At the top of this framework is an  Executive Steering Committee—consisting of OMB’s Controller and  Treasury’s Fiscal Assistant Secretary. OMB and Treasury Have Not Fully Documented Processes and Controls for Their Review of Agency DATA Act Implementation Plans

Although OMB directed federal agencies to submit implementation plans  (through issuance of OMB Memorandum M-15-12), as of July 2016, OMB  had not determined the complete population of agencies that are required  to report spending data under the DATA Act and submit implementation  plans to OMB. However, on June 15, 2016, OMB requested that the 24 CFO Act  agencies submit updates to key components of their implementation  plans by August 12, 2016. Not knowing the complete population of agencies that are required to  report under the DATA Act and not having fully documented processes  and controls for reviewing and using agency DATA Act implementation  plans increase the risk that the purposes and benefits of the DATA Act  may not be fully achieved and could result in incomplete spending data  being reported. Further, without updated implementation plans, including  revised cost estimates and project plans to reflect the impacts of new  technical requirements and guidance, from all agencies that are required  by the DATA Act to report spending data, OMB and Treasury may not  have the information needed to assist them in properly monitoring  resource needs and agencies’ progress in implementing new  requirements government-wide. In addition, OMB staff  stated that the agencies’ general counsels could work with OMB to help  agencies make these determinations. OMB staff noted that the purpose for directing agencies to submit  implementation plans was to use the implementation plan cost estimates  to assist them in formulating the fiscal year 2017 budget. OMB Requested Updated Agency Implementation Plans, but Only from CFO Act Agencies

OMB and Treasury staff initially told us that they were not going to require  or request that agencies submit updated implementation plans for review  although new requirements and information were subsequently released,  such as additional guidance on DATA Act reporting that OMB issued in  May 2016. Agency DATA Act Implementation Plans Were Not Fully in Accordance with OMB and Treasury Guidance

None of the 42 implementation plans we received and reviewed  contained all 51 plan elements described in OMB and Treasury guidance. Based  on OMB’s DATA Act Implementation Plans Guidance and Treasury’s  Data Act Implementation Playbook (Version 1.0), we identified 51 plan  elements to be reported within these four categories. For  example, many agencies’ cost estimates were incomplete as the  agencies did not provide assumptions for their estimates; identify  resource requirements, such as full-time and part-time employees needed  to assist implementation; or differentiate between their business process  costs and technology costs. To help ensure effective implementation of the DATA Act by the agencies  and facilitate the further establishment of overall government-wide  governance, we recommend that the Director of OMB, in collaboration  with the Secretary of the Treasury, take the following three actions related  to monitoring and use of agency implementation plans: establish documented policies and procedures for the periodic review  and use of agency implementation plans to facilitate and monitor  agency progress against the plans;  request that non-CFO Act agencies required to report federal  spending data under the DATA Act submit updated implementation  plans, including updated timelines and milestones, cost estimates,  and risks, to address new technical requirements; and assess whether information or plan elements missing from agency  implementation plans are needed and ensure that all key  implementation plan elements are included in updated implementation  plans. The objectives of this review  were to determine (1) the extent to which the Office of Management and  Budget (OMB) and the Department of the Treasury (Treasury) have  processes and controls in place to review agencies’ implementation  plans, monitor agencies’ progress, provide feedback to the agencies, and  respond to challenges reported by the agencies; (2) the extent to which  selected federal agencies’ DATA Act implementation plans were prepared  in accordance with OMB and Treasury guidance; and (3) challenges  agencies have reported that may affect their ability to implement the  DATA Act and mitigating strategies they have reported to address such  challenges. Monitoring and developing guidance. Electronic Government: Implementation of the Federal Funding  Accountability and Transparency Act of 2006.
Why GAO Did This Study

The federal government annually spends over $3.7 trillion on its programs and operations. To help increase the transparency of online spending information, the DATA Act requires agencies to begin reporting spending data by May 2017, using new data standards established by OMB and Treasury. In May 2015, OMB directed federal agencies to submit DATA Act implementation plans by September 2015. OMB and Treasury subsequently issued guidance to agencies to help them develop plans.
This report is part of a series of products that GAO will provide to Congress in response to a statutory provision to review DATA Act implementation. This report discusses OMB's and Treasury's efforts to facilitate implementation of the DATA Act and the consistency of agency implementation plans with OMB and Treasury guidance, among other things. GAO evaluated OMB's and Treasury's processes against project management and internal control criteria, assessed selected agency implementation plans against OMB and Treasury guidance, and interviewed staff and officials at OMB and Treasury.

What GAO Found

The Office of Management and Budget (OMB) and the Department of the Treasury (Treasury) have not designed and implemented controls or fully documented processes related to the review and use of agency implementation plans for the Digital Accountability and Transparency Act of 2014 (DATA Act). These controls and processes are to be used for reviewing agencies' implementation plans and monitoring agencies' progress against these plans. In addition, as of July 2016, OMB had not determined the complete population of agencies that are required to report spending data under the DATA Act and submit implementation plans to OMB. OMB staff stated that their purpose for directing agencies to submit implementation plans was to use the implementation cost estimates to assist them in formulating the fiscal year 2017 budget, while Treasury officials stated that the purpose of their review of the plans was to facilitate discussions with the agencies. In addition, OMB and Treasury staff initially informed GAO that they were not going to request that agencies submit updated implementation plans that considered new technical requirements and guidance that was released on April 29, 2016. However, on June 15, 2016, OMB requested updated implementation plans by August 12, 2016, but only from Chief Financial Officers (CFO) Act agencies. Lacking fully documented controls and processes as well as a complete population of agencies that are required to report under the DATA Act increases the risk that the purposes and benefits of the DATA Act may not be fully achieved, and could result in incomplete spending data being reported. Further, without updated implementation plans, including revised timelines and milestones, cost estimates, and risks that reflect the impacts of new technical requirements and guidance, from all agencies that are required to report under the DATA Act, OMB and Treasury may not have the information needed to assist them in properly monitoring resource needs and agencies' progress in implementing new requirements government-wide.
Based on OMB and Treasury guidance, GAO identified 51 plan elements in four separate categories—timeline, cost estimate, narrative, and project plan—to be included in agency implementation plans. None of the 42 implementation plans GAO received and reviewed contained all 51 plan elements described in OMB and Treasury guidance. For example, many agencies' cost estimates did not provide all the elements for cost estimates, including total work years and a list of assumptions, or did not differentiate between their business process costs and technology costs.

What GAO Recommends

GAO recommends that OMB, in collaboration with Treasury, determine the population of agencies required to report under the DATA Act, establish fully documented controls and processes to help ensure agencies' effective implementation of the DATA Act, and request updated plans from non-CFO Act agencies. OMB generally concurred with the recommendations and Treasury deferred to OMB.