Inspectors General Evaluate Their Agencies: Spotty Progress on DATA Act (updated on 02/27)

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Inspectors General Evaluate Their Agencies: Spotty Progress on DATA Act (updated on 02/27)

The Digital Accountability and Transparency Act of 2014 (DATA Act) requires every federal agency to begin reporting its spending information using a standardized data structure, starting in May 2017. This is a major change: for the first time, federal spending information will be available as a single, searchable data set, rather than a jumble of disconnected documents and incompatible databases.

The law requires every agency’s office of inspector general (OIG) to evaluate and report on its agency’s progress. We have compiled the OIG reports that are publicly available for the larger federal agencies. While some offices have not submitted their reports, we will continue to monitor the release of these reviews and update this blog, accordingly.

Department of AgricultureAssistant IG Gil H. Harden, February 9, 2017
Conclusion of ReviewThe Department of Agriculture should be able to meet the May 2017 reporting deadline. The IG report notes that USDA has identified challenges that could impede its progress towards implementing the Treasury’s DATA Act Playbook, and has drafted solutions to meet the challenges — “in some cases, developing interim manual solutions until permanent automated solutions can be implemented.” (Page 8)
Department of Commerce, Deputy Assistant IG Richard Bachman, February 17, 2017
Conclusion of Review: The IG report hesitates to express confidence in Commerce’s ability to meet the May 2017 DATA Act reporting deadline. According to the audit, Commerce has condensed implementation steps of the Treasury’s Playbook into a shortened time frame. As such, the IG concludes that “the adverse impact, caused by the delayed planning activities, has created substantial risk that the Department will not be able to complete its implementation of the DATA Act requirements by the April 30, 2017 deadline.” (Pages 3 and 4) 
Department of Defense, Assistant IG Lorin T. Venable, November 17, 2016
Conclusion of Review: DoD has completed Steps 1, 2, and 4 of Treasury’s Agency 8-step Plan, and has mostly completed Step 3. Regarding future expectations for reporting progress, “DoD notified Treasury and OMB that it plans to use two of three waivers to extend the reporting deadline for the transaction-level financial data by 1 year, or until the second quarter 2018.” (Page 4)  
Department of EducationAssistant IG Patrick J. Howard, January 26, 2017
Conclusion of Review: The Department of Education should be able to meet the May 2017 deadline, if present issues are addressed. The IG audit found that the Department of Education has largely complied with the Treasury’s Playbook, steps 1 through 4, but needs to improve its project management process. The identified weaknesses in the management process “may increase the risk of erroneous decision-making and future implementation delays.” (Page 3)
Department of EnergyIG Rickey R. Haas, November 29, 2016
Conclusion of Review: DoE is on track to meet the May 2017 deadline.
Department of Health and Human Services, IG Daniel R. Levinson, November 2, 2016
Conclusion of Review: According to HHS report, which was executed by Ernst & Young (30 June 2016), internal and external factors have hindered the department’s implementation of steps one through four of the Treasury’s Agency 8-Step Plan. The audit recommends that the Department move from high-level planning to detail-driven project execution. 
Department of Homeland Security, October 4, 2016
Part of the IG’s “On-going Projects”:
Department of Housing and Urban Development, Director Thomas R. McEnanly, Financial Audits Division, GAF, August 26, 2016
Conclusion of Review: HUD is not on track to meet the May 2017 deadline. The Department has made progress on Steps 3 and 4, but has been unable to resolve data quality issues with information that would be submitted to  
Department of InteriorAssistant IG Kimberly Elmore, November 30, 2016
Conclusion of Review: Interior is not on track to meet the May 2017 deadline. The IG’s audit found that delayed guidance, lack of funding, and the need for software updates have impeded the Department’s implementation of the “DATA Act Playbook” (also referred to as, Treasury’s Agency 8-Step Plan), Steps 1 through 4.
Department of Justice, IG Michael E. Horowitz, December 2016
Conclusion of Review: “[N]othing came to our attention that caused us to believe that a material modification should be made to the Department’s assertion that it will be ready to implement the requirements of the DATA Act by May 2017. However, we noted areas of concern that potentially could impact the Department’s ability to most effectively meet all the requirements within the requisite timeframe. ”
Department of Labor, IG Scott S. Dahl, September 30, 2016
Conclusion of Review: Labor did not implement appropriate tracking mechanisms to measure progress and could not demonstrate that it had completed major DATA Act milestones. While the Department communicated confidence that it would meet the May 2017 deadlines, the OIG noted that was no reasonable assurance that Labor would meet these deadlines.
Department of State
Report has not been published:
Department of Transportation, IG Louis C. King, November 4, 2016
Conclusion of Review:  DOT made measurable progress in the implementation of Steps 1 through 4, but has also encountered challenges while waiting for software patches from the Department’s Enterprise Services Center (ESC). If the patches do not work, ESC is confident that their office will be able to develop a workaround so that the department can meet the DATA Act May 2017 deadline. (Page 12)
Department of the TreasuryAssistant Secretary of Management Kody Kinsley, December 1, 2016
Conclusion of Review: Treasury has made progress in implementing the DATA Act, but must address project management practices. Reporting standards, communications, and tracking metrics must be improved for Treasury to meet DATA Act implementation deadlines.
Department of Veterans Affairs
Environmental Protection Agency, IG Arthur A. Elkins, Jr., December 2, 2016
Conclusion of Review: The IG review commended the EPA on its progress regarding Steps 1 through 4 of the Agency Playbook, noting that the Agency had highlighted internal key risk areas to address before the May 2017 deadline. Challenges that might delay full compliance with DATA Act standards include award identifications linkage and reconciling accurate data syncs between the Agency and external systems, among others. (Pages 5 and 6)
Report has not been published:
General Services AdministrationAssociate Deputy Assistant IG Marisa A. Roinestad, November 30, 2016
Conclusion of Review: GSA made notable progress in implementing Steps 1 through 4, but faces significant challenges to incorporating additional DATA Act requirements. According to the IG’s report, GSA must address the absence of its required data element (Parent Award ID) in its reports to Treasury and must “ensure the reliability and validity of data submissions.” (Page 6-7)
National Science Foundation, Assistant IG Mark Bell, November 29, 2016
Conclusion of Review: NSF is at risk for not meeting the May 2017 deadline. Delayed software patches and internal project management challenges, among other barriers, may lead to oversights of project tasks and milestones. (Page 2) Upon completion of the OIG review, NSF acknowledged OIG’s recommendations and initiated corrective actions to address its project management challenges, like completing a Risk Management Plan. (Page iv, “At a Glance”)
Nuclear Regulatory Commission, Assistant IG Dr. Brett M. Baker, November 30, 2016
Conclusion of Review: The OIG retained the services of Miracle Systems LLC to review the NRC’s DATA Act readiness levels. Miracle Systems concluded that NRC is on track to meet the May 2017 deadline.
Office of Personnel Management
Railroad Retirement Board, IG Martin J. Dickman, October 4, 2016
Conclusion of Review: The OIG is “uncertain whether the RRB will be able to comply with DATA Act reporting requirements within the specified timeframe because of its heavy reliance on its [FMIS] contractor with limited oversight by RRB management.” (Page 3)
Small Business AdministrationDeputy IG Hannibal M. Ware, December 2, 2016
Conclusion of Review: SBA has successfully worked through Steps 1 through 5 of Treasury’s 8-Step Agency Plan, including the execution of the DATA Act Broker. The IG’s report highlighted two risk areas that SBA will need to address as they move forward with Steps 6 through 8. (Page 3)
Social Security Administration, IG Gale Stallworth Stone, November 9, 2016
Conclusion of Review: Based on the results of the OIG review in August 2016, the reviewers noted no concerns for SSA’s readiness, but did note three challenge areas. The Administration needs to apply a software patch to capture all necessary financial award identifiers during the data inventory process; SSA must reconcile validation errors associated with split funding for information technology systems and delegated building accounts; and the SSA does not currently have the structure to identify award identifiers for grant recipients and grant modifications, which is required for DATA Act reporting. (Page 5)
Commodities Futures and Trading Commission, Assistant IG Miguel A. Castillo, November 29, 2016
Conclusion of Review: In line with the interagency agreement, the Enterprise Service Center (ESC) leads CFTC’s implementation of the DATA Act requirements. According to the OIG report, CFTC is on track to meet the May 2017 deadline and ESC has developed a “comprehensive technical plan for complying with the DATA Act.” (Page 3)
Consumer Financial Protection Bureau, Associate IG Melissa Heist, November 30, 2016
Conclusion of Review: CFPB created the structure and workgroup necessary to initiate the Bureau’s implementation of DATA Act standards, and has identified immediate areas of improvement for the next phase of implementation. According to the IG review, CFPB will need to define the roles and responsibilities of the Bureau’s shared services provider – Bureau of the Fiscal Service, Administrative Resource Center (BFS ARC). Doing this will increase the likelihood that CFPB will meet DATA Act requirement by the May 2017 deadline.
Federal Communications Commission
Federal Deposit Insurance Corporation, Assistant IG Mark F. Mulholland, September 23, 2016
Conclusion of Review: The FDIC made notable progress on Steps 1 through 4, but has been impeded by delayed communications from OMB and Treasury. In addition to these delays, OMB, in collaboration with Treasury, has not addressed GAO’s recommendation to clarify agency efficacy for non-annual award appropriations. Such standards are essential for FDIC to move forward with DATA Act reporting.
Export-Import Bank of the United States, Assistant IG Terry Settle, November 28, 2016
Conclusion of Review: EXIM IG relied on Cotton & Company LLP (Cotton), an independent public accounting firm, to perform the audit. EXIM established internal frameworks to support the implementation of DATA Act standards, but has several opportunity areas for improvement. Cotton listed eight recommendations to help EXIM meet the May 2017 deadline. (Page ii)’%20Report%20on%20the%20Export-Import%20Bank’s%20DATA%20Act%20Readiness%20OIG-AR-17-02.pdf
National Credit Union Administration, IG James W. Hagen, November 16, 2016
Conclusion of Review: The OIG concluded that the National Credit Union Administration current plan aligns with OMB’s requirements and has taken the proper steps to meet the May 2017 deadline.
Overseas Private Investment Corporation
Securities and Exchange Commission, IG Carl W. Hoecker, November 2, 2016
Conclusion of Review: The SEC appears to be on schedule to meet the May 2017 deadline, but cannot guarantee fully implementation of the eight-step plan. The SEC must obtain and apply financial system software patches to create the required DATA Act submission files. These patches will come from the Federal Shared Services Provider, housed in the Department of Transportation’s Enterprise Services Center, which has voiced confidence that the work will be completed on time.
Supplemental information: