On Friday the Government Accountability Office released a report (PDF) evaluating the federal government’s progress toward transforming its spending information from disconnected documents into open data – a transformation mandated by the DATA Act of 2014.
In the smallest of nutshells, the GAO report says, first, that the Treasury Department and the White House Office of Management and Budget (OMB) have done a pretty good job setting up the standardized data fields that will govern all federal spending information. But, second, Treasury and OMB must provide more detailed instructions to explain how, exactly, agencies will be required to match their existing, fragmented spending data to the new standards and report it upward by the time the DATA Act’s deadline hits in May 2017.
On both counts, we agree! And so does Congress. Within hours of the report’s release, Republican and Democratic leaders had sent a follow-up letter to OMB director Shaun Donovan asking when those detailed instructions will be ready.
But this report is worth reading not just for these conclusions, but also for how it defines DATA Act success and failure.
Success = Full Lifecycle Transparency
The GAO says the DATA Act, done right, promises full transparency through the whole “lifecycle” of federal spending (page 5). If the federal government successfully standardizes its spending information, and publishes all that information as the law requires, it’ll be possible to track taxpayer dollars through every stage of the federal government’s decision-making: appropriation, apportionment, allocation, commitment, obligation, and final payment.
Imagine being able to say to your member of Congress, “You voted for this appropriation, and the money went to this agency, got spent on this questionable program, and wound up being paid to this shady contractor!” That’s what full lifecycle transparency means.
The GAO’s vision matches the way the Treasury Department views its DATA Act challenge. Since at least 2014, Treasury has been promising that data standards will open up the lifecycle to public scrutiny.
The GAO’s vision also will give us a way to judge whether the DATA Act is being followed or not. If the law is fully implemented, we’ll have full lifecycle transparency. Anything less is failure, and means someone isn’t following the law.
Linking Financial and Award Information is Crucial
When Treasury and OMB released their initial plans for DATA Act implementation last May, they made an ambitious promise: agencies will be required to link their financial and award information together. Financial information includes accounting and budgeting details; award information includes details about contracts, grants, and other assistance.
Historically these two types of information have lived in separate systems that don’t play well together. But now, as OMB’s guidance (page 8) put it, “This linkage will facilitate timely reporting of award level financial data, reduce reporting errors, and serve as the primary mechanism moving forward for associating expenditures with individual awards as required” by law.
The GAO report now confirms how important this linkage will be for the overall success of the DATA Act. Unless financial and award information are linked, the report says, there’ll be no way to achieve full lifecycle transparency (page 5). And when the report summarizes the steps of DATA Act implementation that agencies must pursue, linking financial and award information takes up a whole step of its own (table 1 and table 3).
For most agencies, this crucial step still lies in the future (page 21). The GAO report says agencies need more help with it: more detailed instructions from Treasury and OMB.
OMB’s Strange Dodge on Data Definitions
The GAO report ends with a view of how OMB – or at least its lawyers – view the DATA Act. They wish it would go away.
Every GAO report includes a summary of how the subject agencies reacted when given an advance view of its findings. For Friday’s report, as usual, GAO asked OMB and Treasury to react.
OMB’s reaction is interesting. In its responses to the GAO report’s discussion of the 57 standardized data fields that were adopted last year, OMB claimed only eleven of them were actually required by the DATA Act, and the rest were just good government.
OMB even said the law doesn’t require the government to standardize the electronic ID codes for grantees, contractors, and the grant and contract awards they receive (page 26). That’s a direct contradiction to the law itself, which says:
“[Treasury and OMB] shall establish Government-wide financial data standards for any Federal funds made available or expended by Federal agencies and entities receiving Federal funds … The data standards … shall, to the extent, reasonable and practicable … include unique identifiers for Federal awards and entities receiving Federal awards that can be consistently applied Government-wide.”
(Federal Funding Accountability and Transparency Act, as amended by DATA Act, Sec. 4.)
The GAO report quite rightly points out the contradiction between what the law says and what OMB says (pages 26-27).
The GAO observations are troubling. It looks like OMB may be trying to redefine the DATA Act to require less than it actually does. By claiming that the law doesn’t really require government-wide ID codes for awards and awardees, OMB could have allowed itself to discontinue work on these standards in the future, or to tell agencies they don’t have to follow these standards if it looks too hard.
Congress should ask OMB why it tried to convince itself, and GAO auditors, that the DATA Act doesn’t mean what it says – and if it’s trying to redefine other parts of the law out of existence.