Federal Data Transparency: Opportunities Remain to Incorporate Lessons Learned as Availability of Spending Data Increases
Published: 2013-09-12T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The federal government spends more than $3.7 trillion annually, with more than $1 trillion awarded through contracts, grants, and loans. Improving transparency of spending is essential to improve accountability. Recent federal laws have required increased public information on federal awards and spending. GAO was asked to review current efforts to improve transparency. This report examines (1) transparency efforts under way and (2) the extent to which new initiatives address lessons learned from the Recovery Act. GAO reviewed relevant legislation, executive orders, OMB circulars and guidance, and previous GAO work, including work on Recovery Act reporting. GAO also interviewed officials from OMB, the GAT Board, and other federal entities; government reform advocates; associations representing fund recipients; and a variety of contract and grant recipients.
section_title: What GAO Found
paragraphs: Several federal entities, including the Government Accountability and Transparency Board (GAT Board), the Recovery Accountability and Transparency Board (Recovery Board), and the Office of Management and Budget (OMB), have initiatives under way to improve the accuracy and availability of federal spending data. The GAT Board, through its working groups, developed approaches to standardize key data elements to improve data integrity; link financial management systems with award systems to reconcile spending data with obligations; and leverage existing data to help improve oversight. With no dedicated funding, GAT Board plans are incremental and leverage ongoing agency initiatives designed to improve existing business processes as well as improve data transparency. These initiatives are in an early stage, and some progress has been made to bring greater consistency to award identifiers. The GAT Board's mandate is to provide strategic direction, not to implement changes. Further, while these early plans are being developed with input from a range of federal stakeholders, the GAT Board and OMB have not developed mechanisms for obtaining input from non-federal fund recipients.
Lessons from implementing the transparency objectives of the Recovery Act could help inform these new initiatives:
Standardize data to integrate systems and enhance accountability . Similar to the GAT Board's current focus on standardization, the Recovery Board recognized that standardized data would be more usable by the public and the Recovery Board for identifying potential misuse of federal funds. However, reporting requirements under the Recovery Act had to be met quickly. Because agencies did not collect spending data in a consistent manner, the most expedient approach was to collect data from fund recipients, even though similar data already existed in agency systems. Given the longer timeframes to develop current transparency initiatives, OMB and the GAT Board are working toward greater data consistency by focusing on data standards. Their plans, however, do not include long-term steps, such as working toward uniform award identifiers that would improve award tracking with less burden on recipients.
Obtain stakeholder involvement as reporting requirements are developed . During the Recovery Act, federal officials listened to the concerns of recipients and made changes to guidance in response, which helped ensure they could meet those requirements. Without similar outreach under current initiatives, reporting challenges may not be addressed, potentially impairing the data's accuracy and completeness, and increasing burden on those reporting.
Delineate clear requirements and lines of authority for implementing transparency initiatives . Unlike the present efforts to expand spending transparency, the Recovery Act provided OMB and the Recovery Board with clear authority and mandated reporting requirements. Given this clarity, transparency provisions were carried out successfully and on time. Going forward, without clear, legislated authority and requirements, the ability to sustain progress and institutionalize transparency initiatives may be jeopardized as priorities shift over time.
section_title: What GAO Recommends
paragraphs: GAO recommends that the Director of OMB, with the GAT Board, develop a long-term plan to implement comprehensive transparency reform, and increase efforts for obtaining stakeholder input to ensure reporting challenges are addressed. Further, Congress should consider legislating transparency requirements and establishing clear authority to implement these requirements to ensure that recommended approaches for improving transparency are carried out across the federal government. The GAT Board, OMB and other cognizant agencies generally concurred with GAO's recommendations and provided further information, which was incorporated into the report as appropriate.

section_title: Letter
paragraphs: The federal government spends more than $3.7 trillion annually. Of that,  more than $1 trillion is awarded through contracts, grants, and loans, and  an additional $1 trillion is forgone in tax revenues through tax  expenditures. Transparency—shedding light on the amount of spending,  what it is spent on, who receives the funds, and what are the results of  that spending—is essential to improving government accountability and  fostering civic engagement. Within the last decade, Congress and the  administration have taken several steps to improve the transparency of  federal spending data, including the passage of two statutes intended to  expand public access to information on federal programs. The first, the  Federal Funding Accountability and Transparency Act of 2006 (FFATA),  required the establishment of an information website on grant and  contract awards and subawards. Today, this federal agency and  subrecipient information is available at www.USAspending.gov. The  second, the American Recovery and Reinvestment Act of 2009 (Recovery  Act), required that recipients’ reports on award and spending data be  made available on a website. Today, this information is accessible at  www.Recovery.gov. These transparency efforts have enabled civic  engagement, and have allowed the public—from ordinary citizens to  sophisticated data users—to access information on spending, recipients,  and uses of funds. The data’s availability has also provided opportunities  for increased oversight to prevent and detect fraud, waste, and abuse of  federal funds, and to improve the efficiency and effectiveness of federal  spending.
While many believe that the transparency of federal spending data has  increased, both the administration and members of Congress have  suggested the need for more transparency. At present, USAspending.gov  only provides data on funds awarded; the site does not include  information on disbursements. In terms of data collection, federal  agencies and recipients report to various systems, sometimes with the  same information and, as a result, direct unnecessary time and resources  to administrative activities. In addition, the lack of consistent data  structures prevents easy aggregation of data at the government-wide  level, hampering the ability to link existing financial, award, and  procurements systems. It also increases the cost of government  transactions and the burden on federal fund recipients. And, as we have  reported previously, the accuracy and reliability of the data needs to be  improved. Emerging transparency efforts include specific changes in  data collection under consideration by the Government Accountability and  Transparency Board (GAT Board), newly-created under a June 2011  Executive Order. Further, proposed legislation has been introduced in  the House and the Senate designed to improve the transparency of  federal spending data.
Given these various initiatives under way, you asked us to examine  federal efforts to increase the transparency of federal spending data, and  identify lessons from the experience of operating existing data systems  that could contribute to these efforts. We examined (1) federal initiatives  to improve the accuracy and availability of federal spending data and (2)  the extent to which lessons identified by us and federal fund recipients  from the operation of Recovery.gov and USAspending.gov are being  addressed by these new transparency initiatives.
To address these objectives we examined data collection and reporting  requirements under FFATA and the Recovery Act; the June 2011  Executive Order related to transparency; relevant Office of Management  and Budget (OMB) guidance; and action plans created by the GAT Board,  Recovery Board, and other federal entities with responsibility for  developing approaches to improve federal data transparency. We  interviewed officials at OMB, the GAT Board, and the Recovery Board  who are examining new data transparency initiatives. We also interviewed  officials at three agencies who are developing new transparency  prototypes within their agencies: the Department of Defense (DOD), the  Department of Health and Human Services (HHS), and the Department of  Treasury (Treasury), respectively. We also interviewed officials at the  General Services Administration (GSA), the agency that manages  USAspending.gov. To get their perspectives on lessons learned from both  the operation of existing transparency systems and federal efforts under  way to improve data transparency, we spoke with officials from  organizations representing federal fund recipients and government reform  organizations. We also conducted seven focus groups with federal fund  recipients representing state and local governments, nonprofit  organizations, higher education research institutions, and private  businesses who receive grants from, or contracted with, the federal  government. Finally, we reviewed our previous work on the reporting  successes and challenges experienced by both agencies and federal  fund recipients. This step allowed us to identify lessons learned from  those experiences that should be considered as new approaches to data  transparency are developed. Although we spoke with numerous affected  entities and stakeholders with opinions on transparency, our work should  not be considered to be generalizeable to all who have opinions about  these issues.
We conducted this performance audit from November 2012 to September  2013 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 objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives. For more information on  our objectives, scope, and methodology, see appendix I.
subsections: section_title: Background
paragraphs: Between 2006 and 2011, Congress initiated two significant efforts to  increase public awareness of, and access to, federal spending data: the  Federal Funding Accountability and Transparency Act of 2006 (FFATA),  and the American Recovery and Reinvestment Act of 2009 (Recovery  Act). Both acts mandated the creation of public-access websites, which  involved a broad range of data-collection and data-reporting activities,  and required OMB and federal agencies, among others, to address  multiple levels of accountability and transparency. The passage of FFATA  was part of a series of legislative and executive branch efforts to make  comprehensive data on federal awards available to the public. Congress  passed FFATA in 2006 to increase the transparency of and accountability  for the more than $1 trillion in contracts and financial assistance awarded  annually by federal agencies. Among other things, the act required OMB  to establish a free, publicly accessible web site containing data on federal  awards (e.g., contracts, loans, and grants) no later than January 1, 2008.  In addition, the act required OMB to include data on subawards by  January 1, 2009 and authorized OMB to provide guidance and instruction  to agencies to ensure the existence and operation of the website, and  required agencies to comply with that guidance. OMB launched the web  site—www.USASpending.gov—in December 2007. However, in 2010, we  reported that the award data in USAspending.gov was not always  complete or reliable.
OMB, Open Government Directive, M-10-06 (Washington, D.C.: Dec. 8, 2009). to collect subaward data.the main sources of USAspending.gov data.
FPDS-NG is a contract database that is one of  In crafting the Recovery Act, Congress and the administration envisioned  an unprecedented level of transparency into federal spending data. The  act required recipients of Recovery Act funds to submit quarterly reports  with information on each project or activity, including the amount and use  of funds and an estimate of the number of jobs created and the number of  jobs retained. Similar to FFATA, the Recovery Act called for the  establishment of a website that would give the public access to  information on the many projects and activities funded under the act. The  Recovery Accountability and Transparency Board launched the  Recovery.gov site in 2009 to fulfill these requirements. In addition, a  second site—www.FederalReporting.gov—was established for recipients  to report their data. Recipients first reported in early October 2009 on the  period from February through September 2009. Reporting has continued  for each quarter since then.
More recently, in June 2011, the administration issued Executive Order  13576 “Delivering an Efficient, Effective, and Accountable Government.”  The order, among other things, established the GAT Board to provide  strategic direction for enhancing transparency of federal spending data.  The GAT Board was also charged with advancing efforts to detect fraud,  waste, and abuse of federal programs. Its 11 members include agency  inspectors general, agency chief financial officers, a senior OMB official  and other such members as the President shall designate. The GAT  Board is mandated to work with the Recovery Board to build on lessons  learned from the Recovery Act’s implementation.
USAspending.gov and Recovery.gov rely on different sources of  information, and make different types of data available to the public.  USAspending.gov provides information on federal award obligations,  including the recipient’s name, funding agency, amount of award, and  descriptive title. It relies primarily on data submitted by federal agencies  and, to some extent, by recipients. In addition, agencies use different  reporting platforms to submit information about contract and grant  awards. In contrast, Recovery.gov, which relies primarily on information  submitted by recipients, provides information on federal award  expenditures, including information on each project or activity funded, the  amount and use of funds, and an estimate of the jobs funded.
The USAspending.gov website draws data from different data sources, as  shown in figure 2.
The Federal Procurement Data System-Next Generation:  Procurement data are imported from this system, which collects  information on contract actions, procurement trends, and achievement  of socioeconomic goals, such as small business participation. OMB  was responsible for establishing the system, and GSA administers it.  Since 1980, FPDS-NG and its predecessor FPDS have been the  primary government-wide databases for contracting information.  Federal agencies are responsible for ensuring the information  reported in this database is complete and accurate.
The Data Submission and Validation Tool: Data on financial  assistance awards (grants, loans, loan guarantees, cooperative  agreements and other assistance) are provided by federal agencies  and are transmitted directly to GSA via this tool. As with FPDS-NG,  federal agencies are responsible for ensuring the information reported  in this database is complete and accurate.
The FFATA Subaward Reporting System: Contractors and grant  recipients use this tool to capture and report subaward and executive  compensation data regarding their first-tier subawards to meet the  FFATA reporting requirements. Contractors and grant recipients are  required to file a report within a specified timeframe after making a  subaward greater than $25,000 and they are responsible for ensuring  information reported to this database is complete and accurate.
In contrast to USAspending.gov, Recovery.gov’s data are collected from  federal fund recipients. Section 1512 of the Recovery Act requires  recovery fund recipients to report quarterly on Recovery Act-related  spending. Recipients provide their information to the agency through  FederalReporting.gov. Agencies, then, review the data provided. The  validated data are then published on Recovery.gov, as illustrated by  figure 3.
section_title: Transparency Efforts Under Way Focus On Standardizing Data to Integrate Systems and Enhance Spending Oversight
subsections: section_title: With Its Role Limited to Providing Strategic Direction, the GAT Board Is Leveraging Ongoing Agency Initiatives for Implementation
paragraphs: The GAT Board’s role is to provide strategic direction for enhancing  federal spending transparency. Along with OMB and the Recovery Board,  it oversees several ongoing government-wide initiatives designed to  expand the transparency of federal spending data. As part of its role to  provide strategic direction, the GAT Board established four work groups  in 2012 and 2013 (see figure 4). These groups are charged with  developing approaches for improving transparency across three  functional areas—procurement, grants, and financial management—and  expanding data availability to improve spending oversight. Work group  members represent the federal procurement, grants, financial  management, and oversight communities. The members are set up to  leverage the collective expertise of several interagency forums.
Procurement Data Standardization and Integrity Working Group:  The work group was established to identify approaches for  standardizing contract data elements and electronic transactions to  ensure data are accurate and contract transactions can be tracked  from purchase order through vendor payment. As the federal  government’s largest contracting agency, DOD is a lead agency on  this work group, along with members of OMB’s Office of Federal  Procurement Policy (OFPP). The Procurement Work Group initiative  grew out of OMB’s and DOD’s long-standing efforts to improve the  accuracy of contract data that agencies submit to FPDS-NG. Work  group members also include representatives from the Chief  Acquisition Officers Council, an interagency forum of agency  acquisition officers.
Grants Data Standardization and Integrity Working Group: The  work group has been tasked with developing approaches to  standardize grants data elements to achieve greater consistency  across the federal government. HHS, along with OMB’s Office of  Federal Financial Management (OFFM), provides leadership to this  work group. Members also include representatives from the newly  established Council on Financial Assistance Reform (COFAR).  According to HHS officials, the group’s efforts build on the agency’s  prior work with the Grants Policy Council and the Grants Executive  Board to standardize and streamline grant procedures.
Financial Management Integration and Data Integrity Working  Group: The GAT Board, in conjunction with Treasury, is examining  approaches for linking the financial management data maintained in  agency financial systems with agency awards data in order to improve  the quality of data displayed to the public. The GAT Board established  this work group to align with Treasury’s ongoing efforts to define their  data vision and approach, including a proposal to move the  administrative responsibility for USAspending.gov from the GSA to  Treasury. While the GAT Board is responsible for setting direction and  developing strategy, the Board is leveraging Treasury’s on-going  modernization efforts with assistance from OFFM.
Data Analytics Working Group: The work group was formed in  response to the executive order establishing the GAT Board, which  required the board to advance efforts to detect and remediate fraud,  waste, and abuse in federal programs. The group is under the  direction of the Inspector General of the United States Postal Service  and has representatives from the Recovery Board. The group also  provides information about its activities with the Council of Inspectors  General for Integrity and Efficiency. The working group’s goal is to  expand on the Recovery Board’s Recovery Operation Center (ROC)  for improving fraud detection in federal spending.
The GAT Board, through its working groups, is in the process of  determining approaches for carrying out its mission. However, its  mandate is only to develop strategy, not to implement it. The GAT Board  relies on the working groups’ lead agencies to develop recommendations  and implement approaches that it has approved. Moreover, with no  dedicated funding, the GAT Board’s strategic plan is short-term and calls  for an incremental approach that builds upon ongoing agency initiatives.  These initiatives include efforts to modernize systems or improve agency  management, designed to improve existing business processes as well  as improve data transparency. The GAT Board’s initial plans largely  focus on efforts at the federal level and some progress has been made to  bring greater consistency to award identifiers.
Data standardization and a uniform convention for identifying contract and  grant awards throughout their life cycle are the first steps in ensuring data  quality and tracking spending data. The GAT Board’s December 2011  Report to the President notes that introducing greater consistency into the  award process will help better reconcile spending information from  multiple sources and allow for more effective analysis and oversight.  Currently, efforts under way are aimed at introducing more consistency  into the way federal spending data are reported, collected, and publically  displayed. Initial efforts are focused on identifying approaches to  standardize contract and grant data elements. These efforts are intended  to improve the accuracy of spending data, link award data to payment  data to help track awards throughout the life cycle, and advance efforts to  detect and remediate fraud, waste, and abuse. While these efforts are  largely in the early stages of development, progress has been made to  establish more uniform award identifiers, and to test the plausibility of  using data standards and a centralized data-collection portal to minimize  the burden of federal fund recipients.
The members of the FAR Council jointly issue and maintain a single government-wide  procurement regulation, known as FAR. The FAR Council’s membership consists of the  OFPP Administrator for Federal Procurement Policy, the Secretary of Defense, the  Administrator of the National Aeronautics and Space Administration, and the GSA  Administrator. The Council manages, coordinates, controls, and monitors the maintenance  of, issuance of, and changes in, FAR. 41 U.S.C. §§ 1301–1304. The FAR Council  periodically publishes rules implementing changes to the FAR. A final rule is typically  preceded by a proposed rule, published in the Federal Register and seeking public  comments. for all contracting offices.across various systems and across its life cycle.
This would enable a contract to be tracked  OMB, in consultation with the GAT Board, has issued new guidance that  requires all federal agencies to establish unique identification numbers for  financial assistance awards. It also mandates agencies to check the  accuracy of spending information against an official record of agency  accounts. grant award data, it only requires agencies to assign award numbers  unique within their agency to grant transactions. Thus, the guidance does  not provide the same level of uniformity as is required for contracts nor  does it provide uniformity across all contract and financial assistance  spending. Agencies and even subunits of agencies use inconsistent  award-numbering systems. These respective systems are created to  conform to their own internal agency management systems to identify  contracts, grants, and loans. In many agencies, there is no direct link or  continuous use of one standard award identifier between systems and  offices. The disparate award identification systems and naming  conventions used by agencies today make the task of reporting and  tracking spending data inefficient and burdensome. Recovery Board  officials raised some concerns, noting that a lack of uniform standards for  identifying grants would make it difficult to pre-populate recipient reports  with information from the awarding agency, and reconcile obligation with  award data. While this lack of uniformity may not optimize the use of the  data, OMB has noted that, in combination with other information provided,  it will uniquely identify a given grant. Further, in their oral comments on  our draft report, an OMB staff member told us that standardizing an  identifier format could cause problems for agency systems because some  agencies structure their award identifiers to track particular characteristics  of grants for their internal use. Therefore, OMB has issued this guidance  and then will evaluate the improvements in light of the added resources  needed to implement them.
The June 12, 2013, memorandum, “Improving Data Quality for USAspending.gov,”  requires all federal agencies to (1) assign financial assistance award identification  numbers unique within the Federal agency; and (2) identify and implement a process to  compare and validate USAspending.gov funding information with data in the agency’s  financial system.
As part of its work with the Grants Data Standardization and Integrity  Working Group, HHS recently completed a preliminary analysis to  determine the degree to which grants data elements are standardized  across the federal government. According to the chair of the GAT Board,  it is currently more challenging to standardize grants data elements  because, unlike FAR’s uniform procurement regulations, there is no  single set of grant regulations in use across the federal government.
The Recovery Accountability and Transparency Board recently concluded  a proof-of-concept project that tests the feasibility of using  FederalReporting.gov, to collect data on non-Recovery Act grant  expenditures. In a pilot involving nine grant recipients and two federal  agencies, the Grant Reporting Information Project (GRIP) captured data  elements from OMB’s standardized grant expenditure reporting form  Standard Form 425, as well as subrecipient and vendor expense data.  GRIP also tested whether such a system could lessen reporting burden  and improve the accuracy of the data submitted by fund recipients. In  addition, the pilot tested whether the use of a universal award  identification number could be used to track grant expenditures  throughout the grant life cycle. The Recovery Board’s analysis of the  GRIP project found that feedback from the pilot participants supported  using FederalReporting.gov for grant reporting. The analysis also  validated the effectiveness of using a universal award identifier. In  addition, the board’s analysis found that, while such features as machine- readable formats and pre-populated data fields helped the reporting  experience, due to the pilot’s short duration, GRIP did not fully  demonstrate that it could reduce the burden on recipients. Similarly, the  Federal Demonstration Partnership, whose member universities  participated in the GRIP pilot, issued a report. It found that, while using a  standard schema increases reporting efficiency, and pre-populating data  can enhance reporting and verify accuracy, at least initially, the pilot did  not reduce the burden on recipients.
section_title: The GAT Board Is Building on Treasury’s Efforts to Integrate Financial Management Systems to Track Spending Better
paragraphs: Information about federal government spending is collected in a complex  web of systems and processes that are both overlapping and fragmented.  While having standardized data and award identifiers is an important first  step to effectively track spending, federal entities also have begun to  examine ways to consolidate and streamline data systems that are  overlapping or duplicative. The Financial Management Integration and  Data Display Working Group is developing recommendations for a work  plan that will leverage Treasury’s on-going transparency and system  modernization efforts.
First, building on Treasury’s initiative to standardize payment transaction  processes, the Payment Application Modernization project will  consolidate more than 30 agency payment systems into a single  application. This application will process agency payment requests using  Treasury’s Standard Payment Request format. All federal agencies that  use Treasury disbursing services (Treasury disbursing organizations) will  be directed to submit payment data into the newly developed standard  format by October 1, 2014. A Treasury official said that federal agencies  representing about 142 of 437 agency location codes had either  converted to the new format, were testing the new format, or had set a  schedule when they would implement the new payment request format.  Despite the finding, this official expressed doubt about the ability of some  agencies that do not use Treasury for disbursing payments to comply with  the data standards by the deadline. The official did note that Treasury  continues to provide assistance to these agencies.
Second, the Financial Management Integration and Data Display Working  Group is also building on Treasury’s initiative to develop a centralized  repository containing detailed and summarized records of payment  transactions from all federal agencies. The Payment Information  Repository will contain data on all payments disbursed by Treasury plus  those reported by the Federal agencies that disburse their own  payments. This repository will contain descriptive data on those  payments for which matching with other data sources (e.g. accounting  data, grant data, commercial vendor data, geographic data, etc.) will  provide additional information regarding the purpose, program, location  and commercial recipient of the payment.
section_title: GAT Board Efforts Also Focus on Leveraging Existing Data to Enhance Spending Oversight
paragraphs: A number of government oversight and law enforcement agencies are  using data analytics—which involve a variety of techniques to analyze  and interpret data to facilitate decision making—to help identify and  reduce fraud, waste, and abuse. Data mining applications are emerging  as essential tools to inform management decisions, develop government- wide best practices and common solutions, and effectively detect and  combat fraud in large programs and investments. For example, predictive  analytic technologies can identify fraud and errors before payments are  made. Others, such as data-mining and data-matching techniques, can  identify fraud or improper payments that have already been awarded.  Thus, agencies have help in recovering these dollars. Data mining  applications are emerging as essential tools to inform management  decisions as well. According to GAT Board officials, making more data  available, and doing so in real time, will help agencies make better  informed decisions about how they manage federal funds.
The Recovery Board’s ROC, established in 2009, uses data analytics to  monitor Recovery Act spending to detect and prevent the fraudulent use  of funds made available under the act. As part of this effort, ROC analysts  use a set of tools that can search large amounts of data from multiple  sources. This process is designed to look for patterns and anomalies that  could indicate the existence of fraud. The Board has provided several  inspectors general with access to these tools through  www.FederalAccountability.gov. This site allows inspectors general to  review and evaluate entities, such as individuals, companies, and  universities, who have received Recovery Act funds. In some cases, ROC  staff was able to notify some agencies that they had awarded Recovery  funds to companies that were debarred. Thus, these companies should  not have received federal funds. For example, ROC analysts found  hidden assets that resulted in a court ordering the payment of a fine. They  also found several individuals employed by other entities while receiving  worker’s compensation benefits.
The GAT Board’s Data Analytics Working Group has set a goal of  expanding on the ROC’s work to develop a shared platform for improving  fraud detection in federal spending programs. This approach relies on the  development of data standards. It will provide a set of analytic tools for  fraud detection to be shared across the federal government. Although this  work is just starting, working group members have identified several  challenges to developing and implementing a shared platform and  analytic tools for fraud detection. These challenges include reaching  consensus among federal agencies on a set of common data attributes to  be used, and changes needed to existing privacy laws to allow access to  certain types of protected data and systems.
In January 2013, we convened a forum on data analytics in conjunction  with the Council of the Inspectors General on Integrity and Efficiency and  the Recovery Board. Its purpose was to explore ways in which oversight  and law enforcement agencies use data analytics to detect and prevent  fraud, waste, and abuse, and to identify the most significant challenges to  realizing the potential of data analytics. Forum participants identified a  range of challenges, including technical and legal challenges currently  experienced by oversight and law enforcement agencies. In particular,  participants highlighted challenges to expanding data sharing within the  federal government, including requirements of the Computer Matching  and Privacy Protection Act of 1988, as amended, that hindered fraud  detection efforts and a lack of data standards and a universal award  identifier that limit data sharing across the federal government and across  federal, state, and local agencies. Participants also identified  opportunities to enhance data-analytics efforts. These opportunities  included consolidating data and analytics operations in one location to  increase efficiencies by enabling the pooling of resources as well as  accessing and sharing of the data.
section_title: As Transparency Efforts Get Under Way, Opportunities Remain to Incorporate Lessons Learned from the Recovery Act
paragraphs: The GAT Board’s mandated responsibilities include working with the  Recovery Board to build on lessons learned and applying approaches  developed by the Recovery Board to new efforts to enhance the  transparency of federal spending. As discussed above, the GAT Board,  the Recovery Board, OMB, and other federal agencies have initiatives  under way to improve federal spending transparency. These initiatives  include efforts to standardize data and consolidate data systems to  improve the accuracy of federal spending and expand oversight of these  funds. In many cases these initiatives build on lessons learned from the  operation of existing transparency systems, including Recovery.gov and  USAspending.gov. However, as new transparency initiatives get under  way, opportunities exist to give additional consideration to these lessons  to help ensure new transparency programs and policies are implemented  successfully.
subsections: section_title: Lesson One: Standardized Data Enhances Accountability and Supports Systems Integration
paragraphs: One of the key lessons learned from the implementation of the Recovery  Act’s transparency provisions, was the value of standardized data,  including a uniform award identification number for contracts, grants,  loans, and other forms of financial assistance. The transparency  envisioned under the Recovery Act for tracking spending was  unprecedented for the federal government, requiring the development of  a system that could track billions of dollars disbursed to thousands of  recipients. The system also needed to be operational quickly for a variety  of programs, across which even the basic question of what constituted a  program or project differed. While agencies had systems that captured  such information as award amounts, funds disbursed, and, to varying  degrees, progress being made by recipients, the lack of uniform federal  data and reporting standards made it difficult to obtain these data from  federal agencies. Instead data were collected directly from recipients,  which placed additional burden on them to provide these data.
As it developed procedures for reporting on the use of federal funds,  OMB directed recipients of covered funds to use a series of standardized  data elements. Further, rather than report to multiple government entities,  each with its own disparate reporting requirements, all recipients of  Recovery funds were required to report centrally into the Recovery  Board’s inbound reporting website, FederalReporting.gov. According to  the GAT Board’s 2011 report to the President, the Recovery Board’s  method for collecting consistent recipient data on spending and posting it  rapidly was effective and significantly increased the speed and quality of  the spending data reported. The availability of standardized data also  allowed the Recovery Board to use data analytics and predictive analysis  to detect, prevent, and remediate the fraudulent use of Recovery Act  funds. The Recovery Board reported that as a result, the board’s analysts  were able to find multiple tax liens, regulatory violations, and suspicious  financial activity for several companies under investigation by an  inspector general. They also were able to notify a number of agencies  that they had awarded Recovery funds to companies that were debarred  and therefore should not have received federal funds. Initially, the ROC  was deployed to detect and prevent fraud under the Recovery Act. In  2012, Congress provided the board the authority to test processes and  technologies for monitoring federal spending. As a result, the board— while continuing to maintain its Recovery Act fraud-prevention efforts—  has expanded its joint efforts with inspectors general and law  enforcement agencies.
As discussed above, the GAT Board had previously identified data  standardization, including moving agencies toward a universal,  standardized identification system for all federal awards, as a critical step  for increased transparency. However, the degree to which data will be  standardized across the federal government is still the subject of some  debate among Board members. The recent OMB guidance requiring a  unique, but not uniform, grant identifier will result in a less standardized  approach for grants than contracts. Further, citing agency budgetary  constraints and the potential of emerging technologies for extracting non- standard data elements from disparate systems, GAT Board members  are taking incremental steps toward increasing data standardization. For  example, as the lead agency for the GAT Board’s Grants Data  Standardization and Integrity Working Group, OMB asked HHS to  analyze the existing level of standardization among grant making  agencies, and assess the feasibility and cost of increasing data  standards. This analysis examined more than 1,110 individual data  elements from more than 17 different sources. It found that there was  widespread variation in terminology and associated definitions that  impacted how spending was captured, tracked, and reported. In addition,  through its work with the GAT Board, Treasury is assessing the potential  for implementing new technologies that would allow non-standardized  data to be accessed by tagging and linking it to source systems, rather  than collecting and warehousing data in a separate system.
A lack of uniform standards could also increase the burden on federal  fund recipients. Federal fund recipients with whom we spoke told us that  the lack of consistent data standards and commonality in how data  elements are defined places undue burden on fund recipients because it  can result in them having to report the same information multiple times via  disparate reporting platforms. Fund recipients also told us that lack of  consistent data standards can impact the accuracy of data reported. For  example, one higher education official noted that increasing data  standardization and reporting consistency across the federal government  would eliminate the need for “human intervention” or manual data entry  which can impact the accuracy and the timeliness of the data reported.  Moreover, collecting data that already exists in agency award systems is  also inefficient and burdensome to recipients. Federal fund recipients we  spoke to expressed concern about the number of disparate agency and  program-specific requirements that obligate them to report the same data  multiple times or to report data that should have come from federal  sources. These recipients offered a number of suggestions for minimizing  reporting redundancy, including limiting data collected from recipients to a  small number of essential elements that can only be obtained from  recipients, pre-populating electronic reporting forms with data available  from agency sources, and using data multiple times rather than requiring  that recipients report the same data multiple times.
section_title: Lesson Two: Involve Stakeholders in the Development of Reporting Requirements and Guidance
paragraphs: Another key lesson learned from the implementation of Recovery Act  reporting requirements was the importance of obtaining and considering  the input of stakeholders—federal agencies, recipients, and  subrecipients—early in the development of both the reporting system and  its procedures. Given the daunting task of rapidly establishing a system to  track billions of dollars in Recovery Act funding, OMB and the Recovery  Board implemented an iterative process. This process allowed many  stakeholders to provide insight into the challenges that could impede their  ability to report Recovery Act expenditures. Throughout the development  of guidance and in the early months of implementing recipient reporting  provisions, OMB and the Recovery Board provided several opportunities  for two-way communication with recipients. For example, OMB and the  Recovery Board held weekly conference calls with state and local  representatives to hear their comments and suggestions, and address  their concerns. As a result of these efforts, federal officials changed their  plans and related guidance. For example, initial guidance in February  2009 began to lay out information that would be reported on  Recovery.gov, and the steps needed to meet reporting requirements,  such as including recipient reporting requirements in grant awards and  contracts. In response to requests for more clarity, OMB, with input from  an array of stakeholders, issued more guidance in June 2009. The  guidance clarified requirements on reporting jobs, such as which  recipients were required to report, and how to calculate jobs created and  retained.
During this current phase of developing transparency efforts, OMB and  the GAT Board have implemented a structure to obtain input from a  variety of federal stakeholders representing the procurement, grants, and  financial management communities. However, mechanisms for obtaining  input from non-federal stakeholders are limited to the public rule-making  process. The GAT Board’s work groups consist of representatives from  select federal agencies, OMB, and interagency forums. The work groups  are designed to leverage the expertise of federal officials with in-depth  knowledge of federal procurement, grant-making, and financial  management operations. The Board does not have any formal  mechanisms, other than the federal rule-making process, to obtain input  from federal fund recipients. An OMB official told us that OMB is  leveraging pre-existing personal contacts made during the Recovery Act  to obtain feedback from state officials. Further, this official said that OMB  had conducted extensive outreach with non-federal stakeholders in  seeking their input on OMB’s grants reform proposal. These outreach  efforts included discussions on standardizing financial information  collected during the pre-award and post-award phases of the grant  process. However, state officials we spoke with expressed interest in  providing additional input into expanding reporting requirements through  more formal mechanisms, such as focus or advisory groups. Without a  systematic approach for receiving and processing recipients’ input, such  as the conference calls held for the Recovery Act, issues that could affect  recipients’ ability to meet new reporting requirements could go  unaddressed, compromising the ability of recipients to provide accurate  data.
Non-federal stakeholders have been involved in the limited GRIP pilot  project discussed above. Recovery Board officials sought feedback from  the participating states, a locality, and institutions of higher education  throughout the duration of the project through a series of webinars and  teleconferences. An online help desk was also established to assist the  recipients through the process. At the conclusion of the study, participants  were surveyed. They expressed approval for several of the project’s  aspects, including data standardization, the inclusion of an error-checking  feature, and the use of a single central portal for reporting expenditures.  Although a Recovery Board official told us that they gained valuable  insight from stakeholders through the pilot, they reported that the more  inclusive networked community of state and local officials that they  established during the Recovery Act implementation had not been  sustained.
Federal fund recipients we spoke with underscored the importance of the  maintaining the connections they established with federal officials during  the implementation of the Recovery Act. They also stressed the  importance of having a formal mechanism to provide feedback to the  federal government as guidance is crafted and before new transparency  reporting requirements are established. Federal fund recipients said that  they need clear and understandable guidance to ensure that the data  they report are accurate, on time, and minimally burdensome. Officials  from organizations representing fund recipients as well as the fund  recipients themselves told us that the interactions between OMB and fund  recipients during Recovery Act implementation were extremely effective.  They noted the frequent communication with OMB staff members who  listened to their concerns, addressed questions, and made adjustments to  guidance, made it easier for them to report accurate spending data.
section_title: Lesson Three: Delineate Clear Requirements and Lines of Authority for Implementation Efforts
paragraphs: Need for Clear Guidance  “Guidelines need to be clear and  uncomplicated so that people can follow them  without having to refer to multiple different  sources. You will not get the same level of  compliance and enthusiasm and you will  produce some degree of frustration if people  do not understand the requirements and have  limited resources to work with.”— An official  from an association representing federal fund  recipients.
Under the Recovery Act, specific requirements and responsibilities for  transparency were clearly laid out in the law, which helped to ensure that  transparency requirements were implemented within tight time frames,  and thereby provided unprecedented transparency. The Recovery Act  specified the timing of reporting, including its frequency and deadlines,  and the items that needed to be included in the reporting. The Recovery  Board reported that the concrete deadlines imposed by the Recovery Act  motivated OMB and the Recovery Board to take action. The Recovery Act  required the Recovery Board to conduct and coordinate oversight of the  funds provided under the Recovery Act to prevent waste, fraud and  abuse, which the Recovery Board accomplished, acting together with  OMB, at the federal level to implement the transparency requirements. To  implement the recipient reporting requirements, OMB worked with the  Recovery Board to deploy a data-collection system at  FederalReporting.gov and a public-facing website at Recovery.gov.  Further, OMB provided centralized guidance that defined the reporting  requirements and the agencies’ role in ensuring the quality of data  recipients provided. An official from one association representing  recipients commented that having information come from one centralized  agency, such as OMB, helped assure recipients that their questions were  addressed correct. The Recovery Act also provided funding for the  Recovery Board, which was used to provide staff and resources for  developing and operating its data collection system, website, and data  analytic activities.
In contrast, authority for implementing the current transparency initiatives  is not as clearly defined. Authority for expanding transparency is centered  in an executive order rather than legislation. As we have previously  reported, given the importance of leadership to any collaborative effort,  transitions and inconsistent leadership, which can occur as  administrations change, can weaken the effectiveness of any  collaborative efforts, and result in a lack of continuity. According to  chairman of the GAT Board, the Board’s vision for comprehensive  transparency reform will take several years to implement. Therefore,  continuity of leadership becomes particularly important. Going forward,  changes in the administration and GAT Board membership could hamper  the success of future reform efforts if requirements and authorities for  implementing reforms are not clearly defined in statute. Moreover, the  executive order that establishes the GAT Board provides it with a role of  setting strategic direction, but not for implementation. As we have  previously reported, interagency collaboration on a project, such as  expanding transparency, is facilitated when one agency is designated to  be accountable, and there are clear roles and responsibilities. This  centralizes accountability and can speed decision making in an  organization. While there are many officials working together—the GAT  Board, work groups led by agency officials, interagency forums such as  the Chief Acquisition Officers Council, Council on Financial Assistance  Reform and Council of the Inspectors General on Integrity and Efficiency,  and OMB—it is not clear where responsibility for implementing the  initiatives lies. In oral comments provided on our draft report, OMB staff  said that the administration, through its fiscal year 2014 budget proposal,  has taken steps to delineate authority by seeking $5.5 million for Treasury  to operate and improve the USAspending.gov web site. They believe that  this proposal will establish Treasury as single implementing entity for  operationalizing transparency reforms.
The lack of clearly delineated authority for implementing initiatives could  result in multiple projects working at cross-purposes, overlapping, or  missing opportunities to improve transparency consistently. The following  represents examples that we gleaned from our interviews and focus  groups:
The GAT Board’s Data Analytics work group has been examining  approaches to expanding the availability of data to help the oversight  community detect and prevent fraud, waste, and abuse in federal  programs. Similarly, the Recovery Board’s ROC has developed a set  of assessment tools that can search large amounts of data from  multiple sources to detect fraudulent spending in federal programs.  Although the GAT Board’s mandate includes a requirement for it to  work with the Recovery Board to apply the approaches developed by  the latter across the federal government, the extent to which the work  of the ROC is being incorporated into the GAT Board’s effort to  develop approaches for using data analytics to improve oversight is  unclear.
The GAT Board and the Recovery Board have similar projects under  way to standardize grants data elements and procedures. The GAT  Board’s Grants Data Standardization and Integrity Working Group is  identifying approaches to standardize key data elements to improve  the accuracy of grants award data. The Recovery Board’s GRIP pilot  examined whether a uniform award identification number could be  used to track grants expenditures throughout the grant life cycle.  However, it is unclear whether the study’s results will be incorporated  into the work of the Grants Data Standardization and Integrity Working  Group, which could lead to inefficiencies caused by duplicated efforts.
Moreover, without operational authority, the GAT Board must leverage  the authorities and networks of its individual members. Thus, the  successful implementation of transparency initiatives depends on the  willingness and capacity of individual members’ agencies to drive this  change, and may not be sustainable. For example, the GAT Board  chairman used his position on the FAR Council to have it consider and  vote on a proposed rule that will require all federal agencies to use a  uniform procurement identification number for all of its solicitations and  awards. The GAT Board chairman drove this initiative based on his  capacity as Director of the Defense Procurement and Acquisition Policy  Office at DOD. However, the extent to which this governance structure  will be effective or sustainable over time is limited to and dependent upon  those existing connections.
Unlike under the Recovery Act, these transparency initiatives are being  funded through existing agency resources using agency personnel, as  separate funding is unavailable. While the GAT Board lacks funding of its  own, it relies on agencies to develop approaches to improve data  transparency. Agency officials we spoke with said they expect that  automation and standardization mechanisms embedded in transparency  initiatives now under way could help federal agencies to more efficiently  and effectively manage their activities and programs. Efficiencies and  economies generated by these initiatives might have the potential to save  money, and thereby lessen the need for appropriations or other forms of  dedicated funding. In the short term, the GAT Board believes it can  continue to make incremental changes by leveraging ongoing agency  initiatives.
section_title: Conclusions
paragraphs: Ensuring the transparency of more than $3.7 trillion in federal spending  annually, including more than $1 trillion awarded through contracts,  grants, and loans, and an additional $1 trillion in forgone revenue from tax  expenditures is an important national goal. Efforts to improve  transparency of spending data continue to involve multiple federal  entities, under the strategic leadership of the GAT Board and OMB.  Meanwhile, the Recovery Board continues to play a role in evaluating  new approaches to collecting data and maintaining systems to use the  data for ensuring accountability. However, roles and responsibilities for  the effort are not clearly delineated. For example, under the Recovery  Act, authority to mandate requirements was centered in OMB and the  Recovery Board, and was clearly delineated and funded, whereas under  the current transparency initiatives, the leadership for implementing  actions is spread across several agencies, knitted together loosely under  the GAT Board’s strategic direction. Given the importance of clear  requirements and consistent leadership for ensuring recommended  approaches are institutionalized across the federal government and  progress is sustained over the long-term, the present governance  structure for transparency efforts could hamper planned advancements.  Having clear requirements and implementation authority, particularly  through legislation, will help ensure effective and sustained  implementation of transparency efforts across the federal government.
While the transparency initiatives under way represent a promising start,  insights could be gleaned from lessons learned from the operation of  Recovery.gov. Such insights would ensure that new approaches are  implemented consistently across the federal government, and progress  toward strategic goals can be sustained long term. As OMB and the GAT  Board take incremental steps to improve data transparency and expand  oversight of federal spending, it will be important to develop a long-term  vision and concrete plan for improving transparency, and ensure its  implementation. For example, a key lesson learned from the  implementation of the Recovery Act was the importance of data  standards, including a universal award identifier to enable the tracking of  Recovery Act spending, and a uniform numbering system for identifying  federal awards would improve the tracking of all federal spending.  Moreover, by listening to stakeholders during Recovery Act  implementation, OMB and the Recovery Board heard concerns and made  changes to plans and guidance accordingly. As new transparency  initiatives are developed, the input of all stakeholders, including  nonfederal entities such as state and local governments, would help OMB  and the GAT Board to identify approaches that minimize the burden on  those doing the reporting, and address reporting challenges. Although the  non-federal stakeholders are a broad and diverse group, as future  changes are considered, it will be important to identify mechanisms to  involve stakeholders as early as possible.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Director of OMB, in collaboration with the  members of the GAT Board, take the following two actions:
Develop a plan to implement comprehensive transparency reform,  including a long-term timeline and requirements for data standards,  such as establishing a uniform award identification system across the  federal government.  Increase efforts for obtaining input from stakeholders, including  entities receiving federal funds, to address reporting challenges, and  strike an appropriate balance that ensures the accuracy of the data  without unduly increasing the burden on those doing the reporting.
section_title: Matter for Congressional Consideration
paragraphs: To ensure effective decision making and the efficient use of resources  dedicated to enhancing the transparency of federal spending data,  Congress should consider legislating transparency requirements and  establish clear lines of authority to ensure that recommended approaches  for improving spending data transparency are implemented across the  federal government.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Director of OMB, the GAT Board  and the Recovery Board Chairs, the Administrator of GSA, and the  Secretaries of HHS, DOD, and Treasury for review and comment. OMB  provided oral comments, which are summarized below. HHS provided  general comments that are also discussed below. In addition, the GAT  Board and DOD concurred with our recommendations and provided  technical comments, as well as additional clarifying information related to  the recommendations. Treasury generally agreed with our findings and  provided technical comments, while the Recovery Board and GSA  provided technical comments only.
In its oral comments, OMB staff indicated that they generally concurred  with our findings and recommendations. Regarding our recommendation  for developing a long-term plan for implementing data standards, OMB  staff agreed that the GAT Board’s plan provides an initial strategy and  added that multiple initiatives are under way. One of these initiatives is  the administration’s fiscal year 2014 budget proposal that would  operationalize comprehensive transparency through the transfer of  USAspending.gov from GSA to Treasury. We have provided additional  information on this in the report. For our recommendation on increasing  efforts to obtain stakeholder input as transparency initiatives are  developed, OMB staff agreed that increasing efforts to obtain stakeholder  input was important and pointed to their outreach to date particularly in  seeking stakeholder comments on the grants reform process, which they  said included discussions on standardizing financial information collected  from recipients during the pre-award and post-award phases of the grant  process. We have provided additional information in this report on this as  well. We continue to believe, however, that as specific proposals for  transparency initiatives are being developed, additional mechanisms  need to be in place to provide two-way communication to ensure that  reporting challenges are addressed without unduly increasing reporting  burden. OMB generally agreed with our matter for congressional  consideration on legislating transparency requirements, but noted that the  Congress has provided a robust statutory framework through legislation,  such as FFATA and the GPRA Modernization Act of 2010, and therefore  additional legislation is unnecessary. However, as we have previously  concluded, given the importance of clear requirements and consistent  leadership for ensuring approaches are institutionalized and sustained  over the long term, legislation will help ensure effective implementation of  comprehensive transparency reform.
The comments submitted by the HHS Assistant Secretary for Legislation  stressed the need to recognize the impact of data standardization on  agency operations and resources, and noted that the overarching federal  vision for transparency must articulate both the long term goals, as well  as more operational and pragmatic steps to be taken in order to achieve  such goals. HHS also underscored the importance of coming to an  agreement on the range of federal spending information that is needed to  achieve transparency and on which data elements are mandatory for  reporting and for information collection requirements.
We are sending copies of this report to the appropriate congressional  committees and the Recovery Board and GAT Board Chairs, the Director  of OMB, the Secretaries of HHS, DOD, and Treasury, and the  Administrator of GSA.
If you or your staff has any questions concerning this report, please  contact me at (202) 512-6806 or czerwinskis@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. Key contributors are listed in appendix IV.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: We were asked to examine efforts to increase the transparency of federal  spending data, and identify lessons from the experience of operating  existing data systems that could help increase federal spending data  transparency. To accomplish this, we (1) reviewed federal initiatives to  improve the accuracy and availability of federal spending data; and (2)  assessed the extent to which lessons identified by GAO and federal fund  recipients from the operation of Recovery.gov and USAspending.gov are  being addressed by these new transparency initiatives.
To address these objectives, we examined data collection and reporting  requirements under FFATA and the Recovery Act, the June 2011  Executive Order that established the GAT Board, Executive Order  13,576, “Delivering an Efficient, Effective, and Accountable Government,”  relevant OMB guidance and memoranda, such as OMB-10-06, Open  Government Directive and Improving Data Quality for USAspending.gov,  and reports outlining action plans and recommendations created by the  GAT Board, the Recovery Board, and other federal entities charged with  developing approaches to improve federal data transparency.
We interviewed officials at OMB, the GAT Board, and the Recovery Board  who are examining new data transparency approaches. We also  interviewed officials at three agencies who represent the perspectives of  the federal procurement, grant, and financial management communities,  and who are working with the GAT Board to build on transparency  initiatives under way within their agencies that could be applied across  the federal government: DOD, HHS, and Treasury, respectively. We also  interviewed officials at GSA, the agency that manages USAspending.gov,  to gain their perspectives on the challenges associated with ensuring the  quality of the data submitted to this site.
To capture the perspective of the federal fund recipients, we conducted a  series of interviews with officials from organizations representing federal  fund recipients and government reform organizations. We wanted to get  their perspectives on lessons learned from the operation of existing  transparency systems, and federal efforts under way to improve data  transparency. We selected these associations because our preliminary  research indicated that they had either been involved in Recovery Act  implementation, had published reports related to the Recovery Act, had  expressed official positions on existing transparency systems, or had  submitted official statements on pending legislation designed to improve  transparency. To capture a wide range of recipient perspectives, we also  selected associations that represented a variety of recipient types, from  state and local governments, nonprofit organizations, and contractors. For  this review, we interviewed and collected comments from officials at the  following organizations:
National Association of State Auditors, Comptrollers, and Treasurers
National Association of State Budget Officers
National Association of Counties
Federal Demonstration Partnership
National Council of Nonprofits
National Association of State Chief Information Officers
Council on Government Relations
Professional Services Council
Center for Effective Government
Project on Government Oversight
Sunlight Foundation  We also conducted seven focus groups representing a range of federal  fund recipients. Focus groups included: (1) state comptrollers and  budget officials; (2) state education and transportation officials; (3) local  government officials from both large and small municipalities; and (4)  nonprofit organizations, research universities, and representatives from  business who contract with the federal government. Each focus group  had between four and eight participants who were recruited from  randomized member lists provided by the recipient associations we  interviewed. We audio-recorded the focus groups, transcribed the  recordings, and analyzed the findings with qualitative analysis software  for common themes and pattern.
Finally, we reviewed our previous work on the reporting successes and  challenges experienced by both agencies and federal fund recipients.  This process was designed to identify lessons learned from those  experiences that should be considered as new approaches to data  transparency are developed.
We conducted this performance audit from November 2012 to September  2013 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 objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
section_title: Appendix II: Government Accountability and Transparency Board and Work Group Agency Partners
paragraphs: The Government Accountability and Transparency Board (GAT Board) is  composed of the following 11 members designated by the President from  among agency Inspectors General, agency Chief Financial Officers or  Deputy Secretaries, and senior officials from OMB. The President  designates a Chairman from among the members.
Director, Defense Procurement and Acquisition Policy, U.S.
Assistant Secretary, Department of the Treasury
Deputy Secretary, U.S. Department of Veterans Affairs
Assistant Secretary for Financial Resources and Chief Financial  Department of Defense  Inspector General, U.S. Postal Service  Inspector General, U.S. Department of Energy  Inspector General, National Science Foundation  Inspector General, U.S. Department of Health and Human Services
Deputy Controller, Office of Management and Budget  Officer, U.S. Department of Health and Human Services  Inspector General, U.S. Department of Transportation  Inspector General, U.S. Department of Education  The GAT Board established four working groups, as shown in table 1.
section_title: Appendix III: Comments from the Department of Health and Human Services
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Carol L. Patey, Assistant  Director, and Kathleen M. Drennan, Ph.D., Analyst-in-Charge, supervised  the development of this report. Gerard S. Burke and Patricia Norris made  significant contributions to all aspects of this report.  Cynthia M. Saunders, Ph.D. assisted with the design and methodology,  Andrew J. Stephens provided legal counsel, Robert Robinson developed  the report’s graphics, and Jessica Nierenberg, Judith Kordahl, and  Keith O’Brien verified the information in this report.
Other important contributors included James R. Sweetman, Jr.,  Michael S. LaForge, William T. Woods, and Tatiana Winger.