DATA Act: Data Standards Established, but More Complete and Timely Guidance Is Needed to Ensure Effective Implementation
Released: 2016-01-29T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: The DATA Act directed OMB and Treasury to establish government-wide data standards by May 2015 to improve the transparency and quality of federal spending data. Agencies must begin reporting spending data in accordance with these standards by May 2017 and must publicly post spending data in machine-readable formats by May 2018. Consistent with GAO’s mandate under the act, this report is part of a series of products that GAO will provide to the Congress as DATA Act implementation proceeds.

This report (1) identifies steps taken by OMB and Treasury to standardize data element definitions and the extent to which those definitions are consistent with leading practices or face challenges that could affect data quality; (2) reviews efforts by OMB and Treasury to provide agencies with technical implementation guidance and related challenges; and (3) examines the implementation status of selected federal agencies. GAO analyzed data standards against leading practices; reviewed key implementation documents, technical specifications, and applicable guidance; and interviewed staff at OMB, Treasury, and other selected agencies.

section_title: What GAO Found
paragraphs: As required by the Digital Accountability and Transparency Act of 2014 (DATA Act), the Office of Management and Budget (OMB) and the Department of the Treasury (Treasury) issued definitions for 57 federal spending data elements. GAO found that most definitions adhered to leading practices derived from international standards for formulating data definitions. Specifically, 12 of the 57 definitions met all 13 leading practices and none met fewer than 9. However, GAO found several definitions that could lead to inconsistent reporting. For example, as shown in the figure below, the Primary Place of Performance definitions’ inclusion of the word “predominant“ leaves much open to interpretation. Without more interpretive clarification, agencies run the risk of reporting data that cannot be aggregated government-wide.

OMB and Treasury addressed some of GAO’s earlier concerns on draft technical guidance for implementing data standards. However, final technical guidance has not been issued, which could impede agency implementation. While OMB and Treasury have released interim versions of technical guidance, they have not yet released final guidance to provide a stable base for agency implementation. They also are developing an intermediary service (“broker”) to standardize and validate agency data submissions. GAO’s review of selected implementation plans found that agencies need the technical guidance and the intermediary service to be finalized before they can develop detailed agency-level plans. If this guidance is not aligned with agency implementation timelines, agencies may delay taking key steps or need to revise existing plans once final technical guidance is released, thereby hindering their ability to meet DATA Act requirements and timelines.

GAO found that the three agencies it reviewed—the Departments of Agriculture and Health and Human Services, as well as the Corporation for National and Community Service—have formed internal teams and are inventorying their data and assessing any needed changes to policies, processes, and technology to implement the DATA Act.

section_title: What GAO Recommends
paragraphs: GAO recommends that OMB and Treasury (1) provide agencies with clarifications to address potential quality issues with the definitions, and (2) take steps to align the release of finalized technical guidance and the broker service with agency implementation time frames. OMB and Treasury generally concurred with our recommendations.

section_title: Letter
paragraphs: The federal government spends more than $3.5 trillion annually; however,  tracking this money can be difficult because spending data are often  incomplete or inaccurate. The Digital Accountability and Transparency  Act of 2014 (DATA Act) holds considerable promise for shedding more  light on how federal funds are spent. To improve the transparency and  quality of the federal spending data made available to the public, the  DATA Act directs the Office of Management and Budget (OMB) and the  Department of the Treasury (Treasury) to establish government-wide data  standards that include common data elements for reporting financial and  payment information by May 2015. In general, the act requires agencies  to begin reporting financial spending data using these standards by May  2017 and publicly post spending data in machine-readable formats by  May 2018.

It is critical that agencies use government-wide standards to report  spending data in order to help ensure the quality and usefulness of the  resulting information. We have previously reported on persistent  challenges involving the quality and completeness of the spending data  that federal agencies report to USAspending.gov, a free, publicly  accessible website containing data on federal awards and subawards.  To address these problems, we recommended that the Director of OMB  (1) clarify guidance on reporting award information and maintaining  supporting records and (2) develop and implement oversight processes to  ensure that awards data are consistent with agency records. OMB  generally agreed with our recommendations and we will continue to  monitor OMB’s implementation of them.

This report is the latest GAO work in response to a statutory provision to  review DATA Act implementation. This report (1) identifies steps taken  by OMB and Treasury to establish government-wide data element  definitions and the extent to which those definitions are consistent with  leading practices or face challenges that could affect data quality; (2)  reviews efforts by OMB and Treasury to provide agencies with technical  implementation guidance to standardize how data are collected and  reported and related challenges; and (3) examines the status of selected  federal agencies’ progress in meeting DATA Act requirements.

To assess the extent to which OMB and Treasury established data  standards that are consistent with leading practices, we analyzed OMB’s  and Treasury’s 57 standardized data element definitions using criteria  established under the DATA Act as well as leading practices for well- constructed data definitions derived from standards developed by the  International Organization for Standardization (ISO). To assess OMB’s  and Treasury’s development of a technical schema that specifies the  format, structure, tagging, and transmission of each data element to allow  consistency and comparability, we reviewed and analyzed differences  between version 0.2, version 0.5, and version 0.6 of the schema. We  reviewed applicable agency guidance and documentation related to the  data standards and technical schema on OMB’s and Treasury’s websites.  We also interviewed knowledgeable agency officials about their  standards-setting and technical schema development processes. To  obtain information on the status of agencies’ efforts to meet their DATA  Act requirements and any challenges they faced meeting those  requirements, we selected three agencies—the Department of Health and  Human Services (HHS), the Department of Agriculture (USDA), and the  Corporation for National and Community Service (CNCS). We identified  these agencies using a three-step selection process that considered (1)  whether the agency was in compliance with existing federal requirements  for federal financial management systems; (2) the type of federal funding  provided (such as grants, loans, and contracts); and (3) status as a  Federal Shared Service Provider for financial management. The selected  agencies represent a mix of these characteristics to illustrate a range of  conditions under which agencies are implementing the DATA Act. We  reviewed the selected agencies’ implementation plans and related project  plans and interviewed agency officials responsible for DATA Act  implementation. Additional details regarding our objectives, scope, and  methodology are provided in appendix I.

We conducted this performance audit from May 2015 to January 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 on our audit objectives.
subsections: section_title: Background
subsections: section_title: The DATA Act Expanded the Required Reporting of Federal Spending Data under FFATA
paragraphs: During the last decade, Congress and the administration have taken  several steps to improve the transparency of federal spending data. In  2006, Congress passed and the President signed the Federal Funding  Accountability and Transparency Act of 2006 (FFATA) to increase the  transparency and accountability of federal contracts and financial  assistance awards. Among other things, FFATA required OMB to  establish USAspending.gov, containing obligational data on federal  awards and subawards, which was launched in December 2007. One of  the stated purposes of the DATA Act is to expand FFATA to include direct  federal agency expenditures and link contract, loan, and grant spending  information to federal programs so that taxpayers and policy makers can  more effectively track federal spending.

Reporting throughout the federal spending cycle. Full and effective  implementation of the DATA Act will allow funds to be tracked at multiple  points in the federal spending lifecycle. For example, once fully  implemented, amounts appropriated, obligated, and subsequently  outlayed for a particular program activity would all be publicly available on  USAspending.gov or a successor website. These additional federal  spending cycle data on appropriations, obligations, and outlays will  provide more transparency on federal awards. USAspending.gov  provides information on award amounts for grants, contracts, and other  types of information, but the only information currently available is data on  federal award obligations.

The DATA Act represents a significant change to the types of data  reported by requiring additional budget and financial information, which,  to date, has not been reported on USAspending.gov. The act requires  budget and financial information to be reported on a monthly basis if  practicable, but not less than quarterly. However, OMB’s May 2015  guidance directs agencies to continue reporting on awards data at least  bi-weekly. To cover appropriations and outlays in addition to obligations,  OMB and Treasury officials noted that data will need to be pulled from  budgetary and financial systems in addition to the multiple contract and  assistance systems currently used. It is essential that all of this data be  appropriately linked to achieve the full potential for users of this data  inside and outside of government.

Reporting on more types of federal spending. The DATA Act requires  reporting on almost all types of federal spending. Currently,  USAspending.gov reports data on federal awards including grants,  contracts, and loans. Under the DATA Act, however, more budget and  financial information will be available that should allow users of the data  to organize and analyze the data in ways that are not currently possible.  Some of these new types of spending information include:

Budget and financial information on the different types of goods and  services purchased by the federal government, such as personnel  compensation, will be reported in the aggregate.

Budget and financial information from financial arrangements of the  federal government, such as public-private partnerships, interagency  agreements, and user charges, will also be reported.

As part of their guidance to agencies on DATA Act implementation,  OMB lowered the threshold at which agencies must report data on  financial assistance and procurement prime awards from $25,000 or  greater to those awards greater than the micro-purchase threshold,  which is currently $3,500.

Improving data quality. Our prior work found that unclear guidance and  weaknesses in executive branch oversight contributed to persistent  challenges with data on USAspending.gov. These challenges relate to the  quality and completeness of data submitted by federal agencies. For  example, in 2010, we reported that USAspending.gov did not include  information on awards from 15 programs at 9 agencies for fiscal year  2008. In that report we also reviewed a sample of 100 awards on the  website and found that each award had at least one data error. In June  2014, we reported that roughly $619 billion in assistance awards were not  properly reported in fiscal year 2012. In addition, we found that few  reported awards—between 2 and 7 percent—contained information that  was fully consistent with agency records for all 21 data elements we  examined. A factor that contributed to this error rate was the lack of  guidance on how to interpret some data elements including award  description. See appendix II for more information on our  recommendations related to these findings and OMB’s and Treasury’s  actions to date.

The DATA Act identifies the improvement of data quality as one of its  purposes. Toward that end, the act requires that inspectors general  conduct reviews of data samples submitted by their respective agency  and subsequently assess and report on the data’s completeness,  timeliness, quality, and accuracy. We are required to review these reports  and then assess and compare the completeness, timeliness, quality, and  accuracy of the data across the federal government.

section_title: OMB and Treasury Issued Guidance to Help Agencies Carry Out DATA Act Reporting Requirements
paragraphs: OMB and Treasury issued initial guidance to federal agencies in May  2015 on reporting requirements pursuant to FFATA as well as the new  requirements that agencies must employ pursuant to the DATA Act. The  guidance also directs agencies to  implement data definition standards for the collection and reporting of  agency-level and award-level data by May 9, 2017; implement a standard data exchange format for providing data to  Treasury to be displayed on USAspending.gov or a successor site;  and link agency financial systems with award systems by continuing the  use of specified unique identification numbers for financial assistance  awards and contracts.

OMB asked agencies to submit DATA Act implementation plans in  September 2015, concurrent with the fiscal year 2017 budget request.  According to OMB staff, as of December 2015, all 24 CFO Act agencies  as well as 27 smaller federal agencies have submitted implementation  plans. OMB required the plans to include: (1) a timeline of tasks and  steps toward implementing the requirements of this guidance; (2) an  estimate of costs to implement these tasks and steps; (3) a detailed  narrative that explains the required steps, 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.

Additionally, OMB and Treasury issued a DATA Act Implementation  Playbook in June 2015, which recommends eight key steps for agencies  to fulfill their requirements under the DATA Act (see table 1).

To support this effort, OMB and Treasury issued guidance to help  agencies develop the plans and hosted workshops and conference calls  to address agency questions.

section_title: OMB and Treasury Established Government-wide Data Standards, but More Remains to Be Done to Ensure Consistent and Comparable Reporting of Federal Spending Data
subsections: section_title: OMB and Treasury Issued 57 Standardized Data Element Definitions for Reporting Federal Spending Data
paragraphs: The DATA Act requires OMB and Treasury to establish government-wide  financial data standards for any federal funds made available to or  expended by federal agencies and recipients of federal funds. The  specific items to be reported under the act are generally referred to as  data elements. The overall data standardization effort consists of two  distinct, but related, components: (1) establishing definitions which  describe what is included in each data element with the aim of ensuring  that information will be consistent and comparable, and (2) creating a  data exchange standard with technical specifications which describe the  format, structure, tagging, and transmission of each data element. The  data exchange standard is also intended to depict the relationships  between standardized data elements.

On May 8, 2015, a year after the passage of the DATA Act, OMB and  Treasury issued the first 15 standardized data element definitions,  including definitions for 8 new elements introduced by the DATA Act.  From June through August 2015, OMB and Treasury released an  additional 42 standardized data element definitions for reporting under  FFATA, as amended by the DATA Act. During this time, OMB and  Treasury released data element definitions in stages and opened a 3- week feedback period for federal and nonfederal stakeholders to provide  public input on the definitions before they were issued. During this  period we separately met with OMB and Treasury staff several times to  share our views and identify issues and concerns with proposed  definitions. See figure 1 for a listing of the 57 standardized data elements  grouped by type. See appendix III for the definitions of each of the data  elements.

section_title: Data Element Definitions Generally Followed Leading Practices, but Exceptions Could Result in Inconsistent Reporting if Not Addressed
paragraphs: The DATA Act requires that data standards—to the extent reasonable  and practicable—incorporate widely-accepted common data elements,  such as those developed by international standards-setting bodies,  federal agencies with authority over contracting and financial assistance,  and accounting standards organizations. Incorporating leading practices  from international standards organizations offers one way to help reduce  uncertainty and confusion when reporting and interpreting data standards.  Developing a well-crafted data element definition is one key component to  ensuring that a data standard produces consistent and comparable  information. The ISO, a standards-setting body composed of international  experts in various fields of study, has developed 13 leading practices for  formulating data definitions for the purposes of specifying, describing,  explaining, and clarifying the meaning of data. These practices include  that definitions be precise and unambiguous, avoid circular reasoning,  and be expressed without embedding definitions of other data or  underlying concepts, among others.

We found that the 57 DATA Act data element definitions largely followed  ISO leading practices for the formulation of data definitions. Specifically,  12 data element definitions met all of the ISO leading practices and each  of the remaining 45 definitions met no fewer than 9 leading practices,  meaning that even the lowest-rated data elements in our review adhered  to almost 70 percent of the ISO leading practices. We also found  variation in which of the leading practices each definition satisfied. For  example, our analysis found that all 57 definitions followed the leading  practices of avoiding circular reasoning and being stated as a descriptive  phrase or sentence, whereas 38 of the 57 were determined to be  sufficiently precise and unambiguous. Table 2 provides a summary of our  findings applying the ISO leading practices for formulating data definitions  to the definitions developed by OMB and Treasury as part of DATA Act  implementation.

Although most of the definitions generally adhered to ISO leading  practices, examples where data elements did not do so raise potential  concerns regarding an increased risk that agencies may not apply the  definitions consistently, thus affecting the comparability of reported data.  Data element definitions that are imprecise or ambiguous may allow for  more than one interpretation by agency staff collecting, compiling, and  reporting on these data and thus could result in inconsistent and  potentially misleading reporting when aggregated across government or  compared between agencies. For example, OMB and Treasury defined  Award Description as “a brief description of the purpose of the award.” In  our previous work on the data quality of USAspending.gov, we identified  challenges with the Award Description data element, citing the wide range  of information that agencies report as the description or purpose.  Specifically, we found that agencies routinely provided information for this  data element using shorthand descriptions, acronyms, or terminology that  could only be understood by officials at the agency that made the award.  For example, in our 2010 report we found that the description for one  contract we reviewed read “4506135384!DUMMY LOA,” while the award  records indicated that the award was for the purchase of metal pipes.  Another was described as “Cont Renewals All Types,” while the award  records showed the contract was for an apartment building. This lack of  basic clarity would make the data element difficult for others outside the  agency to understand and would also limit the ability to meaningfully  aggregate or compare this data across the federal government.

We made recommendations to OMB in 2010 and 2014 and to Treasury in  2014 to improve the accuracy and completeness of Award Description,  which have yet to be addressed. At that time, Treasury officials neither  agreed nor disagreed with our recommendations, while OMB staff  generally agreed with them stating that they were consistent with actions  required under the DATA Act. These OMB staff said while they would  consider interim steps to improve data quality, they did not want to inhibit  agency efforts to work toward implementation of the act. Appendix II  provides more information on the status of these recommendations. In  subsequent discussions, OMB staff stated that they are hesitant to make  substantial changes to the reporting of Award Description, which focuses  on the purpose of a federal award, before additional progress is made on  the related and more complex issue of how to ascribe spending data to a  specific government program. However, it is unclear why this should  prevent them from taking steps such as providing agencies with guidance  on how to avoid excessive jargon, provide a specific level of detail, or  develop a standardized taxonomy of appropriate responses.

While the data quality concerns presented by the definition of Award  Description are relatively straightforward to address, other definitions that  we found to be imprecise and ambiguous present greater challenges due  to long-standing differences in reporting across agencies and among the  federal grant, procurement, and loan communities. An example of this is  the four data elements that OMB and Treasury have issued that  collectively represent the concept of Primary Place of Performance. The  location or place of performance of specific grant, contract, or other  federal spending has long been a data element collected by agencies.  However, in the past, agencies have taken varied approaches to reporting  place of performance information—sometimes describing where the  funded activity takes place, sometimes the recipient of the product or  activity, or sometimes the location of the administrative headquarters of  the provider or a sub-entity. The definitions issued by OMB and Treasury  standardize some of the mechanics of what Primary Place of  Performance covers, such as city, county, state, and ZIP+4 codes. In  addition, OMB staff told us that, by using the words “where the  predominant performance of the award will be accomplished” the  definitions are intended to focus on where the majority of the activity  actually takes place rather than, for example, the location of the ultimate  recipient of the product or service funded by federal spending.

However, OMB’s and Treasury’s definitions still leave room for differing  interpretations that could result in agencies capturing and reporting this  information differently. For example, OMB staff told us that they interpret  the term “predominant performance” to mean “more than half,” but this  clarification is not contained in the definition itself, nor in the  accompanying white paper that was issued with the data element  definitions. Other questions exist regarding the appropriate unit of  analysis for making such a determination. For example, it is unclear if  “where the predominant performance of the award will be accomplished”  is determined by the amount of time spent in a particular location when  carrying out the award or by some other metric such as number of staff  deployed or the amount of financial resources expended in a particular  location. The standardized definitions for Primary Place of Performance  do not address this level of detail and according to OMB staff they have  not issued guidance or other resources, such as a FAQ document, to help  agencies operationalize this concept in a consistent and comparable way.

Another concern involves how to assign a value for Primary Place of  Performance when the activity being described does not readily lend itself  to a discrete geospatial location (such as a consulting service provided in  many locations) or if it spans multiple locations (such as a road traversing  multiple counties or states). One approach that has been previously used  for reporting the location of federal spending for road projects on  USAspending.gov is to assign the spending to the county or state capitol  in the jurisdiction where the majority of the road was constructed. OMB  staff told us that they would likely follow such an approach when reporting  on Primary Place of Performance using the newly standardized definition  in the future. While this may be potentially misleading in some situations,  in the absence of a clearly better alternative it is critical that the particular  decision rules OMB decides to follow are documented and clearly  communicated to agencies providing this data as well as end-users.  Figure 2 provides a notional illustration of some of the different places of  performance that agencies could report for federally funded road projects  based on the current definitions of these data elements.

Despite the potential for multiple interpretations of what should be  reported for Primary Place of Performance, OMB staff told us that federal  agencies have not raised this as a significant reporting challenge.  However, feedback OMB and Treasury received from both federal and  nonfederal stakeholders identified a number of concerns with these  definitions including the need to more clearly define what is meant by  “primary” place of performance and how to interpret the word  “performance” for this definition. In responding to this feedback, OMB and  Treasury acknowledged the difficulty of addressing stakeholder concerns  through a single data element and that in the future, as part of their plans  to adopt a more formal data governance structure, they expect to identify  and standardize other location-related data elements to address other  needs.

section_title: The Data Element Definition for Program Activity Adheres to Leading Practices; However, More Guidance Is Needed to Ensure Program-Related Data Are Consistent and Comparable
paragraphs: In some cases OMB and Treasury will need to take additional steps to  make data standards consistent and comparable for federal and  nonfederal entities. For example, OMB and Treasury standardized the  definition of Program Activity as required by the DATA Act and we found  that this definition adhered to all 13 ISO leading practices. However,  concerns still remain regarding the use of this data element. For example,  OMB’s and Treasury’s guidance on Program Activity acknowledges that  program activities can change from one year to the next and that Program  Activity does not necessarily match “programs” as specified in the GPRA  Modernization Act of 2010 or the Catalog of Federal Domestic  Assistance. In responding to this guidance, officials at USDA said that  when program activities change it is difficult to make comparisons of  federal spending over time.

Moreover, USDA officials noted that more guidance is needed to ensure  that the public can accurately interpret Program Activity compared to the  other common representations of federal programs. In our July 2015  testimony on DATA Act implementation, we reported that OMB and  Treasury will need to build on the program activity structure and provide  agencies with guidance if they are to meet one of the stated purposes of  the DATA Act to link federal contract, loan, and grant spending  information to federal programs to enable taxpayers and policy makers to  track federal spending more effectively. In that testimony, we made a  recommendation that OMB accelerate efforts to develop a federal  program inventory to ensure that federal program spending data are  provided to the public in a transparent, useful, and timely manner. During  the hearing, an OMB official testified that, because the staff that would be  involved in working on the program inventories is heavily involved in  DATA Act implementation, he would not expect an update of the program  inventories to happen before May 2017.

Much remains to be done to effectively implement standard data element  definitions across the federal government in a consistent and comparable  way for reporting purposes. OMB and Treasury told us that they are  making policy decisions and developing guidance to help agencies with  implementing data standards. They expect to issue this guidance in  spring 2016, and we will review it at that time. Consequently, many issues  remain unanswered regarding the extent to which agencies may need to  change their policies, processes, and systems in order to report their  financial data in compliance with the act. A senior HHS official told us that  they have communicated to OMB and Treasury that in the absence of  detailed guidance related to the policy, process, and technology changes  that accompany the data element definitions, agencies cannot develop  effective implementation plans or appropriately commit the necessary  resources toward implementing the DATA Act because implementation  efforts and timelines are highly dependent on this information. Agencies  must begin reporting data using the data definitions established under the  DATA Act by 2017. It remains uncertain the extent to which these data  will be consistent and comparable if OMB and Treasury do not address  concerns with the quality of data definitions.

section_title: OMB and Treasury Addressed Initial Challenges with the Technical Schema, but the Lack of Finalized Technical Guidance Could Impede Agency Implementation
paragraphs: The DATA Act calls for OMB and Treasury to establish government-wide  data standards, to the extent reasonable and practicable, that produce  consistent and comparable data available in machine-readable formats.  Treasury has taken the lead in drafting a technical schema intended to  standardize the way financial assistance awards, contracts, and other  financial data will be collected and reported under the DATA Act.  Toward that end, the technical schema describes the standard format for  data elements including their description, type, and length. In July 2015,  we identified several potential concerns with version 0.2 of the schema,  including that the schema might not prevent inconsistent reporting  because it allowed alphabetic characters to be entered into a data field  that should only accept numeric data. We also noted that the schema  did not identify a computer markup language that agencies can use for  communicating financial data standards. Identification of such a language  provides standards for annotating or tagging information so that data can  be transmitted over the Internet and can be readily interpreted by a  variety of computer systems.

OMB and Treasury addressed several of the concerns we raised in  version 0.6 of the DATA Act schema issued in October 2015. For  example, version 0.6 of the schema addressed inconsistencies between  machine-readable and human-readable documentation and simplified the  schema so that data elements, names, and definitions are consistent  across all award types including grants, loans, and contracts. According  to Treasury officials, subsequent versions of the schema will include  additional information about complex data types and introduce extensible  business reporting language (XBRL) formats in preparation for version  1.0. Treasury planned to issue version 1.0 by December 31, 2015,  which it said would provide a more stable base to help agencies  understand how to map their financial and award information to adhere to  DATA Act requirements. However, instead of releasing version 1.0 as  planned, they released another interim version—version 0.7. According to  Treasury, this version incorporates additional financial data elements and  attributes that are intended to support more accurate and detailed  financial and budgetary accounting information.

Given the importance of having a largely stable schema to serve as the  foundation for developing subsequent technical processes at the agency  level, any significant delay in releasing version 1.0 of the schema will  likely have consequences for timely implementation of the act. Treasury  officials told us they are not prepared to provide a time frame for  completion of version 1.0. As previously mentioned, OMB’s and  Treasury’s DATA Act Implementation Playbook outlines eight specific  steps and timelines for implementing the DATA Act at the agency level.  However, in some cases guidance that would help agencies carry out  these steps has not been provided in time to coincide with when the  agency was expected to carry out key activities outlined in the DATA Act  Implementation Playbook. For example, step 3 of the 8-step plan calls for  agencies to inventory agency data and associated business processes  from February to September 2015 to identify where there are gaps in the  data that are collected. OMB and Treasury provided technical tools  including a template to help agencies inventory their financial and awards  data to identify any gaps that could impede standardization. However, a  stable DATA Act schema that specifies the form and content the data  should be reported in was not available to agencies to help them fully  carry out this step.

Corporation for National and Community Service (CNCS) officials told us  that because operational details for how data are to be exchanged have  not yet been finalized, the agency has not taken steps to map agency  financial and awards data to the schema. Treasury officials told us, that  because they are using an iterative approach to technical implementation,  they have not finalized an architecture for the collection and  dissemination of government-wide data that could provide agencies with  a description of the various technology layers, interoperability and  structures, and reporting languages that they will be expected to use  beginning in May 2017. In the absence of a clear and consistent set of  technical specifications, agency technical staff, enterprise resource  planning (ERP) vendors, and others tasked with adapting Treasury’s  schema to work with the financial and award management environment at  individual federal agencies may delay plans to carry out key steps until  the schema is finalized. Alternatively, if agencies decide to move ahead  and then significant changes are subsequently made to the schema,  agencies could incur additional costs to revise their systems and  processes to conform to a later version.

In addition to the draft technical schema, Treasury is developing an  intermediary service called a “broker” to standardize data formatting and  assist reporting agencies in validating their data submissions before they  are submitted to Treasury. As part of this effort, Treasury recently  completed a limited-use pilot test of the broker service with the Small  Business Administration (SBA) to test agency data submissions. Treasury  has future plans to develop and test a broker prototype for contracts. The  pilot demonstrated a broker prototype that could extract data from SBA’s  grant and financial systems, perform data validation, and convert data to  the DATA Act schema for submission to Treasury’s database. A Treasury  official acknowledged, however, that it may be more difficult for larger or  more complex agencies to extract their data and perform these necessary  functions.

In September 2015, Treasury posted the limited-use SBA broker  prototype on GitHub, a public online collaboration website, so that  agencies and the public could begin reviewing the broker prototype.  Treasury also made a set of high-level conceptual models available to  agencies on MAX.gov to help them understand how they might extract  data from their own financial and award systems. Treasury told us that  they plan to build and host a centralized broker service, but have not  specified a time frame when it will be available. In addition, Treasury is  exploring the option to allow agencies to use the Treasury broker service  locally to work within their own operational environments. According to  these officials, agencies may also choose to work through ERP vendors  who could develop commercial products that would be made available to  agencies.

However, because the SBA broker prototype was primarily tested on  grants, a broker prototype that extracts and validates data from other  types of awards, such as contracts and loans, is still not available to  agencies. Moreover, little is known about how the prototype would work  with other forms of awards, which are often located in different systems  and use different definitions. Agencies need this information to begin  testing the broker using their own data so they can develop effective  strategies for data submission within the time frame—October 2015 to  February 2016—prescribed in the DATA Act Implementation Playbook.  The prototype tested grants data from SBA’s award system which is  already linked to SBA’s financial management system through unique  award identifiers. It is not known whether and how the broker prototype  would work for a number of agencies that have financial and award  systems that are not yet linked. According to a Treasury official, most  agencies have not established linkages between their financial and award  systems.

Our review of three selected agency implementation plans and interviews  with agency officials indicates that agencies are waiting for technical  guidance on the broker service so that they can begin to develop plans to  extract data from their current systems and map it to the DATA Act  schema. For example, CNCS’s implementation plan submitted to OMB in  September of 2105 cites the lack of information about the broker as a  significant challenge that could impede effective implementation of the  data standards and new reporting requirements. As a result of this  uncertainty, USDA officials told us that they decided to move ahead with  the development of its own broker to compile and validate its data  centrally and then forward it on to Treasury. Moreover, USDA officials  noted that since much of Treasury’s technical guidance to date has  focused on grants and cooperative agreements little is known about how  the broker service would work with other financial assistance awards such  as loans and insurance programs.

section_title: Selected Agencies Have Taken Initial Steps to Implement Data Standards
paragraphs: The three agencies in our review—the Corporation for National and  Community Service (CNCS), the Department of Health and Human  Services (HHS), and the Department of Agriculture (USDA)—have begun  addressing the requirements of the DATA Act by forming DATA Act  teams, participating in government-wide deliberations on data standards,  developing an inventory of their data, identifying systems containing  pertinent data and the associated business practices, and assessing the  policy, process, and technology changes that may be needed for  successful implementation. In addition to providing guidance in the DATA  Act Implementation Playbook, OMB and Treasury have regularly engaged  agency officials to address questions and concerns related to  implementing data standards. This outreach has included monthly  conference calls with agency senior accountable officials (SAO), posted  office hours for agencies to obtain feedback on the implementation  process and raise OMB’s and Treasury’s awareness regarding specific  implementation challenges, and a biweekly digest that is distributed to  SAOs to keep agency staff informed about recent and upcoming DATA  Act activities. Table 3 provides additional information regarding the status  of DATA Act implementation activities for these three agencies.

section_title: Conclusions
paragraphs: Once fully and effectively implemented, the DATA Act holds great  promise for improving the transparency and accountability of federal  spending data by providing consistent, reliable, and complete data on  federal spending. In order to fully and effectively implement the DATA  Act, the federal government will need to address complex policy and  technical issues. Central among these is defining and developing  common data elements across multiple reporting areas and standing up  the necessary supporting systems and processes to enable reporting of  the federal spending data required by the DATA Act. Toward that end,  OMB and Treasury have made progress since the act was signed into law  in May 2014, including issuing definitions for 57 data elements,  developing an 8-step plan and timelines for agencies to follow as they  move through the implementation process, and providing a variety of  outreach approaches to address agency questions and to obtain  feedback from federal and nonfederal stakeholders.

The implementation accomplishments to date exist alongside continued  challenges that OMB and Treasury need to address in order to  successfully meet the requirements and objectives of the act. Although  the majority of the 57 data element definitions generally follow leading  practices, we identified limitations with some data element definitons and  their documentation that, if not addressed, could lead to inconsistent  reporting, and limit the ability to meaningfully aggregate or compare data  for these elements across the federal government. Moreover, the  standards will be of little value if agencies are not prepared to collect and  report quality data in conformance with the standards. Therefore, it is of  vital importance that OMB and Treasury provide federal agencies with  timely information and support so that they are in a position to effectively  implement these standards. We provided OMB and Treasury with input  on identified challenges related to the data element definitions and draft  technical schema to help ensure these challenges are addressed as  implementation progresses. Moreover, as agencies work through the 8- step implementation process, it will be important for OMB and Treasury to  provide them with finalized technical guidance that can serve as a  foundation for developing the necessary systems and processes for  agency implementation. If guidance is not timed to coincide with  agencies’ expected milestones for key steps in the implementation  process, agencies could incur additional costs as they revise  implementation plans to align with later versions of the guidance or could  be forced to delay implementation.

section_title: Recommendations for Executive Action
paragraphs: 1.  To help ensure that agencies report consistent and comparable data  on federal spending, we recommend that the Director of OMB, in  collaboration with the Secretary of the Treasury, provide agencies  with additional guidance to address potential clarity, consistency, or  quality issues with the definitions for specific data elements including  Award Description and Primary Place of Performance and that they  clearly document and communicate these actions to agencies  providing this data as well as to end-users.  2.  To ensure that federal agencies are able to meet their reporting  requirements and timelines, we recommend that the Director of OMB,  in collaboration with the Secretary of the Treasury, take steps to align  the release of finalized technical guidance, including the DATA Act  schema and broker, to the implementation time frames specified in  the DATA Act Implementation Playbook.

section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Director of OMB, the Secretaries  of the Treasury, HHS and USDA, and the Chief Executive Officer of  CNCS for review and comment. Both OMB and Treasury submitted  written comments, which provided additional clarifying information related  to our recommendations. OMB’s and Treasury’s written comments are  discussed below and reproduced in appendixes IV and V respectively. In  addition, OMB, Treasury, CNCS, and HHS provided technical comments,  which we incorporated as appropriate, and USDA had no comments.

In his written response, the OMB Controller generally concurred with our  first recommendation to provide agencies with additional guidance to  address potential clarity, consistency, or quality issues with data element  definitions. However, in the discussion of OMB’s efforts to date to expand  and improve federal spending transparency, the OMB Controller  distinguished between the 11 data elements that were standardized in  May 2015 and the remaining 46 data elements that were issued in August  2015. OMB interpreted the DATA Act requirement to standardize data  elements as only applying to the 11 data elements, and indicated that the  remaining 46 elements were standardized pursuant to the overarching  policy goal of improving the consistency of federal spending data on  USAspending.gov. OMB stated that the additional 46 data elements  provided an opportunity to increase comparability and data quality.

However, both the statutory language and the purposes of the DATA Act  support the interpretation that OMB and Treasury were required to  establish data standards for award and awardee information in addition to  account level information. The DATA Act states that the financial data  standards OMB and Treasury are required to establish are to include  financial and payment information required to be reported by federal  agencies and entities receiving federal funds. Such information reported  by entities receiving federal funds is information on awards and  awardees, not account-level financial data. The act further provides that  the data standards are to include, to the extent reasonable and practical,  unique identifiers for federal awards and entities receiving federal  awards. However, OMB does not interpret Award Identification Number  and Awardee/Recipient Unique Identifier to be among those data  elements they are required to standardize pursuant to the DATA Act.  Lastly, OMB’s interpretation is inconsistent with Congress’s intent when it  passed the DATA Act. As described in the legislative history of the act,  Congress sought to address the known data quality issues with award  and awardee information that had been reported under FFATA. To  accomplish this, data standards for those elements were necessary.  Without data standards for award and awardee information, the  inconsistent and non-comparable reporting under FFATA that Congress  sought to remedy through the DATA Act would continue. For these  reasons, we conclude that the requirement in the DATA Act to establish  data standards applies not only to account-level information, but also to  award and awardee information. This is an important distinction for  ensuring that federal agencies are held appropriately accountable for the  completeness, quality, and accuracy of the spending data to be reported  in the years to come.

In addition to responding to the recommendations made in this report,  OMB also addressed the recommendation made in our July 2015  testimony which called on OMB to accelerate efforts to determine how  best to merge DATA Act purposes and requirements with requirements  under the GPRA Modernization Act of 2010 (GPRAMA) to produce a  federal program inventory. In response to this recommendation, the  OMB Controller noted that OMB promulgated guidance in OMB Circular  A-11, Sections 82 and 83, requiring agencies to start submitting object  class and program activity information from their accounting systems to  OMB. We recognize that requiring agencies to submit data on object  class and program activity may be a step toward meeting the requirement  of the DATA Act to report this information and may contribute toward the  broader effort of developing a federal program inventory as required by  GPRAMA. However, much still remains to be done in order to produce  such an inventory. We continue to believe, as we previously  recommended, that OMB should accelerate those efforts and we will  continue to monitor progress in meeting this statutory requirement.

Regarding our recommendation to align the release of finalized technical  guidance to the implementation timelines specified in the DATA Act  Implementation Playbook, OMB deferred matters of technical  operationalization to Treasury, which has program responsibility for  technical implementation.

In their written response, Treasury officials deferred our first  recommendation to provide agencies with additional guidance to address  potential clarity, consistency, or quality issues with data element  definitions to OMB. Regarding our second recommendation to align the  release of finalized technical guidance to the implementation timelines  specified in the DATA Act Implementation Playbook, Treasury officials  generally concurred with our recommendation, noting that they recognize  the importance of providing agencies with timely technical guidance and  reporting submission specifications.

We are sending copies of this report to the heads of the Departments of  Agriculture, Health and Human Services, Treasury, OMB, and the  Corporation for National and Community Service, as well as interested  congressional committees and other interested parties. This report will  also be available at no charge on the GAO website at http://www.gao.gov.

If you or your staff has any questions about this report, please contact me  at (202) 512-6806 or sagerm@gao.gov . Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of our report. Key contributors to this report are listed in appendix VI.

section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report (1) identifies steps taken by the Office of Management and  Budget (OMB) and the Department of Treasury (Treasury) to establish  government-wide data element definitions and the extent to which those  definitions are consistent with leading practices or face challenges that  could affect data quality; (2) reviews efforts by OMB and Treasury to  provide agencies with technical implementation guidance to standardize  how data are collected and reported and related challenges; and (3)  examines the status of selected federal agencies’ progress in meeting  DATA Act requirements. This review is a part of an ongoing effort to  provide interim reports on the progress being made in the implementation  of the DATA Act, while also meeting our audit reporting requirements  mandated by the act.

For the first objective, we reviewed our past work that raised concerns  about the quality of federal spending data on USAspending.gov to inform  our review of OMB’s and Treasury’s efforts to establish data standards.  We analyzed the definitions of the 57 data elements issued May 8, 2015  through August 31, 2015, and assessed the extent to which the data  definitions are consistent with DATA Act requirements and leading  practices from standards set by the International Organization for  Standardization (ISO).

To assess the extent to which the data standards are consistent with ISO  standards, we had two analysts independently rate each of the 57 data  element definitions against all 13 ISO leading practices and determine  whether the data element (1) met the ISO leading practice, (2) did not  meet the ISO leading practice, (3) partially met the ISO leading practice,  or (4) whether the ISO leading practice was not applicable to the  particular data element definition. When the two raters independently  came to the same rating for a particular leading practice and data element  definition, the raters were considered to be in concurrence and the  agreed upon rating was carried forward as the assessment of record.  After the first round of assessments, the initial raters were in concurrence  on 630 of 741 necessary assessments. When the two raters  independently came to different ratings for a particular leading practice  and data element definition, a third rater independently assessed those  data element definitions and leading practices to attempt to reach  concurrence. This was necessary in 111 cases. When the third rater  independently came to the same rating as one of the initial two raters,  that rating was carried forward as the assessment of record. After this  second round of assessments, the raters were in concurrence on 727 of  741 necessary assessments. When the third rater came to a different  rating as both of the initial two raters for a particular leading practice and  data element definition, the three raters met to discuss their application of  the leading practice to the data element definition and come to consensus  on a final assessment of record. After these discussions, the raters were  in concurrence on 741 of 741 necessary assessments.

For data element definitions related to federal budget terms, we  supplemented our analysis with a legal review to ensure assessments  were both accurate and complete. For purposes of reporting, when the  final assessment of record was that a given data element definition met or  partially met the ISO leading practice or that the ISO leading practice was  not applicable, the data element definition was considered to adhere to  the given leading practice. For the purposes of aggregating our  assessments, we considered a “partial” response to be a “yes” because  the ISO standards represented leading practices and not firm  requirements for OMB and Treasury to follow. Therefore, we erred on the  side of giving the agencies credit for the contents of their definitions  meeting parts of the leading practice. When the assessment of record  was “no” the data element definition was considered as not adhering to  the given leading practice.

For the second objective assessing OMB’s and Treasury’s development  of a technical schema that specifies the format, structure, tagging, and  transmission of each data element to allow consistency and  comparability, we consulted the U.S. Digital Services Playbook and we  reviewed and analyzed differences between version 0.2, version 0.5, and  version 0.6 of the schema. We reviewed applicable agency guidance  and documentation related to the data standards and technical schema  on OMB’s and Treasury’s websites. We also interviewed knowledgeable  agency officials about their standards-setting and technical schema  development processes.

For the third objective, we selected three agencies for review—the  Department of Health and Human Services, the Department of  Agriculture, and the Corporation for National and Community Service.  Using a three-step selection process, we looked for agencies that met  varying conditions: (1) compliance with requirements for federal financial  management systems; (2) representation across multiple lines of  business—grants, loans, and contracts; and (3) status as a Federal  Shared Service Provider for financial management. Table 4 shows each  selected agency in relation to these criteria.

Although the results from our review of these three agencies are not  generalizable to all agencies, they are designed to illustrate a range of  conditions under which agencies are implementing the act.

We assessed whether the selected agencies submitted their  implementation plans and identified a senior accountable official (SAO) to  report on progress. We also reviewed the implementation plans and  related project plans and interviewed agency DATA Act team members  for their assessment of implementation progress, including what controls  are in place to ensure data quality, the challenges they have encountered  thus far, and the extent to which identified challenges could impede timely  and effective implementation.

We conducted this performance audit from May 2015 to January 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 on our audit objectives.

section_title: Appendix II: Status of GAO’s Open Recommendations and Matters for Congressional Consideration Related to the DATA Act
subsections: section_title: Recommendation/matter for congressional consideration 1. To improve the accuracy, completeness, and
paragraphs: timeliness of all data submissions to the Office of  Management and Budget’s (OMB)  USAspending.gov website, the Director of OMB  should revise guidance to federal agencies on  reporting federal awards to clarify (1) the  requirement that award titles describe the award’s  purpose; and (2) requirements for validating and  documenting agency awards data submitted by  federal agencies.

Implementation status  Closed—not implemented. Provisions of  the Digital Accountability and Transparency  Act of 2014 could address this  recommendation, but implementation will  take several years.

2.  To improve the accuracy, completeness, and  timeliness of all data submissions to OMB’s  USAspending.gov website, the Director of OMB  should include information on the city where work is  performed in OMB’s public reporting of the  completeness of agency data submissions.

Closed—not implemented. OMB no  longer uses the reporting mechanism  discussed in the recommendation.

Open. As a result of passage of the Digital  Accountability and Transparency Act  (DATA Act) in May 2014, OMB is working  with the Department of the Treasury  (Treasury) and other members of the  Government Accountability and  Transparency Board to develop a long-term  strategy to implement key transparency  reforms including government-wide data  standards. We will continue to monitor the  progress of their efforts to implement key  provisions of the act.  Open. OMB and Treasury are working to  implement the DATA Act, which includes  several provisions that could address our  recommendations once fully implemented. data submissions to the USAspending.gov  website, the Director of OMB, in collaboration with  Treasury’s Fiscal Service, should clarify guidance  on (1) agency responsibilities for reporting awards  funded by non-annual appropriations; (2) the  applicability of USAspending.gov reporting  requirements to non-classified awards associated  with intelligence operations; (3) the requirement  that award titles describe the award’s purpose  (consistent with our prior recommendation); and  (4) agency maintenance of authoritative records  adequate to verify the accuracy of required data  reported for use by USAspending.gov.

section_title: Report
paragraphs: Open. As part of their DATA Act  implementation efforts, OMB and Treasury  have outlined a process for agencies to  identify authoritative systems to validate  agency spending information. In addition,  the inspector general community is working  on standard audit methodologies to verify  the accuracy and completeness of agency  reporting. Implementation of these efforts is  planned to begin in fiscal year 2016.  Open. In commenting on a draft of this  statement in July 2015, OMB staff stated  that they neither agreed nor disagreed with  this recommendation. Testifying before two  subcommittees of the House Oversight and  Government Reform Committee on July 29,  2015, OMB’s Acting Deputy Director for  Management and Controller stated that the  agency planned to address the issue of  identifying “programs” for the purposes of  DATA Act reporting but that such efforts  would likely not start until sometime in fiscal  year 2016, and would not be completed until  after May 2017.  Open. In an August 31, 2015, whitepaper  published on their DATA Act collaboration  website, OMB and Treasury stated their  intent to address this recommendation by  working to establish in fiscal year 2016 a  formal, long-term governance process and  structure for future data standards  maintenance. This governance structure  would be the forum to review  recommendations for new data elements to  be reported to USAspending.gov and for  additional data standards to be adopted  moving forward.  Open. In commenting on a draft of the  statement in July 2015, OMB staff stated  that they neither agreed nor disagreed with  this recommendation. addressed as implementation efforts continue, the  Director of OMB, in collaboration with the  Secretary of the Treasury, should build on existing  efforts and put in place policies and procedures to  foster ongoing and effective two-way dialogue with  stakeholders including timely and substantive  responses to feedback received on the Federal  Spending Transparency GitHub website.

Recommendation/matter for congressional  consideration  1.  To capitalize on the opportunity created by the  DATA Act, the Secretary of the Treasury should  reconsider whether certain assets—especially  information and documentation such as  memoranda of understanding (MOUs) that would  help transfer the knowledge gained through the  operation of the Recovery Operations Center— could be worth transferring to the Do Not Pay  Center Business Center to assist in its mission to  reduce improper payments. Additionally, the  Secretary should document the decision on  whether Treasury transfers additional information  and documentation and what factors were  considered in this decision.

Open. Treasury concurred with our  recommendation that it should consider  additional knowledge transfers from the  Recovery Operations Center to assist in the  Do Not Pay Center Business Center’s  mission to reduce improper payments and  will document its rationale and final decision  in this regard..

Matter for Congressional Consideration:  1.  To help preserve a proven resource supporting  the oversight community’s analytic capabilities,  Congress may wish to consider directing the  Council of the Inspectors General on Integrity and  Efficiency (CIGIE) to develop a legislative  proposal to reconstitute the essential capabilities  of the Recovery Operations Center to help ensure  federal spending accountability. The proposal  should identify a range of options at varying  scales for the cost of analytic tools, personnel,  and necessary funding, as well as any additional  authority CIGIE may need to ensure such  enduring, robust analytical and investigative  capability for the oversight community.

Open.

section_title: Appendix III: Definitions of Issued Data Elements
paragraphs: This appendix lists the data elements and their definitions broken out by  type, as issued by the Office of Management and Budget (OMB) and the  Department of Treasury (Treasury) on May 8, 2015 and August 31, 2015.

Account Level Data Standards: These data elements describe the appropriations accounts from which agencies fund Federal  awards.

Data Definition  The basic unit of an appropriation generally reflecting each unnumbered paragraph in an  appropriation act. An appropriation account typically encompasses a number of activities or  projects and may be subject to restrictions or conditions applicable to only the account, the  appropriation act, titles within an appropriation act, other appropriation acts, or the Government as  a whole.  An appropriations account is represented by a TAFS created by Treasury in consultation with OMB  (defined in OMB Circular A-11).

A provision of law (not necessarily in an appropriations act) authorizing an account to incur  obligations and to make outlays for a given purpose. Usually, but not always, an appropriation  provides budget authority (defined in OMB Circular A-11).

Categories in a classification system that presents obligations by the items or services purchased  by the Federal Government. Each specific object class is defined in OMB Circular A-11 § 83.6  (defined in OMB Circular A-11).

Obligation means a legally binding agreement that will result in outlays, immediately or in the  future. When you place an order, sign a contract, award a grant, purchase a service, or take other  actions that require the Government to make payments to the public or from one Government  account to another, you incur an obligation. It is a violation of the Antideficiency Act (31 U.S.C. §  1341(a)) to involve the Federal Government in a contract or obligation for payment of money  before an appropriation is made, unless authorized by law. This means you cannot incur  obligations in a vacuum; you incur an obligation against budget authority in a Treasury account that  belongs to your agency. It is a violation of the Antideficiency Act to incur an obligation in an amount  greater than the amount available in the Treasury account that is available. This means that the  account must have budget authority sufficient to cover the total of such obligations at the time the  obligation is incurred. In addition, the obligation you incur must conform to other applicable  provisions of law, and you must be able to support the amounts reported by the documentary  evidence required by 31 U.S.C. § 1501. Moreover, you are required to maintain certifications and  records showing that the amounts have been obligated (31 U.S.C. § 1108). Additional detail is  provided in Circular A‐11.

New borrowing authority, contract authority, and spending authority from offsetting collections  provided by Congress in an appropriations act or other legislation, or unobligated balances of  budgetary resources made available in previous legislation, to incur obligations and to make  outlays (defined in OMB Circular A-11).

Payments made to liquidate an obligation (other than the repayment of debt principal or other  disbursements that are “means of financing” transactions). Outlays generally are equal to cash  disbursements but also are recorded for cash-equivalent transactions, such as the issuance of  debentures to pay insurance claims, and in a few cases are recorded on an accrual basis such as  interest on public issues of the public debt. Outlays are the measure of Government spending  (defined in OMB Circular A-11).

A specific activity or project as listed in the program and financing schedules of the annual budget  of the United States Government (defined in OMB Circular A-11).

Data Definition  Treasury Account Symbol: The account identification codes assigned by the Department of the  Treasury to individual appropriation, receipt, or other fund accounts. All financial transactions of the  Federal Government are classified by TAS for reporting to the Department of the Treasury and the  Office of Management and Budget (defined in OMB Circular A-11).  Treasury Appropriation Fund Symbol: The components of a Treasury Account Symbol – allocation  agency, agency, main account, period of availability and availability type – that directly correspond  to an appropriations account established by Congress (defined in OMB Circular A-11).

Unobligated balance means the cumulative amount of budget authority that remains available for  obligation under law in unexpired accounts at a point in time. The term “expired balances available  for adjustment only” refers to unobligated amounts in expired accounts. Additional detail is  provided in Circular A‐11.
subsections: section_title: Award Characteristic Data Standards: These data elements describe characteristics that apply to specific financial assistance and/or procurement awards Data Element Action Date
paragraphs: Data Definition  The date the action being reported was issued / signed by the Government or a binding  agreement was reached.

A brief description of the purpose of the award.

Award Identification (ID) Number  The unique identifier of the specific award being reported, i.e. Federal Award Identification  Number (FAIN) for financial assistance and Procurement Instrument Identifier (PIID) for  procurement.

The identifier of an action being reported that indicates the specific subsequent change to the  initial award.

Description (and corresponding code) that provides information to distinguish type of contract,  grant, or loan and provides the user with more granularity into the method of delivery of the  outcomes.

A collection of indicators of different types of recipients based on socio-economic status and  organization / business areas.

The number assigned to a Federal area of work in the Catalog of Federal Domestic Assistance.

The title of the area of work under which the Federal award was funded in the Catalog of Federal  Domestic Assistance.

The identifier that represents the North American Industrial Classification System Code assigned  to the solicitation and resulting award identifying the industry in which the contract requirements  are normally performed.

The title associated with the NAICS Code.

Data Definition  For procurement, the date on which, for the award referred to by the action being reported, no  additional orders referring to it may be placed. This date applies only to procurement indefinite  delivery vehicles (such as indefinite delivery contracts or blanket purchase agreements).  Administrative actions related to this award may continue to occur after this date. The period of  performance end dates for procurement orders issued under the indefinite delivery vehicle may  extend beyond this date.

The identifier of the procurement award under which the specific award is issued, such as a  Federal Supply Schedule. This data element currently applies to procurement actions only.

The current date on which, for the award referred to by the action being reported, awardee effort  completes or the award is otherwise ended. Administrative actions related to this award may  continue to occur after this date. This date does not apply to procurement indefinite delivery  vehicles under which definitive orders may be awarded.

For procurement, the date on which, for the award referred to by the action being reported if all  potential pre-determined or pre-negotiated options were exercised, awardee effort is completed or  the award is otherwise ended. Administrative actions related to this award may continue to occur  after this date. This date does not apply to procurement indefinite delivery vehicles under which  definitive orders may be awarded.

Period of Performance Start Date  The date on which, for the award referred to by the action being reported, awardee effort begins  or the award is otherwise effective.

The address where the predominant performance of the award will be accomplished. The address  is made up of six components: Address Lines 1 and 2, City, County, State Code, and ZIP+4 or  Postal Code.

U.S. congressional district where the predominant performance of the award will be  accomplished. This data element will be derived from the Primary Place of Performance Address.

Country code where the predominant performance of the award will be accomplished.

Name of the country represented by the country code where the predominant performance of the  award will be accomplished.

section_title: Record Type Award Amount Data Standards: These data elements describe characteristics that apply to amount information for financial assistance and/or procurement awards. Data Element Amount of Award
paragraphs: Code indicating whether an action is an individual transaction or aggregated.

Data Definition  The cumulative amount obligated by the Federal Government for an award, which is calculated by  USAspending.gov or a successor site.  For procurement and financial assistance awards except loans, this is the sum of Federal Action  Obligations.  For loans or loan guarantees, this is the Original Subsidy Cost.

For procurement, the total amount obligated to date on a contract, including the base and  exercised options.

Amount of Federal Government’s obligation, de-obligation, or liability, in dollars, for an award  transaction.

For financial assistance, the amount of the award funded by a non-Federal source(s), in dollars.  Program Income (as defined in 2 C.F.R. § 200.80) is not included until such time that Program  Income is generated and credited to the agreement.

For procurement, the total amount that could be obligated on a contract, if the base and all options  are exercised.

section_title: Awardee and Recipient Entity Data Standards: These data elements describe the recipients/awardees of Federal funds Data Element Awardee/Recipient Legal Entity Name
paragraphs: Data Definition  The name of the awardee or recipient that relates to the unique identifier. For U.S. based  companies, this name is what the business ordinarily files in formation documents with individual  states (when required).

The unique identification number for an awardee or recipient. Currently the identifier is the 9-digit  number assigned by Dun & Bradstreet referred to as the DUNS® number.

First Name: The first name of an individual identified as one of the five most highly compensated  “Executives.” “Executive” means officers, managing partners, or any other employees in  management positions.  Middle Initial: The middle initial of an individual identified as one of the five most highly  compensated “Executives.” “Executive” means officers, managing partners, or any other  employees in management positions.  Last Name: The last name of an individual identified as one of the five most highly compensated  “Executives.” “Executive” means officers, managing partners, or any other employees in  management positions.

The cash and noncash dollar value earned by the one of the five most highly compensated  “Executives” during the awardee’s preceding fiscal year and includes the following (for more  information see 17 C.F.R. § 229.402(c)(2)): salary and bonuses, awards of stock, stock options,  and stock appreciation rights, earnings for services under non-equity incentive plans, change in  pension value, above-market earnings on deferred compensation which is not tax qualified, and  other compensation.

The awardee or recipient’s legal business address where the office represented by the Unique  Entity Identifier (as registered in the System for Award Management) is located. In most cases,  this should match what the entity has filed with the State in its organizational documents, if  required. The address is made up of five components: Address Lines 1 and 2, City, State Code,  and ZIP+4 or Postal Code.

Legal Entity Congressional District  The congressional district in which the awardee or recipient is located. This is not a required data  element for non-U.S. addresses.

Code for the country in which the awardee or recipient is located, using the ISO 3166-1 Alpha-3  GENC Profile, and not the codes listed for those territories and possessions of the United States  already identified as “states.”

The name corresponding to the Country Code.

Ultimate Parent Legal Entity Name  The name of the ultimate parent of the awardee or recipient. Currently, the name is from the  global parent DUNS® number.

The unique identification number for the ultimate parent of an awardee or recipient. Currently the  identifier is the 9-digit number maintained by Dun & Bradstreet as the global parent DUNS®  number.

section_title: Awarding Entity Data Standards: These data elements describe the characteristics of the entity that made the award. Data Element Awarding Agency Code
paragraphs: Data Definition  A department or establishment of the Government as used in the Treasury Account Fund  Symbol (TAFS).

The name associated with a department or establishment of the Government as used in the  Treasury Account Fund Symbol (TAFS).

Identifier of the level n organization that awarded, executed or is otherwise responsible for the  transaction.

Name of the level n organization that awarded, executed or is otherwise responsible for the  transaction.

Identifier of the level 2 organization that awarded, executed or is otherwise responsible for the  transaction.

Name of the level 2 organization that awarded, executed or is otherwise responsible for the  transaction.

section_title: Funding Entity Data Standards: These data elements describe the characteristics of the entity that provided the funding for an award. Data Element Funding Agency Code
paragraphs: Data Definition  The 3-digit CGAC agency code of the department or establishment of the Government that  provided the preponderance of the funds for an award and/or individual transactions related to  an award.

Name of the department or establishment of the Government that provided the preponderance  of the funds for an award and/or individual transactions related to an award.

Identifier of the level n organization that provided the preponderance of the funds obligated by  this transaction.

Name of the level n organization that provided the preponderance of the funds obligated by this  transaction.

Identifier of the level 2 organization that provided the preponderance of the funds obligated by  this transaction.

Name of the level 2 organization that provided the preponderance of the funds obligated by this  transaction.

section_title: Appendix IV: Comments from the Office of Management and Budget

section_title: Appendix V: Comments from the Department of Treasury

section_title: Appendix VI: Staff Acknowledgments
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, J. Christopher Mihm (Managing  Director), Peter Del Toro (Assistant Director), Kathleen Drennan (analyst- in-charge), Shirley Hwang, Jason Lyuke, Kiran Sreepada and David  Watsula made major contributions to this report. Other key contributors  include Shari Brewster; Mark Canter; Jenny Chanley; Robert Gebhart;  Charles Jones; Lauren Kirkpatrick; Michael LaForge; Donna Miller; Laura  Pacheco; Carl Ramirez; Paula Rascona; Andrew J. Stephens; James  Sweetman, Jr.; and Carroll Warfield, Jr. Additional members of GAO’s  DATA Act Working Group also contributed to the development of this  report.


Question-summary annotations: questions: question: What did the OMB and Treasury have to do per the DATA Act?
answer: As required by the Digital Accountability and Transparency Act of 2014 (DATA Act), the Office of Management and Budget (OMB) and the Department of the Treasury (Treasury) issued definitions for 57 federal spending data elements.
child_questions: question: How many definitions met leading international standards?
answer: GAO found that most definitions adhered to leading practices derived from international standards for formulating data definitions. Specifically, 12 of the 57 definitions met all 13 leading practices and none met fewer than 9.

question: What was a negative aspect of the definitions that GAO found?
answer: However, GAO found several definitions that could lead to inconsistent reporting.
child_questions: question: What is an example of this?
answer: For example, as shown in the figure below, the Primary Place of Performance definitions’ inclusion of the word “predominant“ leaves much open to interpretation.

question: What's the risk of this flaw?
answer: Without more interpretive clarification, agencies run the risk of reporting data that cannot be aggregated government-wide.

questions: question: What has OMB and Treasury failed to do with GAO's concerns as of now?
answer: However, final technical guidance has not been issued, which could impede agency implementation. While OMB and Treasury have released interim versions of technical guidance, they have not yet released final guidance to provide a stable base for agency implementation.
child_questions: question: What are they currently developing?
answer: They also are developing an intermediary service (“broker”) to standardize and validate agency data submissions.

question: What did GAO's review of implementation plans find?
answer: GAO’s review of selected implementation plans found that agencies need the technical guidance and the intermediary service to be finalized before they can develop detailed agency-level plans.

question: What is the concern if the GAO guidance and implementation timelines are not aligned?
answer: If this guidance is not aligned with agency implementation timelines, agencies may delay taking key steps or need to revise existing plans once final technical guidance is released, thereby hindering their ability to meet DATA Act requirements and timelines.

questions: question: What did the DATA Act direct OMB and Treasury to do?
answer: The DATA Act directed OMB and Treasury to establish government-wide data standards by May 2015 to improve the transparency and quality of federal spending data.

question: What did the agencies need to begin doing by May 2017 and 2018?
answer: Agencies must begin reporting spending data in accordance with these standards by May 2017 and must publicly post spending data in machine-readable formats by May 2018.

question: What series of items will this report be a part of?
answer: Consistent with GAO’s mandate under the act, this report is part of a series of products that GAO will provide to the Congress as DATA Act implementation proceeds.