DATA Act Implementation Underway
Last month saw a significant uptick in implementation activities for the DATA Act. On May 8, 2015, the Office of Management and Budget (OMB) and the Department of the Treasury (Treasury) released information on the implementation of the DATA Act. OMB and the Treasury published:
- A list of 57 governmentwide standard financial data elements
- Memorandum M-15-12: Agency guidance on implementing the DATA Act
- A DATA Act Playbook that identifies eight key steps for agencies
In May 2014, President Barack Obama signed The Digital Accountability and Transparency Act (DATA Act) of 2014 , which is designed to enhance the transparency of government spending. Once fully implemented in 2018, the DATA Act will require agencies to publish all Federal spending on USASpending.gov. The DATA Act impacts the grants community by requiring all grant expenditures to be available to the public.
Federal Spending Data Elements
OMB and the Treasury released a list of 57 Federal spending data elements designed to fully implement the DATA Act. Under the DATA Act, all Federal agencies will be required to use the data elements on financial award documents and to upload the information to USASpending.gov. The public has the opportunity to comment on some of the proposed data elements, as only 15 of the 57 data elements have been finalized.
Many of the data elements were previously required under the Federal Funding Accountability and Transparency Act (FFATA). The DATA Act, however, requires Federal awarding agencies to report on account level information. Therefore, new data elements include information related to specific appropriations accounts.
Agency Guidance on Implementing the DATA Act
To assist agencies in implementing the DATA Act, OMB released Memorandum M-15-12 Increasing Transparency of Federal Spending by Making Federal Spending DATA Accessible, Searchable, and Reliable. M-15-12 supersedes all previous guidance from FFATA and agency reporting requirements to USASpending.gov.
Under M-15-12, agencies must:
- Appoint a Senior Accountable Official responsible for the agency’s implementation of the DATA Act
- Develop an implementation framework that identifies timelines, possible challenges, and available resources
- Follow existing reporting procedures through May 9, 2017
- Continue to assign a unique Federal Award Identification Number (FAIN) for all financial assistance awards
- Report specific programmatic information about all financial awards greater than the micro-purchase level of $3,000 to USASpending.gov by May 9, 2017
DATA Act Playbook
In conjunction with M-15-12, the Treasury developed a DATA Act Playbook designed to assist agencies in implementing the DATA Act. The Treasury did not publicly release the Playbook, but did make available a summary of the Playbook’s contents.
The Playbook recommends agencies:
- Create a DATA Act work group
- Review the list of standardized data elements
- Perform an inventory of agency data, processes, and systems
- Identify necessary changes to systems and business processes
- Implement a broker, a virtual data layer that complies with the DATA Act Schema
- Test the broker implementation
- Update other systems as necessary
- Update and refine processes to submit agency data
OMB Announces Pilot Program
The DATA Act requires OMB to test the implementation of the law with a pilot program. To meet this mandate, OMB selected the Department of Health and Human Services (HHS) to conduct that pilot to facilitate the development of the standardized data elements, identify and recommend the elimination of unnecessary duplication in financial reporting, and propose measures to reduce the compliance cost for recipients of Federal awards. HHS will conduct the pilot program for two years and provide OMB recommendations for improved implementation.
In addition to conducting a pilot program, HHS has also created the Common Data Element Repository Library (C-DER Library). The C-DER Library is the single, authoritative source for all Federal-wide standardized data elements. The website contains a downloadable database identifying and explaining each data element. HHS will also update the website to announce new developments regarding the implementation of the DATA Act.
Impact for Grant Recipients
The DATA Act is designed to create minimal administrative burden for grant recipients. It requires Federal awarding agencies to submit all required reporting information, and OMB has until August 2018 to determine if grant recipients will be required to report their information using the data standards. This may pose challenges for some grant recipients to update internal business systems and processes to conform with the required data elements. Therefore, it is important for the grants community to remain informed of the DATA Act implementation timeline, review current systems, and identify potential changes.
Grant recipients may also want to participate in the Chief Acquisition Officers Council’s (CAOC) National Dialogue. The CAOC created a forum in which the grants community can provide feedback and suggestions on reducing reporting compliance costs associated with the DATA Act. The dialogue will be open for two years and the CAOC, OMB, and other government agencies and working groups will use the recommendations to improve the implementation.
The DATA Act is ushering in a more transparent government. It is imperative for Federal awarding agencies and grant recipients remain informed of the changes the law will necessitate. Sign up for our grants blog and eClips newsletter to stay up to date!