Last week, just before the Thanksgiving holiday, the U.S. Treasury Department collected formal comments from all interested parties on the crucial first step of implementing the Digital Accountability and Transparency Act (DATA Act). By May 2015, Treasury and the White House Office of Management and Budget (OMB) must establish government-wide data standards for federal spending.
Data standards will transform U.S. federal spending from disconnected documents into open, machine-readable data. So it’s crucial for Treasury and OMB to get the data standards right.
The Data Transparency Coalition’s comment – full text available here – runs over 20 pages. If you prefer a quick summary to the full text, you’re in luck. Here’s what we said.
Sing from the Same Data Hymnbook!
Once government money managers start singing from the same data hymnbook, taxpayers and their representatives in Congress will be able to follow the money. Agencies will be able to use Big Data tools to better manage their own finances. And recipients of federal grants and contracts will be able to save money by reporting automatically. Data standards can deliver these benefits.
But in order to deliver the promised benefits, the standards, and the way they’re maintained and used, must meet certain basic criteria.
- The data standards must be complete. The law requires that the standards cover all of the existing reporting regimes that agencies and recipients use to report how they receive and spend federal money.Agencies report their spending through five key reporting regimes: (1) Financial Account Balances, reported to Treasury; (2) Payment Requests, submitted to Treasury; (3) Budget Actions, reported to OMB; (4) Contracts, reported to the GSA; and (5) Grants and Other Assistance, formerly reported to the Commerce Department but now reported to Treasury. For recipients, the picture is more complicated. Grantees and contractors might report to the agency that gave them the funds; to various systems at the General Services Administration; and to the FFATA Subaward Reporting System, if they’ve packaged the money they received into sub-grants or sub-contracts.The data standards have to incorporate all these reporting regimes – and must link them together with common data elements. In our comment, we discussed five groups of core concepts that could become a government-wide core taxonomy, or basic data element dictionary, for federal spending:
What for? (Transaction Subject), How much? (Dollar Amount), Who? (Payor/Payee), When? (Time), and Where? (Location).
- The data standards must be fully accepted. Treasury and OMB should start with data elements and data formats that others have already built, like the Legal Entity Identifier for grantees and contractors and XML / XBRL to format reports.
- The data standards must be nonproprietary. The data standards can’t be restricted by licensing requirements, or the data won’t be truly open. There’s more (much more!) on this topic below.
- The data standards must be adopted incrementally. Treasury and OMB should start with the reporting regimes they already control and encourage the others to start using the data standards more gradually.
- The data standards must be fully enforced. The failure of the Securities and Exchange Commission to enforce the quality of the structured financial data that it collects from public companies shows it’s crucial to reject, and correct, submissions that don’t adhere to the data standards.
- The data standards must be fully sustainable. There should be some sort of governance framework to maintain the data standards and update them as needed. There’s more on this below.
- Once federal spending information is reported using the data standards, these reports must easily support validation. It should be easy for agencies and recipients to submit standardized spending reports, see where there are errors, and correct the errors.
DATA Implementation needs a Governance Structure
Treasury and OMB can’t create and maintain the data standards on their own. They must create a government-wide advisory body, involving everybody who participates in the existing reporting regimes. This advisory body can provide input on what the data standards should look like – and later be responsible for harmonizing the different reporting regimes to conform to the data standards.
The Data Transparency Coalition comment encouraged Treasury and OMB to create an advisory body representing each existing reporting regime. These regime-specific advisory bodies could supplement the work of the government-wide DATA Act inter-agency advisory committee that Treasury and OMB have already established. Working together, the inter-agency and regime-specific advisory groups could recommend first a government-wide core taxonomy and then regime-specific supplements to that core, each mapping to the core taxonomy. After the announcement of the first version of the standards (by the legislative deadline of May 9, 2015), the regime-specific groups could be put in charge of harmonizing their own reporting regime with the core and with its own regime-specific taxonomy.
Our comment includes examples of standards governance and the lessons lessons already learned. For example, we noted that National Information Exchange Network (NIEM) handles many disparate domains, from health care to homeland security, with varying needs for extensibility. The NIEM program offers two types of standards updates: major and minor releases, so we suggested that Treasury and OMB could choose to maintain DATA Act data standards in a similar manner.
Want DATA to work? Dump DUNS
If high quality government spending information is to be freely available to taxpayers and their representatives in Congress, then the government needs to use a non-proprietary identifier for grantees and contractors. Treasury and OMB must choose to stop using the proprietary Data Universal Numbering System (DUNS) number, which is owned by Dun & Bradstreet, Inc.
The government’s continued reliance on the DUNS number prevents federal spending data from being truly open. And it unduly restricts competition in the transparency marketplace.
Why is the method of identifying recipients so important? Here’s one example.
Our comment describes Treasury’s collection of payment requests and GSA’s collection of contract summaries, which both require agencies to identify the recipient of contract payments. Today the two reporting regimes express this information differently. Most payment requests submitted to Treasury identify the recipient using an Employer Identification Number (EIN). In contrast, contract summaries identify the contractor using the DUNS number. If these two reporting regimes used the same number, it would become possible to match payments to recipients.
(Dun & Bradstreet’s own comment to Treasury has a different perspective.)
The Data Transparency Coalition generally encourages the government to engage industry – companies like Dun & Bradstreet – to help improve the quality of data. However, the core “Who” element is so central to federal spending that no one company should hold a monopoly on how it’s expressed.
Increase Transparency, Reduce Compliance Costs, and Create Tech Jobs.
If implemented successfully, the DATA Act will deliver cost savings within government by reducing red tape and allowing information to flow better between silos. The DATA Act has the potential to modernize government, giving stakeholders the tools to understand, monitor, predict, and make decisions using timely data on actual expenses – just as America’s leading corporations do already. The DATA Act could also relieve the burden of compliance on industry through automated reporting of data rather than documents.
Our members have business opportunities to pursue, too.
The DATA Act’s enactment and successful implementation has been a primary motivator for the Data Transparency Coalition’s founding in 2012. As the nation’s only open data trade association, we represent leading technology and consulting firms, including both industry leaders and growing startups. Some of our members offer software solutions and platforms. Others offer solution-agnostic expert advice. The DATA Act transformation will also enable many of our members to pursue new business models and create high-tech jobs.
We’re confident that Treasury and OMB can deliver data standards that will do all these things. We’ll be watching to make sure.