U.S. RAILROAD RETIREMENT BOARD

OFFICE OF INSPECTOR GENERAL 

Audit of Railroad Retirement 

Board’s Digital Accountability 

and Transparency Act of 2014 

Submission for First Quarter of 

Fiscal Year 2019

Report No. 20-01 November 6, 2019
OFFICE OF INSPECTOR GENERAL

U.S. RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of 

Fiscal Year 2019

Report Summary November 6, 2019 Report No. 20-01

What We Found

Our audit determined that the Railroad Retirement Board (RRB)

generally submitted complete, accurate, and high quality 

financial and award data for its first quarter of fiscal year 2019

publication on USASpending.gov, which consisted of $4.1 billion 

in obligations. As of December 2018, the RRB’s obligation 

amount was in the top 20 for the Federal Government. 

However, we determined improvements could be made to 

internal controls over the Digital Accountability and 

Transparency Act of 2014 (DATA Act) submission, the 

completeness and accuracy of the agency’s File B submission,

the timeliness of the Senior Accountable Official’s (DATA Act)

certification, and the completeness and accuracy of Files D1 and 

D2.

Further, we determined that the RRB generally implemented 

and used the governmentwide financial data standards 

established by the Office of Management and Budget and the 

Department of the Treasury, in accordance with standards. 

However, we did identify improvements that could be made to 

the reporting of financial assistance awards containing 

personally identifiable information and resolving gaps between 

authoritative data sources and RRB’s actual data sources.

What We Recommend

To address the exceptions identified in this audit, we made 

11 recommendations for improving the RRB’s DATA Act policies 

and procedures, internal controls, and the overall DATA Act 

submission.

RRB management concurred with all of our recommendations. 

The Bureau of Fiscal Operations has provided target completion 

dates in its management comments as provided in the 

appendix. However, the Bureau of the Actuary and Research 

has not provided target completion dates in its management 

comments.

What We Did 

The DATA Act required the 

Inspector General of each federal 

agency to review a statistically 

valid sample of the spending data 

submitted under the DATA Act; 

and submit to Congress and make 

publicly available a report 

assessing the completeness, 

timeliness, quality, and accuracy of 

the data sampled and the 

implementation and use of data 

standards by the federal agency. 

The objectives of this audit were to

assess the completeness, accuracy, 

timeliness, and quality of the first 

quarter of fiscal year 2019 financial 

and award data submitted by the 

RRB for publication on 

USASpending.gov; and assess the 

RRB’s implementation and use of 

the governmentwide financial data 

standards established by the Office 

of Management and Budget and 

the Department of the Treasury.

The scope of the audit was first 

quarter of fiscal year 2019 data the 

RRB submitted for publication on 

USASpending.gov, and any 

procedures, certifications, 

documentation, and controls to 

achieve this process. 
OFFICE OF INSPECTOR GENERAL – U.S. RAILROAD RETIREMENT BOARD 

 

Contents

INTRODUCTION 1

OBJECTIVES, SCOPE, AND METHODOLOGY 1

BACKGROUND 2

RRB DATA ACT REPORTING PRIMARY ROLES AND RESPONSIBILITIES 6

RESULTS OF AUDIT 8

RRB’S INTERNAL CONTROLS OVER DATA ACT REPORTING WERE GENERALLY EFFECTIVE BUT NEED 

IMPROVEMENT 9

CONSIDERATION AND USE OF THE RRB’S DATA QUALITY PLAN NEEDS IMPROVEMENT 9

MANAGEMENT’S WRITTEN ASSURANCE AND STATEMENT OF ACCOUNTABILITY WAS 

INCOMPLETE 10

RRB’S DATA ACT POLICIES AND PROCEDURES NEED IMPROVEMENT 11

RECOMMENDATIONS 12

MANAGEMENT’S COMMENTS AND OUR RESPONSE 13

RRB’S DATA ACT CERTIFICATION AND SUBMISSION WERE GENERALLY COMPLETE BUT NEED 

IMPROVEMENT ON TIMELINESS AND ACCURACY 13

THE AGENCY’S SUBMISSION FOR FILES A, B, AND C WAS GENERALLY COMPLETE 13

ACCURACY OF SUMMARY-LEVEL DATA FOR FILES A AND B AND LINKAGES NEED 

IMPROVEMENT 14

THE AGENCY’S SUBMISSION WAS NOT TIMELY 18

SAMPLE RESULTS – THE RRB’S DATA WAS OF HIGHER QUALITY 18

RECOMMENDATIONS 20

MANAGEMENT’S COMMENTS AND OUR RESPONSE 20

THE RRB’S IMPLEMENTATION AND USE OF THE DATA STANDARDS COULD BE IMPROVED 20

SOME FINANCIAL ASSISTANCE AWARDS CONTAINING PERSONALLY IDENTIFIABLE 

INFORMATION WERE INCORRECTLY REPORTED 21

GAPS EXIST BETWEEN AUTHORITATIVE SOURCES AND ACTUAL SOURCES 21

RECOMMENDATIONS 23

MANAGEMENT’S COMMENTS AND OUR RESPONSE 23

APPENDIX I: MANAGEMENT COMMENTS 24

APPENDIX II: MANAGEMENT COMMENTS 27

APPENDIX III: SAMPLING METHODOLOGY 29
OFFICE OF INSPECTOR GENERAL – U.S. RAILROAD RETIREMENT BOARD 

 

SCOPE 29

REVIEW METHODOLOGY 29

RESULTS 30

CONCLUSION 31

APPENDIX IV: RRB’S RESULTS FOR THE DATA ELEMENTS 33

APPENDIX V: BASIC VALIDATION RULES FOR AGGREGATE AND NON-AGGREGATE REPORTING 36

APPENDIX VI: ANOMALY LETTER 37

LIST OF TABLES

TABLE 1. RRB’S DATA ACT FILES 5

TABLE 2. RRB’S REPORTED AMOUNTS BY FEDERAL ACCOUNT – FIRST QUARTER OF FISCAL YEAR 2019 6

TABLE 3. QUALITY, COMPLETENESS, ACCURACY, AND TIMELINESS DEFINITIONS 8

TABLE 4. OIG EVALUATION OF FILES A, B, AND C 14

TABLE 5. FILE A TO FILE B VARIANCES RULE A18 15

TABLE 6. FILE A TO FILE B VARIANCES RULE A19 16

TABLE 7. LEVELS OF DATA QUALITY 18

TABLE 8. DATA ACT AUTHORITATIVE SOURCE AND RRB’S SOURCE SYSTEM 22

TABLE 9. RRB RESULTS PER SAMPLE RECORD 31

TABLE 10. RRB’S RESULTS FOR DATA ELEMENTS 33
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 1

INTRODUCTION

This report presents the results of the Office of Inspector General’s (OIG) audit of the Railroad 

Retirement Board’s (RRB) compliance with the Digital Accountability and Transparency Act of 

2014 (DATA Act), as mandated.

1 The RRB reported $4.1 billion in obligations on 

USASpending.gov for the first quarter of fiscal year 2019. At that time, the RRB’s obligated 

amount was in the top 20 for the Federal Government.

Objectives, Scope, and Methodology

The objectives of this audit were to

 assess the completeness, accuracy, timeliness, and quality of the first quarter of fiscal 

year 2019 financial and award data submitted by the RRB for publication on 

USASpending.gov; and

 assess the RRB’s implementation and use of the governmentwide financial data 

standards established by the Office of Management and Budget (OMB) and the 

U.S. Department of the Treasury (Treasury).

The scope of the audit was first quarter of fiscal year 2019 financial and award data the RRB 

submitted for publication on USASpending.gov, and applicable procedures, certifications, 

documentation, and controls to achieve this process.

To accomplish the audit objectives, we

 identified criteria from the law as well as OMB governmentwide guidance; 

 reviewed the Council of the Inspectors General on Integrity and Efficiency (CIGIE) Federal 

Audit Executive Committee (FAEC) Inspectors General Guide to Compliance under the 

DATA Act (CIGIE FAEC Guide);

2

 interviewed applicable management, staff, and key personnel;

 assessed the internal and information system controls in place for the extraction of data 

from the source systems and for the reporting of data to Treasury’s DATA Act Broker; 

 reviewed and reconciled the first quarter of fiscal year 2019 summary-level data 

submitted by the RRB for publication on USASpending.gov, including Files A, B, and C; 

 1 Pub. L. No. 113-101 (2014). 2 Unless otherwise indicated, from this point forward in the report the term “CIGIE FAEC Guide” will imply Council 

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

General Guide to Compliance under the Digital Accountability and Transparency Act of 2014 (DATA Act),

(Washington, D.C.: February 14, 2019). 
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 2

 reviewed a statistically valid sample from first quarter of fiscal year 2019 financial and 

award data submitted by the RRB for publication on USASpending.gov, including 

Files A, B, C, D1, and D2; 

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

data sampled; and 

 assessed the RRB’s implementation and use of the 57 data elements and standards 

established by OMB and Treasury.

We did not assess Files E or F as the quality of this data is the legal responsibility of the awardee

in accordance with terms and conditions of federal agreements. The RRB and other federal 

agencies are not responsible for certifying the quality of data reported by awardees.

We adhered to the overall methodology, objectives, and audit procedures outlined in the CIGIE 

FAEC Guide.

We considered the DATA Act date anomaly as determined by CIGIE. CIGIE identified a timing 

anomaly with the oversight requirements contained in the DATA Act. That is, the first Inspector 

General reports were due to Congress on November 2016; however, federal agencies were not 

required to report spending data until May 2017. To address this reporting date anomaly, the 

Inspectors General provided Congress with their first required reports by November 2017, 

one year after the statutory due date, with two subsequent reports to be submitted following a 

2-year cycle. On December 22, 2015, CIGIE’s chair issued a letter detailing the strategy for 

dealing with the Inspector General reporting date anomaly and communicated the strategy to 

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

Committee on Oversight and Government Reform.3 A copy of the CIGIE letter can be found in 

Appendix VI.

We conducted this performance audit 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 objective. We believe that the evidence obtained provides a reasonable 

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

We conducted our fieldwork at RRB headquarters in Chicago, Illinois, from May 2019 through 

October 2019.

Background

The RRB is an independent agency in the executive branch of the Federal Government. The 

agency administers comprehensive retirement/survivor and unemployment/sickness insurance 

benefit programs for railroad workers and their families under the Railroad Retirement Act and 

the Railroad Unemployment Insurance Act. These programs provide income protection during 

old age and in the event of disability, death, temporary unemployment, or sickness. 

 3 CIGIE FAEC Guide.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 3

During fiscal year 2018, RRB paid retirement and survivor benefit payments totaling 

approximately $13.1 billion to about 540,000 retirement and survivor beneficiaries. RRB also 

paid net unemployment/sickness benefits of $100.2 million to about 25,000 claimants.

The DATA Act requires

...the Inspector General of each Federal agency, in consultation with the Comptroller 

General of the United States, shall—‘‘(A) review a statistically valid sampling of the 

spending data submitted under this Act by the Federal agency; and ‘‘(B) submit to 

Congress and make publically available a report assessing the completeness, 

timeliness, quality, and accuracy of the data sampled and the implementation and use 

of data standards by the Federal agency.

4

The DATA Act amended the Federal Funding Accountability and Transparency Act of 2006 

(FFATA), which required OMB to “...ensure the existence and operation of a single searchable 

website, accessible by the public at no cost....”5 The Act expanded FFATA in various aspects 

such as

 requiring the disclosure of direct federal agency expenditures and linkage of federal 

contract, loan, and grant spending information to federal programs so taxpayers and 

policy makers can more effectively track federal spending;

 establishing governmentwide data standards for financial data to provide consistent, 

reliable, and searchable governmentwide spending data that are displayed accurately 

for taxpayers and policy makers;

 simplifying reporting for entities receiving federal funds by streamlining reporting 

requirements and reducing compliance costs while improving transparency;

 improving the quality of data submitted by holding federal agencies accountable for the 

completeness and accuracy of the data submitted; and

 applying approaches developed by the Recovery Accountability and Transparency Board 

to spending across the Federal Government.

The DATA Act charged OMB and Treasury with issuing guidance on the data standards needed 

to implement the DATA Act and required full disclosure of federal funds on the public website 

USASpending.gov no later than May 2017.6 The DATA Act further required the Secretary of the 

Treasury, in consultation with the Director of OMB, to ensure that the information is posted to 

the public website at least quarterly, but monthly when practicable. The DATA Act did not 

provide any additional funding dedicated to its implementation.

Treasury published 57 data definition standards and required federal agencies to report 

financial data in accordance with these standards for DATA Act reporting, beginning 

January 2017.7 These standards ensure consistency across departments and agencies and 

 4 Pub. L. No. 113-101 (2014). 5 Pub. L. No. 109-282 (2006). 6 Office of Management and Budget (OMB), Increasing Transparency of Federal Spending by Making Federal 

Spending Data Accessible, Searchable, and Reliable, OMB Memorandum M-15-12 (Washington, D.C.: May 8, 2015). 7 Pub. L. No. 113-101 (2014).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 4

define the specific data elements agencies must report under the DATA Act, such as 

appropriation account, object class, expenditures, and program activity. Not all data elements 

are required for every file. This information is published in the DATA Act Information Model 

Schema (DAIMS), which provides agencies an overall view of the hundreds of distinct data 

elements included in agencies’ DATA Act files. 

According to OMB guidance, to ensure maximum transparency in federal spending, agencies 

must report each financial assistance award at the most granular level practicable while 

protecting personally identifiable information (PII).

8 Given the required data collections, if 

reporting at the single award level is not practicable, agencies may report at the county level, 

and if not practicable, aggregated at the state level, consistent with the following:

 Single Awards Containing PII: Agencies should report single awards at the award-level to 

the maximum extent practicable. If an agency captures a Federal Award Identification 

Number (FAIN) and other details for an award to an individual, the agency should report 

that award to USASpending.gov as a single, discrete record. Records reported in this 

way will be linked using the FAIN as the award identification, with any PII redacted by 

the agencies before submission.

 Aggregated Awards - County Level: If single award-level reporting is not practicable, 

agencies may report at the county level. If an agency does not capture a FAIN or other 

individual details for an award to an individual, the agency should include that award in 

a county-level aggregate record with other similar awards. Records reported in this way 

must be linked using the Unique Record Identifier (URI).

 Aggregated Awards - State Level: If neither single award-level reporting nor county-level 

reporting is practicable, agencies may report at the state level. Records reported in this 

way must be linked using the URI.

The RRB reported its financial assistance awards by aggregating the data at the county level. 

The RRB’s DATA Act submission was comprised of the following files, as shown in Table 1.

 8 OMB, Additional Guidance for DATA Act Implementation: Further Requirements for Reporting and Assuring DATA 

Reliability, OMB Memorandum M-17-04 (Washington, D.C.: November 4, 2016).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 5

Table 1. RRB’s DATA Act Files

File Name Description Number of 

Records

File A – Appropriations 

Account

Included the appropriations account detail 

information aligned to SF-133 Report on Budget 

Execution and Budgetary Resources (SF-133).

34

File B – Program Activity and 

Object Class

Included the object class and program activity 

detail information based on the SF-133s.

331

File C – Award Financiala Included the award level financial detail 

information from agency financial and award 

systems (FMIS, PREH, MBF, and MACRO).

b

33,125

File D1 – Award Attributes 

(Procurement)

Contained the award and awardee attributes for 

procurement sourced from Federal Procurement 

Data System – Next Generation (FPDS-NG).

70

File D2 – Award Attributes 

(Financial Assistance)

Contained the award and awardee attributes for 

financial assistance from Financial Assistant 

Broker Submission (FABS) submission process.

c

33,057

Source: RRB OIG Analysis of Files A through D2 and OMB M-17-04, Additional Guidance for DATA Act Implementation: Further 

Requirements for Reporting and Assuring DATA Reliability, November 4, 2016. a To view the additional details and attributes of File C, see Files D1/D2 in combination with File C.

b Financial Management Integrated System (FMIS) is the RRB’s financial system, whereas, Payment, Rate and Entitlement 

History File (PREH) is the system of record for payment, rates, and entitlement history. The Master and Clearance Records 

Online (MACRO) is a DB2 database which parallels the contents of the Railroad Unemployment Insurance Act master and 

clearance files, the system of record for unemployment and sickness benefits. c The Financial Assistance Broker Submission (FABS) portal replaced the Award Submission Portal (ASP).

Files A through C were generated by the RRB, and Files D1 and D2 were generated from the

DATA Act Broker. The DATA Act Broker extracted the agency’s information from the Federal 

Procurement Data System – Next Generation (FPDS-NG) and the Financial Assistance Broker 

Submission (FABS) portal for Files D1 and D2, respectively. During the submission process, the 

DATA Act Broker generates warnings and errors based on Treasury-defined rules. The results of 

validations are displayed in severity as a separate file, which contains errors and warning 

messages per DAIMS Validation Rules v1.3.1, dated February 8, 2019:

 Errors must be corrected before proceeding to the next step because these validations 

indicate incorrect values for fundamental data elements. Agencies are unable to submit 

data containing errors.

 Warnings will not prevent continuing to the next step because these messages may not 

indicate inaccuracies in the data. The warning messages were created to alert the 

agency to possible issues worth further review.

We determined that File B was the primary file that fed into USASpending.gov’s spending 

explorer. Using the explorer, a user could quickly view the RRB’s first quarter of fiscal year 2019

spending as shown in Table 2.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 6

Table 2. RRB’s Reported Amounts by Federal Account – First Quarter of Fiscal Year 2019

Name and Federal Treasury Account Symbol (TAS) Obligated Amount Percent of Total

Social Security Equivalent Benefit Account

060-8010

$1,894,233,965 46.20 %

Railroad Retirement Account

060-8011

$1,486,791,721 36.26 %

National Railroad Retirement Investment Trust

060-8118

$377,004,812 9.20 %

Federal Payments to the Railroad Retirement Accounts

060-0113

$231,294,627 5.64 %

Limitation on Administration

060-8237

$57,007,164 1.39 %

Railroad Unemployment Insurance Trust Fund, Administrative 

Expenses

060-8051a

$45,305,894 1.11 %

Dual Benefit Payments Account

060-0111

$4,536,252 0.11 %

Limitation on the Office of the Inspector General

060-8018

$3,764,331 0.09 %

Railroad Unemployment Insurance Extended Benefit Payments

060-0117

$2,141 Less than 0.01 %

Total $4.1 billion 100 %

Source: Data as of December 31, 2018 as it appeared on USASpending.gov. a Railroad Unemployment Insurance Trust Fund, Administrative Expenses full account number was 060X8051.002.

On June 6, 2018, OMB issued new guidance that required agencies to develop a Data Quality 

Plan (DQP). According to Appendix A to OMB Circular No. A-123, Management of Reporting and 

Data Integrity Risk (OMB M-18-16), DATA Act reporting agencies were required to implement a 

DQP effective fiscal year 2019 through fiscal year 2021 at a minimum. The guidance became 

effective immediately. The DQP must 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. Once developed by the agency, quarterly certifications of data 

submitted by the Senior Accountable Official (SAO), or the designee should be based on the 

consideration of the DQP and the internal controls documented by the agency.9

RRB DATA Act Reporting Primary Roles and Responsibilities

First quarter of fiscal year 2019 RRB DATA Act reporting was accomplished through 

coordination and cooperation efforts of the Bureau of Fiscal Operations (BFO), the Bureau of 

the Actuary and Research (Actuary), the Office of Administration’s Division of Acquisition 

 9 OMB, Appendix A to OMB Circular No. A-123, Management of Reporting and Data Integrity Risk, OMB M-18-16 

(Washington, D.C.: June 6, 2018).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 7

Management (AM), and RRB’s contractor, CGI Federal Incorporated (CGI). According to the RRB, 

they assigned the following bureaus and offices with primary roles and responsibilities:

 RRB’s Chief Financial Officer was designated as the SAO for RRB’s DATA Act activities. 

OMB’s DATA Act implementation guidance states that “[o]n a quarterly basis, agency 

Senior Accountable Officials must provide reasonable assurance that their internal 

controls support the reliability and validity of the agency account-level and award-level 

data they submit to Treasury for publication on USASpending.gov.”10

 The RRB’s SAO designee, also the DATA Act Certifier (Certifier), was appointed to certify 

the DATA Act files for publishing on USASpending.gov on behalf of the SAO. The Certifier

was responsible for ensuring that any warnings or errors returned by the DATA Act 

Broker had been acknowledged and signed off by the corresponding bureau points of 

contact, that the summary procurement and financial assistance awards matched the 

summary amounts provided in File C, and they add any comments to the submission as 

necessary. This individual works in BFO’s accounting section and reports to the SAO.

 BFO was assigned as the primary organizational unit that was responsible for compiling

and reporting all applicable data for the RRB’s DATA Act submission (Files A through D2). 

In addition, they conducted tasks associated with the roles of pre-broker reviewer, file 

submitter, bureau point of contact, post-broker reviewer, and contracting officer’s

representative for CGI.

 AM was the organizational unit that certified procurement records as complete, 

accurate, and timely (Files C and D1). Additionally, they were responsible for verifying, 

addressing, and investigating any discrepancies identified by pre and post-broker 

reviewers.

 Actuary was the organizational unit that certified financial assistance records as 

complete, accurate, and timely (Files C, D2, and their External Source FAADS+ File).

Additionally, they were responsible for verifying, addressing, and investigating any 

discrepancies identified by pre and post-broker reviewers.

 CGI was the RRB contractor that assisted in the file generation process, performed

maintenance on the pre-broker validation queries, performed maintenance on the 

DATA Act structured query language (SQL), assisted in the pre and post-broker review, 

assisted in resolving warnings or errors with the bureau points of contact, and assisted 

in certifying data.

 10 OMB, Additional Guidance for DATA Act Implementation: Implementing Data-Centric Approach for Reporting 

Federal Spending Information, OMB Management Procedures Memorandum (MPM) 2016-03 (Washington, D.C.: 

May 3, 2016).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 8

RESULTS OF AUDIT

Our audit determined that the RRB generally submitted complete, accurate, and high quality

financial and award data for its first quarter of fiscal year 2019 publication on USASpending.gov

and had generally effective internal controls over its DATA Act submission. However, we 

identified exceptions with the 1) internal controls related to the use of a DQP, management’s 

written assurance and statement of accountability, and the RRB’s DATA Act policies and 

procedures, 2) accuracy of the agency’s Files B submission, 3) process in addressing DATA 

Broker validation warnings and completing reconciliations, 4) timeliness of the SAO’s DATA Act 

certification, and 5) completeness and accuracy of Files D1 and D2. 

Quality, completeness, accuracy, and timeliness are defined in Table 3.

Further, we determined the RRB generally implemented and used the governmentwide

financial data standards established by OMB and Treasury. However, we did identify 

improvements that could be made to the reporting of financial assistance awards containing PII 

and resolving gaps between authoritative data sources and RRB’s actual data sources.

Table 3. Quality, Completeness, Accuracy, and Timeliness Definitions

Attribute Definition

Quality  Data that is complete, accurate, and reported on a timely basis.

Completeness  Agency Submission – Transactions and events that should have been 

recorded were recorded in the proper period.

 Data Elements – For each of the required data elements that should have 

been reported, the data element was reported in the appropriate Files A 

through D2.

Accuracy  Data Elements – Amounts and other data relating to recorded transactions 

have been recorded in accordance with the DAIMS, Reporting Submission 

Specification, Interface Definition Document, the online data dictionary, and 

agree with the authoritative source records.

Timeliness  Agency Submission – Reporting of the agency DATA Act submission to the 

DATA Act Broker is in accordance with the schedule established by the 

Treasury DATA Act Project Management Office.

 Data Elements – For each of the required data elements that should have 

been reported, the data elements were reported in accordance with the 

reporting schedules defined by the financial, procurement, and financial 

assistance requirements.

Source: CIGIE FAEC Guide.

We made 11 recommendations to address the exceptions identified. The full text of 

management’s responses to these recommendations has been included in Appendix I and II.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 9

RRB’s Internal Controls over DATA Act Reporting were Generally 

Effective but Need Improvement

We determined that RRB’s internal controls over its DATA Act submission were generally 

effective. The internal and information system controls for (1) the extraction of data from 

source systems and (2) the reporting of data to the DATA Act Broker were designed, 

implemented, and operating effectively to the extent of producing the financial assistance and 

award data necessary for DATA Act reporting. However, we determined the RRB could make 

internal control improvements related to the use of a DQP, management’s written assurance

and statement of accountability, and documentation of the RRB’s DATA Act policies and 

procedures.

Consideration and Use of the RRB’s Data Quality Plan Needs Improvement

The agency SAO did not base the first quarter’s DATA Act submission and certification of data 

on the DQP because its first DQP was not prepared until August 9, 2019 – four and half months 

after the submission was made on March 21, 2019.

Starting in fiscal year 2019, OMB guidance established that agencies must develop a DQP to

identify a control structure tailored to address identified risks. SAO quarterly certifications

should be based on the considerations of the agency’s DQP. Additionally, OMB guidance

requires that agencies consider their DQP in their annual assurance statement on internal 

controls over reporting, beginning in fiscal year 2019.11 According to OMB:

The Data Quality Plan should cover significant milestones and major decisions 

pertaining to:

• Organizational structure and key processes providing internal controls for 

spending reporting.

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

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

• Testing plan and identification of high-risk reported data, including specific 

data the agency determines to be high-risk that are explicitly referenced by 

the DATA Act, confirmation that these data are linked through the inclusion 

of the award identifier in the agency’s financial system, and reported with 

plain English award descriptions.

• Actions taken to manage identified risks.12

Because the DQP did not exist when the first quarter 2019 data was submitted, risks to data 

quality in the RRB’s spending data may not have been identified or managed. The RRB may also 

have imposed duplicative and unnecessary processes to publish their quarterly submissions,

due to the lack of a clear organizational structure and key processes to provide internal controls 

over financial and award data reporting. If the conditions we described are not corrected, the 

 11 OMB, M-18-16. 12 OMB, M-18-16.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 10

completeness, accuracy, timeliness, and quality of the data submitted, or implementation and 

use of the data standards in future DATA Act submissions may be adversely impacted.

Management’s Written Assurance and Statement of Accountability was 

Incomplete

During the RRB’s DATA Act submission, the RRB’s management (1) leveraged data quality and 

management controls established in statute, regulation, and governmentwide policy,

(2) aligned data quality controls with the internal control and risk management strategies in 

OMB M-18-16, and (3) did not identify any deficiencies in internal control or other limitations 

that would prevent the SAO from certifying that the data submitted for publication on 

USASpending.gov was complete, accurate, timely, of quality, and complied with the established 

governmentwide financial and award data standards. However, the SAO’s quarterly assurance 

statement, obtained from USASpending.gov, did not contain a statement of accountability to 

confirm the RRB’s efforts to support data quality and assurances on interconnectivity/linkages 

across all the data files.

According to OMB guidance, “[a]s stated in MPM 2016-03 agency DATA Act SAOs or their 

designees must provide a quarterly assurance that their agency's internal controls support the 

reliability and validity of the agency account-level and award-level data reported for display on 

USASpending.gov.”13 In general, the required assurance is a statement of accountability to 

confirm an agency’s efforts to support data quality. According to OMB guidance, the agency 

SAO assurances should be submitted quarterly through the DATA Act Broker process. This

process requires the SAO to assure that the alignment among Files A through F and the data in 

each file submitted for display on USASpending.gov were valid and reliable.14

During the DATA Act submission process, the RRB identified misalignments when comparing 

File C and File D1; but, they did not provide comments regarding this in the quarterly assurance 

statement comment boxes available on the DATA Act Broker. The misalignments were among

Procurement Instrument Identifier Numbers (PIID)

 60RRBH19P0080 – $9,324.07, which appeared in File C but not in File D1;

 RRB15C006 A00005 – $86,591, which appeared in File D1 but not File C; and

 RRB17A0046 P00002 and RRB17D0001 P00002 – $0.00, which each appeared in File D1 

but not in File C.

OMB guidance and DAIMS v 1.3 Practices and Procedures explain where there are legitimate 

differences between files, the SAO should provide categorical explanations for misalignments.15

 13 OMB, M-17-04 and MPM 2016-03. 14 Since a DATA Act submission contains a combination of many data sets, assurance over alignment requires the 

Senior Accountable Official (SAO) to attest to the interconnectivity/linkages (e.g. award ID linkage) across all the 

data in Files A, B, C, D, E, and F. 15 OMB M-17-04 and Department of Treasury (Treasury), DATA Act Information Model Schema (DAIMS) Practices 

and Procedures For DATA Broker Submissions v 1.3 (June 29, 2018).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 11

These explanations can be entered into a separate comment box available for each file being 

certified. These comments are made public along with the certified files on USASpending.gov.

Further, the SAO did not attest to the interconnectivity/linkages across all the data files. We 

discuss linkage issues in the sections titled The Agency did not Achieve Automatic Linkage for 

New Aggregate Records and Gaps Exist Between Authoritative Sources and Actual Sources.

Neither the SAO nor designee knew that a statement of accountability was a quarterly

requirement when they developed written statements certifying the completeness, accuracy, 

and timeliness of the data submitted to address previous OIG audit recommendations.

16

Instead, they attempted to address it once by stating, “[a]s the Senior Accountable Official, it is 

my opinion that RRB’s comprehensive review process for Data Act file submissions provides the 

internal controls to support the reliability and validity of the data submitted to Treasury for 

publication on USASpending.gov under the DATA Act.” Additionally, the SAO thought the 

designee’s certification for each quarterly submission through the DATA Act Broker application 

was adequate.

As a result, taxpayers and policy makers could be led to believe the alignment among the RRB’s 

Files A through F were valid and reliable, and the RRB’s data in each DATA Act file submitted for 

display on USASpending.gov were also valid and reliable. If the conditions we described are not 

corrected, they may adversely impact the completeness, accuracy timeliness, and quality of the 

data submitted, or implementation and use of the data standards in future DATA Act 

submissions.

On August 9, 2019, the RRB provided OIG auditors with a draft of the SAO quarterly assurance 

statement that they planned to use during the next DATA Act submission. The statement was

not evaluated as it was not within the scope of this audit.

RRB’s DATA Act Policies and Procedures Need Improvement

The RRB’s policies and procedures contained minimum standards and information for the RRB 

to manage and facilitate the reporting of financial and award data in accordance with the 

requirements of the DATA Act.17 Even though the procedures included various controls to 

ensure overall quality of the data, deficiencies were identified and improvements could be 

made. We determined that BFO did not include Actuary’s efforts in preparing File D2 in BFO’s 

revised procedures titled, Data Act Process Flow, last updated on May 22, 2019.18 Actuary

compiled and reported the benefit payment information using various preexisting processes, 

then uploaded it to the Financial Assistance Broker Submission (FABS) portal. Once it was 

 16 Railroad Retirement Board (RRB) Office of Inspector General (OIG), Railroad Retirement Board’s Initial DATA Act 

Submission, While Timely, Was Not Complete or Accurate, Report No. 18-01 (Chicago, IL; November 8, 2017). 17 Pub. L. No. 113-101 (2014). 18 According to the RRB, the Data Act Process Flow established comprehensive controls and procedures covering 

the submission and certification of RRB’s DATA Act files, to include review of source and resulting data to be 

submitted. They explained that these procedures detail the contractor staff responsibilities; and the roles and 

responsibilities associated with ensuring accurate and complete DATA Act files for all responsible or designated 

RRB staff.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 12

uploaded to FABS, it was available for download as File D2. The D2 file is the foundation of the 

RRB’s DATA Act reporting because File C is created and generated based on information 

contained in Files D1 and D2. File C contained 33,125 records, of which 33,057 of them came 

from File D2. The 33,057 records accounted for $3.2 billion of the $4.1 billion reported on the 

USASpending website.19 Additionally, we determined there were no procedures established to 

ensure File A and B totals matched.

Throughout our fieldwork, we had to request supplemental documentation, including flow 

charts, as there were limited details in the RRB’s Data Act Process Flow on how the RRB’s 

contractor CGI, BFO, Actuary, and AM actually compiled and converted the source data into the 

governmentwide financial data standards established by the OMB and Treasury.

According to Government Accountability Office (GAO), Standards for Internal Control in the 

Federal Government, “[i]nternal control comprises the plans, methods, policies, and procedures 

used to fulfill the mission, strategic plan, goals, and objectives of the entity.”20 Management 

should implement control activities through policies, which should be documented in the 

appropriate level of detail to allow management to effectively monitor the activity. Accordingly, 

management is responsible for designing policies and procedures to fit the agency’s situation.

BFO did not object to our observation relating to BFO not including Actuary’s effort in preparing 

Files C and D2 in its revised procedures. But, they did not provide an explanation regarding why 

this omission occurred. On August 9, 2019, the RRB provided OIG auditors with an updated 

Data Act Process Flow. We did not evaluate the new Data Act Process Flow because it was not 

within the scope of this audit.

The risk of the RRB’s controls failing at anytime is high due to the lack of written, detailed, and 

inclusive procedures, which may adversely impact the completeness, accuracy timeliness, and 

quality of the data submitted, or implementation and use of the data standards in future DATA 

Act submissions.

Recommendations

We recommend that the Bureau of Fiscal Operations

1. base the Railroad Retirement Board’s DATA Act quarterly submission and certification 

on the Railroad Retirement Board’s Data Quality Plan; 

2. provide a quarterly assurance statement that the agency’s internal controls support the 

reliability and validity of the agency account-level and award-level data reported for 

display on USASpending.gov in accordance with Office of Management and Budget 

Management Procedures Memorandum 2016-03 and Memorandum M-17-04. This 

statement should include assurances on interconnectivity/linkages across all the data in 

Files A, B, C, D, E, and F;

 19 See Table 1 and Table 2 for additional details. 20 Government Accountability Office (GAO), Standards for Internal Control in the Federal Government, 

GAO 14-704G (Washington, D.C.: September 2014).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 13

3. ensure the Senior Accountable Official or the Senior Accountable Official’s designee, 

including the DATA Act Certifier, obtain DATA Act training to ensure they have an

understanding of the DATA Act’s required written assurance statement, including the 

statement of accountability; and

4. update and expand the Railroad Retirement Board’s DATA Act Process Flow to include 

the Bureau of Actuary and Research’s efforts in preparing the financial assistance award 

portion of the DATA Act submission.

Management’s Comments and Our Response

For recommendations 1, 2, 3, and 4, BFO concurred with our recommendations. For 

recommendation 4, BFO stated

We concur that the DATA Act Process Flow needed to be updated to include discussion 

of Bureau of Actuary and Research’s efforts in preparing the financial assistance 

award portion of the DATA Act submission. As such, corrective action was taken during 

the course of your audit and the updated document was provided to your office on 

August 9, 2019.

We were able to conduct a review of the August 9, 2019 documents after the exit conference 

and issuance of the draft report. We determined that the updated DATA Act Process Flow in 

conjunction with the RRB’s DQP met the intent of recommendation 4. Therefore, we consider 

recommendation 4 implemented and closed. Please note that a full review of the RRB’s new 

DQP was not completed during the course of this audit. In our opinion, auditors must consider 

both documents when referring to the RRB’s policies and procedures as they related to 

DATA Act reporting. This should be noted for future reviews and audits.

RRB’s DATA Act Certification and Submission were Generally Complete 

but Need Improvement on Timeliness and Accuracy

The RRB’s first quarter of fiscal year 2019 DATA Act submission was generally complete and 

partially accurate at the summary-level, but not timely. We determined the SAO designee 

submitted and certified the data for publication on USASpending.gov one day late. To be 

considered timely, the SAO’s certification should have been provided on or before 

March 20, 2019. Even though the submission was generally complete and partially accurate, 

there is need for improvement in addressing DATA Broker validation warnings, conducting

reconciliations, obtaining interconnectivity/linkages across all data files, and timeliness.

The Agency’s Submission for Files A, B, and C was Generally Complete

The RRB’s first quarter of fiscal year 2019 DATA Act submission was generally complete. We 

evaluated RRB’s Files A, B, and C that were submitted to the DATA Act Broker. Our evaluation 

consisted of Treasury Account Symbol (TAS) to SF-133 comparisons, file to file comparisons, and 

a review of Broker warnings. Table 4 summarizes our comparisons.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 14

Table 4. OIG Evaluation of Files A, B, and C

File 

Name

Was the File 

Complete? If yes or no, why? Effect Percent Complete

File A Yes  Matched SF-133s. 100 %

File B Yes  All TASs in File A were accounted for in File B. 100 %

File C No  Micro-purchases were included in File D1 but

not File C.

Understated 

by $86,591a

99 %

Source: RRB OIG analysis of Files A, B, and C. a After examining File C for completeness, linkage to File B, and linkage to Files D1/D2, we determined File C was missing one 

record in an amount of $86,591. However, this record was not required to be reported in File C per DAIMS v 1.3 Practices and 

Procedures. Micro-purchase transactions are not required to be entered into FPDS-NG. Information entered into FPDS-NG 

directly effects File D1 which directly effects File C.

Accuracy of Summary-Level Data for Files A and B and Linkages Need 

Improvement

We determined that BFO submitted inaccurate data for File B on USASpending.gov and did not 

ensure linkages were automatic between the RRB’s financial and award systems. There is need 

for improvement in addressing Broker validation warnings and conducting reconciliations. Our 

test work noted variances between Files A, B, and C. See Tables 5 and 6 for details pertaining to 

Files A and B.

The Agency’s File B was Inaccurate

We determined that File A was accurate when matched against comparable information found 

in the RRB’s SF-133. However, File B was inaccurate when matched against File A and when 

matched against the President’s Budget.

21

We conducted two different comparisons between Files A and B. In the first, we compared 

gross outlays and in the second, we compared obligation amounts. According to 

USASpending.gov, an outlay occurs when federal money is actually paid out, not just promised 

to be paid. A promise to pay is known as an obligation and is a binding agreement. 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 require it to make a payment.

As shown in Table 5, we compared gross outlay amounts and determined File B was 

understated by $8.1 million. According to DAIMS validation rule A18, gross outlay amount by 

TAS found in File A should be equal to the sum of all gross outlay amount by program object 

class in File B.

 21 OMB, Appendix, Budget of the United States Government, Fiscal Year 2019, Detailed Budget Estimates 

(Washington, D.C.: February 2018).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 15

Table 5. File A to File B Variances Rule A18

TAS File A’s Sum of Gross Outlay 

Amount

File B’s Sum of Gross Outlay 

Amount

Difference

(File A - File B)

8010 (1,823,287,650.45) (1,824,741,891.22) 1,454,240.77

8011 (1,402,765,534.79) (1,402,827,144.22) 61,609.43

8118 (377,004,811.87) (377,004,811.90) 0.03

0113 (231,294,626.89) (231,294,626.90) 0.01

8237 (37,534,268.34) (28,035,199.47) (9,499,068.87)

8051 (32,045,783.21) (31,884,543.59) (161,239.62)

0111 (4,506,286.34) (4,540,128.61) 33,842.27

8018 (3,445,140.51) (3,445,140.51) 0.00

0114 (5,561.95) 0.00 (5,561.95)

0117 (3,280.02) 907.18 (4,187.20)

Total (3,911,892,944.37) (3,903,772,579.24) (8,120,365.13)

Source: RRB OIG analysis and review of Files A and B. DATA Act Information Model Schema (DAIMS) Validation Rules v1.3.1, 

revision date February 8, 2019.

As shown in Table 6, we compared obligation amounts and determined File B was overstated by 

$1.15 million. According to DAIMS validation rule A19, File A’s obligations incurred total by TAS 

should be equal to the negative sum of obligations incurred by program object class in File B as 

of the same reporting period.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 16

Table 6. File A to File B Variances Rule A19

TAS USASpending.gov File A’s Sum of 

Obligations Incurred

File B’s Sum of 

Obligations Incurred

Difference

(File A - File B)

8010 1,894,233,965 1,894,233,964.92 (1,894,233,965.04) (0.12)

8011 1,486,791,721 1,486,791,720.77 (1,486,791,720.98) (0.21)

8118 377,004,812 377,004,811.87 (377,004,811.90) (0.03)

0113 231,294,627 231,294,626.89 (231,294,626.90) (0.01)

8237 57,007,164 56,562,459.30 (57,007,164.40) (444,705.10)

8051 45,305,894 45,305,894.07 (45,305,894.07) (0.00)

0111 4,536,252 4,537,830.46 (4,536,252.45) 1,578.01

8018 3,764,331 3,057,376.36 (3,764,331.30) (706,954.94)

0117 2,141 2,141.32 (2,141.32) (0.00)

0114 -- -- -- --

Total 4,099,940,908 4,098,790,825.96 (4,099,940,908.36) (1,150,082.40)

Source: RRB OIG analysis and review of Files A, B, and USASpending.gov’s Spending Explorer tool. DATA Act Information Model 

Schema (DAIMS) Validation Rules v1.3.1, revision date February 8, 2019.

During RRB’s pre-certification process through the Broker, misalignments were identified 

between Files A and B but not addressed. The SAO designee could not support why this 

occurred and claimed that the differences between Files A and B were due to timing and were 

not material. Further, the designee did not reconcile or validate File B to ensure it was accurate. 

During our fieldwork, BFO tried to determine the cause of the differences and claimed that the 

same issue has not recurred since they revised their reconciliation procedures. After further 

review, we determined that the raw File B CGI generated matched File A. This led us to believe 

that CGI could have potentially used the wrong File B or had a breakdown in their SQL coding 

and that it was not a timing issue. We shared this information with RRB management during 

the exit conference.

Additionally, we determined File B’s program activity names and codes were inaccurate when 

compared to the President’s Budget:

22

 In File B, TAS 0114 and 0117 had a code of 0003 (Railroad Unemployment Insurance 

Trust Fund), yet neither fund in the President’s Budget contained that code.

 The President’s Budget contained code 0002 (Railroad Social Security Equivalent 

Benefit) under TAS 8237 and 8018 yet this code was absent from File B.

 22 OMB, Appendix, Budget of the United States Government, Fiscal Year 2019, Detailed Budget Estimates.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 17

 File B contained a code that did not match the program activity name under TAS 8237. 

The code 0001 was used for (Medicare and other reimbursements) instead of the 

correct code 0801.23

We believe the discrepancies with File B and the President’s Budget was attributable to CGI’s 

SQL command statement used to query the Financial Management Integrated System (FMIS) to 

prepare File B as the program activity names and codes were populated based on a conditional 

script.

Lack of reconciliation procedures and inaction towards Broker warnings resulted in the 

submission of inaccurate, unreliable, and inconsistent summary level data. Since File B was 

inaccurate, the primary USASpending.gov screen for the RRB was also inaccurate and 

overstated by $1.15 million or 0.03 percent of total obligations reported.

24 As a result, 

taxpayers and policy makers could not fully rely on the RRB’s data to track federal spending 

more effectively. If left unchecked, this could lead to decreased accountability and 

transparency in federal spending across the Federal Government.

The Agency did not Achieve Automatic Linkage for New Aggregate Records

The RRB did not meet OMB’s deadline for automatic linkages. BFO did not ensure URI linkages 

were automatic between the RRB’s financial and award systems in accordance with OMB 

guidance.

25 For the RRB’s DATA Act reporting, URIs are used only for financial assistance awards 

and not procurement awards.26

According to OMB guidance, agencies that are unable to include the URI in management and 

financial systems for county level aggregate records displayed beginning May 2017 may 

manually link the award and financial data in their submission (award financial file - File C) using 

URI. All agencies will be required to achieve the automatic linkage for new aggregate records 

between the financial and award management systems by October 1, 2018.27

Actuary explained that URIs were manually created when they prepared the financial assistance 

awards data for the monthly FABS reporting. BFO explained that the RRB is not currently in a 

position to use FMIS as the source of data for financial assistance awards because there is no 

automated interface between FMIS and its benefit paying systems. We discuss this further in 

the section titled Gaps Exist Between Authoritative Sources and Actual Sources.

Lack of automatic linkages, could lead to decreased user capability. According to OMB, they 

want users to have the same spending lifecycle view as provided through use of the Award ID 

linkage.

 23 Potentially stemming from the same program activity name issue, we found a variance between File C and 

File B’s program activity names for PIID 60RRBH19F0079, Parent Award ID GS35F198CA. 24 We were unable to view the effect of the understated gross outlay total of $8.1 million through the 

USASpending.gov’s spending explorer tool.

25 OMB, M-17-04. 26 As defined per DATA.gov, a Unique Record Identifier (URI) is an agency defined identifier that (when provided) is 

unique for every reported action.

27 OMB, M-17-04.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 18

The Agency’s Submission was not Timely

The SAO designee submitted and certified the RRB's first quarter of fiscal year 2019 financial 

and award data for publication on USASpending.gov one day late. The submission and 

certification occurred on March 21, 2019. 

According to the CIGIE FAEC guide, an agency submission should be considered timely when the 

submission by the agency to the DATA Act Broker is in accordance with the reporting schedule 

established by the Treasury DATA Act Project Management Office, which is traditionally within 

45 days of quarter end. Due to a government shutdown, the due date for agency submissions 

for first quarter of fiscal year 2019 was extended to March 20, 2019. 

In response to our entrance conference, BFO provided us DATA Act submission documents and 

emails. One email included the new due date of Wednesday, March 20, 2019, which the SAO 

designee forwarded to the appropriate RRB DATA Act points of contact. In contradiction to the 

emails, the SAO designee stated they were confused about the due date as it was changed due 

to a partial government shutdown. According to the SAO designee, they tried to obtain the 

submission deadline schedule from MAX.gov but could not access it at the time. 

Late DATA Act submissions could contribute to decreased accountability and transparency in 

federal spending across the Federal Government and the prevention of taxpayers and policy 

makers to track federal spending more effectively.

Sample Results – The RRB’s Data was of Higher Quality

We determined that RRB’s data was considered of Higher quality based on the CIGIE FAEC 

Guide. The Higher quality rating was determined as a result of our statistically random sample

shown in Appendix III.

Based on the sample, the RRB’s projected error rates for completeness, accuracy, and 

timeliness were 0.00 percent, 0.43 percent, and 0.00 percent, respectively. The highest of the 

three error rates was used as the determining factor of quality, which was 0.43 percent. Using 

Table 7, the rate of 0.43 percent placed the RRB in the Higher category.

Table 7. Levels of Data Quality

Error Rate Quality Level

0% - 20% Higher

21% - 40% Moderate

41% and above Lower

Source: CIGIE FAEC Guide.

As part of the statistically valid random sample of 385 records, we tested 52 of the 57 data 

elements for completeness, accuracy, and timeliness.28 To conduct the data element analysis, 

 28 Per CIGIE FAEC Guide, we were not required to test all 57 data elements. See Appendix IV for details.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 19

we first had to determine if the element was required or applicable per award type, 

aggregation type, and CIGIE FAEC guidance. See Appendix IV for information on the 52 tested 

data elements. 

The substantial decrease in error rate for the sample was attributed to CIGIE’s 2019 prescribed 

sampling approach, the aggregation of data, and the RRB’s existing financial assistance award 

reporting process. The RRB improved its accuracy error rate for the sample from 91 percent to 

0.43 percent in two years. 

This occurred partially because the composition of the sample universe changed from 2017, 

including the approach. The 2017 auditors were limited to sampling solely from File D1, which 

consisted of procurement awards only, rather than from the preferred File C, which also 

included financial assistance awards. For the 2017 audit, the team determined they could not 

sample from File C because it was missing two months of financial assistance award data. 

Therefore, it was incomplete and not suitable for sampling. When we conducted our suitability 

for sampling test of File C in 2019, we determined it was complete and could follow CIGIE’s 

sampling methodology. Therefore, we sampled from File C which contained 384 financial 

assistance awards and 1 procurement award. Further, the 2017 sampling results were 

concluded on a pass or fail basis, whereas, this audit’s error rate conclusion was based on the 

numerical average of the percentage of actual errors of individual data elements in each 

sample.

Additionally, we attributed the improved error rate to the financial assistance award reporting 

requirements which allowed for an aggregation of data. This reduced the amount of individual 

information reported and the amount of unique data to be tested. In contrast, procurement 

transactions contained a variety of information unique to each transaction and criteria. Lastly, 

the RRB compiled its financial assistance award data based on previously established FAADS+ 

reporting process, which was already consistent with DATA Act requirements.

For the fiscal year 2019 errors, we determined the majority of the errors found pertained to the 

inaccurate use of FAIN, data element (DE) 34, while reporting aggregate records.

29 As described 

in the section titled Some Financial Assistance Awards Containing Personally Identifiable 

Information were Incorrectly Reported, Actuary did not appropriately apply OMB guidance 

when reporting financial assistance awards containing PII as they used FAIN to distinguish 

foreign benefit payments from domestic instead of using FAIN to report a single award 

containing PII.

30 FAIN is intended to be used for individual records not aggregates.

Additionally, we found a few errors pertaining to the one procurement transaction sampled. 

We found accuracy errors with Appropriations Account (DE 51) in File C and Legal Entity 

Address (DE 5), Award Type (DE 16), Period of Performance Start Date (DE 26), Ordering Period 

 29 As defined on DATA.gov, a Unique Record Identifier (URI) is an agency defined identifier that (when provided) is 

unique for every reported action. The Federal Award Identification Number (FAIN) is the unique ID within the 

Federal agency for each (non-aggregate) financial assistance award. 30 OMB, M-17-04.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 20

End Date (DE 29), and Primary Place of Performance Address (DE 30) in File D1. The remaining 

errors pertained to other financial assistance awards. For details refer to Appendices III and IV.

Recommendations

We recommend Bureau of Fiscal Operations

5. ensure a reconciliation between Files A, B, C, D1, and D2 occur before the Railroad 

Retirement Board’s DATA Act submission and certification is finalized each quarter;

6. ensure DATA Act Broker warnings are addressed each quarter, if necessary, document 

any misalignments among Files A, B, C, D1, and D2 that were submitted for display on 

USASpending.gov;

7. update and expand the Railroad Retirement Board’s DATA Act Process Flow to include 

the Railroad Retirement Board’s DATA Act reconciliation processes for Files A, B, C, D1, 

and D2; and

8. develop a process to ensure the DATA Act Certifier provides the Railroad Retirement 

Board’s DATA Act submission and certification on or before each quarterly due date.

Management’s Comments and Our Response

For recommendations 5, 6, 7, and 8, BFO concurred with our recommendations. For 

recommendation 7, BFO stated

We concur that the DATA Act Process Flow needed to be updated to include discussion 

of Railroad Retirement Board’s DATA Act reconciliation processes for Files A, B, C, D1, 

and D2. As such, corrective action was taken during the course of your audit and the 

updated document was provided to your office on August 9, 2019.

We were able to conduct a review of the August 9, 2019 documents after the exit conference 

and issuance of the draft report. We determined that the updated DATA Act Process Flow in 

conjunction with the RRB’s DQP met the intent of recommendation 7. Therefore, we consider 

recommendation 7 implemented and closed. Please note that a full review of the RRB’s new 

DQP was not completed during the course of this audit. In our opinion, auditors must consider 

both documents when referring to the RRB’s policies and procedures as they related to 

DATA Act reporting. This should be noted for future reviews and audits.

The RRB’s Implementation and Use of the Data Standards Could be 

Improved

We determined the RRB generally implemented and used the governmentwide financial data 

standards for spending information as developed by OMB and Treasury. However, we noted

that improvements could be made to the reporting of financial assistance awards containing PII 

and resolving gaps between authoritative sources and actual sources.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01 21

Some Financial Assistance Awards Containing Personally Identifiable 

Information were Incorrectly Reported

As previously cited, Actuary did not appropriately apply OMB M-17-04 guidance when reporting 

financial assistance awards containing PII as they used FAIN to distinguish foreign benefit 

payments from domestic instead of using FAIN to report a single award containing PII.31

According to OMB guidance, to ensure maximum transparency in federal spending, agencies 

must report each financial assistance award at the most granular level practicable while 

protecting PII.32 Given the required data collections, if reporting at the single award level is not 

practicable, agencies may report at the county level, and if not practicable, aggregated at the 

state level. Actuary reports RRB’s financial assistance awards aggregated at the county level, 

therefore, records reported this way must be linked using the URI.

According to Actuary, Treasury advised the RRB to report foreign financial assistance awards 

using FAIN. Actuary obtained this advice from Treasury when DATA Act reporting first started. 

The RRB’s erroneous use of FAIN in DATA Act reporting could lead to user misinterpretation as 

a specific bundle of awards would be mistakenly presented as a single award.

Gaps Exist Between Authoritative Sources and Actual Sources

BFO and Actuary did not resolve gaps between the DATA Act authoritative sources and RRB’s 

actual sources. BFO explained the financial assistance data elements do not reside in the 

agency’s financial system (FMIS) because there is no automated interface between the RRB’s 

benefit paying systems and the financial system. Conversely, BFO explained the required data 

elements for the financial assistance portion of File C were extracted from the benefit paying 

systems and sent to CGI as comma separated value files; and, they were the same files that 

were uploaded, validated, and published to FABS.33

According to OMB guidance, the authoritative source for File C’s data is the agency’s financial 

system. Our evaluation and comparison of authoritative sources versus actual sources for 

DATA Act is shown in Table 8, which includes a condensed version of RRB’s DATA Act File A 

through D2 creation and generation process.

34

 31 As defined per DATA.gov, a Unique Record Identifier (URI) is an agency defined identifier that is unique for every 

reported action. The Federal Award Identification Number (FAIN) is the unique ID within the federal agency for 

each (non-aggregate) financial assistance award. 32 OMB, M-17-04. 33 According to Microsoft, comma separated value files, often known as a .CSV, are simple text files with rows of 

data where each value is separated by a comma.

34 OMB, MPM 2016-03 and M-17-04.
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Table 8. DATA Act Authoritative Source and RRB’s Source System

File Name DATA Act 

Authoritative 

Source

RRB’s DATA Act Reporting Process

(Source Systems and Files)

File A

Appropriations

SF-133 derived from 

GTAS dataa

CGI generates File A from GTAS-133.

File B

Object Class 

Program Activity

SF-133 derived from 

GTAS dataa

CGI generates File B from FMIS database using SQL, which 

matches GTAS-133.

File C

Award Financial -

Procurement

Financial Systems BFO/CGI generates this portion of File C from RRB’s 

Financial System (FMIS) using SQL.

Acquisitions reviews the FMIS extracted File C for 

accuracy. 

File C

Award Financial -

Financial Assistance

Financial Systems BFO/CGI generates this portion of File C from conversion 

files derived from an Actuary produced external source 

file.

File D1

Procurement Award 

Attributes

Federal 

Procurement Data 

System – Next 

Generation (FPDSNG) 

BFO/CGI generates File D1 from DATA Act Broker. DATA 

Act Broker generates D1 from FPDS-NG.

Acquisitions verifies accuracy of File D1 against their paper

contract files and electronic contract files in FMIS.

File D2

Financial Assistance 

Award Attributes

Agency Award 

Management

Systems or Files and 

SAM

BFO/CGI generates File D2 from DATA Act Broker. DATA 

Act Broker generates D2 from FABS. Actuary produces the 

FABS file also known as the external source file FAADS+.

Actuary prepares the FAADS+ file from PREH, MBF, and 

MACRO, the RRB’s applicable systems of record.

Source: RRB OIG analysis of the RRB’s DATA Act reporting process, OMB MPM 2016-03, and OMB M-17-04. a Governmentwide Treasury Account Symbol Adjusted Trial Balance System (GTAS)

According to BFO, they did not identify any other gaps except the ones described in Table 8 

since the remaining required data elements in File A, File B, and File C (procurement only) 

reside in the RRB’s financial system (FMIS). 

The gaps occurred because the RRB is not currently in a position to use FMIS as the source of 

data for financial assistance awards. BFO stated that it may be possible to request a 

modification of the system to periodically accept and store financial assistance data for File C 

processing in order to fit the prescribed definition of authoritative source. BFO said that such a 

system modification would have any effect on the timeliness or accuracy of DATA Act reporting 

beyond the current process. Gaps could have a negative impact on the timeliness or 

effectiveness of RRB’s DATA Act reporting and could complicate the reporting for the RRB.
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Recommendations

We recommend the Bureau of Actuary and Research

9. ensure financial assistance awards containing personally identifiable information are 

reported in accordance with Office of Management and Budget Memorandum M-17-04; 

and

10. ensure DATA Act file assistance award preparers obtain training over the reporting of 

financial assistance awards containing personally identifiable information. For example, 

financial assistance award should be reported at the most granular level practicable 

while protecting personally identifiable information. The RRB and Bureau of Actuary and 

Research should consider the different available Record Types as described in 

Appendix V.

We recommend the Bureau of Fiscal Operations

11. develop a plan to obtain an automated interface between the RRB’s benefit paying 

systems and the RRB’s financial system that would ensure the RRB is in compliance with 

Office of Management and Budget Management Performance Memorandum 2016-03 

and Office of Management and Budget Memorandum M-17-04.

Management’s Comments and Our Response

For recommendations 9 and 10, Actuary concurred with our recommendations. However, 

Actuary has not provided target completion dates in its management comments.

For recommendation 11, BFO concurred with our recommendation and stated

As agreed to by the Audit Manager via discussion on October 30, 2019, RRB will meet 

the intent of this recommendation by discussing this matter further with the Office of 

Management Budget. 
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APPENDIX I: MANAGEMENT COMMENTS
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APPENDIX II: MANAGEMENT COMMENTS
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APPENDIX III: SAMPLING METHODOLOGY

This appendix presents the methodology and results of our statistical sample to assess the 

completeness, accuracy, timeliness, and overall quality of selected required data fields 

submitted as part of Railroad Retirement Board’s (RRB) Digital Accountability and Transparency 

Act of 2014 (DATA Act) for File C.

Scope

As recommended by the Council of the Inspectors General on Integrity and Efficiency (CIGIE) 

Federal Audit Executive Committee (FAEC) Inspectors General Guide to Compliance under the 

DATA Act (CIGIE FAEC Guide), our sample was selected from the award financial detail data 

included in RRB’s DATA Act File C submission for the first quarter of fiscal year 2019, submitted 

for publication on USASpending.gov. This file consisted of financial assistance awards (benefit 

payments) and procurement transactions for the period October 1, 2018 through 

December 31, 2018. This universe included financial assistance awards (benefit payments) and 

procurement award transactions (new awards and modifications to existing awards) made by 

RRB. The universe consisted of 33,125 award financial detail records found in File C. Of the 

33,125 records, 68 were procurement award and 33,057 were financial assistance awards. 

Review Methodology

We used attribute sampling to test the completeness, accuracy, and timeliness of data reported 

for each record in File C. A record is considered a row in the data file within File C. A record 

could be a portion of a transaction or award activity and not necessarily the whole transaction 

or award activity. In our sample, a sampling unit is either a procurement award identified with 

unique Procurement Instrument Identifier Numbers (PIID) or financial assistance award 

identified with the Financial Assistance Identifier Numbers (FAIN) or Unique Record Identifiers 

(URI). All sampling units in the universe were eligible for random sample selection.

We selected our sample from procurement and benefit payment transactions in File C because 

the file was deemed suitable for sampling according to the CIGIE FAEC Guide.

Based on sampling criteria contained in guidance for this audit, the sample had an expected 

error rate of 50 percent, desired precision rate of 5 percent, and desired confidence level of 

95 percent. This resulted in a sample size of 385 transactions, which is at the limit according to

the CIGIE FAEC Guide. We selected a statistically valid simple random sample using TeamMate 

Analytics software. OIG transactions were not selected in our sample. Once the sample was 

selected from File C, we 

1. confirmed the sample selected was included in File D1 to test corresponding D1 data 

elements;

2. confirmed the financial assistance awards selected matched the FAIN/URI in File D2 to 

test corresponding data elements;

3. determined the aggregate records were reported consistently with OMB M-17-04;
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4. determined if the data element was required and included for the record selected;

5. determined the accuracy of applicable data elements in Files D1 and D2;

6. determined the timeliness of data elements;

7. calculated and projected the overall error rates; and

8. determined the overall quality of data sampled based on a scale of Higher, Moderate, or 

Lower.

We used CIGIE FAEC’s Testing Results Spreadsheet tool in summarizing the results of the 

detailed record-level test of each sample and each of the data elements for Files C, D1, and D2. 

According to the CIGIE FAEC Guide, completeness, accuracy and timeliness of data elements 

will be tested independently of each other but may overlap.35 An error of one kind does not 

preclude nor assume an error of another kind. 

For completeness, we considered the sample item or data element to be an error when the 

data element fields was left empty or if a data element that was required to be reported, was 

not reported. For accuracy, we considered the sample item or data element to be an error if the 

data did not agree with the authoritative source records. For timeliness, we considered the 

sample item or data element to be an error if the data reported was not reported within the 

quarter in which it occurred; was not reported in FPDS-NG within 3 business days after contract 

award; or was not reported within 30 days after award, in accordance with FFATA. 

During our sampling, we made a decision to test the 384 financial assistance award records 

against Treasury’s Record Type 1 criteria because the RRB erroneously used FAIN instead of 

URI, therefore, incorrectly reported the associated record as Record Type 2.36 This effected 5 of 

the 384 financial assistance award records sampled. Aggregate reporting criteria is shown in 

Appendix V.

We calculated the overall error rate for completeness, accuracy, and timeliness for each sample 

item and data element based on the results of the testing of the data elements found in 

Appendix IV and CIGIE FAEC’s Testing Results Spreadsheet tool as shown in Table 9.

For quality, we used the results of the statistical sample in order to provide a range of results. If 

the highest error rate of completeness, accuracy and timeliness is between 0 percent and 

20 percent then the quality would be considered Higher. If the highest error rate is between 

21 percent and 40 percent then the quality would be considered Moderate. If the highest error 

rate is 41 percent or more, then the quality would be considered Lower. 

Results

We reviewed a sample of 385 award financial detail, drawn from a population of 33,125 records 

in File C. The data element tested and results of tests for the attributes of completeness, 

accuracy, and timeliness for each data element are detailed in Appendix IV. The sample tested 

 35 Refer to Appendix IV for data element analysis. 36 Source: U.S. Dept. of Treasury, DATA Act Information Model Schema (DAIMS) Practices and Procedures for DATA 

Act Broker Submissions Version 1.3, (June 29, 2018).
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and results of each individual sample was based on CIGIE FAEC’s Testing Results Spreadsheet

tool and maintained in our audit files. In order to provide the stakeholders with easy to discern 

information regarding the 385 samples, we provided an extract of our testing spreadsheet in 

Table 9.

Table 9. RRB Results Per Sample Record

A B C D E F G H

Sample

Record #

Total #

Data Elements

# Incomplete # Inaccurate # Untimely

27 40 0 0.00 % 8 20.00 % 0 0.00 %

60 40 0 0.00 % 8 20.00 % 0 0.00 %

92 40 0 0.00 % 2 5.00 % 0 0.00 %

127 40 0 0.00 % 2 5.00 % 0 0.00 %

137 40 0 0.00 % 2 5.00 % 0 0.00 %

138 40 0 0.00 % 8 20.00 % 0 0.00 %

159 40 0 0.00 % 8 20.00 % 0 0.00 %

161 44 0 0.00 % 6 13.64 % 0 0.00 %

190 40 0 0.00 % 2 5.00 % 0 0.00 %

239 40 0 0.00 % 2 5.00 % 0 0.00 %

285 40 0 0.00 % 2 5.00 % 0 0.00 %

323 40 0 0.00 % 2 5.00 % 0 0.00 %

330 40 0 0.00 % 2 5.00 % 0 0.00 %

332 40 0 0.00 % 2 5.00 % 0 0.00 %

350 40 0 0.00 % 2 5.00 % 0 0.00 %

380 40 0 0.00 % 8 20.00 % 0 0.00 %

All Others 40 0 0.00 % 0 0.00 % 0 0.00 %

Total Errors 0 66a 0

Error Rate 0.00 % 0.43 %b 0.00 %

Source: RRB OIG Analysis of 385 samples and CIGIE FAEC’s Testing Results Spreadsheet tool. a Total errors of 66 = Sum of column E. b Error rate of 0.43 = Sum of column F divided by 385.

Conclusion

Based on the sample of 385 records, we determined the RRB’s overall projected error rates for 

completeness, accuracy, and timeliness were 0.00 percent, 0.43 percent, and 0.00 percent, 

respectively.
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The highest error rate was 0.43 percent, which is considered a quality of Higher since it was

between 0 percent and 20 percent as shown in Table 7. Therefore, the RRB’s data was 

determined to be of Higher quality.
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APPENDIX IV: RRB’S RESULTS FOR THE DATA ELEMENTS

Table 10 summarizes the results of our data element testing. We sorted the results by error 

rate in order to provide the stakeholders with easy to discern information regarding which data 

elements were determined to have the highest instances of error. Table 10 is based on the 

results of our testing of 384 financial assistance records and 1 procurement record submitted in 

RRB’s first quarter of fiscal year 2019 DATA Act submission. Since the RRB did not have a DQP at 

the time of submission, we were unable to determine whether these risks were consistent with 

the risks identified in its applicable DQP.

Table 10. RRB’s Results for Data Elements

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

Error Ratea

Data 

Element 

Number

Errors 

Found 

in File

Data Element Name # C % A % T %

6 D2 Legal Entity Congressional District 10 0.00 2.60 0.00

31 D2 Primary Place of Performance Congressional District 10 0.00 2.60 0.00

34 C/D2 Award ID Number (PIID/FAIN/URI) 10 0.00 2.60 0.00

5 D1/D2 Legal Entity Address 6 0.00 1.56 0.00

26 D1/D2 Period of Performance Start Date 6 0.00 1.56 0.00

1 D2 Awardee/Recipient Legal Entity Name 5 0.00 1.30 0.00

27 D2 Period of Performance Current End Date 5 0.00 1.30 0.00

35 D2 Record Type 5 0.00 1.30 0.00

36 D2 Action Type 5 0.00 1.30 0.00

16 D1 Award Type 1 0.00 0.26 0.00

29 D1 Ordering Period End Date 1 0.00 0.26 0.00

30 D1 Primary Place of Performance Address 1 0.00 0.26 0.00

51 C Appropriations Account 1 0.00 0.26 0.00

2 n/a Awardee/Recipient Unique Identifier 0 0.00 0.00 0.00

3 n/a Ultimate Parent Unique Identifier 0 0.00 0.00 0.00

4 n/a Ultimate Parent Legal Entity Name 0 0.00 0.00 0.00

7 n/a Legal Entity Country Code 0 0.00 0.00 0.00

8 n/a Legal Entity Country Name 0 0.00 0.00 0.00

11 n/a Federal Action Obligation 0 0.00 0.00 0.00
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Completeness (C), Accuracy (A), and Timeliness (T)

Error Ratea

Data 

Element 

Number

Errors 

Found 

in File

Data Element Name # C % A % T %

12 n/a Non-Federal Funding Amount 0 0.00 0.00 0.00

13 n/a Amount of Award 0 0.00 0.00 0.00

14 n/a Current Total Value of Award 0 0.00 0.00 0.00

15 n/a Potential Total Value of Award 0 0.00 0.00 0.00

17 n/a NAICS Code 0 0.00 0.00 0.00

18 n/a NAICS Description 0 0.00 0.00 0.00

19 n/a Catalog of Federal Domestic Assistance Number 0 0.00 0.00 0.00

20 n/a Catalog of Federal Domestic Assistance Title 0 0.00 0.00 0.00

22 n/a Award Description 0 0.00 0.00 0.00

23 n/a Award Modification/Amendment Number 0 0.00 0.00 0.00

24 n/a Parent Award ID Number 0 0.00 0.00 0.00

25 n/a Action Date 0 0.00 0.00 0.00

28 n/a Period of Performance Potential End Date 0 0.00 0.00 0.00

32 n/a Primary Place of Performance Country Code 0 0.00 0.00 0.00

33 n/a Primary Place of Performance Country Name 0 0.00 0.00 0.00

37 n/a Business Types 0 0.00 0.00 0.00

38 n/a Funding Agency Name 0 0.00 0.00 0.00

39 n/a Funding Agency Code 0 0.00 0.00 0.00

40 n/a Funding Sub Tier Agency Name 0 0.00 0.00 0.00

41 n/a Funding Sub Tier Agency Code 0 0.00 0.00 0.00

42 n/a Funding Office Name 0 0.00 0.00 0.00

43 n/a Funding Office Code 0 0.00 0.00 0.00

44 n/a Awarding Agency Name 0 0.00 0.00 0.00

45 n/a Awarding Agency Code 0 0.00 0.00 0.00

46 n/a Awarding Sub Tier Agency Name 0 0.00 0.00 0.00

47 n/a Awarding Sub Tier Agency Code 0 0.00 0.00 0.00

48 n/a Awarding Office Name 0 0.00 0.00 0.00

49 n/a Awarding Office Code 0 0.00 0.00 0.00
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Completeness (C), Accuracy (A), and Timeliness (T)

Error Ratea

Data 

Element 

Number

Errors 

Found 

in File

Data Element Name # C % A % T %

50 n/a Object Class 0 0.00 0.00 0.00

53 n/a Obligation 0 0.00 0.00 0.00

54 n/a Unobligated Balance 0 0.00 0.00 0.00

56 n/a Program Activity 0 0.00 0.00 0.00

57 n/a Outlay 0 0.00 0.00 0.00

9 n/a Not Tested – Highly Compensated Officer Nameb -- -- -- --

10 n/a Not Tested – Highly Compensated Officer Total 

Compensationb

-- -- -- --

21 n/a Not Tested – Treasury Account Symbolc -- -- -- --

52 n/a Not Tested – Budget Authority Appropriatedd -- -- -- --

55 n/a Not Tested – Other Budgetary Resourcesd -- -- -- --

Source: RRB OIG Analysis – Sampling of Files C, D1, and D2. a All estimates from the sample have a margin of error no greater than plus or minus 5 percentage points. b We did not test DE 9 and DE 10 because they are reported in Files E and F and not in Files C, D1, or D2. c We did not test DE 21 because it was included in DE 51 testing. d We did not test DE 52 and DE 55 because they are reported in File A and not Files C, D1 or D2.
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APPENDIX V: BASIC VALIDATION RULES FOR AGGREGATE AND 

NON-AGGREGATE REPORTING

Note: Blanks in the following picture indicate the element is optional.

Source: U.S. Dept. of Treasury, DATA Act Information Model Schema (DAIMS) Practices and Procedures for DATA Act Broker 

Submissions Version 1.3, (June 29, 2018)
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APPENDIX VI: ANOMALY LETTER

Council of the Inspectors General on Integrity and Efficiency’s DATA Act Anomaly Letter 

submitted to the Senate Committee on Homeland Security and Government Affairs and the 

House Committee on Oversight and Government Reform.
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