Office of the Secretary 

Commerce Has 

Procedures in Place for 

Recovery Act Recipient Reporting, but 

Improvements Should Be Made 

Final Report No. OIG-11-031-A 

July 29, 2011 

FOR PUBLIC RELEASE 

OIG Office of Audit and Evaluation

U.S. DEPARTMENT OF COMMERCE

Office of Inspector General
July 29,2011

MEMORANDUM FOR: Barry Berkowitz

Senior Procurement Director and Director,

Office of Acquisition Management

UNITED STATES DEPARTMENT OF COMMERCE

Office of Inspector General

Washington. D.C. 20230

FROM: Ann C. Eilers

SUBJECT: Commerce Has Procedures in Place for RecovelY Act

Recipient Reporting. but Improvements Should Be Made

Final Report No. OIG-II-031-A

We have attached our final audit report related to our continued review of funds disbursed under

the American Recovery and Reinvestment Act of2009. Our audit objective was to determine

whether the Department ofCommerce has implemented sufficient internal controls to ensure that

data related to Recovery Act funds and fund recipients are rep0l1ed completely, accurately, and

in a timely manner, and that any material omissions and significant errors are identified and

corrected. We conducted this review under the authority of the Inspector General Act of 1978, as

amended, and Department Organization Order 10-13, dated August 31, 2006.

Our review offive ofthe Department's agencies-the Economic Development Adminish'ation

(EDA), National Institute of Standards and Technology (N 1ST), National Oceanic and

Ahnospheric Administration (NOAA), National Telecommunications and Information

Administration (NTlA), and Census Bureau-found that while Commerce has implemented

effective internal controls over its recipient reporting, there are still opportunities for

improvement. Additionally, agencies could improve data quality by updating their management

systems to more efficiently monitor inforn1ation that must be reported under the Recovery Act.

We received responses to our draft report from the Department, EDA, NIST, Census, and

NOAA. We modified this final report as needed to address the agencies' comments, summarized

the comments in the report, and included the forn1al responses as an appendix. The final report

will be posted on OIG's website pursuant to section 8L ofthe Inspector General Act of 1978, as

amended.

Please direct any inquiries regarding this report to me at (202) 482-2754, and refer to the report

title in all cOITespondence.

Attachment

Principal Inspector General for Audit and Evaluation
cc: Scott Quehl, Chief Financial Officer and Assistant Secretary for Administration 

 Darryl Anderson, Director, Commerce Acquisition Solutions 

 Trudy Gallic, Audit Liaison 

Sandi Walters, Chief Financial Officer/Chief Administrative Officer, EDA

 Deborah Neff, Audit Liaison, EDA 

 Wesley Dias, Audit Liaison, Economics and Statistics Administration 

 Michael Palensky, Chief, Acquisition Division, Census Bureau 

 Adam Miller, Audit Liaison, Census Bureau 

 Cecelia Royster, Chief, Acquisition Management Division, NIST 

 Usha Ganti, Division Chief, Grants and Agreements Management Division, NIST 

 Rachel Kinney, Audit Liaison, NIST 

 Chad Wagner, Branch Chief Oversight and Compliance, NOAA 

 Mitchell Ross, Director, Acquisition and Grants Office, NOAA 

 Mack Cato, Audit Liaison, NOAA 

 Aimee Meacham, Compliance Specialist, NTIA 

 Milton Brown, Audit Liaison, NTIA 
Report In Brief

U.S. Department of Commerce Offi ce of Inspector General

July 29, 2011

Office of the Secretary

Commerce Has Procedures in Place for Recovery Act 

Recipient Reporting, but Improvements Should 

Be Made (OIG-11-031-A)

 

Why We Did This Review

Background

This report is part of OIG’s 

continued oversight of the $7.9

e 

e 

-

ne

al

O

m

billion in funds received by 

five Department of Commerc

agencies (plus OIG) under th

American Recovery and Rein

vestment Act of 2009. 

Our objective was to determi

whether the Department has 

implemented sufficient intern

controls to ensure that data 

related to Recovery Act funds, 

projects, and fund recipients 

are reported completely, accurately, and in a timely manner, 

and that any material omissions and significant errors are 

identified and corrected. 

What We Found

What We Recommended

In February 2009, the American Recovery and Reinvestment Act of 2009 was signed 

into law. Section 1512 of the 

act requires fund recipients 

to submit quarterly reports 

containing detailed information 

on the projects and activities funded by the Recovery 

Act and their impact on job 

creation and retention. It also 

directs federal agencies to 

review this information for 

accuracy before it is posted to 

www.Recovery.gov. 

The Recovery Accountability 

and Transparency Board is 

responsible for coordinating 

and conducting oversight of 

Recovery Act spending to 

help prevent waste, fraud, and 

abuse. The board has created 

an online system to collect section 1512 data from Recovery 

Act fund recipients and provide the information to taxpayers on www.Recovery.gov. 

ur review of fi ve of the Department’s agencies—the Economic Development Adinistration (EDA), National Institute of Standards and Technology (NIST), National 

Oceanic and Atmospheric Administration (NOAA), National Telecommunications and 

Information Administration (NTIA), and Census Bureau—found that while Commerce 

has implemented effective internal controls over its Recovery Act recipient reporting, 

there are still opportunities for improvement. 

We compared data elements in the quarterly reports submitted by the recipients to the 

same information in Commerce’s grants and contracts management systems. While the 

overall error rate in recipient reporting was low and the data differences were generally 

in non-critical reporting fi elds, Commerce agencies did not identify and correct some 

of the signifi cant data errors on the quarterly reports. In addition, incorrect or inconsistent data in the Department’s three grants management systems meant that Commerce 

personnel had to perform many manual procedures to reconcile the data to the information in the recipients’ reports. 

We found several areas in which Commerce could reduce its reliance on manual effort, 

increase the effi ciency of its reporting, and improve data quality. For example, its systems could be updated to make data fi elds consistent with recipients’ quarterly reports. 

Also, implementing a single Department-wide management system to replace the three 

current systems would further streamline processes and increase accuracy. 

We recommended that Commerce’s Director of the Office of Acquisition Management

1. evaluate ways to automate the reports generated by the Department’s three grants 

management systems; 

2. develop a plan for consolidating the data from the three distinct grants management 

systems into a single system; and 

3. consider upgrading the Department’s new contract management system interface so 

that a single database incorporating data from all Commerce agencies would supply 

the information in the interface. 

Additionally, agencies could improve data quality by updating their management systems to more efficiently monitor information that must be reported under the Recovery 

Act.
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

Contents 

Introduction ..................................................................................................................................... 1

Findings and Recommendations ..................................................................................................... 4

I. Commerce Agencies Did Not Detect All Incorrect Recovery Act Data on Recipients’ 

Quarterly Reports ........................................................................................................................ 4

II. Incorrect and Missing Data in Commerce Management Systems Affect the Adequate 

Monitoring of Recovery Act Recipients’ Quarterly Reports ...................................................... 5

III. Commerce Agencies Can Improve the Recovery Act Data Quality Process by Updating 

Their Management Systems ........................................................................................................ 6

IV. Recommendations ............................................................................................................ 7

V. Other Matters Noted ......................................................................................................... 8

VI. Summary of Agency Comments and OIG Response ....................................................... 9

Appendix A: Commerce Recovery Act Funding .......................................................................... 10

Appendix B: Objectives, Scope, and Methodology ...................................................................... 11

Appendix C: Recovery Act Data Inconsistencies on Quarterly Reports and Management 

Systems ......................................................................................................................................... 12

Appendix D: Responses to OIG Draft Report .............................................................................. 13
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

Introduction

In February 2009, the American Recovery and Reinvestment Act of 2009 (Pub. L. No. 111-5) 

was signed into law. Section 1512 of the Recovery Act requires recipients to submit quarterly 

reports containing detailed information on the projects and activities funded by the Recovery Act 

and their impact on job creation and retention. It also directs federal agencies to review this 

information before it is posted to the www.Recovery.gov website (see figure 1 on the next page 

for an illustration of the process). This 

reporting requirement is part of the 

President’s stated commitment to provide an 

unprecedented level of transparency and 

accountability with regard to the use of 

Recovery Act funds. 

The American Recovery and The Recovery Accountability and 

Transparency Board is responsible for Reinvestment Act of 2009 (Pub. L. No.111-5) was 

coordinating and conducting oversight of enacted February 17, 2009, to preserve and 

Recovery Act spending to help prevent fraud, create jobs; assist those most affected by the 

waste, and abuse. The Recovery Board has recession; increase economic efficiency by 

created a system at the website investing in technological advances in science and 

www.FederalReporting.gov to collect this health care; invest in transportation, environmental 

section 1512 data from Recovery Act fund protection, and other infrastructure that will provide 

recipients and provide the information to long-term economic benefits; and stabilize state taxpayers on the www.Recovery.gov website. 

and local budgets. 

The Department of Commerce received 

$7.9 billion of Recovery Act funds for six of 

its agencies—the Economic Development Administration (EDA), National Institute of Standards 

and Technology (NIST), National Oceanic and Atmospheric Administration (NOAA), Census 

Bureau, National Telecommunications and Information Administration (NTIA), and Office of 

Inspector General (OIG). (See appendix A for a breakdown of funding among these agencies.) 

As of March 31, 2011, approximately $2.1 billion of these funds had been expended by the 

Department. For the period of our audit, the quarter ending June 30, 2010, about $224 million of 

grant and contract expenditures were reflected in the recipient quarterly reports. These reports 

were submitted by 320 grant recipients and 137 contract recipients. 

The objective of this review was to determine whether the Department had implemented 

sufficient internal controls to ensure that recipient data is reported completely, accurately, and in 

a timely manner, and that any material omissions and significant errors are identified and 

corrected. We have detailed the objectives, scope, and methodology of our audit in appendix B. 

We found that, with minor exceptions, Commerce has internal control policies and procedures in 

place to effectively review the recipient quarterly reports. However, agencies could improve the 

data quality process by updating their management systems so that they can more efficiently 

monitor the information required to be reported by the Recovery Act. 

1
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

Figure 1. Recipient Reporting Timeline for Quarter Ending June 30, 2010a 

Reporting Timeline and Activities

Agency, 

Prime and 

Sub 

Recipient 

Registration 

1 – 14 days 

after end of 

Quarter

21 -22 days 

after end of 

Quarter

23 – 29 days 

after end of 

Quarter

30 days 

after end of 

Quarter

Prime 

Recipients 

& Subs 

Enter Draft 

Reporting 

Data 

Initial 

Submission 

2

Prime 

Recipients 

Review Data 

Submitted 

By Sub(s)

3

Prime 

Recipients 

& Subs 

Make 

Corrections

5

Agency 

Review of 

Data 

Submitted

Recipient 

Reports 

Published 

on 

Recovery.

gov

Prime 

Recipients 

& Subs 

Make 6 Corrections 8

7

Agency Review Period

Continuous

9

33- 75 days 

after end of 

Quarter**

Reporting

Phase: Initial 

Submission

Recipient

Review

Agency

Review Published

Prime 

Recipients 

Review Data 

Submitted 

By Sub(s)

Agency 

Comments 

on Data 

Submitted

10

**During the Continuous QA Period, reports may not be submitted, only corrected

31-32 days after end of Quarter - Maintenance

Recipient Report Corrections Possible

Continuous

QA

Prime 

Recipients 

& Subs 

Make 

Corrections

12

Agency “View Only” and Daily Extract

15 – 20 days 

after end of 

Quarter

Late 

Submission 

1

Late

Submission

4

11

Source: Office of Management and Budget a

Other recipient reporting quarterly periods have had slightly different numbers of days for each part of the reporting 

and reviewing process. We used the June 30, 2010, process because this was the period data was reviewed. 

We reviewed all 457 of the Recovery Act quarterly reports received from Commerce agencies 

during the quarter ending June 30, 2010, representing 6,443 recipient data entries. We compared 

data element information in the quarterly reports to the same information in Commerce agencies’ 

grants and contracts management systems and found 646 errors or data inconsistencies1

(approximately 10 percent of the entries reviewed). Of these errors or inconsistencies, we found 

the following: 

• One hundred six errors (approximately 2 percent of all data entries reviewed) were made 

by Recovery Act recipients on their quarterly reports and not caught during the review 

process by the awarding Commerce agency; six of these errors (less than 0.01 percent) 

are classified under Office of Management and Budget (OMB) guidance as significant 

errors

2

 but have not been reported to OMB as required. 

• Five hundred forty inconsistencies (approximately 8 percent of all data entries reviewed) 

were found in Recovery Act recipients’ data information maintained on Commerce 

                                                            

1 The data inconsistencies are a result of our comparison of Recovery Act recipient data being maintained on 

Commerce agencies’ management systems to the same data submitted by recipients on quarterly reports to 

www.FederalReporting.gov. 2 Significant reporting errors are defined as those instances in which required data are not reported accurately, and 

the erroneous reporting results in significant risk that the public will be misled or confused by the report in question 

(OMB M-09-21).  

2
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

agencies’ grant and contract management systems. This amount consisted of 281 

instances of incorrect recipient data on these systems and 259 instances of required 

section 1512 data not being captured by these systems; the current Commerce systems, 

which were created prior to the Recovery Act and were not updated after it was enacted, 

do not capture all the data required in section 1512 reports. 

While the overall error rate in recipient reporting was very low, it came at the price of many 

manual procedures being performed by the Department’s grants and contracts personnel to 

compensate for errors or inconsistencies. Updated management systems could result in a more 

efficient use of time and resources, as well as ensure consistently high data quality and lower 

error rates. 

 

3
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

Findings and Recommendations

I. Commerce Agencies Did Not Detect All Incorrect Recovery Act Data on Recipients’ 

Quarterly Reports 

OMB Memorandum M-09-21, section 4.3, requires federal agencies, recipients, and 

subrecipients to establish internal controls to ensure data quality, completeness, accuracy, and 

timely reporting of all amounts funded by the Recovery Act. Section 4.2 of the memorandum 

requires federal agencies to provide advice or programmatic assistance to recipients, perform 

limited data quality reviews to identify material omissions or significant reporting errors, and 

notify the recipients of the need to make appropriate and timely changes. These steps are vital 

because incorrect data may give users of the www.Recovery.gov website an inaccurate portrayal 

of how Recovery Act funds have been spent. Inaccurate or incomplete data does not reflect the 

President’s stated commitment to transparency and accountability. 

Commerce agencies did not detect, and then require recipients to correct, 106 errors on recipient 

quarterly reports for the period ended June 30, 2010 (see appendix C). This resulted in inaccurate 

Recovery Act data information being posted on www.Recovery.gov for public viewing. Most of 

the incorrect data involved insignificant errors such as primary-place-of-performance ZIP codes3

and award dates. These data errors affected 75 of the 457 quarterly reports reviewed (table 1). 

Table 1. Recovery Act Reports with Errors 

NOAA NIST NTIA EDA Census Total 

Contracts 27 19 - - 2 48 

Grants 3 7 12 5 - 27 

Totals 30 26 12 5 2 75 

Source: OIG Analysis of Agency Data 

OMB Memorandum M-10-08, part 1, requires Recovery Act recipients to correct all data errors 

identified by federal agencies for the current reporting period, or submit a reasonable explanation 

of why a critical data element4

 was not incorrect. If the reporting on the critical data elements is 

not corrected, the award report is considered to have significant errors. Six of the 106 errors we 

reviewed are categorized as significant. As table 2 shows, the errors were in critical data fields—

the recipient name, award amount, and award numbers—and were distributed over four of the six 

reporting agencies. Management did not detect these errors because it relied on a labor-intensive 

imperfect manual reconciliation process to review recipient reporting integrity. We discuss this 

                                                           

3

 The primary-place-of-performance ZIP code and primary-place-of-performance congressional district data 

elements denote the location at which most of the Recovery Act-funded work is being performed. 

4 OMB Memorandum M-10-08 defines the critical element data fields that are of major concern for significant errors 

as (1) federal amount of the award, (2) number of jobs retained or created by the project, (3) federal award number, 

and (4) recipient name. We did not test for jobs created or retained because we did not go out to recipient sites.

4
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

process in more detail later in the report. These errors should have been reported to OMB by end 

of the quarter, but OIG has not been provided any evidence that this was done. 

Table 2. Significant Reporting Data Errors 

Critical Data NIST NTIA NOAA EDA Totals 

Recipient Name - - 1 1 2 

Award Amount 2 - - - 2 

Award Number - 2 - - 2 

Totals 2 2 1 1 6 

Source: OIG Analysis of Agency Data 

II. Incorrect and Missing Data in Commerce Management Systems Affect the Adequate 

Monitoring of Recovery Act Recipients’ Quarterly Reports 

We found 540 inconsistencies between the data reported by the recipients and the information 

maintained on Commerce’s management systems. These instances included 281 data entries in 

which the agencies’ systems contained incorrect information; in the rest, the systems did not 

maintain the information required in section 1512 reports (see table 3 and appendix C). These 

inconsistencies have increased the cost of reconciling the quarterly recipient reports with the data 

maintained in Commerce systems due to increased employee hours needed to perform manual 

reconciliations. 

Table 3. Inconsistent Data in Management Systems 

NTIAa NOAA EDA NIST CENSUS Total 

Incorrect Data 159 61 31 26 4 281 

Missing Data 38 98 85 33 5 259 

Totals 197 159 116 59 9 540 

Source: OIG Analysis of Agency Data aNTIA awards are handled by either NOAA or NIST. 

Of the 281 instances of incorrect data, 220 (approximately 78 percent) were on NOAA’s and 

NTIA’s systems. These instances included incorrect awarding and funding agency identification 

numbers, primary-place-of-performance ZIP codes, and primary-place congressional district 

numbers for certain NOAA and NTIA awards. According to NOAA officials, 61 errors were due 

to NOAA incorrectly identifying itself, rather than NTIA, as the awarding agency in cases in 

which NOAA had an agreement to administer grants on behalf of NTIA (the actual awarding 

5
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

agency). NOAA officials also stated that the data fields in their management systems for 

primary-place-of-performance ZIP codes and congressional districts only have the capability to 

identify the main address for the grant recipients, while the recipient quarterly reports received 

on www.FederalReporting.gov show where the grant work is actually being performed as 

required by OMB Memorandum M-09-21. 

The 259 instances of missing data on Commerce management systems consisted mostly of 

missing funding agency identification numbers for NOAA and NIST contract awards and 

missing primary-place-of-performance ZIP codes for NTIA, NOAA, and EDA grant awards. 

NOAA and NIST contract officials explained that the Federal Procurement Data System-Next 

Generation (FPDS-NG) 5 does not require system users to enter funding agency identification 

numbers when they are the same as the contracting agency numbers. NOAA officials further 

stated that all of NOAA’s discrepancies were corrected in September 2010. NIST and NOAA 

officials stated that their management systems do not capture the primary-place-of-performance 

ZIP codes from the grant awards. NIST officials also said that NIST’s system does not require 

the entry of “ZIP+4” codes, but staff will add the additional numbers to the data entries that had 

been flagged as errors during the quarter we reviewed. 

III. Commerce Agencies Can Improve the Recovery Act Data Quality Process by 

Updating Their Management Systems 

OMB Memorandum M-09-21, section 3.12, states that “[f]ederal agencies should develop 

internal policies and procedures for reviewing reported data” and that “[a]utomated checks for 

accuracy may be conducted by comparing recipient data to the award data stored in agency 

financial systems of record.” 

During our review, we noted that Commerce agencies could improve the Recovery Act data 

quality process by updating their automated management systems so that the agencies can more 

efficiently monitor the information the Recovery Act requires them to report. While our review 

found that the overall recipient reporting error rate was low (less than 1 percent were significant 

errors), to achieve these results grants and contracts personnel had to perform many additional 

manual tasks that adversely affected efficiency. The following automated management system 

improvements would make it easier for Commerce and its agencies to review grants and 

contracts data information and identify errors in recipient information: 

1. The implementation of a single Department-wide management system would assist 

Commerce in its data reviews. Commerce agencies currently use three different 

management systems for grant awards. These systems were designed to meet the needs of 

EDA, NIST, and NOAA but are not always updated to meet changing requirements. The 

contracts management system used by all federal departments, including Commerce, is 

the FPDS-NG; however, individual agencies do not have individual input or control over 

this system. Multiple departmental management systems have led to an increased need 

for manual reviews of agency and award data. With the reduced staffing that several 

agencies have reported to us as a possibility in FY 2012, the accuracy of a highly manual 

                                                           

5 FPDS-NG is a single-source database system the federal government uses to report information and data on all 

federal contracts. 

6
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

process is likely to decrease. In addition, award information requirements may continue 

to change over time; therefore, for ease and accuracy, it is in the best interest of the 

Department to have a consistent management system. 

2. Systems should be updated as needed to reflect changes in federal reporting 

requirements. For example, NOAA grant officials stated that its grants management 

system, Grants Online, does not have fields to capture some critical data, such as the 

primary place of grant performance. Therefore, NOAA has to manually look up data in 

the grant award file to make comparisons in its required review of recipient quarterly 

reports. 

3. By making data entry fields consistent between agency systems and the recipients’ 

quarterly reports, agencies would be better able to track the data and correct problems 

quickly. The current systems did not always capture data consistently with the quarterly 

reports. Our review found instances in which management systems limited the number of 

characters in certain data entry fields and other fields that only permitted default entries. 

These limitations made it challenging for agencies to review and reconcile the same data 

element on the recipient quarterly reports. For example, in the comparison of the 

primary-place-of-performance ZIP codes, we noted 189 instances in which quarterly 

reports did not agree with the agencies’ management systems. NIST grant officials stated 

the main reason for the differences was that their management systems only allowed for 

the traditional five-digit ZIP codes, not nine-digit “ZIP+4” codes. 

4. Systems should be modified to permit changes to data. The systems do not always allow 

for changes once the data is entered. EDA grant officials told us that they could not 

update their management system to change a recipient’s Data Universal Numbering 

System (DUNS) number to agree with the number used by the recipient in its quarterly 

reports. 

5. The implementation of a single Department-wide acquisitions management system 

interface would assist Commerce in its data reviews. The contract management system 

used by all federal departments, including Commerce, is FPDS-NG. The Department is 

currently using a web-based product as an interface with FPDS-NG and is in process of 

upgrading to a new product called C-Award. However, this new interface still has a 

significant limitation: C-Award currently uses four separate databases (NOAA, NIST, the 

Department, and Census) to track the contracts that are being reported into FPDS-NG. If 

these four databases were combined into one, it would be useful for running Departmentwide acquisition queries and complying with Recovery Act reporting requirements. 

IV. Recommendations 

We recommend that Commerce’s Director of the Office of Acquisition Management 

1. Evaluate ways to automate the reports generated by the Department’s three grants 

management systems. This automation will help to ensure that recipient data are 

accurately reported and that agency staff uses the most efficient process to review data. 

7
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

2. Develop a plan for consolidating the data from the three distinct grants management 

systems into a single system that can provide accurate and comprehensive data feeds to 

public websites such as www.Recovery.gov.

6

 

3. Consider upgrading the new C-Award contract system so that a single database 

incorporating data from all Commerce agencies would supply the information in the 

interface. This would assist the Department in running acquisition queries, resulting in a 

less manual process for data comparisons and reporting to public websites such as 

www.Recovery.gov. 

We also recommend that Commerce agencies implement the following improvements for 

reviewing Recovery Act recipient data so that significant errors do not occur: 

1. Ensure that the management systems used by the agencies can be updated to incorporate 

Recovery Act reporting requirements. 

2. Establish the ability to make corrections to data once they have been entered into the 

agencies’ management systems. 

Improvements in these areas would make it easier for the Department and its agencies to review 

grants and contracts information and identify errors in recipient data information, thus reducing 

the manual effort currently involved in the review process. 

V. Other Matters Noted 

In addition to the data inconsistencies noted previously, we found the following issues in the 

quarterly reports we reviewed: 

• Nine reports showed incorrect award amounts in the FPDS-NG. While the agency 

involved (NOAA) is aware that the amounts reported are incorrect in FPDS-NG, 

Commerce agencies do not have a way to correct the award amounts after the first 

invoice has been received. Officials stated that the award amounts reported to 

www.Recovery.gov are correct. 

• Seven recipients were considered noncompliant7

 by OMB for not submitting their 

quarterly reports by the due date. The recipients gave various reasons for their 

noncompliance, including not understanding the reporting process and having difficulty 

with the www.FederalReporting.gov registration process. These instances of 

noncompliance were corrected in the subsequent quarter, and the recipients are being 

monitored to ensure they continue to submit reports correctly. 

                                                           

6

A similar recommendation was included in OIG report ARR-19779, More Automated Processing by Commerce 

Bureaus Would Improve Recovery Act Reporting, dated December 2009. 7

Noncompliant recipients are those who have failed to submit a section 1512 report as required by the terms of their 

awards.  

8
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

• Two reports included instances that revealed administrative or technical issues.8 One 

such issue occurred in the period ending June 30, 2010. Both have also been corrected by 

recipients. 

VI. Summary of Agency Comments and OIG Response 

We received and reviewed agency responses to our draft report. Formal responses were sent by 

the Department, NIST, and NOAA; EDA and Census submitted informal comments. Because its 

awards are handled by NOAA or NIST, NTIA had no comments on the draft. In general, the 

Department and the agencies that responded concurred with our findings. We have modified this 

final report to address their comments, and have included the formal responses as appendix D. 

                                                           

8

 OMB M-10-14 states that administrative or technical issues include (but are not limited to) duplicated reports, 

unlinked reports, or technical issues relating to a record identifier.

9
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

Appendix A: Commerce Recovery Act Funding

(in thousands) 

Economic Development 

Administration (EDA) 

 $150,000

$ 150,000 

Grants to economically distressed areas to support efforts to 

create higher‐skill, higher‐wage jobs by promoting innovation 

and entrepreneurship and connecting regional economies with 

the worldwide marketplace 

Census Bureau 

$1,000,000 1,000,000 

Hire new personnel for partnership and outreach efforts to 

minority communities and hard‐to‐reach populations, increase 

targeted media purchases, and ensure proper management of 

other operational and programmatic risks 

National Oceanic and 

Atmospheric Administration 

(NOAA) 

$830,000

230,000 Habitat restoration, navigation projects, vessel maintenance 

430,000 

Construction and repair of NOAA facilities, ships, and 

equipment; improvements for weather forecasting and satellite 

development 

170,000 Climate computing and modeling 

National Institute of 

Standards and Technology 

(NIST) 

$610,000

220,000 

Laboratory research supporting economic growth and innovation 

through competitive grants, research fellowships, and advance 

measurement equipment 

360,000 Maintenance and renovation backlog 

30,000 

Funds from the Department of Health and Human Services for 

standards-related research on medical records; from the 

Department of Energy to develop a framework for an 

interoperable smart grid for the U.S. electric power system 

National 

Telecommunications and 

Information Administration 

(NTIA) 

$4,690,000 Broadbanda 

$650,000 Converter boxb

3,890,000 

Broadband Technology Opportunities Program—awards to 

eligible entities to develop and expand broadband services to 

rural and underserved areas and improve access to broadband 

by public safety agencies 

350,000 Broadband inventory mapping 

250,000 Sustainable adoption of broadband services 

200,000 Upgrade of public computer centers 

650,000 TV converter box coupons 

Office of Inspector General 

$16,000 16,000 Oversight 

Total 7,946,000 

a

Since subject to $302 million rescission. 

b

Since subject to $240 million rescission.

10
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

Appendix B: Objectives, Scope, and Methodology

Section 1512 of the American Recovery and Reinvestment Act of 2009 requires recipients to 

report funding and project data to www.FederalReporting.gov. The objective of our review was 

to determine whether the Department of Commerce has implemented sufficient internal controls 

to ensure that recipient data is reported completely, accurately, and in a timely manner and that 

any material omissions and significant errors are identified and corrected. 

During this review, we performed the following activities: 

• Interviewed Commerce’s Recovery Act staff to obtain an understanding of the steps 

performed in reviewing and analyzing data received from www.FederalReporting.gov. 

• Interviewed contract and grant staff responsible for Recovery Act awards to obtain an 

understanding of how they ensure accuracy, completeness, and timeliness of the data. 

• Reviewed internal controls to determine how the staff is monitoring material omissions, 

significant errors, anomalies, and other administrative or technical errors in the data. 

• Determined whether policies and procedures were in place to remediate systemic and 

chronic reporting problems, including ways to handle non-reporters. 

• Conducted a 100 percent review of recipient-reported data on quarterly reports submitted 

through www.FederalReporting.gov and electronically compared them with the 

information in the agency-owned systems to determine the accuracy and completeness of 

the data submitted for the quarterly period ending June 30, 2010. 

We also examined the Recovery Accountability and Transparency Board’s Data Quality Review 

Guide, which provides additional guidance to the inspector general (IG) community for assessing 

bureaus’ plans for ensuring data quality of Recovery Act recipient reporting. IG offices use the 

guide to conduct audits to determine whether each bureau receiving Recovery Act funding has 

established a process to perform limited data quality reviews. These reviews are intended to 

identify material omissions and significant reporting errors, as well as notify the recipients of the 

need to make appropriate and timely changes. 

We conducted this performance audit from July 2010 through March 2011 under the authority of 

the Inspector General Act of 1978, as amended, and Department Organization Order 10-13, 

dated August 31, 2006. We conducted this audit in accordance with generally accepted 

government auditing standards, which 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 objective. We believe the evidence obtained does provide a reasonable basis 

for our findings and conclusions. 

11
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

Appendix C: Recovery Act Data Inconsistencies 

on Quarterly Reports and Management Systems

Quarterly Reports

Data Elements NOAA NTIA/ 

NOAA NIST NTIA/ NIST EDA CENSUS TOTALS 

Funding Agency ID 1 7 8 

Primary-Place-ofPerformance Zip Code 9 13 8 3 33 

Award Date 6 9 2 2 1 20 

Award Missing from 

FederalReporting.gov 16 16 

Activity Code 4 1 5 

Other 8 1 11 1 2 1 24 

TOTALS 43 1 35 11 7 9 106 

Management Systems

Data Elements NOAA NTIA/ 

NOAA EDA NIST NTIA/ NIST CENSUS TOTALS 

Awarding Agency ID 65 65 

Funding Agency ID 35 23 58 

Recipient 

Congressional District 5 8 2 15 

Primary-Place-ofPerformance Zip Code 47 43 60 18 36 1 205 

Primary-Place-ofPerformance 

Congressional District 

23 22 8 1 54 

Award Amount 7 3 1 11 

Award Date 1 4 1 2 8 

Award Disbursements 10 12 38 6 16 5 87 

Award Missing from 

FederalReporting.gov 15 15 

Other 17 1 2 2 22 

TOTALS 159 142 116 59 55 9 540 

Source: OIG Analysis of Agency Data 

12
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

Appendix D: Responses to OIG Draft Report

Department Response 

13

UNrTaI STATES tJEPAln'MENf OF COMMERCE

ou.t Fn...a.I Officer _

__s.cr-.ry for Ad,,"aco ali<w,

JUL 1i lOll ~llC.20230

MEMORANDUM FOR: Ann C. Eilers

~torGene",] for Audit and £\'aluation

FROM: ~kSenior Procuremcn! Exe<:uti~e

and DireOlOr for Acquisition Man.gemen!

SUBJECT: Commuce lI"s Proced'ues in Pluct'ft" Reeo"t'T)' ACI

RecipietU Reponinl;. but /mpro\"l'metl/s Should Be Mode

Draft Rqx,"

Thank you for the opportunity 10 commcnt on the draft l'I'JX'rt from the Office of

lns~tor G('f\eral (DIG) emitled Commerce lias f'r(J('edurc.< ITl Piua jQl' Recovery ACI

Ruipien, Rep<1l'ting. butlmprm'l'menu Should Be M"de. TIM: Office of Acquisition

Management grncrall)' concurs "ilh the findings and n,commcndatioTl3.

If you have any questions N:i:3rding this response. please contact Virna Winters at

V" intcrs@'doc.Go\·or202-482-3483.
July 15. 2011

/~j'\ \ .....1

....'T.D .TAT" NT 0" CO••••C•

....,_.' _ An" A 'n, ".... CHIEF AOMINISTRATIVe OFFICER

ME.\IORANDUM FOR:

FRO.\!:

SUBJECT, DOlfl OIG Rcpon c.'<NII"",ru 1/",1 l'rlJ<""I"u.' in 1'/(,..<,jm'

H,-cm"".\' Act Hed/,;"", Rep".-/;"". b'III",W"'"""'''''''' !ilwllid H"

Millie

Than~ y'>1I for (he "l'fI"nunoly 11.1 L'l'llln,.,m on the om,c of III.: In'rec1or Gcncml', dr-1ft '''flOn

or il> I'll' iew of American R,...,,,.'cry and Ikin_eSlmell' ACI fund_ di,llu......'d by Ihe NW'(><l,t1

OccamI' Md AmlO!'phcnc Adm,mSlr.nioll. Our ,['Cel nc commenh On the ~""n', finding, ""d

n:<:omn",rnla'iofl.' arc al1.>ChiXI.

Anochmcl1l

U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

NOAA Response (p. 1) 

14
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

NOAA Response (p. 2) 

15

l.k'pHlmcn. or l.:ommcrrc

Nali,,",,1 lXcanic and AlI"osl,heric ,\dn.iniSl"'-,1 i,,,,

C"mmcnl.~ "n lh~ Ilmn OIG R,·por. En1H1<'lI

"COt1l1nCre~ /las I'rorcdu ..... in 1'1""" r"r R""',,"u)' Arl Redl,ienl Rel'"ning. bu.

Impro,'cme"l' Sbould lie ~t;,d.·"

(t\!U{,\-(lUUtO&lJune 15, ZOII)

(;cn"I"~1 C"m",,'nl,

The: lXpartmenl "(Commerce',, National Oceanic and Almosphcric Adtllini~tmtion (NOA,\)

aPflrer;ates the ron,idc,.~blc time and cffOrl of lhe Offirc of In.'pecmr General (OIG) in

condoctin£ it, re,';ew of l{coco'-cry Act recipient reponing pmetire' within NOAA,

Reo,:unm.cndalion I: "'En,ure that the management 'y,tcm, u>Cd ean be ,'pdated lO IRCO<'Jl'O!'ale

Re<.-o'-ery ,\t-I reponing "-"<Juiremenl,."

NO,\A Response: We coorur. The Granl' Online granl' m"m'gemcm 'y,'em is" eU'lOm;z<od

imemal ')'''cm ~nd change,' can hi: ma<lc wllh proper approvab. If a""w Rerm-ery Art

repuning requm:m"nt i, j(lcmified amI "",,,,,,itale., a changc to lhe NOAA Gra"" Online

man~gcmem 'y<tem. the aPfln:>priatc 'Y"tcm gO"crn~nc" proce" will n,'Cd 10 hi: follow,od 10

Implemenllhe ebanb'C. Any f"'ure changes \till be dependenl upon the av"ilabilily of fundmg

nccc,sary 10 Cffttllhe 'y,'em chan!,'C.

A, nored in the OIG' • reporl. G"am~ Online doc' nOl haw a field 10 "apl",e the primory placc of

grunl performance, Therefore, Ihi, "a, ,-criflcd f(}l" e,,"-,h award and lhcn manually entered mlO

USAspendmg,gov. the public ",archable wc""ile eslabli,hed by ,he Office of Managemenl

Boogcl 10 nxeive and d"play dala pert"ining 10 obligalion, of Fede,.~1 awards. Since lhe

primary place of gmnl perfomlUnee datil field i.' only required for ARRA funded j!.,,~nh," lI,eh

accounled f(}l" only IIl",c percenl of NOAA granl> pl\x.-.:,>Cd in fi«'al year 2009. NOAA made lilt'

dt'Ci,ion r,N 10 modify Ihe G,.~nt, Online 'y>lem.

Rffo",",cnduliotl Z: '-E,labli,h Ihe abil1ly 10 l1la~e corr~'Ctiom to dala oocc Ihey ha'c been

entered inlo the "genei",' managemenl 'ySlem....

"';OAA Resp"""." We concur. NOA,\ eum:n11 y lIa, ,he ability to ma~e correclioo, 10 dala

enlen:d inlo boIh NO,\A Granl, Online and C-Buy.lhr Depanmcnl ofCommcrre procuremenl

and acqui,illon 'y,lem
UNITED BTATlES DEP,&,RTMENT DF CDMMERCE

InBtit~.. '" S..-. _ T_lc>gy

~.Mirvbrd 20099·

"dUL 262011

MEMORANDUM fOR Ann C. Eilers

Principalln>'nligatQr General for Audit and E,,,tLmlion

From' GwrgeE.Jenkim QJ~ "A". dlA.A'

Chief Financial Officer - (J ...O~--'

SUbjecl: NIST Comment< on "Commertc Has ProceduI'CS in Place for Reeo"cry ACI

Recipient Reporting. bUI Impro"ements Should Be Made"

The follo"'ing commenlS arc offered in re"iewoflhe Office of Inspe<:lOr Geneml', <Ubj"l draft

audil rcporl. datcd June IS. 2011, relaled to the American Recovery and Rein,'eSlment Act

(ARRA)of2009.

Gnot. and ,\grN'mrnh Management lIi,";,;nn IG,\Mlll

"age II. 5...,tioo I\'

I. Ensure that lhe mlU\ltgemcnl <YSlcm, u<;ed can be updaled to incorporate Recovery Act

reponing requirements.

The Natinnal lnsriturc OfSlaooards and T..choology (NIST) is aware Oflhe iss"" and has

revie,,-ed the reporl along wilh the a<<<>eialed data lhat was based upon ARRA Quane,ly Repons

that were submitu:d for the 2nd Quaner of calendar year 2010. which ended June )0, 2010. As

dClaHcd in Appendix C ofthc reporl. the majority of lhe data inconsistencies in the a"-ards

managed by NISTs GAMD included rhc recipient>" primary piKe ofperformance. funding

codes and award dales. Since those reports ,,"ere <ubmilted. the GAMD has Up',"led the GranlS

ManagemenllnformatiOn SySlem (G~lJS) to include the Primary I'lace of PcrfOITfl3l1CC for all

ARM award. All incorrect fWldingcodC's and a"'ar<! dalC!< ha"e been corrected, and the ARM

reporting " ..b,ite. wwwFe!kralReooninsuo\",hubeenupdated100fferrecipientsalool

de,igned <p""ifically to faciliUlte aceUlllle. repel;tive rcporling offunding codes, award dates,

and other additional informalion requited in all ARRA Quanerly Reports. The "copy forward"

1001 allows the reporting recipients to autornatieaHy ",prod""c signifieaol quantity ofdata.

mcntioned above. into new ARRA Quarle,ly Kepons, "'hith not onl)' sa"c, rtporting timc. but

alro climinales Ihe thance for lypographical data entri~ 10 fIeld, in Ihe ARRA Quancrl)'

Repons.

P~gc 8. S...,tion IV

2. Establish the ability to make oorrcctions to data onec the)' ha"c been c:ntered into lht

agcncin' management sy'lelTlll.

U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

NIST Response (p. 1) 

16

NlSr
U.S. Department of Commerce Final Report 

Office of Inspector General July 29, 2011 

NIST Response (p. 2) 

 (ARRA–000108)

17

NIST is DWare of the issue and plans enhancements to GMIS during lhe next fiscal year 10

~UlOfl\ate uploading of revi$e'll g.ranHeialed informalion to US,\Spen<!;ng,gov during monthly

updates. This "ill ensUJ'C' llCcul1lCY Qfspecific g.ranHelatcd ;nfQrmation lhat has been re\';sed

during lhe pre,-ious month on USASpen<ling,go,' within 30 da)'s of lilt change via an automaled

~. This wi11 replace current method which requires the GAMD Grnnls Specialists to make

individual reqUl:slll to the GAMD GMIS Coordin~lor to upload newl)' revised informal;on for

viewing by the public on """v. USASprndjOlI,guV.

t'eQul,il;On l\Iaoal:cmeollli"jsion (Al\Illl

hgt 4. Seetion 1

Some ohhe ZlI' code errors were made On the last 4 digits of 9 digit ZIP codes. In addition. lhe

Central ConU1><ts Registry (CCR) m:ipients provided different ZIP codes for the same a"'lIrd in

the CCR registration and the \\)\W.fes!emlreoonjnM.!l9v repon.

Page 5, Section I. Table!

The lwo NIST ;ocorre<:t contract amoums h"'e been corrected.

Pagt 6, Section II

'rne funding agency identification code in FPDS ,,-as oot a mandalory field ulllil Apri!. 2010,

Since then, all F"PDS repons must include lhe funding agency id\'1l\ification codes.

There are too many managemelll5ptcms. The contmcts personnel once again have to manually

review and enter data numerous times

Page 8. Section IV 113

NIST would suggest e"emually upgrading tu a whole l\C:Vo' sy.'tem. The CSTARS system does

OOt compare to others on tile market.