DATA ACT: Improvements Needed in Reviewing Agency Implementation Plans and Monitoring Progress
Published: 2016-07-29T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The federal government annually spends over $3.7 trillion on its programs and operations. To help increase the transparency of online spending information, the DATA Act requires agencies to begin reporting spending data by May 2017, using new data standards established by OMB and Treasury. In May 2015, OMB directed federal agencies to submit DATA Act implementation plans by September 2015. OMB and Treasury subsequently issued guidance to agencies to help them develop plans.
This report is part of a series of products that GAO will provide to Congress in response to a statutory provision to review DATA Act implementation. This report discusses OMB's and Treasury's efforts to facilitate implementation of the DATA Act and the consistency of agency implementation plans with OMB and Treasury guidance, among other things. GAO evaluated OMB's and Treasury's processes against project management and internal control criteria, assessed selected agency implementation plans against OMB and Treasury guidance, and interviewed staff and officials at OMB and Treasury.
section_title: What GAO Found
paragraphs: The Office of Management and Budget (OMB) and the Department of the Treasury (Treasury) have not designed and implemented controls or fully documented processes related to the review and use of agency implementation plans for the Digital Accountability and Transparency Act of 2014 (DATA Act). These controls and processes are to be used for reviewing agencies' implementation plans and monitoring agencies' progress against these plans. In addition, as of July 2016, OMB had not determined the complete population of agencies that are required to report spending data under the DATA Act and submit implementation plans to OMB. OMB staff stated that their purpose for directing agencies to submit implementation plans was to use the implementation cost estimates to assist them in formulating the fiscal year 2017 budget, while Treasury officials stated that the purpose of their review of the plans was to facilitate discussions with the agencies. In addition, OMB and Treasury staff initially informed GAO that they were not going to request that agencies submit updated implementation plans that considered new technical requirements and guidance that was released on April 29, 2016. However, on June 15, 2016, OMB requested updated implementation plans by August 12, 2016, but only from Chief Financial Officers (CFO) Act agencies. Lacking fully documented controls and processes as well as a complete population of agencies that are required to report under the DATA Act increases the risk that the purposes and benefits of the DATA Act may not be fully achieved, and could result in incomplete spending data being reported. Further, without updated implementation plans, including revised timelines and milestones, cost estimates, and risks that reflect the impacts of new technical requirements and guidance, from all agencies that are required to report under the DATA Act, OMB and Treasury may not have the information needed to assist them in properly monitoring resource needs and agencies' progress in implementing new requirements government-wide.
Based on OMB and Treasury guidance, GAO identified 51 plan elements in four separate categories—timeline, cost estimate, narrative, and project plan—to be included in agency implementation plans. None of the 42 implementation plans GAO received and reviewed contained all 51 plan elements described in OMB and Treasury guidance. For example, many agencies' cost estimates did not provide all the elements for cost estimates, including total work years and a list of assumptions, or did not differentiate between their business process costs and technology costs.
section_title: What GAO Recommends
paragraphs: GAO recommends that OMB, in collaboration with Treasury, determine the population of agencies required to report under the DATA Act, establish fully documented controls and processes to help ensure agencies' effective implementation of the DATA Act, and request updated plans from non-CFO Act agencies. OMB generally concurred with the recommendations and Treasury deferred to OMB.

section_title: Letter
paragraphs: The federal government annually spends more than $3.7 trillion on its  programs and operations. In an effort to increase the availability,  accuracy, and usefulness of online federal spending information,  Congress passed and the President signed the Digital Accountability and  Transparency Act of 2014 (DATA Act). Among other things, the DATA  Act expands the required federal spending information reported online by  agencies; mandates that the information appear in a form that is both  searchable and downloadable; requires the establishment of data  standards to generate uniform agency data that are consistent and  comparable; and directs agency inspectors general (IG) and GAO to  report on agencies’ implementation and use of data standards as well as  the completeness, timeliness, quality, and accuracy of federal spending  data submitted. The DATA Act identifies the Office of Management and  Budget (OMB) and the Department of the Treasury (Treasury) as the two  agencies responsible for establishing data standards and issuing related  guidance, and therefore they are responsible for leading government- wide implementation of the act. The DATA Act requires federal agencies  to begin reporting federal spending data using the data standards by May  2017.
With the DATA Act reporting deadline approaching, it is a critical period  for agency implementation. OMB’s and Treasury’s leadership and  monitoring will play a key role in determining the success of the DATA  Act’s implementation as they work with federal agencies, provide  guidance, clarify and communicate DATA Act reporting requirements, and  review agency DATA Act implementation plans and monitor progress  against those plans. Given the challenges associated with efforts to  improve the quality and completeness of federal spending data reported  by agencies, which are discussed further in this report, it is crucial that  oversight and monitoring of DATA Act implementation be undertaken in a  formal and organized manner.
We and the Treasury IG have previously reported on OMB’s and  Treasury’s efforts to implement the requirements of the DATA Act. We  reported that OMB and Treasury have made progress in developing a  governance framework that includes structures for both project  management and data governance. In May 2015, the Treasury IG  reported on Treasury’s project management practices and raised a  number of issues that the IG believes could hinder the effective  implementation of the act if not addressed. In addition, we reported on  OMB’s and Treasury’s steps taken to establish a governance process for  developing data standards. We recommended that OMB and Treasury  establish a set of clear policies and processes for developing and  maintaining data standards that are consistent with leading practices for  data governance, but our recommendation has yet to be fully addressed.  We have also previously reported on persistent challenges involving  efforts to improve the quality and completeness of federal spending data  reported by agencies to USAspending.gov, a free, publicly accessible  website containing data on federal contract, grant, loan, and other  financial assistance awards. In that report, we recommended that the  Director of OMB (1) clarify guidance on reporting and maintaining records  of award information and (2) develop and implement oversight processes  to ensure that award data are consistent with agency records. These  recommendations have also not yet been fully addressed. For a complete  list of our previous work in this area, see the Related GAO Products page  at the end of this report.
This report is part of an ongoing effort by GAO in response to a statutory  provision to review DATA Act implementation and focuses on the project  management aspects of OMB’s and Treasury’s overall implementation  governance with emphasis on OMB’s requirement that agencies prepare  and submit plans describing how they will implement the DATA Act  requirements. Our objectives for this report were to determine (1) the  extent to which OMB and Treasury have processes and controls in place  to review agencies’ implementation plans, monitor agencies’ progress,  provide feedback to the agencies, and respond to challenges reported by  the agencies; (2) the extent to which selected federal agencies’ DATA Act  implementation plans were prepared in accordance with OMB and  Treasury guidance; and (3) challenges agencies have reported that may  affect their ability to implement the DATA Act and mitigating strategies  they have reported to address such challenges.
To address our first objective, we met with OMB and Treasury officials to  gain an understanding of their processes for reviewing implementation  plans, monitoring agencies’ progress, providing feedback to agencies,  and responding to reported challenges. We requested supporting  documentation on OMB’s and Treasury’s written processes, policies, and  procedures and assessed their processes and controls against various  criteria, including Standards for Internal Control in the Federal  Government and the Project Management Institute’s A Guide to the  Project Management Body of Knowledge (PMBOK® Guide).
For our second objective, we requested the DATA Act implementation  plans for 51 agencies and received such plans from 42 of those agencies,  including all 24 Chief Financial Officers (CFO) Act agencies, 7 other  agencies identified by OMB and Treasury as significant to the Fiscal Year  2014 Financial Report of the United States Government, and 11 smaller  federal agencies. We did not receive implementation plans from the  remaining 9 agencies because they (1) had determined the DATA Act  was not applicable to them, (2) did not prepare plans because they were  using or relying on their shared service providers’ implementation plans,  or (3) had not completed and submitted their plans to OMB yet. We did  not validate the agencies’ determination that the DATA Act was not  applicable to them or review shared service providers’ implementation  plans because it was not within the scope of this review. We reviewed the  42 implementation plans we received and assessed them against 51 plan  elements described in OMB and Treasury guidance. We also analyzed  the OMB and Treasury guidance to agencies on preparing  implementation plans and found it generally consistent with the PMBOK®  Guide. We did not evaluate the quality of the information provided in the  agencies’ implementation plans, such as whether the implementation plan  steps were sufficient to achieve successful implementation by the  agencies, as this was outside the scope of this review.
For our third objective, we identified challenges and mitigating strategies  reported by federal agencies in the 42 DATA Act implementation plans  that we reviewed. We analyzed the overall results to identify common  themes and categories of challenges and mitigation strategies reported  by the agencies.
We conducted this performance audit from November 2015 to July 2016  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. Appendix I provides additional  details on our scope and methodology.
subsections: section_title: Background
paragraphs: Over the past decade, Congress and the executive branch have taken  steps to improve the transparency of federal spending data. Congress  passed and the President signed the Federal Funding Accountability and  Transparency Act of 2006 (FFATA) to increase the availability of  information about federal spending and improve the accountability over  federal contracts and financial assistance awards. In response to  FFATA, in December 2007, OMB established USAspending.gov to give  the American public access to information on how their tax dollars are  spent.
More recently, the DATA Act, signed into law on May 9, 2014, expanded  FFATA to link federal agency spending to federal program activities so  that taxpayers and policymakers can more effectively track federal  spending. To improve the quality of reported data, the DATA Act also  requires that agency-reported award and spending information comply  with new data standards that OMB and Treasury have established. The  data standards, including the data elements, specify the items to be  reported under the DATA Act and define and describe what is to be  included in each element with the aim of ensuring that information will be  consistent and comparable. The DATA Act technical schema, developed  by Treasury, details the specifications for the format, structure, tagging,  and transmission of each data element.
The DATA Act requires GAO to issue reports in 2017, 2019, and 2021,  assessing and comparing the quality of data submitted under the DATA  Act as well as agency implementation and use of data standards. As we  have previously reported, the DATA Act, if fully and effectively  implemented, holds great promise for improving the transparency and  accountability of federal spending data by providing consistent, reliable,  and complete data on federal spending.
subsections: section_title: DATA Act Implementation Plans
paragraphs: In May 2015, OMB issued OMB Memorandum M-15-12 to federal  departments and agencies directing them to submit DATA Act  implementation plans to OMB. OMB directed that agencies submit their  implementation plans concurrent with their fiscal year 2017 budget  requests that were due September 14, 2015. In June 2015, OMB issued  DATA Act Implementation Plans Guidance to assist agencies in  completing their implementation plans. According to the guidance, agency  implementation plans were to include four parts: (1) a timeline of tasks  and steps that graphically displays the major milestones the agency  expects to complete as part of the implementation process, (2) a cost  estimate that includes costs for each activity and step in the timeline, (3) a  narrative that summarizes the steps the agency will take to implement the  DATA Act and any foreseeable challenges, and (4) a detailed project plan  that reflects the major milestones in the agency’s timeline and expands  on the narrative.
In June 2015, Treasury issued the DATA Act Implementation Playbook  (Version 1.0) that contains an explanation of the eight suggested steps  and a timeline for agencies to use as they began to develop their plan for  DATA Act implementation.
Step 1: Organize team and create an agency DATA Act work group  including affected communities and identify senior accountable official  (by spring 2015).
Step 2: Review list of elements and participate in data standardization  process (by spring 2015).
Step 3: Perform inventory of agency data and associated business  processes (February 2015 to September 2015).
Step 4: Design and strategize changes to systems and business  processes to capture complete, multilevel data (e.g., summary and  award detail) and prepare cost estimates for fiscal year 2017 budget  projections (March 2015 to September 2015).
Step 5: Execute broker to map agency data to DATA Act schema,  implement system changes, and extract data (October 2015 to  February 2016).
Step 6: Test broker implementation and outputs to ensure that data  are valid (October 2015 to February 2016).
Step 7: Update systems and implement other systems changes  (October 2015 to February 2017).
Step 8: Submit data and update and refine process (March 2016 to  May 2017).
The DATA Act Implementation Playbook (Version 1.0) indicates that  agencies will be working on steps 5 through 8 throughout fiscal years  2016 and 2017. These eight steps were to be discussed in the narrative  section of agency implementation plans. On June 24, 2016, Treasury  issued DATA Act Implementation Playbook (Version 2.0) which includes,  among other things, expanded guidance on actions and steps to be  included in steps 5 through 8.
In December 2015, OMB issued clarifying guidance in the form of a two- page Controller Alert that was narrowly focused on three areas of  concern—a requirement to comply with data standards, a requirement to  link award and account-level data, and a requirement to identify funding  and awarding offices for financial assistance awards. In April 2016,  Treasury issued technical requirements for implementation, including  version 1.0 of the technical schema known as the DATA Act Information  Model Schema. This includes technical guidance for federal agencies  about what data to report to Treasury, including the authoritative sources  of the data elements and the submission format. In May 2016, OMB  issued Additional Guidance for DATA Act Implementation: Implementing  Data-Centric Approach for Reporting Federal Spending Information in  Management Procedures Memorandum No. 2016-03. This memorandum  provided additional guidance on new federal prime award reporting  requirements and agency assurances and authoritative sources for  reporting.
section_title: OMB and Treasury Approach to DATA Act Implementation
paragraphs: Recently, a Treasury official testified that Treasury and OMB were leading  implementation of the DATA Act with the goal of providing more  accessible, searchable, and reliable spending data for the purposes of  promoting transparency, facilitating better decision making, and improving  operational efficiency. The Treasury official also previously testified that  a well-thought-out implementation plan is one of the key factors to  successful implementation. He stated that the plan Treasury had  developed, in partnership with OMB, not only reflected the requirements  and intent of the law, but it will also lead to a more data-driven  government.
OMB and Treasury have formed a governance framework that provides  initial structures for project management and development of data  standards, with OMB being the lead agency for policy decisions and  Treasury being the lead agency for technical issues and decisions  regarding DATA Act implementation. At the top of this framework is an  Executive Steering Committee—consisting of OMB’s Controller and  Treasury’s Fiscal Assistant Secretary. The Executive Steering Committee  sets overall policy and guidance, oversees recommendations, and makes  key decisions affecting government-wide implementation of the act. OMB  staff and Treasury officials stated that they have established a joint  partnership for DATA Act implementation, and one of their joint activities  was reviewing agency implementation plans. According to OMB staff,  OMB and Treasury are using an iterative approach for DATA Act  implementation. According to the PMBOK® Guide, iterative processes  are generally preferred when an organization needs to manage changing  objectives and scope, to reduce the complexity of a project, or when the  partial delivery of a product is beneficial and provides value for one or  more stakeholder groups without impact to the final deliverable or set of  deliverables.
According to Treasury officials, the Treasury Program Management Office  is using an agile approach to develop a mechanism for agencies to report  spending data and make changes to USAspending.gov. According to the  PMBOK® Guide, adaptive processes include agile methods and are  intended to respond to high levels of change and ongoing stakeholder  involvement. Adaptive methods are also both iterative and incremental.  OMB’s Digital Service team outlines agile and iterative guidance in the  U.S. Digital Services Playbook, which reflects the principles that OMB  and Treasury have stated they are using in their approaches to DATA Act  implementation.
section_title: OMB and Treasury Have Not Fully Documented Processes and Controls for Their Review of Agency DATA Act Implementation Plans
paragraphs: Although OMB directed federal agencies to submit implementation plans  (through issuance of OMB Memorandum M-15-12), as of July 2016, OMB  had not determined the complete population of agencies that are required  to report spending data under the DATA Act and submit implementation  plans to OMB. Further, OMB and Treasury have not fully documented  processes and controls for reviewing and using agencies’ DATA Act  implementation plans to facilitate and monitor agencies’ progress against  the implementation plans, to provide feedback to agencies, and to  respond to reported challenges. In addition, OMB and Treasury initially  informed us that they were not planning to require or request that  agencies submit updated implementation plans for review that would  consider new technical requirements and guidance that were released.  However, on June 15, 2016, OMB requested that the 24 CFO Act  agencies submit updates to key components of their implementation  plans by August 12, 2016.
Not knowing the complete population of agencies that are required to  report under the DATA Act and not having fully documented processes  and controls for reviewing and using agency DATA Act implementation  plans increase the risk that the purposes and benefits of the DATA Act  may not be fully achieved and could result in incomplete spending data  being reported. Further, without updated implementation plans, including  revised cost estimates and project plans to reflect the impacts of new  technical requirements and guidance, from all agencies that are required  by the DATA Act to report spending data, OMB and Treasury may not  have the information needed to assist them in properly monitoring  resource needs and agencies’ progress in implementing new  requirements government-wide.
subsections: section_title: OMB Has Not Determined the Complete Population of Agencies That Are Required to Report under the DATA Act
paragraphs: As of July 2016, OMB had not yet determined the complete population of  agencies required to report under the DATA Act. According to OMB staff,  OMB had not made this determination because of differing interpretations  of how the DATA Act defines “federal agencies.” This issue is not  entirely new. We reported in June 2014, among other things, that it was  unclear which agencies were required to report award data in accordance  with FFATA because of differing interpretations of the funds that were  exempt from reporting. We also reported that without clear OMB guidance  to define the types of funds exempt from reporting, it is unclear whether  justifications from the agencies for not reporting are appropriate. OMB  generally agreed with our recommendations to clarify guidance on  reporting award information and stated that the recommendations were  consistent with actions required by the DATA Act, but our  recommendations have yet to be fully addressed.
Similarly, OMB and Treasury annually prepare the U.S. government’s  consolidated financial statements, which requires the identification of the  complete population of agencies that are required to report their annual  audited financial information. As a result, Treasury has established a set  of controls and procedures to validate the completeness of this population  of agencies and help ensure that financial information is received from all  agencies required to report. Leveraging this existing process and controls  with appropriate modifications could help establish a complete population  of agencies required to report under the DATA Act and reduce the risk of  incomplete data being reported.
On April 19, 2016, OMB’s Controller testified that OMB would provide  Congress with its determination of the population of agencies required to  report under the DATA Act, while emphasizing that the 24 CFO Act  agencies—which both OMB and the CFO Act agencies agree are all  required to report—represent about 90 percent of federal spending. In  May 2016, OMB and Treasury published guidance in the form of  frequently asked questions to help federal agencies determine whether  they are required to comply with the DATA Act. In addition, OMB staff  stated that the agencies’ general counsels could work with OMB to help  agencies make these determinations. However, OMB does not have a  process or plan in place to validate agency determinations and on a  periodic basis request updated agency determinations or initial  determinations for newly formed federal entities.
The PMBOK® Guide, a globally recognized standard for project  management, includes defining the scope of the project—in this case, the  population of agencies that are required to report. In addition, Standards  for Internal Control in the Federal Government states that management— in this case, OMB—should periodically review policies, procedures, and  related control activities for continued relevance and effectiveness in  achieving the entity’s objectives—in this case, successful implementation  of the DATA Act. It is important for OMB and Treasury to determine on a  periodic basis the complete population of agencies that are required to  comply with DATA Act reporting requirements so that OMB and Treasury  can follow up with agencies that have not reported and help ensure that  they comply. Without determining the complete population of agencies  required to report under the DATA Act—including submitting an  implementation plan and reporting spending data—there is an increased  risk that financial and nonfinancial information reported to  USAspending.gov may be incomplete.
section_title: OMB and Treasury Have Not Fully Documented Processes and Controls for Reviewing and Using Agency Implementation Plans
paragraphs: OMB and Treasury have not fully documented processes or designed and  implemented controls specifically related to reviewing and using agency  implementation plans to facilitate and monitor agencies’ progress against  their implementation plans, to provide feedback to agencies, and to  respond to reported challenges. OMB and Treasury officials confirmed  that they do not have documented policies and procedures, or processes  and controls, specifically for reviewing agency DATA Act implementation  plans. OMB staff noted that the purpose for directing agencies to submit  implementation plans was to use the implementation plan cost estimates  to assist them in formulating the fiscal year 2017 budget. OMB staff  stated that they have a documented process for budget formulation and  that it was sufficient for their review of agency implementation plans.  However, given the goals of the DATA Act, fully documented processes  and controls for reviewing all information in the agencies’ implementation  plans, such as reported challenges, implementation plan timelines, and  detailed project plans, would be useful for facilitating agency  implementation of DATA Act requirements and monitoring agency  progress.
Treasury officials, in their role working with OMB to lead DATA Act  implementation, also reviewed agencies’ implementation plans and  provided us with a list of the agency plans they reviewed. They described  their review of implementation plans as a point-in-time review, the  objective of which was to identify overarching government-wide issues  and identify agencies that could benefit from one-on-one discussions with  Treasury about their plans. A Treasury official noted that Treasury’s  review of implementation plans was meant to encourage agencies to start  considering how they would implement the DATA Act and facilitate initial  discussions with the agencies. OMB and Treasury officials noted that the  implementation plan is not their only tool for facilitating and monitoring  agency implementation of the DATA Act. A Treasury official stated that  they have a more holistic approach for engaging agencies through other  tools and mechanisms, including office hours, sessions for agencies to  test their data files, webinars, and interactive communication tools, which  led to the development of the technical requirements and updates to  USAspending.gov.
OMB and Treasury described their processes for providing, documenting,  and sharing feedback given to agencies in October and November 2015  regarding the agencies’ implementation plans. OMB and Treasury  officials told us that based on their initial reviews of the agencies’  implementation plans, they provided feedback to certain agencies as  needed through written comments, e-mails, discussions, conferences and  forums, monthly calls with senior accountable officials, weekly project  management office hours, and workshops. A Treasury official provided us  with examples of the written feedback provided to selected agencies  based on Treasury’s review of agencies’ implementation plans. However,  OMB and Treasury did not provide us with documentation detailing the  results of their assessments of government-wide issues or the possible  impacts to their DATA Act planning activities or timelines resulting from  their review of agencies’ implementation plans.
In April 2016, the Controller of OMB testified that OMB and Treasury are  monitoring and tracking agency progress against implementation plans  through May 2017. The Controller stated that he and the Fiscal  Assistant Secretary of Treasury are leading readiness discussions to  encourage timely DATA Act implementation. OMB plans to complete  these senior-level discussions in July 2016. However, OMB staff  confirmed that they do not have documented policies and procedures for  conducting or communicating the results of these discussions. OMB staff  told us that these are unstructured, high-level reviews tailored to  individual agencies. OMB staff stated that the agencies come forward  with particular concerns, identify risks they are facing, and where they  need help from OMB and Treasury.
According to Standards for Internal Control in the Federal Government,  management should design control activities to achieve objectives and  respond to risks. Applying these standards to this situation suggests  that procedures for reviewing agencies’ implementation plans, including  how to use information such as reported challenges in agencies’ plans,  are control activities that would help OMB and Treasury achieve their  objective to lead efforts to implement the DATA Act. In addition, according  to the PMBOK® Guide, monitoring project performance should be done  consistently and regularly, and should include tracking and reviewing the  progress and performance of the project, identifying areas where changes  are required, and initiating corresponding changes. It should also include  collecting, measuring, and distributing performance information and  assessing measurement and trends to effect process improvements.
While OMB and Treasury staff noted that they also use other tools and  mechanisms, such as office hours and webinars, to help support  agencies in their implementation efforts, a well-developed agency  implementation plan would be a key tool for OMB and Treasury to use to  better monitor agencies’ efforts to implement the DATA Act. Without  clearly documented processes and controls for reviewing and using  agency implementation plans to facilitate and monitor agencies’ progress  against their implementation plans, OMB and Treasury may not be able to  fully determine resources, guidance, or other agency needs requiring  actions by OMB and Treasury for the successful implementation of the  DATA Act government-wide.
section_title: OMB Requested Updated Agency Implementation Plans, but Only from CFO Act Agencies
paragraphs: OMB and Treasury staff initially told us that they were not going to require  or request that agencies submit updated implementation plans for review  although new requirements and information were subsequently released,  such as additional guidance on DATA Act reporting that OMB issued in  May 2016. The Controller of OMB later testified in April 2016 that OMB  would request updated implementation plans from the agencies in June  or July of 2016 after the technical schema has been issued; Treasury  subsequently issued the schema on April 29, 2016.
In a June 15, 2016 memorandum to CFO Act agencies, OMB requested  that those agencies submit updated information on key components of  their implementation plans by August 12, 2016. OMB requested that the  updated information include a timeline with updated milestones and a  narrative explaining the milestones, the agency’s progress to date, and  updated risks and a risk mitigation strategy. OMB also requested updated  information on the CFO Act agencies’ resources—funds spent on the  effort to date as well as estimated total future spending.
According to the PMBOK® Guide, updates arising from approved  changes during the project may significantly affect parts of the project  management plan and the project documents. Updates to these  documents provide greater precision with respect to schedule, costs, and  resource requirements to meet the defined project scope. For example,  certain CFO Act agencies reported cost estimates for DATA Act  implementation that ranged from $387,000 to $38.8 million for fiscal years  2015 through 2018, but these estimates are likely to change as a result of  the technical requirement changes and additional guidance issued in April  and May 2016. Furthermore, since agencies will be implementing steps 5  through 8—execute, test, update, and submit data—in the DATA Act  Implementation Playbook (Version 2.0) throughout fiscal years 2016 and  2017, additional focus and details for these steps in the agency  implementation plans may be needed to help accomplish those steps as  the May 2017 implementation date draws nearer.
OMB staff stated that they have focused OMB’s implementation efforts on  the CFO Act agencies as they account for a large majority of federal  government spending. OMB’s recent request for updated implementation  plans from CFO Act agencies is a step in the right direction. However, the  DATA Act is a government-wide initiative requiring full reporting of federal  spending data that includes reporting beyond that of the CFO Act  agencies. As discussed in this report, both CFO Act and other federal  agencies submitted implementation plans to OMB. With the recent  issuance of additional guidance and changes to technical requirements,  agencies should be able to provide more extensive information in their  project plans for completing steps 5 through 8 in OMB and Treasury’s  implementation plan guidance. Without updated agency implementation  plans from all agencies required to report under the DATA Act, including  revised timelines and milestones, cost estimates, and updated risks that  reflect the impacts of new technical requirements and guidance, OMB  and Treasury may not have the information needed to assist them in  properly monitoring resource needs and agencies’ progress in  implementing new requirements government-wide.
section_title: Agency DATA Act Implementation Plans Were Not Fully in Accordance with OMB and Treasury Guidance
paragraphs: None of the 42 implementation plans we received and reviewed  contained all 51 plan elements described in OMB and Treasury guidance.  OMB’s DATA Act Implementation Plans Guidance outlined four  categories of information to be included in agency implementation plans:  (1) timeline, (2) cost estimate, (3) narrative, and (4) project plan. Based  on OMB’s DATA Act Implementation Plans Guidance and Treasury’s  Data Act Implementation Playbook (Version 1.0), we identified 51 plan  elements to be reported within these four categories. Appendix II lists the  51 plan elements in each category and the percentage of the 42 agencies  that included each element in their implementation plans, as well as the  combined average of agencies that included the elements in each of the  four categories. Descriptions of the categories and the number of plan  elements in each category are shown in table 1.
Based on our review of agency implementation plans, we found that none  of the 42 agencies’ plans included all of the 51 plan elements. For  example, many agencies’ cost estimates were incomplete as the  agencies did not provide assumptions for their estimates; identify  resource requirements, such as full-time and part-time employees needed  to assist implementation; or differentiate between their business process  costs and technology costs. Table 2 shows the average inclusion rate— the average of the percentages of specific plan elements in a category  that the 42 agencies included in their implementation plans.
As shown above, the plan elements that were most often included were  those in the timeline category. We determined that the average inclusion  rate across the 11 plan elements of the timeline category was 74 percent.
Of the four categories, the project plan category had the lowest average  inclusion rate.
As shown in table 3, the 5 plan elements most often included in agency  implementation plans were related to milestone dates, tasks, and  changes to information technology systems (in the timeline category) and  information on conducting an inventory of agency data (in the narrative  category).
As shown in table 4, the 5 plan elements that were most often not  included in agency implementation plans were information on resource  needs and dependencies (in the project plan category), information on  which steps can be or have been done with existing resources (in the cost  estimate category), notation on the project plan of which steps require  OMB and Treasury action (in the project plan category), and information  relating to procedures for verifying the completeness of data submitted to  Treasury (in the narrative category). OMB guidance also requested that  agencies report cost savings, if any. However, our review of the  implementation plans found that no agencies reported cost savings.
In our review of the 42 agency implementation plans, we found that the  amount of information varied based on whether the agency was a CFO  Act agency and whether the agency referred to a shared service  provider. For example, we found that CFO Act agency plans were  generally more complete than non-CFO Act agency plans, which  highlights the importance of obtaining updated implementation plans from  non-CFO Act agencies, as previously discussed. Table 5 shows  differences between the 24 CFO Act agencies’ and the 18 non-CFO Act  agencies’ implementation plans in their average inclusion rates across the  four categories of DATA Act implementation plan elements.
We also found that less information was provided in the plans for  agencies that indicated they used a shared service provider than for  those agencies that did not indicate they used a shared service provider.  Agencies that indicated they used a shared service provider often made  reference to their shared service provider’s implementation plan instead  of identifying what steps the agency would take for a particular plan  element to implement the DATA Act. Of the 42 agency implementation  plans we reviewed, we found there were 26 agencies that did not make  reference to using shared service providers and 16 agencies that referred  to using a shared service provider for implementation. Table 6 shows that  the average inclusion rate among agencies not referencing use of a  shared service provider was higher for all four categories than among  those agencies that referenced using a shared service provider.
Given the lack of consistent and complete agency implementation plans,  it may be difficult for OMB and Treasury to determine whether agencies  will be able to implement the data standards finalized by OMB and  Treasury in August 2015. In addition, the implementation plans we  reviewed are now not up-to-date and do not address the new technical  requirements issued by Treasury in April 2016 and the guidance issued  by OMB in May 2016 or provide all the necessary details needed to  implement steps 5 through 8 of the DATA Act Implementation Playbook  (Version 2.0). In June 2016, OMB requested that CFO Act agencies  submit updated information on key components of their implementation  plans by August 12, 2016. While OMB and Treasury noted that they have  other tools and mechanisms to monitor agencies’ implementation efforts,  without updated implementation plans from all agencies required to report  under the DATA Act, it is unclear whether OMB and Treasury will have  sufficient information to determine the full range of resources and  guidance that will be needed to help ensure the successful government- wide implementation of DATA Act requirements by the May 2017  deadline.
section_title: Agencies Reported Significant Challenges and Identified Mitigating Strategies for Implementing the DATA Act
paragraphs: Although OMB and Treasury have issued data standards and provided  guidance and feedback to federal agencies on their DATA Act  implementation plans, as discussed above, our work indicates that  challenges remain and will need to be addressed to successfully  implement the DATA Act government-wide. OMB’s DATA Act  Implementation Plans Guidance was issued to the agencies, detailing  what should be included in their implementation plans and asking  agencies to describe any potential difficulties or foreseeable challenges  that could hinder their implementation of the DATA Act. This guidance  also encouraged agencies to provide suggestions to mitigate the  challenges they foresee. As we testified in April 2016, our review of the  42 agency implementation plans we received, dated from August 2015  through January 2016, provides insight into the challenges agencies face  as well as the mitigation strategies they suggest to address them.  Based on our analysis of the agencies’ implementation plans, we believe  that the challenges and mitigation strategies reported provide important  insight as to the level of effort, communication, collaboration, and  resources needed to successfully implement the DATA Act government- wide.
subsections: section_title: Challenges Reported by Agencies in Their DATA Act Implementation Plans
paragraphs: Based on the results of our review of the 42 agency implementation  plans, we identified seven overarching categories of challenges reported  by agencies to effectively and efficiently implementing the DATA Act, as  shown in table 7.
The results of our review of the 42 agency implementation plans we  received found that 31 agencies reported specific challenges, some of  which may overlap with multiple categories. As shown in figure 1,  agencies most frequently reported challenges with competing priorities,  systems integration, and resources. See appendix III for examples of the  types of challenges agencies reported in each category.
section_title: Mitigation Strategies Reported by Agencies in Their DATA Act Implementation Plans
paragraphs: The results of our review found that 26 agencies reported in their  implementation plans mitigation strategies to address challenges. Some  strategies discussed in the agency implementation plans address multiple  challenges. As shown in figure 2, agencies reported crosscutting  mitigation strategies to address specific areas of concern most frequently  with respect to leveraging existing resources and communication and  information sharing. See appendix III for examples of the mitigating  strategies agencies reported in each category.
Overall, our work indicates that agency implementation plans contain  valuable information on a variety of challenges in implementing the DATA  Act, including a lack of funding, inadequate guidance, tight time frames,  competing priorities, and system integration issues. Agencies reported  working closely with internal and external stakeholders to address these  challenges as effectively as possible, but also reported that additional  support from OMB and Treasury is needed for successful implementation  of the DATA Act.
section_title: Conclusions
paragraphs: Managing and overseeing government-wide projects such as DATA Act  implementation requires a governance framework that includes structures  for both project management and data governance. Agency DATA Act  implementation plans are one of the tools that OMB and Treasury use to  facilitate implementation of the DATA Act. However, they do not have fully  documented processes and controls for reviewing and using agency  implementation plans to monitor agencies’ progress against their plans,  provide needed guidance or resources, and respond to challenges  reported by the agencies. In addition, as of July 2016, OMB had not yet  determined the complete population of federal agencies that are required  to report spending data under the DATA Act and only requested that CFO  Act agencies submit updated implementation plans to OMB. As a result,  OMB and Treasury may not be fully informed of government-wide issues  or concerns, which may impair their ability to help ensure that all agencies  have the full range of resources and guidance needed to fully achieve the  purposes and benefits of the DATA Act. In addition, without updated  implementation plans from all agencies required to report under the DATA  Act that reflect the impacts of new technical requirements and guidance  on timelines and milestones, cost estimates, and risks, OMB and  Treasury may not have complete information to properly monitor resource  needs and progress in implementing new requirements government-wide.  To sustain the progress that has been made, addressing these concerns  will become even more important as the May 2017 agency  implementation date draws nearer.
section_title: Recommendations for Executive Action
paragraphs: To help ensure effective government-wide implementation and that  complete and consistent spending data will be reported as required by the  DATA Act, we recommend that the Director of OMB, in collaboration with  the Secretary of the Treasury, take the following two actions related to  oversight and monitoring of agencies’ progress: establish or leverage existing processes and controls to determine the  complete population of agencies that are required to report spending  data under the DATA Act and make the results of those  determinations publicly available and  reassess, on a periodic basis, which agencies are required to report  spending data under the DATA Act and make appropriate notifications  to affected agencies.
To help ensure effective implementation of the DATA Act by the agencies  and facilitate the further establishment of overall government-wide  governance, we recommend that the Director of OMB, in collaboration  with the Secretary of the Treasury, take the following three actions related  to monitoring and use of agency implementation plans: establish documented policies and procedures for the periodic review  and use of agency implementation plans to facilitate and monitor  agency progress against the plans;  request that non-CFO Act agencies required to report federal  spending data under the DATA Act submit updated implementation  plans, including updated timelines and milestones, cost estimates,  and risks, to address new technical requirements; and assess whether information or plan elements missing from agency  implementation plans are needed and ensure that all key  implementation plan elements are included in updated implementation  plans.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Director of OMB and the  Secretary of the Treasury for review and comment. Both OMB and  Treasury submitted written comments that are discussed below and  reprinted in appendixes IV and V, respectively. In addition, OMB and  Treasury provided technical comments, which we incorporated as  appropriate.
In its written comments, OMB generally concurred with our  recommendations related to determining the population of agencies  required to report under the DATA Act, but OMB stated that it maintains  that each agency is responsible for determining whether it is subject to  the DATA Act. OMB also stated that it and Treasury issued frequently  asked questions clarifying the legal framework under which an agency  would be subject to reporting and that agencies may consult with OMB for  additional counsel. Although OMB agreed that complete reporting from  federal agencies is a critical component of successful DATA Act  implementation, we still have concerns about whether and how OMB, in  coordination with Treasury, will help ensure completeness of the  information reported at the government-wide level.
In addition, OMB generally concurred with our recommendations related  to the monitoring and use of agency implementation plans. OMB  reiterated that it considered the initial implementation plans in the budget  formulation process and used the plans for resource planning purposes.  OMB also noted other outreach efforts we discussed in this report,  including OMB and Treasury’s recent progress meetings (i.e., readiness  discussions) held with each CFO Act agency’s senior accountable official  and OMB’s request to CFO Act agencies for updates to their  implementation plans to complement these meetings. OMB agreed that a  more formalized process should be established for reviewing agency  updates to implementation plans and stated that it would work to  systematically report on the contents of the implementation plan updates.  However, we are still concerned about OMB focusing primarily on the 24  CFO Act agencies. In its response, OMB reiterated its view that because  the 24 CFO Act agencies represent over 90 percent of federal spending,  they provide OMB with the visibility needed to address significant  implementation challenges. We recognize that the CFO Act agencies  represent the majority of federal spending, but as we discussed in this  report, the DATA Act is a government-wide initiative requiring full  reporting of all federal spending. Without updated implementation plan  information from all agencies, OMB may not have all the information it  needs to monitor resource needs and progress government-wide.
In its written comments, Treasury noted that OMB would separately  respond to the recommendation related to determining the population of  agencies required to report under the DATA Act and that Treasury will  continue to collaborate with and assist OMB on such matters. Regarding  our recommendations related to agency implementation plans, Treasury  stated that because OMB is requesting the updated implementation plan  information, Treasury would defer to OMB on a decision to expand the  request to non-CFO Act agencies and on the monitoring of the  completeness of implementation plans. To the extent that Treasury  undertakes a detailed review of updates to agency implementation plans  in the future, Treasury stated that it will establish documented policies  and procedures for its review of those plans. Treasury agreed that it has a  responsibility to monitor agency progress and stated that it remains  committed to that effort.
We are sending copies of this report to the Director of the Office of  Management and Budget, the Secretary of the Treasury, and appropriate  congressional addressees. In addition, the report is available at no charge  on the GAO website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-9816 or rasconap@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix VI.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This review is part of an ongoing effort to provide interim reports on the  progress being made in the implementation of the Digital Accountability  and Transparency Act of 2014 (DATA Act), while also meeting our  reporting requirements mandated by the act. The objectives of this review  were to determine (1) the extent to which the Office of Management and  Budget (OMB) and the Department of the Treasury (Treasury) have  processes and controls in place to review agencies’ implementation  plans, monitor agencies’ progress, provide feedback to the agencies, and  respond to challenges reported by the agencies; (2) the extent to which  selected federal agencies’ DATA Act implementation plans were prepared  in accordance with OMB and Treasury guidance; and (3) challenges  agencies have reported that may affect their ability to implement the  DATA Act and mitigating strategies they have reported to address such  challenges.
To address the first objective, we interviewed cognizant OMB and  Treasury officials and requested supporting documentation to further  understand the processes and internal controls that OMB and Treasury  have related to their (1) reviewing of agencies’ implementation plans,   (2) monitoring of agencies’ progress and providing of feedback on the  implementation plans, and (3) responding to challenges reported by the  agencies. Specifically, we made inquiries of OMB and Treasury officials  on the processes they used to analyze agency implementation plans and  how they communicated the results of their reviews government-wide and  to individual agencies. We also made inquiries about their actions taken  in response to the issues identified and the extent to which their reviews  assist agencies in implementing the DATA Act. Further, we reviewed  examples Treasury provided to us of correspondence between Treasury  and agencies discussing feedback on agency implementation plans. We  had discussions with OMB and Treasury officials to determine if there  were any updates or revisions to agencies’ implementation plans or  implementation status reports. We used Standards for Internal Control in  the Federal Government and the Project Management Institute’s A Guide  to The Project Management Body of Knowledge (PMBOK® Guide) to  assess OMB’s and Treasury’s processes and controls that were in place  from November 2015 through July 2016.
For our second objective, we requested agencies’ DATA Act  implementation plans from OMB and, at OMB’s request, requested them  directly from 51 agencies that we identified based primarily on a listing of  agencies in an OMB information system used to support OMB’s federal  management and budget processes. The 51 agencies we identified  included the 24 Chief Financial Officers (CFO) Act agencies, 13 other  agencies significant to the Fiscal Year 2014 Financial Report of the  United States Government, and 14 smaller federal agencies. However,  we note that the 51 agencies we identified may not be all of the agencies  required to report under the DATA Act. We received plans from 42 of  these agencies; 9 agencies did not submit their plans for various reasons  (see table 8). We did not validate the agencies’ determination that the  DATA Act was not applicable to them or review shared service providers’  implementation plans because it was not within the scope of the audit.
We reviewed OMB and Treasury guidance—OMB Memorandum M-15- 12, DATA Act Implementation Plans Guidance and DATA Act  Implementation Playbook (Version 1.0). Based on this guidance and the  PMBOK® Guide, we identified 51 specific plan elements for inclusion in  an agency’s implementation plan if it was prepared in accordance with the  guidance. The 51 plan elements were grouped into four separate  categories: (1) timeline, (2) cost estimate, (3) narrative, and (4) project  plan. According to OMB’s DATA Act Implementation Plans Guidance,  agencies’ implementation plans should consist of multiple parts: (1) a  timeline of tasks and steps toward implementing the requirements of  OMB Memorandum M-15-12; (2) an estimate of costs to implement these  tasks and steps; (3) a detailed narrative that explains the required steps  the agency will take to implement the DATA Act, identifies the underlying  assumptions, and outlines the potential difficulties and risks to  successfully implement the plan; and (4) a detailed project plan that  agencies will develop over time. See appendix II for a list of the 51 plan  elements. We did not evaluate the quality of the information provided in  the agencies’ plans, such as whether the implementation plan steps were  sufficient to achieve successful implementation by the agencies, as this  was outside the scope of this review. We reviewed OMB and Treasury  guidance to agencies on preparing DATA Act implementation plans,  assessed it against the PMBOK® Guide, and found that it was generally  consistent. We then reviewed the implementation plans using a data  collection instrument to document our assessment of the extent to which  the plans contained the 51 plan elements. Appendix II contains the overall  results of our review.
For the third objective, we reviewed the 42 federal agency DATA Act  implementation plans to identify any challenges and mitigating strategies  reported by the agencies. We did not assess the significance of the  challenges or merits of the mitigating strategies reported in the agencies’  plans. We also reviewed the 24 CFO Act agencies’ performance reports  and agency financial reports for fiscal years 2014 and 2015, as well as  the 27 other agencies’ financial reports available for fiscal year 2015, to  identify any additional challenges or mitigating strategies reported; none  were noted. We analyzed the information obtained and identified common  themes and categories of challenges and mitigating strategies that the  agencies reported.
We coordinated our audit efforts with the inspector general (IG)  community through monthly working group meetings to promote an  efficient and effective audit process and avoid duplication of audit efforts.  We plan to communicate the results of our review to individual agency  IGs (upon request) to help inform their readiness reviews on issues or  potential risk areas. The objective of IG readiness reviews is to allow an  agency’s IG to gain an understanding of the agency’s processes and  procedures implemented or planned to be implemented, and to assess  and report on the quality and use of data standards of the financial and  payment data in accordance with the requirements of the DATA Act.
We conducted this performance audit from November 2015 to July 2016  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: DATA Act Implementation Plan Elements
section_title: Appendix III: Agency-Reported Challenges and Mitigating Strategies
paragraphs: As we testified in April 2016, we identified seven overarching categories  of challenges to effectively and efficiently implementing the Digital  Accountability and Transparency Act of 2014 (DATA Act) as reported in  agencies’ implementation plans. In our review of the 42 agency  implementation plans we received, we found that 31 agencies reported  specific challenges, some of which may overlap with multiple categories.  We also found that 26 agencies identified mitigation strategies to address  challenges, as suggested by Office of Management and Budget (OMB)  guidance. Some strategies discussed in the agency implementation  plans address multiple challenges. The following examples of agency- reported challenges were included in our April 2016 testimony, as well as  some of the mitigating strategies reported.
subsections: section_title: Challenges Reported by Agencies in Their DATA Act Implementation Plans
paragraphs: Competing priorities. Of the 31 agencies reporting challenges in their  implementation plans, 23 reported competing statutory, regulatory, or  policy priorities that could potentially affect DATA Act implementation.  One competing priority certain agencies reported is meeting the  requirements of OMB Circular No. A-11, which provides agencies with  guidance on the budget process, including how to prepare and submit  required materials for budget preparation and execution. For example,  requirements on “object class” and “program activity” reporting create  competing priorities both for the agency’s software vendors and for the  agency’s internal resources. The agency noted that staff with knowledge  needed to understand and comment on new DATA Act data element  one agency noted that the different timelines for OMB Circular No. A‐11  definitions are the same staff required to work on the new Circular No. A‐ Circular No. A‐11 changes is severely inhibited.  11 reporting requirements. The agency added that its ability to engage  effectively on the DATA Act requirements while working to implement the  Another competing priority some agencies reported is the data  requirement set forth in the Federal Acquisition Regulation (FAR).  Specifically, in October 2014 the FAR was amended to standardize the  format of the Procurement Instrument Identifier (PIID) that must be in  effect for new awards issued beginning in October 2017. The PIID must  be used to identify all solicitation and contract actions, and agencies must  ensure that each PIID used is unique government-wide for at least 20  years from the date of the contract award. Some agencies reported that  they were concerned about the amount of effort involved in also  implementing the PIID for the DATA Act. For example, one agency noted  that it had implemented a standard PIID and developed processes and  systems to handle the new identifiers to meet the FAR requirements, but  the extent of any changes necessary to implement the PIID for the DATA  Act, which also requires a unique identifier, is unknown. Another agency  noted that this initiative and other agency initiatives will compete for many  of the same resources, including subject matter experts.
Systems integration. Systems integration is another challenge reported by  23 agencies in their implementation plans. Some agencies noted  concerns about their systems’ ability to obtain and easily submit to the  Department of the Treasury (Treasury) all the data elements needed to  implement the DATA Act, including the requirement to establish a unique  award identification number. For example, one agency reported that it  does not have a systematic link to pull data from multiple systems by a  unique award ID and it does not have an automated grants management  system because the agency noted that it reports grants data manually  using spreadsheets. This agency noted that it needs to replace its  financial system and modify supporting systems to fully comply with the  DATA Act. Another agency noted that five of the required data elements  are not included in its procurement and financial assistance system. As a  result, the agency noted that it will have to modify its system’s software to  include these elements in order to comply with the DATA Act. These  statements from agency implementation plans indicate that given the vast  number and complexity of systems government-wide that are potentially  involved in DATA Act implementation efforts, agencies may face a variety  of challenges related to systems integration.
Resources. Limited resources are another concern reported by 22  agencies in their implementation plans. Agencies frequently identified  funding and human resources as needs for efficient and effective  implementation. For example, one agency noted that the execution of its  implementation plan greatly depends on its receiving the requisite funding  and human resources as estimated in the plan, and the agency added  that delays in securing additional resources for fiscal years 2016, 2017,  and beyond will have a direct impact on its DATA Act implementation and  schedule. Similarly, another agency pointed out that having insufficient  funds for contractor support, managing the overall implementation, testing  interfaces between systems, and addressing data mapping issues will  pose a challenge for its components and systems.
Some agencies also reported that human resources are key to successful  DATA Act implementation. One agency reported that it is concerned  about the adequacy of its human resources, which could impair its ability  to comply with changes or additional DATA Act requirements. In addition,  the agency added that this may prevent it from being able to address any  deficiencies in its data and operations. Specifically, the agency reported  that resources are required for project management, data analysis, data  management, and training for financial inquiry and analysis. The need for  subject matter experts, such as data architects, was raised as a challenge  by another agency. Furthermore, one agency noted that the need to  share limited resources for DATA Act implementation with other  operational activities presents a significant challenge for its  implementation strategy.
Guidance. In their implementation plans, 19 agencies reported the lack of  adequate guidance as a challenge to implementing the DATA Act.  Several agencies noted that they cannot fully determine how their  policies, business processes, and systems should be modified to support  DATA Act reporting because, in their view, OMB and Treasury have not  yet issued complete, detailed, finalized DATA Act implementation  guidance on required data elements, the technical schema, and other key  policies. According to these agencies, issuance of such guidance is part  of the critical path to meeting their implementation goals. For example,  one agency noted that its implementation plan greatly depends on  Treasury developing the technical schema for DATA Act implementation.  The agency also reported that any delays or changes to Treasury  requirements in the technical schema will significantly affect the agency’s  solution design, development and testing schedule, and cost estimate.  Another agency included a list of unanswered questions in its  implementation plan that it wanted OMB to address in its guidance related  to the time frames, various technical requirements, level of reporting,  linking systems, and tracking and reconciling data.
Dependencies. Eighteen agencies reported in their implementation plans  that the completion of certain implementation activities is subject to  actions or issues that must be addressed by OMB and Treasury in order  for the agencies to effectively implement the DATA Act. Some agencies  also noted that they were relying on their shared service providers’  implementation of the DATA Act for agency compliance with the act. For  example, one agency noted that it will rely on its shared service provider  to enhance its system, but funding may be restricted to enhance a system  that the agency does not own. Another key dependency noted in one  agency’s implementation plan is the need for Treasury to provide detailed  information or requirements regarding the data formats, validation  module, error correction and resubmission process, and testing schedule.  Without this information, the agency noted that it cannot provide complete  cost estimates, determine changes to system and business processes,  and determine the level of effort and resources required to develop the  data submissions.
Time frames. In their implementation plans, 16 agencies reported time  constraints as a challenge in implementing the DATA Act. For example,  one agency noted that the time frame to get everything done indicated in  the original guidance coupled with the complexity of the known issues  makes it highly unlikely that its DATA Act initiative will stay on target. The  agency also noted that there is no mitigation strategy for meeting the  expected deadline on all aspects of the reporting because even if all tasks  were worked concurrently, the schedule is not attainable for the agency.  Another agency noted that its current reporting of award and awardee  information to USAspending.gov is in accordance with the Federal  Funding Accountability and Transparency Act of 2006. This information is  reported 3 days after the award is made for contracts and bimonthly for  financial assistance, while the DATA Act requires reporting of account- level information monthly where practicable but not less than quarterly.  This agency noted that linking financial information with nonfinancial  information that is reported with a different frequency creates a “moving  target” and poses a challenge to linking the financial and nonfinancial  data.
Other challenges. Agencies reported several other challenges in their  implementation plans less frequently than the ones listed above. For  example, a few agencies reported challenges related to the overall  policies, procedures, and processes, such as governance, risk  management, and training. Some agencies also noted challenges related  to the level of detail required in DATA Act information differing from  existing financial reporting processes, including the ability to reconcile  information and data to sources and official records. Finally, agencies  reported concerns about the quality and integrity of data in underlying  agency systems and its effect on DATA Act reporting.
section_title: Mitigating Strategies Reported by Agencies in Their DATA Act Implementation Plans
paragraphs: Leveraging existing resources. To effectively use limited resources, some  agencies noted in their implementation plans the importance of leveraging  available systems and human resources by reassigning staff, using  subject matter experts, and multitasking when possible to maximize  efficiency. For example, one agency reported that it will leverage senior  executive support to make the DATA Act implementation a priority and  see what resources might be available in the “least expected places,” as  well as work on tasks concurrently. In addition, agencies reported the  need to update systems to encompass more data elements and  streamline reporting. For example, one agency reported that it plans to  designate a Chief Data Officer to oversee a multitiered review of agency  data and implement solutions for consolidating agency data.
Communication and information sharing. In their implementation plans,  some agencies reported the need for frequent communication with OMB,  Treasury, shared service providers, vendors, and other agencies in order  to keep one another updated on their implementation activities, as well as  to share best practices and lessons learned throughout the process.  Agencies also suggested that reviewing other agencies’ implementation  plans for best practices, common challenges, and solutions would  facilitate information sharing. For example, one agency pointed out that in  its view lines of communication between Treasury and the agencies must  be transparent to help ensure that the submission of financial data is  accurate and the process for submitting them runs smoothly. Another  agency noted that it believes that collaboration with other agencies to  share common concerns will be beneficial.
Process and policy review/adaptation. In order to implement the DATA  Act, agencies also plan to review and adapt their current processes and  policies in order to incorporate the act’s requirements. For example, one  agency noted in its plan that it will develop a continuous process to  analyze, plan, track, and control potential risks throughout DATA Act  implementation. Another agency noted that it plans to align the  implementation schedules for its system upgrades as closely as possible.  In its plan, the agency pointed out that performing testing, independent  validation and verification, and other tasks at the same time for both  projects will save time. The agency’s plan also noted that this strategy will  minimize the burden on both agency and contractor personnel while  keeping them on track to meet the required completion dates.  Furthermore, agencies reported that they will conduct reviews of their  business processes and procedures to find gaps and help ensure that  submitted data are complete and accurate. For example, an agency  noted in its plan that it will conduct reconciliations to review the data  processed and ensure that the submitted data match the supporting  documentation.
Utilizing external resources. Agencies noted plans to use external  resources in implementing the DATA Act. For example, several agencies’  plans noted that they plan to work closely with their shared service  providers throughout the implementation process. One agency also noted  that it will hire a contractor to assess cost and risk management  procedures to determine their alignment with leading practices. Another  agency noted that it intends to leverage access to external working  groups for addressing concerns as well as decision making. Finally, one  agency discussed the need to replace its current financial system in order  to comply with DATA Act requirements.
Monitoring and developing guidance. In their implementation plans,  agencies also discussed plans to closely monitor DATA Act  implementation guidance in order to adapt agency implementation  strategies as the guidance changes. For example, one agency noted that  it will monitor and evaluate the release of DATA Act guidance as well as  data elements and the technical schema in order to identify the effect on  the project. Another agency noted that it plans to use its established  governance structure to immediately facilitate solutions when additional  guidance is provided. Further, some agencies discussed developing  guidance and training materials for internal use. For example, one agency  stated that it plans to create a common set of tools by establishing a  “project management toolkit” for agency leaders to ensure that DATA Act  implementation needs are addressed efficiently and effectively.
Technical solutions. Some agencies plan to utilize various technical  solutions as part of their DATA Act implementation plans. For example,  one agency noted in its plan that it will leverage existing technologies and  processes available to extract, transform, load, and build on established  and successful mappings and minimize cost and schedule impacts.  Another agency’s plan noted that it may use an interface file that contains  both the award ID and the document number used in its financial system  to crosswalk between the financial detail and the award ID in its systems.  One agency also noted that it will implement business intelligence and  analytics tools, including the development of automated, multiple data  reconciliations where feasible. Furthermore, another agency noted that it  will engage system vendors to make system changes and thereby reduce  the need for future custom development. According to the agency, this  strategy will help manage its initial implementation costs.
section_title: Appendix IV: Comments from the Office of Management and Budget
section_title: Appendix V: Comments from the Department of the Treasury
section_title: Appendix VI: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Michael LaForge (Assistant  Director); Carroll Warfield, Jr. (analyst-in-charge); Fred Evans; Thomas  Hackney; Charles Jones; Diane Morris; and Laura Pacheco made major  contributions to this report. Other key contributors include Peter Del Toro,  Kathleen Drennan, Doreen Eng, Patrick Frey, Jason Kelly, Jason Kirwan,  Leticia Pena, Carl Ramirez, Michelle Sager, Andrew J. Stephens, and  James Sweetman, Jr. Additional members of GAO’s Internal Working  Group on the Digital Accountability and Transparency Act of 2014 also  contributed to the development of this report.
section_title: Related GAO Products
paragraphs: DATA Act: Section 5 Pilot Design Issues Need to Be Addressed to Meet  Goal of Reducing Recipient Reporting Burden. GAO-16-438. Washington,  D.C.: April 19, 2016.
DATA Act: Progress Made but Significant Challenges Must Be Addressed  to Ensure Full and Effective Implementation. GAO-16-556T. Washington,  D.C.: April 19, 2016.
DATA Act: Data Standards Established, but More Complete and Timely  Guidance Is Needed to Ensure Effective Implementation. GAO-16-261.  Washington, D.C.: January 29, 2016.
Federal Spending Accountability: Preserving Capabilities of Recovery  Operations Center Could Help Sustain Oversight of Federal  Expenditures. GAO-15-814. Washington, D.C.: September 14, 2015.
DATA Act: Progress Made in Initial Implementation but Challenges Must  be Addressed as Efforts Proceed. GAO-15-752T. Washington, D.C.:   July 29, 2015.
Federal Data Transparency: Effective Implementation of the DATA Act  Would Help Address Government-wide Management Challenges and  Improve Oversight. GAO-15-241T. Washington, D.C.: December 3, 2014.
Government Efficiency and Effectiveness: Inconsistent Definitions and  Information Limit the Usefulness of Federal Program Inventories.  GAO-15-83. Washington, D.C.: October 31, 2014.
Data Transparency: Oversight Needed to Address Underreporting and  Inconsistencies on Federal Award Website. GAO-14-476. Washington,  D.C.: June 30, 2014.
Federal Data Transparency: Opportunities Remain to Incorporate  Lessons Learned as Availability of Spending Data Increases.  GAO-13-758. Washington, D.C.: September 12, 2013.
Government Transparency: Efforts to Improve Information on Federal  Spending. GAO-12-913T. Washington, D.C.: July 18, 2012.
Electronic Government: Implementation of the Federal Funding  Accountability and Transparency Act of 2006. GAO-10-365. Washington,  D.C.: March 12, 2010.
Federal Contracting: Observations on the Government’s Contracting Data  Systems. GAO-09-1032T. Washington, D.C.: September 29, 2009.