Data Act: Customer Agencies' Experiences Working with Shared Service Providers for Data Submissions

Over the past 2 decades, the federal government has undertaken efforts to save money and increase efficiencies by encouraging agencies to use administrative and operational services and processes that other federal and external parties provide, commonly referred to as shared services. The DATA Act was enacted to increase accountability and transparency and, among other things, establish government-wide data standards. Certain agencies have used shared services of federal SSPs to implement the act. The act also requires a series of oversight reports by agencies' Offices of Inspector General (OIG) and GAO. OIGs for five agencies have made recommendations related to agencies' use of SSPs for DATA Act services, and four agencies concurred with the recommendations.

The objectives of this report are to describe (1) the types and variations of services that federal SSPs provide to their financial management customer agencies to assist them with implementing the DATA Act and meeting the act's requirements and (2) the challenges federal SSPs and their financial management customer agencies have encountered in their efforts to ensure the quality of data submissions consistent with DATA Act standards and steps they have taken to address those challenges.

To address these objectives, GAO interviewed staff at four federal SSPs, OMB, and Treasury; reviewed selected agreements between the SSPs and their customer agencies; conducted a survey of customer agencies from December 2018 to January 2019; and analyzed the survey responses.

GAO found that the 27 agencies that responded to its survey use federal shared service providers (SSP) for a variety of services, including financial system hosting, general ledger accounting, financial reporting, and various Digital Accountability and Transparency Act of 2014 (DATA Act) services.

Sixteen of the 27 SSP customer agencies reported that they experienced challenges associated with using an SSP, many of which affected the timeliness, completeness, or accuracy of agency DATA Act submissions. Ten of these agencies experienced challenges with depending on an SSP to take actions before the agency could proceed. Agencies responding to GAO's survey also reported other challenges, such as a lack of guidance from the Office of Management and Budget (OMB) and the Department of the Treasury (Treasury), limited customer agency and SSP resources, SSP errors affecting data quality, and inadequate SSP project management activities. Twelve of these 16 agencies stated that they are taking steps to address these challenges—such as increasing communication with their SSPs, making technology improvements, and performing manual work-arounds to reconcile and correct data files. Nine agencies reported remaining additional steps, for example, correcting data errors and developing a reconciliation process and internal guidance on topics such as data quality plans. While agencies are primarily responsible for the quality of DATA Act submissions, five agencies also reported that their SSPs had taken similar steps to address identified challenges.

Twenty of the 27 agencies described useful practices for working with SSPs on DATA Act submissions, including the agency discussing issues with the SSP and obtaining data files from the SSP each month to provide additional time to correct any identified errors. Treasury officials stated prior to GAO's survey that they held workshops for SSPs in the early stages of DATA Act implementation and clarified guidance issued in June 2018 to specifically address their concerns and questions. After GAO's survey, in April 2019, OMB issued a memorandum on shared services that among other things described the process and desired outcomes for shared services and established a governance and accountability model for achieving them.

The Digital Accountability and Transparency Act of 2014 (DATA Act) was  enacted, in part, to increase accountability and transparency of federal  spending, which totaled over $4 trillion for fiscal year 2018. It includes  provisions requiring us to review Office of Inspector General (OIG) reports  and to issue reports assessing and comparing the completeness,  timeliness, accuracy, and quality of data federal agencies submitted  under the act and their implementation and use of data standards. In  November 2017, we issued our first report on the quality of initial data that  agencies submitted and made available to the public on  USAspending.gov. In July 2018, we also issued a report on our review of  OIG reports on agencies’ first DATA Act submissions and in the course of  our review found that some OIGs reported challenges involving the use of  federal shared service providers (SSP) to help agencies implement the  act.

Over the past 2 decades, the federal government has undertaken efforts  to save money and increase efficiencies by encouraging agencies to use  administrative and operational services and processes that other federal  and external parties provide, commonly referred to as shared services.  Presidential administrations have made it a priority to promote the use of  shared services for human resources and financial management  activities. For example, in 2014 and again in 2018, the Office of  Management and Budget (OMB) established a priority goal of improving  the use, quality, and availability of administrative shared services.

Complementing the goal, the DATA Act is intended to increase the  transparency, standardization, and use of agencies’ spending data.

The objectives of this report are to describe (1) the types and variations of  services the federal SSPs provide to their financial management  customer agencies to assist them with implementing the DATA Act and  meeting the act’s requirements and (2) the challenges that federal SSPs  and their financial management customer agencies have encountered in  their efforts to ensure the quality of data submissions consistent with  standards established under the DATA Act and any steps they have  taken to address those challenges.

To address our objectives, we interviewed the officials of four federal  SSPs prior to our survey of customer agencies to obtain information on  the types and variations of services provided to financial management  customer agencies that are related to DATA Act implementation and  meeting the act’s requirements, including challenges and actions taken to  address them. From December 2018 to January 2019, we also conducted  a survey of 67 customer agencies that submitted data to the Department  of the Treasury (Treasury) to be published on USAspending.gov and that  federal SSPs identified as external customers for DATA Act or other  financial management services. We received 27 survey responses from  eligible members of this population that were sufficiently complete. We  analyzed the 27 responses to determine the types and variations of  services that the SSPs provide their customer agencies to assist with  implementing and meeting the act’s requirements. In the survey, we also  requested and obtained customer agencies’ perspectives on any  challenges experienced since their initial DATA Act submissions  associated with using an SSP. We also asked whether the challenge(s)  affected the timeliness, completeness, and accuracy of any of the  agency’s submissions. While we do not have evidence of material bias  from those not responding, we limit our survey results in this report to only  those 27 agencies that responded. Using the customer agencies’ survey  responses and statements from the four federal SSPs made prior to our  survey, we identified any steps the SSPs and their customers took to  address challenges and to help ensure the quality of data submissions.  Appendix I provides additional details on our scope and methodology.  The survey questions and summarized results are in appendix II.

We conducted this performance audit from July 2018 to July 2019 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 based on our audit objectives.

The DATA Act was enacted May 9, 2014, for purposes that include  expanding on previous federal transparency legislation by requiring the  disclosure of federal agency expenditures and linking agency spending  data to federal program activities, so that both policymakers and the  public can more effectively track federal spending. The act also holds  agencies accountable for submitting complete and accurate data to  Treasury and requires that agency-reported award and financial data  comply with OMB and Treasury data standards. The DATA Act requires  OMB and Treasury to establish government-wide data standards that to  the extent reasonable and practicable provide consistent, reliable, and  searchable spending data for any federal funds made available to or  expended by federal agencies. These standards specify the data  elements to be reported under the DATA Act and define and describe  what is to be included in each data element, with the aim of ensuring that  data will be consistent and comparable. The DATA Act requires OMB and  Treasury to ensure that the standards are applied to the data made  available on USAspending.gov and also requires agencies’ OIGs and  GAO to review these data and report on their completeness, timeliness,  accuracy, and quality.

USAspending.gov has many sources of data, including data that agencies  submitted to Treasury through their financial management systems and  other data extracted from government-wide award systems that collect  data from federal agencies and external award recipients. Treasury’s  DATA Act Broker (Broker) is a key component of the data collection and  reporting framework. The Broker enables agencies to upload, validate,  and certify financial data and create linkages between the financial and  award data for publication on the USAspending.gov website.

Agencies are expected to submit three data files with specific details and  data elements to the Broker from their financial management systems in  accordance with Treasury guidance documents.

File A: Appropriations account includes summary data such as the  fiscal year cumulative federal appropriations account balances and  includes data elements such as the agency identifier, main account  code, budget authority appropriated amount, gross outlay amount,  and unobligated balance.

File B: Object class and program activity includes summary data  such as the names of specific activities or projects as listed in the  program and financing schedules of the annual budget of the U.S.  government.

File C: Award financial includes award transaction data such as the  obligation amounts for each federal financial award made or modified  during the reporting quarter (e.g., January 1, 2017, through March 31,  2017).

The Broker also extracts data from four government-wide award reporting  systems: the Federal Procurement Data System–Next Generation  (FPDS-NG), System for Award Management (SAM), Financial Assistance  Broker Submission (FABS), and the FFATA Subaward Reporting System  (FSRS). These systems supply award and sub-award data (e.g., federal  grants, loans, and contracts) to USAspending.gov. The systems compile  data that agencies and external federal award recipients submit to report  procurement and financial assistance award data required under the  Federal Funding Accountability and Transparency Act of 2006 (FFATA).  The four files produced with data that the Broker extracts from the four  systems are as follows:

File D1: Procurement includes data on the attributes of the award  and the awardee and the recipient of the award (extracted from  FPDS-NG on a daily basis) for procurement awards (contracts), if any,  and contains elements such as the total dollars obligated, current total  value of award, potential total value of award, period of performance  start date, and other data to identify the procurement award.

File D2: Financial assistance includes award and awardee attribute  data (extracted from FABS nightly) on financial assistance awards  (grants and loans) and contains data elements such as the federal  award identification number, the total funding amount, the amount of  principal to be repaid for the direct loan or loan guarantee, the funding  agency name, and other data to identify the financial assistance  award.

File E: Additional awardee attributes includes additional data  (extracted from SAM) on the award recipients and contains elements  such as the awardee or recipient unique identifier; the awardee or  recipient legal entity name; and data on the award recipient’s five  most highly compensated officers, managing partners, or other  employees in management positions.

File F: Subaward attributes includes data (extracted from FSRS) on  awards made to subrecipients under a prime award, if any, and  contains elements such as the subaward number, the subcontract  award amount, total funding amount, the award description, and other  data to facilitate the tracking of subawards.

According to Treasury guidance, after agencies submit Files A, B, and C,  the Broker runs a series of validations and produces warnings and error  reports for agencies to review. After passing validations for these three  files, the Broker generates Files D1 and D2 containing details on  procurement and assistance awards and performs a cross-file validation  of linkages between File C and Files D1 and D2, which generates error  and warning reports, as appropriate. The Broker also generates Files E  and F containing data on highly compensated officers and subawards  associated with the prime awards. There are no field-level or cross-file  validations for Files E and F. With their quarterly submission, agency  senior accountable officials (SAO) are required to certify the data  submissions and to provide assurance over the alignment of Files A  through F and that the data are valid and reliable in accordance with OMB  guidance. According to Treasury officials, once the certification is  submitted, a sequence of computer program instructions or scripts is  issued to transfer the data from the Broker to tables set up in a database  used as a source for the data on the website. Data are then displayed on  USAspending.gov along with certain historical data from other sources,  including Monthly Treasury Statements.

OMB and Treasury implementation guidance called for customer  agencies to consider how best to leverage their SSPs to capture data for  their submissions, engage with their SSPs throughout the implementation  process, and document the SSP role in agency DATA Act submissions.  According to the SSPs, 60 non–Chief Financial Officers Act of 1990 (CFO  Act) agencies use a federal SSP for all or part of the data submissions  out of the 82 reporting data under the DATA Act as of the fourth quarter in  fiscal year 2018.

In 2014, Treasury designated four federal financial management SSPs to  provide financial management services to other federal agencies.  Although the four Treasury-designated federal financial management  SSPs have changed over the years, the four federal financial  management SSPs, which performed DATA Act services for external  customers as of December 2018, are as follows:

The Administrative Resource Center (ARC) is a Treasury SSP that  provided financial management services to 42 customer agencies  external to Treasury. According to ARC, 21 of those agencies  received DATA Act services from ARC.

The Enterprise Services Center (ESC) is a Department of  Transportation financial management SSP that provided services to  seven external customer agencies. According to ESC, six of those  customer agencies received DATA Act services from ESC.

Pegasys Financial Services (PFS) is a Department of Agriculture  financial management SSP that provided services to 37 external  customer agencies. According to PFS, 24 of those customer agencies  received DATA Act services from PFS.

The Interior Business Center (IBC) is a Department of the Interior  financial management SSP that provided services to 18 external  customer agencies. According to IBC, nine of those customer  agencies received DATA Act services from IBC.

The DATA Act requires agencies’ OIGs to issue reports assessing the  quality of the agencies’ spending data submissions and compliance with  the DATA Act. In the OIGs’ reports covering their agencies’ second  quarter fiscal year 2017 submissions, nine OIGs reported issues with their  agencies’ use of an SSP for DATA Act submissions. Five of the nine  OIGs issued recommendations related to these issues, and four agencies  concurred with the recommendations. For example, one OIG  recommended that its agency work closely with its SSP to address timing  and coding errors that the SSP caused for future DATA Act submissions.  Another OIG recommended that its agency work with its SSP to identify  OMB requirements that the SSP is to perform and insert them into the  service-level agreement, in order to address errors caused by confusion  as to whether the SSP or the agency should submit certain types of data.  Although our prior reports on the DATA Act included recommendations,  our recommendations were not related to SSPs’ implementation of the  DATA Act. The DATA Act requires OIGs and GAO to issue their second  reports on data quality in November 2019.

Federal SSPs Provide a Variety of DATA Act Services for Their Customer Agencies

Customer Agencies Use Federal Financial Management SSPs for a Variety of Services

The 27 customer agencies that responded to our survey reported that the  four federal financial management SSPs provide a variety of services  (see fig. 1). All 27 agencies reported using their federal financial  management SSPs for DATA Act services, and almost all of the agencies  used their SSPs for several other financial management services, such as  general ledger accounting, financial reporting, and hosting the customer  agencies’ financial systems. As such, the SSPs play a key role in  helping to ensure that these customer agencies successfully carry out the  requirements of the DATA Act and submit Files A, B, and C from their  financial management systems. In addition, 17 agencies reported using  their SSPs for payroll or budget execution services, while fewer reported  using their SSPs for other financial management services, such as grant  or loan processing.

DATA Act services. All 27 customer agencies responding to our survey  reported using an SSP for DATA Act services. As discussed in more  detail below, these DATA Act services may include activities such as  preparing DATA Act files from financial systems, consolidating DATA Act  files from multiple agency component entities, reconciling DATA Act files  to other source data, and uploading DATA Act files to the Broker for  validation.

General ledger accounting. Twenty-six agencies reported using SSPs  for general ledger accounting, which may include activities such as  general ledger setup and maintenance, posting transactions to the  general ledger, accrual and liability processing, and period-end general  ledger closing.

Financial reporting. Twenty-six agencies also reported using SSPs for  financial reporting, which may include activities such as Treasury  reporting, financial statement preparation, cash forecasting and reporting,  and financial performance and operational reporting.

Financial system hosting. Twenty-five agencies reported using SSPs  for financial system hosting, which may include services such as systems  management and monitoring, disaster recovery, help desk administration,  network security compliance and controls, and continuity of operations  plans and testing.

Invoice processing. Twenty-four agencies reported using SSPs for  invoice processing, which may include services such as recording  receiving and acceptance reports, recording invoices, matching invoices  to receiving and acceptance reports, and routing invoices to obtain  approval for payment.

Budget execution. Seventeen agencies reported using their SSPs for  financial management services related to budget execution, which may  include activities such as budget setup and maintenance, fund allocation  and control, and budgetary reporting.

Payroll. Seventeen agencies reported using SSPs for payroll. SSP  payroll services may include recording payroll and benefit payments;  reconciling payroll service data with financial management data; and  recording credits, payment adjustments, and employee receivable offsets.

Procurements/contracts. Thirteen agencies reported using SSPs for  procurement and contract services. SSP procurement and contract  services may include recording credits and payment adjustments;  auditing payments; processing payments for incurred expenses and  payments in advance; and capturing award identifier data, such as the  Procurement Instrument Identifier (PIID) and agency Unique Record  Identifier (URI) to support DATA Act reporting.

Grants processing. Seven agencies reported using SSPs for grants  processing, which may include recording requests for grant payments,  matching grant payment requests to obligating documents, routing grant  payment requests for approval, and generating payment transactions.  These processes also include payments for expenses and payments in  advance as well as capturing award identifier data, such as Federal  Award Identification Numbers (FAIN) and Catalog of Federal Domestic  Assistance (CFDA) codes to support DATA Act reporting.

Loans processing. Three agencies reported using SSPs for loan  processing. Loan processing services may include recording requests for  loan payments, matching loan payment requests to obligating documents,  generating payment transactions, resolving payment issues, and  recording credits and payment adjustments.

Customer Agencies Rely on Their SSPs to Perform Various DATA Act Services

All 27 agencies responding to our survey reported that their federal SSPs  perform a variety of DATA Act services or activities, as shown in figure 2.  Preparing data files A, B, or C and uploading them to the Broker are the  most prevalent DATA Act services or activities that the federal SSPs  perform, whereas fewer than half of the SSPs certify and publish the files  for the agency after receiving agency approval.

All 27 agencies reported that their SSPs prepare at least one of the Files  A, B, or C using data from either SSP or customer agency financial  systems. In addition, 15 of the 27 agencies reported that their SSPs  consolidate DATA Act files from multiple agency components. Seventeen  agencies reported that their SSPs reconcile Files A, B, or C to other  source data. For example, a reconciliation of general ledger and  subledgers may include verifying that (1) general ledger account balances  can be traced to aggregated or discrete agency transactions and   (2) aggregated or discrete agency transactions can be traced to the point  of origination and source documents. Twenty-five of the 27 agencies  reported that their SSPs upload Files A, B, or C to the Broker for  validation. In turn, the Broker runs a series of data validations and  produces warnings and error reports for agencies to review after the files  are submitted. Twenty-one agencies reported that their SSPs address  these warnings and errors on their behalf. After warnings have been  reviewed and all errors have been addressed, Files A, B, and C have  been uploaded and Files D1, D2, E, and F have been generated, the  agency’s SAO is required to certify the validity and reliability of the data  submissions in accordance with OMB guidance. Twenty-four agencies  reported that their SSPs provide final Files A, B, or C for the customer  agency to review and certify in the Broker, and 11 agencies reported that  their SSPs finalize the files in the Broker and click the Certify and Publish  button after receiving agency approval to certify.

Most Customer Agencies and the Four Federal SSPs Reported DATA Act Challenges and Have Taken Steps to Address Them

Customer Agencies and SSPs Reported Various Challenges Affecting Timeliness, Completeness, and Accuracy of Their DATA Act Submissions

We asked customer agencies in our survey to specify the challenges  associated with using an SSP that they experienced since their initial  DATA Act submission; the SSP’s role in these challenges; and whether  the challenges affected the timeliness, completeness, or accuracy of their  submissions. Sixteen of the 27 customer agencies that responded to our  survey identified one or more challenges associated with using an SSP  (see fig. 3), many of which affected the timeliness, completeness, and  accuracy of agency submissions. The survey questions and summarized  results are shown in appendix II. In addition, officials from all four federal  SSPs described various challenges they experienced in helping their  agency customers with DATA Act submissions.

The challenges reported by these 16 customer agencies and the federal  SSPs are summarized below. Depending on the effectiveness of  agencies’ and SSPs’ actions to address them (as discussed further  below), these challenges may increase the risk that agencies will be  unable to submit quality data in accordance with the DATA Act.

Dependencies. Ten agencies reported that they have experienced  challenges related to agency submission activities that depend on  relationships with, or actions being taken by, the SSP before the agency  can proceed. One agency reported that it must rely on its SSP to prepare,  validate, and finalize all DATA Act files prior to agency certification and  the files are often submitted close to the due date. Another agency  reported that its SSP provided DATA Act submission files to the agency  the day before or near the certification deadline. Relying on SSPs to  prepare DATA Act files in a timely manner increases the risk that  agencies may be unable to certify and publish their DATA Act  submissions on time.

Resources. Seven agencies said that they have experienced resource  challenges related to a lack of funding or human resources at the  customer agency or its SSP. One agency noted that its SSP has only a  small group of people that assist with all of its SSP’s services, making it  challenging in particularly busy seasons (such as the close of the fiscal  year) for the SSP to meet internal deadlines and resolve data  discrepancies affecting the timeliness, completeness, and accuracy of  data submissions. Another agency reported challenges with funding  resources, noting that the agency has been unable to use its SSP’s  integrated financial and procurement system because of the costs  associated with implementation, operation, and maintenance. The  shortage of resources to bring on more staff or improve systems  increases the risk that agencies may be unable to submit quality data and  fully carry out DATA Act requirements.

Competing priorities. Five agencies said that they have experienced  challenges related to statutory, regulatory, policy, or other matters that  have competing priorities or conflicting requirements that may affect an  agency or its SSP’s DATA Act submission process. One agency reported  that the fourth quarter DATA Act reporting deadline falls within fiscal year- end reporting time frames, requiring the agency to prioritize fiscal year- end reporting over some of the DATA Act reporting tasks. Similarly,  officials from an SSP told us that they also experienced challenges with  the short turnaround times required to incorporate system updates for  DATA Act submissions.

Data quality. Four agencies reported that they have experienced  challenges related to meeting DATA Act requirements for data quality  because they use an SSP, including completeness and accuracy of  agency data to be reported as well as SAO certification and reporting of  nonfinancial data elements. One agency reported that its SSP included  extraneous transactions in its File C that were not required for DATA Act  reporting. This created a high volume of warning messages when the  Broker compared the data with file D2 during the validation process.  Another agency reported that its SSP provided incomplete files for  agency certification and that the data in the files did not reflect the data in  the agency’s financial reports. These challenges not only increase the risk  of lower-quality agency data submissions but may also require SSPs and  customer agencies to expend additional resources to address warning  messages that the Broker generated.

Guidance. Four agencies reported experiencing challenges involving  incomplete, unclear, missing, and evolving OMB and Treasury guidance  related to SSP implementing requirements and Broker changes, including  data elements, the technical schema, and other key policies. One agency  noted that guidance on performing quarterly certifications is not readily  available. Two agencies reported challenges involving a lack of guidance  on how to communicate error corrections and desired changes to their  SSPs. Lack of guidance could result in misunderstandings or  miscommunications between the SSP and its customer agency,  increasing the risk of delays or errors in the agency’s data submissions.

Technology. Four agencies reported that they have experienced  technology challenges with developing and submitting required files.  These challenges include SSP infrastructure issues, such as integrating  multiple existing and disparate management systems or their SSPs  needing to modify existing systems to implement the DATA Act. Agencies  reported that some systems are unable to include the required data  elements for all reported transactions. Similarly, an SSP official told us  prior to our survey of customer agencies that the SSP also experienced  technical challenges with systems and data that have since been  resolved. Another SSP experienced challenges with its financial systems  not capturing award identification data elements, such as the PIID. Such  limitations in customer agency and SSP technology may require the use  of limited resources for error corrections and manual work-arounds,  increasing the risk of reporting errors, and may hamper customer  agencies’ and SSPs’ ability to submit quality data in accordance with the  DATA Act.

Project management. Two agencies reported that they have  experienced challenges related to their SSPs’ project management, such  as the lack of a designated project manager and inadequate  documentation of progress made or key decisions. Specifically, both  customer agencies said that their SSPs did not provide data in a timely  manner for their review prior to submission. One agency reported that  although this did not affect the timeliness of its submission, it affected  data quality because the agency did not have sufficient time to test and  implement sufficient internal controls and validation procedures prior to  data being published on USAspending.gov. Additionally, the same  agency reported that there is no senior project manager at the SSP who  oversees the processes used to provide financial management services  to the agency. This challenge may affect agencies’ ability to resolve  errors, increasing the risk that they submit incorrect data. However, none  of the four federal SSPs described any project management challenges  when we asked them prior to our survey what challenges they faced in  carrying out their roles and responsibilities for assisting their customer  agencies with implementing the DATA Act.

Agencies Reported Steps They Have Taken to Address Identified DATA Act Submission Challenges and Ensure Data Quality

We asked customer agencies in our survey to describe the steps they  and their SSP have taken to address reported challenges and help  mitigate risks associated with them. Of the 16 agencies that identified  challenges, 12 agencies reported that they had already taken steps to  address them and five agencies said they were aware of steps their SSPs  had taken. As discussed in more detail below, communication and  coordination between the SSP and Treasury, as well as customer agency  technological improvements and manual work-arounds were the steps  most often reported by agencies to address identified challenges.

Communication and coordination. Eight of the 12 agencies described  communication efforts with their SSPs or Treasury to facilitate  coordination and seek information needed to address their challenges  associated with using an SSP. These efforts include requesting  information from the SSP, Treasury, and other government resources to  obtain additional knowledge regarding the DATA Act and to prepare  internal guidance and procedures. One agency reported implementing a  weekly meeting with its SSP on DATA Act reporting. Another agency  reported that its SSP has been very proactive in sharing information  (bulletins, updates, etc.) and assisting with submitting DATA Act  information. According to the eight customer agencies, increased  communication and coordination has helped to address several  technology, dependency, and resource challenges.

Technology improvements. To address technology challenges, four  agencies discussed making improvements in technology at both the  agency and the SSP. The improvements include implementing an  integrated financial and procurement system platform and working with  the software vendor to obtain access to FPDS-NG for anticipated 2019  procurement activity reporting. Another agency is currently implementing  a technological solution to aid in consolidating and reconciling files. In  addition to technological solutions, two agencies reported using manual  work-arounds, such as developing and implementing internal manual  processes to reconcile and correct data files. Some agencies also  discussed actions their SSPs had taken to address technology issues,  including two SSPs that are working with the developers to address  software issues. One agency reported that in addition to addressing  technology challenges, these improvements also provided substantial  cost savings.

We also asked the 27 customer agency survey respondents to specify the  internal control processes and activities they use to assure the quality of  data submitted to the Broker. Twenty-four of 27 agencies reported that  they use various processes and activities to provide such assurance.  Specifically, these 24 agencies reported that they reconcile data files to  other agency data and sources (e.g., the Governmentwide Treasury  Account Symbol Adjusted Trial Balance System). These reconciliations  can help identify errors in data files and ensure that they are consistent  with other agency data. In addition, 18 agencies reported that they review  their SSPs’ Service Organization Control (SOC) reports to identify any  internal control deficiencies, and nine agencies reported that they  implemented controls to address control deficiencies identified in their  SSPs’ SOC reports. Twenty agencies reported that they review or verify  agency data displayed on USAspending.gov. By reviewing these data,  agencies can confirm that the data that they uploaded to the Broker are  presented accurately on the website.

Nineteen agencies reported that they incorporate the results of OMB  Circular No. A-123 reviews that affect their DATA Act submissions.  OMB Circular No. A-123 provides a methodology for agency  management’s reporting on internal controls over reporting, and it also  establishes an assessment process based on our Standards for Internal  Control in the Federal Government that management must implement in  order to properly assess and improve internal controls over operations,  reporting, and compliance.

Agencies Described Useful Practices for Working with SSPs on DATA Act Submissions

Twenty of the 27 agencies that responded to our survey described useful  practices in working with an SSP on DATA Act submissions. These  agencies reported most often that discussing issues with the SSP and  performing data reconciliations or comparisons were helpful. For  example, 12 agencies reported that working and communicating with the  SSP was useful. They also reported that having a readily available point  of contact for better communication and communicating early about the  need to complete the DATA Act submission helps to resolve any  concerns prior to the due date. One agency reported that it conducts  weekly meetings with its SSP to discuss key topics, including  implementation, data quality, and reporting processes and procedures.  Eleven agencies reported that conducting data reconciliations or  comparisons, and creating a standard operating procedure to ensure that  their data are consistently reviewed, reconciled, corrected, and certified,  was also useful. One agency noted that in addition to the quarterly files  that require certification, the SSP also provides monthly files that the  agency can review to provide additional time to correct any identified  errors.

These 20 agencies also suggested other practices for successfully  working with an SSP on DATA Act submissions, such as automating  reconciliations and other internal control processes to increase efficiency,  implementing continuous training and monitoring, assigning an  accountant as an agency contact, and conducting an analysis of agency  risk as recommended in the Data Quality Playbook. One agency  reported that it performs extensive comparisons of agency-generated  data reports to SSP-prepared data files, and that it partially automated  this process to help increase efficiency.

Agencies Described the Need for Additional Steps, Tools, and Guidance Related to Using an SSP for DATA Act Submissions

Nine of the 16 agencies that identified challenges associated with using  an SSP reported that their agencies need to take additional steps to  address their identified challenges. Some of these agencies reported that  they still need to address issues such as correcting data and improving  communication with their SSPs. These agencies also reported the need  to negotiate annual service-level agreements with their SSPs to address  resource and competing priority concerns. One of these agencies  reported that it continues to work with its SSP to understand what is  lacking in the process of correcting PIID information for obligations. A few  agencies reported the need to develop internal guidance on topics such  as data quality plans per OMB guidance and a reconciliation process to  address their data quality challenges. Finally, one agency reported that  it is in the process of hiring additional personnel to address its challenges  with competing priorities.

While customer agencies are primarily responsible for the quality of their  DATA Act submissions, six of the 16 agencies that reported challenges  reported that their SSPs also need to take certain steps to address  identified challenges, such as communicating with the customer agency  and making technology improvements. For example, one agency reported  that its SSP does not provide the customer agency with updated data  submission files after the agency has requested changes. The customer  agency suggested that the SSP provide updated files more often to help  the agency ensure that the changes are included in the final file it submits  to the Broker. Another agency reported that its SSP has been  experimenting with different methods to eliminate cross-file warnings and  errors in File C that need to be addressed.

Five of the 27 customer agencies we surveyed reported that additional  tools or guidance from OMB, Treasury, or other entities (such as the  SSP) could assist agencies with using an SSP for DATA Act submission.  Specifically, three agencies reported that they would like to have  guidance, including standard operating procedures, for communicating  and working with their SSPs. One agency suggested additional OMB or  Treasury training on compliance with the DATA Act, and one agency  suggested improvements by Treasury to prevent Broker errors that result  from normal business scenarios and require manual work-arounds to the  agencies’ system-generated files.

OMB staff told us that they are involved with the DATA Act Executive  Steering Committee, working closely with Treasury to oversee all aspects  of both policies and implementation related to federal spending  transparency efforts. According to OMB staff, neither the SSPs nor their  customer agencies have reported any current challenges with DATA Act  submissions to OMB. OMB staff stated that effective implementation of  OMB Memorandum M-18-16 guidance to agencies and SSPs, which  discusses establishing entity-level controls related to using SSPs, would  help to ensure that the SSPs provide quality services. In April 2019,  OMB issued Memorandum M-19-16 on shared services, which among  other things described the process and desired outcomes for shared  services and established a governance and accountability model for  achieving them. For example, as it relates to the DATA Act, the  memorandum calls for the Shared Services Governance Board to  leverage the DATA Act Executive Steering Committee’s work on DATA  Act standards.

Treasury officials told us prior to our survey that they held two workshops  for SSPs in the early stages of implementation to address specific  concerns and questions on DATA Act implementation. Treasury officials  stated that the only challenge reported by SSPs to the department related  to linking and certifying award data using the Broker when the awarding  agency and the file C reporting agency were different. To address this  concern, Treasury added clarification in guidance on files A, B, and C  submissions and a new Broker feature allowing agencies to specify  whether the award data submitted in Files D1 and D2 comes from the  funding agency or the awarding agency.

We provided a draft of this report to OMB; Treasury, including ARC; ESC;  PFS; and IBC for comment. OMB, ESC, and IBC told us that they had no  comments on the draft report. Treasury and PFS provided technical  comments, which we incorporated as appropriate.

We are sending copies of this report to the Director of the Office of  Management and Budget, the Secretary of the Treasury, the four federal  financial management shared service providers, and interested  congressional committees and other interested parties. In addition, the  report is available at no charge on the GAO website at  http://www.gao.gov.

If you or your staffs have any questions about this report, please contact  me at (202) 512-9816 or rasconap@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. Key contributors to this report are listed in  appendix III.

Appendix I: Objectives, Scope, and Methodology

The Digital Accountability and Transparency Act of 2014 (DATA Act)  requires us to review Office of Inspector General (OIG) reports and issue  reports of our own assessing and comparing the completeness,  timeliness, accuracy, and quality of the data that federal agencies submit  under the act and the implementation and use of data standards. We  issued our first report on data quality in November 2017, as required. In  July 2018, we issued a report on our review of OIG reports on agencies’  first DATA Act submissions and in the course of our review found that  some OIGs reported challenges involving the use of federal shared  service providers (SSP) that helped agencies implement the DATA Act.

For this report, our objectives were to describe (1) the types and  variations of services that the federal SSPs provide to their financial  management customer agencies to assist them in implementing the  DATA Act and meeting the act’s requirements and (2) any challenges that  federal SSPs and their financial management customer agencies have  encountered in their efforts to ensure the quality of data submissions  consistent with the standards established under the DATA Act and the  steps they have taken to address those challenges.

To address our first objective, we interviewed four federal SSPs and  surveyed their financial management customer agencies to identify the  types and variations of services the SSPs provide related to DATA Act  implementation and meeting the act’s requirements. We also obtained  and reviewed selected service-level agreements executed between the  four SSPs and their financial management customer agencies to  determine the types and variations of DATA Act services that the SSPs  provided to them.

In December 2018, we emailed a survey questionnaire to 67 customer  agencies that the four federal SSPs told us were external customers for  DATA Act or other financial management services and that also  submitted data under the DATA Act as of December 2018. During the  survey, we determined that 60 of those 67 agencies actually received  DATA Act services from a federal SSP and were eligible members of our  study population. We received survey responses from 31 agencies by our  January 2019 deadline and, based on our review, determined that 27  were eligible and sufficiently complete for our purposes. After excluding  ineligible agencies from our population, the response rate was 45  percent.

In developing, administering, and analyzing the survey, we took steps to  minimize the five types of potential errors, described below, that may  affect survey results. Because we surveyed all agencies in our  population, there was no sampling error. To minimize the effects of  coverage error—the exclusion of some eligible members of the  population, or inclusion of ineligible members—we identified as ineligible  and removed seven initially identified agencies because we determined  that they did not use a federal SSP to provide DATA Act services.  Measurement error may result from differences in how a question is  interpreted and the sources of information available to respondents. To  help prevent measurement error, we conducted pretests of the draft  questionnaire with four customer agencies, each using a different SSP,  and made revisions to improve the validity and minimize the burden of  responding to our questions.

Nonresponse error may result when a survey fails to capture information  from all agencies selected in the survey, and it may introduce bias if those  agencies that did not respond would have given materially different  answers than those that did. To maximize survey response, we sent  multiple email reminders to the surveyed agencies and extended the  submission deadline. While we do not have evidence of material bias  from those not responding, we limit our survey results in this report as  representing only those 27 agencies responding. Finally, to limit the  possibility of processing error, survey responses were checked for invalid  or illogical answer patterns, and data edits were made as necessary to  facilitate processing and analysis of the results. This analysis was verified  by a separate data analyst.

Table 1 lists the 27 customer agencies (by shared service provider) for  which we obtained, reviewed, and included customer agency survey  responses. The survey questions and summarized results are shown in  appendix II.

To meet our second objective, we interviewed the officials of the four  federal SSPs prior to our survey to obtain information on the challenges  the SSPs and their customer agencies encountered and steps taken to  address them. We reviewed and analyzed the 27 customer agency  survey responses to identify challenges responding agencies reported  since their initial DATA Act submissions because they are working with an  SSP and any steps SSPs and their financial management customers took  to address challenges and to help ensure the quality of data submissions.  We did not corroborate the customer agencies’ survey responses with the  four federal SSPs, Office of Management and Budget (OMB), or  Department of the Treasury (Treasury). To identify steps taken to address  challenges, we also obtained and reviewed any reports related to DATA  Act implementation that the SSPs or their respective OIGs produced.

In addition, we interviewed OMB staff and Treasury officials about any  guidance they have provided or actions they have taken to assist the four  SSPs and their financial management customers with any challenges  related to DATA Act compliance.

Appendix II: Results of Survey of Federal Financial Management Shared Service Provider Customer Agencies

United States Government Accountability Office Survey of Customer Agencies’ Use of Shared Service Providers  for Digital Accountability and Transparency Act   (DATA Act) Submissions  This questionnaire asks about your agency’s use of and relationship with  your federal shared service provider (SSP). It should be completed by  officials knowledgeable about the DATA Act services your federal SSP  provides. Please submit only one survey response per agency, but  consult with other officials as needed; when answering, please consider  any agency component activity and experiences together, and answer at  the agency level to the best of your ability. If your agency uses more than  one federal SSP, please be sure to include information about both SSPs  in your answers.

This is a fillable PDF form. You can click buttons and type into highlighted  boxes throughout the form; the boxes will accommodate more text than is  immediately visible.

Save this file to a drive now, and save your answers periodically as you  go.

When completed, save this file and email it to  DATAActImplementation@gao.gov. If a “Submit” button appears in the  upper right corner of your screen, you may also use that to automatically  email your completed questionnaire (some viewers will not see this button  depending on your system’s Javascript settings).

If you have any questions, or feel this questionnaire was sent to your  office in error, please contact   1.  What is the name of the person completing this questionnaire, title,  agency name, and contact information?   (Please submit only one survey response per agency)

2.  What is the name and title of the individual who reviews and certifies  your agency’s DATA Act submission in the Treasury broker as ready  for publishing?

a.  Is this person also your agency’s DATA Act Senior  Accountable Official (SAO)?

3.  Which federal SSP(s) (if any) does your agency currently use for the  financial management services listed below? (Select all that apply)

4.  Which specific DATA Act services/activities does the federal SSP(s)  identified in question 3 perform for your agency (in whole or in part)?  (Select all that apply)

Finalize the files in the Treasury broker by  clicking the “Certify and Publish” button  after receiving agency certification   Other SSP services or activities   (specify in the box below)

5.  Which, if any, of the following activities does the federal SSP(s) you  identified above initiate for your agency (in whole or in part) for the  broker to perform? (Select one answer in each row)

6.  What are the steps taken by your agency to certify the final DATA Act  files before they are published (e.g., by whom and how are the data  validated, reviewed, and comments (if any) provided on the files)?

Summary included in report 7.  Since your agency’s initial DATA Act submission, has your agency  experienced any challenges in the following areas because it is  working with an SSP, and did the challenge(s) in working with the  SSP have an impact on the timeliness, completeness, and accuracy  of any of your agency’s submissions?   (Select all the area(s) with challenges and any impacts that apply)

Technology issues  Including challenges with developing and submitting  required files, and SSP infrastructure issues such as  integrating multiple existing and disparate financial and  management systems, or the SSP needing to install new  systems or modify existing systems to implement the DATA  Act.   Dependencies  Agency submission activities depend on relationships with  or actions being taken by the SSP before the agency can  proceed.  Guidance  Incomplete, unclear, missing, and evolving guidance related  to the SSP implementing requirements and broker changes,  including data elements, the technical schema, and other  key policies issued by OMB and Treasury.  Resources  Lack of funding or human resources by your agency or  SSP.

Project management  Challenges related to the SSP’s project or program  management, such as lack of a designated project manager  and inadequate documentation of progress made or key  decisions.  Data quality  Issues related to meeting DATA Act requirements for data  quality because of the use of an SSP, including  completeness and accuracy of agency data to be reported,  as well as Senior Accountable Official certification and  reporting of nonfinancial data elements.  Competing priorities  Statutory, regulatory, policy or other matters that have  competing priorities or conflicting requirements that may  affect an agency or their SSP’s DATA Act submission  process.

Contract Management  Challenges related to the management of the Service Level  Agreement (SLA) and/or tasks and services that the SSP  provides for the customer agency or the SSP should be  providing but are not in the SLA.  Other challenges   (specify in box below)

8.  What were the specific challenge(s) with your agency’s DATA Act  submissions identified in question 7, and how did your SSP play a  role? If your agency used multiple SSPs, please specify to which  provider the challenge(s) was related.  a.  What steps, if any, has your agency taken to address  these challenge(s)?  b.  What steps, if any, remain to be taken by your agency to  address these challenge(s)?  c.  What steps, if any, are you aware of that your SSP has  taken to address these challenge(s)?  d.  What steps, if any, remain to be taken by your SSP to  address these challenge(s)?

Summary included in report 9.  What management or oversight practices has your agency found to  be useful in working with your SSP on DATA Act submissions? 10. What internal control processes and activities does your agency use  to provide assurance over the quality of data submitted to the  Treasury broker and displayed on USAspending.gov?

Internal control processes and activities:  Reconcile data files to other agency data and sources (e.g., SF 133, GTAS)

Review SSP’s Statement on Standards for Attestation Engagements No. 18/Service and  Organization Controls (SOC) reports to identify any internal control deficiencies. (Describe  internal control deficiencies related to DATA Act submissions, if any, in box below)

Implement complementary controls to address SSP control deficiencies identified in the SOC  report. (Describe controls implemented, if any, in box below)

Review/verify agency data displayed on USAspending.gov  Incorporate the results of A-123 reviews that have an impact on DATA Act   Other internal control processes or activities (specify in box below)

11. What additional tools or guidance, if any, are needed from OMB,  Treasury, or others to assist with your agency’s use of the SSP or  DATA Act submission?  12. Please provide any additional comments or explanations not already  discussed above.

Please save and e-mail your responses to  DATAActImplementation@gao.gov.

Thank you for completing our questionnaire!

Appendix III: GAO Contact and Staff Acknowledgments

In addition to the contact named above, Michael LaForge (Assistant  Director), Laura Pacheco (Auditor in Charge), Umesh Basnet, Thomas  Hackney, Roy Kilgore, and Diane Morris made major contributions to this  report. Other key contributors include Dave Ballard, Jenny Chanley, Peter  Del Toro, Patrick Frey, Ricky Harrison, Maxine Hattery, Jason Kelly,  James Kernen, Christina Quattrociocchi, Carl Ramirez, Michelle Sager,  and James Sweetman.

DATA Act: OMB Needs to Formalize Data Governance for Reporting  Federal Spending. GAO-19-284. Washington, D.C.: March 22, 2019.

Streamlining Government: OMB and GSA Could Strengthen Their  Approach to Implementing a New Shared Services Plan. GAO-19-94.  Washington, D.C.: March 7, 2019.

Open Data: Treasury Could Better Align USAspending.gov with Key  Practices and Search Requirements. GAO-19-72. Washington, D.C.:  December 13, 2018.

DATA Act: Reported Quality of Agencies’ Spending Data Reviewed by  OIGs Varied Because of Government-wide and Agency Issues.  GAO-18-546. Washington, D.C.: July 23, 2018.

DATA Act: OMB, Treasury, and Agencies Need to Improve Completeness  and Accuracy of Spending Data and Disclose Limitations. GAO-18-138.  Washington, D.C.: November 8, 2017.

DATA Act: As Reporting Deadline Nears, Challenges Remain That Will  Affect Data Quality. GAO-17-496. Washington, D.C.: April 28, 2017.

DATA Act: Office of Inspector General Reports Help Identify Agencies’  Implementation Challenges. GAO-17-460. Washington, D.C.: April 26,  2017.

DATA Act: Implementation Progresses but Challenges Remain.  GAO-17-282T. Washington, D.C.: December 8, 2016.

DATA Act: OMB and Treasury Have Issued Additional Guidance and  Have Improved Pilot Design but Implementation Challenges Remain.  GAO-17-156. Washington, D.C.: December 8, 2016.

DATA Act: Initial Observations on Technical Implementation.  GAO-16-824R. Washington, D.C.: August 3, 2016.

DATA Act: Improvements Needed in Reviewing Agency Implementation  Plans and Monitoring Progress. GAO-16-698. Washington, D.C.: July 29,  2016.

DATA Act: Progress Made but Significant Challenges Must Be Addressed  to Ensure Full and Effective Implementation. GAO-16-556T. Washington,  D.C.: April 19, 2016.

DATA Act: Data Standards Established, but More Complete and Timely  Guidance Is Needed to Ensure Effective Implementation. GAO-16-261.  Washington, D.C.: January 29, 2016.

DATA Act: Progress Made in Initial Implementation but Challenges Must  be Addressed as Efforts Proceed. GAO-15-752T. Washington, D.C.:   July 29, 2015.

Federal agencies are required to report their spending data to make it more transparent to the public via USASpending.gov. Nearly 80% of smaller agencies use a shared service provider—an entity that provides administrative and operational services—to help them compile and submit their data.

Of the 27 agencies we surveyed, 16 noted delays, inaccuracies, and other problems with their submissions due to challenges related to working with a service provider. However, 20 of those agencies described ways they worked well with service providers, such as increasing communication and reviewing their files monthly to leave more time for correcting errors.