	Progress Made In Establishing Data Standards but More Complete and Timely Guidance Is Needed to Ensure Effective Implementation

		OMB and Treasury Issued Standardized Data Element Definitions for Reporting Federal Spending Data, but More Needs to Be Done to Ensure Consistent and Comparable Reporting

In our January 2016 report on data standards we noted that by the end of  August 2015 OMB and Treasury had issued a list of 57 standardized data  elements. We also raised concerns about OMB’s efforts to merge DATA Act  requirements with certain GPRAMA requirements. GPRAMA requires the  Office of Management and Budget (OMB) to make information available  about each federal program. Our prior work identified data quality  issues with certain data elements, such as Award Description, which  OMB and Treasury defined 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 this data element, citing the wide range of  information that agencies report as the description or purpose. Lack of Finalized Technical Guidance Could Impede Agency Implementation of DATA Act Requirements

OMB and Treasury issued initial guidance to federal agencies in May  2015 on meeting the reporting requirements of the Federal Funding  Accountability and Transparency Act of 2006 (FFATA), as amended by  the DATA Act, in accordance with the new data standards. Treasury has issued several iterative  versions of the technical schema that describes the standard format for  reporting data elements including their description, type, and length, but  has not made available a finalized schema that would provide agencies  with a stable base from which to develop data submission plans. OMB’s  and Treasury’s DATA Act Implementation Playbook outlines eight specific  steps and timelines for implementing the DATA Act at the agency level. In responding to a  draft of this statement, Treasury officials told us they provided final draft  technical guidance to agencies for comment. Agencies Reported Significant Challenges and Identified Mitigating Strategies for Implementing the DATA Act; Addressing Them Will be Key to Successful Implementation

OMB and Treasury have issued data standards and provided guidance  and feedback to federal agencies on their DATA Act implementation  plans. However, our ongoing work in this area indicates that challenges  remain and will need to be addressed to successfully implement the  DATA Act government-wide. Challenges Reported by Agencies in their DATA Act Implementation Plans

Based on our preliminary results from our ongoing review of agency  implementation plans, we identified seven overarching categories of  challenges reported by agencies to effectively and efficiently implement  the DATA Act. Figure 1 shows that  agencies reported challenges, most frequently in the following categories:  competing priorities, resources, and systems integration. Some agencies  noted concerns about the ability of their systems to obtain and easily  submit to Treasury all the data elements needed to implement the DATA  Act, including the requirement to establish a unique award ID. For example, one agency noted that  it will monitor and evaluate the release of DATA Act guidance as well as  data elements and technical schema in order to identify the effect on the  project. Agencies  reported working closely with internal and external stakeholders to  address these challenges as effectively as possible, but also reported that  additional support from OMB and Treasury is needed for successful  implementation of the DATA Act. OMB created a two-part pilot that  focused on two communities: federal grants and federal contracts  (procurement). For grants, OMB designated the Department of Health  and Human Services (HHS) to serve as its executing agent. On the  contracting side, OMB’s Office of Federal Procurement Policy (OFPP) is  responsible for leading the procurement portion working with the General  Services Administration’s 18F and others. Design of Grants Portion of the Section 5 Pilot Is On Track to Meet DATA Act Requirements and Partially Adheres to Leading Pilot Design Practices

As the executing agent for the grants portion of the pilot, HHS has  developed six “test models” that evaluate a variety of approaches to  potentially reduce grantee reporting burden, including the development of  a data repository for identifying common data elements and forms  intended to eliminate duplicative reporting on Consolidated Federal  Financial Reports. While valuable information, it does not clearly  convey how the procurement portion of the pilot would specifically  contribute to meeting the act’s requirement regarding diversity of  participants. In addition, we found that the design of the procurement portion of the  pilot did not reflect leading practices for effective pilot design which would  help OMB develop effective recommendations to simplify reporting for  contractors. We have requested  documentation of the steps OMB and Treasury have  taken to foster ongoing and effective two-way dialogue  with stakeholders including timely and substantive  responses to feedback.
Why GAO Did This Study

The DATA Act requires OMB and Treasury to establish government-wide data standards and requires federal agencies to begin reporting financial and payment data in accordance with these standards by May 2017. The act also requires OMB to establish a pilot program to develop recommendations for simplifying federal award reporting for grants and contracts. GAO has an ongoing body of work examining implementation of different aspects of the DATA Act.
This statement focuses on the following questions: (1) What efforts have been made to develop government-wide standards and associated technical guidance? (2) What implementation challenges and mitigation strategies have been reported by agencies? (3) How effective is OMB's design of the Section 5 Pilot to reduce recipient reporting burden? The statement also provides an update on OMB's and Treasury's efforts to address GAO's DATA Act recommendations.
This statement is primarily based on two GAO reports issued in 2016, as well as ongoing work examining agency DATA Act implementation plans. For its work examining agency implementation plans, GAO reviewed 42 plans to identify reported challenges and mitigation strategies that could affect agency progress toward meeting requirements under the act. GAO also interviewed OMB and Treasury staff to update the status of prior open recommendations pertaining to the act. Treasury had technical comments, which GAO incorporated as appropriate; OMB had none.

What GAO Found

The Office of Management and Budget (OMB) and the Department of the Treasury (Treasury) have taken some significant steps toward implementing the key provisions of the Digital Accountability and Transparency Act of 2014 (DATA Act); however, several challenges need to be addressed in order to successfully meet the act's requirements.
Data standards and technical schema. GAO reported in January 2016, that OMB and Treasury had issued standardized data element definitions for reporting federal spending, but the lack of key guidance has slowed the ability of agencies to operationalize the data standards. Specifically, OMB and Treasury had not yet released guidance to agencies regarding how some data elements should be reported in order to produce consistent and comparable data. For example, Award Description, defined as a brief description of the purpose of the award, led to different interpretations by agencies.
GAO also found that Treasury's technical guidance continues to evolve and lacks finality which may impede agency implementation. Treasury has issued several iterative versions of the technical schema that describes the standard format for reporting data elements. Each iteration results in revisions to the technical guidance which may adversely affect the timely implementation of the act. A finalized technical schema would provide agencies with a stable base from which to develop data submission plans and processes. According to Treasury officials, final draft guidance has been provided to agencies for comment.
Agency reported implementation challenges and mitigation strategies. GAO's ongoing review of required implementation plans submitted to OMB indicates that federal agencies have identified significant challenges in implementing the DATA Act including competing priorities, resources, systems integration, and guidance. Some agencies also identified strategies to mitigate identified challenges, including effective communication and information sharing and leveraging of existing resources, and reported that additional support from OMB and Treasury is needed for successful implementation.
Pilot to reduce recipient reporting burden. OMB has designed a pilot that consists of two parts focused on the grants and procurement communities. The Department of Health and Human Services (HHS) has been designated as the executing agency for the grant portion while OMB leads the procurement portion with support by the General Services Administration's 18F and others. If implemented according to HHS's proposed design, the grants portion of the pilot will likely meet requirements established under the act and will partially reflect leading practices for effective pilot design. However, the procurement portion does not clearly document how it will contribute to meeting the act's requirements nor does it reflect leading practices for effective pilot design.
Although progress has been made, GAO has been unable to close any DATA Act recommendations including those calling for establishing a data governance structure, developing a federal program inventory, and expanding two-way dialogue with stakeholders. GAO will continue to monitor OMB's and Treasury's progress to address its recommendations as implementation proceeds.