Act Broker and 

determined that the submission was timely. To be considered timely, it had to be submitted and certified 

within 45 days of quarter end.

Completeness of Summary-Level Data for Files A and B

We performed summary-level data reconciliations and linkages for Files A and B and did not identify any 

variances. The test results verified: (1) summary-level data from File A matched the Agency’s GTAS SF133; (2) the totals and Treasury Account Symbols (TAS) identified in File A matched File B; and (3) all 

object class codes from File B match codes defined in Section 83 of OMB Circular No. A-11.

Results of Linkages from File C to Files B and D1

We tested the linkages between File C to File B by TAS, object class, and program activity, the linkages 

between File C to File D1 by both the PIID and Parent Award ID. All of the TAS, object class, and program 

activity data elements from File C existed in File B. However, 36 records included in File C did not exist 

in File D1; and four records included in File D1 did not exist in File C. As a result of File C not reconciling 

to File D1, we determined that File C was not suitable for testing. For more information, see Section VIII.

“Notice of Finding and Recommendations” that address the suitability and accuracy of File C. 

Analysis of the Accuracy of Dollar Value-related Data Elements

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 element are not projected to the population.
4

Accuracy of Dollar-Value Related Data Elements

PIID/FAIN Data Element Accurate Not 

Accurate

Not 

Applicable

Total 

Tested

Error 

Rate

Absolute 

Value of 

Errors

PIID 13 Federal Action Obligation 22 0 0 22 0%

PIID 53 Obligation 16 4 2 22 20% $35,657.89

Total 38 4 2 44

Analysis of Errors in Data Elements Not Attributable to the Agency

The following table displays the results of errors in data elements that were not attributable to the FEC.

Errors in DATA Elements not Attributable to the Agency

PIID/FAIN Data Element Number of 

Exceptions

Attributed to

PIID 4 Ultimate Parent Legal Entity Name 1 Based on SAM Input

PIID 6 Legal Entity Congressional District 10 Third Party

Total 11

File C COVID-19 Outlay Testing and Results 

The Federal Government’s response to the COVID-19 pandemic included an economic relief package and 

new reporting requirements for agencies that received COVID-19 funds. Effective for the June 2020 

reporting period, agencies with COVID-19 relief funding must submit DATA Act Files A and B on a 

monthly basis. We reviewed Files A and B and determined that the FEC did not receive or report any 

COVID-19 relief funding for FY 2021.

VI. Other Report Content

Assessment of Internal Controls

The FEC’s management is responsible for the compliance of the FY 2021 Q1 financial and award data 

submissions in accordance with the DATA Act and submission standards developed by the Treasury and 

the OMB. 

We assessed internal controls and compliance with laws and regulations in accordance with Government 

Auditing Standards: 2018 Revision Technical Update April 2021 (GAO-21-368G – Technical Updates)

necessary to satisfy the audit objectives. We assessed the internal control components and their related 

principles outlined in the Government Accountability Office (GAO), Standards for Internal Controls in the 

Federal Government September 2014 (Green Book, GAO-14-704G Federal Internal Control Standards)

that we deemed significant. The following internal control components and related principles were deemed 

significant to our audit objectives:

1. Control Environment - Principles: 3) establish an organization structure, assign responsibility 

and delegate authority to achieve the entity’s objectives. 

2. Risk Assessment - Principles: 6) define objectives clearly to enable the identification of risks

and define risk tolerance; 7) identify, analyze, and respond to risks; and 8) consider the potential 

for fraud when identifying, analyzing and responding to risks. 
5

3. Control Activities - Principles: 11) design the entity’s information system and related control 

activities to achieve objectives and respond to risks; and 12) implement control activities 

through policies. 

4. Information and Communication - Principles: 13) use quality information to achieve the 

entity’s objectives; and 15) externally communicate the necessary quality information to 

achieve the entity’s objectives. 

5. Monitoring - Principles: 16) establish and operate monitoring activities to monitor the internal 

control system and evaluate the results; and 17) remediate identified internal control 

deficiencies on a timely basis

Since our review was limited to these internal control components and underlying principles, it may not 

have disclosed all internal control deficiencies that may have existed at the time of this audit.

We determined that the FEC internal and information system controls as it relates to the extraction of data 

from the source systems and the reporting of data to the DATA Act Broker have been properly designed 

and implemented and are operating effectively. However, we were unable to determine the effectiveness of 

internal controls related to the FSSP to ensure potential errors are identified and corrected timely.

DATA Act Date Anomaly

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

with the oversight requirements contained in the Digital Accountability and Transparency Act of 2014. 

That is, the first Inspector General (IG) reports were due to Congress on 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 by November 8, 2017, 1-year after the statutory 

due date, with two subsequent reports to be submitted following on a 2-year cycle. This is the third and 

final report required under the DATA Act. On December 22, 2015, CIGIE’s chair issued a letter detailing 

the strategy for dealing with the IG reporting date anomaly and communicated the strategy to the Senate 

Committee on Homeland Security and Governmental Affairs and the House Committee on Oversight and 

Government Reform. See Appendix VI for the letter.

Testing Limitations for Files E and F

File E of the DATA Act Information Model Schema contains additional awardee attribute information the 

Treasury DATA Act Broker software extracts from the System for Award Management (SAM). File F 

contains sub-award attribute information the broker software extracts from the FFATA Subaward Reporting 

System (FSRS). Files E and F data remain the responsibility of the awardee in accordance with terms and 

conditions of Federal agreements, and the quality of these data remains the legal responsibility of the 

recipient. Therefore, agency senior accountable officials (SAO) are not responsible for certifying the quality 

of File E and F data reported by awardees, but they are responsible for assuring controls are in place to 

verify that financial assistance awardees register in SAM at the time of the award. As such, we did not 

assess the completeness, accuracy, timeliness, and quality of the data extracted from SAM and FSRS via 

the Treasury broker software system.

VII. Status of Prior Period Findings and Recommendations

There were no open recommendations from prior DATA Act audit reports.
6

VIII. Notice of Finding and Recommendations

FEC DATA Act Notification of Finding and Recommendations

Finding: Federal Election Commission (FEC) FY 2021 Q1 File C submission was not complete, 

accurate, and did not include all transactions and linkages. 

Condition:

During our testing of the FEC Record-Level Linkages between Files C and D1, we determined that FY 

2021 Q1 File C submission is not complete or suitable for detailed testing due to the following:

• 36 records in File C did not link to File D1. These were not obligations and thus should not 

have been reported in File C (See Table 1 for detail of errors). 

• 4 records in File D1 were not recorded in File C (See Table 4 for detail of errors).

• 13 interagency agreements (IAAs) were reported in File C. Based on the type of IAA’s the FEC 

has these transactions should not be reported in File C (See Tables 2 & 5 for detail of errors). 

The FEC has a process to periodically review DATA Act Broker warning reports and performs monthly

reconciliations between File C and File D1 to identify and research potential errors and to determine if 

corrections are needed. During this process, the FEC DATA Act program team identified these potential 

errors and communicated to the Federal Share Service Provider (FSSP) for correction. However, the 

discrepancies between File C and D1 were not corrected timely.

The difference between Files C and D1 are presented below. 

Table 1 - Difference between Files C and D1

DATA Act File Amount

File C-Total Obligation Amount that should not have been reported in File C $1,819,157.51

File D1-Federal Action Obligation that should have been included in File C 35,657.89

Variance between File C and File D1 $1,783,499.62

*The total obligation amount not reported in File C includes the 30 PIIDs $1,819,157.51 and the 6 PIIDS 

totaling $35,657.89 that should be included in File C. 

Table 2 - File C Errors

PIID Number

Error-Records 

recorded in File C 

and not in D1.

Amount Attributed to

9531BP17F0050 1 $107,313.20 Error attributable to the FSSP and the FEC 

9531BP18C0004 1 10,000.00 Error attributable to the FSSP and the FEC 

9531BP18F0007 1 5,726.97.00 Error attributable to the FSSP and the FEC 

9531BP18F0015 1 194,312.32 Error attributable to the FSSP and the FEC

9531BP18F0019 1 114,203.75 Error attributable to the FSSP and the FEC

9531BP18F5006 1 17,164.31 Error attributable to the FSSP and the FEC 

9531BP18F5007 1 54,423.00 Error attributable to the FSSP and the FEC 
7

PIID Number

Error-Records 

recorded in File C 

and not in D1.

Amount Attributed to

9531BP18G0002 1 53,014.84 Error attributable to the FSSP and the FEC 

9531BP18P0014 1 5,625.00 Error attributable to the FSSP and the FEC 

9531BP19F5029 1 22,453.60 Error attributable to the FSSP and the FEC 

9531BP19F5031 1 11,210.37 Error attributable to the FSSP and the FEC 

9531BP19F5033 1 33,642.11 Error attributable to the FSSP and the FEC 

9531BP19F5047 2 10,512.87 Error attributable to the FSSP and the FEC 

9531BP19F5059 1 29,875.95 Error attributable to the FSSP and the FEC 

9531BP19H0030 1 152,750.00 Error attributable to the FSSP and the FEC

9531BP19P0034 1 28,647.75 Error attributable to the FSSP and the FEC 

9531BP20A0007 1 7,040.00 Error attributable to the FSSP and the FEC 

9531BP20F0012 1 34,311.00 Error attributable to the FSSP and the FEC 

9531BP20F0019 1 7,172.00 Error attributable to the FSSP and the FEC 

9531BP20F0033 1 181,570.08 Error attributable to the FSSP and the FEC 

9531BP20F0037 1 90,079.59 Error attributable to the FSSP and the FEC 

9531BP20F0041 1 16,086.00 Error attributable to the FSSP and the FEC 

9531BP20F0042 1 16,559.03 Error attributable to the FSSP and the FEC 

9531BP20G0003 6 62,274.71 Error attributable to the FSSP and the FEC 

9531BP20H0016 1 14,432.41 Error attributable to the FSSP and the FEC 

9531BP20P0005 1 41,76.00 Error attributable to the FSSP and the FEC 

9531BP20P0029 1 5,547.37 Error attributable to the FSSP and the FEC 

9531BP21F0004 1 31,222.56 Error attributable to the FSSP and the FEC 

9531BP21L0002 1 421,175.94 Error attributable to the FSSP and the FEC 

Total 36 $1,819,157.51

*There are 30 unique PIID Identifiers with 6 additional modifications for samples #13 and #25

Table 3 - File C Errors

Sample 

Number PIID Number

Error-Records 

recorded in File 

D1 and not 

recorded in File C 

Amount Attributed to 

1 9531BP21P0004 1 $13,442.50 Error attributable to the FSSP and the FEC 

2 9531BP21F0005 1 16,872.96 Error attributable to the FSSP and the FEC 

3 FE16G057 1 510.43 Error attributable to the FSSP and the FEC 

4 FE9531BP17F0001 1 4,832 Error attributable to the FSSP and the FEC 

Total 4 $35,657.89
8

Table 4 - Difference with IAAs removed from File C

DATA Act File Amount

File C-Total Obligation Amount $1,465,532.44

File C - Total Obligation related to IAAs 411,247.83

File C Gross Total $1,054,284.61

*The Total Obligation amount includes all transactions from October 1, 2020 - December 31, 2020 in the 

amount of $1,465,532.44. The Total Obligation amount related to IAAs is $411,247.83 this amount is 

subtracted from the total obligation amount due to reconciling items removed from File C. 

Table 5 - File C IAAs

PIID Number IAAs recorded 

in File C Amount Attributed to

9531BP21L0002 1 $ 421,175.94 Error attributable to the FSSP

9531BP20H0016 1 14,432.41 Error attributable to the FSSP

9531BP21H0014 1 289.19 Error attributable to the FSSP 

9531BP21H0003 1 151.00 Error attributable to the FSSP 

9531BP20H0030 1

3295.57 Error attributable to the FSSP 

9531BP20H0027 1 21.50 Error attributable to the FSSP 

9531BP20H0019 1 2435.50 Error attributable to the FSSP 

9531BP20H0015 1 200.00 Error attributable to the FSSP 

9531BP20H0009 1 151.00 Error attributable to the FSSP 

9531BP20H0005 1 282.19 Error attributable to the FSSP 

9531BP21H0019 1 (411.00) Error attributable to the FSSP 

9531BP21H0020 1 (442.15) Error attributable to the FSSP 

9531BP21H0015 1 (30,333.32) Error attributable to the FSSP 

Total 13 $411,247.83

Criteria:

Digital Accountability and Transparency Act of 2014 Section 2 states the purposes of this Act are to (4) 

improve the quality of data submitted to USAspending.gov by holding Federal agencies accountable for 

the completeness and accuracy of the data submitted.

Council of the Inspectors General on Integrity and Efficiency (CIGIE) Federal Audit Executive Council 

(FAEC), Inspectors General Guide to Compliance under the DATA Act December 4, 2020, defines 

Accuracy for the DATA Act as:

“Amounts and other data relating to recorded transactions have been 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.”
9

Cause:

There are several causes which include:

• The 36 records included in File C and not in File D1 were initially correctly recorded in File C 

as outlays (non-TOA transactions). As this was the first-time outlays have been reported in the 

FEC’s File C, the FEC DATA Act Team did not recognize these transactions and thus notified 

the FSSP that these were “foreign” transactions that should be removed. The FSSP attempted 

to remove the transactions from File C, however, the transactions also subsequently appeared 

in File C as obligations (TOA records) in error. FEC did not receive Cares Act Funds and were 

not aware that outlays would be reported in File C. As a result, the miscommunication also 

contributed to these errors. 

• The FEC used an internal management system (Comprizon) to initiate, manage and approve 

awards, which is also used to transmit award data to FPDS-NG which in turns generates File 

D1. This award management system is not integrated with the FSSP financial management 

system (Pegasys) which generates File C. Therefore, procurement award data must be manually 

submitted and processed in the financial management system by the FSSP. Also, corrections 

were not completed in a timely manner by the FSSP. 

• The FSSP process on how IAAs are supposed to be reported in File C did not align with the 

FEC’s expectation.

Effect:

Financial and award data that is not complete, accurate and timely in USAspending.gov decreases the 

reliability and usefulness of the data. 

Recommendation 1:

We recommend the FEC DATA Act program team coordinate with the FSSP to correct errors identified in 

DATA Act File C submission, as well as to come to a mutual agreement how IAAs should be reported.

Recommendation 2:

We recommend that the FEC’s SAO and FSSP SAO collaborate to ensure going forward, adequate time is 

provided to identify and correct errors prior to the final DATA Act submission due dates.

Management Response:

In response to Recommendation 1 and 2, FEC’s Management stated “while management supports 

efforts to improve data quality, it does not agree with these recommendations.” Management stated 

that it has “already worked with the FSSP to accomplish positive results by, for example, 

identifying Interagency Agreements that should not be included in File C. We hope subsequent 

quarter reflects these efforts.”

Management stated that “management see the 36 outlays records incorrectly recorded as 

obligations as primarily a system issue in the DATA Act files maintained by the FSSP. Without 

full ability to modify the system, it may be difficult to achieve the desired results.”

See Appendix VII – Management’s Response for the complete response, and Section X below for 

auditor’s comment to management response.
10

IX. Status of Prior Period Recommendations

There were no open recommendations from prior FEC DATA Act audit reports.

X. Auditor’s Comment to Management Response

The FSSP performs a significant role with FEC to improve the completeness and accuracy of the DATA 

Act data submitted. Therefore, FEC should continue its efforts with the FSSP to correct File C data. 

Based on the follow-up work performed related to the errors identified above as well as the OIG’s 

communications with both Management and the FSSP, we stand by our conclusions and Recommendations 

1 and 2 herein. 

In order to ensure these types of errors are prevented and/or rectified going forward, it will require a group 

effort and a mutual agreement between the FEC and the FSSP. Although we understand that the FEC does 

not have access to the financial system that generates File C, per the DATA Act each agency is ultimately 

responsible for the accuracy of the data displayed on USAspending.gov. We hope that this audit will result 

in meaningful collaboration and corrective actions between the two parties. 

In addition, we would like to address management’s response related to the 36 records (outlays) which we 

do not believe is totally accurate. Per the DAIMs, the data element for outlays has always been one of the 

57 standard data elements. However, prior to FY 2021 Q1 this was an optional data element. Beginning in 

FY 2021 Q1, outlays are required for agencies who received Cares Act Funds, and will be required for all 

other agencies beginning FY 2022 Q2. Although outlays reporting was not required for the FEC in FY 2021 

Q1, the FSSP began to report outlays for all their clients. It appears that FEC management was not aware 

that the FSSP planned to begin reporting outlays in their File C. Therefore, the FEC did not recognize these 

records as outlays and because outlays are not reported in File D1, they could not reconcile these records 

to File C. As a result, the FEC communicated to the FSSP that these records (outlays) were identified as 

potential errors and requested that they be removed. The audit team was not able to determine what actually 

happened after that. However, when we pulled File C from the Broker, these 36 records ended up also being 

reported in the FEC’s File C transmission as obligations which is in error.

Greenbelt, Maryland

November 5, 2021
11

Appendix I – Objective, Scope and Methodology

Objective

The objective of this performance audit was to assess the FEC compliance under the DATA Act with respect 

to: 

• The completeness accuracy, timeliness, and quality of FY 2021 Q1 financial and award data 

submitted to the Treasury for publication on USAspending.gov, and 

• The FEC’s implementation and use of the Government-wide financial data standards 

established by the OMB and Treasury.

Scope

The scope of this engagement is FEC’s FY 2021 Q1 financial and award data submitted for publication on 

USAspending.gov. 

The scope includes examining DATA Act information reported in FEC’s FY 2021 Q1 financial and award 

data files listed below, as applicable:

• File A: Appropriations Account

• File B: Object Class and Program Activity

• File C: Award Financial

• File D1: Award (Procurement)

• File E: Additional Awardee Attributes

• File F: Sub-award Attributes

Files A, B, and C are submitted by FEC’s Federal Shared Service Provider. Files A and B are summarylevel financial data. File C is reportable award-level data. Files D1 through F contain detailed demographic 

information for award-level records reported in File C. Files D1 through F are submitted by external award 

reporting systems to Treasury’s DATA Act Broker. The senior accountable official for FEC is required to 

certify the applicable data files for its agency’s financial and award data to be published on 

USAspending.gov. FEC did not have any required reporting data for Files D2-F.

Methodology

We conducted this performance audit in accordance with Generally Accepted Government Auditing 

Standards. Our audit was performed in accordance with the relevant DATA Act guidance and policies 

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

under the DATA Act, dated December 4, 2020. We conducted our fieldwork from May1, 2021 through 

September 24, 2021. 

To accomplish our objectives, we:

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

financial and award data under the DATA Act; 

• 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;
12

• reviewed and reconciled the FY 2021 Q1 summary-level data submitted by FEC for publication 

on USAspending.gov.

• assessed FEC’s implementation and use of the 59 data elements/standards established by OMB 

and Treasury; and

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

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

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

• reviewed FEC’s certification and submission process;

• determined the timeliness of FEC’s submission; 

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

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

• selected and examined the entire population of 22 total records in FEC’s FY 2021 Q1 certified 

spending data reported in File C;

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

• tested detailed record-level data elements for Files C and D1for completeness, accuracy, 

timeliness, and quality; and analyzed results.

We tested the total population of 22 records from File D1. The testing was designed to ensure each of the 

required 59 data elements that should have been reported was reported in the appropriate Files A through 

D1.

In relation to the Federal Shared Service Provider (FSSP), we:

• Assessed FEC’s DATA Act reporting roles and responsibilities as documented in their service 

agreement with the FSSP.

• Determined whether any findings could have a significant impact on the FEC’s DATA Act 

submission.

• Identified corrective actions implemented by the FSSP to address reported deficiencies, if any.

• Determined whether the FSSP SAO and the FEC SAO are coordinating and communicating to 

ensure that:

o FSSP has identified and resolved areas of concern brought to their attention by FEC

and their IGs based on the prior DATA Act audits/submissions, if any.

o FSSP continues to engage FEC to collaborate and address potential changes/updates 

to reporting requirements and DAIMS.

o FSSP and FEC are tracking FSSP statuses for the need to upgrade systems, and/or 

implement new processes to comply with updated DATA Act requirements and ensure 

these responsibilities are reflected in their service agreements.

o FSSP and FEC have established reporting responsibilities for FSSPs and their 

customers, and that the DATA Act reporting roles and responsibilities for financial, 

procurement, and grants, are being established and documented in their service 

agreement.

o FSSP, in coordination with FEC are continuing to determine applicable data elements 

and identify gaps and issues (if applicable).

• Reviewed the most recent FSSP SOC report for control deficiencies related to DATA Act 

submissions.
13

Appendix II – FY 2021 FEC DATA Act Q1 Quality Scorecard 

FEC’s quality of data is defined as data that is complete, accurate, and timely, and includes statistical and 

non-statistical testing results. The quality scorecard calculates the quality based on weighted scores of both 

statistical sampling results and non-statistical testing results. For the quality scorecard, statistical testing 

results are valued at 60 points and non-statistical testing results are valued at 40 points, for a total of 100 

points. We combined the results of the statistical sample with the results on the non-statistical testing in the 

below quality scorecard. The overall quality score is Higher at 90.15%.

Quality Level

Level

0.0 69.9 Lower

70.0 84.9 Moderate

85.0 94.9 Higher

95.0 100 Excellent

Range
14

Appendix III – FY 2021 FEC Computation of the Error Rates

The following table displays the results for errors in data elements by sample record for completeness, 

accuracy, and timeliness. For each sample record, we tested the applicable data elements, documented the 

number of errors and computed the error rates (number of errors divided by total number DEs). We 

computed the total errors and the average error rates: 3.80% incomplete 3.80% inaccurate, and 3.80% 

untimely.

Results of PIID and FAIN Statistical Sample Testing

Sample Record 

Number

Total Number 

DEs

Number 

Incomplete

Number 

Inaccurate Number Untimely

1 47 0 0.00% 0 0.00% 0 0.00%

2 45 1 2.22% 1 2.22% 1 2.22%

3 39 1 2.56% 1 2.56% 1 2.56%

4 46 0 0.00% 0 0.00% 0 0.00%

5 39 1 2.56% 1 2.56% 1 2.56%

6 46 0 0.00% 0 0.00% 0 0.00%

7 47 8 17.02% 8 17.02% 8 17.02%

8 44 0 0.00% 0 0.00% 0 0.00%

9 45 0 0.00% 0 0.00% 0 0.00%

10 44 6 13.64% 6 13.64% 6 13.64%

11 46 0 0.00% 0 0.00% 0 0.00%

12 45 0 0.00% 0 0.00% 0 0.00%

13 47 1 2.13% 1 2.13% 1 2.13%

14 46 0 0.00% 0 0.00% 0 0.00%

15 47 0 0.00% 0 0.00% 0 0.00%

16 46 7 15.22% 7 15.22% 7 15.22%

17 47 7 14.89% 7 14.89% 7 14.89%

18 46 1 2.17% 1 2.17% 1 2.17%

19 44 1 2.27% 1 2.27% 1 2.27%

20 47 1 2.13% 1 2.13% 1 2.13%

21 44 2 4.55% 2 4.55% 2 4.55%

22 47 1 2.13% 1 2.13% 1 2.13%

Total Errors 38 38 38

Error Rate 3.80% 3.80% 3.80%
15

Appendix IV – FY 2021 FEC Data Element Analysis

This FY 2021 FEC Data Element Analysis depicts our test results and the associated error rates by data 

element, as applicable. The analysis includes the results for completeness, accuracy and timeliness in 

descending order by accuracy error rate percentage (non-projected)2.

DAIMS 

Element

No.

Data Element Name A

Accuracy

C

Completeness

T

Timeliness

6 Legal Entity Congressional District 45% 45% 45%

34 Award ID Number (PIID/FAIN) 20% 20% 20%

50 Object Class 20% 20% 20%

51 Appropriations Account 20% 20% 20%

53 Obligation 20% 20% 20%

56 Program Activity 20% 20% 20%

430 Disaster Emergency Fund Code (No. 59) 20% 20% 20%

24 Parent Award ID Number 15% 15% 15%

4 Ultimate Parent Legal Entity Name 5% 5% 5%

1 Awardee/Recipient Legal Entity Name 0% 0% 0%

2 Awardee/Recipient Unique Identifier 0% 0% 0%

3 Ultimate Parent Unique Identifier 0% 0% 0%

5 Legal Entity Address 0% 0% 0%

7 Legal Entity Country Code 0% 0% 0%

8 Legal Entity Country Name 0% 0% 0%

11 Amount of Award 0% 0% 0%

12 Non-Federal Funding Amount 0% 0% 0%

13 Federal Action Obligation 0% 0% 0%

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

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

16 Award Type 0% 0% 0%

17 NAICS Code 0% 0% 0%

18 NAICS Description 0% 0% 0%

22 Award Description 0% 0% 0%

23 Award Modification / Amendment Number 0% 0% 0%

25 Action Date 0% 0% 0%

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

2 For each data element, we divided the number of exceptions by the total sample count for the relevant files to obtain 

the percentage error rate for that data element.
16

DAIMS 

Element

No.

Data Element Name A

Accuracy

C

Completeness

T

Timeliness

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

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

29 Ordering Period End Date 0% 0% 0%

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

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

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

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

36 Action Type 0% 0% 0%

38 Funding Agency Name 0% 0% 0%

39 Funding Agency Code 0% 0% 0%

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

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

42 Funding Office Name 0% 0% 0%

43 Funding Office Code 0% 0% 0%

44 Awarding Agency Name 0% 0% 0%

45 Awarding Agency Code 0% 0% 0%

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

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

48 Awarding Office Name 0% 0% 0%

49 Awarding Office Code 0% 0% 0%

51 Appropriations Account 0% 0% 0%

163 National Interest Action (No. 58) 0% 0% 0%

19 Catalog of Federal Domestic Assistance (CFDA) 

Number N/A N/A N/A

20 Catalog of Federal Domestic Assistance (CFDA) Title N/A N/A N/A

35 Record Type N/A N/A N/A

37 Business Types N/A N/A N/A

54 Unobligated Balance N/A N/A N/A

57 Outlay (Gross Outlay Amount By Award CPE) N/A N/A N/A
17

Appendix V – FY 2021 and FY 2019 FEC Comparative Results Table

This table below identifies the error rate by data element from the FY 2021 and FY 2019 audit results. The 

information is being provided for illustrative purposes only and may not necessarily be indicative of actual 

percent change based on differences in testing procedures such as population size, sample methodology, 

quarter tested, file tested, and changes to data definition standards.

FEC Comparative Results for Data Elements

Based on Accuracy Error Rates in Descending Order3

DAIMS 

Element 

No.

Data Element Name

2021 

Error 

Rate A

2019 

Error 

Rate A

% 

Change A

6 Legal Entity Congressional District 45% 0% 45%

34 Award ID Number (PIID/FAIN) 20% 0% 20%

50 Object Class 20% 38% -18%

51 Appropriations account 20% 38% -18%

53 Obligation 20% 38% -18%

56 Program Activity 20% 38% -18%

430 Disaster Emergency Fund Code (No. 59) 20% N/A 0%

24 Parent Award ID Number 15% 12% 3%

4 Ultimate Parent Legal Entity Name 5% 0% 5%

1 Awardee/Recipient Legal Entity Name 0% 0% 0%

2 Awardee/Recipient Unique Identifier 0% 0% 0%

3 Ultimate Parent Unique Identifier 0% 12% -12%

5 Legal Entity Address 0% 0% 0%

7 Legal Entity Country Code 0% 0% 0%

8 Legal Entity Country Name 0% 0% 0%

11 Amount of Award 0% 0% 0%

12 Non-Federal Funding Amount 0% 0% 0%

13 Federal Action Obligation 0% 0% 0%

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

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

16 Award Type 0% 4% -4%

17 NAICS Code 0% 0% 0%

18 NAICS Description 0% 0% 0%

22 Award Description 0% 0% 0%

23 Award Modification / Amendment Number 0% 0% 0%

25 Action Date 0% 0% 0%

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

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

3

 For each FY and data element, we divided the number of exceptions by the total sample count for the relevant 

files to obtain the percentage error rate for that data element. 
18

DAIMS 

Element 

No.

Data Element Name

2021 

Error 

Rate A

2019 

Error 

Rate A

% 

Change A

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

29 Ordering Period End Date 0% 0% 0%

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

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

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

33 Primary Place of Performance Country Name 0% 38% -38%

36 Action Type 0% 0% 0%

38 Funding Agency Name 0% 0% 0%

39 Funding Agency Code 0% 0% 0%

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

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

42 Funding Office Name 0% 0% 0%

43 Funding Office Code 0% 0% 0%

44 Awarding Agency Name 0% 0% 0%

45 Awarding Agency Code 0% 0% 0%

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

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

48 Awarding Office Name 0% 0% 0%

49 Awarding Office Code 0% 0% 0%

51 Appropriations Account 0% 38% -38%

163 National Interest Action (No. 58) 0% N/A 0%

19 Catalog of Federal Domestic Assistance (CFDA) Number N/A N/A N/A

20 Catalog of Federal Domestic Assistance (CFDA) Title N/A N/A N/A

35 Record Type N/A N/A N/A

37 Business Types N/A N/A N/A

54 Unobligated Balance N/A N/A N/A

57 Outlay (Gross Outlay Amount By Award CPE) N/A N/A N/A
19

Appendix VI – CIGIE’s DATA Act Anomaly Letter

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_____________ BROWN & COMPANY ---------CERTIFIED PUBLIC ACCOUNTANTS AND MANAGEMEN:=T:-'.C::".O::":N~S=UL= TAN-:-:-:'.T= s=--.-=p=L-=- L-=c -----------1• 
20
21

Appendix VII – Management’s Response

MEMORANDUM 

TO: Christopher Skinner, Inspector General 

FROM: John Quinlan, CFO~ 

Gilbert For~get Director and Senior Accountable Official for the Digital 

Accountability and Transparency Act of2014 (DATA Act) 

DATE: November 1, 2021 

SUBJECT: Management Response to Independent Auditor's Report on the Compliance with 

the Digital Accountability and Transparency Act of20 14 Submission 

Requirements for Fiscal Year 2021 

Thank you for the Office of the Inspector General's (OIG) review of FY 2021 first quarter 

information (October ~December 2021) produced in accordance with the DAT A Act. We are 

pleased that the controls that management put in place after the 2019 report led to marked 

improvements. For example, the error rates for completeness, timeliness and accuracy were 

reduced to 3.8 percent, leading to the classification of the data as higher quality. The files 

provided by the Federal Election Commission's (FEC) accounting service provider also show 

improvements. 

Below is management's response to the recommendations contained in the repo11. We look 

forward to working with the OIG to identify activities to realize further improvements to the 

information provided under the DAT A Act. 

NFR 2021-1: Finding: Federal Election Commission (FEC) FY 2021 first quarter Files C 

submission was not complete, accurate, and did not include all transactions and linkages. 

Recommendation 1: We recommend the FEC DATA Act program team coordinate with the 

FSSP to correct errors identified in DAT A Act File C submission, as well as to come to a mutual 

agreement how IAAs should be reported. 

______________ BROWN & COMPANY~~~~~~~::;;;;;~~:;:~;::==============t"~ ----------CERTIFIED PUBLIC ACCOUNTANTS AND MANAGEMENT CONSULTANTS, PLLC _________ _ 
22

Reconunendation 2: We recommend that the FEC's SAO and FSSP SAO collaborate to ensure 

going forward, adequate time is provided to identify and correct errors prior to the final DATA 

Act submission due dates. 

While management suppor1s etYort.~ to improve data quality, it does not agree with these 

recommendations. Management largely supp01ts collaboration with the Federal Shared 

Scrvicc Provider (FSSP) to improve DAT A Act File C. We have already worked with the 

FSS P to accomplish positive results hy, for example, idcntifying lnterageney Agreements 

!hat should nut be included in File C. We hope subsequenl quarters rdket these clfort.s. 

:\fanagemcnt. however, docs not folly agree with the condition or the cause set forth in the 

finding, so it docs not have confidence that collaboration beyond its cun-e11t ctforts will 

necessarily have the desired uuh;ome uf aligning File C records wilh File D1 (prornrement 

award data). 

For ir1stance, management sccs the 36 outlay records inconcctly recorded as obligations as 

primmily a system issuc in the DATA Act tiles maintained by the FSSP. FEC did not 

receive CARES Act funding, and thcreforc was not required to rcpm1 on outlays in Ql of 

FY2021. Further, the D1 iilc docs nut include outlays, making a linkage between !he two 

files diflicult for comparison pmposes. The FEC DATA Act team appropriately identified 

these items as not obligations and outside the scope nfrcquircd data clement.~. 

l Jnfor1unately, for reasons unknown to n :c, the system that produces the final File C 

induded lhcsc records as obligations. Once this File C was prcsenled to FEC, it faced a 

catch-22 to acccpt the files and include comments or risk all records, including concctly 

recorded transaction, not hcing cnnsidcrcd timely and, more impmtantly, not presenkd 011 

!he: CSAspc:nding.gov website for public review. Similarly, the four procurement at:lions 

induded in !he D1 iik, bul nul in lik C, arc normally recorded in the 1inan1.Cial system or 

record maintained by the FSSP after FEC sends an obligation transmittal. 111c system that 

produces the File C data, however, did not indude these four entries. Wilhout. foll ability t.o 

rnodily the syslem, ii may be diilicult lo aehieve !he desired res ulls. 

______________ BROWN & COMPANY~~~~~~~::;;;;;~~:;:~;::==============t-~ ----------CERTIFIED PUBLIC ACCOUNTANTS AND MANAGEMENT CONSULTANTS, PLLC _________ _ 
23

Appendix VIII – Glossary of Abbreviations and Acronyms

CIGIE The Council of the Inspectors General on Integrity and Efficiency

COVID-19 Coronavirus Disease 2019

DAIMS DATA Act Information Model Schema

DATA Act The Digital Accountability and Transparency Act of 2014

Data elements Data definition standards

FABS Financial Assistance Broker Submission

FAEC Federal Audit Executive Council

FAIN Federal Award Identification Number

FAR Federal Acquisition Regulations

FEC Federal Election Commission

FFATA Federal Funding Accountability and Transparency Act of 2006

FPDS-NG Federal Procurement Data System - Next Generation

FSRS Subaward Reporting Systems

FSSP Federal Shared Services Provider

FY Fiscal Year

GAGAS Generally Accepted Government Auditing Standards

GAO Government Accountability Office

GTAS Government-wide Treasury Account Symbol Adjusted Trial Balance System 

IAA Interagency Agreements

IDD Interface Definition Document

IG Inspector General

NAICS North American Industry Classification System

OFF Oracle Federal Financial

OIG Office of Inspector General

OMB Office of Management and Budget

OMB Circular 

No. A-11

OMB Circular No. A-11, Preparation, Submission and Execution of the Budget

PIID Procurement Instrument Identifier

RSS Reporting Submission Specification

SAM System for Award Management

SAO Senior Accountable Official

SF-133 Standard Form - 133 Report on Budget Execution and Budgetary Resources

SOC Service Organization Control

TAS Treasury Account Symbols

TOA Transaction Obligated Amount

Treasury The United States Department of the Treasury

URI Unique Record Identifier