In mid-June, the White House Office of Management and Budget (OMB) released the Draft 2019-2020 Federal Data Strategy Action Plan, requesting public feedback from the data community. On July 8th, the Data Coalition co-hosted a public forum with the White House and separately submitted written commentary and targeted suggestions aimed at improving the Draft Year 1 Action Plan.
The Federal Data Strategy is a component of the President’s Management Agenda, specifically Cross-Agency Priority Goal #2 – Leveraging Data as a Strategic Asset. The Federal Data Strategy has four agency co-leads: OMB, Office of Science and Technology Policy (OSTP), Department of Commerce, and the Small Business Administration. It also has three iteratively developed components:
- Phase I – Government-wide framing Principles now finalized as Ethical Governance, Conscious Design, and Learning Culture.
- Phase II – A framework of 40 newly codified data management Practices now codified in M-19-18 “A Framework for Consistency.”
- Phase III – Sixteen proposed Year 1 (2020) Action Steps to implement the overall strategy.
The June 2019 Strategy timeline on Performance.gov details the iterative process and notes the target September 2019 release of the final Year 1 Action Plan for 2020:
Initial Feedback for Phase I:
The Data Coalition’s comments lead with the theme that the Draft Action Plan provides a unique opportunity to support the implementation of the Foundations for Evidence-Based Policymaking Act (Evidence Act) (P.L. 115-435), which includes the OPEN Government Data Act. However, we see areas where the Draft Action Plan missed the opportunity to fully coordinate with the law.
Shortly after the July 8th public comment deadline, OMB released their long-anticipated Evidence Act implementation guidance (see the Phase 1 guidance, M-19-23). The comprehensive guidance largely addressed our critiques, including the need for government-wide clarification on the agency appointment of chief data officers, evaluation officers, and statistical officials, as well as the Chief Data Officer Council establishment. The Data Coalition is pleased to see the guidance address these items, consistent with the Evidence Act’s intentions. These concepts should also be addressed in the final Action Plan under the Federal Data Strategy.
The Data Coalition’s written feedback recommends making immediate progress on several areas omitted from the strategy, such as developing the National Secure Data Service (NSDS) through the establishment of an advisory committee on data for evidence-building. Additionally, Title III of the Evidence Act requires the codification of OMB Statistical Policy Directive No. 1 (SPD1), a policy mechanism to protect statistical data. OMB could immediately initiate the regulatory process to ensure SPD1 is reflected in administrative law ahead of future OMB guidance documents.
New Suggested Action – Establish Government-Wide Entity Identifier Working Group:
The Data Coalition recommended a new draft action to address an important issue for ensuring data quality and comparability: organizational identifiers. The federal government currently uses more than fifty identifiers for companies, nonprofits, and other non-federal entities which agencies regulate, survey, and issue contracts, grants, and loans to. Implementing a common entity identifier could reduce unnecessary time and resources devoted to harmonizing different identifiers across agencies; the Legal Entity Identifier (LEI), for example, is a global standard that could be further considered. In 2016, OMB convened the Employer Data Matching Workgroup to study the issue, but little progress has been made since then.
The Coalition suggests the inclusion of an action to extend initial steps to improve common entity identifiers. In particular, a government-wide organizational identifier working group could study the disparate identification codes currently in use and the feasibility of a full transition to a common nonproprietary federal entity identifier such as the LEI.
Commentary on the Proposed Action Items:
The Coalition’s detailed feedback on the action plan focuses on three specific action items as well as a number of broader uncategorized feedback items.
Action 3: Develop a Data Ethics Framework. This action discusses GSA working with academia, professional associations, and government stakeholders to create a Data Ethics Framework that extends beyond legal requirements. The Coalition applauds this effort and encourages the Ethics Framework to reflect decision points and directives mapped to specific examples. This will help improve the framework’s relevance for practitioners and the public. The framework’s development should be conducted transparently and include periodic updates with public input opportunities.
Action 10: Improve Financial Management Data Standards. This action considers how the Federal Government will improve management of financial data assets through federal IT spending transparency, results-oriented accountability for grants, and accurate payments. The Coalition points out that this action step also needs to address the continued implementation of the DATA Act (P.L. 113-101), specifically how OMB needs to work with Treasury to improve data quality issues. The Administration should further leverage the DATA Act Information Model Schema (DAIMS) to facilitate more automated integration with other federal performance and budget reporting. Additionally, any future federal reporting requirements must leverage modern standard-setting best practices that incorporate a robust machine-readable schema, taxonomy, and ontology into the data standard model.
Action 15: Identify Data Needs to Answer Key Agency Questions. The Data Coalition recommends this action be clearly connected to the learning agendas and evidence-building plans required by the Evidence Act and articulated in OMB’s annual budget preparation guidance (OMB Circular A-11). The Action Plan should also more clearly articulate how proposed deadlines will work around the budget formation calendar as well as the Evidence Act’s September 2020 agency learning agendas submission deadline. The development of learning agendas should involve stakeholder feedback, including appropriate organizations and program participants outside of government.
The Coalition provided other targeted comments to improve the overall Action Plan.
- OMB should give attention to ensuring a collaborative and participatory process with the primary co-implementers of key government data activities: state and local governments.
- The Action Plan should identify individual senior leaders, rather than agencies, who will be held responsible both internally and publicly for achieving each goal, with specific deadlines rather than relative timeframes.
- Many performance metrics are either misaligned with the stated action or offer mere binary determinations on whether an action was achieved. For example, the Action Plan seems to emphasize the mere establishment of an OMB Data Council (Action 1) over defining the council’s actual goals and definition of success.
- More attention should be given in the Action Plan to delineating how the actions align with new legal obligations in the Evidence Act and other statutory authorities.
Resources Allocation is the Key to Success. Without question, the actions in the Draft Action Plan for the Federal Data Strategy will require chances in resource allocations across government to be fully successful. The Data Coalition recommends that OMB issue an additional FY 2020 budget request to Congress to support the establishment, organization, and empowerment of new leadership positions established under the Evidence Act. With the release of OMB’s Phase 1 Evidence Act implementation guidance (M-19-23) and a preliminary budget deal being reached between the President and Congress, there is now an opportunity to request targeted FY 2020 implementation resources to help meet critical agency needs.
The Data Coalition recently issued a Congressional letter emphasizing that “additional resources are critically needed by agencies to fulfill the intent of the Evidence Act, the vision of the Evidence Commission, and to succeed in making government data accessible, high-quality, and useful.”
Additionally, OMB should encourage agencies to assess resource needs for implementing the Evidence Act as well as share resource requests with OMB when submitting annual budget requests to OMB in September 2020. OMB should also direct the new OMB Data Council to explore potential updates to OMB’s agency service fees (Circular A-25). This will ensure that fee mechanisms align with the current guidance. OMB could consider the development of Evidence Incentive Funds as recommended by the U.S. Commission on Evidence-Based Policymaking, and examine how the government can apply flexibility in procurement processes to achieve additional efficiencies.
Overall the Draft Action Plan serves as a critical, cohesive document that has coalesced a government-wide conversation on the actionable priorities for supporting a successful Federal Data Strategy. We anticipate the final Year 1 Action Plan this September and encourage the Administration to follow a similar iterative and open approach to developing future Action Plans.
To read the Data Coalition’s comments on the Strategy’s Draft Action Plan, click here.