Office of Inspector General

DATA Act Audit, 2019

A20-01

 November 2019 

 FEDERAL MARITIME COMMISSION
Table of Contents 

REPORT HIGHLIGHTS................................................................................................................ 1

BACKGROUND ............................................................................................................................ 2

FMC DATA ACT REPORTING ................................................................................................... 3

OBJECTIVES, SCOPE, AND METHODOLOGY........................................................................ 4

RESULTS ....................................................................................................................................... 6

Assessment of Internal Control over Source Systems............................................................. 6

Assessment of Internal Controls over DATA Act Submission ............................................... 7

Assessment of DATA Act Submission ................................................................................... 8

Summary-Level Data and Linkages for Files A, B, and C ...................................................... 8

Record-Level Data and Linkages for Files C and D1 .............................................................. 8

Testing Limitations................................................................................................................. 9

Implementation and Use of the Data Standards ...................................................................... 9

FINDING 1– Timely Reporting to FPDS-NG .............................................................................. 10

FINDING 2 – Inaccurate Procurement Information ..................................................................... 11

FINDING 3 – “Double Dash” Process ......................................................................................... 13

Appendix A – Agency Response .................................................................................................. 15

Appendix B – CIGIE Date Anomaly Letter ................................................................................. 17

Appendix C – FMC’s Results for the Data Elements ................................................................... 19

Appendix D – Analysis of the Accuracy of Dollar Value-Related Data Elements ...................... 22

Appendix E – Analysis of Errors in Data Elements ..................................................................... 23
1 

Federal Maritime Commission 

Office of Inspector General (OIG)

REPORT

HIGHLIGHTS

The OIG Recommends the FMC Enhance Policies and 

Procedures to Ensure the Accurate and Timely 

Reporting of Procurement Information in the DATA Act 

Reporting Process

(Audit A20-01, November 2019)

What We Found 

The Federal Maritime Commission’s (FMC) DATA Act reporting process involves 

multiple parties: Treasury’s Bureau of the Fiscal Service, Administrative 

Resource Center (BFS ARC); the FMC’s Senior Accountable Official (SAO) 

(Managing Director); the FMC’s Office of Budget and Finance (OBF); and the 

FMC’s Office of Management Services (OMS). The FMC uses two systems for its 

spending data: Oracle Financials as its source system for all financial data, and 

the Procurement Request Information System Management (PRISM) as its 

source system for contract data. The FMC also uses the Federal Procurement 

Data System-Next Generation (FPDS-NG) for collecting and reporting data on 

agency procurements. 

The OIG tested 15 unique procurement transactions (records) to be reported on 

USAspending.gov for the first quarter of fiscal year 2019. These transactions 

were tested for completeness, accuracy, and timeliness. The OIG’s audit 

determined that the FMC’s error rate for completeness was 6.33%; the error 

rate for accuracy was 7.12%; and the error rate for timeliness was 24.21%. The 

majority of these errors were determined to be not attributable to the FMC, and 

the result of two different third-party system issues.

Due to a system issue, in two cases, PRISM was only interfacing the ‘draft’ 

version of a processed, finalized award into FPDS-NG. As a result, FPDS-NG 

was not receiving the final version that is ultimately reported to 

USAspending.gov. While the FMC is able to manually approve and finalize the 

draft in FPDS-NG, the system does not generate a notice to the agency when 

manual approval is required. In addition, due to the lack of clear procedures 

on the process to record transactions in PRISM and FPDS-NG when a vendor 

has changed their DUNS number, this caused incomplete, inaccurate, and 

untimely reporting for one of the testing samples. In addition to the system 

issues, there were four procurement actions that had accuracy issues that were 

likely caused by data entry errors by procurement staff. 

Recommendations 

1. Until such time as the BFS ARC resolves the issue of PRISM only interfacing

the ‘draft’ version of a processed, finalized award to FPDS-NG, the Senior

Accountable Official (SAO) should develop policies and procedures that

ensure the timely reporting of procurement information to FPDS-NG.

2. The Senior Accountable Official (SAO) should develop policies and

procedures to enter and report procurement information accurately in the

DATA Act reporting process.

3. The Senior Accountable Official (SAO) should work with the Bureau of the

Fiscal Service Administrative Resource Center to develop policies and

procedures to enter and report procurement information accurately in the

DATA Act reporting process for instances when a vendor changes their

DUNS number.

Why We Did This Audit 

The Digital Accountability and

Transparency Act of 2014 (DATA 

Act) was enacted May 9, 2014. In 

part, the DATA Act requires the 

Inspector General (IG) of each

Federal agency to review a

statistically valid sample of the 

spending data submitted by its 

Federal agency and to submit to 

Congress a publicly available

report assessing the completeness, 

timeliness, quality, and accuracy 

of the data sampled and the

implementation and use of the 

Government-wide financial data

standards by the Federal agency. 

Background 

USAspending.gov was launched in 

December 2007 to implement the 

Federal Funding Accountability

and Transparency Act (FFATA) of 

2006 by providing the public with 

free centralized access to

information on Federal spending. 

The DATA Act expanded the 

reporting requirements pursuant 

to the FFATA. The DATA Act, in 

part, requires Federal agencies to 

report financial and award data in 

accordance with the established 

Government-wide financial data

standards. In 2015, the Office of 

Management and Budget (OMB) 

and Department of the Treasury 

published 57 data definition

standards and required Federal 

agencies to report financial data in 

accordance with these standards 

for DATA Act reporting, beginning 

May 2017.
2 

DATA ACT AUDIT, 2019 

BACKGROUND

USAspending.gov was launched in December 2007 to implement the Federal Funding 

Accountability and Transparency Act (FFATA) of 2006 by providing the public with free 

centralized access to information on Federal spending. To ensure USAspending.gov is providing 

current and accurate information, the Office of Management and Budget (OMB) and Federal 

agencies must take steps to ensure data reliability and quality. Reliable data allows the public to 

trust the information the government provides, and for Federal and elected officials to use that 

information to make informed decisions about government programs and projects. Reliable data 

also allows Federal managers to analyze and better structure government programs to prevent 

waste, fraud, and abuse. Further, reliable data provides those with an oversight function with the 

assurance that agencies and programs are accountable for the Federal funds spent.

The Digital Accountability and Transparency Act of 2014 (DATA Act) was enacted May 

9, 2014, to expand the reporting requirements pursuant to the FFATA. The DATA Act, in part, 

requires Federal agencies to report financial and award data in accordance with the established 

Government-wide financial data standards. In 2015, OMB and Department of the Treasury 

published 571 data definition standards and required Federal agencies to report financial data in 

accordance with these standards for DATA Act reporting, beginning May 2017. 

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

a statistically valid sample of the spending data submitted by its Federal agency and to submit to 

Congress a publicly available report assessing the completeness, timeliness, quality, and accuracy 

of the data sampled and the implementation and use of the Government-wide financial data 

standards by the Federal agency. 

The Council of the Inspectors General on Integrity and Efficiency (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 IGs provided Congress with their first required reports by November 8, 2017, 1-year after the 

statutory due date, with two subsequent reports to be submitted following on a 2-year cycle. On 

1 The 57 data elements including definitions can be found at 

https://portal.max.gov/portal/assets/public/offm/DataStandardsFinal.htm. 
3 

December 22, 2015, CIGIE’s chair issued a letter detailing the strategy for dealing with the IG 

reporting date anomaly and communicated the strategy to the Senate Committee on Homeland 

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

Reform. See CIGIE Anomaly Letter in Appendix B. 

FMC DATA ACT REPORTING

The Federal Maritime Commission’s (FMC) DATA Act reporting process involves 

multiple parties: Treasury’s Bureau of the Fiscal Service, Administrative Resource Center (BFS 

ARC); the FMC’s Senior Accountable Official (SAO) (Managing Director); the FMC’s Office of 

Budget and Finance (OBF); and the FMC’s Office of Management Services (OMS). The FMC

uses two systems for its spending data: Oracle Financials as its source system for all financial data, 

and the Procurement Request Information System Management (PRISM) as its source system for 

contract data. The FMC maintains an agreement with BFS ARC to provide financial system 

services and relies on BFS ARC to help meet DATA Act reporting requirements. 

A data broker is designed to standardize data formatting and help Federal agencies validate 

data submissions. The Treasury DATA Act Broker uses Federal spending data from agency award 

and financial systems, validates it, and standardizes it against the common DATA Act model that 

includes the following broker files: 

• File A: Appropriations Account 

• File B: Object Class and Program Activity

• File C: Award Financial 

• File D1: Award and Awardee Attributes—Procurement Awards 

• File D2: Award and Awardee Attributes—Financial Assistance Awards 

• File E: Additional Awardee Attributes 

• File F: Sub-Award Attributes 

Files A and B contain summary-level financial data. File C contains reportable recordlevel data. Files D1 and E contain detailed information for record-level transactions reported in 

File C. The FMC does not have files D2 or F because the agency does not have financial assistance 

awards, such as grants or loans. The FMC OIG did not assess the completeness, accuracy, 

timeliness, and quality of the data extracted from the System for Award Management (SAM) via 

the DATA Act Broker, as described in the Testing Limitations section of this report. 
4 

OBJECTIVES, SCOPE, AND METHODOLOGY

To meet the needs of the IG community, the CIGIE Federal Audit Executive Council 

(FAEC) established the DATA Act Working Group (Working Group). The Working Group’s 

mission is to assist the IG community in understanding and meeting its DATA Act oversight 

requirements by (1) serving as a working level liaison with the Department of the Treasury 

(Treasury), (2) consulting with the Government Accountability Office (GAO), (3) developing a 

common approach and methodology, and (4) coordinating key communications with other 

stakeholders. 

In consultation with GAO, as required by the DATA Act, the Working Group developed 

the CIGIE FAEC Inspectors General Guide to Compliance under the DATA Act, February 14, 

2019. The guide presents a baseline framework for the required reviews performed by the IG 

community and to foster a common methodology for performing these mandates. Under the 

DATA Act, each IG is required to issue three reports on its agency’s data submission and 

compliance with the DATA Act. The original 2017 guide was updated in 2019 for the second 

required report, due November 8, 2019, and may be updated again for the subsequent report due 

November 2021. 

We conducted this performance audit in accordance with Government Auditing Standards, 

2011 revision. Those standards require that we plan and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and conclusions based on our 

audit objectives. We believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions, based on our audit objectives. 

The objectives of this engagement are to assess the FMC’s: (1) completeness, timeliness, 

quality, and accuracy of fiscal year 2019, first quarter financial and award data submitted for 

publication on USAspending.gov; and (2) implementation and use of the Government-wide 

financial data standards established by OMB and Treasury. The OIG also followed-up on the 

FMC’s implementation of the 2017 DATA Act audit recommendation. The scope of this 

engagement was fiscal year 2019, first quarter financial and award data the FMC submitted for 

publication on USAspending.gov, and any applicable procedures, certifications, documentation, 

and controls to achieve this process. To accomplish the objectives of this audit, the OIG performed 

the following steps: 

• obtained an understanding of the criteria related to the FMC’s responsibilities to report 

financial and award data under the DATA Act;
5 

• assessed the agency’s systems, processes, and internal controls in place over data 

management under the DATA Act; 

• assessed the general and application controls pertaining to the procurement system from 

which the data elements were derived and linked; 

• assessed the agency’s internal controls in place over the financial and award data reported 

to USAspending.gov per OMB Circular A-1232; 

• reviewed the fiscal year 2019, first quarter financial and award data submitted by the 

agency for publication on USAspending.gov; 

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

data sampled for fiscal year 2019, first quarter; and 

• assessed the agency’s implementation and use of the 57 data definition standards 

established by OMB and Treasury. 

The DATA Act requires the IG of each Federal agency to review a statistically valid sample 

of the spending data submitted by its Federal agency and to submit to Congress a publicly available 

report assessing the completeness, timeliness, quality, and accuracy of the data sampled and the 

implementation and use of the Government-wide financial data standards by the Federal agency. 

The FAEC DATA Act Working Group guidance states the engagement team should select a 

statistically valid sample of certified spending data from the reportable award-level transactions 

(procurement awards) included in the agency’s certified data submission for File C, or Files D1 

and D2, if File C is unavailable. FMC’s File C contained 15 unique transactions and File D1 

contained 16 unique transactions. The FMC had no grant activity, and therefore the data broker 

did not generate Files D2. The FMC OIG decided to test 100% of the transactions because the total 

number of unique spending transactions was 16 or fewer. The testing included coverage of both 

Files C and D1. 

For each record selected for testing, we compared the information in FMC’s File C and 

File D1 to the source document (such as contract, modification, or other obligating document) to 

determine whether the records submitted for publication in USAspending.gov were complete, 

accurate, and timely, as defined below. 

• Completeness is defined as: for each of the required data elements that should have 

2 Office of Management and Budget, Appendix A to OMB Circular No. A-123, Management of Reporting and Data 

Integrity Risk, OMB Memorandum M-18-16 (June 6, 2018).
6 

been reported, the data element was reported in the appropriate files A through D1. 

• Timeliness is defined as: 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. 

Timeliness can be assessed in two ways: (1) Award financial data elements within File 

C should be reported within the quarter in which it occurred; and (2) Procurement 

award data elements within File D1 should be reported in FPDS-NG3 within 3 

business days after contract award in accordance with the Federal Acquisition 

Regulation (FAR) Part 4.604. 

• Accuracy is defined as: amounts and other data relating to recorded transactions have 

been recorded in accordance with the DAIMS4, Reporting Submission Specification 

(RSS), Interface Definition Document (IDD), and the online data dictionary; and 

agrees with authoritative source documentation. 

RESULTS

Assessment of Internal Control over Source Systems

 

The FMC has an interagency agreement with BFS ARC to provide the FMC with 

accounting and procurement systems and support. The FMC uses Oracle Financials as its source 

system for all financial data, and PRISM as its source system for contract data. We performed 

procedures to determine whether internal controls over PRISM, as they relate to the FMC’s FY 

2019 quarter 1 DATA Act submission, are properly designed, implemented, and operating 

effectively. Those procedures consisted of: 

• Gaining an understanding of the source system used for recording procurement 

transactions; 

• Reviewing BFS ARC’s Statement of Standards for Attestation Engagements Number 

18 (SSAE 18), Service Organization Controls (SOC) 1 report, and determining whether 

3 Government agencies are responsible for collecting and reporting data on federal procurements through the 

Federal Procurement Data System-Next Generation (FPDS-NG).

4 The DATA Act Information Model Schema (DAIMS) gives an overall view of the hundreds of distinct data 

elements used to tell the story of how federal dollars are spent. It includes artifacts that provide technical guidance 

for federal agencies about what data to report to Treasury including the authoritative sources of the data elements 

and the submission format.
7 

there were any issues noted by the auditors that could have an impact on the FMC’s 

DATA Act submission; and

• Obtaining an understanding of the FMC’s complementary customer agency controls as 

required by the BFS ARC SOC 1 report. 

Procurement information in FPDS-NG is generally updated through an interface in PRISM. 

However, during the audit the OIG learned of an issue whereby PRISM only interfaces the ‘draft’ 

version of a processed, finalized award into FPDS-NG. When a user initially launches FPDS-NG, 

the draft is created and stays this way until it is automatically finalized by the approval of the 

PRISM contract or award. However, we found that some awards were not getting automatically 

finalized in FPDS-NG. While the FMC is able to manually approve and finalize the draft in FPDSNG, the system does not generate a notice to the agency when manual approval is required. We 

did see several instances of errors that were as a result of this interface issue. 

When a vendor changes their Data Universal Numbering System (DUNS) number, a 

modification needs to be completed in PRISM, but there is a work-around that is required to 

process the modification. The Contracting Specialist is required to record a special coding in order 

for the modification to be processed by PRISM. This special coding is called a “double dash”. For 

example, to process a modification to a contract numbered FMC-16-C-0001 when the vendor’s

DUNS number has changed, the Contracting Specialist would need to add a double dash to the 

original contract number, such as “FMC-16-C-0001--”. However, due to the lack of clear 

procedures on the process to record transactions in PRISM and FPDS-NG when a vendor has 

changed their DUNS number, this caused incomplete, inaccurate, and untimely reporting for one 

of the testing samples.

Other than the issues noted above, we found that FMC designed and implemented effective 

internal controls over its source system. 

Assessment of Internal Controls over DATA Act Submission

We performed inquiry and document review to determine whether internal controls over 

the DATA Act submission were operating effectively. We found that overall, controls over the FY 

2019 quarter 1 DATA Act submission were effective, however we noted an improvement that

could be made to the DATA Act procedures. 

The FMC OIG’s 2017 DATA Act audit recommended that the “Senior Accountable 

Official (SAO) should develop policies and procedures to enter and report obligations in a manner 

that ensures they are included in the DATA Act reporting process; and ensure that any anomalies 
8 

are reviewed, reconciled, and corrected in a timely manner”5. The FMC implemented the 

recommendation and developed a Standard Operating Procedure (SOP) for reviewing, 

reconciling, correcting, and certifying data, but the SOP should be updated to reflect a change in 

the process since the OIG’s 2017 audit. The SOP references the DATA Act Reconciliation Tool,

a file that BFS previously provided to the FMC to assist in the FMC’s review, reconciliation, and 

correction of the FMC procurement data; however, the Reconciliation Tool is no longer provided. 

Further, the SOP does not address the circumstances when the SAO should qualify one or more of 

the FMC’s DATA Act files in the submission of the quarterly assurance statement, as the SAO did 

for the FY 19 Q1 data submission. 

Assessment of DATA Act Submission

We evaluated the FMC’s DATA Act submission to Treasury’s DATA Act Broker and 

determined that the submission was complete and submitted timely. 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. 

Summary-Level Data and Linkages for Files A, B, and C

We reconciled Files A and B to determine if they were accurate. Through our test work, 

we noted that Files A and B were accurate. Additionally, we reconciled the linkages between Files 

A, B, and C to determine if the linkages were valid and to identify any significant variances 

between the files. Our test work did not identify any significant variances between Files A, B, and 

C. 

Record-Level Data and Linkages for Files C and D1 

 

The OIG tested 15 records and 46 unique data elements for completeness, accuracy, and 

timeliness. 

Completeness of the Data Elements

The error rate for the completeness of the data elements is 6.33%. A data element was 

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

Accuracy of the Data Elements

The error rate for the accuracy of the data elements is 7.12%. A data element was 

considered accurate when amounts and other data relating to recorded transactions were recorded 

5 2017 DATA Act audit can be found at https://www.fmc.gov/wp-content/uploads/2019/04/DATAAct2017.pdf
9 

in accordance with the DAIMS, RSS, IDD, and the online data dictionary, and agree with the 

authoritative source records. 

Timeliness of the Data Elements

The error rate for the timeliness of the data elements is 24.21%. The timeliness of data 

elements was based on the reporting schedules defined by the procurement requirements. 

Quality of the Data Elements

Quality of the data elements is defined as data that is complete, accurate, and provided 

timely. The highest of the three error rates was used as the determining factor of quality. The 

following table provides the range of error in determining the quality of the data elements. 

Error Rate Quality Level

0-20% Higher

21-40% Moderate

41% and above Lower

Source: CIGIE FAEC Inspectors General Guide to Compliance under the DATA Act, 2/14/2019, Section 710.04. 

Based on our test work and the highest error rate of 24.21%, we determined that the quality

of the FMC’s data is considered Moderate. 

Testing Limitations

File E of the DATA Act Information Model Schema (DAIMS) contains additional awardee 

attribute information extracted from the System for Award Management (SAM) via the DATA Act 

Broker (broker). It is the prime awardee’s responsibility to report sub-award and executive 

compensation information in SAM. Data reported from SAM is generated in the broker for display 

on USAspending.gov. We did not assess the completeness, accuracy, timeliness, and quality of the 

data extracted from SAM via the DATA Act Broker.

Implementation and Use of the Data Standards 

We have evaluated the FMC’s implementation and use of the government-wide financial 

data standards for spending information as developed by OMB and Treasury. For the broker files 

tested, the required elements were generally present in the files except for the findings described

below. 
10 

FINDING 1– Timely Reporting to FPDS-NG

Condition 

There were three procurement actions that had untimely data elements in file D1 for the first 

quarter fiscal year 2019 DATA Act submission. 

Criteria

The DATA Act, in part, requires Federal agencies to report financial and award data in accordance 

with the established Government-wide financial data standards. In May 2015, the Office of 

Management and Budget (OMB) and Treasury published 57 data definition standards6 and 

required Federal agencies to report financial data in accordance with these standards for DATA 

Act reporting, beginning January 2017. 

Timeliness is determined 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. Timeliness can be assessed in two 

ways: (1) Award financial data elements within File C should be reported within the quarter in 

which it occurred; and (2) Procurement award data elements within File D1 should be reported in 

FPDS-NG within 3 business days after contract award in accordance with the FAR Part 4.604. 

Cause

When the FMC contracting specialist processes a procurement action in PRISM, the specialist 

launches the FPDS-NG application within PRISM to enable the procurement action to ultimately 

be reported to USAspending.gov. However, due to an undetermined system issue, in two cases, 

PRISM was only interfacing the ‘draft’ version of a processed, finalized award into FPDS-NG. As 

a result, FPDS-NG was not receiving the final version. While the FMC is able to manually approve 

and finalize the draft in FPDS-NG, the system does not generate a notice to the agency when 

manual approval is required. 

In one instance, the untimely reporting of data elements for an award was not a result of a system 

issue, and was likely the result of procurement staff not submitting the award to FPDS-NG within 

3 business days. 

6 The 57 data elements including definitions can be found at 

https://portal.max.gov/portal/assets/public/offm/DataStandardsFinal.htm
11 

Effect

DATA Act reporting for the first quarter of fiscal year 2019 was untimely for some D1 data 

elements. 

Recommendation 1 

Until such time as the BFS ARC resolves the issue of PRISM only interfacing the ‘draft’ version 

of a processed, finalized award to FPDS-NG, the Senior Accountable Official (SAO) should 

develop policies and procedures that ensure the timely reporting of procurement information to

FPDS-NG. 

Agency Comments 

Management agrees with this recommendation. When this issue was discovered during the audit 

process, the Office of Management Services consulted the Bureau of the Fiscal Service, 

Administrative Resource Center (BFS ARC) for assistance in determining the cause and resolution 

of the PRISM issue. Thereafter, a procedure was developed and implemented by OMS to ensure 

that PRISM procurement documents are properly finalized and that procurement information is 

timely reported to FPDS-NG. This procedure will be included in the DQP. 

OIG Response 

The agency’s comments are responsive to the OIG’s recommendation. 

FINDING 2 – Inaccurate Procurement Information

Condition 

There were four procurement actions that had inaccurate data elements in file D1 for the first 

quarter fiscal year 2019 DATA Act submission. 

Criteria

The DATA Act, in part, requires Federal agencies to report financial and award data in accordance 

with the established Government-wide financial data standards. In May 2015, the Office of 

Management and Budget (OMB) and Treasury published 57 data definition standards and required 
12 

Federal agencies to report financial data in accordance with these standards for DATA Act 

reporting, beginning January 2017. 

Accuracy is defined as: amounts and other data relating to recorded transactions that have been 

recorded in accordance with the DAIMS, Reporting Submission Specification (RSS), Interface 

Definition Document (IDD), and the online data dictionary; and agrees with authoritative source 

documentation. 

Cause

The OIG believes the likely cause of the inaccurate data was data entry errors by procurement staff 

processing awards in PRISM or FPDS-NG. 

Effect

DATA Act reporting for the first quarter of fiscal year 2019 was inaccurate for some D1 data 

elements.

Recommendation 2 

The Senior Accountable Official (SAO) should develop policies and procedures to enter and report 

procurement information accurately in the DATA Act reporting process. 

Agency Comments 

Management agrees that procurement information should be complete, accurate, and timely. 

During this audit process, a procedure was developed and implemented by OMS to ensure 

completeness, accuracy, and timeliness of information, and will be added to the DQP. 

OIG Response 

The agency’s comments are responsive to the OIG’s recommendation. 
13 

FINDING 3 – “Double Dash” Process 

Condition 

One procurement action was incomplete, inaccurate, and untimely because it did not appear in File 

D1. 

Criteria

The DATA Act, in part, requires Federal agencies to report financial and award data in accordance 

with the established Government-wide financial data standards. In May 2015, the Office of 

Management and Budget (OMB) and Treasury published 57 data definition standards7 and 

required Federal agencies to report financial data in accordance with these standards for DATA 

Act reporting, beginning January 2017. 

Accuracy is defined: as amounts and other data relating to recorded transactions have been 

recorded in accordance with the DAIMS, Reporting Submission Specification (RSS), Interface 

Definition Document (IDD), and the online data dictionary; and agrees with authoritative source 

documentation.

Timeliness is defined: as 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. Timeliness can be assessed in two 

ways: (1) Award financial data elements within File C should be reported within the quarter in 

which it occurred; and (2) Procurement award data elements within File D1 should be reported in 

FPDS-NG within 3 business days after contract award in accordance with the FAR Part 4.604. 

Completeness of a data element is defined as: for each of the required data elements that should 

have been reported, the data element was reported in the appropriate files A-D1. 

Cause

There is a lack of clear procedures on the process to record transactions in PRISM and FPDS-NG 

when a vendor has changed their DUNS number. When a vendor changes their Data Universal 

7 The 57 data elements including definitions can be found at 

https://portal.max.gov/portal/assets/public/offm/DataStandardsFinal.htm
14 

Numbering System (DUNS) number, a modification needs to be completed in PRISM, but there 

is a work-around that is required to process the modification. The Contracting Specialist is required 

to record a special coding in order for the modification to be processed by PRISM. This special 

coding is called a “double dash”. For example, to process a modification to a contract numbered 

FMC-16-C-0001 when the vendor’s DUNS number has changed, the Contracting Specialist would 

need to add a double dash to the original contract number, such as “FMC-16-C-0001--”. 

Effect

DATA Act reporting for the first quarter of fiscal year 2019 was inaccurate, incomplete, and 

untimely for the D1 data elements. 

Recommendation 3 

The Senior Accountable Official (SAO) should work with the Bureau of the Fiscal Service 

Administrative Resource Center to develop policies and procedures to enter and report 

procurement information accurately in the DATA Act reporting process for instances when a 

vendor changes their DUNS number. 

Agency Comments 

Management agrees with this recommendation, and received BFS ARC guidance on August 12, 

2019, on accurate reporting of procurement information when a vendor changes its DUNS number. 

The guidance was implemented by OMS and will be included in the DQP. 

OIG Response 

The agency’s comments are responsive to the OIG’s recommendation. 
15 

Appendix A – Agency Response

UNITED STATES GOVERNMENT FEDERAL MARITIME COMMISSION 

 Memorandum

TO : Inspector General DATE: October 29, 2019

FROM : Managing Director 

SUBJECT : A20-01, DATA Act Audit, 2019

I have reviewed the findings and recommendations contained in the subject audit. 

Management values the Office of the Inspector General’s efforts in reviewing the Commission’s 

implementation of and compliance with the DATA Act. We appreciate the recommendations 

for improvement in this important effort. 

The OIG recommended that the DATA Act SOP for Reviewing, Reconciling, Correcting, 

and Certifying Data be updated. Prior to the end of FY 2019, a Data Quality Plan (DQP) was 

developed, which supersedes that SOP. The DQP will be supplemented by the end of the first 

quarter of FY 2020 to reflect the IG’s recommendations as noted below. 

Recommendation #1: Until such time as the BFS ARC resolves the issue of PRISM only 

interfacing the ‘draft’ version of a processed, finalized award to FPDS-NG, the Senior 

Accountable Official (SAO) should develop policies and procedures that ensure the timely 

reporting of procurement information to FPDS-NG. 

Comment: Management agrees with this recommendation. When this issue was discovered 

during the audit process, the Office of Management Services consulted the Bureau of the Fiscal 

Service, Administrative Resource Center (BFS ARC) for assistance in determining the cause and 

resolution of the PRISM issue. Thereafter, a procedure was developed and implemented by 

OMS to ensure that PRISM procurement documents are properly finalized and that 

procurement information is timely reported to FPDS-NG. This procedure will be included in the 

DQP.

Recommendation #2: The Senior Accountable Official (SAO) should develop policies and 

procedures to enter and report procurement information accurately in the DATA Act reporting 

process. 

Comment: Management agrees that procurement information should be complete, accurate, 

and timely. During this audit process, a procedure was developed and implemented by OMS to 

ensure completeness, accuracy, and timeliness of information, and will be added to the DQP. 
16 

Recommendation #3: The Senior Accountable Official (SAO) should work with the BFS ARC to 

develop policies and procedures to enter and report procurement information accurately in the 

DATA Act reporting process for instances when a vendor changes their DUNS number. 

Comment: Management agrees with this recommendation, and received BFS ARC guidance on 

August 12, 2019, on accurate reporting of procurement information when a vendor changes its 

DUNS number. The guidance was implemented by OMS and will be included in the DQP.

 Karen V. Gregory

cc: Office of the Chairman
17 

Appendix B – CIGIE Date Anomaly Letter

CIGIE’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 
18 

Appendix B 

CIGIE’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 
19 

Appendix C – FMC’s Results for the Data Elements

The table below summarizes the results of our data element testing. Results are sorted in 

descending order by completeness error rate (the data element with the highest completeness error 

rate is listed first). This table is based on the results of our testing of the 15 unique procurement 

records submitted in FMC's FY 2019, Quarter 1 DATA Act submission. Note: some data elements 

were not applicable for the 15 records. 

FMC's results listed in descending order by completeness error rate.

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

Data 

Element 

No. 

File Data Element Name

Error Rate

C A T 

1 of 1 of 1 of 

29 File D1 Ordering Period End Date 1 1 1 

1 of 1 of 3 of 

23 File D1 Award Modification/ Amendment Number 6 6 6 

1 of 1 of 2 of 

24 File D1 Parent Award ID Number 7 7 7 

1 of 1 of 3 of 

36 File D1 Action Type 11 11 11

1 of 1 of 4 of 

1 File D1 Awardee/Recipient Legal Entity Name 15 15 15

1 of 1 of 4 of 

2 File D1 Awardee/Recipient Unique Identifier 15 15 15

1 of 1 of 4 of 

3 File D1 Ultimate Parent Unique Identifier 15 15 15

1 of 1 of 4 of 

4 File D1 Ultimate Parent Legal Entity Name 15 15 15

1 of 1 of 4 of 

5 File D1 Legal Entity Address 15 15 15

1 of 1 of 4 of 

6 File D1 Legal Entity Congressional District 15 15 15

1 of 1 of 4 of 

7 File D1 Legal Entity Country Code 15 15 15

1 of 1 of 4 of 

8 File D1 Legal Entity Country Name 15 15 15

1 of 1 of 4 of 

11 File D1 Federal Action Obligation 15 15 15

1 of 2 of 4 of 

14 File D1 Current Total Value of Award 15 15 15

1 of 2 of 4 of 

15 File D1 Potential Total Value of Award 15 15 15

1 of 1 of 4 of 

16 File D1 Award Type 15 15 15

1 of 1 of 4 of 

17 File D1 NAICS Code 15 15 15
20 

Data 

Element 

No. 

File Data Element Name

Error Rate

C A T 

18 File D1 NAICS Description

1 of 

15

1 of 

15

4 of 

15

22 File D1 Award Description

1 of 

15

1 of 

15

4 of 

15

25 File D1 Action Date

1 of 

15

2 of 

15

4 of 

15

26 File D1 Period of Performance Start Date

1 of 

15

2 of 

15

4 of 

15

27 File D1 Period of Performance Current End Date

1 of 

15

1 of 

15

4 of 

15

28 File D1 Period of Performance Potential End Date

1 of 

15

2 of 

15

4 of 

15

30 File D1 Primary Place of Performance Address

1 of 

15

1 of 

15

4 of 

15

31 File D1 Primary place of Performance Congressional District

1 of 

15

1 of 

15

4 of 

15

32 File D1 Primary Place of Performance Country Code

1 of 

15

1 of 

15

4 of 

15

33 File D1 Primary Place of Performance Country Name

1 of 

15

1 of 

15

4 of 

15

34 File C Award ID Number (PIID/FAIN)

1 of 

15

1 of 

15

4 of 

15

38 File D1 Funding Agency Name

1 of 

15

1 of 

15

4 of 

15

39 File D1 Funding Agency Code

1 of 

15

1 of 

15

4 of 

15

40 File D1 Funding Sub Tier Agency Name

1 of 

15

1 of 

15

4 of 

15

41 File D1 Funding Sub Tier Agency Code

1 of 

15

1 of 

15

4 of 

15

42 File D1 Funding Office Name

1 of 

15

1 of 

15

4 of 

15

43 File D1 Funding Office Code

1 of 

15

1 of 

15

4 of 

15

44 File D1 Awarding Agency Name

1 of 

15

1 of 

15

4 of 

15

45 File D1 Awarding Agency Code

1 of 

15

1 of 

15

4 of 

15

46 File D1 Awarding Sub Tier Agency Name

1 of 

15

1 of 

15

4 of 

15

47 File D1 Awarding Sub Tier Agency Code

1 of 

15

1 of 

15

4 of 

15

48 File D1 Awarding Office Name

1 of 

15

1 of 

15

4 of 

15

49 File D1 Awarding Office Code

1 of 

15

1 of 

15

4 of 

15
21 

Data 

Element 

No. 

File Data Element Name

Error Rate

C A T 

24 File C Parent Award ID Number

0 of 

7

0 of 

7

0 of 

7

34 File C Award ID Number (PIID/FAIN)

0 of 

15

0 of 

15

0 of 

15

50 File C Object Class

0 of 

15

0 of 

15

0 of 

15

51 File C Appropriations Account

0 of 

15

0 of 

15

0 of 

15

53 File C Obligation

0 of 

15

0 of 

15

0 of 

15

12 File D2* Non-Federal Funding Amount N/A N/A N/A

13 File D2* Amount of Award N/A N/A N/A

19 File D2* Catalog of Federal Domestic Assistance (CFDA) Number N/A N/A N/A

20 File D2* Catalog of Federal Domestic Assistance (CFDA) Title N/A N/A N/A

35 File D2* Record Type N/A N/A N/A

37 File D2* Business Types N/A N/A N/A

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

57 N/A Outlay N/A N/A N/A

56 File C Program Activity N/A N/A N/A

*Only applicable to Federal Assistance Awards, therefore not applicable to FMC. 
22 

Appendix D – Analysis of the Accuracy of Dollar Value-Related Data 

Elements

Our testing included tests of certain dollar value-related data elements, such as federal action 

obligation, current total value of award, potential total value of award, and transaction obligation 

amount. The table below shows the results of the accuracy of the data elements related to dollar 

value. 

Accuracy of Dollar-Value Related Data Elements

Data Element Number and Name Accurate Not 

Accurate

N/A Total 

Tested

Error 

Rate

Absolute Value of 

Errors

11 Federal Action Obligation 14 1 0 15 6.67% $116,069.30

14 Current Total Value of Award 13 2 0 15 13.33% $122,195.17

15 Potential Total Value of Award 13 2 0 15 13.33% $173,019.43

53 Transaction Obligation Amount 15 0 0 15 0.00% $ - 

Total 55 5 0 60
23 

Appendix E – Analysis of Errors in Data Elements 

There were two different third-party system errors, PRISM only interfaces the ‘draft’ version of a 

processed, finalized award into FPDS-NG, and special coding requiring a double dash. Please see 

page 6 of this report for more information. The third party is aware of both issues and is working 

with the FMC to address them. The below table shows the breakdown of errors that are attributable 

and not attributable to the agency. 

Incomplete Inaccurate Untimely

Total Errors Total # 

of 

Errors

40 45 153

Error 

Rate

6.33% 7.12% 24.21%

Errors 

Attributable 

to the FMC 

Total # 

of 

Errors

0 5 37

Error 

Rate

0.00% 0.79% 5.85%

Errors Not 

Attributable 

to the FMC 

Total # 

of 

Errors

40 40 116

Error 

Rate

6.33% 6.33% 18.35%