DATA ACT

Data Standards 

Established, but More 

Complete and Timely 

Guidance Is Needed 

to Ensure Effective 

Implementation

Report to Congressional Committees

January 2016

GAO-16-261

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-261, a report to 

congressional committees

January 2016

DATA ACT

Data Standards Established, but More Complete and 

Timely Guidance Is Needed to Ensure Effective 

Implementation

Why GAO Did This Study

The DATA Act directed OMB and 

Treasury to establish government-wide 

data standards by May 2015 to 

improve the transparency and quality 

of federal spending data. Agencies 

must begin reporting spending data in 

accordance with these standards by 

May 2017 and must publicly post 

spending data in machine-readable 

formats by May 2018. Consistent with 

GAO’s mandate under the act, this 

report is part of a series of products 

that GAO will provide to the Congress 

as DATA Act implementation 

proceeds.

This report (1) identifies steps taken by 

OMB and Treasury to standardize data 

element definitions and the extent to 

which those definitions are consistent 

with leading practices or face 

challenges that could affect data 

quality; (2) reviews efforts by OMB and 

Treasury to provide agencies with 

technical implementation guidance and 

related challenges; and (3) examines 

the implementation status of selected 

federal agencies. GAO analyzed data 

standards against leading practices; 

reviewed key implementation 

documents, technical specifications, 

and applicable guidance; and 

interviewed staff at OMB, Treasury, 

and other selected agencies.

What GAO Recommends

GAO recommends that OMB and 

Treasury (1) provide agencies with 

clarifications to address potential 

quality issues with the definitions, and 

(2) take steps to align the release of 

finalized technical guidance and the 

broker service with agency 

implementation time frames. OMB and 

Treasury generally concurred with our 

recommendations.

What GAO Found

As required by the Digital Accountability and Transparency Act of 2014 (DATA 

Act), the Office of Management and Budget (OMB) and the Department of the 

Treasury (Treasury) issued definitions for 57 federal spending data elements.

GAO found that most definitions adhered to leading practices derived from 

international standards for formulating data definitions. Specifically, 12 of the 57 

definitions met all 13 leading practices and none met fewer than 9. However, 

GAO found several definitions that could lead to inconsistent reporting. For 

example, as shown in the figure below, the Primary Place of Performance

definitions’ inclusion of the word “predominant“ leaves much open to 

interpretation. Without more interpretive clarification, agencies run the risk of 

reporting data that cannot be aggregated government-wide.

Example of Data Element Definitions That Could Be Interpreted in a Variety of Ways

OMB and Treasury addressed some of GAO’s earlier concerns on draft technical 

guidance for implementing data standards. However, final technical guidance has 

not been issued, which could impede agency implementation. While OMB and 

Treasury have released interim versions of technical guidance, they have not yet 

released final guidance to provide a stable base for agency implementation. They 

also are developing an intermediary service (“broker”) to standardize and validate 

agency data submissions. GAO’s review of selected implementation plans found 

that agencies need the technical guidance and the intermediary service to be 

finalized before they can develop detailed agency-level plans. If this guidance is 

not aligned with agency implementation timelines, agencies may delay taking key 

steps or need to revise existing plans once final technical guidance is released,

thereby hindering their ability to meet DATA Act requirements and timelines. 

GAO found that the three agencies it reviewed—the Departments of Agriculture

and Health and Human Services, as well as the Corporation for National and 

Community Service—have formed internal teams and are inventorying their data

and assessing any needed changes to policies, processes, and technology to 

implement the DATA Act.

View GAO-16-261. For more information, 

contact Michelle Sager at (202) 512-6806 or 

sagerm@gao.gov.
Page i GAO-16-261 Data Standards

Letter 1

Background 4

OMB and Treasury Established Government-wide Data 

Standards, but More Remains to Be Done to Ensure Consistent 

and Comparable Reporting of Federal Spending Data 8

OMB and Treasury Addressed Initial Challenges with the 

Technical Schema, but the Lack of Finalized Technical 

Guidance Could Impede Agency Implementation 18

Selected Agencies Have Taken Initial Steps to Implement Data 

Standards 22

Conclusions 24

Recommendations for Executive Action 25

Agency Comments and Our Evaluation 25

Appendix I Objectives, Scope, and Methodology 30

Appendix II Status of GAO’s Open Recommendations and Matters for 

Congressional Consideration Related to the DATA Act 34

Appendix III Definitions of Issued Data Elements 37

Appendix IV Comments from the Office of Management and Budget 42

Appendix V Comments from the Department of Treasury 46

Appendix VI Staff Acknowledgments 48

Contents
Page ii GAO-16-261 Data Standards

Tables

Table 1: OMB’s and Treasury’s 8-Step Implementation Plan for 

Agencies 7

Table 2: DATA Act Data Element Definitions’ Adherence to the 

International Organization for Standardization’s Leading 

Practices for Formulating Data Definitions 12

Table 3: Status of DATA Act Implementation for Three Selected 

Agencies 23

Table 4: Criteria for Agency Selection 32

Figures

Figure 1: The 57 DATA Act Standardized Data Elements, 

Grouped by Type 10

Figure 2: Current Definitions for Primary Place of Performance

Data Elements Could Be Interpreted in a Variety of Ways 16
Page iii GAO-16-261 Data Standards

Abbreviations

CNCS Corporation for National and Community Service

DATA Act Digital Accountability and Transparency Act of 2014

ERP enterprise resource planning

FFATA Federal Funding Accountability and Transparency Act of

2006

HHS Department of Health and Human Services

ISO International Organization for Standardization

OMB Office of Management and Budget

SAO senior accountable official

SBA Small Business Administration

SGL U.S. Government Standard General Ledger

Treasury Department of the Treasury

USDA United States Department of Agriculture

XBRL extensible business reporting language

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

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

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

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

necessary if you wish to reproduce this material separately.
Page 1 GAO-16-261 Data Standards

441 G St. N.W.

Washington, DC 20548

January 29, 2016

Congressional Committees:

The federal government spends more than $3.5 trillion annually; however, 

tracking this money can be difficult because spending data are often 

incomplete or inaccurate. The Digital Accountability and Transparency 

Act of 2014 (DATA Act) holds considerable promise for shedding more 

light on how federal funds are spent.1 To improve the transparency and 

quality of the federal spending data made available to the public, the 

DATA Act directs the Office of Management and Budget (OMB) and the 

Department of the Treasury (Treasury) to establish government-wide data 

standards that include common data elements for reporting financial and 

payment information by May 2015. In general, the act requires agencies 

to begin reporting financial spending data using these standards by May 

2017 and publicly post spending data in machine-readable formats by 

May 2018. 

It is critical that agencies use government-wide standards to report 

spending data in order to help ensure the quality and usefulness of the 

resulting information. We have previously reported on persistent 

challenges involving the quality and completeness of the spending data 

that federal agencies report to USAspending.gov, a free, publicly 

accessible website containing data on federal awards and subawards.2

To address these problems, we recommended that the Director of OMB 

(1) clarify guidance on reporting award information and maintaining 

supporting records and (2) develop and implement oversight processes to 

ensure that awards data are consistent with agency records. OMB 

generally agreed with our recommendations and we will continue to 

monitor OMB’s implementation of them.

 1

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

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

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

added to FFATA by the DATA Act as DATA Act requirements.

2

GAO, Data Transparency: Oversight Needed to Address Underreporting and 

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

2014). 

Letter
Page 2 GAO-16-261 Data Standards

This report is the latest GAO work in response to a statutory provision to 

review DATA Act implementation.3 This report (1) identifies steps taken 

by OMB and Treasury to establish government-wide data element 

definitions and the extent to which those definitions are consistent with 

leading practices or face challenges that could affect data quality; (2) 

reviews efforts by OMB and Treasury to provide agencies with technical 

implementation guidance to standardize how data are collected and 

reported and related challenges; and (3) examines the status of selected 

federal agencies’ progress in meeting DATA Act requirements.

To assess the extent to which OMB and Treasury established data 

standards that are consistent with leading practices, we analyzed OMB’s

and Treasury’s 57 standardized data element definitions using criteria 

established under the DATA Act4 as well as leading practices for wellconstructed data definitions derived from standards developed by the 

International Organization for Standardization (ISO).5 To assess OMB’s 

and Treasury’s development of a technical schema that specifies the 

format, structure, tagging, and transmission of each data element to allow 

consistency and comparability, we reviewed and analyzed differences 

 3

Previous work includes: GAO, DATA Act: Progress Made in Initial Implementation but 

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

July 29, 2015) and GAO, Federal Data Transparency: Effective Implementation of the 

DATA Act Would Help Address Government-wide Management Challenges and Improve 

Oversight, GAO-15-241T (Washington, D.C.: Dec. 3, 2014).

4

The DATA Act requires that data standards comply with certain requirements to the 

extent reasonable and practicable. Those requirements include that data standards (1) 

incorporate widely-accepted common data elements, such as those developed by 

international standards-setting bodies, federal agencies with authority over contracting 

and financial assistance, and accounting standards organizations; and (2) produce 

consistent and comparable data. FFATA, § 4(b)(1), (6).

5

The International Organization for Standardization (ISO) is an independent, 

nongovernmental membership organization and the world’s largest developer of voluntary 

international standards. It has published more than 20,500 international standards 

covering a wide range of industries including technology, agriculture, and health care. For 

the purposes of this report, we refer to leading practices derived from the ISO standards 

as ISO leading practices. For access to the ISO leading practices for the formulation of 

data definitions, published July 15, 2004 see: 

http://standards.iso.org/ittf/PubliclyAvailableStandards/c035346_ISO_IEC_11179-

4_2004(E).zip. ©ISO: This material is reproduced from ISO/IEC 11179-4:2004(E) with 

permission of the American National Standards Institute (ANSI) on behalf of the 

International Organization for Standardization. All rights reserved.
Page 3 GAO-16-261 Data Standards

between version 0.2, version 0.5, and version 0.6 of the schema.6 We 

reviewed applicable agency guidance and documentation related to the 

data standards and technical schema on OMB’s and Treasury’s websites.

We also interviewed knowledgeable agency officials about their 

standards-setting and technical schema development processes. To 

obtain information on the status of agencies’ efforts to meet their DATA 

Act requirements and any challenges they faced meeting those 

requirements, we selected three agencies—the Department of Health and 

Human Services (HHS), the Department of Agriculture (USDA), and the 

Corporation for National and Community Service (CNCS). We identified 

these agencies using a three-step selection process that considered (1) 

whether the agency was in compliance with existing federal requirements 

for federal financial management systems; (2) the type of federal funding

provided (such as grants, loans, and contracts); and (3) status as a 

Federal Shared Service Provider for financial management.7 The selected 

agencies represent a mix of these characteristics to illustrate a range of 

conditions under which agencies are implementing the DATA Act. We 

reviewed the selected agencies’ implementation plans and related project 

plans and interviewed agency officials responsible for DATA Act 

implementation.

8 Additional details regarding our objectives, scope, and 

methodology are provided in appendix I.

We conducted this performance audit from May 2015 to January 2016 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

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

 6

OMB and Treasury released version 0.1 of the DATA Act schema on March 30, 2015, 

and subsequently released additional versions in the following months: version 0.2 in May, 

version 0.5 in July, and version 0.6 in October. Versions 0.3 and 0.4 were not publicly 

released. On December 31, 2015, OMB and Treasury released version 0.7, which we 

have yet to fully review. 

7

The full list of agencies we selected from included the 24 CFO Act agencies, as well as 

smaller agencies that already reported spending data to USAspending.gov under FFATA.

8

Office of Management and Budget, Increasing Transparency of Federal Spending by 

Making Federal Spending Data Accessible, Searchable, and Reliable, OMB Memorandum 

M-15-12 (May 8, 2015). Among other things, this memorandum directs agencies to 

designate an agency point of contact or senior accountable official who is a senior official

in the agency with the ability to coordinate across multiple communities and federal lines 

of business.
Page 4 GAO-16-261 Data Standards

the evidence obtained provides a reasonable basis for our findings and 

conclusions on our audit objectives.

During the last decade, Congress and the administration have taken

several steps to improve the transparency of federal spending data. In 

2006, Congress passed and the President signed the Federal Funding 

Accountability and Transparency Act of 2006 (FFATA) to increase the 

transparency and accountability of federal contracts and financial

assistance awards. Among other things, FFATA required OMB to 

establish USAspending.gov, containing obligational data on federal 

awards and subawards,

9 which was launched in December 2007. One of 

the stated purposes of the DATA Act is to expand FFATA to include direct 

federal agency expenditures and link contract, loan, and grant spending 

information to federal programs so that taxpayers and policy makers can 

more effectively track federal spending.

Reporting throughout the federal spending cycle. Full and effective 

implementation of the DATA Act will allow funds to be tracked at multiple 

points in the federal spending lifecycle. For example, once fully 

implemented, amounts appropriated, obligated, and subsequently 

outlayed for a particular program activity would all be publicly available on 

USAspending.gov or a successor website.10 These additional federal 

spending cycle data on appropriations, obligations, and outlays will 

provide more transparency on federal awards. USAspending.gov 

provides information on award amounts for grants, contracts, and other 

types of information, but the only information currently available is data on 

federal award obligations.

 9

An obligation is a definite commitment that creates a legal liability of the government for 

the payment of goods and services ordered or received, or a legal duty on the part of the 

United States that could mature into a legal liability by virtue of actions on the part of the 

other party beyond the control of the United States. An agency incurs an obligation, for 

example, when it places an order, signs a contract, awards a grant, purchases a service, 

or takes other actions that required the government to make payments to the public or 

from one government account to another.

10An appropriation is budget authority to incur obligations and to make payments from the 

Treasury for specified purposes, such as an appropriations act. Outlays are amounts paid 

by federal agencies, by cash or cash equivalent, to liquidate government obligations.

Background

The DATA Act Expanded 

the Required Reporting of 

Federal Spending Data 

under FFATA
Page 5 GAO-16-261 Data Standards

The DATA Act represents a significant change to the types of data 

reported by requiring additional budget and financial information, which, 

to date, has not been reported on USAspending.gov. The act requires 

budget and financial information to be reported on a monthly basis if 

practicable, but not less than quarterly. However, OMB’s May 2015 

guidance directs agencies to continue reporting on awards data at least 

bi-weekly. To cover appropriations and outlays in addition to obligations, 

OMB and Treasury officials noted that data will need to be pulled from 

budgetary and financial systems in addition to the multiple contract and 

assistance systems currently used. It is essential that all of this data be 

appropriately linked to achieve the full potential for users of this data 

inside and outside of government.

Reporting on more types of federal spending. The DATA Act requires 

reporting on almost all types of federal spending. Currently, 

USAspending.gov reports data on federal awards including grants, 

contracts, and loans. Under the DATA Act, however, more budget and 

financial information will be available that should allow users of the data 

to organize and analyze the data in ways that are not currently possible. 

Some of these new types of spending information include:

• Budget and financial information on the different types of goods and 

services purchased by the federal government, such as personnel 

compensation, will be reported in the aggregate.

• Budget and financial information from financial arrangements of the 

federal government, such as public-private partnerships, interagency 

agreements, and user charges, will also be reported. 

• As part of their guidance to agencies on DATA Act implementation, 

OMB lowered the threshold at which agencies must report data on 

financial assistance and procurement prime awards from $25,000 or 

greater to those awards greater than the micro-purchase threshold, 

which is currently $3,500.

11

Improving data quality. Our prior work found that unclear guidance and 

weaknesses in executive branch oversight contributed to persistent 

challenges with data on USAspending.gov. These challenges relate to the 

 11OMB Memorandum M-15-12. 48 C.F.R. § 2.101. For certain acquisitions, such as 

acquisitions of construction subject to the Davis-Bacon Act, the micro-purchase threshold 

is set at a higher or lower dollar amount.
Page 6 GAO-16-261 Data Standards

quality and completeness of data submitted by federal agencies. For 

example, in 2010, we reported that USAspending.gov did not include 

information on awards from 15 programs at 9 agencies for fiscal year 

2008.12 In that report we also reviewed a sample of 100 awards on the 

website and found that each award had at least one data error. In June 

2014, we reported that roughly $619 billion in assistance awards were not 

properly reported in fiscal year 2012.13 In addition, we found that few 

reported awards—between 2 and 7 percent—contained information that 

was fully consistent with agency records for all 21 data elements we 

examined. A factor that contributed to this error rate was the lack of 

guidance on how to interpret some data elements including award 

description. See appendix II for more information on our 

recommendations related to these findings and OMB’s and Treasury’s 

actions to date.

The DATA Act identifies the improvement of data quality as one of its 

purposes. Toward that end, the act requires that inspectors general 

conduct reviews of data samples submitted by their respective agency 

and subsequently assess and report on the data’s completeness, 

timeliness, quality, and accuracy. We are required to review these reports 

and then assess and compare the completeness, timeliness, quality, and 

accuracy of the data across the federal government.

OMB and Treasury issued initial guidance to federal agencies in May 

2015 on reporting requirements pursuant to FFATA as well as the new 

requirements that agencies must employ pursuant to the DATA Act.14 The 

guidance also directs agencies to

• implement data definition standards for the collection and reporting of 

agency-level and award-level data by May 9, 2017;

 12GAO, Electronic Government: Implementation of the Federal Funding Accountability and 

Transparency Act of 2006, GAO-10-365 (Washington, D.C.: Mar. 12, 2010).

13GAO-14-476.

14OMB Memorandum M-15-12.

OMB and Treasury Issued 

Guidance to Help 

Agencies Carry Out DATA 

Act Reporting 

Requirements
Page 7 GAO-16-261 Data Standards

• implement a standard data exchange format for providing data to 

Treasury to be displayed on USAspending.gov or a successor site; 

and

• link agency financial systems with award systems by continuing the 

use of specified unique identification numbers for financial assistance 

awards and contracts.

OMB asked agencies to submit DATA Act implementation plans in 

September 2015, concurrent with the fiscal year 2017 budget request.

According to OMB staff, as of December 2015, all 24 CFO Act agencies 

as well as 27 smaller federal agencies have submitted implementation 

plans. OMB required the plans to include: (1) a timeline of tasks and 

steps toward implementing the requirements of this guidance; (2) an 

estimate of costs to implement these tasks and steps; (3) a detailed 

narrative that explains the required steps, identifies the underlying 

assumptions, and outlines the potential difficulties and risks to 

successfully implement the plan; and (4) a detailed project plan that 

agencies will develop over time.

Additionally, OMB and Treasury issued a DATA Act Implementation 

Playbook in June 2015, which recommends eight key steps for agencies 

to fulfill their requirements under the DATA Act (see table 1).

Table 1: OMB’s and Treasury’s 8-Step Implementation Plan for Agencies

Steps for agencies Timeline for completion

Organize a DATA Act team and appoint a senior accountable official Spring 2015

Review DATA Act elements Spring 2015

Inventory data and associated business processes February 2015-September 2015

Plan for required changes to systems and business processes and develop an 

implementation plan

March 2015-September 2015

Execute the broker service: implement system changes and extract data October 2015-February 2016

Test broker outputs to ensure data are valid October 2015-February 2016

Update systems: implement other system changes (e.g., establish linkages between 

program and financial data, capture any new data)

October 2015-February 2017

Submit data March 2016-May 9, 2017

Source: GAO analysis of OMB’s and Treasury’s DATA Act Implementation Playbook (June 2015). | GAO-16-261

To support this effort, OMB and Treasury issued guidance to help 

agencies develop the plans and hosted workshops and conference calls 

to address agency questions.
Page 8 GAO-16-261 Data Standards

The DATA Act requires OMB and Treasury to establish government-wide 

financial data standards for any federal funds made available to or 

expended by federal agencies and recipients of federal funds. The 

specific items to be reported under the act are generally referred to as 

data elements. The overall data standardization effort consists of two 

distinct, but related, components: (1) establishing definitions which 

describe what is included in each data element with the aim of ensuring 

that information will be consistent and comparable, and (2) creating a 

data exchange standard with technical specifications which describe the 

format, structure, tagging, and transmission of each data element. The 

data exchange standard is also intended to depict the relationships 

between standardized data elements.

On May 8, 2015, a year after the passage of the DATA Act, OMB and 

Treasury issued the first 15 standardized data element definitions, 

including definitions for 8 new elements introduced by the DATA Act. 

From June through August 2015, OMB and Treasury released an 

additional 42 standardized data element definitions for reporting under 

FFATA, as amended by the DATA Act. During this time, OMB and 

Treasury released data element definitions in stages and opened a 3-

week feedback period for federal and nonfederal stakeholders to provide 

OMB and Treasury 

Established 

Government-wide 

Data Standards, but 

More Remains to Be 

Done to Ensure 

Consistent and 

Comparable 

Reporting of Federal 

Spending Data

OMB and Treasury Issued 

57 Standardized Data 

Element Definitions for 

Reporting Federal 

Spending Data
Page 9 GAO-16-261 Data Standards

public input on the definitions before they were issued.15 During this 

period we separately met with OMB and Treasury staff several times to 

share our views and identify issues and concerns with proposed 

definitions. See figure 1 for a listing of the 57 standardized data elements 

grouped by type. See appendix III for the definitions of each of the data 

elements.

 15OMB and Treasury used their Federal Spending Transparency website to solicit public 

input on proposed data element definitions. These discussions can be found at: 

https://github.com/fedspendingtransparency/fedspendingtransparency.github.io/issues. 
Page 10 GAO-16-261 Data Standards

Figure 1: The 57 DATA Act Standardized Data Elements, Grouped by Type
Page 11 GAO-16-261 Data Standards

The DATA Act requires that data standards—to the extent reasonable 

and practicable—incorporate widely-accepted common data elements, 

such as those developed by international standards-setting bodies, 

federal agencies with authority over contracting and financial assistance, 

and accounting standards organizations.16 Incorporating leading practices 

from international standards organizations offers one way to help reduce 

uncertainty and confusion when reporting and interpreting data standards. 

Developing a well-crafted data element definition is one key component to 

ensuring that a data standard produces consistent and comparable 

information. The ISO, a standards-setting body composed of international 

experts in various fields of study, has developed 13 leading practices for 

formulating data definitions for the purposes of specifying, describing, 

explaining, and clarifying the meaning of data.17 These practices include 

that definitions be precise and unambiguous, avoid circular reasoning, 

and be expressed without embedding definitions of other data or 

underlying concepts, among others.

We found that the 57 DATA Act data element definitions largely followed 

ISO leading practices for the formulation of data definitions. Specifically, 

12 data element definitions met all of the ISO leading practices and each 

of the remaining 45 definitions met no fewer than 9 leading practices, 

meaning that even the lowest-rated data elements in our review adhered 

to almost 70 percent of the ISO leading practices.18 We also found 

variation in which of the leading practices each definition satisfied. For 

example, our analysis found that all 57 definitions followed the leading 

practices of avoiding circular reasoning and being stated as a descriptive 

phrase or sentence, whereas 38 of the 57 were determined to be 

sufficiently precise and unambiguous. Table 2 provides a summary of our 

findings applying the ISO leading practices for formulating data definitions 

 16FFATA, § 4(b)(1).

17©ISO: This material is reproduced from ISO/IEC 11179-4:2004(E) with permission of the 

American National Standards Institute (ANSI) on behalf of the International Organization 

for Standardization. All rights reserved.

18The 12 data element definitions that met all 13 ISO leading practices are: Action Date, 

Award Identification Number, Awarding Agency Name, Awarding Sub Tier Agency Code, 

Awarding Sub Tier Agency Name, Catalog of Federal Domestic Assistance Number, 

Catalog of Federal Domestic Assistance Title, North American Industrial Classification 

System Code, Parent Award Identification Number, Period of Performance Start Date, 

Potential Total Value of Award, and Program Activity.

Data Element Definitions 

Generally Followed 

Leading Practices, but 

Exceptions Could Result 

in Inconsistent Reporting if 

Not Addressed
Page 12 GAO-16-261 Data Standards

to the definitions developed by OMB and Treasury as part of DATA Act 

implementation.

Table 2: DATA Act Data Element Definitions’ Adherence to the International 

Organization for Standardization’s Leading Practices for Formulating Data 

Definitions

ISO leading practicea

Number of data 

element definitions 

that adhere to leading 

practice (out of 57)

Avoid circular reasoning 57

Be appropriate for the type of metadata item being defined 57

Be stated as a descriptive phrase or sentence(s) 57

State what the concept is, not only what it is not 57

Be stated in the singular 54

Be concise 53

Be able to stand alone 52

Contain only commonly understood abbreviations 52

Be expressed without embedding definitions of other data or 

underlying concepts

50

State the essential meaning of the concept 49

Use the same terminology and consistent logical structure for 

related definitions

49

Be expressed without embedding rationale, functional usage, or 

procedural information

39

Be precise and unambiguous 38

Source: GAO analysis and application of ISO leading practices and standardized DATA Act data element definitions. | GAO-16-261

a

©ISO. This material is reproduced from ISO/IEC 11179-4:2004(E) with permission of the American 

National Standards Institute (ANSI) on behalf of the International Organization for Standardization. All 

rights reserved.

Although most of the definitions generally adhered to ISO leading 

practices, examples where data elements did not do so raise potential 

concerns regarding an increased risk that agencies may not apply the 

definitions consistently, thus affecting the comparability of reported data. 

Data element definitions that are imprecise or ambiguous may allow for 

more than one interpretation by agency staff collecting, compiling, and 

reporting on these data and thus could result in inconsistent and 

potentially misleading reporting when aggregated across government or 

compared between agencies. For example, OMB and Treasury defined 

Award Description as “a brief description of the purpose of the award.” In 

our previous work on the data quality of USAspending.gov, we identified 

challenges with the Award Description data element, citing the wide range 
Page 13 GAO-16-261 Data Standards

of information that agencies report as the description or purpose.19

Specifically, we found that agencies routinely provided information for this 

data element using shorthand descriptions, acronyms, or terminology that 

could only be understood by officials at the agency that made the award. 

For example, in our 2010 report we found that the description for one 

contract we reviewed read “4506135384!DUMMY LOA,” while the award 

records indicated that the award was for the purchase of metal pipes. 

Another was described as “Cont Renewals All Types,” while the award 

records showed the contract was for an apartment building. This lack of 

basic clarity would make the data element difficult for others outside the 

agency to understand and would also limit the ability to meaningfully 

aggregate or compare this data across the federal government.

We made recommendations to OMB in 2010 and 2014 and to Treasury in 

2014 to improve the accuracy and completeness of Award Description, 

which have yet to be addressed. At that time, Treasury officials neither 

agreed nor disagreed with our recommendations, while OMB staff 

generally agreed with them stating that they were consistent with actions 

required under the DATA Act. These OMB staff said while they would 

consider interim steps to improve data quality, they did not want to inhibit 

agency efforts to work toward implementation of the act. Appendix II 

provides more information on the status of these recommendations. In 

subsequent discussions, OMB staff stated that they are hesitant to make 

substantial changes to the reporting of Award Description, which focuses 

on the purpose of a federal award, before additional progress is made on 

the related and more complex issue of how to ascribe spending data to a 

specific government program. However, it is unclear why this should 

prevent them from taking steps such as providing agencies with guidance 

on how to avoid excessive jargon, provide a specific level of detail, or 

develop a standardized taxonomy of appropriate responses.

While the data quality concerns presented by the definition of Award 

Description are relatively straightforward to address, other definitions that 

we found to be imprecise and ambiguous present greater challenges due 

to long-standing differences in reporting across agencies and among the 

federal grant, procurement, and loan communities. An example of this is 

the four data elements that OMB and Treasury have issued that 

 19GAO-14-476 and GAO-10-365.
Page 14 GAO-16-261 Data Standards

collectively represent the concept of Primary Place of Performance.

20 The 

location or place of performance of specific grant, contract, or other 

federal spending has long been a data element collected by agencies. 

However, in the past, agencies have taken varied approaches to reporting 

place of performance information—sometimes describing where the 

funded activity takes place, sometimes the recipient of the product or 

activity, or sometimes the location of the administrative headquarters of 

the provider or a sub-entity. The definitions issued by OMB and Treasury 

standardize some of the mechanics of what Primary Place of 

Performance covers, such as city, county, state, and ZIP+4 codes. In 

addition, OMB staff told us that, by using the words “where the 

predominant performance of the award will be accomplished” the 

definitions are intended to focus on where the majority of the activity 

actually takes place rather than, for example, the location of the ultimate 

recipient of the product or service funded by federal spending.

However, OMB’s and Treasury’s definitions still leave room for differing 

interpretations that could result in agencies capturing and reporting this 

information differently. For example, OMB staff told us that they interpret 

the term “predominant performance” to mean “more than half,” but this 

clarification is not contained in the definition itself, nor in the 

accompanying white paper that was issued with the data element 

definitions. Other questions exist regarding the appropriate unit of 

analysis for making such a determination. For example, it is unclear if 

“where the predominant performance of the award will be accomplished”

is determined by the amount of time spent in a particular location when 

carrying out the award or by some other metric such as number of staff 

deployed or the amount of financial resources expended in a particular 

location. The standardized definitions for Primary Place of Performance

 20The four Primary Place of Performance data elements are defined as follows: (1) 

Primary Place of Performance Address: The address where the predominant performance 

of the award will be accomplished. The address is made up of six components: Address 

Lines 1 and 2, City, County, State Code, and ZIP+4 or Postal Code; (2) Primary Place of 

Performance Congressional District: U.S. Congressional district where the predominant 

performance of the award will be accomplished. This data element will be derived from the 

Primary Place of Performance Address; (3) Primary Place of Performance Country Code: 

Country code where the predominant performance of the award will be accomplished; and

(4) Primary Place of Performance Country Name: Name of the country represented by the 

country code where the predominant performance of the award will be accomplished. 

Although OMB and Treasury treat these as four discrete data elements, for the purposes 

of our discussion in this report we refer to them collectively as Primary Place of 

Performance.
Page 15 GAO-16-261 Data Standards

do not address this level of detail and according to OMB staff they have 

not issued guidance or other resources, such as a FAQ document, to help 

agencies operationalize this concept in a consistent and comparable way.

Another concern involves how to assign a value for Primary Place of 

Performance when the activity being described does not readily lend itself 

to a discrete geospatial location (such as a consulting service provided in 

many locations) or if it spans multiple locations (such as a road traversing

multiple counties or states). One approach that has been previously used 

for reporting the location of federal spending for road projects on 

USAspending.gov is to assign the spending to the county or state capitol 

in the jurisdiction where the majority of the road was constructed. OMB 

staff told us that they would likely follow such an approach when reporting 

on Primary Place of Performance using the newly standardized definition 

in the future. While this may be potentially misleading in some situations, 

in the absence of a clearly better alternative it is critical that the particular 

decision rules OMB decides to follow are documented and clearly 

communicated to agencies providing this data as well as end-users. 

Figure 2 provides a notional illustration of some of the different places of 

performance that agencies could report for federally funded road projects 

based on the current definitions of these data elements.
Page 16 GAO-16-261 Data Standards

Figure 2: Current Definitions for Primary Place of Performance Data Elements Could Be Interpreted in a Variety of Ways

Note: OMB and Treasury issued four standardized data elements to encompass the concept of 

Primary Place of Performance. For the purposes of this illustration, we present Primary Place of 

Performance as a single concept composed of these data elements.

Despite the potential for multiple interpretations of what should be 

reported for Primary Place of Performance, OMB staff told us that federal 

agencies have not raised this as a significant reporting challenge.

However, feedback OMB and Treasury received from both federal and 

nonfederal stakeholders identified a number of concerns with these 

definitions including the need to more clearly define what is meant by 

“primary” place of performance and how to interpret the word 

“performance” for this definition. In responding to this feedback, OMB and 

Treasury acknowledged the difficulty of addressing stakeholder concerns 

through a single data element and that in the future, as part of their plans 

to adopt a more formal data governance structure, they expect to identify 
Page 17 GAO-16-261 Data Standards

and standardize other location-related data elements to address other 

needs.

In some cases OMB and Treasury will need to take additional steps to 

make data standards consistent and comparable for federal and 

nonfederal entities. For example, OMB and Treasury standardized the 

definition of Program Activity as required by the DATA Act and we found 

that this definition adhered to all 13 ISO leading practices. However, 

concerns still remain regarding the use of this data element. For example, 

OMB’s and Treasury’s guidance on Program Activity acknowledges that 

program activities can change from one year to the next and that Program 

Activity does not necessarily match “programs” as specified in the GPRA 

Modernization Act of 2010 or the Catalog of Federal Domestic 

Assistance. In responding to this guidance, officials at USDA said that 

when program activities change it is difficult to make comparisons of 

federal spending over time.

Moreover, USDA officials noted that more guidance is needed to ensure 

that the public can accurately interpret Program Activity compared to the 

other common representations of federal programs. In our July 2015 

testimony on DATA Act implementation, we reported that OMB and 

Treasury will need to build on the program activity structure and provide 

agencies with guidance if they are to meet one of the stated purposes of 

the DATA Act to link federal contract, loan, and grant spending 

information to federal programs to enable taxpayers and policy makers to 

track federal spending more effectively.21 In that testimony, we made a

recommendation that OMB accelerate efforts to develop a federal 

program inventory to ensure that federal program spending data are 

provided to the public in a transparent, useful, and timely manner. During 

the hearing, an OMB official testified that, because the staff that would be 

involved in working on the program inventories is heavily involved in 

DATA Act implementation, he would not expect an update of the program 

inventories to happen before May 2017.

Much remains to be done to effectively implement standard data element 

definitions across the federal government in a consistent and comparable 

way for reporting purposes. OMB and Treasury told us that they are 

 21GAO-15-752T.

The Data Element 

Definition for Program 

Activity Adheres to 

Leading Practices; 

However, More Guidance 

Is Needed to Ensure 

Program-Related Data Are 

Consistent and 

Comparable
Page 18 GAO-16-261 Data Standards

making policy decisions and developing guidance to help agencies with 

implementing data standards. They expect to issue this guidance in 

spring 2016, and we will review it at that time. Consequently, many issues 

remain unanswered regarding the extent to which agencies may need to 

change their policies, processes, and systems in order to report their 

financial data in compliance with the act. A senior HHS official told us that 

they have communicated to OMB and Treasury that in the absence of 

detailed guidance related to the policy, process, and technology changes 

that accompany the data element definitions, agencies cannot develop 

effective implementation plans or appropriately commit the necessary 

resources toward implementing the DATA Act because implementation 

efforts and timelines are highly dependent on this information. Agencies 

must begin reporting data using the data definitions established under the 

DATA Act by 2017. It remains uncertain the extent to which these data 

will be consistent and comparable if OMB and Treasury do not address 

concerns with the quality of data definitions.

The DATA Act calls for OMB and Treasury to establish government-wide 

data standards, to the extent reasonable and practicable, that produce 

consistent and comparable data available in machine-readable formats.22

Treasury has taken the lead in drafting a technical schema intended to 

standardize the way financial assistance awards, contracts, and other 

financial data will be collected and reported under the DATA Act.23

Toward that end, the technical schema describes the standard format for 

data elements including their description, type, and length. In July 2015, 

we identified several potential concerns with version 0.2 of the schema, 

including that the schema might not prevent inconsistent reporting 

because it allowed alphabetic characters to be entered into a data field 

that should only accept numeric data.24 We also noted that the schema 

did not identify a computer markup language that agencies can use for 

communicating financial data standards. Identification of such a language 

provides standards for annotating or tagging information so that data can 

 22FFATA, §§ 2(c)(7), 4(b)(3), (6).

23OMB has taken the lead to standardize data element definitions, while Treasury is 

leading efforts to develop the technical schema and intermediary service (referred to as 

the data “broker”) to extract and validate agency data submissions. 

24GAO-15-752T.

OMB and Treasury 

Addressed Initial 

Challenges with the 

Technical Schema, 

but the Lack of 

Finalized Technical 

Guidance Could 

Impede Agency 

Implementation
Page 19 GAO-16-261 Data Standards

be transmitted over the Internet and can be readily interpreted by a 

variety of computer systems.

OMB and Treasury addressed several of the concerns we raised in 

version 0.6 of the DATA Act schema issued in October 2015. For 

example, version 0.6 of the schema addressed inconsistencies between 

machine-readable and human-readable documentation and simplified the 

schema so that data elements, names, and definitions are consistent 

across all award types including grants, loans, and contracts. According 

to Treasury officials, subsequent versions of the schema will include 

additional information about complex data types and introduce extensible 

business reporting language (XBRL) formats in preparation for version 

1.0.25 Treasury planned to issue version 1.0 by December 31, 2015, 

which it said would provide a more stable base to help agencies 

understand how to map their financial and award information to adhere to 

DATA Act requirements. However, instead of releasing version 1.0 as 

planned, they released another interim version—version 0.7. According to 

Treasury, this version incorporates additional financial data elements and 

attributes that are intended to support more accurate and detailed 

financial and budgetary accounting information.

Given the importance of having a largely stable schema to serve as the 

foundation for developing subsequent technical processes at the agency 

level, any significant delay in releasing version 1.0 of the schema will

likely have consequences for timely implementation of the act. Treasury 

officials told us they are not prepared to provide a time frame for

completion of version 1.0. As previously mentioned, OMB’s and 

Treasury’s DATA Act Implementation Playbook outlines eight specific 

steps and timelines for implementing the DATA Act at the agency level. 

However, in some cases guidance that would help agencies carry out 

these steps has not been provided in time to coincide with when the 

agency was expected to carry out key activities outlined in the DATA Act 

Implementation Playbook. For example, step 3 of the 8-step plan calls for 

agencies to inventory agency data and associated business processes 

from February to September 2015 to identify where there are gaps in the 

data that are collected. OMB and Treasury provided technical tools 

including a template to help agencies inventory their financial and awards 

 25XBRL is an international standard for digital reporting of financial, performance, risk and 

compliance information, although it is also used for many other types of reporting.
Page 20 GAO-16-261 Data Standards

data to identify any gaps that could impede standardization. However, a 

stable DATA Act schema that specifies the form and content the data 

should be reported in was not available to agencies to help them fully

carry out this step.

Corporation for National and Community Service (CNCS) officials told us 

that because operational details for how data are to be exchanged have 

not yet been finalized, the agency has not taken steps to map agency 

financial and awards data to the schema. Treasury officials told us, that 

because they are using an iterative approach to technical implementation, 

they have not finalized an architecture for the collection and 

dissemination of government-wide data that could provide agencies with 

a description of the various technology layers, interoperability and 

structures, and reporting languages that they will be expected to use 

beginning in May 2017. In the absence of a clear and consistent set of 

technical specifications, agency technical staff, enterprise resource 

planning (ERP) vendors,26 and others tasked with adapting Treasury’s 

schema to work with the financial and award management environment at 

individual federal agencies may delay plans to carry out key steps until 

the schema is finalized. Alternatively, if agencies decide to move ahead 

and then significant changes are subsequently made to the schema, 

agencies could incur additional costs to revise their systems and 

processes to conform to a later version.

In addition to the draft technical schema, Treasury is developing an 

intermediary service called a “broker” to standardize data formatting and 

assist reporting agencies in validating their data submissions before they 

are submitted to Treasury. As part of this effort, Treasury recently 

completed a limited-use pilot test of the broker service with the Small 

Business Administration (SBA) to test agency data submissions. Treasury 

has future plans to develop and test a broker prototype for contracts. The 

pilot demonstrated a broker prototype that could extract data from SBA’s 

grant and financial systems, perform data validation, and convert data to 

the DATA Act schema for submission to Treasury’s database. A Treasury 

official acknowledged, however, that it may be more difficult for larger or 

more complex agencies to extract their data and perform these necessary 

functions.

 26Enterprise resource planning (ERP) vendors provide an integrated suite of business 

applications to some federal agencies for financial management purposes. 
Page 21 GAO-16-261 Data Standards

In September 2015, Treasury posted the limited-use SBA broker 

prototype on GitHub, a public online collaboration website, so that 

agencies and the public could begin reviewing the broker prototype.27

Treasury also made a set of high-level conceptual models available to 

agencies on MAX.gov to help them understand how they might extract 

data from their own financial and award systems.28 Treasury told us that 

they plan to build and host a centralized broker service, but have not 

specified a time frame when it will be available. In addition, Treasury is 

exploring the option to allow agencies to use the Treasury broker service

locally to work within their own operational environments. According to 

these officials, agencies may also choose to work through ERP vendors 

who could develop commercial products that would be made available to 

agencies.

However, because the SBA broker prototype was primarily tested on 

grants, a broker prototype that extracts and validates data from other 

types of awards, such as contracts and loans, is still not available to 

agencies. Moreover, little is known about how the prototype would work 

with other forms of awards, which are often located in different systems 

and use different definitions. Agencies need this information to begin 

testing the broker using their own data so they can develop effective 

strategies for data submission within the time frame—October 2015 to 

February 2016—prescribed in the DATA Act Implementation Playbook. 

The prototype tested grants data from SBA’s award system which is 

already linked to SBA’s financial management system through unique 

award identifiers. It is not known whether and how the broker prototype 

would work for a number of agencies that have financial and award 

systems that are not yet linked. According to a Treasury official, most 

agencies have not established linkages between their financial and award 

systems.

 27GitHub is a web-based software repository hosting service. OMB and Treasury have 

established a DATA Act collaboration website on GitHub to obtain input on the 

development of data standards. This website can be found at

http://fedspendingtransparency.github.io.

28OMB hosts an online collaboration space on MAX.gov to provide executive branch 

agencies with updates and additional guidance on DATA Act implementation. This 

website, accessible only to executive branch agencies, can be found at 

https://community.max.gov/x/BYbyL .
Page 22 GAO-16-261 Data Standards

Our review of three selected agency implementation plans and interviews 

with agency officials indicates that agencies are waiting for technical 

guidance on the broker service so that they can begin to develop plans to 

extract data from their current systems and map it to the DATA Act 

schema. For example, CNCS’s implementation plan submitted to OMB in 

September of 2105 cites the lack of information about the broker as a 

significant challenge that could impede effective implementation of the 

data standards and new reporting requirements. As a result of this 

uncertainty, USDA officials told us that they decided to move ahead with 

the development of its own broker to compile and validate its data 

centrally and then forward it on to Treasury. Moreover, USDA officials 

noted that since much of Treasury’s technical guidance to date has 

focused on grants and cooperative agreements little is known about how 

the broker service would work with other financial assistance awards such 

as loans and insurance programs.

The three agencies in our review—the Corporation for National and 

Community Service (CNCS), the Department of Health and Human 

Services (HHS), and the Department of Agriculture (USDA)—have begun 

addressing the requirements of the DATA Act by forming DATA Act 

teams, participating in government-wide deliberations on data standards, 

developing an inventory of their data, identifying systems containing 

pertinent data and the associated business practices, and assessing the 

policy, process, and technology changes that may be needed for 

successful implementation. In addition to providing guidance in the DATA 

Act Implementation Playbook, OMB and Treasury have regularly engaged 

agency officials to address questions and concerns related to 

implementing data standards. This outreach has included monthly 

conference calls with agency senior accountable officials (SAO), posted 

office hours for agencies to obtain feedback on the implementation 

process and raise OMB’s and Treasury’s awareness regarding specific 

implementation challenges, and a biweekly digest that is distributed to 

SAOs to keep agency staff informed about recent and upcoming DATA 

Act activities. Table 3 provides additional information regarding the status 

of DATA Act implementation activities for these three agencies.

Selected Agencies 

Have Taken Initial 

Steps to Implement 

Data Standards
Page 23 GAO-16-261 Data Standards

Table 3: Status of DATA Act Implementation for Three Selected Agencies

DATA Act Implementation Playbook 8-

step plan for agency implementation 

(and time frames)

Implementation status at selected agencies as of December 2015

(Corporation for National and Community Service (CNCS), the Department of 

Agriculture (USDA), and the Department of Health and Human Services (HHS)) 

Step 1

Organize DATA Act teams and appoint a 

senior accountable official (SAO)

(Spring 2015)

All three selected agencies (HHS, USDA, and CNCS) have designated an SAO and 

established DATA Act implementation teams that are composed of representatives from 

budget, financial assistance, procurement, financial management, and 

systems/information technology communities.

Step 2

Review proposed data element definitions 

and participate in the data element 

standardization process

(Spring 2015)

Each selected agency also participated in the standardization process by providing 

ongoing feedback to the DATA Act Interagency Advisory Committee through their 

membership on various interagency councils such as the Award Committee for eGovernment, the Financial Assistance Committee for e-Government, the Budget Officers 

Advisory Council, and the Chief Financial Officers Council.a

Step 3

Inventory agency data and associated 

business processes to identify gaps

(February 2015-September 2015)

All three selected agencies have begun inventorying their data.

CNCS officials told us they leveraged their ongoing financial management systems 

modernization efforts to identify data sources and assess the agency’s readiness to 

comply with DATA Act reporting requirements.

HHS officials told us they conducted an initial survey of HHS’s reporting communities and 

identified gaps including where data are stored in specific systems and inconsistencies in 

the way the data are used across various systems. HHS initiated a Critical Systems 

Assessment process to build on the lessons learned from its initial data inventory 

process.

USDA’s data inventory process is ongoing with results expected in 2016. 

Step 4

Assess status of agency financial and 

award system linkages and develop an 

implementation plan

(March 2015-September 2015)

All three selected agencies submitted implementation plans concurrent with their 2017 

budget submissions.

CNCS has a fully integrated financial management and procurement system and a grants 

management system that is linked to the agency’s financial management system through 

a unique award identifier.

All but two USDA agencies use a single centralized financial management system, an 

integrated acquisitions system, and a centralized grant award system. USDA is exploring 

solutions for integrating awards processed outside of centralized systems.

HHS’s financial and award systems are not currently linked with the same award ID 

number. HHS initiated an integrated project team to examine ways to ensure that 

financial and award systems could be linked by a standard award ID number. According 

to HHS officials, the biggest challenge is standardizing the award ID across the agency, 

without losing the business intelligence built into the various award identification 

numbers.

Step 5

Execute the broker service by extracting 

data from agency source systems and, 

mapping to the DATA Act schema

(October 2015-February 2016)

The three agencies have not developed plans to execute the broker service being 

developed by Treasury because it has not been finalized.

CNCS will rely on a broker service developed by its enterprise resource planning vendor, 

according to CNCS officials.

USDA has started to develop its own process to extract data from agency financial and 

award systems into a central data mart to be mapped to the DATA Act schema through 

the Treasury broker.

HHS officials reported that HHS is monitoring Treasury’s broker development, but has not 

made plans to execute the broker service because clear guidance on this process from 

Treasury is pending.
Page 24 GAO-16-261 Data Standards

DATA Act Implementation Playbook 8-

step plan for agency implementation 

(and time frames)

Implementation status at selected agencies as of December 2015

(Corporation for National and Community Service (CNCS), the Department of 

Agriculture (USDA), and the Department of Health and Human Services (HHS)) 

Step 6

Test broker outputs to ensure data are 

valid

(October 2015-February 2016)

CNCS and HHS are awaiting additional guidance before they take steps to test a broker 

service, according to officials at each agency; USDA began testing the broker prototype 

in early December 2015. 

Step 7

Update systems to implement required 

system changes

(October 2015-February 2017)

The three agencies have not yet taken this step.

Step 8

Submit data

(March 2016-May 9, 2017)

This step is not scheduled to begin until March 2016.

Source: GAO analysis of OMB and Treasury DATA Act Implementation Playbook and selected agency implementation plans. | GAO-16-261

a

The Interagency Advisory Committee is charged with representing the numerous business and 

functional communities across the government that have stakes in DATA Act implementation. The 

membership includes representatives of the Chief Financial Officers Council, the Budget Officers 

Advisory Council, the Award Committee for E-Government, the Council on Financial Assistance 

Reform, the Chief Acquisition Officers Council, the Chief Information Officers Council, and the 

Performance Improvement Council, and the Council of the Inspectors General on Integrity and 

Efficiency, among others.

Once fully and effectively implemented, the DATA Act holds great 

promise for improving the transparency and accountability of federal 

spending data by providing consistent, reliable, and complete data on 

federal spending. In order to fully and effectively implement the DATA 

Act, the federal government will need to address complex policy and 

technical issues. Central among these is defining and developing 

common data elements across multiple reporting areas and standing up 

the necessary supporting systems and processes to enable reporting of 

the federal spending data required by the DATA Act. Toward that end, 

OMB and Treasury have made progress since the act was signed into law 

in May 2014, including issuing definitions for 57 data elements, 

developing an 8-step plan and timelines for agencies to follow as they 

move through the implementation process, and providing a variety of 

outreach approaches to address agency questions and to obtain 

feedback from federal and nonfederal stakeholders.

The implementation accomplishments to date exist alongside continued 

challenges that OMB and Treasury need to address in order to 

successfully meet the requirements and objectives of the act. Although 

the majority of the 57 data element definitions generally follow leading 

practices, we identified limitations with some data element definitons and 

their documentation that, if not addressed, could lead to inconsistent 

Conclusions
Page 25 GAO-16-261 Data Standards

reporting, and limit the ability to meaningfully aggregate or compare data 

for these elements across the federal government. Moreover, the 

standards will be of little value if agencies are not prepared to collect and 

report quality data in conformance with the standards. Therefore, it is of 

vital importance that OMB and Treasury provide federal agencies with 

timely information and support so that they are in a position to effectively 

implement these standards. We provided OMB and Treasury with input 

on identified challenges related to the data element definitions and draft 

technical schema to help ensure these challenges are addressed as 

implementation progresses. Moreover, as agencies work through the 8-

step implementation process, it will be important for OMB and Treasury to 

provide them with finalized technical guidance that can serve as a 

foundation for developing the necessary systems and processes for 

agency implementation. If guidance is not timed to coincide with 

agencies’ expected milestones for key steps in the implementation 

process, agencies could incur additional costs as they revise 

implementation plans to align with later versions of the guidance or could 

be forced to delay implementation.

1. To help ensure that agencies report consistent and comparable data 

on federal spending, we recommend that the Director of OMB, in 

collaboration with the Secretary of the Treasury, provide agencies 

with additional guidance to address potential clarity, consistency, or 

quality issues with the definitions for specific data elements including 

Award Description and Primary Place of Performance and that they 

clearly document and communicate these actions to agencies 

providing this data as well as to end-users.

2. To ensure that federal agencies are able to meet their reporting 

requirements and timelines, we recommend that the Director of OMB, 

in collaboration with the Secretary of the Treasury, take steps to align 

the release of finalized technical guidance, including the DATA Act 

schema and broker, to the implementation time frames specified in 

the DATA Act Implementation Playbook.

We provided a draft of this report to the Director of OMB, the Secretaries 

of the Treasury, HHS and USDA, and the Chief Executive Officer of 

CNCS for review and comment. Both OMB and Treasury submitted 

written comments, which provided additional clarifying information related 

to our recommendations. OMB’s and Treasury’s written comments are 

discussed below and reproduced in appendixes IV and V respectively. In 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation 
Page 26 GAO-16-261 Data Standards

addition, OMB, Treasury, CNCS, and HHS provided technical comments,

which we incorporated as appropriate, and USDA had no comments. 

In his written response, the OMB Controller generally concurred with our 

first recommendation to provide agencies with additional guidance to 

address potential clarity, consistency, or quality issues with data element 

definitions. However, in the discussion of OMB’s efforts to date to expand 

and improve federal spending transparency, the OMB Controller 

distinguished between the 11 data elements that were standardized in 

May 2015 and the remaining 46 data elements that were issued in August 

2015. OMB interpreted the DATA Act requirement to standardize data 

elements as only applying to the 11 data elements, and indicated that the 

remaining 46 elements were standardized pursuant to the overarching 

policy goal of improving the consistency of federal spending data on 

USAspending.gov. OMB stated that the additional 46 data elements 

provided an opportunity to increase comparability and data quality. 

However, both the statutory language and the purposes of the DATA Act 

support the interpretation that OMB and Treasury were required to 

establish data standards for award and awardee information in addition to 

account level information. The DATA Act states that the financial data 

standards OMB and Treasury are required to establish are to include 

financial and payment information required to be reported by federal 

agencies and entities receiving federal funds.29 Such information reported 

by entities receiving federal funds is information on awards and 

awardees, not account-level financial data. The act further provides that 

the data standards are to include, to the extent reasonable and practical, 

unique identifiers for federal awards and entities receiving federal 

awards.30 However, OMB does not interpret Award Identification Number

and Awardee/Recipient Unique Identifier to be among those data 

elements they are required to standardize pursuant to the DATA Act. 

Lastly, OMB’s interpretation is inconsistent with Congress’s intent when it 

passed the DATA Act. As described in the legislative history of the act, 

Congress sought to address the known data quality issues with award 

and awardee information that had been reported under FFATA. To 

 29FFATA, § 4(a)(2).

30FFATA, § 4(b)(3).
Page 27 GAO-16-261 Data Standards

accomplish this, data standards for those elements were necessary.31

Without data standards for award and awardee information, the 

inconsistent and non-comparable reporting under FFATA that Congress 

sought to remedy through the DATA Act would continue. For these 

reasons, we conclude that the requirement in the DATA Act to establish 

data standards applies not only to account-level information, but also to 

award and awardee information. This is an important distinction for 

ensuring that federal agencies are held appropriately accountable for the 

completeness, quality, and accuracy of the spending data to be reported 

in the years to come. 

In addition to responding to the recommendations made in this report, 

OMB also addressed the recommendation made in our July 2015 

testimony which called on OMB to accelerate efforts to determine how 

best to merge DATA Act purposes and requirements with requirements 

under the GPRA Modernization Act of 2010 (GPRAMA) to produce a 

federal program inventory.

32 In response to this recommendation, the 

OMB Controller noted that OMB promulgated guidance in OMB Circular 

A-11, Sections 82 and 83, requiring agencies to start submitting object 

class and program activity information from their accounting systems to 

OMB. We recognize that requiring agencies to submit data on object 

class and program activity may be a step toward meeting the requirement 

of the DATA Act to report this information and may contribute toward the 

broader effort of developing a federal program inventory as required by 

GPRAMA. However, much still remains to be done in order to produce 

such an inventory. We continue to believe, as we previously 

recommended, that OMB should accelerate those efforts and we will 

continue to monitor progress in meeting this statutory requirement. 

 31H.R. Rep. No, 113-270 at 9 (2014); S. Rep. 113-139 at 4-5 (2014). The House of 

Representatives report explains the importance of establishing data standards for all types 

of information this way: “Significantly, the usefulness of both USAspending.gov and 

Recovery.gov is hampered by the federal government's long-term failure to adopt common 

data elements and reporting standards for electronic financial information. For example, 

there is no system of identifier codes for all federal awards; instead, every agency 

separately tracks grants, contracts, and loans using its own distinct system. Similarly, 

there is no system of identifier codes for all recipients of federal grants, contracts, and 

loans; no master list of all federal programs; and, in fact, no agreed system of agency 

codes. Without government-wide identifiers for awards, recipients, programs, agencies, 

and other data elements, sophisticated electronic searches and comparisons will be 

impossible, even under a comprehensive spending transparency mandate.”

32GAO, DATA Act: Progress Made in Initial Implementation but Challenges Must be 

Addressed as Efforts Proceed, GAO-15-752T (Washington, D.C.: July 29, 2015).
Page 28 GAO-16-261 Data Standards

Regarding our recommendation to align the release of finalized technical 

guidance to the implementation timelines specified in the DATA Act 

Implementation Playbook, OMB deferred matters of technical 

operationalization to Treasury, which has program responsibility for 

technical implementation. 

In their written response, Treasury officials deferred our first 

recommendation to provide agencies with additional guidance to address 

potential clarity, consistency, or quality issues with data element 

definitions to OMB. Regarding our second recommendation to align the 

release of finalized technical guidance to the implementation timelines 

specified in the DATA Act Implementation Playbook, Treasury officials 

generally concurred with our recommendation, noting that they recognize 

the importance of providing agencies with timely technical guidance and 

reporting submission specifications.

We are sending copies of this report to the heads of the Departments of 

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

Corporation for National and Community Service, as well as interested 

congressional committees and other interested parties. This report will 

also be available at no charge on the GAO website at http://www.gao.gov.

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

at (202) 512-6806 or sagerm@gao.gov . Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of our report. Key contributors to this report are listed in appendix VI.

Michelle Sager

Director, Strategic Issues
Page 29 GAO-16-261 Data Standards

List of Congressional Committees

The Honorable Ron Johnson

Chairman

The Honorable Thomas R. Carper

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Mark R. Warner

Chairman

Task Force on Government Performance

Committee on the Budget

United States Senate

The Honorable Jason Chaffetz

Chairman

The Honorable Elijah E. Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives

The Honorable Mark Meadows

Chairman

The Honorable Gerald E. Connolly

Ranking Member

Subcommittee on Government Operations

Committee on Oversight and Government Reform

House of Representatives

The Honorable Will Hurd

Chairman

The Honorable Robin Kelly

Ranking Member

Subcommittee on Information Technology

Committee on Oversight and Government Reform

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-16-261 Data Standards

This report (1) identifies steps taken by the Office of Management and 

Budget (OMB) and the Department of Treasury (Treasury) to establish 

government-wide data element definitions and the extent to which those 

definitions are consistent with leading practices or face challenges that 

could affect data quality; (2) reviews efforts by OMB and Treasury to 

provide agencies with technical implementation guidance to standardize 

how data are collected and reported and related challenges; and (3) 

examines the status of selected federal agencies’ progress in meeting 

DATA Act requirements. This review is a part of an ongoing effort to 

provide interim reports on the progress being made in the implementation 

of the DATA Act, while also meeting our audit reporting requirements 

mandated by the act.

For the first objective, we reviewed our past work that raised concerns 

about the quality of federal spending data on USAspending.gov to inform 

our review of OMB’s and Treasury’s efforts to establish data standards. 

We analyzed the definitions of the 57 data elements issued May 8, 2015 

through August 31, 2015, and assessed the extent to which the data 

definitions are consistent with DATA Act requirements and leading 

practices from standards set by the International Organization for 

Standardization (ISO).

To assess the extent to which the data standards are consistent with ISO 

standards, we had two analysts independently rate each of the 57 data 

element definitions against all 13 ISO leading practices and determine 

whether the data element (1) met the ISO leading practice, (2) did not 

meet the ISO leading practice, (3) partially met the ISO leading practice, 

or (4) whether the ISO leading practice was not applicable to the 

particular data element definition. When the two raters independently 

came to the same rating for a particular leading practice and data element 

definition, the raters were considered to be in concurrence and the 

agreed upon rating was carried forward as the assessment of record. 

After the first round of assessments, the initial raters were in concurrence 

on 630 of 741 necessary assessments. When the two raters 

independently came to different ratings for a particular leading practice 

and data element definition, a third rater independently assessed those 

data element definitions and leading practices to attempt to reach 

concurrence. This was necessary in 111 cases. When the third rater 

independently came to the same rating as one of the initial two raters, 

that rating was carried forward as the assessment of record. After this 

second round of assessments, the raters were in concurrence on 727 of 

741 necessary assessments. When the third rater came to a different 

rating as both of the initial two raters for a particular leading practice and 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-16-261 Data Standards

data element definition, the three raters met to discuss their application of 

the leading practice to the data element definition and come to consensus 

on a final assessment of record. After these discussions, the raters were 

in concurrence on 741 of 741 necessary assessments.

For data element definitions related to federal budget terms, we 

supplemented our analysis with a legal review to ensure assessments 

were both accurate and complete. For purposes of reporting, when the 

final assessment of record was that a given data element definition met or 

partially met the ISO leading practice or that the ISO leading practice was 

not applicable, the data element definition was considered to adhere to 

the given leading practice. For the purposes of aggregating our 

assessments, we considered a “partial” response to be a “yes” because 

the ISO standards represented leading practices and not firm 

requirements for OMB and Treasury to follow. Therefore, we erred on the 

side of giving the agencies credit for the contents of their definitions 

meeting parts of the leading practice. When the assessment of record 

was “no” the data element definition was considered as not adhering to 

the given leading practice.

For the second objective assessing OMB’s and Treasury’s development 

of a technical schema that specifies the format, structure, tagging, and 

transmission of each data element to allow consistency and 

comparability, we consulted the U.S. Digital Services Playbook and we 

reviewed and analyzed differences between version 0.2, version 0.5, and 

version 0.6 of the schema.1 We reviewed applicable agency guidance 

and documentation related to the data standards and technical schema 

on OMB’s and Treasury’s websites. We also interviewed knowledgeable 

agency officials about their standards-setting and technical schema 

development processes.

For the third objective, we selected three agencies for review—the 

Department of Health and Human Services, the Department of 

Agriculture, and the Corporation for National and Community Service. 

Using a three-step selection process, we looked for agencies that met 

 1

OMB and Treasury released version 0.1 of the DATA Act schema on March 30, 2015, 

and subsequently released additional versions in the following months: version 0.2 in May, 

version 0.5 in July, and version 0.6 in October. Versions 0.3 and 0.4 were not publicly 

released. On December 31, 2015, OMB and Treasury released version 0.7, which we 

have yet to fully review.
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-16-261 Data Standards

varying conditions: (1) compliance with requirements for federal financial 

management systems; (2) representation across multiple lines of 

business—grants, loans, and contracts; and (3) status as a Federal 

Shared Service Provider for financial management.2 Table 4 shows each 

selected agency in relation to these criteria. 

Table 4: Criteria for Agency Selection

Criteria

Department of Health and Human 

Services (HHS)

Department of Agriculture 

(USDA)

Corporation for National 

and Community Service 

(CNCS)

Compliance with requirements 

for federal financial 

management systems

Noncompliant with systems and 

U.S. Government Standard 

General Ledger (SGL) 

requirements of the Federal 

Financial Management 

Improvement Act of 1996 in fiscal 

year 2014.

Noncompliant with systems 

and SGL requirements of the 

Federal Financial Management 

Improvement Act of 1996 in 

fiscal year 2014.

Not applicable.

Representation across multiple 

lines of business—grants, 

contracts, and loans

In fiscal year 2013, HHS was 

represented across both grants and 

contracts.

In fiscal year 2013, USDA was 

represented across grants, 

contracts, and loans.

In fiscal year 2013, CNCS 

was represented across both 

grants and contracts.

Status as a Federal Shared 

Service Provider for financial 

management

HHS is not a Federal Shared 

Service Provider for financial 

management.

USDA is a Federal Shared 

Service Provider for financial 

management.

CNCS is not a Federal 

Shared Service Provider for 

financial management.

Source: GAO. | GAO-16-261

Although the results from our review of these three agencies are not 

generalizable to all agencies, they are designed to illustrate a range of 

conditions under which agencies are implementing the act.

We assessed whether the selected agencies submitted their 

implementation plans and identified a senior accountable official (SAO) to 

report on progress. We also reviewed the implementation plans and 

related project plans and interviewed agency DATA Act team members 

for their assessment of implementation progress, including what controls 

are in place to ensure data quality, the challenges they have encountered 

thus far, and the extent to which identified challenges could impede timely 

and effective implementation.

We conducted this performance audit from May 2015 to January 2016 in 

accordance with generally accepted government auditing standards. 

 2

The full list of agencies we selected from included the 24 CFO Act agencies, as well as 

smaller agencies that already reported spending data to USAspending.gov under FFATA.
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-16-261 Data Standards

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions on our audit objectives.
Appendix II: Status of GAO’s Open 

Recommendations and Matters for 

Congressional Consideration Related to the 

DATA Act

Page 34 GAO-16-261 Data Standards

Report

Recommendation/matter for congressional 

consideration Implementation status

GAO-10-365: Electronic 

Government: Implementation 

of the Federal Funding 

Accountability and 

Transparency Act of 2006 

(March 2010)

1. To improve the accuracy, completeness, and 

timeliness of all data submissions to the Office of 

Management and Budget’s (OMB) 

USAspending.gov website, the Director of OMB 

should revise guidance to federal agencies on 

reporting federal awards to clarify (1) the 

requirement that award titles describe the award’s 

purpose; and (2) requirements for validating and 

documenting agency awards data submitted by 

federal agencies.

Closed—not implemented. Provisions of 

the Digital Accountability and Transparency 

Act of 2014 could address this 

recommendation, but implementation will 

take several years.

2. To improve the accuracy, completeness, and 

timeliness of all data submissions to OMB’s 

USAspending.gov website, the Director of OMB 

should include information on the city where work is 

performed in OMB’s public reporting of the 

completeness of agency data submissions.

Closed—not implemented. OMB no 

longer uses the reporting mechanism 

discussed in the recommendation.

GAO-13-758: Federal Data 

Transparency: Opportunities 

Remain to Incorporate 

Lessons Learned as 

Availability of Spending Data 

Increases (September 2013)

1. The Director of OMB, in collaboration with the 

members of the Government Accountability and 

Transparency Board, should develop a plan to 

implement comprehensive transparency reform, 

including a long-term timeline and requirements for 

data standards, such as establishing a uniform 

award identification system across the federal 

government.

Open. As a result of passage of the Digital 

Accountability and Transparency Act 

(DATA Act) in May 2014, OMB is working 

with the Department of the Treasury 

(Treasury) and other members of the 

Government Accountability and 

Transparency Board to develop a long-term 

strategy to implement key transparency 

reforms including government-wide data 

standards. We will continue to monitor the 

progress of their efforts to implement key 

provisions of the act.

GAO-14-476: Data 

Transparency: Oversight 

Needed to Address 

Underreporting and 

Inconsistencies on Federal 

Award Website (June 2014)

1. To improve the completeness and accuracy of 

data submissions to the USAspending.gov 

website, the Director of OMB, in collaboration with 

Treasury’s Fiscal Service, should clarify guidance 

on (1) agency responsibilities for reporting awards 

funded by non-annual appropriations; (2) the 

applicability of USAspending.gov reporting 

requirements to non-classified awards associated 

with intelligence operations; (3) the requirement 

that award titles describe the award’s purpose 

(consistent with our prior recommendation); and 

(4) agency maintenance of authoritative records 

adequate to verify the accuracy of required data 

reported for use by USAspending.gov.

Open. OMB and Treasury are working to 

implement the DATA Act, which includes 

several provisions that could address our 

recommendations once fully implemented.

Appendix II: Status of GAO’s Open 

Recommendations and Matters for 

Congressional Consideration Related to the 

DATA Act
Appendix II: Status of GAO’s Open 

Recommendations and Matters for 

Congressional Consideration Related to the 

DATA Act

Page 35 GAO-16-261 Data Standards

Report

Recommendation/matter for congressional 

consideration Implementation status

2. To improve the completeness and accuracy of 

data submissions to the USAspending.gov 

website, the Director of OMB, in collaboration with 

Treasury’s Fiscal Service, should develop and 

implement a government-wide oversight process 

to regularly assess the consistency of information 

reported by federal agencies to the website other 

than the award amount.

Open. As part of their DATA Act 

implementation efforts, OMB and Treasury 

have outlined a process for agencies to 

identify authoritative systems to validate 

agency spending information. In addition, 

the inspector general community is working 

on standard audit methodologies to verify 

the accuracy and completeness of agency 

reporting. Implementation of these efforts is 

planned to begin in fiscal year 2016.

GAO-15-752T: DATA Act: 

Progress Made in Initial 

Implementation but Challenges 

Must be Addressed as Efforts 

Proceed (July 2015)

1. To ensure that federal program spending data are 

provided to the public in a transparent, useful, and 

timely manner, the Director of OMB should 

accelerate efforts to determine how best to merge 

DATA Act purposes and requirements with the 

GPRAMA requirement to produce a federal 

program inventory.

Open. In commenting on a draft of this 

statement in July 2015, OMB staff stated

that they neither agreed nor disagreed with 

this recommendation. Testifying before two 

subcommittees of the House Oversight and 

Government Reform Committee on July 29, 

2015, OMB’s Acting Deputy Director for 

Management and Controller stated that the 

agency planned to address the issue of 

identifying “programs” for the purposes of 

DATA Act reporting but that such efforts 

would likely not start until sometime in fiscal 

year 2016, and would not be completed until 

after May 2017.

2. To ensure that the integrity of data standards is 

maintained over time, the Director of OMB, in 

collaboration with the Secretary of the Treasury, 

should establish a set of clear policies and 

processes for developing and maintaining data 

standards that are consistent with leading 

practices for data governance.

Open. In an August 31, 2015, whitepaper 

published on their DATA Act collaboration 

website, OMB and Treasury stated their 

intent to address this recommendation by 

working to establish in fiscal year 2016 a 

formal, long-term governance process and 

structure for future data standards 

maintenance. This governance structure 

would be the forum to review 

recommendations for new data elements to 

be reported to USAspending.gov and for 

additional data standards to be adopted 

moving forward.

3. To ensure that interested parties’ concerns are 

addressed as implementation efforts continue, the 

Director of OMB, in collaboration with the 

Secretary of the Treasury, should build on existing 

efforts and put in place policies and procedures to 

foster ongoing and effective two-way dialogue with 

stakeholders including timely and substantive 

responses to feedback received on the Federal 

Spending Transparency GitHub website.

Open. In commenting on a draft of the 

statement in July 2015, OMB staff stated 

that they neither agreed nor disagreed with 

this recommendation.
Appendix II: Status of GAO’s Open 

Recommendations and Matters for

Congressional Consideration Related to the 

DATA Act

Page 36 GAO-16-261 Data Standards

Report

Recommendation/matter for congressional 

consideration Implementation status

GAO-15-814: Federal 

Spending Accountability: 

Preserving Capabilities of 

Recovery Operations Center 

Could Help Sustain Oversight 

of Federal Expenditures

(September 2015)

1. To capitalize on the opportunity created by the 

DATA Act, the Secretary of the Treasury should 

reconsider whether certain assets—especially 

information and documentation such as 

memoranda of understanding (MOUs) that would 

help transfer the knowledge gained through the 

operation of the Recovery Operations Center—

could be worth transferring to the Do Not Pay 

Center Business Center to assist in its mission to 

reduce improper payments. Additionally, the 

Secretary should document the decision on 

whether Treasury transfers additional information 

and documentation and what factors were 

considered in this decision.

Open. Treasury concurred with our 

recommendation that it should consider 

additional knowledge transfers from the 

Recovery Operations Center to assist in the 

Do Not Pay Center Business Center’s 

mission to reduce improper payments and 

will document its rationale and final decision 

in this regard..

Matter for Congressional Consideration:

1. To help preserve a proven resource supporting 

the oversight community’s analytic capabilities, 

Congress may wish to consider directing the 

Council of the Inspectors General on Integrity and 

Efficiency (CIGIE) to develop a legislative 

proposal to reconstitute the essential capabilities 

of the Recovery Operations Center to help ensure 

federal spending accountability. The proposal 

should identify a range of options at varying 

scales for the cost of analytic tools, personnel, 

and necessary funding, as well as any additional 

authority CIGIE may need to ensure such 

enduring, robust analytical and investigative 

capability for the oversight community.

Open.

Source: GAO. | GAO-16-261
Appendix III: Definitions of Issued Data 

Elements

Page 37 GAO-16-261 Data Standards

This appendix lists the data elements and their definitions broken out by 

type, as issued by the Office of Management and Budget (OMB) and the 

Department of Treasury (Treasury) on May 8, 2015 and August 31, 2015.

Account Level Data Standards: These data elements describe the appropriations accounts from which agencies fund Federal 

awards.

Data Element Data Definition

Appropriations Account The basic unit of an appropriation generally reflecting each unnumbered paragraph in an 

appropriation act. An appropriation account typically encompasses a number of activities or 

projects and may be subject to restrictions or conditions applicable to only the account, the 

appropriation act, titles within an appropriation act, other appropriation acts, or the Government as 

a whole.

An appropriations account is represented by a TAFS created by Treasury in consultation with OMB 

(defined in OMB Circular A-11).

Budget Authority Appropriated A provision of law (not necessarily in an appropriations act) authorizing an account to incur 

obligations and to make outlays for a given purpose. Usually, but not always, an appropriation 

provides budget authority (defined in OMB Circular A-11).

Object Class Categories in a classification system that presents obligations by the items or services purchased 

by the Federal Government. Each specific object class is defined in OMB Circular A-11 § 83.6 

(defined in OMB Circular A-11).

Obligation Obligation means a legally binding agreement that will result in outlays, immediately or in the 

future. When you place an order, sign a contract, award a grant, purchase a service, or take other 

actions that require the Government to make payments to the public or from one Government 

account to another, you incur an obligation. It is a violation of the Antideficiency Act (31 U.S.C. § 

1341(a)) to involve the Federal Government in a contract or obligation for payment of money 

before an appropriation is made, unless authorized by law. This means you cannot incur 

obligations in a vacuum; you incur an obligation against budget authority in a Treasury account that 

belongs to your agency. It is a violation of the Antideficiency Act to incur an obligation in an amount 

greater than the amount available in the Treasury account that is available. This means that the 

account must have budget authority sufficient to cover the total of such obligations at the time the 

obligation is incurred. In addition, the obligation you incur must conform to other applicable 

provisions of law, and you must be able to support the amounts reported by the documentary 

evidence required by 31 U.S.C. § 1501. Moreover, you are required to maintain certifications and 

records showing that the amounts have been obligated (31 U.S.C. § 1108). Additional detail is 

provided in Circular A‐11.

Other Budgetary Resources New borrowing authority, contract authority, and spending authority from offsetting collections 

provided by Congress in an appropriations act or other legislation, or unobligated balances of 

budgetary resources made available in previous legislation, to incur obligations and to make 

outlays (defined in OMB Circular A-11).

Outlay Payments made to liquidate an obligation (other than the repayment of debt principal or other 

disbursements that are “means of financing” transactions). Outlays generally are equal to cash 

disbursements but also are recorded for cash-equivalent transactions, such as the issuance of 

debentures to pay insurance claims, and in a few cases are recorded on an accrual basis such as 

interest on public issues of the public debt. Outlays are the measure of Government spending 

(defined in OMB Circular A-11).

Program Activity A specific activity or project as listed in the program and financing schedules of the annual budget 

of the United States Government (defined in OMB Circular A-11).

Appendix III: Definitions of Issued Data 

Elements
Appendix III: Definitions of Issued Data 

Elements

Page 38 GAO-16-261 Data Standards

Data Element Data Definition

Treasury Account Symbol 

(excluding sub-account)

Treasury Account Symbol: The account identification codes assigned by the Department of the 

Treasury to individual appropriation, receipt, or other fund accounts. All financial transactions of the 

Federal Government are classified by TAS for reporting to the Department of the Treasury and the 

Office of Management and Budget (defined in OMB Circular A-11).

Treasury Appropriation Fund Symbol: The components of a Treasury Account Symbol – allocation 

agency, agency, main account, period of availability and availability type – that directly correspond 

to an appropriations account established by Congress (defined in OMB Circular A-11).

Unobligated Balance Unobligated balance means the cumulative amount of budget authority that remains available for 

obligation under law in unexpired accounts at a point in time. The term “expired balances available 

for adjustment only” refers to unobligated amounts in expired accounts. Additional detail is 

provided in Circular A‐11.

Award Characteristic Data Standards: These data elements describe characteristics that apply to specific financial 

assistance and/or procurement awards

Data Element Data Definition

Action Date The date the action being reported was issued / signed by the Government or a binding 

agreement was reached.

Action Type Description (and corresponding code) that provides information on any changes made to the 

Federal prime award. There are typically multiple actions for each award.

(Note: This definition encompasses current data elements ‘Type of Action’ for financial assistance 

and ‘Reason for Modification’ for procurement)

Award Description A brief description of the purpose of the award.

Award Identification (ID) Number The unique identifier of the specific award being reported, i.e. Federal Award Identification 

Number (FAIN) for financial assistance and Procurement Instrument Identifier (PIID) for 

procurement.

Award Modification/Amendment 

Number

The identifier of an action being reported that indicates the specific subsequent change to the 

initial award.

Award Type Description (and corresponding code) that provides information to distinguish type of contract, 

grant, or loan and provides the user with more granularity into the method of delivery of the 

outcomes.

Business Types A collection of indicators of different types of recipients based on socio-economic status and 

organization / business areas.

Catalog of Federal Domestic 

Assistance (CFDA) Number

The number assigned to a Federal area of work in the Catalog of Federal Domestic Assistance.

Catalog of Federal Domestic 

Assistance (CFDA) Title

The title of the area of work under which the Federal award was funded in the Catalog of Federal 

Domestic Assistance.

North American Industrial 

Classification System (NAICS) 

Code

The identifier that represents the North American Industrial Classification System Code assigned 

to the solicitation and resulting award identifying the industry in which the contract requirements 

are normally performed.

North American Industrial 

Classification System (NAICS) 

Description

The title associated with the NAICS Code.
Appendix III: Definitions of Issued Data 

Elements

Page 39 GAO-16-261 Data Standards

Data Element Data Definition

Ordering Period End Date For procurement, the date on which, for the award referred to by the action being reported, no 

additional orders referring to it may be placed. This date applies only to procurement indefinite 

delivery vehicles (such as indefinite delivery contracts or blanket purchase agreements). 

Administrative actions related to this award may continue to occur after this date. The period of 

performance end dates for procurement orders issued under the indefinite delivery vehicle may 

extend beyond this date.

Parent Award Identification (ID) 

Number

The identifier of the procurement award under which the specific award is issued, such as a 

Federal Supply Schedule. This data element currently applies to procurement actions only.

Period of Performance Current 

End Date

The current date on which, for the award referred to by the action being reported, awardee effort 

completes or the award is otherwise ended. Administrative actions related to this award may 

continue to occur after this date. This date does not apply to procurement indefinite delivery 

vehicles under which definitive orders may be awarded.

Period of Performance Potential 

End Date

For procurement, the date on which, for the award referred to by the action being reported if all 

potential pre-determined or pre-negotiated options were exercised, awardee effort is completed or 

the award is otherwise ended. Administrative actions related to this award may continue to occur 

after this date. This date does not apply to procurement indefinite delivery vehicles under which 

definitive orders may be awarded.

Period of Performance Start Date The date on which, for the award referred to by the action being reported, awardee effort begins 

or the award is otherwise effective.

Primary Place of Performance 

Address

The address where the predominant performance of the award will be accomplished. The address 

is made up of six components: Address Lines 1 and 2, City, County, State Code, and ZIP+4 or 

Postal Code.

Primary Place of Performance 

Congressional District

U.S. congressional district where the predominant performance of the award will be 

accomplished. This data element will be derived from the Primary Place of Performance Address.

Primary Place of Performance 

Country Code

Country code where the predominant performance of the award will be accomplished.

Primary Place of Performance 

Country Name

Name of the country represented by the country code where the predominant performance of the 

award will be accomplished.

Record Type Code indicating whether an action is an individual transaction or aggregated.

Award Amount Data Standards: These data elements describe characteristics that apply to amount information for financial 

assistance and/or procurement awards.

Data Element Data Definition

Amount of Award The cumulative amount obligated by the Federal Government for an award, which is calculated by 

USAspending.gov or a successor site.

For procurement and financial assistance awards except loans, this is the sum of Federal Action 

Obligations.

For loans or loan guarantees, this is the Original Subsidy Cost.

Current Total Value of Award For procurement, the total amount obligated to date on a contract, including the base and 

exercised options.

Federal Action Obligation Amount of Federal Government’s obligation, de-obligation, or liability, in dollars, for an award 

transaction.

Non-Federal Funding Amount For financial assistance, the amount of the award funded by a non-Federal source(s), in dollars. 

Program Income (as defined in 2 C.F.R. § 200.80) is not included until such time that Program 

Income is generated and credited to the agreement.

Potential Total Value of Award For procurement, the total amount that could be obligated on a contract, if the base and all options 

are exercised.
Appendix III: Definitions of Issued Data 

Elements

Page 40 GAO-16-261 Data Standards

Awardee and Recipient Entity Data Standards: These data elements describe the recipients/awardees of Federal funds

Data Element Data Definition

Awardee/Recipient Legal Entity 

Name

The name of the awardee or recipient that relates to the unique identifier. For U.S. based 

companies, this name is what the business ordinarily files in formation documents with individual 

states (when required).

Awardee/Recipient Unique 

Identifier

The unique identification number for an awardee or recipient. Currently the identifier is the 9-digit 

number assigned by Dun & Bradstreet referred to as the DUNS® number.

Highly Compensated Officer 

Name

First Name: The first name of an individual identified as one of the five most highly compensated 

“Executives.” “Executive” means officers, managing partners, or any other employees in 

management positions.

Middle Initial: The middle initial of an individual identified as one of the five most highly 

compensated “Executives.” “Executive” means officers, managing partners, or any other 

employees in management positions.

Last Name: The last name of an individual identified as one of the five most highly compensated 

“Executives.” “Executive” means officers, managing partners, or any other employees in 

management positions.

Highly Compensated Officer Total 

Compensation

The cash and noncash dollar value earned by the one of the five most highly compensated 

“Executives” during the awardee’s preceding fiscal year and includes the following (for more 

information see 17 C.F.R. § 229.402(c)(2)): salary and bonuses, awards of stock, stock options, 

and stock appreciation rights, earnings for services under non-equity incentive plans, change in 

pension value, above-market earnings on deferred compensation which is not tax qualified, and 

other compensation.

Legal Entity Address The awardee or recipient’s legal business address where the office represented by the Unique 

Entity Identifier (as registered in the System for Award Management) is located. In most cases, 

this should match what the entity has filed with the State in its organizational documents, if 

required. The address is made up of five components: Address Lines 1 and 2, City, State Code, 

and ZIP+4 or Postal Code.

Legal Entity Congressional District The congressional district in which the awardee or recipient is located. This is not a required data 

element for non-U.S. addresses.

Legal Entity Country Code Code for the country in which the awardee or recipient is located, using the ISO 3166-1 Alpha-3 

GENC Profile, and not the codes listed for those territories and possessions of the United States 

already identified as “states.”

Legal Entity Country Name The name corresponding to the Country Code.

Ultimate Parent Legal Entity Name The name of the ultimate parent of the awardee or recipient. Currently, the name is from the 

global parent DUNS® number.

Ultimate Parent Unique Identifier The unique identification number for the ultimate parent of an awardee or recipient. Currently the 

identifier is the 9-digit number maintained by Dun & Bradstreet as the global parent DUNS® 

number.

Awarding Entity Data Standards: These data elements describe the characteristics of the entity that made the award.

Data Element Data Definition

Awarding Agency Code A department or establishment of the Government as used in the Treasury Account Fund 

Symbol (TAFS).

Awarding Agency Name The name associated with a department or establishment of the Government as used in the 

Treasury Account Fund Symbol (TAFS).

Awarding Office Code Identifier of the level n organization that awarded, executed or is otherwise responsible for the 

transaction.
Appendix III: Definitions of Issued Data 

Elements

Page 41 GAO-16-261 Data Standards

Data Element Data Definition

Awarding Office Name Name of the level n organization that awarded, executed or is otherwise responsible for the 

transaction.

Awarding Sub Tier Agency Code Identifier of the level 2 organization that awarded, executed or is otherwise responsible for the 

transaction.

Awarding Sub Tier Agency Name Name of the level 2 organization that awarded, executed or is otherwise responsible for the 

transaction.

Funding Entity Data Standards: These data elements describe the characteristics of the entity that provided the funding for 

an award.

Data Element Data Definition

Funding Agency Code The 3-digit CGAC agency code of the department or establishment of the Government that 

provided the preponderance of the funds for an award and/or individual transactions related to 

an award.

Funding Agency Name Name of the department or establishment of the Government that provided the preponderance 

of the funds for an award and/or individual transactions related to an award.

Funding Office Code Identifier of the level n organization that provided the preponderance of the funds obligated by 

this transaction.

Funding Office Name Name of the level n organization that provided the preponderance of the funds obligated by this 

transaction.

Funding Sub Tier Agency Code Identifier of the level 2 organization that provided the preponderance of the funds obligated by 

this transaction.

Funding Sub Tier Agency Name Name of the level 2 organization that provided the preponderance of the funds obligated by this 

transaction.

Source: Office of Management and Budget and the Department of the Treasury | GAO-16-261
Appendix IV: Comments from the Office of 

Management and Budget

Page 42 GAO-16-261 Data Standards

Appendix IV: Comments from the Office of 

Management and Budget
Appendix IV: Comments from the Office of 

Management and Budget

Page 43 GAO-16-261 Data Standards
Appendix IV: Comments from the Office of 

Management and Budget

Page 44 GAO-16-261 Data Standards
Appendix IV: Comments from the Office of 

Management and Budget

Page 45 GAO-16-261 Data Standards
Appendix V: Comments from the Department 

of Treasury

Page 46 GAO-16-261 Data Standards

Appendix V: Comments from the Department 

of Treasury
Appendix V: Comments from the Department 

of Treasury

Page 47 GAO-16-261 Data Standards
Appendix VI: Staff Acknowledgments

Page 48 GAO-16-261 Data Standards

Michelle Sager, (202) 512-6806 or sagerm@gao.gov

In addition to the contact named above, J. Christopher Mihm (Managing 

Director), Peter Del Toro (Assistant Director), Kathleen Drennan (analystin-charge), Shirley Hwang, Jason Lyuke, Kiran Sreepada and David 

Watsula made major contributions to this report. Other key contributors 

include Shari Brewster; Mark Canter; Jenny Chanley; Robert Gebhart; 

Charles Jones; Lauren Kirkpatrick; Michael LaForge; Donna Miller; Laura 

Pacheco; Carl Ramirez; Paula Rascona; Andrew J. Stephens; James

Sweetman, Jr.; and Carroll Warfield, Jr. Additional members of GAO’s 

DATA Act Working Group also contributed to the development of this 

report.

Appendix VI: Staff Acknowledgments

GAO Contact

Staff 

Acknowledgments

(451146)
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