Data Act: OMB Needs to Formalize Data Governance for Reporting Federal Spending

The DATA Act required OMB and Treasury to establish data standards for the reporting of federal government spending and required agencies to report spending data using these standards beginning in May 2017. GAO's prior work examining the quality of the data reported under the act found significant challenges that limit the usefulness of the data for Congress and the public. These data quality challenges underscore the need for OMB and Treasury to make progress on addressing GAO's prior recommendation to establish a set of clear policies and processes for developing and maintaining data standards.

The DATA Act includes a provision for GAO to report on the implementation and use of data standards, and on the quality of the data reported using those standards. This report (1) describes the status of OMB's and Treasury's efforts to establish policies and procedures for governing data standards; and (2) evaluates the extent to which procedures for changing established data standards are consistent with key practices for data governance.

The Office of Management and Budget (OMB) and the Department of the Treasury (Treasury) have established some procedures for governing the data standards established under the Digital Accountability and Transparency Act of 2014 (DATA Act), but a formal governance structure has yet to be fully developed. Since enactment, OMB has relied on a shifting array of advisory bodies to obtain input on data standards. As of December 2018, some governance procedures are in place, but others continue to evolve. OMB staff told us that the governing bodies involved in initial implementation efforts had been disbanded, and that the functions previously performed by these advisory bodies over governance of DATA Act data standards would be accomplished within the broader context of the cross-agency priority goals established under the 2018 President's Management Agenda (PMA). However, the documentation of the governance structure established for these goals does not make explicit how it would apply to the data standards established under the DATA Act. Clarifying the connection between this governance structure and the DATA Act could help stakeholders understand how governance of the DATA Act standards is accomplished within the broader context of the PMA.

With regard to one specific data governance function—making changes to existing standards—GAO found that OMB does not have procedures for managing changes to the web page it identifies in guidance as the authoritative source for data definition standards. The DATA Act requires, to the extent reasonable and practicable, that data standards be capable of being continually upgraded. In addition, key practices for data governance state that organizations should document policies and procedures for making decisions about changes to standards. In June 2018, revisions were made to the Primary Place of Performance Address data element without following a documented process. OMB staff described these revisions as minor technical corrections to align the definitions with the technical guidance agencies were already using to report data. However, without documented procedures for revising the definitions, needed changes may not be made in a timely manner, which could lead to inconsistent reporting.

OMB also did not transparently communicate to stakeholders these changes to data definition standards. Along with the corrections to definitions, in June 2018 OMB changed introductory text on the data definitions web page to clarify policy about how agencies should use DATA Act definitions. However, OMB did not publicly announce this clarification or identify on the website that changes had been made. Without transparent communication of changes to data definition standards, stakeholders—including staff at federal agencies required to report data according to these definitions—may miss important information relating to changes in how, when, and by whom data definitions are to be applied.

Although OMB lacks procedures governing changes to DATA Act data definitions, Treasury has established a process for changing related technical guidance in consultation with stakeholders. Treasury's procedures contribute to the objectives of data quality and transparency by helping to ensure that agencies are aware of reporting requirements and users understand how those data are created and reported.

GAO makes two recommendations to OMB to (1) document its procedure for changing data definition standards for DATA Act reporting, and (2) ensure that changes made in June 2018 to clarify policy regarding data definitions are identified in an authoritative public source of DATA Act standards and guidance. OMB neither agreed nor disagreed with the recommendations, but provided comments, which GAO incorporated as appropriate.

The Digital Accountability and Transparency Act of 2014 (DATA Act)  directed the Office of Management and Budget (OMB) and the  Department of the Treasury (Treasury) to establish data standards to  enable the tracking of agency spending. The act also required agencies  to begin reporting data under the new standards by May 2017. In the  almost 5 years since the law was enacted, OMB, Treasury, and other  federal agencies have made significant strides to address many of the  policy and technical challenges presented by the act’s requirements. This  progress includes standardizing data elements across the federal  government, linking data contained in agencies’ financial and award  systems, and expanding the type of data reported.

However, our 2017 audit of the initial data submitted by agencies and  made available to the public on USAspending.gov shows that much more  needs to be done if the federal government is to fully realize the DATA  Act’s promise of improving the accuracy and transparency of data on  federal spending. Specifically, we identified issues and challenges with  the completeness and accuracy of the data submitted, use of data  elements, and presentation of the data on USAspending.gov. These  challenges limit the usefulness of the data for Congress and the public.  The DATA Act holds each agency accountable for submitting accurate  and complete data. To ensure that they are able to do so, it is critically  important for OMB and Treasury to make additional progress in  addressing our 2015 recommendation that they establish clear policies  and processes for governing data standards. Such policies and processes are needed to promote data quality and ensure that the  integrity of data standards is maintained over time.

This is one in a series of products we have provided to Congress on the  implementation of the DATA Act. Specifically, this report: (1) describes  the status of OMB’s and Treasury’s efforts to establish policies and  procedures for governing the data standards established under the DATA  Act; and (2) evaluates the extent to which procedures for changing  established data standards are consistent with key practices for data  governance.

To describe the status of OMB’s and Treasury’s ongoing efforts to  establish policies and procedures for governing the data standards  established under the act, we reviewed guidance documents to  understand the extent to which data governance policies and procedures,  as well as roles and responsibilities for carrying out data governance  activities, have been defined, documented, and communicated to  stakeholders. We also met with OMB staff and Treasury officials to obtain  an update on any efforts underway to further develop formal policies and  procedures for governing the standards established under the DATA Act.

To assess the extent to which data governance policies and procedures  are consistent with key practices, we compared OMB’s and Treasury’s  data governance efforts to key practices for effective data governance.  We identified key practices in our prior work by examining a range of  organizations—including domestic and international standard-setting  organizations, industry groups and associations, and federal agencies— to ensure we had a comprehensive understanding of data governance  key practices across several domains.

We also met with OMB staff and Treasury officials to obtain information  on the status of their efforts to address our previous recommendations on  the implementation of the DATA Act. Our recommendations from July  2015 through December 2018 cover a range of issues, including creating  and communicating guidance to agencies, designing and implementing  quality controls, and more clearly disclosing known data limitations. (See  appendix II for the implementation status of these recommendations.)

We conducted this performance audit from November 2017 to March  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 expands on previous  federal transparency legislation. It requires federal agency expenditures  to be disclosed and agency spending information to be linked to federal  program activities so that policymakers and the public can more  effectively track federal spending. The DATA Act also requires  government-wide reporting on a greater variety of data related to federal  spending, such as budget and financial information, as well as tracking  these data at multiple points in the federal spending life cycle.

To accomplish these goals, among others, the act gives OMB and  Treasury responsibility for establishing government-wide financial data  standards for any federal funds made available to or expended by federal  agencies. These standards specify the data 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 information reported will be  consistent and comparable. As Treasury and OMB implemented the  DATA Act’s requirement to create and apply data standards, the overall  data standardization effort has been divided into two distinct, but related,  components: (1) establishing definitions which describe what is included  in each data element with the aim of ensuring that information will be  consistent and comparable, and (2) creating a data exchange standard  with technical specifications which describe the format, structure, tagging,  and transmission of each data element.

In the implementation of the DATA Act, OMB took principal responsibility  for the definitions, while Treasury took principal responsibility for the  technical standards that express these definitions, which federal agencies  use to report spending data for publication on USAspending.gov. The act  also holds agencies accountable for submitting complete and accurate  data to USAspending.gov and requires that agency-reported award and  financial information comply with the data standards established by OMB  and Treasury.

The Importance of Data Governance for Ensuring Data Quality

One of the purposes of the DATA Act is to establish government-wide  data standards to provide consistent, reliable, and searchable spending  data that are displayed accurately for taxpayers and policymakers on  USAspending.gov (or a successor website). As we have reported  previously, establishing a data governance structure—an institutionalized  set of policies and procedures for providing data governance throughout  the life cycle of developing and implementing data standards—is critical  for ensuring that the integrity of the standards is maintained over time.  The need for a data governance structure is underscored by our previous  analyses of the quality of the federal spending data available on  USAspending.gov and inconsistencies we identified in how agencies  report data according to data standards. A data governance structure  could be useful for adjudicating revisions, monitoring, and ensuring  compliance with the standards over time. As we have noted, such a  structure, if properly implemented, would greatly increase the likelihood  that the data made available to the public will be accurate.

A data governance structure can also provide consistent data  management during times of change and transition. We have previously  reported that gaps in leadership can occur as administrations change.  This can impair the effectiveness and efficiency of complex government- wide efforts, potentially resulting in delays and missed deadlines.

Accordingly, in 2015, we recommended that OMB, in collaboration with  Treasury, establish a set of clear policies and processes for developing  and maintaining data standards that are consistent with leading  practices. OMB and Treasury did not comment on our recommendation.  We plan to conduct work intended to help inform OMB’s and Treasury’s  efforts. This work may include the development of a maturity model that  could provide a framework for assessing data governance activities  related to federal spending data. This work may also have broader  government-wide implications as agencies begin implementing the  requirements of the Foundations for Evidence-Based Policymaking Act  enacted on January 14, 2019, including designating Chief Data Officers  with data governance and implementation responsibilities.

Although Some Governance Procedures Are in Place, a Formal Structure for Governing Data Standards Continues to Evolve

Roles of Data Governance Interagency Advisory Groups Have Shifted During DATA Act Implementation

In December 2018, OMB staff told us that they are transitioning from the  governance structure used for initial DATA Act implementation to a new  structure for managing data standards within the broader context of  efforts to establish a federal data strategy. According to OMB staff, the  initial data governance structure reflected OMB’s and Treasury’s focus on  creating the design and build functions required to meet the statutory  requirements of the DATA Act.

The President’s Management Agenda (PMA), released in March 2018,  outlines a long-term vision for modernizing federal operations. To address  the issues outlined in the PMA, the administration established a number  of cross-agency priority (CAP) goals. These goals, required by the GPRA  Modernization Act of 2010, are to address issues in a limited number of  policy areas requiring action across multiple agencies, or management  improvements that are needed across the government. According to  OMB staff, several of the 2018 goals relate to data standardization, and a  new governance structure is needed to achieve those goals.

OMB staff informed us in July 2018 that the governance structure used  for initial implementation efforts, which included the DATA Act  Interagency Advisory Committee and Data Standards Committee, had  been disbanded, and that the advisory roles of these groups were  assumed by the Chief Financial Officers Council’s DATA Act Working  Group (CFOC Working Group). According to OMB staff, the working  group includes four subgroups, which focus on Policy, Internal Controls  and Data Quality, Audit Coordination, and the DATA Act Information  Model Schema (DAIMS), respectively.

OMB staff also told us that by December 2018 an interagency board and  council, both led by the General Services Administration (GSA), had  begun to advise OMB on policy matters. According to an action plan that  OMB and GSA released along with the March 2018 PMA, the new  interagency Shared Solutions Governance Board (SSGB) and Business  Standards Council (BSC) are responsible for setting goals and providing  advice to promote a government-wide marketplace for shared services.  Specifically, they cover mission-support services such as human  resources and financial management that a small number of providers  offer to many agencies. According to OMB staff, this oversight function  involves creating and administering government-wide data standards,  including data standards established to support the DATA Act. The SSGB  includes executives from across the federal government and is  responsible for making recommendations to OMB on shared services  policy. The BSC provides expertise on various subject matter areas (e.g.,  procurement and financial assistance) to promote the development of  common business capabilities and data standards.

The action plan does not discuss how the functions carried out by the  SSGB and BSC apply specifically to the data standards established under  the DATA Act. In commenting on a draft of this report, OMB staff told us  that the “Governance Ecosystem” page on the website of Unified Shared  Services Management (USSM) describes the SSGB and links functions of  the SSGB and BSC to the DATA Act. They said it does this by showing  that OMB and Treasury have key roles in all three entities. However, this  common membership does not, in itself, provide the transparency and  clarity of documented policies and procedures for governing DATA Act  standards.

Treasury officials said that the CFOC Working Group is involved in  aligning DATA Act data standards across various functional communities,  including procurement and financial assistance. Further, the group is  considering making recommendations to OMB regarding changes to data  definitions and other policy matters. For example, Treasury officials told  us that in fall 2018, the DAIMS Subgroup identified difficulties in aligning  different definitions of Period of Performance Start Date used for  procurement and in financial assistance awards, and plans to elevate this  issue to the Policy Subgroup for review. Specifically, the DAIMS  Subgroup found that it is not always clear whether the start date should  be reported as the date when a specific transaction occurred or the date  when the original underlying award was made. This choice about how to  interpret the data element can have substantial consequences for the  consistency of the data reported. For example, in some cases, the  underlying awards for recent transactions were made in the 1960s or  1970s.

According to OMB staff and Treasury officials, at the center of this shifting  array of advisory bodies, the DATA Act Executive Steering Committee  (ESC) has continued to meet regularly and to serve as the top-level  governance body for DATA Act implementation. OMB staff told us that the  ESC is chiefly responsible for setting government-wide policy for the data  standards based on the recommendations from various advisory bodies.  In addition to the ESC, Treasury has continued to maintain and update  the DAIMS and DATA Act Broker, following a set of change control  procedures that involve consultation with stakeholders and public release  of information about updates.

OMB and Treasury Have Instituted Some Data Governance Activities but Have Not Established a Set of Clear Policies and Processes

Although OMB has taken some steps to address our recommendation,  efforts are still needed to establish a clear set of policies and procedures  for governing the data standards established under the act. The key  practices for data governance that we identified in our previous work are  shown in table 1. In the specific context of the DATA Act standards,  Treasury and OMB have taken steps to enforce the use of data standards  by directing agencies to develop and maintain data quality plans and  requiring agencies to submit data through the DATA Act Broker. The  broker performs validations to improve data quality and ensure the  consistent application of data standards. However, because the approach  to governing DATA Act data standards has continued to evolve during the  past few years, and because a set of data governance policies and  procedures is not documented, we were unable to conduct a  comprehensive assessment of OMB’s and Treasury’s data governance  efforts against leading practices.

While some data governance activities have been undertaken within the  specific context of DATA Act data standards, others are part of broader  efforts under the PMA. In July 2018, OMB staff told us that governance  over the DATA Act data standards would be accomplished within the  broader context of the CAP goals established under the PMA. For  example, OMB established a governance structure to achieve the  objectives of CAP goals related to “Results-Oriented Accountability for  Grants.” As part of this broader effort to standardize grants management  business processes and data to increase efficiency and reduce reporting  burden, OMB, the Department of Health and Human Services, and other  federal agencies have published a list of draft grants management data  standards for public comment.

However, published documents describing this effort do not explain how  the process for developing grants management standards under this CAP  goal would apply specifically to the data standards established under the  DATA Act. Nor do they address if or how these new standards align with  those established under the act. Further, none of the documentation on  the PMA’s governance structure for grants management mentions the  DATA Act. In commenting on a draft of this report, OMB staff told us that  the staff members from OMB and Treasury who are responsible for the  grants management standards are the same people involved in managing  the DATA Act standards. While this connection between the two efforts  may provide adequate communication in the short term, staffing is likely  to change over time, and there is no assurance that the same people will  always be involved. As we have reported previously, having documented  policies in place that delineate clear roles and responsibilities for  decision-making could help to ensure continuity into the future. As the  Comptroller General testified in 2015, in the absence of a clear set of  institutionalized policies and processes for developing standards and for  adjudicating necessary changes, the ability to sustain progress and  maintain the integrity of established data standards may be jeopardized  as priorities and data standards shift over time.

OMB Does Not Have Procedures for Updating Data Definition Standards

OMB Has Not Established Procedures for Making Decisions about Changes to Existing Data Definitions

Managing and controlling changes to data standards is a key activity for  data standardization and effective data governance. The DATA Act  requires OMB and Treasury, in consultation with the heads of federal  agencies, to establish government-wide financial data standards that  include common data elements for financial and payment information  required to be reported by federal agencies and entities receiving federal  funds. Among other requirements, these standards, to the extent  reasonable and practicable, must be capable of being continually  upgraded as necessary. According to key practices for data governance  that we identified in our previous work, organizations should have  documented policies and procedures for making decisions about changes  to existing data standards.

In June 2018, OMB staff changed certain data definitions in the publicly  accessible website that serves as the official repository for the data  definitions. However, OMB does not have a documented procedure for  updating or making changes to these definitions. In commenting on a  draft of this report, OMB staff stated that the DATA Act Information Model  Schema (DAIMS) change control procedures were the method for  updating data standards. However, OMB’s website for data definitions is  maintained separately from the DAIMS, and the DAIMS procedures only  address changes to the DAIMS, and do not address this separate  repository of data definition standards.

OMB staff said that the June 2018 revisions were made in response to  the findings of our November 2017 report. Specifically, OMB revised the  Primary Place of Performance Address definition to no longer include a  street address or county. OMB amended the definition of Record Type to  clarify that it applies to financial assistance awards only. As shown in  figure 1, OMB also amended the explanatory text preceding the  definitions to revise and clarify its policy regarding agencies’ use of data  definitions. OMB staff described the changes to definitions as minor  technical corrections to align with the reporting instructions in the DAIMS.

In December 2018, OMB staff informed us that OMB’s procedure for  making changes to the data definitions it maintains in the official  repository can be found on the “Governance Ecosystem” page of the  website of Unified Shared Services Management (USSM). However, our  review of that page in January 2019, including the links it provides to  other pages, found no evidence that the website provides any  documentation related to the DATA Act. In particular, we found no  evidence of a documented procedure for making changes to the data  definitions in OMB’s official repository. The staff were unable to provide  documentation to show that any standard procedure was followed in  making the June 2018 changes, or that the DATA Act Executive Steering  Committee approved the changes. As discussed earlier in this report, that  committee is the top-level governing body for DATA Act implementation  and is responsible for approving changes to data standards.

The evolution of OMB’s approach to developing a governance structure to  maintain the integrity of the DATA Act data standards could in part  explain the lack of a documented procedure for updating the definitions.  As discussed above, OMB has created and disbanded various advisory  bodies for DATA Act data standards and has only recently decided on an  approach for formalizing governance over the standards, namely the  decision to integrate governance of these standards with the governance  processes administered by the SSGB. In 2015, we reported that  establishing a formal framework for providing data governance throughout  the life cycle of developing and implementing these standards is critical  for ensuring that the integrity of the standards is maintained over time.

Without established written procedures for making revisions to data  definitions, needed changes may not be made in a timely manner, which  could impair data quality. For example, if the definitions in the DATA Act  official repository and definitions in other sources are not aligned, then  agency staff responsible for DATA Act compliance and reporting may  make inconsistent choices about which definitions to apply when creating  and submitting data. As we have previously reported, the current data  governance structure did not prevent inconsistencies between the DAIMS  and the official repository for data definitions.

OMB Revised Data Definition Standards without Transparently Communicating the Changes to Stakeholders

Changes to data standards for federal spending data should be  transparently communicated to stakeholders, including the public. The  DATA Act requires OMB and Treasury to consult with public and private  stakeholders in establishing data standards. In addition, according to  key practices for data governance that we identified in 2016,  organizations should have documented policies and procedures for  managing, controlling, monitoring, and enforcing consistent application of  data standards and for obtaining input from stakeholders and involving  them in key decisions, as appropriate. Standards for internal control in  the federal government state that management should externally  communicate the necessary quality information to achieve the entity’s  objectives. These objectives can include those relating to the release of  reliable information in accordance with appropriate standards, applicable  laws and regulations, and expectations of stakeholders. In the context of  standards for transparently reporting federal spending data, stakeholders  include the general public as well as staff at federal agencies.

OMB did not transparently communicate the June 2018 revisions. OMB  staff said that the changes were communicated in OMB Memorandum M- 18-16, which was issued on June 6, 2018. As shown in figure 2, a  footnote in that memorandum contains a link to the official web page for  OMB’s Office of Federal Financial Management. That page includes a  link, labeled “DATA Act Data Standards,” to the public MAX.gov page that  serves as the official repository for the data definition standards.  However, neither this footnote nor other text in the memorandum makes  reference to changes made to the definitions and policy. As of March 18,  2019, the official repository did not indicate that any changes have been  made since the initial creation of the definitions in 2015.

OMB did not provide documentation showing that the revisions were  communicated to the public or to specific categories of stakeholders, such  as users of the data standards within the federal government. As  described below, the procedures that Treasury has implemented for  managing changes to technical guidance, including publishing revision  histories for guidance documents, represent one potentially effective  approach to informing stakeholders, including the public, about changes  to data standards.

OMB staff viewed the revisions made in June 2018 as minor technical  corrections that were needed to align the definitions with other OMB  policies and with the consensus view of stakeholders at the time the data  standards were first established. Consequently, they did not believe it  was necessary to communicate these revisions publicly or indicate in the  official repository that changes had been made. However, these revisions  required significant changes in some federal agencies’ use of data  definitions. As we reported in November 2017, some agencies applied  DATA Act definitions directly when generating data to be reported to  USAspending.gov. The new explanatory text added to the data  definition repository instructs agencies not to apply these definitions  directly, but instead to apply the more detailed definitions contained in  regulations and policies governing the making and management of  awards.

Without transparent communication of changes to data definition  standards, stakeholders—including staff at federal agencies required to  report data according to these definitions—may miss important  information relating to changes in how, when, and by whom data  definitions are to be applied. The staff may then report data that are not  consistent and comparable across the federal government. Such  inconsistent reporting can undermine the transparency goals of the DATA  Act, particularly when it affects key data elements, such as those  describing geographical information. For example, we found in November  2017 that inconsistent data were reported about the locations where the  federal government spends money, because some agencies used OMB’s  DATA Act definition of the Primary Place of Performance data element,  while other agencies used definitions from other sources, such as the  data dictionary for the Federal Procurement Data System – Next  Generation (FPDS-NG). In addition, a revision history showing when  clarifications of policy and corrections to data standards were made could  assist users of federal spending data, including historical data, in  interpreting those data and assessing their reliability and quality.

Treasury Has Procedures in Place for Communicating with Stakeholders Regarding Changes to Technical Guidance

Treasury has established procedures for consulting with and informing  stakeholders, including the public, about changes to technical guidance  and reporting processes. Treasury’s stakeholder engagement process  includes regular review of and revisions to its technical guidance. Before  revisions to guidance are put into effect, Treasury staff circulate proposed  changes through an email list that any member of the public can  subscribe to, discuss these changes at frequent meetings with federal  agency staff responsible for DATA Act reporting, and provide  opportunities for agencies to test reporting under the new rules and  provide feedback from this testing to Treasury. In addition, the guidance  documents provide logs of all changes that have been made since the  documents were created.

According to Treasury staff, the most important tools for ensuring that  agencies report consistent and comparable data are the DATA Act  Information Model Schema (DAIMS) and the DATA Act Broker.  Treasury’s documentation states that the DAIMS is “the data standard of  the DATA Act” and contains standardized data elements that are  complete and reflect the requirements of the act. The DAIMS includes  reporting guidance that provides agencies with a complete listing of data  elements they must report as well as a complete listing of data elements  that will be extracted from government-wide systems, such as FPDS-NG.  The DAIMS also includes a validation rules document that describes the  business rules employed by the DATA Act Broker, which is Treasury’s  system for collecting and validating agency data. Treasury provides  federal agencies with detailed procedures for submitting DATA Act data  to the broker.

Before making changes to the DAIMS and DATA Act Broker, Treasury  provides stakeholders with information about the planned changes and an  opportunity to comment on them. For example, in June 2018, Treasury  released DAIMS 1.3, an updated version of the DAIMS to be  implemented during fiscal year 2019. Before releasing the final version of  DAIMS 1.3, on June 29, 2018, Treasury shared its plans for the release  with stakeholders through the Chief Financial Officers Council’s DATA Act  Working Group (CFOC Working Group) and office hours calls. Treasury  also transmitted a notice of proposed changes to federal agencies,  collected comments from agencies during a designated comment period,  and included responses to these comments in the final version of the  release. Before implementing any of the changes in DAIMS 1.3 in the  DATA Act Broker, Treasury provided agencies with a testing environment  that allowed agency staff to identify any issues with the changes before  those changes were applied to data published on USAspending.gov.

Treasury’s documentation for the public and for federal agencies includes  detailed information about the history of changes to the DAIMS. Each of  the DAIMS guidance documents includes a change log that shows  revisions made since the document was first created. The detailed  information Treasury provides about changes to technical guidance can  promote data quality and transparency by ensuring that federal staff are  aware of reporting requirements, and that users of the data understand  how those data are created and reported.

Since 2014, OMB and Treasury have made significant strides to address  the DATA Act’s requirements for standardization of federal spending data.  As they move forward, appropriately and effectively managing changes to  data standards will be critical to ensuring the quality and comparability of  the data across the federal government. Treasury has instituted regular  procedures for making changes to technical data standards, including  procedures for consulting with stakeholders and for recording and  communicating changes.

OMB has taken responsibility for maintaining an official list of data  definition standards separate from the technical data standards  maintained by Treasury. However, OMB lacks comparable procedures for  maintaining these data definition standards. OMB made changes to some  of the definitions and clarified policies about how they are to be applied,  but did not communicate those changes to stakeholders, including the  public. Definitions of data elements and policies about how those  definitions are to be applied are a key component of the management of  federal spending data under the DATA Act.

Although OMB has completed the task of creating an initial set of  definitions, it has not formally and explicitly documented a consistent  approach for maintaining the integrity of the data definition standards over  time as we previously recommended. Until OMB establishes procedures  to ensure that changes are controlled, it will continue to be a challenge to  apply and interpret these definitions consistently, presenting risks to data  quality. In addition, clearly identifying the changes that have already been  made in the official repository could aid agency officials in reporting data  and users in understanding the context in which past data have been  reported. These actions would be important steps toward improving  control over the data standards, creating an effective governance  structure, and ultimately improving the consistency and quality of federal  spending data.

We are making two recommendations to the Office of Management and  Budget:  The Director of OMB should clarify and document OMB’s procedure for  changing official data definition standards for DATA Act reporting, for  example, by explicitly describing how change procedures developed for  other government-wide initiatives apply to DATA Act definition standards  in a public source of guidance or information. (Recommendation 1)

The Director of OMB should ensure that the June 2018 policy changes  regarding DATA Act data definition standards are clearly identified and  explained in the official repository or another authoritative public source of  DATA Act standards and guidance, such as by including a revision history  along with the current version of the definitions. (Recommendation 2)

We provided a draft of this report to OMB and Treasury for review and  comment. OMB neither agreed nor disagreed with our recommendations,  and OMB staff from the Office of Federal Financial Management provided  oral comments, which are summarized below and incorporated as  appropriate in the report. Treasury informed us that they had no  comments on the draft report.

In their oral comments, OMB staff stated that on the whole, the report  correctly described the complex ecosystem of governance over data  standards for federal spending data. However, OMB staff stated that in  certain places the report did not fully capture the extent of OMB’s actions  related to data governance for the DATA Act data standards.

According to OMB staff, the Shared Solutions Governance Board  (SSGB), under OMB’s direction, plays an important role in governing  DATA Act data standards. OMB staff said that this relationship exists  because the same agencies and staff participate in both the SSGB and  the governance of the DATA Act data standards.

In addition, OMB staff confirmed that descriptions of the specific roles and  responsibilities of the SSGB, CFOC Working Group, and the Treasury  office that manages the DAIMS have not been documented. OMB staff  said that many of the same agency personnel participate in all of these  groups, and therefore work closely together on a regular basis. OMB staff  stated that this close involvement results in effective communication and  a consistent approach to governance, and ensures an understanding of  the procedures for changing data standards even though those  procedures are not formally documented.

We acknowledge OMB’s assertion that the various groups for creating  and administering government-wide data standards (including data  standards established to support the DATA Act) share many of the same  staff. However, OMB’s approach relies on the continued participation of  the same staff in order to maintain continuity rather than relying on  documented policies, procedures, roles, and responsibilities for data  governance functions. A key benefit of having a robust, institutionalized  data governance structure is to provide consistent data management  during times of change and transition, such as during staffing transitions  or administration changes. It is important for OMB to clearly delineate  roles and responsibilities so stakeholders understand how governance of  the DATA Act standards is accomplished within the broader context of the  PMA and other efforts.

OMB staff also said they have communicated all changes to DATA Act  data standards that have been made since the standards were created.  OMB staff told us that the DAIMS is the official data standard for DATA  Act reporting and, as such, includes logs that record all changes to the  standards. According to OMB staff, OMB updated its public data  standards web page on www.max.gov in June 2018 to fix an error and  ensure that the page matched the DAIMS. Staff stated their belief that  such a correction did not represent an actual change to a data standard  and therefore did not need to be recorded in the DAIMS change log or  communicated publicly.

However, guidance issued in June 2018, OMB Memorandum M-18-16,  identifies the MAX.gov web page as the official repository of the data  standards. Specifically, the guidance directs agencies to report data in  accordance with the standards maintained by OMB and Treasury  pursuant to FFATA, as amended by the DATA Act, and provides a link to  the OFFM website’s listing of data standards definitions.  If OMB chose to  identify the DAIMS—instead of the MAX.gov page—as the official source  of data standards, then the issue about changes not being identified on  the MAX.gov page would not be important. Although OMB made  conforming changes based on our input to align the definition of Primary  Place of Performance on the MAX.gov web page, having clearly  documented procedures for making changes to the data standards and  for ensuring that changes are communicated widely is important for  ensuring the consistent and comparable reporting envisioned under the  act.

Additionally, in June 2018, OMB made an important change to the  explanatory text that precedes these official data definitions as posted on  the MAX.gov website, clarifying OMB’s policy regarding the use of the  DATA Act data definitions. OMB staff acknowledged that that this  clarification could have been publicized more effectively, which is why we  continue to believe that our second recommendation—to include a  revision history along with the current version of the DATA Act data  definitions—remains valid.

We are sending copies of this report to the Secretary of the Treasury and  the Acting Director of OMB, as well as interested congressional  committees and other interested parties. This report will be available at no  charge on our website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  Michelle Sager 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. Key contributors to this report are listed in  appendix III.

Appendix I: Interagency Groups Responsible for DATA Act Governance

Appendix I: Interagency Groups Responsible  for DATA Act Governance GitHub is a web-based software repository hosting service. The Federal Spending Transparency  website can be found at: http://fedspendingtransparency.github.io/.  JIRA is an online software development tool that Treasury uses to provide responses to stakeholder  questions and comments related to the development of the broker.

Appendix II: Status of Open GAO Recommendations Related to the DATA Act

Appendix III: GAO Contact and Staff Acknowledgments

In addition to the contact named above, Peter Del Toro, Assistant  Director, and Kathleen M. Drennan, Analyst-in-Charge, supervised the  development of this report. Theodore Alexander and Sherrice Kerns  made major contributions to this report. Also contributing to this report in  their areas of expertise were David M. Ballard, Ann Czapiewski, Jenny  Chanley, Robert Gebhart, Michael LaForge, Carl Ramirez, Andrew J.  Stephens, and James Sweetman, Jr.

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: Section 5 Pilot Design Issues Need to Be Addressed to Meet  Goal of Reducing Recipient Reporting Burden. GAO-16-438. Washington,  D.C.: April 19, 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 Data Transparency: Effective Implementation of the DATA Act  Would Help Address Government-wide Management Challenges and  Improve Oversight. GAO-15-241T. Washington, D.C.: December 3, 2014.

Government Efficiency and Effectiveness: Inconsistent Definitions and  Information Limit the Usefulness of Federal Program Inventories.  GAO-15-83. Washington, D.C.: October 31, 2014.

Data Transparency: Oversight Needed to Address Underreporting and  Inconsistencies on Federal Award Website. GAO-14-476. Washington,  D.C.: June 30, 2014.

Federal Data Transparency: Opportunities Remain to Incorporate  Lessons Learned as Availability of Spending Data Increases.  GAO-13-758. Washington, D.C.: September 12, 2013.

Government Transparency: Efforts to Improve Information on Federal  Spending. GAO-12-913T. Washington, D.C.: July 18, 2012.

Electronic Government: Implementation of the Federal Funding  Accountability and Transparency Act of 2006. GAO-10-365. Washington,  D.C.: March 12, 2010.

The DATA Act seeks to improve reporting on federal spending and make federal funds more transparent via USASpending.gov.

Agencies began reporting using DATA Act standards in May 2017. Going forward, those standards may be changed to ensure that they are capturing useful data from agencies—specifically, data that is accurate, consistent, and comparable across government.

The Office of Management and Budget doesn't have regular procedures for changing the data standards, and has made some changes without informing the public, which could lead to inconsistent reporting. Our recommendations are to address these and other issues we found.