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. However, additional effort is needed  to address 11 previous GAO recommendations that remain open. Initial Steps Taken to Develop a Governance Structure but Further Steps Needed to Maintain the Integrity of Data Standards

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. Key Practices for Data Governance Structures  i. 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. 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. Reporting. Based on our review, we identified seven overarching categories  of mitigating strategies reported by these agencies to address DATA Act  implementation challenges: making changes to internal policies and  procedures, leveraging existing resources, using external resources,  continuing communications, employing manual and temporary  workarounds, monitoring and developing guidance, and enhancing  existing systems. 2016-03 directs agencies to  leverage existing procedures for providing assurances of the quality of  their DATA Act data submissions and directs agency SAOs to provide  reasonable assurance that their internal controls support the reliability  and validity of the data submitted to Treasury for publication on  USASpending.gov. Although OMB has made some progress with these efforts, other data  definitions lack clarity—including primary place of performance and award  description—which still needs to be addressed to ensure agencies report  consistent and comparable data. This was followed, in  July 2016, by a revised version of the design for the procurement portion. Design of the Procurement Portion of the Pilot Does Not Clearly Document How its Focus on Certified Payroll Reporting Will Apply to Other Procurement Reporting Requirements

We found some areas where the revised procurement design does not  fully reflect leading practices for effective pilot design. This is of particular concern given the diversity of  reporting requirements contained in the FAR. However, the revised design does not provide  any details on how this will be done. As a result  of these additional steps, GSA officials expect to be able to begin  collecting data through the centralized reporting portal sometime between  late January 2017 and late February 2017. For example,  OMB and Treasury can build upon the initial step of establishing a data  standards committee responsible for maintaining already established  standards and identifying new standards towards the goal of establishing  an institutionalized system of data management that follows key practices  and ensures the integrity of the data standards over time. By  addressing issues such as this and continuing to focus on implementing  the act, the administration greatly increases the likelihood of creating a  system that will achieve the goals of the act—to increase the  transparency of financial information and improve the usefulness of that  data to Congress, federal managers, and the American people. Recommendation for Executive Action

In order to ensure that the procurement portion of the Section 5 Pilot  better reflects leading practices for effective pilot design, we recommend  that the Director of OMB clearly document in the pilot’s design how data  collected through the centralized certified payroll reporting portal will be  used to test hypotheses related to reducing reporting burden involving  other procurement reporting requirements. OMB neither agreed nor disagreed with GAO’s  recommendation. This report examines: (1) steps  taken to establish a clear data governance structure which is particularly  important during the upcoming transition to a new administration; (2)  challenges reported by Chief Financial Officers Act of 1990 (CFO Act)  agencies in their implementation plan updates; (3) the operationalization  of government-wide data standards and the technical specifications for  data reporting; and (4) updated designs for the Section 5 Pilot for  reducing recipient reporting burden and progress made in its  implementation. To assess the extent to which the Section 5 pilot designs adhered to  leading practices for effective pilot design, we reviewed the documented  designs for both the grants and procurement portions of the pilot. Appendix II: Status of GAO’s Recommendations Related to the DATA Act

Appendix III: Information Included in Chief Financial Officers Act Agencies’ Implementation Plan Updates

In May 2015, the Office of Management and Budget (OMB) directed  federal agencies to submit Digital Accountability and Transparency Act of  2014 (DATA Act) implementation plans to OMB concurrent with the  agencies’ fiscal year 2017 budget requests.
Why GAO Did This Study

Effective implementation of the DATA Act will allow federal funds to be better tracked and greatly increase the types of data made publicly available. OMB and Treasury have taken significant steps to implement the act, but challenges remain as the critical deadline of May 2017 approaches. Consistent with GAO's mandate under the act, this report is one in a series of products GAO will provide to Congress providing oversight of DATA Act implementation. This report examines (1) steps taken to establish a clear data governance structure which is important during the upcoming transition to a new administration, (2) challenges reported by major agencies in their implementation plan updates, (3) the operationalization of government-wide data standards and technical specifications for data reporting, and (4) updated designs for the Section 5 pilot for reducing recipient reporting burden and progress made in its implementation. GAO reviewed key implementation documents, compared the Section 5 Pilot to leading practices, and interviewed staff at OMB, Treasury, and other selected agencies.

What GAO Found

Data governance and the transition to the new administration. Consistent with a July 2015 GAO recommendation to establish clear policies and processes that follow leading practices for data governance under the Digital Accountability and Transparency Act of 2014 (DATA Act), the Office of Management and Budget (OMB) and the Department of the Treasury (Treasury) have taken the initial step of convening a committee to maintain established standards and identify new standards. Although this represents progress, more needs to be done to establish a data governance structure that is consistent with key practices to ensure the integrity of standards over time. The upcoming transition to a new administration presents risks to implementing the DATA Act, potentially including shifted priorities or lost momentum. The lack of a data governance structure for managing efforts going forward jeopardizes the ability to sustain progress as priorities shift over time.
Implementation plan updates. The 24 Chief Financial Officers Act agencies continue to face challenges implementing the DATA Act, according to information in their implementation plan updates. GAO identified four categories of challenges reported by agencies that may impede their ability to implement the act: systems integration issues, lack of resources, evolving and complex reporting requirements, and inadequate guidance. To address these challenges, agencies reported changing internal policies and procedures; leveraging existing resources; and using external resources, and manual and temporary workarounds, among other actions.
Operationalizing data standards and technical specifications for data reporting. OMB issued additional guidance on how agencies should report data involving specific transactions, such as intragovernmental transfers, and how agencies should provide quality assurances for submitted data. However, this guidance does not provide sufficient detail in areas such as the process for providing assurance on data submissions and it does not address others, such as how agencies should operationalize the definitions for data elements (e.g., primary place of performance and award description). Treasury released a new version of the DATA Act Broker—a system that collects and validates agency data—in October 2016 and is making minor adjustments to its functionality. Agencies have reported making progress creating and testing their data submissions, but some report needing to rely on interim solutions for initial reporting while they wait for automated processes to be developed.
Pilot to reduce recipient reporting burden. GAO reviewed the revised design for both the grants and procurement portions of the pilot and found that they partly met each of the leading practices for effective pilot design. Although this represented significant progress since April 2016, GAO identified an area where further improvement is still needed. Specifically, the plan for the procurement portion of the pilot does not clearly document how findings related to the centralized certified payroll reporting portal will be applicable to other types of required procurement reporting. This is a particular concern given the diversity of federal procurement reporting requirements. To date, all six components of the grant portion are underway. Data collection for the procurement portion is delayed and is not expected to begin until January or February 28, 2017.

What GAO Recommends

GAO is making one new recommendation: that for the Section 5 Pilot, OMB clearly document in its design of the procurement portion how data collected through the centralized certified payroll reporting portal will be applied to other required procurement reporting. Moving forward, additional progress needs to be made to address GAO's 11 previous DATA Act recommendations that remain open. OMB neither agreed nor disagreed with GAO's recommendation.