Office of Inspector General

DATA Act Audit, 2017 

A18-03

 NOVEMBER 2017

 FEDERAL MARITIME COMMISSION
 
Table of Contents 

BACKGROUND ............................................................................................................................ 1
	

FMC DATA ACT REPORTING.................................................................................................... 2
	

OBJECTIVES, SCOPE, AND METHODOLOGY ........................................................................ 3
	

RESULTS ....................................................................................................................................... 5
	

Complete, Timely, Accurate, and of Good Quality ................................................................. 5
	

Applicable DATA Act Standards Were Used ......................................................................... 5
	

Testing Limitations ................................................................................................................. 6
	

FINDING – Reporting and Reconciliation ..................................................................................... 6
	

Appendix A – Agency Response .................................................................................................... 8
	
	 	 	 	

 

 

DATA ACT AUDIT, 2017
 

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 in 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 May 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 January 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. 

Completeness is measured in two ways: (1) all transactions that should have been recorded 

are recorded in the proper reporting period; and (2) as the percentage of transactions containing all 

applicable data elements required by the DATA Act. Timeliness is measured as the percentage of 

transactions reported within 30 days of quarter end. Accuracy is measured as the percentage of 

transactions that are complete and agree with the systems of record or other authoritative sources. 

Quality is defined as a combination of utility, objectivity, and integrity: utility refers to the 

1

 The 57 data elements including definitions can be found at https://fedspendingtransparency.github.io/dataelements/. 

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usefulness of the information to the intended users; objectivity refers to whether the disseminated 

information is being presented in an accurate, clear, complete, and unbiased manner; and integrity 

refers to the protection of information from unauthorized access or revision. 

As written in the DATA Act, the first set of IG reports were due to Congress in November 

2016. However, Federal agencies were not required to submit spending data in compliance with 

the DATA Act until May 2017. As a result, IGs were not able to report on the spending data 

submitted under the DATA Act, as this information would not exist until 2017. For this reason, 

the Council of the Inspectors General on Integrity and Efficiency (CIGIE) developed an approach 

to address the reporting date anomaly. The IGs plan to provide Congress with the first required 

reports by November 8, 2017, 1-year later than the due date in the statute, with subsequent reports 

following on a 2-year cycle, in November 2019 and November 2021. On December 22, 2015, 

CIGIE’s chair issued a letter memorializing the strategy for dealing with the IG reporting date 

anomaly and communicated it to the Senate Committee on Homeland Security and Governmental 

Affairs and the House Committee on Oversight and Government Reform. 

FMC	DATA	ACT	REPORTING	

The FMC’s 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 meet DATA Act reporting requirements. BFS ARC uses Oracle Financials and PRISM 

to perform financial spending data reconciliations and to extract data for reporting to 

USAspending.gov. 

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

data submissions. The data 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: 

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 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 required data at the 

award level. Files D1 and E contain detailed demographic information for award-level 

transactions; these files may contain one or more of the 57 required standard government-wide 

data elements, such as award type, action date, and period of performance. The FMC does not 

have files D2 or F because the agency does not have financial assistance awards, such as grants 

or loans. 

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, the Working Group developed the Inspectors General (IG) 

Guide to Compliance Under the Digital Accountability and Transparency Act of 2014, February 

27, 2017. The guide presents a common methodological and reporting approach for the IG 

community to use in performing its mandated work. 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 

February 2017 guide has been developed for the first required report due November 8, 2017, and 

will be updated for subsequent reports due November 2019 and 2021 based on feedback from the 

IG community and GAO after the first reports have been issued. 

We conducted this performance audit in accordance with generally accepted government 

auditing standards, issued by the Comptroller General of the United States. Those standards 

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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 2017, second 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 scope of this first engagement 

was fiscal year 2017, second 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. According to OMB’s Management Procedures Memorandum No. 2016-

03, data reported by Federal agencies in fiscal year 2017, second quarter was to be displayed on 

USAspending.gov by May 2017. To accomplish the objectives of this audit, the OIG performed 

the following steps: 

 obtained an understanding of the criteria related to its agency’s responsibilities to report 

financial and award data under the DATA Act; 

 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 financial management
	

systems (e.g. procurement) 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-123; 

 reviewed the fiscal year 2017, second 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; 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 guidance says the engagement team should randomly select a statistically valid sample of 

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certified spending data from the reportable award-level transactions 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 13 unique transactions and File D1 contained 11 unique transactions. The FMC had no 

grant activity, and therefore the data broker did not generate Files D2 or F. The FMC OIG decided 

to test 100% of the transactions because the total number of unique spending transactions was 13 

or fewer. The testing included coverage of both Files C and D1. 

RESULTS	

Complete, Timely,	Accurate,	and of	Good Quality

Except for a limited number of exceptions, the OIG determined that the FMC transactions 

audited for publication on USAspending.gov were complete, accurate, timely, and of good 

quality. The OIG found completeness errors attributable to the FMC (error rate of approximately 

26%). The OIG also identified both completeness and accuracy errors attributable to issues 

associated with the DATA Act broker or other external causes; however, the OIG did not calculate 

an error rate for causes where the agency does not have control. We assessed these characteristics 

using the framework provided in the FAEC guide. Overall, the OIG made the following 

conclusions on the spending data submitted by the FMC for reporting on USAspending.gov, as 

follows: 

•		 Complete. With some exception, the OIG found the spending data contained the applicable 

elements and were submitted for the proper reporting period. 

•		 Accurate. With few exceptions, transactions included the obligated amount and a 

document number containing a combination of unique identifiers, and all data submitted 

matched the accounting data in the FMC’s financial systems of record. 

•		 Timely. All data were reported within 30 days of the quarter’s end. 

•		 Quality. All data were generally of good quality—that is, data were complete, timely, and 

accurate, and the FMC’s and the service provider’s internal controls over source systems 

and the data submission gave us reasonable assurance that controls were designed, 

implemented, and operating effectively. 

Applicable	DATA	Act	Standards Were	Used

Based on the OIG’s testing, we found that the FMC implemented and used the governmentwide financial data standards as established by OMB and Treasury, as applicable. For the broker 

files tested, we generally found that the required elements were present in the files and that the 

transaction values were presented in accordance with the standards. 

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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). File F contains sub-award attribute information extracted from the FFATA 

Subaward Reporting System (FSRS) via the broker. It is the prime awardee’s responsibility to 

report sub-award and executive compensation information in SAM and FSRS. Data reported from 

these two award reporting systems are generated in the broker for display on USAspending.gov. 

As outlined in OMB’s Management Procedures Memorandum 2016-03, the authoritative sources 

for the data reported in Files E and F are SAM and FSRS respectively with no additional action 

required of Federal agencies. As such, we did not assess the completeness, accuracy, timeliness, 

and quality of the data extracted from SAM and FSRS via the DATA Act Broker. 

FINDING	–	Reporting	and	Reconciliation	

Condition 

The OIG found four transactions that were not reported in FPDS-NG2 for the 2nd quarter of fiscal 

year 2017, and therefore would not be reported on USAspending.gov. In addition, of these four 

transactions, two were not reported in File C. 

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 standards3 and 

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

Act reporting, beginning January 2017. 

Completeness is measured in two ways, (1) all transactions (summary-level data and/or awardlevel data) that should have been recorded are recorded in the proper reporting period4 and (2) as 

the percentage of transactions containing all applicable data elements required by the DATA Act.5 

2

 FPDS-NG provides procurement data to USAspending.gov, and interfaces with PRISM, the FMC’s system for
	

contracting.

3

 The 57 data elements, including definitions, can be found at https://fedspendingtransparency.github.io/dataelements/.
	 4

 GAO-08-585G, GAO Financial Audit Manual, (July 25, 2008). 

5

 OMB Open Government Directive – Federal Spending Transparency, (April 6, 2010). 

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Cause 

The OIG believes the likely cause is the failure to enter the transactions in FPDS-NG at the time 

of award. In addition, the OIG found no evidence that FMC had adequately reviewed, reconciled, 

or corrected the anomalies that the financial service provider prepared for the FMC. 

Effect 

DATA Act reporting for the second quarter of fiscal year 2017 may have been incomplete and 

obligation data reported to USAspending.gov for that quarter may have been understated by the 

amounts of the awards not entered in FPDS-NG. 

Recommendation 

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 are reviewed, reconciled, and corrected in a timely manner. 

Agency Comments 

Management agrees with the recommendation, and will take corrective action to ensure that, going 

forward, staff will enter and report obligations properly, and that there is a process in place for the 

timely review, reconciliation, and / or correction of any anomalies in the data provided by the 

Bureau of the Fiscal Service (the Commission's financial services provider) to ensure that the 

DATA Act reporting is accurate. It is anticipated that an SOP will be developed to memorialize 

this process by the end of the second quarter of FY 2018. 

OIG Response 

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

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UNITED STATES GOVERNMENT FEDERAL MARITIME COMMISSION 

Memorandum 

TO Inspector General DATE: November 8, 2017 

FROM Managing Director 

SUBJECT : Data Act Audit, 2017 (A-18-03)- Management's Response 

I have reviewed the finding and recommendation contained in the subject report. Commission 

management values the efforts of the OIG in reviewing our DATA Act implementation, and 

appreciate the recommendations for improvement in this important effort. 

Recommendation: 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 are reviewed, reconciled, and 

corrected in a timely manner. 

Comment: Management agrees with the recommendation, and will take corrective action to 

ensure that, going forward, staff will enter and report obligations properly, and that there is a 

process in place for the timely review, reconciliation, and I or correction of any anomalies in 

the data provided by the Bureau of the Fiscal Service (the Commission's financial services 

provider) to ensure that the DATA Act reporting is accurate. It is anticipated that an SOP will be 

developed to memorialize this process by the end of the second quarter of FY 2018. 

cc: Office of the Chairman 

Appendix	A	–	Agency	Response
 

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