Data Act: Pilot Effectively Tested Approaches for Reducing Reporting Burden for Grants but Not for Contracts

The DATA Act required OMB or a designated federal agency to establish a pilot program to develop recommendations for reducing recipient reporting burden for federal grantees and contractors. The grants portion of the pilot tested six ways to reduce recipient reporting burden while the procurement portion focused on testing a centralized reporting portal for submitting reporting requirements. This report follows a 2016 GAO review on the design of the pilot.

This report assesses the extent to which (1) the pilot met the statutory requirements set out in the DATA Act, (2) the grants portion of the pilot demonstrated changes in reporting burden, and (3) the procurement portion demonstrated changes in reporting burden. GAO reviewed statutory requirements, pilot plans, agency data and reports and interviewed OMB staff and officials from HHS and GSA.

In response to requirements of the Digital Accountability and Transparency Act of 2014 (DATA Act), the Office of Management and Budget (OMB) led implementation of a pilot program, known as the Section 5 Pilot, aimed at developing recommendations for reducing recipient reporting burden for federal grantees and contractors.

The pilot program met many, but not all, of its statutory requirements. For example, the act required OMB to issue guidance to agencies for reducing reporting burden for federal award recipients (including both grantees and contractors) based on the pilot's findings. OMB partially met this requirement because the guidance it issued only applied to grants.

The pilot program consisted of two parts, which differed considerably in both design and results: The grants portion, administered by the Department of Health and Human Services (HHS), examined six approaches for reducing grantee reporting burden and found positive results related to reductions in reporting time as well as reduced duplication. HHS incorporated ongoing stakeholder input during the pilot, and its findings contributed to government-wide initiatives related to federal reporting and reducing grantee-reporting burden.

The procurement (contracts) portion of the pilot, led by OMB with assistance from the General Services Administration (GSA), did not collect sufficient evidence to determine whether centralizing procurement reporting through a single web-based portal would reduce contractor reporting burden—a key objective of the pilot. The pilot planned to test the portal by collecting weekly Davis-Bacon wage data from a minimum of 180 contractors, potentially resulting in thousands of submissions over a year. However, in the end, the pilot did not result in any Davis-Bacon data due to lack of contractor participation and the absence of iterative and ongoing stakeholder engagement. Subsequently, OMB expanded the pilot to include hydrofluorocarbon (HFC) reporting but received only 11 HFC submissions. (See figure.) In addition, HFC reporting was not suited for assessing changes in reporting burden because it was a new requirement and thus no comparative data existed. OMB plans to expand its use of the portal for additional procurement reporting requirements but still does not have information from stakeholders that could help inform the expansion.

GAO recommends that the Director of OMB ensure that information is collected regarding how centralized reporting of procurement requirements might reduce recipient reporting burden—including input from stakeholders such as contractors through an iterative and ongoing process—to inform OMB's planned expansion of the Central Reporting Portal. OMB neither agreed nor disagreed with the recommendation but provided technical comments, which GAO incorporated as appropriate.

In fiscal year 2017, the federal government awarded $675 billion in grants  to state and local governments and $500 billion in contracts. Recipients of  these grants and contracts are required to report federal spending and a  range of other information to comply with applicable laws and regulations.  Grant recipients and federal contractors face challenges related to  duplicative and burdensome reporting when complying with these  requirements. Using standardized data and processes can reduce federal  reporting burden and increase the accuracy of data reported.

The Digital Accountability and Transparency Act of 2014 (DATA Act)  required the Office of Management and Budget (OMB) and the  Department of the Treasury to establish standardized government-wide  financial data standards. In addition, the DATA Act added section 5 to  the Federal Funding Accountability and Transparency Act of 2006  (FFATA), which provided an opportunity for simplifying reporting for  federal contracts, awards, and subawards. Toward that end, the act  required OMB, or a federal agency designated by OMB, to establish a  pilot program to test potential approaches for reducing reporting burden  for federal award recipients–-both grantees and contractors  (procurement). OMB was also charged with developing evidence-based  recommendations and guidance to federal agencies for eliminating  unnecessary duplication in financial reporting, and for reducing  compliance costs for federal award recipients based on the pilot findings.

The DATA Act includes a provision for us to review its implementation.  This report assesses the extent to which (1) the Section 5 Pilot met the  statutory requirements of the act, (2) the grants portion of the Section 5  Pilot demonstrated changes in federal award recipients’ reporting burden,  and (3) the procurement portion of the Section 5 Pilot demonstrated  changes in federal award recipients’ reporting burden.

To address these objectives, we assessed pilot activities by reviewing the  requirements for the pilot contained in the DATA Act as well as pilot plans  and data from agencies involved in administering and executing the pilot.  These agencies included the Department of Health and Human Services  (HHS), OMB’s Offices of Federal Financial Management (OFFM) and  Federal Procurement Policy (OFPP), and the General Services  Administration (GSA). We determined that the pilot data we reviewed  were reliable for the purposes of our work by reviewing the data, tracing  them back to underlying agency source documents, and interviewing  relevant agency staff. We also reviewed OMB documents including a  report to Congress and two memorandums to federal agencies based on  the findings of the pilot. We interviewed OMB staff as well as HHS and  GSA officials responsible for implementing the Section 5 Pilot. Additional  details regarding our objectives, scope, and methodology are provided in  appendix I.

We conducted this performance audit from November 2017 to April 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.

Signed into law on May 9, 2014, the DATA Act required OMB, or an  agency it designated, to establish a pilot program to facilitate the  development of recommendations for (1) standardized reporting elements  across the federal government, (2) elimination of unnecessary duplication  in financial reporting, and (3) reduction of compliance costs for recipients  of federal awards. To meet these requirements, OMB established a pilot  program with two components—one that focused on federal grants and  another on federal contracts (procurement). OMB designated HHS as the  executing agency of the grants portion of the Section 5 Pilot with  oversight from OFFM. OFPP was responsible for designing and leading  the procurement portion of the pilot focusing on reporting of Federal  Acquisition Regulation (FAR) procurement requirements. OFPP  collaborated with the Chief Acquisitions Officers’ Council and GSA on  specific aspects of implementation including the development of the  Central Reporting Portal, a reporting tool which is intended to centralize  FAR reporting. See figure 1 for a timeline of the activities undertaken by  the grants and procurement portions of the pilot as well as deadlines  required by the act.

As part of our ongoing oversight of the DATA Act’s implementation, we  have monitored OMB’s efforts to meet its statutory requirements related  to the Section 5 Pilot. In April 2016, we reported on the design plans for  the Section 5 Pilot. We found that HHS’s design for the grants portion of  the pilot was generally on track to meet statutory requirements and  partially adhered to leading pilot design practices. However, we also  reported that the procurement portion was not on track to meet  requirements, and that its plans did not follow leading pilot design  practices. In response to a recommendation in our report, OMB revised  its plan for the procurement portion to better reflect leading practices for  pilot design identified in our April 2016 report. These changes included  more fully documenting its data collection plans and including a sampling  plan to meet diversity requirements for pilot participants.

According to OMB staff, the ongoing work and related grants guidance  resulting from the Section 5 Pilot reflects a broader strategy for reducing  federal recipient reporting burden that is outlined in the President’s  Management Agenda (PMA). Released in March of 2018, and led by the  Executive Office of the President and the President’s Management  Council, PMA is a strategy to modernize how federal agencies deliver  mission outcomes and provide services in three key areas: (1) modern  information technology; (2) data, accountability, and transparency; and (3)  the workforce for the 21st Century.

Several Cross-Agency Priority (CAP) goals include PMA’s milestones and  activities. These CAP goals identify opportunities for multiple agencies to  collaborate on government-wide efforts and report on goal progress  quarterly. Two of these, CAP Goals 5 and 8, include strategies for  reducing federal award recipient reporting burden. OMB staff told us that  some of the findings from the Section 5 Pilot and recommendations from  their subsequent report to Congress informed the focus of these CAP  goals. For example, according to OMB staff, the grants portion of the  Section 5 Pilot focused on identifying how changes in grants data  collection and grant management may reduce federal recipient reporting  burden. PMA CAP Goal 8 is described as building on these efforts by  shifting the focus toward the life cycle of grants management and  standardizing grants management activities using agile technology.

Section 5 Pilot Met Many but Not All Statutory Requirements

We determined that the Section 5 Pilot fully met three of the DATA Act’s  statutory requirements, substantively met one, and partially met two  others. The Section 5 Pilot fully met the following statutory requirements:  (1) that pilot data collection cover a 12-month reporting cycle; (2) timely  issuance of OMB’s report to Congress in August of 2017 to select  congressional committees; and (3) that the report to Congress contain a  discussion of any needed legislative actions as well as recommendations  related to automating and streamlining aspects of federal financial  reporting to reduce the reporting burden of federal award recipients.

We found that the pilot also substantively met the requirement that the  pilot program include a combination of federal award recipients and an  aggregate value of awards of not less than $1 billion but not more than $2  billion. Although the $122 billion in grants included in the pilot greatly  exceeded the upper bound, this was principally a result of the decisions  by OFFM and HHS to pilot different test models for reducing reporting  burden, and to include a wide range of different types of grants. The total  value of grant awards exceeded the amount envisioned by the act.

OMB’s August 2017 report stated that the decision to go beyond the  minimum requirement of testing one approach was made in the interest of  achieving the DATA Act’s objective to identify ways to reduce reporting  burden as well as the effect this decision would have on the aggregate  value of grants sampled. We believe that the pilot substantively met this  requirement and did not identify any negative effects related to the larger  aggregate value of grants, contracts, and subawards included in the  grants portion of the pilot. We found that the approach followed by OMB  and HHS furthered the broader objective identified by this section of the  act.

In addition, we determined that the pilot partially met two of the act’s  requirements. The first of these requirements concerns the act’s  requirement that OMB’s report to Congress include a description of the  data collected, the usefulness of the data provided, and the cost to collect  pilot data from participants. The report that OMB issued to Congress in  August 2017 included information on the first two of these but only partly  addressed the third. Specifically, it contained cost information for only the  grants portion of the pilot, stating that the cost associated with executing  this portion during fiscal years 2015 through 2017 was more than $5.5  million. The report did not contain any cost information on the  procurement portion of the pilot.

The DATA Act also required that OMB issue guidance to agencies for  reducing reporting burden for federal award recipients—including both  grantees and contractors—but the guidance subsequently issued only  pertained to the grants community. We determined that OMB only  partially met this requirement. On September 5, 2018, OMB issued M-18- 24: Strategies to Reduce Grant Recipient Reporting Burden. Among other  things, this memorandum contained guidance to federal agencies making  the SF-424B form optional based on findings from the grants portion of  the pilot. Form SF-424B is used by grantees to document assurances  regarding their compliance with a wide range of rules and regulations.  Figure 2 summarizes our assessment.

The Grants Portion of the Pilot Identified Several Ways to Reduce Reporting Burden and Provided Support for Government-Wide Streamlining Efforts All Six Grant Test Models Reported Evidence of Reducing Burden, Increasing Accuracy, or Both

As the agency designated by OMB to execute the grants portion of the  Section 5 Pilot, HHS developed and analyzed six “test models” to  determine if adopting the proposed changes would contribute to the pilot  program’s objectives of reducing reporting burden and duplication. These  test models examined a variety of grant reporting issues that HHS had  identified as presenting challenges. All but one of the test models, the  Common Data Element Repository (CDER) Library 2, based their findings  on data collected from grantees.

The text box below provides high-level summaries of each of the six  models. Additional details on the approach followed for each model, as  well as reported results, can be found in appendix II.

OMB Used Findings from the Grants Portion of the Pilot to Support Recommendations and Government-wide Guidance for Reducing Grantee Reporting Burden

OMB’s August 2017 report to Congress on the findings of the Section 5  Pilot contained three broad recommendations and stated that OMB plans  to take action on these recommendations. These recommendations  covered (1) standardizing core data elements, (2) eliminating duplication  through auto-population of data, and (3) leveraging information  technology open data standards to develop new tools across the federal  government. We found that evidence from the grant test models  supported all three recommendations for streamlining federal reporting  discussed in the report. For example, OMB recommended that its staff  standardize core data elements used for managing federal financial  assistance awards based on reductions in administrative burden  experienced in the CDER Library 1 test model. In another example, four  test models supported OMB’s recommendation for increased use of data  auto-population from existing federal data sources as a way to reduce  duplication in reporting.

Findings from the grants portion of the Section 5 Pilot also provided  support for government-wide efforts to streamline reporting and reduce  recipient reporting burden. These include OMB’s memorandum M-18-24:  Strategies to Reduce Grant Recipient Reporting Burden, which discusses  efforts to automate and centralize grant management processes. Among  other things, M-18-24 requires that federal agencies evaluate the systems  and methods currently used to collect information from grant recipients to  eliminate duplicative data requests. OMB staff confirmed that M-18-24  incorporates findings from some of the test models of the grants portion of  the pilot such as the Single Audit test model, which examined reducing  duplicative reporting of grant recipients’ data. The efforts to reduce  duplicative reporting in M-18-24 also align with OMB’s recommendation in  its August 2017 report to Congress to eliminate unnecessary duplication  in reporting by leveraging information technology that can auto-populate  from existing data sources.

In addition, OMB staff told us that findings from the grants portion of the  pilot contributed to broader, government-wide initiatives related to federal  reporting. For example, according to OMB staff, the three  recommendations from the August 2017 report to Congress are reflected  in CAP Goal 8 of the President’s Management Agenda, which focuses on  results-oriented accountability for grants. These OMB staff also told us  that findings from the grants portion of the pilot informed two CAP Goal 8  strategies. For example, the CAP Goal 8 grants management strategy  focuses on standardizing grants management business processes and  data. OMB developed a comprehensive taxonomy for core grants  management data standards that is currently available for public  comment. In addition, a second strategy focuses on incorporating a risk- based performance management approach to metrics in grant award  operations to determine low-risk and high-value federal awards. CAP  Goal 8 also states plans to streamline the 2019 Single Audit Compliance  Supplement to focus on requirements that inform grant award  performance.

Procurement Portion of Pilot Did Not Result in Sufficient or Appropriate Data to Assess Changes in Contractors’ Burden Reduction Lack of Contractor Participation and the Absence of Iterative and Ongoing Stakeholder Engagement Limited the Ability of Procurement Pilot to Achieve its Objectives

Unlike the grants portion of the pilot, the procurement portion did not  result in data collection that could be used for an evidence-based  assessment of ways to reduce reporting burden. OMB’s Office of Federal  Procurement Policy (OFPP) sought to assess five test models that,  according to the report to Congress, were essential to centralized  procurement reporting. However, the pilot did not fully test any of the  hypotheses associated with those test models. The reasons for not  testing the hypotheses included a lack of contractor participation and a  lack of iterative and ongoing stakeholder participation and engagement  throughout the course of the pilot. See appendix III for additional  information regarding the various procurement test models, associated  hypotheses, and additional details regarding our assessment.

The procurement portion of the pilot focused entirely on the development  and testing of a central reporting portal to consolidate FAR reporting  requirements. According to OFPP staff, the pilot intended to eventually  identify ways to centralize a wide range of reporting requirements that  contractors currently meet through decentralized methods. Contractors  must report many types of information depending on the contract. Toward  that end, OFPP, with the assistance of GSA, created a procurement  reporting website called the Central Reporting Portal. To test the efficacy  of this portal for reducing burden, OFPP initially decided to examine how  well it handled a specific FAR reporting requirement—the reporting of  payroll data in accordance with the Davis-Bacon Act. According to pilot  plans, Davis-Bacon reporting requirements were selected because they  were identified by contractors as “pain points” during initial stakeholder  outreach conducted in 2014 and 2015. OFPP planned to collect and  analyze 1 year of weekly Davis-Bacon wage reporting data from at least  180 contractors through the Central Reporting Portal to identify how  centralized reporting might reduce contractor reporting burden.

However, during the 12-month procurement data collection period, no  contractors agreed to submit their Davis-Bacon data as part of the pilot.  Consequently, OFPP did not collect any wage data. Despite OFPP  stating in its plans and reiterating to us as late as September 2017 that it  expected to be able to secure at least 180 pilot participants, only one  contractor expressed interest in reporting its Davis-Bacon information  using the portal. This contractor withdrew from the pilot before  submitting any data through the Central Reporting Portal. OFPP staff told  us they were aware of the potential for low pilot participation for Davis- Bacon reporting when pilot testing began in February 2017 because  contractors already had established processes for fulfilling the highly  complex Davis-Bacon reporting requirements, and pilot participation was  optional. According to GSA contracting staff, the one contractor who  initially expressed interest ultimately decided not to participate because  the format in which the contractor tracked and reported payroll data was  incompatible with that used by the pilot portal, resulting in additional  burden.

However, it was not until August 2017—approximately 7 months into its  year-long data collection period—that specific steps were taken to  address the fact that the procurement portion of the pilot had not collected  any data from Davis Bacon contractors. During this period OFPP did not  conduct pilot outreach activities with the contractors, who were key to  successful implementation of the pilot. OFPP staff told us that at the time  of the pilot launch they learned that contractors were interested in having  the Central Reporting Portal be able to communicate with third-party  payroll reporting systems to automate reporting. OFPP staff said that  although they are exploring this possibility, it was not a capability that was  included as part of the pilot. Had this type of feedback on stakeholder  needs been obtained sooner, OMB could have explored the feasibility of  adding this capability to the portal or engaged in communication with  stakeholders to develop alternate approaches that might have persuaded  more contractors to participate.

The usefulness of iterative and ongoing communication is recognized by  the Standards for Internal Control in the Federal Government. Those  standards state that management should use quality information to  achieve its objectives, and that management should collect quality  information by engaging with stakeholders through iterative and ongoing  processes and in a timely manner. In this case, key stakeholders include  relevant agencies, contracting officials, and contractors using the system.  OFPP’s plan for the procurement portion of the pilot recognized the  importance of stakeholder engagement stating that, to include a diverse  group of recipients in the pilot, they should identify eligible participants for  the pilot, conduct outreach to identify participants, and repeat this process  as necessary until they achieved the sample necessary to test the Central  Reporting Portal. However, as previously stated, no contractors agreed  to submit their Davis-Bacon data as part of the pilot. Therefore, OFPP did  not repeat this process until the pilot obtained the necessary sample size.  Such interactions could have provided important information on  contractors’ needs and concerns that OFPP could have used to inform  their decisions regarding the pilot’s implementation.

Expansion of Procurement Pilot to Include Hydrofluorocarbon Reporting Had Limitations

In November 2017, OFPP expanded the type of data accepted by the  pilot to include hydrofluorocarbon (HFC) reporting, a new FAR reporting  requirement. However, this choice had limitations in its suitability for  providing useful data for testing the hypotheses of the five procurement  test models. Unlike Davis-Bacon reporting, where contractors submit  weekly reports, HFC is an annual reporting requirement for contractors  that emit HFC gases over a certain threshold. The Central Reporting  Portal is the only location where contractors can submit HFC reporting.  For the purposes of the pilot, the Central Reporting Portal accepted HFC  submissions from November 2017 through February 2018.

During the pilot, 11 HFC annual reports were submitted to the portal (see  figure 3). As a result of the small number of reports collected, OMB  collected much less data than it had initially expected to receive to test  the capabilities of the Central Reporting Portal. If the procurement portion  of the pilot had been executed as planned, it could have theoretically  resulted in 9,360 Davis-Bacon submissions for analysis. A larger data  set of contractors’ experiences using the Central Reporting Portal could  have informed OMB’s decision-making process through analysis of more,  and potentially more varied data.

In addition to the small number of submitted HFC annual reports, the  decision to switch to using HFC data had another limitation. These data  could not be used to examine changes in reporting burden as a result of  using the Central Reporting Portal. This is because HFC reporting was a  new reporting requirement, and as such, it did not have an established  reporting process to use as a point of comparison to assess changes in  reporting burden. The objective of the procurement pilot was to assess  how centralized reporting can reduce reporting burden. This objective  could not be achieved without data on the existing reporting burden.

OMB’s Recommendations for Streamlining Reporting Were Not Supported by Findings from the Procurement Portion of the Pilot

Evidence from the procurement portion of the pilot did not support OMB’s  government-wide recommendations for reducing reporting burden in its  August 2017 report to Congress. As previously stated, OMB’s report to  Congress included three recommendations that focused on (1)  standardizing core data elements, (2) eliminating duplication by using  data auto-population, and (3) leveraging information technology open  standards to develop new tools. As support for the first recommendation,  the report stated that results from the procurement pilot test models  demonstrated that standard data elements—coupled with uniform data  adoption—and the ability to centrally collect and share information  reduces administrative burden. Since the procurement portion of the pilot  did not gather or analyze any pilot data from the Davis-Bacon  participants, OMB did not assess the extent to which the ability to  centrally collect data actually reduces burden.

Recommendation two stated that support from the procurement test  model demonstrated that recipient burden is reduced when identical data  can be entered once in one place and reused. However, the HFC data  collection process did not reuse data when capturing information and did  not have the ability to auto-populate data. HFC data collection was the  only part of the procurement portion of the pilot that collected information  that could have been used to inform this recommendation. According to  OFPP staff, the Davis-Bacon portion of the portal had the capability to  auto-populate data. However, no Davis-Bacon data were collected that  would have allowed quantification of the effects of reusing data on  reporting burden. OMB stated that support for the third recommendation  included data and information collected from the pilot. Although there was  some consultation with stakeholders during initial planning and design of  the procurement portion of the pilot and the early development of the  portal, the pilot did not actually collect any data from either Davis-Bacon  contractors or through the HFC portion of the pilot in the data gathering  and analysis portion of the pilot related to this recommendation.

OMB Plans to Expand Use of the Central Reporting Portal to Streamline Reporting of FAR Requirements

In August 2018, OMB announced plans to expand the use of the Central  Reporting Portal for FAR reporting, stating that the portal allows  contractors to report data to one central location. OFPP staff told us that  they are considering centralizing a third FAR requirement using the portal  in the future but have not yet determined what that will be. As discussed  above, the procurement portion of the pilot did not collect sufficient data  to test the effect of the portal on reporting burden. In addition, the plan for  the procurement portion states that OFPP intended to analyze feedback  on pilot data collection and, depending on that feedback, decide whether  to expand the pilot to other FAR reporting requirements. However, the  pilot did not collect any such feedback to inform its determination to  expand the Central Reporting Portal in the future. As a result, OFPP has  limited information regarding issues that could affect expanded use of the  Centralized Reporting Portal. In the absence of such information, it is  difficult for OFPP to determine whether continued or expanded use of the  Central Reporting Portal will reduce reporting burden, and which  additional FAR requirements, if any, to include.

To reduce the burden and cost of reporting for recipients of federal funds,  Congress included specific provisions in the DATA Act to encourage  OMB to take a deliberate and evidence-based approach toward  developing guidance for federal agencies in this area. The Section 5 Pilot  offered OMB a valuable opportunity—namely, to test a variety of methods  and techniques at a small scale before applying them more widely. Such  a process may enhance the quality, credibility, and usefulness of  evaluations in addition to helping to ensure that time and resources are  used more effectively. Similar to what we found when we analyzed the  design of the Section 5 Pilot in 2016, our review of its implementation and  the results it produced found differences between the grant and  procurement portions.

OMB and HHS designed and executed a robust grants portion of the pilot  that tested several different approaches for reducing the reporting burden  experienced by federal grant recipients. The resulting findings were used  to develop OMB’s government-wide recommendations, and to inform two  subsequent goals in the 2018 President’s Management Agenda related to  reducing recipient reporting burden.

In contrast, OMB did not fully implement the procurement portion of the  pilot consistent with its plans. The procurement portion did not collect  data to test the hypotheses associated with any of its five test models,  and therefore could not provide empirical support for either OMB’s  government-wide recommendations or guidance related to reducing  reporting burden. Among the factors responsible for this were the lack of  Davis-Bacon contractor participation and OMB’s inability to find a suitable  alternative. OMB has announced its intention to expand centralized  reporting for FAR requirements across government. In the absence of  timely information regarding the needs and concerns of stakeholders,  OMB faces the risk of experiencing implementation challenges similar to  those it experienced during the pilot. Although the use of a centralized  reporting portal could ultimately prove useful for reducing burden, the lack  of information from stakeholders—including the contractors who would  use it—raises concerns about the future success of plans for expanding  the Central Reporting Portal.

The Director of OMB should ensure that information is collected regarding  how centralized reporting of procurement requirements might reduce  recipient reporting burden—including input from stakeholders such as  contractors through an iterative and ongoing process—to inform OMB’s  planned expansion of the Central Reporting Portal.

We provided a draft of this report to OMB, HHS, and GSA for review and  comment. HHS and GSA informed us that they had no comments. OMB  provided technical comments, which we incorporated as appropriate.  OMB neither agreed nor disagreed with our recommendation.

We are sending copies of this report to the appropriate congressional  committees, The Secretary of Health and Human Services, The Acting  Director of OMB, the Administrator of GSA, 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 staff have any questions about this report, please contact  me at 202-512-6806 or sagerm@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of our report. GAO staff who made key contributions to this report  are listed in appendix IV.

To assess the extent to which the pilot met statutory requirements we  reviewed section 5 of the Federal Funding Accountability and  Transparency Act of 2006, as amended by the Digital Accountability and  Transparency Act of 2014, to determine the legal requirements set forth in  the act pertaining to establishing, designing, and executing the Section 5  Pilot. We compared these requirements to documents from the Office of  Management and Budget (OMB) and designated agencies. These  documents included pilot plans for the grants and procurement portions of  the pilot, OMB’s August 2017 report to Congress, M-18-23: Shifting from  Low-Value to High-Value Work and M-18-24: Strategies to Reduce Grant  Recipient Reporting Burden. We also interviewed staff from agencies  involved in administering and executing the pilot on how they carried out  their responsibilities. These agencies included the Department of Health  and Human Services (HHS), OMB’s Offices of Federal Financial  Management (OFFM) and Federal Procurement Policy (OFPP), and the  General Services Administration (GSA).

To assess the extent to which the grants portion of the Section 5 Pilot  demonstrated changes in federal award recipients’ reporting burden, we  reviewed HHS’ plans. We analyzed the plans compared to information  collected from the various test models throughout the pilot. The data we  assessed included survey data and analyses. We also assessed whether  statements on changes in grantees’ reporting burden made in OMB’s  August 2017 report to Congress were supported by documentation. We  did this by verifying the statements against supporting information. We  determined that the pilot data we reviewed were reliable for the purposes  of our work by reviewing the data, tracing them back to underlying agency  source documents, and interviewing relevant agency staff. We also  interviewed OFFM staff and HHS officials on how the grants portion of the  pilot was executed.

To assess the extent to which the procurement portion of the pilot  demonstrated changes in reporting burden, we reviewed OMB’s plans  and compared them to actions OMB took to execute the pilot. We  compared OMB’s actions to execute the procurement portion of the pilot  against criteria identified in Standards for Internal Control in the Federal  Government. We viewed a demonstration of the Central Reporting Portal  tool for reporting Davis-Bacon and hydrofluorocarbon (HFC) submissions.  GSA developed the portal and OFPP provided oversight for the portal’s  development. We also reviewed documentation including HFC reporting  submissions made through the portal. In addition, we interviewed OFPP  staff, GSA officials responsible for administering the portal, and three  contracting officials from GSA who were assigned to participate in the  Davis-Bacon component of the procurement portion of the pilot regarding  their actions related to implementing the procurement portion of the pilot.

Appendix II: Description of Test Models from Grants Portion of the Section 5 Pilot

This appendix provides detailed information regarding the test models  from the grants portion of the Section 5 Pilot.

The Common Data Element Repository Library 1 Test Model

The Common Data Element Repository (CDER) Library is an online  repository for federal grants-related data standards, definitions, and  context. The library is intended to be an authorized source for data  elements and definitions for use by the federal government and for  recipients reporting grant information.

Hypothesis: If grant recipients are provided with definitions of data  elements through the CDER Library, then they will be able to  accurately complete forms in a timely manner.

Methodology: The Department of Health and Human Services (HHS)  divided test model participants into two groups to read a scenario  based on the grants lifecycle and complete a data collection tool. The  first group used the CDER Library to complete the data collection tool  while the second group used all other available sources to complete  the data collection tool. After completion of the data collection tool,  test model participants filled out a survey about their experiences  using the CDER Library.

Test Model Metrics: Accuracy and completeness of captured data  within a period of time and survey results.

Example of Test Model Results: On average, test model  participants that completed a data collection tool using the CDER  Library scored 11 percent higher in the accuracy of information  requested and, on average, spent 6 fewer minutes when completing  the tool.

Number of Test Model Participants: Fifty-nine.

The Common Data Element Repository Library 2 Test Model

The CDER Library 2 Test Model focused on identifying duplication in  grant forms and data elements across the federal government based on  the data standards, definitions, and context within the CDER Library 1.

Hypothesis: If duplication across forms can be identified using the  CDER Library, then agencies can update or reduce forms to reduce  grant recipient burden.

Methodology: HHS conducted an internal analysis of SF-424 form  families, using the CDER Library, to identify duplication in data  elements to determine which forms could be consolidated.

Test Model Metrics: Number of duplicative fields within form families  and across forms for selected federal entities

Example of Test Model Results: The internal analysis conducted by  HHS identified 371 instances of data element duplication across 10  agency grant funding applications when using standardized data  elements from the CDER Library 1.

Number of Test Model Participants: Not Applicable; the CDER 2  Library Test model did not collect information from test model  participants because the test model was an internal document review.  The CDER Library 2 test model tested the utility of the data element  definitions within the CDER Library 1.

The Consolidated Federal Financial Report Test Model

The Consolidated Federal Financial Report Test Model focused on  examining the potential early validation of consolidated CFFR data and  potential future streamlining of the close-out process by allowing the  submission of Federal Financial Report (FFR) data in one system, rather  than in multiple entry systems.

Hypothesis: If grant recipients can enter complete FFR information  systematically through one entry point instead of multiple different  avenues and that information could be shared electronically from that  point forward, then grant recipient burden will be reduced and data  accuracy will be improved.

Methodology: HHS surveyed Administration for Children and  Families grant recipients on their experience submitting a  consolidated FFR via HHS’s Payment Management System, and  grantees on their perceptions of the process for using a consolidated  FFR through facilitated discussions.

Example of Test Model Results: Sixty-four percent of the CFFR test  model participants reported that submitting their FFR through a single  system would result in reduced reporting time. In addition, 65 percent  of the CFFR test model participants believed using the payment  management system for submitting FFR data would improve the  accuracy of the information they submitted.

Number of Test Model Participants: One-hundred fifteen tested the  pilot environment and 30 participated in the facilitated discussions.

The Single Audit Test Model consisted of (1) an audit and opinions on the  fair presentation of the financial statements and the Schedule of  Expenditures of Federal Awards; (2) gaining an understanding of and  testing internal control over financial reporting and the entity’s compliance  with laws, regulations, and contract or grant provisions that have a direct  and material effect on certain federal programs (i.e., the program  requirements); and (3) an audit and an opinion on compliance with  applicable program requirements for certain federal programs. The  Single Audit Test Model focused on reducing reporting of data on  duplicative forms.

Hypothesis: If grant recipients do not have to report the same  information on duplicative forms—for example, the SEFA compared to  the Single Audit Report Package and Data Collection Form—then  grant recipients’ burden will be reduced.

Methodology: HHS collaborated with the Office of Management and  Budget’s Office of Federal Financial Management and the Department  of Commerce Federal Audit Clearinghouse (FAC) to create a pilot  environment for test model participants to submit key portions of a  modified Standard Form—Single Audit Collection. HHS conducted  two focus groups with test model participants subject to the Single  Audit. The first focus group discussed and completed a survey on the  new form. The second group, a sample of test model participants who  are subject to perform a Single Audit submitted the existing form in  the FAC pilot environment, completed a separate data collection form  similar to the new form, and completed a survey on the effectiveness  and burden of the new form.

Test Model Metrics: Focus group feedback and survey results.

Example of Test Model Results: All test model participants with  access to the Single Audit’s pilot environment believed the upload  feature for reporting requirements could decrease duplication in  required grant reporting.

Number of Test Model Participants: Thirteen tested the pilot  environment and 123 participated in facilitated discussions.

This model focused on the feasibility of developing a standardized Notice  of Award (NOA) to reduce reporting burden and facilitate access to  standardized data needed to populate Single Audit information  collection.

Hypothesis: If grant recipients have a standardized NOA for federal  awards, then grant-reporting burden may be reduced for recipients by  standardizing access to data needed to populate information  collections.

Methodology: HHS divided test model participants into two groups  and completed a data collection tool. The first group completed the  data collection tool using three standardized NOAs, while the second  group completed the data collection tool using three non-standardized  NOAs. After completion of the data collection tool, test model  participants self-reported their respective times to complete the data  collection tool. They also filled out a survey about the standardized  NOA’s impact on reporting burden and provided input on elements to  include in a standardized NOA.

Test Model Metrics: Self-reported form completion time, accuracy,  and survey results.

Example of Test Model Results: Test model participants with  access to the standardized NOA coversheets spent an average of 3  minutes less when completing the test model’s data collection tool.

Number of Test Model Participants: One-hundred four.

The Learn Grants Test Model is a website on Grants.gov that  summarizes and provides links to new and important grants information  such as policies, processes, funding, and other information needed  throughout the grants life cycle. The website intended to make it easier  for stakeholders to find, learn about, and apply for federal grants and  promote the standardization of grants terminology and data.

Hypothesis: If grant recipients are supplied with grants life cycle  information in one website, then they will have increased access to  grants resources and knowledge of the grants life cycle process.

Methodology: HHS developed a grants knowledge quiz from  information on the Learn Grants website. HHS administered the  knowledge quiz to test model participants in two phases. First, test  model participants completed the knowledge quiz using existing  knowledge and without the Learn Grants website. Next, test model  participants completed the knowledge quiz with access to the Learn  Grants website. HHS compared the results from both knowledge  quizzes. After completion of the knowledge quiz, test model  participants completed a survey on the usefulness of the Learn Grants  website and its impact on increasing knowledge quiz scores.

Test Model Metrics: Knowledge quiz accuracy and survey results on  the usefulness of Learn Grants website.

Example of Test Model Results: Test model participants  experienced an average 10 percent (one quiz point) increase in their  grant knowledge quiz scores when using the Learn Grants website.  New grantees who participated in the test model also reported that the  Learn Grants website provided useful grants information.

Number of Test Model Participants: Fifty-seven.

Appendix III: Assessment of Test Models in the Procurement Portion of the Section 5 Pilot

Appendix III: Assessment of Test Models in the  Procurement Portion of the Section 5 Pilot Hypothesis not tested.

Hypothesis:  Verification of FAR standards for post award  reporting will confirm the value of existing  data standards and reduce variations that  will, in turn, reduce contractor burden and  cost.

Original plan (Davis-Bacon):  OFPP planned to execute this test model through focus  groups. According to OFPP, no focus groups were  conducted.  Revised Strategy (HFC):  This hypothesis could not be tested through HFC reporting  because it was a reporting requirement without an existing  reporting method through which to compare reporting  burden.

Original Strategy (Davis-Bacon):  OFPP planned to test this hypothesis by gathering data on  the time it takes to submit reporting data through the  Central Reporting Portal and outside of the portal, with  self-reported data from contractors. According to OFPP,  data were not collected due to a lack of participation in the  Davis-Bacon portion of pilot.  Revised Strategy (HFC):  This hypothesis could not be tested through HFC reporting  because it was a reporting requirement without an existing  reporting method through which to compare reporting  burden.

Procurement Test Model and Hypothesis GAO’s Assessment 4. Consolidate data collection and Hypothesis not tested.

Hypothesis:  If contractors can enter FAR-required  reporting data systematically through one  entry point instead of multiple different  avenues, and that information can be shared  electronically with appropriate individuals,  then contractor burden will be reduced and  data access improved.

Assessment Rationale  Original plan (Davis-Bacon):  OFPP planned to test this hypothesis by gathering data on  the time it takes to submit reporting data through the  Central Reporting Portal and outside of the portal, with  self-reported data from contractors. OMB also planned to  conduct guided discussions. According to OFPP, data  were not collected due to a lack of participation in the  Davis-Bacon portion of pilot.  Revised Strategy (HFC):  This hypothesis could not be tested through HFC reporting  because it was a reporting requirement without an existing  reporting method with which to compare reporting burden.

Hypothesis not tested, but  metric associated with test  model was met.

Hypothesis:  If interfaces can be built to support access to  other reporting systems, contractor burden  will be reduced.

Original plan (Davis-Bacon):  According to OFPP staff, the Davis-Bacon part of the  Central Reporting Portal was able to provide prepopulating  of data by interfacing with other reporting systems or drop  down menus for all reporting fields. However, it could not  demonstrate that such prepopulation resulted in a  reduction of contractor burden.  Revised Strategy (HFC):  This is not applicable for HFC reporting which is reported  through open fields.

Although OFPP did not actually test the hypothesis associated with this test model, it did meet the  metric that it had associated with the test model in its pilot plan. That metric is to develop  prepopulating capabilities in the Central Reporting Portal by interfacing with other reporting systems.

Appendix IV: GAO Contact and Staff Acknowledgments

In addition to the contact named above, Peter Del Toro, Assistant  Director; Silvia Porres-Hernandez, Analyst-in-Charge; Jazzmin Cooper;  and Jimmy Nunnally made major contributions to this report. Also  contributing to this report in their areas of expertise were Michael  Bechetti, Jenny Chanley, Mike LaForge, Carl Ramirez, Stewart Small,  Andrew J. Stephens, James Sweetman Jr., and Tatiana Winger.

Some recipients of federal grants and contracts say the accompanying paperwork can be duplicative and burdensome.

The Office of Management and Budget led a pilot on how to reduce the reporting burden for grants and contracts. The grants portion of the pilot found ways to reduce reporting time and duplication, and resulted in OMB's issuing guidance. However, we found that the contracts portion of the pilot did not collect sufficient information to test whether its new central reporting portal will actually reduce reporting burden.

We recommend that OMB gather additional information before deciding whether to move ahead with the portal.


Federal Research: Agency Actions Could Strengthen Scientific Integrity Policies

This testimony summarizes the information contained in GAO's April 2019 report, entitled Scientific Integrity Policies: Additional Actions Could Strengthen Integrity of Federal Research ( GAO-19-265 ).

The nine selected agencies GAO reviewed have taken various actions to help achieve the objectives of their scientific integrity policies in three areas:

Educating staff. Seven of the nine agencies have taken some actions to educate and communicate to staff about their policies, consistent with the 2007 America COMPETES Act. However, the Office of Fossil Energy (FE), which follows the Department of Energy's (DOE) policy, and the National Institute of Standards and Technology (NIST) have not taken action.

Providing oversight. Eight of the nine agencies have a designated official, or the equivalent, to oversee implementation of their scientific integrity policies. However, FE does not have such an official because DOE has not appointed one and currently has no plans or timeframe to do so, although DOE policy states that DOE will appoint an official for oversight.

Monitoring and evaluating implementation. Four of the nine agencies have monitored and evaluated implementation of their scientific integrity policies, consistent with federal standards that call for such control activities. However, FE, the Federal Aviation Administration (FAA), NIST, the National Oceanic and Atmospheric Administration (NOAA), and the U.S. Geological Survey (USGS) have not undertaken such activities.

Seven of the nine agencies have specific, documented procedures for identifying and addressing alleged violations of their scientific integrity policies. Although the details of agencies' procedures vary, they generally include the steps shown below. However, two agencies—FE, following DOE's policy, and the National Aeronautics and Space Administration (NASA)—do not have documented procedures for identifying and addressing alleged violations. A 2009 presidential memo on scientific integrity states that agencies should have procedures to identify and address instances in which the scientific process or the integrity of scientific and technological information may be compromised. Without procedures, FE and NASA do not have assurance that their staff understand how to report allegations and that investigations are conducted consistently.

I am pleased to be here today to discuss our report on federal agencies’  establishment of scientific integrity policies.

As you know, allegations of agency officials inappropriately influencing  science have been reported in the federal government. For example, the  Union of Concerned Scientists, in 2004 and 2008, and the National  Aeronautics and Space Administration’s (NASA) Office of Inspector  General (OIG), in 2008, reported instances in which political influences or  other agency actions adversely affected the integrity of scientific  information. More recently, the Union of Concerned Scientists surveyed  federal scientists in 2018, and many respondents reported censorship of  their work, especially work related to climate change.

In 2007, Congress passed the America Creating Opportunities to  Meaningfully Promote Excellence in Technology, Education, and Science  (COMPETES) Act, which required the Office of Science and Technology  Policy (OSTP) to develop an overarching set of scientific integrity  principles. According to the act, these principles should ensure the  communication and open exchange of data and results from research  conducted by federal scientists and prevent the intentional or  unintentional suppression or distortion of such research findings. OSTP  issued guidance, most recently in 2010, to the heads of executive  departments and agencies on implementing scientific integrity policies.  OSTP’s guidance states that scientific integrity is important because,  among other things, scientific and technological information is often a  significant contributor to the development of sound public policy. In  response to the 2010 guidance, 24 federal departments and agencies  developed scientific integrity policies.

My testimony today summarizes the findings and recommendations from  our April 2019 report. Accordingly, this testimony addresses the extent to  which selected agencies (1) have scientific integrity policies that are  consistent with federal guidance, (2) have taken actions to achieve the  objectives of their scientific integrity policies, and (3) have procedures for  identifying and addressing alleged violations of their scientific integrity  policies.

For all three objectives, we selected a nongeneralizable sample of nine  agencies—seven agencies from cabinet-level departments and two  independent agencies. We selected these nine agencies because they  are civilian federal agencies that conduct scientific research, employ  federal scientists, and were among the federal agencies with the greatest  levels of funding for intramural research (i.e., research conducted by  federal agencies in their own facilities). Our findings are not generalizable  to all agencies but provide illustrative examples of these agencies’  scientific integrity policies and their actions to implement those policies.  The agencies we selected are the

Agricultural Research Service (ARS) in the U.S. Department of  Agriculture (USDA);

Environmental Protection Agency (EPA), an independent agency;

Federal Aviation Administration (FAA) in the Department of  Transportation (DOT);

Office of Fossil Energy (FE) in the Department of Energy (DOE);

National Institutes of Health (NIH) in the Department of Health and  Human Services (HHS);

National Institute of Standards and Technology (NIST) in the  Department of Commerce (Commerce);

National Oceanic and Atmospheric Administration (NOAA) in

U.S. Geological Survey (USGS) in the Department of the Interior.

We reviewed the nine agencies’ scientific integrity policies, procedures,  and related documents. Some agencies we selected do not have agency- specific scientific integrity policies or procedures because they follow  department-level policies or procedures. In those cases, we included the  department’s policy and procedures in our analyses. For our reporting  purposes, we describe an agency as having a policy or procedure even in  those cases where the agency is following a department-level policy or  procedure.

To determine the extent to which the selected agencies have policies that  are consistent with federal guidance on scientific integrity, we compared  the selected agencies’ scientific integrity policies and supporting  documents to two of the four principles identified in OSTP’s guidance: (1)  foundations of scientific integrity in government and (2) professional  development of government scientists and engineers. We focused on  these two principles because they most closely align with scientific  integrity issues related to political influence. To determine the extent to  which selected agencies have taken actions to achieve the objectives of  their scientific integrity policies, we compared agencies’ scientific integrity  policies and actions against Standards for Internal Control in the Federal  Government related to communicating information to staff, providing  oversight, and monitoring and evaluating performance. To determine  the extent to which the selected agencies have procedures for identifying  and addressing alleged violations of their scientific integrity policies, we  compared the agencies’ procedures to guidance on scientific integrity  policies and federal standards for internal control. Additional information  on our scope and methodology is available in our report. The work on  which this testimony is based was conducted from March 2018 to April  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.

Selected Agencies Have Scientific Integrity Policies That Are Generally Consistent with Federal Guidance

In our April 2019 report, we found that all nine of the selected agencies  have policies that are generally consistent with OSTP’s guidance for the  principles of scientific integrity that we reviewed: foundations of scientific  integrity in government and professional development of government  scientists and engineers. OSTP’s guidance describes several  components for each of these principles, which the selected agencies  addressed either (1) through their scientific integrity policies, (2) in related  policies, or (3) through related actions. For example, when addressing the  components of foundations of scientific integrity in government, NOAA’s  scientific integrity policy states that the agency will ensure the free flow of  scientific information online and in other formats, consistent with privacy  and classification standards, and in keeping with other Commerce and  NOAA policies. In another example, NASA’s scientific integrity policy  states that NASA facilitates the free flow of scientific and technological  information among scientists and engineers, between NASA staff and the  scientific and technical community, and between NASA employees and  the public. The policy goes on to cite additional NASA policies on  dissemination of information and public access to data.

Similarly, we found that all nine selected agencies addressed all of the  components of the principle professional development of government  scientists and engineers. For example, EPA’s policy states that the  agency encourages publication and presentation of research findings in  peer-reviewed, professional, or scholarly journals and at professional  meetings. NIST’s scientific integrity policy states that the agency supports  scientists’ full participation in professional or scholarly societies,  committees, task forces, and other specialized bodies of professional  societies, with proper legal review and approval. The policy goes on to  cite separate NIST guidance for staff on how to seek approval for  memberships and participation in professional organizations.

All of the Selected Agencies Took Some Action to Achieve Policy Objectives, but Opportunities Exist for Furthering Those Objectives

We found in our April 2019 report that the nine selected agencies have  taken some actions to help achieve the objectives of their scientific  integrity policies in the three areas we reviewed—communicating  information to staff, providing oversight, and monitoring and evaluating  performance.

First, according to our analysis, seven of the nine selected agencies have  taken some actions to educate and communicate to staff about their  scientific integrity policies, and two have not. Specifically, FE and NIST  have not provided scientific integrity training for staff, according to  officials, or taken other actions to promote their scientific integrity policies  with staff. Under the 2007 America COMPETES Act, civilian agencies  that conduct scientific research are, among other things, required to  widely communicate and readily make accessible to all employees their  scientific integrity policies and procedures. According to FE and NIST  officials, the agencies made their policies available to staff on their  websites and believed no additional actions were needed. By taking  action to educate and communicate their scientific integrity policies to  staff through, for example, regular training, these agencies would have  better assurance that employees have the information, skills, and  competencies they need to help achieve agency scientific integrity  objectives. We recommended the Secretary of Energy and Director of  NIST take action to educate and communicate the agencies’ polices to  staff through, for example, regular training. In DOE’s written comments on  a draft of our report, reproduced in our final report, the department  explained that it will designate a scientific integrity official to be  responsible for leading and coordinating with other offices across DOE to  develop measures to educate and communicate to staff about scientific  integrity policies. In Commerce’s written comments, reproduced in in our  final report, NIST identified ways it plans to provide training to its staff.

Second, we found that eight of the nine selected agencies have  designated scientific integrity officials, or the equivalent, who are  responsible for overseeing the agencies’ implementation of their scientific  integrity policies. FE, which follows DOE’s policy, does not have a  scientific integrity official or the equivalent. DOE’s scientific integrity policy  states that the Secretary of Energy will designate a scientific integrity  official for the department. DOE officials explained that the scientific  integrity official has not been designated because the scientific integrity  policy was implemented in January 2017, as the administration was  changing, and that the current Secretary has not yet designated a  scientific integrity official. We recommended the Secretary of Energy  should establish steps and a time frame for designating a scientific  integrity official to oversee the department’s scientific integrity activities. In  DOE’s written comments on a draft of our report, reproduced in our final  report, the department concurred with our recommendation and estimated  that it would address the recommendation by the end of 2019.

Third, we found in our April 2019 report that four of the nine selected  agencies—ARS, EPA, NASA, and NIH—monitor and evaluate the  performance of their activities under their scientific integrity policies, or  have plans to do so. The remaining five agencies—FAA, FE, NIST,  NOAA, and USGS—have, for different reasons, not done so. Standards  for Internal Control in the Federal Government states that management  should design control activities to achieve objectives and respond to risks,  which may include establishing activities to monitor performance  measures and indicators. By establishing mechanisms to effectively  monitor the implementation of their scientific integrity policies, agencies  may be better positioned to evaluate and measure whether their scientific  integrity policies are achieving their objectives and, where necessary,  improve their implementation.

We recommended in our April 2019 report that the five agencies develop  mechanisms to regularly monitor and evaluate implementation of their  scientific integrity policies, including mechanisms to remediate identified  deficiencies and make improvements where necessary. All five agencies  agreed with our recommendation and responded as follows:  In a May 2019 letter from DOT, the department identified several  mechanisms it plans to implement by the end of March 2020.

In DOE’s written comments on a draft of our report, the department  said that its scientific integrity official will have the responsibility to  lead in developing procedures to monitor and evaluate  implementation of DOE’s policy.

In Commerce’s written comments, NIST stated that, beginning in  fiscal year 2019, the agency will review implementation of its policy at  least annually and make recommendations to the Director of NIST as  to whether any improvements are needed.

In Commerce’s written comments, NOAA stated that it will identify  additional metrics for monitoring and evaluating its policy.

The Department of the Interior’s written comments stated that the  department plans to implement a biennial scientific integrity survey of  USGS employees, beginning in 2020, to gauge scientific integrity  policy awareness and effectiveness at USGS, among other things.

Most of the Selected Agencies Have Procedures for Addressing Alleged Violations of Scientific Integrity Policies, but Two Do Not, Raising Questions about the Consistency of Their Investigations

Seven of the nine selected agencies—ARS, EPA, FAA, NIH, NIST,  NOAA, and USGS—have specific, documented procedures for identifying  and addressing alleged violations of their scientific integrity policies.  Although the details of agencies’ procedures may vary, the procedures  generally include five basic steps: (1) report allegation, (2) screen  allegation, (3) investigate allegation, (4) respond to violation, and (5)  appeal decision (see fig. 1).

In contrast, two of the nine selected agencies—FE and NASA—do not  have specific, documented procedures for identifying and addressing  alleged violations of their scientific integrity policies. In March 2009, the  President issued a memorandum on scientific integrity that states that  each agency should have in place procedures to identify and address  instances in which the scientific process or the integrity of scientific and  technological information may be compromised. FE, which follows  DOE’s scientific integrity policy, does not have specific procedures  because DOE has not established any. DOE and FE officials said staff  can report allegations to a supervisor, the whistleblower ombudsperson,  or the U.S. Office of Special Counsel (OSC). Similarly, NASA officials  said employees can report allegations through their chain of command,  such as to a supervisor, for investigation on a case-by-case basis.  However, without documented procedures for identifying and addressing  alleged violations of their scientific integrity policies, DOE and NASA do  not have assurance that all staff have a clear understanding of how to  report allegations and that investigations will be conducted consistently.

We recommended the Secretary of Energy and Administrator of NASA  develop documented procedures for identifying and addressing alleged  violations of their scientific integrity policies. In DOE’s written comments  on a draft of our report, the department stated that it will be the  responsibility of the scientific integrity official to lead, and coordinate with  other elements of the department, in developing procedures for identifying  and addressing alleged violations of its scientific integrity policy and  estimated completing actions in June 2020. In written comments from  NASA, the agency stated that it will develop documented procedures for  identifying and addressing alleged violations of its policy and estimated  completion by October 2020.

Chairwoman Stevens and Chairwoman Sherrill, Ranking Member Baird  and Ranking Member Norman, and Members of the Subcommittees, this  concludes my prepared statement. I would be pleased to respond to any  questions that you may have at this time.

If you or your staff have any questions about this statement, please  contact John Neumann, Managing Director, Science, Technology  Assessment, and Analytics, at (202) 512-6888 or neumannj@gao.gov.  Contact points for our Offices of Congressional Relations and Public  Affairs may be found on the last page of this statement. GAO staff who  made key contributions to this testimony are Rob Marek (Assistant  Director), Wyatt R. Hundrup (Analyst in Charge), Cheryl Harris, and  Douglas G. Hunker. Also contributing to this testimony were Eric Charles  and Ben Shouse. Additional staff who made contributions to our April  2019 report are identified in that report.

This is a work of the U.S. government and is not subject to copyright protection in the  United States. The published product may be reproduced and distributed in its entirety  without further permission from GAO. However, because this work may contain  copyrighted images or other material, permission from the copyright holder may be  necessary if you wish to reproduce this material separately.

How do agencies protect the integrity of scientific research?

Federal guidance on scientific integrity includes principles to ensure the open exchange of information and prevent the distortion of research findings.

We testified that all 9 agencies we reviewed have policies based on those principles. However:

2 agencies have not provided scientific integrity training for staff

1 does not have a scientific integrity official

5 do not monitor or evaluate activities under their scientific integrity policies

2 do not have procedures to address alleged violations of their policies

We made 10 recommendations in a related report.