Office of Inspector General

 DATA Act Readiness Review 

A16-03 

September 2016 

FEDERAL MARITIME COMMISSION
 
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Federal Maritime Commission 

Office of Inspector General 

Report 

Highlights 

Increased Engagement by the FMC Will be Positive 

for the Success of Implementation Efforts 

(DATA Act Readiness Review, September 2016, Assignment 16-03) 

Why We Did This 

Review 

The objective of this 

readiness review was 

to gain an 

understanding of the 

processes, systems 

and controls which 

the FMC has 

implemented, or plans 

to implement, to 

report Federal agency 

expenditures and link 

Federal spending 

information in 

accordance with the 

requirements of the 

DATA Act. This 

understanding is 

necessary for the OIG 

to develop an 

informed methodology 

for the future OIG 

reviews required by 

the DATA Act. In 

addition, the results of 

this review will enable 

the OIG to provide 

suggestions on how to 

improve the likelihood 

of compliance with the 

requirements of the 

DATA Act prior to full 

implementation. 

Background 

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

enacted May 9, 2014 and, among other things, requires that Federal 

agencies (FMC) report financial and payment data in accordance with data 

standards established by the Department of Treasury (Treasury) and the 

Office of Management and Budget (OMB). The data reported will be 

displayed on a website available to taxpayers and policy makers. In 

addition, the DATA Act requires that agency Offices of Inspectors General 

(OIGs) review statistical samples of the data submitted by the agency under 

the DATA Act and report on the completeness, timeliness, quality and 

accuracy of the data sampled and the use of the data standards by the 

agency. 

What We Found 

While the OIG recognizes the FMC is largely relying on the implementation 

efforts of the Bureau of the Fiscal Service (BFS), the OIG believes the FMC 

should be more actively engaged in the overall implementation of the DATA 

Act requirements. The OIG’s review focused on the first four steps of the 

Agency 8-Step Plan based on the OMB Memorandum M-15-12. Overall, 

the OIG found the FMC had not completed, or only partially completed, 

some of these first four steps. 

Suggestions 

1. The FMC’s planned update of the DATA Act implementation plan should 

encompass both the FMC’s and the Bureau of the Fiscal Service’s 

responsibilities, and include expanded narrative and cost information; 

milestones; and project plan of completed and future steps. 

2. The FMC DATA Act working group should better define the personnel 

assigned to the group, as well as their responsibilities. Working group 

members should have an understanding of who their team members 

are, and should develop proper communication thereafter to hold 

regular and necessary meetings. 

3. The FMC should establish its own methodology for reviewing data, 

systems and milestones, to include those completed on their behalf by 

the Bureau of the Fiscal Service. 

4. Consistent with the FMC’s stated intentions, the DATA Act Senior 

Accountable Official (SAO) should be a senior management official with 

the ability to coordinate across multiple offices, including Budget and 

Finance, and Procurement. 

Corrective Action 

Prior to the release of this final report, the agency generally adopted all 

four of the OIG suggestions. The agency updated and improved their 

DATA Act implementation plan, better defined the FMC working group 

responsible for the DATA Act, and appointed a new DATA Act Senior 

Accountable Official with the ability to coordinate efforts across multiple 

offices. 
 

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Table	of	Contents	

INTRODUCTION................................................................................................................................................... 1
 

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

REVIEW OBJECTIVES ........................................................................................................................................... 2
 

SCOPE AND METHODOLOGY.............................................................................................................................. 3
 

CONCLUSIONS & SUGGESTIONS......................................................................................................................... 9
 

Appendix A – CIGIE DATA Act Anomaly Letter................................................................................................ 10
 

Appendix B – Agency Implementation Plan October 2015............................................................................. 12
 

Appendix C – Agency Response & August 2016 Revised FMC DATA Act Implementation Plan.................... 15
 

		
 

 

 

 

INTRODUCTION 

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

May 9, 2014 and, among other things, requires that Federal agencies report 

financial and payment data in accordance with data standards established by the 

Department of Treasury (Treasury) and the Office of Management and Budget 

(OMB). The data reported will be displayed on a website available to taxpayers and 

policy makers. In addition, the DATA Act requires that agency Offices of Inspectors 

General (OIGs) review statistical samples of the data submitted by the agency under 

the DATA Act and report on the completeness, timeliness, quality and accuracy of 

the data sampled and the use of the data standards by the agency. 

The DATA Act provides for this oversight by way of the OIGs and the Comptroller 

General of the United States. That is, the Act requires a series of oversight reports, 

and these will begin in calendar year 2017. 

BACKGROUND 

The Federal Maritime Commission (FMC) is an independent Federal agency of the 

United States government responsible for regulating the U.S. international ocean 

transportation system for the benefit of the U.S. exporters, importers, and the U.S. 

consumer. The FMC’s mission is to foster a fair, efficient, and reliable international 

ocean transportation system and to protect the public from unfair and deceptive 

practices. FMC is an appropriated agency with a fiscal year (FY) 2016 appropriation 

of $25,660,000. 

The FMC is directed by five commissioners nominated by the President and 

confirmed by the Senate, each serving a staggered five-year term. No more than 

three members of the Commission may be from the same political party. The 

President designates one commissioner to serve as Chairman. In FY 2015, the FMC 

was authorized 124 full-time equivalents (FTEs), and had 121 employees onboard 

at fiscal year’s end. The majority of these employees are located in Washington, 

D.C., with a small number of personnel stationed in major U.S. seaport locations in 

Houston, Los Angeles, New Orleans, New York/New Jersey, Seattle/Tacoma, and 

South Florida. 

The FMC has an interagency agreement with the Bureau of the Fiscal Service (BFS) 

to provide full service accounting and financial reporting services. BFS maintains 

the financial accounts of the FMC and prepares its financial statements. According 

to the FMC, BFS’ Administrative Resource Center (ARC) will largely handle 

implementation efforts for the DATA Act on the FMC’s behalf, with FMC oversight 

and input. In addition, the National Finance Center (NFC) is FMC’s Federal Shared 

Service Provider (FSSP) for personnel and payroll processing. All requisitions and 

procurement documents are entered into BFS’ PRISM system by FMC’s Contracting 

Specialist, Contracting Officer and staff. 

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 

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is, the first Inspector General (IG) reports are due to Congress in November 2016; 

however, Federal agencies are not required to report spending data until May 2017. 

To address this reporting date anomaly, the OIGs plan to provide Congress with 

their first required reports in November 2017, a 1-year delay from the statutory due 

date, with subsequent reports following on a 2-year cycle. Although CIGIE 

determined the best course of action was to delay the IG reports, CIGIE is 

encouraging OIGs to undertake DATA Act “Readiness Reviews” at their respective 

agencies well in advance of the first November 2017 report. 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. Appendix A contains a copy of this letter. 

The IG community, through the Federal Audit Executive Council (FAEC) stood up 

the FAEC DATA Act Working Group (Working Group). On December 03, 2015, the 

Working Group issued the DATA Act Readiness Review Guide (version 1.0) to assist 

OIGs in their readiness reviews. That guide concentrated on steps 1 through 4 of 

the “Agency 8-Step Plan” as described in the DATA Act Implementation Playbook 

(version 1.0). In addition, the FAEC produced the DATA Act Readiness Review guide 

version 2.0 on June 02, 2016, which includes procedures for the OIGs’ review on 

each of the 8 steps from the original implementation plan. This OIG review focused 

on steps 1 through 4 of the “Agency 8-Step Plan” per Office of Management and 

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

Making Federal Spending Data Accessible, Searchable, and Reliable, and M-10-06, 

Open Government Directive. Further, the OIG focused the review on the FMC’s 

actions to date, future plans, and oversight of their DATA Act implementation 

service provider, the Bureau of the Fiscal Service. 

REVIEW OBJECTIVES 

The objective of the readiness review was to gain an understanding of the processes, 

systems and controls which the Federal Maritime Commission (FMC) has 

implemented, or plans to implement, to report Federal agency expenditures and 

linking Federal spending information in accordance with the requirements of the 

DATA Act. This understanding is necessary for the OIG to develop an informed 

methodology for the future OIG reviews required by the DATA Act. In addition, the 

results of this review will enable the OIG to provide suggestions on how to improve 

the likelihood of compliance with the requirements of the DATA Act prior to full 

implementation. 

2 
 

	 	

SCOPE AND METHODOLOGY 

To accomplish the objectives of this review, the OIG initiated this DATA Act 

Readiness Review on June 15, 2016 and performed the following review steps: 

	 Obtained an understanding of the laws, directives, and any other regulatory 

criteria (and guidance) related to FMC’s responsibilities to report financial and 

payment information under the DATA Act. 

	 Obtained an understanding of the FMC governance structure, processes, and 

controls planned and/or established using a questionnaire and meetings with 

the individuals responsible for the implementation of the DATA Act at the 

agency-level, to include the FMC’s Senior Accountable Official (SAO). 

 Identified the major reporting components within the agency responsible for 

implementation of the DATA Act. 

 Assessed FMC’s efforts and formal implementation plans to report financial and 

payment information under the DATA Act. 

The OIG performed the review using the FAEC’s DATA Act Working Group’s 

Readiness Review Guide version 2.0, June 02, 2016. The Readiness Review Guide 

incorporates guidance from the Office of Management and Budget, to include 

Memoranda M-15-12 and M-10-06. The table that follows provides a series of 

checklists for each implementation step based on guidance from OMB and the 

Department of Treasury. Based on meetings and a written questionnaire, the OIG 

obtained information from the FMC on their progress and future implementation 

plans. The OIG’s assessment and comments are included in the table on the 

following pages. 

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Step 1 Checklist – Organize Team

Milestone Details Initial OMB

Suggested

Timeline

OIG Comments

Designate

Senior

Accountable

Official (SAO)

SAO	is	responsible	for	their	

agency’s	implementation, which	

includes	overseeing	the	

governance	and	progress	of	the	

workgroup.

Spring 2015 At the time of the OIG review, the

FMC’s DATA Act SAO is the

Director of the Office of Budget

and Finance (OBF). Because the

OBF Director is not responsible

for oversight of the procurement

office, a component of the DATA

Act implementation, the SAO

should be a higher level

management official. At the

time of this review, the FMC

indicated a plan to designate the

Managing Director/Chief

Financial Officer as the SAO.

Form

workgroup with	

subject	matter	

experts	(SMEs)	

In	addition	to	SMEs,	be	sure	to

identify	and	engage	with key	

stakeholders,	including	Federal	

Shared	Service	Providers	

(FSSPs),	agencies	with	similar	

business	lines	or	systems,	and	

your	Inspector	General.	

Spring 2015 The FMC had not formally

identified members of a DATA

Act working group. The FMC

advised the OIG that an updated

DATA Act implementation plan

being drafted will identify the

position titles of the working

group members.

Review 8 Step

Plan and	develop	

agency	

roadmap/project	

plan	

Determine	key	agency	

implementation	milestones,	a	

workgroup	governance	

structure,	and roles	and	

responsibilities	of	people	and	

offices within	your	agency.	

Spring 2015 The FMC developed an

implementation plan, dated

October 2015. However, the

plan lacks sufficient narrative

detail, and does not include

milestones to monitor progress.

The OIG understands the FMC is

currently updating their

implementation plan.

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Step 2 Checklist – Review Elements

Milestone Details Initial OMB

Suggested

Timeline

OIG Comments

Read May OMB	

policy	guidance	

(M‐15‐12)

Read	guidance	and identify key

requirements,	along	with	

remaining	questions	and

clarifications needed	from	OMB	

and	Treasury.	OMB	guidance	is

available at:

https://www.whitehouse.gov/s

ites/default/files/omb/memor

and/2015/m‐15‐12.pdf.

Spring 2015 The OIG identified evidence

that the FMC’s SAO and

other staff received

guidance and key

requirements provided by

OMB, Treasury, and their

FSSP.

Review

standards for	

data	elements

Treasury and	OMB	are	posting	

data	standards	online.		

Agencies	can	also	review	the	

existing	USAspending.gov

data	elements,	which	need	to	be	

captured	in	addition	to	the	

standardized	elements.	

May – September

2015

Step 2 of the FMC’s

October 2015

implementation plan

states that the

Commission’s DATA Act

working group will review

the list of DATA Act

elements identified by ARC

and, if necessary or

appropriate, will

participate with ARC in

data definitions

standardization. The OIG

could find no evidence that

the FMC has completed

this step.

Communicate

feedback	and

questions	to	OMB	

and	Treasury

Agencies	have	an	opportunity	

to	provide	feedback	on

OMB/Treasury	policy	decisions	

through	advisory	councils	

and	Treasury.		

May – September

2015

According to the FMC,

there have been no specific

questions submitted to

OMB or Treasury.

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Step 3 Checklist – Inventory Data

Milestone Details Initial OMB

Suggested

Timeline

OIG Comments

Locate DATA Act	

elements,	

agency/FSSP	

systems

Identify	and	understand	

linkages	and/or	gaps	in	how	

DATA	Act	elements	are	

captured	in the	financial	and	

management	award	systems.	

Some	helpful	resources	

include—	Data	inventory	

template	and	Blueprints	and	

Blueprint	guides.	

March – September

2015	

The OIG understands that

the FMC has relied on their

FSSP (BFS) to review data

linkages. The OIG has

evidence that their FSSP

(BFS) identified these

linkages on their

customers’ behalf.

Document

systems,

processes,	and	

policies	for	each	

element

Gather	relevant	subject	matter	

experts,	data	dictionaries,	and	

other	technical	documentation	

and	planning	in order	to

inventory	how	its	elements,	

sources,	processes,	regulations,	

and	policies	fit	together.		

Document	the	role	of	FSSPs	and	

enterprise	resource	planning	

(ERP)	vendors,	along	with	

planning	migration and	changes	

to	information	technology	

systems.	

June – September

2015	

Step 3 of the FMC’s

October 2015

implementation plan

states that the

Commission’s DATA Act

working group will

perform an inventory of

data and associated

business processes

managed by the FMC. The

OIG could not find evidence

that the FMC has

completed this step. The

FMC’s FSSP (BFS) has

identified changes to

information technology

systems at the FSSP and

communicated this to FMC.

Identify gaps in	

agency	systems	

and	processes	

(Re)review DATA Act	

requirements	and	finalized	data	

standards	and	identify	

anticipated gaps	in	

completeness	of	data,	such as	

whether	award	ID,	object	class,	

and	program activity	are

recorded	in	financial systems.	

July – September

2015

Based on information

provided by the SAO to the

OIG, the FMC’s FSSP (BFS)

has identified data gaps at

the FSSP and reported this

to FMC.

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Step 4 Checklist – Design and Strategize

Milestone Details Initial OMB

Suggested Timeline

OIG Comments

Establish leads

and/or	integrate	

project	teams;	

plan	to	capture	

all	DATA	Act	

elements;	and	

plan	linkage		of	

core	financial	

and	mixed	feeder	

management

systems	by	

award	ID

Establish	some	leads	and/or	

smaller	integrated	project	

teams	that	will	work	to	develop	

solutions	to	fill	each	specific	

gap	in agency	data;	develop	

options	for	any	gaps	in	the

completeness and	accuracy	of	

the	DATA Act;	and	develop	

options	for	any	gaps	in	the

linkage	of	financial	and	non‐

financial	DATA	Act elements.		

August – December

2015

According to the SAO, the

FMC will rely on BFS to

complete these

requirements.

Update

implementation

plans and	submit	

to	OMB

After	an	initial	inventory of	

DATA	Act	elements,	processes,	

and	systems,	agency	

workgroups	should	update	the	

DATA	Act	implementation	

plans.	

March – September

2015

The OIG has received the

FMC’s original

implementation plan

dated October 2015. The

OIG has also identified that

as of July 2016, the FMC is

making revisions to the

plan.

Build "mapping

engine" and

"validation

engine"

Map	data	from	the	Agency

Schema	(original	format) to

the	DATA	Act	Schema	and	

apply	basic	validation	rules	to	

verify	data	are	accurate	and	

consistent	with	the	DATA Act	

Schema	metadata.	

October 2015	–

February	2016	

(update	iteratively)

According to the SAO, the

FMC will rely on BFS to

complete these

requirements.

Build interface

that	provides	

validation

reports	and	other	

desired	

functionality	to	

end	users; and	

build	method to

retrieve data

from	agency	and	

government‐

wide	sources

The	interface	allows	data	

stewards	within	the	agency to	

receive	validation	reports	and	

provides	other	functionality;	

and	components	can	retrieve

data	from	multiple	agency	

systems	and	government‐wide	

systems.			

Winter	/	spring	

2016	

(update	iteratively)

According to the SAO, the

FMC will rely on BFS to

complete these

requirements.

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Milestone Details Initial OMB

Suggested Timeline

OIG Comments

Build	method	to

transfer data

between	agency

data	

store/broker	to	

Treasury;	test

mapping	to	

DATA Act	

Schema;	and test	

submission	

process	to	

Treasury

This	component	will	transfer	

data from	the agency to	the	

government‐wide	repository	at	

Treasury;	sample,	and test	

validity	for	data	and	

compliance	with	DATA	Act	

standard;	and	verify	data	are	

accurately	and	consistently	

transferred to	Treasury.

Spring/summer/fall

2016	

(update	iteratively)

According to the SAO, the

FMC is relying on BFS to

transfer their data, and

test its mapping and

submission.

Analyze data in	

DATA Act	

Schema	to	inform	

future	planning

Analyze	data	to	inform	future	

system	updates,	process	

changes,	and

agency	planning	and	policy.	

Ongoing According to the SAO, the

FMC will rely on BFS to

complete this requirement.

Update source

systems to	

capture	DATA	

Act	elements and	

required	linkages

Start	to	make	needed	system	

changes	to	link	financial	

and	mixed	feeder	systems	by	

award	ID.	Also	make

additional	system	changes	to	

resolve	gaps	identified	by	

the	data inventory	and	DATA	

Act	implementation	

planning	process.	

October 2015 –

February	2017	

According to the SAO, the

FMC will rely on BFS to

complete this requirement.

Re‐test data	

transfer

processes	as	

needed

As	new	data	are	captured,	re‐

test	IT	architecture	that	

retrieves	data	and	maps	to the

DATA	Act	Schema.	

Late	2016	/	early	

2017

According to the SAO, the

FMC will rely on BFS to

complete this requirement.

Submit to	

Treasury

Be sure to	verify	data	are fully	

submitted.

Early	2017 Successful completion of

these milestones is

necessary for

implementation.

8 
CONCLUSIONS	 	 & SUGGESTIONS		

While the OIG recognizes the FMC is largely relying on the implementation efforts 

of the Bureau of the Fiscal Service (BFS), the OIG believes the FMC should be 

more actively engaged in the overall implementation of the DATA Act 

requirements. The OIG’s review focused on the first four steps of the Agency 8-

Step Plan based on the Office of Management and Budget’s Memorandum M-15-

12. Overall, the OIG found the FMC had not completed, or only partially 

completed, some of these first four steps. Increased engagement by the FMC will 

be positive for the success of implementation efforts. In this regard, the OIG 

provides the following suggestions for improvement: 

1. The FMC’s planned update of the DATA Act implementation plan should 

encompass both the FMC’s and the Bureau of the Fiscal Service’s 

responsibilities, and include expanded narrative and cost information; 

milestones; and project plan of completed and future steps. 

2. The FMC DATA Act working group should better define the personnel 

assigned to the group, as well as their responsibilities. Working group 

members should have an understanding of who their team members are, and 

should develop proper communication thereafter to hold regular and 

necessary meetings. 

3. The FMC should establish its own methodology for reviewing data, systems 

and milestones, to include those completed on their behalf by the Bureau of 

the Fiscal Service. 

4. Consistent with the FMC’s stated intentions, the DATA Act Senior 

Accountable Official (SAO) should be a senior management official with the 

ability to coordinate across multiple offices, including the Office of Budget 

and Finance, and Procurement. 

Prior to the release of this final report, the agency generally adopted these four 

suggestions. The agency updated and improved their DATA Act implementation 

plan, better defined the FMC working group responsible for the DATA Act, and 

appointed a new DATA Act Senior Accountable Official with the ability to 

coordinate efforts across multiple offices. 

9 
Appendix A – CIGIE DATA Act Anomaly Letter

10 
11 
Appendix B – Agency Implementation Plan October 2015

12 
13 
14 
Appendix C – Agency Response & August 2016 Revised FMC DATA Act

			Implementation Plan

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