The DATA Act Doesn’t Require Big System Change. Here’s Why.

Guest blog post by Jason Ludwig (BackOffice Associates)


The Digital Accountability and Transparency Act of 2014 (DATA Act) was passed by Congress to make federal spending data more transparent and accessible – not just to citizens, but to internal users as well. The law requires the Treasury Department and the White House Office of Management and Budget (OMB), working together, to establish common data standards to govern financial and award information that all federal agencies must report. Most of this data will be published on the government’s main spending transparency portal,, but the data standards cover agencies’ confidential spending information too, even if it is not to be published.

Alongside agencies’ spending reports, the DATA Act standards are also intended to cover the information that grantees and contractors receiving federal funds must report. But there is a crucial difference. While agencies must, under the law, standardize their information by May 2017, grantees and contractors don’t yet face a mandate. Instead, OMB will run a pilot program to determine whether the standards work properly for grantee and contractor reporting. This post focuses on the challenges facing agencies.

Any technological change presents its own set of unique challenges. The DATA Act is no different. For each agency, the biggest challenges of implementing and complying with the DATA Act lie in understanding its own financial and award information. Financial and award information is managed by many separate systems, for multiple purposes. Until the DATA Act, there has been no mandate to bring all this information together to create a standardized data set.

The problem we face is that information is dynamic. The definition of a piece of data in one system may be different than the definition in another related system. To further complicate the issue, the business processes that define and consume the data and even the systems themselves, are under constant change. The fact that each agency’s information is by its very nature in a constant state of change makes it very difficult to identify a single source of the truth. Yet that is the goal at which the DATA Act drives.

First: The Enterprise Data Assessment

The first step toward addressing these challenges is completing an enterprise data assessment. This assessment should be done with specific questions in mind. How are existing financial and award data sets stored? How are they managed? How are they used? By answering these questions, we can determine what data is actually relevant to the view of truth the DATA Act wants us to identify.

For an example, an agency’s grant system may not properly identify whether a particular grant award is active or not.   If the agency’s transactional data shows an award is active, that data should be considered relevant, regardless of the status of the award within the grant system. Moreover, this kind of informal reliance may indicate a technical or business process gap.

For a second example, suppose a vendor name field in the contracting systems says, “See vendor 123.” That would indicate a possible gap between the agency’s system capabilities and its business process.

The key to any enterprise data assessment is to analyze how the data is used or “let the data speak for itself”.

Next: the Harmonized View

Once an enterprise data assessment has answered questions about the agency’s financial and award data sets, it becomes possible to create a harmonized view.

If the agency has multiple disparate systems that define and use the same data differently, there are potentially multiple correct answers to how the data is being used and defined. The DATA Act requires the agency to provide the data as it is defined by the DATA Act standards. The goal is to identify what data is available and what must be done to map, cross walk and augment the data so it complies with the standards – without impacting the current systems or business processes.

For example, the contracting system may store the name of the vendor at the time of the award, the financial system may retrieve the vendor record remotely from the GSA’s System for Award Management (SAM), yet the DATA Act standard defines the awardee name as the name of “the awardee/recipient that relates to the Awardee DUNS® Number.”

The enterprise data assessment reveals conflicts like this one. Once conflicts are revealed, the agency can choose how to resolve them and apply that choice consistently in a way that supports the existing processes. By resolving these conflicts, the agency can assemble a standardized, harmonized view of the whole picture. That view can then be mapped and cross walked to support DATA Act compliance – while also improving the agency’s internal business processes and decision making.

The good news is that data assessments and harmonization don’t require an agency to change or consolidate the underlying systems. System changes are expensive, and the associated risks often make them prohibitive.

This approach to the DATA Act can be done in a fraction of the time and expense with minimal risk. Let’s recap these steps and then add two more:

  1. Data Assessments – By analyzing how the data is stored, managed and used by the business, an enterprise data assessment determines what data is actually relevant, identifies gaps and data quality issues, identifies the authoritative data sources, and is used to develop an enterprise business glossary.
  2. Data Mapping and Harmonization – The fact-based analysis from the enterprise data assessment is then used to map, cross walk and augment the spending data providing a standardized, harmonized view of the agency’s spending data. This single view of the truth complies with the DATA Act, provides the required data to, and gives the agency its best-ever understanding of its spending data and business processes.
  3. Data Validation – The Data Assessment and the Data Mapping and Harmonization can then be used for the data governance required to validate information within the financial and award systems, improving quality across all those systems and the processes they touch. This includes the reports, documentation and metrics required for the agency’s inspector general to report on the completeness, timeliness, quality, and accuracy of the agency’s standardized spending data – also required under the DATA Act.
  4. Future Harmony – As long as the harmonized view is maintained, there is no need to ditch the current systems. Thanks to the harmonized view, regardless of the systems the agency use, enterprise wide data quality, accuracy and relevancy can be achieved.

Apply People, Process, and Technology to Be Successful

There are three necessary ingredients to be successful with all this – people, process or methodology and technology.

The People: The people conducting an enterprise data assessment and creating a harmonized view need to know their agency! One common misconception is that the people managing data and information need to be IT experts. Data exists to support the agency’s mission, and its management is a business problem – not an IT one. The people supporting this initiative should be supported by IT, but in-depth business process knowledge is required to manage the data and define the requirements.

The Process: A repeatable process and methodology is required to create the harmonized view of the data. The goal is to create the mapping, transformation, and harmonization logic that can be executed consistently and have the ability to be scheduled. Consistent results cannot be obtained without a repeatable process.

The Technology: A successful DATA Act implementation depends on the agency’s ability to manage the orchestration of specific business processes that span the data lifecycle. The ideal technical solution should provide a single platform to inventory and analyze the source systems, identify what data is available and map it to the DATA Act requirements. This platform should also provide web enabled processes to cross walk, augment, harmonize and manage the data where it does not meet the DATA Act requirements. Finally the solution should provide the governance capabilities required to understand the data, its quality and provide the means to remediate issues where required. In the end, the solution should provide a DATA Act specific view of the agency data that does not require customizations or consolidations of the existing systems. Ultimately the goal should be for the technology to support the coordination of the “data and information management” business process. This is indeed a tall order, but there are commercially available solutions, like the Data Stewardship Platform from BackOffice Associates that meet this requirement.

The DATA Act poses some significant challenges but creating a harmonized view of an agency’s enterprise information allows an agency to continue using its current business processes and provide the transparency and accountability that is required. Leveraging the right combination of people, process and technology significantly reduces risk and minimizes the impact to ongoing operations. Defining a harmonized view of the agency information also provides the in-depth understanding of the data required to improve internal management and meet future challenges.