Signed into law on May 9, 2014, the DATA Act expanded on previous federal transparency legislation to link federal agency spending to federal program activities so that taxpayers and policymakers can more effectively track federal spending. The DATA Act requires government- wide reporting on a greater variety of federal funds as well as tracking of these funds at multiple points in the federal spending lifecycle. The act also calls for the federal government to set government-wide data standards, identify ways to reduce reporting burdens for grantees and contractors (Section 5 Pilot), and regularly review data quality to help improve the transparency and accountability of federal spending data. OMB and Treasury have taken significant steps toward implementing the act’s various requirements including standardizing data element definitions, issuing guidance to help agencies develop their implementation plans, and designing a pilot for developing recommendations to reduce recipient reporting burden. We have previously reported on these efforts and others and have identified a number of ongoing challenges that will need to be addressed in order to successfully meet the act’s requirements. Throughout our ongoing oversight of OMB’s and Treasury’s efforts to implement the act, we have coordinated closely with OMB and Treasury to provide timely feedback and have made a number of recommendations that, if addressed, could help ensure the full and effective implementation of the act. OMB and Treasury have made progress implementing 5 of our recommendations related to DATA Act implementation. However, additional effort is needed to address 11 previous GAO recommendations that remain open. See appendix II for a list of our previous recommendations relating to the DATA Act and their implementation status. OMB and Treasury are developing a governance structure, but more work will be needed to ensure that this structure is consistent with key practices for developing and maintaining the integrity of data standards over time. In July 2015, we reported that OMB and Treasury took initial steps to develop organizational structures for project governance but had not yet established a formal framework for providing data governance throughout the lifecycle of developing and implementing standards. Such a framework is key for ensuring that the integrity of data standards is maintained over time. Accordingly, we recommended that OMB and Treasury establish a clear set of policies and procedures for developing and maintaining data standards that are consistent with leading practices. OMB and Treasury generally agreed with our recommendation and, in response, engaged a contractor to interview key stakeholders and develop a set of potential next steps. The first of these steps was to establish a new Data Standards Committee that will be responsible for maintaining established standards and developing new data elements or data definitions that could affect more than one functional community (e.g., financial management, financial assistance, and procurement). According to OMB staff, the Data Standards Committee held its inaugural meeting on September 15, 2016, and will meet on a monthly basis. The committee has also drafted a charter that will delineate the scope of the committee’s work, as well as the composition and responsibilities of its members. According to OMB staff, members include representatives from a range of federal communities including the grants, procurement, financial management and human resources communities, as well as representatives of several interagency councils including the Chief Information Officers Council and the Performance Improvement Council. OMB staff told us that the committee will focus on clarifying existing data standard definitions, including the definition of predominant place of performance, and identifying new standards that may be needed going forward. In October 2016, according to OMB staff, the charter was under review by the DATA Act Executive Steering Committee. Several data governance models exist that could inform OMB’s and Treasury’s efforts to ensure the integrity of the data standards over time. These models define data governance as an institutionalized system of decision rights and accountabilities for planning, overseeing, and controlling data management. Many of these models promote a common set of key practices that include establishing clear policies and procedures for developing, managing, and enforcing data standards. A common set of key practices endorsed by standards setting organizations recommend that data governance structures should include the key practices shown in the text box below. We have shared these key practices with OMB and Treasury. Key Practices for Data Governance Structures i. Developing and approving data standards. ii. Managing, controlling, monitoring, and enforcing consistent application of data standards. iii. Making decisions about changes to existing data standards and resolving conflicts related to the application of data standards. iv. Obtaining input from stakeholders and involving them in key decisions, as appropriate. v. Delineating roles and responsibilities for decision-making and accountability, including roles and responsibilities for stakeholder input on key decisions. OMB and Treasury have not yet institutionalized and clearly documented policies and procedures that are consistent with these key practices. For example, processes have not been developed to both approve new standards and ensure that already established standards are consistently applied and enforced across the federal government. One reason why having a robust, institutionalized data governance structure is important is to provide consistent data management during times of change and transition. The transition to a new administration presents one such situation. We have previously reported that, given the importance of continuity when implementing complex, government-wide initiatives, the potential for gaps in leadership that can occur as administrations change can impact the effectiveness and efficiency of such efforts, potentially resulting in delays and missed deadlines. Such transitions may disrupt the momentum for meeting implementation timeframes or cause the government to fail to continue to build on previous accomplishments. The absence of a robust and institutionalized data governance structure presents additional potential risks regarding the integrity of data standards over time and the ability of agencies to meet their statutory timelines in the event that priorities shift with the incoming administration or momentum is lost. In June 2016, OMB directed the 24 CFO Act agencies to update their initial DATA Act implementation plans that they submitted in response to OMB’s May 2015 request. Each agency was to (1) update its timeline and milestones and explain the agency’s progress to date and the remaining actions it would take to implement the act in accordance with the suggested steps in Treasury’s DATA Act Implementation Playbook (Version 2.0) (Playbook 2.0), (2) report costs to date and estimated total future costs, and (3) explain any new challenges and mitigation strategies. In reviewing the 24 CFO Act agencies’ implementation plan updates that we obtained from the agencies, we found the following: Each of the 24 CFO Act agencies’ updates included timelines and milestones and most of the updates included most of the OMB required information. For example, most of the 24 CFO Act agencies included remaining actions the agencies would take to implement the suggested steps in Playbook 2.0. Some of the CFO Act agencies did not include information about some of the remaining actions to implement the suggested steps in Playbook 2.0. For example, 5 of the 24 CFO Act agencies did not include information about testing for completeness and accuracy of data elements submitted to Treasury, 11 CFO Act agencies did not include information about workflows for addressing validation errors and revisions needed to agency data submissions, and 13 CFO Act agencies did not include information about testing linkages of program and financial data or possible interim solutions to link such data, if needed. Without such information in agencies’ updates, it may be more difficult for OMB and Treasury to determine where to target their monitoring and assistance efforts to help ensure the DATA Act is successfully implemented. Our review of the CFO Act agencies’ August 2016 implementation plan updates found that 21 of the 24 CFO Act agencies reported costs to date and future estimated costs to implement the DATA Act reporting requirements. One agency reported future estimated costs, but did not report costs to date. Two agencies did not provide any cost estimates. Total cumulative and future estimated costs for full DATA Act implementation that was reported by 22 CFO Act agencies in their implementation plan updates ranged from approximately $1.0 million to $59.1 million, for a total of about $202.4 million. This total estimated cost reported by CFO Act agencies to implement the DATA Act includes costs for systems integration and modernization. It is important to note that the estimated total costs reported by CFO Act agencies to implement the DATA Act requirements is relatively small when compared to the almost $81 billion spent on information technology by the CFO Act agencies in fiscal year 2016 alone. See appendix III for more details about the information that OMB required CFO Act agencies to include in their implementation plan updates, remaining actions to implement the suggested steps in Playbook 2.0, and the number of CFO Act agencies that included the information. In our July 2016 report, we reported on challenges agencies included in their initial implementation plans. The implementation plan updates indicate that 19 of the 24 CFO Act agencies continue to face challenges in their efforts to implement the DATA Act. Based on our review of the 24 CFO Act agency implementation plan updates, we identified four overarching categories of challenges reported by agencies that may impede their ability to effectively and efficiently implement the DATA Act: systems integration issues, lack of resources, evolving and complex reporting requirements, and inadequate guidance. See table 4 in appendix III, which describes the categories of challenges and the number of CFO Act agencies reporting challenges in each category. Some of the challenges reported by the CFO Act agencies in their updates include the following: Systems integration. Nineteen of the 24 CFO Act agencies reported challenges related to systems integration, which include concerns with systems limitations, modernization efforts, and timing. For example, one agency reported that validation presents challenges because its financial systems are not properly integrated with procurement and grant systems. Similarly, the agency reported that several of its components are undergoing grant, procurement, or financial system improvements that coincide with implementing the DATA Act, which could pose a risk to timely DATA Act implementation if the improvements are delayed. Another agency reported that, for one of its legacy systems, obtaining the unique identifier to generate award financial data will likely be a manual process.