U.S. COMMODITY FUTURES TRADING COMMISSION

Office of the Inspector General

Office of Audits

Report Number: 21-AU-03

Performance Audit: CFTC’s 

Compliance with the Digital 

Accountability and Transparency Act 

(DATA Act) of 2014 

(FY 2021 Quarter II) 
U.S. COMMODITY FUTURES TRADING COMMISSION

 Three Lafayette Centre

 1155 21st Street, NW, Washington, DC 20581

 Telephone: (202) 418-5110

1 

Introduction 

The purpose of this performance audit is to fulfill our obligations under the Digital 

Accountability and Transparency Act of 20141 (DATA Act) which derived from the

Federal Funding Accountability and Transparency Act of 20062 requiring Federal 

agencies to disclose direct expenditures and link contract, loan, and grant 

spending information to agency programs. The Council of Inspectors General on 

Integrity and Efficiency Federal Audit Executive Council (CIGIE FAEC) issued 

guidelines3 for IGs to fulfill their obligations. In April 2020, OMB issued M-20-21, 

Implementation Guidance for Supplemental Funding Provided in Response to the 

Coronavirus Disease 2019 (COVID-19),4 which included changes to the 

frequency of agency reporting, additional audit testing, and a combination of nonstatistical audit techniques for agencies receiving funding under the CARES Act.

5

We conducted this audit in accordance with Generally Accepted Government 

Auditing Standards (GAGAS).

 

1P.L. 113-101, 128 Stat. 1146 (2014). Section 2 of the DATA Act states the purposes of this Act is to track 

federal spending more effectively; establish government-wide data standards for financial data; simplify 

reporting for entities receiving federal funds; and improve the quality of data submitted to USASpending.gov.

2 P.L. 109-282, 120 Stat. 1186 (2006). 3 CIGIE FAEC Inspectors General Guide to Compliance under the DATA Act. 4 OMB-20-21, Implementation Guidance for Supplemental Funding Provided in Response to the 

Coronavirus Disease 2019 (COVID-19). 5 Coronavirus Aid, Relief, and Economic Security (CARES) Act, P.L. 116-136, 134 Stat. 281 (2020). OMB 

required additional testing requirements for agencies receiving CARES Act funding. The CFTC did not 

receive funding under the CARES Act.

TO: Rostin Behnam, Acting Chairman 

Dawn DeBerry Stump, Commissioner

Dan M. Berkovitz, Commissioner 

FROM: Miguel A. Castillo, CPA, CRMA

Assistant Inspector General for Audits

DATE: September 28, 2021

SUBJECT: Performance Audit: CFTC’s Compliance with the Digital Accountability and 

Transparency Act of 2014 (FY 2021 Quarter II) 
2

For FY 2021 Quarter II (Q2), our audit objectives were to assess (1) the 

completeness, accuracy, timeliness, and quality of the financial and procurement 

award data submitted for publication on USASpending.gov,

6 and (2) CFTC’s 

implementation and use of Government-wide financial data standards 

established by OMB and Treasury.

Executive Summary

Overall, our audit noted that CFTC’s quarterly reporting and surrounding controls 

were effective to ensure the completeness, accuracy, and timeliness of agency 

submissions. This includes the appropriate use of the Government-wide financial 

data standards established by OMB and Treasury, the submission quality of 

summary-level data (Files A and B7), and the quality of record-level data and 

linkages (Files C8 and D1/D29). We also found File C suitable for sample testing 

and projected low error rates for completeness and accuracy of data elements. 

File C included Quarter I (Q1) transactions that were informational outlays. We 

concluded this did not impact DATA Act compliance because CFTC is preparing 

to fulfill an FY 2022 requirement10 to report cumulative outlays to the DATA Act 

Broker and management did not report them to the broker. CFTC’s service 

provider also completed systems updates to comply with a similar but earlier 

deadline for its CFO Act agency customers. With this forward-looking, early

transition to cumulative reporting, the Senior Agency Official appropriately 

certified the agency’s submission comfortably by the required due date, 

appropriately reported validation warnings, but made no explicit disclosure of Q1 

informational outlays.

Based on CIGIE’s scorecard to consistently evaluate and report on data quality

government-wide, CFTC’s submission is considered “excellent” quality – the 

highest of 4 ratings.

 

6 USASpending.gov provides detailed spending data for nearly all accounts across the Federal Government. 

Agencies are required to report financial and award data to USASpending.gov via the DATA Act Broker, a 

website used to securely upload, validate, and certify financial data in support of DATA Act compliance. 7 File A includes fiscal year cumulative Federal appropriations account summary-level data. File B includes 

fiscal year cumulative Federal object class and program activity summary-level data. In accordance with 

FAEC guidance, we determined whether File A included all Treasury Account Symbols (TAS) from which 

funds were obligated (as reflected in the Government-wide Treasury Account Symbol Adjusted Trial Balance 

System (GTAS) SF-133), except for Loan Financing Accounts; and assessed the completeness of File A by 

selecting all summary-level data from File A and matching certain elements to agency records. FAEC 

guidance, page 16. 

8 The File C Award Financial Detail report is generated monthly and submitted to the Treasury Broker.

9 In accordance with the FAEC guide, sample awards reported in File C should be linked to applicable data 

elements reported in Files D1 and D2 or vice versa. FAEC guidance, page 21.

10See, OMB-20-21, Implementation Guidance for Supplemental Funding Provided in Response to the 

Coronavirus Disease 2019 (COVID-19), April 10, 2020. 
3

Recommendation:

To improve disclosures in DATA Act submissions we recommended the 

Accounting Officer report items of significance such as informational outlays.

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

Managements Comments

We provided the Accounting Officer a draft copy of the report. To improve DATA

Act reporting, he agreed to enhance disclosures as appropriate with its 

submissions. Management actions are responsive to the recommendation. 

We completed our audit in accordance with GAGAS. This report is intended 

solely for the use of management of the CFTC and Congress and should not be 

used by those who have not agreed to the procedures and taken responsibility 

for the sufficiency of the procedures for their purposes. See Appendix A for

further audit details, Appendix B for additional background, scope, and 

methodology and Appendix C for management response dated September 27, 

2021.

We will publish this report on the Office of the Inspector General’s web page and 

the report will be summarized in our September 2021 Semiannual Report to 

Congress. If you have any questions, please contact me at (202) 418-5084 or 

Branco Garcia, lead auditor, at (202) 418-5013.

cc:

United States Senate Committee on Homeland Security and Governmental 

Affairs

Chairman and Ranking Member

340 Dirksen Senate Building

Washington, DC 20510

United States House Committee on Oversight and Reform

Chairman and Ranking Member

2157 Rayburn House Office Building

Washington, DC 20515
4

United States Senate Committee on the Budget

Chairman and Ranking Member

624 Dirksen Senate Office Building

Washington, DC 20510

United States House Committee on the Budget

Chairman and Ranking Member

204-E Cannon House Office Building

Washington, DC 20515

GAO at DATAActImplementation@gao.gov

Treasury IG at DATAAct@oig.treas.gov

David Gillers, Chief of Staff

Summer Mersinger, Chief of Staff

Erik F. Remmler, Chief of Staff

Anthony C. Thompson, Executive Director and Chief Administrative Officer

Joel Mattingley, Chief Financial Officer

Keith Ingram, Accounting Officer

A. Roy Lavik, Inspector General 

Judith A. Ringle, Deputy Inspector General and Chief Counsel
5

Appendix A

Internal Controls

We assessed internal controls and compliance with laws and regulations 

necessary to satisfy the audit objective. A control deficiency in internal control 

exists when the design or operation of a control does not allow management or 

employees to prevent or detect and correct errors on a timely basis. A significant 

deficiency is a control deficiency or a combination of control deficiencies that 

adversely affects CFTC’s ability to initiate, authorize, record, process, or report 

financial data reliably. A material weakness is a significant deficiency, or 

combination of significant deficiencies, that results in more than a remote 

likelihood that a material error will not be prevented or detected. However, 

because our review was limited to these internal control components and 

underlying principles, it may not have disclosed all internal control deficiencies 

that may have existed at the time of this audit.

We assessed CFTC’s payment (spending) reporting risk “low” because:

• FY 2019 and 2020 internal control tests performed by independent public 

accountants contracted by OIG did not identify material control 

deficiencies for payments. Our review of the IPA’s internal control work 

papers and test results also did not reveal control deficiencies for this 

matter.

• CFTC executed mitigation strategies documented in its Data Quality Plan 

(DQP) to ensure Files A-F are valid and reliable. 

• CFTC service provider (Department of Transportation ESC)11 validations 

support the principles of data quality; ensuring completeness, accuracy, 

and timeliness of submission(s).

• CFTC’s accounting system service provider did not disclose material 

payment weaknesses in their independent audit report.

12

• Our independent analytic Z tests of Q2 data showed a .12% potential 

payment integrity risk which considered attributes of completeness, 

accuracy, and timeliness. 

 

11 Department of Transportation’s Enterprise Services Center (ESC) is used for operation and maintenance 

of the CFTC’s financial management and procurement systems (known as Delphi and PRISM, respectively).

ESC is located at the Federal Aviation Administration's Center in Oklahoma City, Oklahoma. 12 The American Institute of Certified Public Accountants (AICPA) Statements on Standards for Attestation 

Engagements 18 (SSAE-18) examination of Delphi for the period covering October 1, 2019, through June 

30, 2020, was conducted by KPMG LLP. KPMG concluded that management presented its description of 

ESC controls fairly in all material respects and that the controls, as described, were suitably designed and 

operating effectively for all stated control objectives. DOT ESC, FY 2020 Agency Financial Report (2020), 

page 23. 
6 

Data Standards 

We have evaluated CFTC’s implementation of the government-wide financial 

data standards for award and spending information and determined the CFTC is 

using the standards as defined by OMB and Treasury.

13 

CFTC linked by common identifiers (e.g., PIID, FAIN), all of the data elements in 

the agency’s procurement and financial systems, as applicable. For the 

Treasury’s DATA Act Broker files tested, we generally found that the required 

elements were present in the file and that the record values were presented in 

accordance with the standards.

CFTC had no responsibility for additional data element and reporting 

responsibilities required by the CARES Act as communicated in OMB-20-21. 

Non-Statistical Results

Completeness of the Agency DATA Act Submission

We evaluated CFTC’s DATA Act submission to Treasury’s DATA Act Broker and 

determined that the submission was complete. To be considered a complete 

submission, we evaluated Files A, B and C to determine that all transactions and 

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

noted transactions from Q1 were intended as informational outlays in Q2 

because CFTC is preparing to fulfill a FY 2022 requirement to report cumulative 

outlays to the DATA Act Broker.

Timeliness of the Agency DATA Act Submission

We evaluated CFTC’s fiscal year 2021 Q2 DATA Act submission to Treasury’s 

DATA Act Broker and determined that the submission was timely. To be 

considered timely, it had to be submitted and certified by April 29th and May 17th

2021, respectively, per the below reporting schedule. 

 

13 The DATA Act Information Model Schema Reporting Submission specification provides standards and 

definitions for Files A, B, and C that specify how each file should be prepared for the DATA Act Broker, 

including common heading titles for each file.

Period Period End GTAS Reporting Window Agency Deadline for 

Program Activities 

DATA Act Submission 

Start Date

DATA Act Monthly 

Due Date

DATA Act Certification 

Date

March

P06 March 31, 2021 Tuesday, April 6, 2021, 8 a.m. ET

Friday, April 16, 2021, 2 p.m. ET April 2, 2021 April 19, 2021 April 29, 2021 May 17, 2021

FY 2021 DATA Act Monthly Reporting Window Schedule
7 

CFTC’s Senior Accountable Officer (SAO) certified the Q2 submission 

comfortably before the schedule’s due dates as pictured below.

Completeness of Summary-Level Data for Files A and B

We performed summary-level data reconciliations and linkages for Files A and B 

and did not identify any variances. The test results verified: (1) summary-level 

data from File A matched the Agency's GTAS SF-133; (2) the totals and TAS 

identified in File A matched File B; and (3) all object class codes from File B 

match codes defined in Section 83 of OMB Circular No. A-11.

Results of Linkages from File C to Files B/D1/D2

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

program activity, the linkages between File C to File D1 by both the PIID and 

Parent Award ID. All of the TAS, object class, and program activity data elements 

from File C existed in File B and all of the PIIDs/Parent Award IDs from File C 

existed in File D1/D2; and all PIIDs/Parent Award in Files D1/D2 existed in File 

C.

Analysis of the Accuracy of Dollar Value-related Data Elements

For applicable dollar related PIID data elements, we found no accuracy errors in 

our selected samples. The Federal Award Identification Number amounts were 

not applicable to CFTC given it does not administer financial assistance awards 

or grants.

Accuracy of Dollar-Value Related Data Elements

PIID

Data 

Element

Accurate Not 

Accurate

Total 

Tested

Error 

Rate

Absolute Value of 

Errors

14

Current 

Total Value

61 0 61 0% $0.00

15 61 0 61 0% $0.00
8

Accuracy of Dollar-Value Related Data Elements

Potential 

Total Value 

of Award

53

Obligation

61 0 61 0% $0.00

Total 183 0 183 0% $0.00

Statistical Results 

Sample results projected low error rates for completeness and accuracy of data 

elements. However, sample testing for timeliness of File C data elements 

showed a significant number of Q1 transactions (nearly 51%) reported in Q2. 

Transactions from Q1 are considered informational outlays in Q2 because CFTC 

is preparing to fulfill a FY 2022 requirement to report cumulative outlays to the 

DATA Act Broker beginning FY 2022. CFTC’s service provider also completed 

system updates to comply with an earlier similar deadline for its CFO Act agency 

customers. Management did not report informational outlays to the DATA Act 

Broker and thus did not impact DATA Act compliance. As such, we considered 

this condition short-lived and cost-effective, and adjusted our sample projection 

accordingly.

Results of PIID Statistical Sample Testing 

Incomplete Inaccurate Untimely

# Sample 

Errors

0 1 0

Projected 

Error Rate

0.00% 3.33% 0%

Note: Revised universe 30514 and sample size is 30. Max projected error rate is 8.9%, 16.4%, 

and 8.9%, respectively.

 

14 Original Sample Universe = 649 transactions of which 344 transactions were from Q1 and 305 

transactions were from Q2 (Revised Sample Universe).
9

Quality Determination 

Without informational outlays, CFTC scored 98.998 points, which is a quality 

rating of “Excellent”.

Criteria Score Quality Level

Maximum Points Possible

Without Outlays

(No COVID-19 

Funding)

With Outlays

(COVID-19 

Funding)

FY 2021 DATA Act

Quality Scorecard

U.S. CFTC

Timeliness of Agency 

Submission

5.0 5.0 5.0 Level

Completeness of Summary

Level Data (Files A & B) 13.0 13.0 10.0 0.0 69.9 Lower

Suitability of File C for 

Sample Selection

13.0 13.0 10.0 70.0 84.9 Moderate

Record-Level Linkages

(Files C & D1/D2) 9.0 9.0 7.0 85.0 94.9 Higher

COVID-19 Outlay Testing

Non-Statistical Sample No COVID-19 Funding 0.0 8.0 95.0 100 Excellent

Range

Non-Statistical

Completeness 15.0 15.0 15.0

Accuracy 29.0 30.0 30.0

Timeliness 15.0 15.0 15.0

Quality 

Score Excellent 98.998 100.0 100.0 Statistical
10

Appendix B

Background

The Digital Accountability and Transparency Act of 2014 (DATA Act) which is 

derived from Federal Funding Accountability and Transparency Act of 2006 

(FFATA) required Federal agencies to disclose direct expenditures and link 

contract, loan, and grant spending information to agency programs. The DATA 

Act also requires federal agencies to report such financial and award data to the 

U.S. Department of the Treasury (Treasury) in accordance with Governmentwide 

financial data standards or data elements established by the Office of 

Management and Budget (OMB) and Treasury. In May 2017, Treasury began 

displaying on USASpending.gov federal agencies’ financial and award data 

submitted pursuant to the DATA Act.

In order to support federal agencies, OMB issued memoranda outlining how 

agencies are to implement new and existing reporting requirements and link 

information in Federal financial systems to Federal award management 

systems15. OMB also required agencies to develop a Data Quality Plan (DQP) by 

the end of fiscal year FY 2019.16 The federal agency DQP needed to consider 

incremental risks to data quality in Federal spending data and any controls that 

would manage such risks in accordance with OMB Circular No. A-123.

17

In addition, Treasury developed a DATA Act Implementation Playbook 

(Playbook). The Playbook provides a high-level discussion of the vision and 

objectives of the DATA Act and an eight-step implementation plan for federal 

agencies to develop methodologies for implementing the DATA Act.

A core requirement of the DATA Act is the development of Governmentwide 

financial data standards to ensure the reporting of reliable, consistent Federal 

spending data. In May 2015, OMB and Treasury finalized 57 data definition 

standards, which Treasury used to develop the initial draft of the DATA Act 

Information Model Schema (DAIMS or Schema).8 The Schema gives an overall 

view of the hundreds of distinct data elements used to explain how Federal 

dollars are spent. The Schema also provides agencies technical guidance about 

what data to report to Treasury, including sources of data elements and the 

submission format.

 

15 OMB Memorandum M-15-12, Increasing Transparency of Federal Spending by Making Federal Spending 

Data Accessible, Searchable, and Reliable (May 8, 2015); and OMB Memorandum M-17-04, Additional 

Guidance for DATA Act Implementation: Further Requirements for Reporting and Assuring Data Reliability 

(November 4, 2016).

16 OMB Memorandum M-18-16, Appendix A to OMB Circular No. A-123, Management of Reporting and 

Data Integrity Risk (June 6, 2018).

17 OMB Circular No. A-123, Management's Responsibility for Enterprise Risk Management and Internal 

Control (July 15, 2016).
11

To comply with the DATA Act, on a quarterly basis, federal agencies must ensure

and attest that their spending data are valid and then submit the data to Treasury 

for publication on USAspending.gov by uploading the data to Treasury’s DATA 

Act Broker (Broker). The Broker is a system that receives agency data, validates 

the data against the Schema, and tests linkages between financial data produced 

by agencies with other spending data on Federal awards, including grants, loans, 

and procurement data. While agencies submit some data to the Broker, the 

Broker extracts other data from existing Governmentwide reporting systems and 

helps ensure the files are in the standard format. Specifically, agencies submit to 

the Broker data in files known as File A, File B, and File C, and the Broker 

extracts from existing systems data to generate files known as File D1, File D2, 

File E, and File F. 

Table 1 describes each file and its source.

Name Data Description Data Source

File A Appropriations Accounts Agency

File B Object Class and Program Activity Agency

File C Award Financial Agency

File D1 Award Procurement Agency

File D2 Award Financial Assistance Agency

File E Additional Awardee Attributes Agency

File F Sub-Award Attributes Agency

Under an interagency agreement with a Federal shred service provider, the 

Department of Transportation’s Enterprise Services Center (ESC) provides 

operation and maintenance of the CFTC’s financial management and 

procurement systems (known as Delphi and PRISM). Since CFTC is responsible 

for agency compliance with the DATA Act, it depends on ESC to inventory and 

map data elements, make system changes needed to create files submitted to 

Treasury, and submit required files by the deadlines established in the DATA Act. 

Thus, providing system support for CFTC to fulfill its reporting obligation under 

the DATA Act. ESC followed the eight-step implementation plan from the DATA 

Act Implementation Playbook18 for system development and published 

procedures19 for its use which includes data validations. Those tasks that the 

CFTC cannot perform are delegated to ESC, monitored, and discussed monthly 

with the Chief Financial Officer/Senior Accountable Officer. Since initial reporting 

requirements, ESC has made system updates to comply with additional DATA

Act requirements embedded in the CARES Act of 2020.

 

18 Treasury released versions 1.0 and 2.0 of the DATA Act Implementation Playbook in June 2015 and June 

2016, respectively.

19 AMKWI-333-334-335-00032 DATA Act Bulk File Submission.
12

Scope and Methodology

We followed the CIGIE FAEC Inspectors General Guide to Compliance under the 

DATA Act, dated December 4, 2020, to complete our audit.

The DATA Act requires the Inspector General (IG) of each Federal agency to 

audit a statistically valid sample of the spending data submitted by its Federal 

agency and submit to Congress a publicly available report assessing the 

completeness, accuracy, timeliness, and quality of the data sampled; and the 

agency’s implementation and use of the Governmentwide financial data 

standards. The first IG reports were due to Congress in November 2016; 

however, Federal agencies were not required to submit spending data until May 

2017. To address this timing anomaly, in 2016 some Federal IGs, including the 

CFTC IG, conducted readiness reviews of agencies’ progress toward compliance 

with the DATA Act. The IG community, including the CFTC IG,20 provided 

Congress the first required reports in November 2017,21 with subsequent reports 

following on a 2-year cycle, in November 201922 and this year’s, due in 

November 2021.

To foster a consistent methodology and reporting approach across the IG 

community, the Council of the Inspectors General on Integrity and Efficiency’s 

(CIGIE) Federal Audit Executive Council (FAEC) established the DATA Act 

Working Group (Working Group). The Working Group consulted with the U.S. 

Government Accountability Office (GAO) to develop the December 4, 2020, 

CIGIE FAEC Inspectors General Guide to Compliance under the DATA Act (the 

IG Guide).23 According to the IG Guide, IGs should comply with GAO’s 

Government Auditing Standards and conduct a performance audit of their 

component agency’s FY 2020 Q3 through FY 2021 Q2 financial and award data 

submitted for publication on USASpending.gov. In coordination, as part of the 

third mandated DATA Act audit, IGs must assess and report on:

• agency internal controls and any identified control deficiencies that may 

adversely impact the completeness, accuracy, timeliness, and quality of 

the FY 2021 Q2 data submitted, or the implementation and use of the data 

standards;

• the completeness and timeliness of the FY 2021 Q2 submission, including 

assessing the completeness of Files A, B, and C;

• summary-level data linkages between Files A, B, and C;

 

20 U.S. Commodity Futures Trading Commission Compliance with DATA Act of 2014 – Readiness Review in 

Fiscal Year (FY) 2016. 21 Compliance with DATA Act of 2014 - Reporting Accuracy (FY 2017 Quarter II). 22 CFTC’s Compliance with the Digital Accountability and SUBJECT: Transparency Act (DATA Act) of 2014 

(FY 2019 Quarter 1). 23 CIGIE FAEC Inspectors General Guide to Compliance Under the DATA Act, December 4, 2020.
13

• the results of prescribed test work;24 and

• the final determination of the agency’s implementation and use of the data 

standards.

To evaluate completeness, timeliness, accuracy overall quality of CFTC’s FY 

2021 Q2 submission, we assessed internal controls over the CFTC procurement 

cycle to determine the appropriate level of risk and tested a sample of File C 

transactions among other non-statistical tests. The Inspectors General guide 

included a detail testing spreadsheet tool to facilitate tests of details and a 

scorecard, which we used to analyze and conclude on the quality of data 

submissions, respectively. The CFTC does not administer federal awards and 

thus our tests were designed for CFTC’s procurement operations and payment 

reporting.

In reference to internal controls, management is responsible for the design, 

implementation, and operating effectiveness of the agency’s internal controls. We 

assessed applicable internal controls to determine the nature, timing, and extent 

of testing in accordance with GAO’s Standards for Internal Control in the Federal 

Government. As part of our assessment, we reviewed FMB’s fiscal year 2020 

management assurance statements and risk assessments and determined that 

no significant deficiencies or material weaknesses were identified. Also, we relied 

on internal control and substantive testing performed by the Department of 

Transportation OIG, which included a review of ESC’s quality controls and 

concluded that ESC suitably designed and implemented internal controls over 

hosting and operating Delphi and PRISM; source systems for data submitted to 

Treasury. We also verified that the SAO’s designee timely certified the CFTC’s 

FY 2021 Q2 submission to the Broker.

In addition, we inspected CFTC’s FY 2021 Q2 submission to evaluate data 

elements and summary transactions. We selected a statistically valid sample of 

underlying transaction data representing payments. Management reconciled 

underlying payment data to summary transactions submitted in order for us to 

test accordingly. As such we determined our sample size, 61,

25 based on FAEC’s 

formula26 for a smaller population. Our sample was selected from a population of 

649 reportable transactions using a confidence level of 95% and an expected 

 

24 Results of prescribed test work include: (1) the results of summary-level testing of Files A and B; (2) the 

projected error rates for completeness, accuracy, and timeliness of the statistical sample from Files C and D; 

(3) the final determination of the quality of the data; and (4) supplemental reporting of the results of the 

sample testing.

25 We used RAT-STATS version 4 to select sample and project attribute results. RAT-STATS is a free 

statistical software package created by the Department of Health and Human Services (HHS) OIG in the late 

1970; among other tasks, the software assists the user in selecting random samples and estimating 

improper payments. See, HHS OIG, RAT-STATS - Statistical Software. 26 Where the recommended sample size of 385 represents 5 percent or more of the population, we reduced 

the sample size by applying the finite correction factor 385/[1+(385/N)], where “N” represents the population 

size. Figure 2 presents the inputs associated with our simple random sample.
14

error rate of 20%. We adjusted our sample size accordingly to address 

informational outlays in file C.

We measured whether all applicable data elements required by the DATA Act 

were included or complete. Timeliness was measured as the percentage of 

transactions reported appropriately within the period and submitted within 30 

days of quarter end. Accuracy was measured by agreement with the systems of 

record and supporting documentation. 

In summary, we reviewed:

• assessments of relevant risks and internal controls as reported in FY 2019

– FY 2020 management assurance statements for Office of 

Administration;

• FY 2020 Agency Financial Report:

• FY 2020 FISMA Compliance Report;

• CFTC’s enterprise risk management (ERM) risk profile, as of July 2020; 

• CFTC’s DQP;

• SSAE 18 for Department of Transportation and its OIG as it pertains to 

ESC; and ESC SOP to understand procedures for certifying and 

submitting files to the Broker and the steps financial management branch 

took to validate the CFTC’s FY 2020 Q2 submission.

We conducted this audit in accordance with GAGAS. Systems data used for our 

audit was sufficiently reliable to support the findings, conclusions and 

recommendations in our report.27

 

27 We considered the Government Accountability Office publication Assessing the Reliability of ComputerProcessed Data, GAO-09-680G (July 2009) (p.19) to assess accuracy for this purpose. We determined that 

contract data were sufficiently reliable and thus accurate for the purposes of this report.
15

Appendix C 

Management Response 
16
17