THE
CONTROLLER
M-17-04
EXECUTIVE
OFFICE
OF
THE
PRESIDENT
OFFICE
OF
MANAGEMENT
AND
BUDGET
WASHINGTON,
D.C
.
20503
November
4,
2016
MEMORANDUM
FOR
AGENCY SENIOR ACCOUNTABLE OFFICIALS
FROM:
David~~
Controller
SUBJECT: Additional Guidance for DATA Act Implementation: Further Requirements for
Reporting and Assuring Data Reliability
This Memorandum provides additional guidance to Federal agencies to support the technical
operationalization ofreporting to
USASpending.gov
1
in accordance with the Federal Funding
Accountability and Transparency Act
of2006
2
(FFATA), as amended by the Digital
Accountability and Transparency Act
of2014
3
(DATA Act or FFATA,
as
amended), and
in
furtherance
of
Federal spending transparency. This guidance does not affect
ot
change any
existing policy or regulation.
Consistent with MPM
2016-03 "Additional Guidance for DATA Act Implementation:
Implementing a Data-Centric Approach for Reporting Federal Spending
Information," this
Memorandum further specifies
(1) responsibilities for reporting financial information for awards
involving Intragovernmental Transfers (IGTs), (2) guidance for reporting financial assistance
award records containing personally identifiable information
(PII), and (3)"guidance for agencies
to provide the Senior Accountable Official
(SAO) assurance over quarterly submissions to
USASpending.gov. Agencies are required to comply with the record keeping and reporting
requirements detailed below for the first May
2017 DATA Act reporting and for every quarter
thereafter.
Agency
SAOs will coordinate with ongoing efforts government-wide and across appropriate
partner agencies,
OMB, and Treasury to ensure the protection
of
classified or protected
information as defined by Section 7
of
the DATA Act. Through this ongoing government-wide
coordination effort, agencies should not disclose classified activities over the data they submit to
USASpending.gov, including unclassified information that when aggregated becomes classified.
1
This
Memorandum's
requirements apply
to
reporting
of
required data
for
posting on USASpending.gov
or
its
successor website. Any reference
to
"USASpending.gov" means USASpending.gov
or
a successor system.
2
Federal Funding Accountability and Transparency Act
of
2006 Pub.
L.
No. 109-282, 120 Stat. 1186 (codified
as
amended at 31
U.S.C.
§ 6101 note).
3
Digital Accountability and Transparency Act
of
2014. Pub.
L.
No. 113-101, 128 Stat. 1146, (codified
as
amended at
31
U.S.C.
§ 6101 note).
1
1.
Reporting Financial Information involving lntragovernmental Transfers
This section specifies reporting responsibilities for financial information required by the
DATA Act involving funds transferred between agencies. DA TA Act requirements affect
the reporting
of
two types
of
intragovernmental transfers: allocation transfers and buy/sell
transactions which result in Federal awards that are subject to FF ATA reporting. The
guidelines below
do
not affect or change any existing policy or regulation.
In
circumstances where awards are made using funds from such intragovernmental
transfers, awarding agencies
4
will continue to report award-level information (Files
Dl
and D2
of
the
DATA
Act Information Model Schema (DAIMS)
5
)
under FFATA and the
Federal Acquisition Regulation (FAR)
if
applicable; however, the responsibility for
reporting financial information (Files A-C
of
DAIMS) depends on the type
ofIGTs
being
reported.
• Allocation Transfers
Beginning with the first DAT A
Act
submission, the awarding agency will submit
and assure the appropriations information, program activity and object class, and
award financial information for allocation transfers for display on
USASpending.gov (Files A-C
ofDAIMS
vl.O). Funding and awarding agencies
should determine an internal process to share the data in Files A-C before the
awarding agency submits the data for display on
USASpending.gov.
OMB
Circular No. A-11 (A-11) requires the funding agency to determine which
agency, funding or awarding, is required to report to GTAS (Governmentwide
Treasury Account
Symbol). In the future, DATA Act reporting will also allow the
funding agency to determine which agency, funding or awarding, will submit
appropriations information, program activity and object class, and award financial
information for display on
USASpending.gov (Files A-C
of
DAIMS
vl.0).
6
Consistent with A-11 and OMB Circular No. A-136 (A-136)11.4.2 (5), the
funding agency is responsible for appropriations information, program activity,
and object class information (Files A-B
ofDAIMS). The funding and awarding
agencies will share responsibility for the award financial data (File C ofDAIMS).
Specifically, the awarding agency will be responsible for individual obligations
and the funding agency will be responsible for the association
of
the individual
financial obligations data to the appropriations account level data.
4
"Awarding agency"
or
"awarding entity" refers
to
the "child," seller, or serving agency whose budget authority
comes from offsetting
collections. Consistent
with
the data definitions finalized August 2015, awarding agency
is
"the name associated
with
a department
or
establishment
of
the Government
as
used
in the Treasury Account
Fund
Symbol
(TAFS)"
that
"awarded, executed
or
is
otherwise responsible for the transaction."
5
For
additional information regarding the DAIMS
see:
https://community.max.gov/x/Clbyl
6
To
provide alignment with the reporting required by Circular A-136
11.4.2
(5), the
same
exceptions outlined A-136
11.4
.2
(5)
apply
to
DATA
Act reporting.
2
For all allocation transfer related data included in DATA Act Files A-C, the
awarding agency must provide assurance
of
the accuracy and reliability
of
the
data to the funding agency. The funding agency, in turn, will be responsible for
assuring the submission
of
the information in Files A-C for display on
USASpending.gov.
To
facilitate a more robust parent/child submission workflow
and certification process could be included in subsequent releases
of
an updated
DAIMS could be updated post-May 2017 with input from agencies.
• Buy/Sell Transactions:
When a funding agency funds a service through an awarding agency, both the
awarding and funding agency are responsible for submitting appropriations data
and program activity and object class data (Files A-B
of
the DAIMS vl.O). In
addition, the awarding agency will submit the financial award data (File
C) and
will continue to report award-level information (Files D 1 and
D2
of
DAIMS v 1.0)
under FF A
TA
and the
FAR
if
applicable. Buy/sell transactions may include many
funding agencies to one awarding agency or one awarding agency to one funding
agency; the instructions for reporting are the same in both cases.
2.
Reporting Financial Assistance Awards Containing PII
Consistent with §7
ofFFATA,
as amended by DATA
Act
and current reporting practices,
personal identifiable information
(PII) associated with awards to individuals should not be
reported to
USASpending.gov. OMB Circular No. A-130 defines PII as "information that can
be used to distinguish
or
trace an individual's identity, either alone
or
when combined with
other information that is linked or linkable to a specific
individual." Agencies currently
report financial assistance records containing
PII in summary groups
of
similar awards at the
county level known as
"aggregate records."
Level
of
Reporting Financial Assistance Awards with
PI!
To ensure maximum transparency in Federal spending, agencies must report each fmancial
assistance award at the most granular level practicable while protecting
PII. This guidance
does not require any change to the nature
of
data agencies are required to collect from
recipients for financial assistance award management and oversight. Given the required data
collections,
ifreporting
at the single award level
is
not practicable,
7
agencies may report at
the county level, and
if
not practicable, aggregated at the state level, consistent with the
following:
• Single Awards Containing PII: Agencies should report single awards at the
award-level to the maximum extent practicable.
Criteria for reporting at this level:
If
an agency captures a FAIN and other details
for an award to an individual, the agency should report that award to
7
Reporting at the single award level may not
be
practicable due
to
a lack
of
data collected or due to the extent
of
the required redactions.
3
USASpending.gov as a single, discrete record.
Method for linking: Records reported in this way
will be linked using the FAIN as
the Award ID, with any
PII redacted by the agencies before submission.
• Aggregated Awards- County Level:
If
single award-level reporting is not
practicable, agencies may report at the county level.
Criteria for reporting at this level:
If
an agency does not capture a FAIN or other
individual details for an award to an individual, the agency should include that
award in a county-level aggregate record with other similar awards.
Method for linking: Records reported in this way will be linked using the Unique
Record Identifier (URI) as described below and conform to the validations as
defined in the DAIMS.
• Aggregated Awards- State Level:
If
neither single award-level reporting nor
county-level reporting is practicable, agencies may report at the state level.
Awards currently reported at a lower level than state (i.e., county) should continue
to be reported at the same or lower level to maintain the current standards
of
transparency.
Criteria for reporting at this level: Awards should be aggregated at the lowest
possible level to ensure the highest degree
of
transparency and data quality.
If
awards are not able to be aggregated at the county level, they should be
aggregated at the state level.
Method for linking: Records reported in this way will be linked using the URI as
described below.
As
of
the date
of
this Memorandum, the DAIMS v.1.0 provides for reporting at the aggregate
county level only. Agencies should continue the current practice ofreporting county-level
aggregates to protect
PII until modification
of
the DAIMS v.1.0 to support reporting at the
single award level, with redacted
Pll, and the state level can be implemented post-May 2017.
More technical guidance about reporting at the single award level and the state award level
will be shared when the DATA Act Schema is modified to accept these records.
Linking Aggregate Records through the URI
Agencies must link new financial assistance aggregate records to financial data through the
URI for data displayed on USASpending.gov by May
2017.
By
using the URI for connecting
the aggregate financial data and award data, users will have the same spending lifecycle view
as provided through use
of
the Award ID linkage.
Agencies that are unable to include the
URI in management and financial systems for county-
level aggregate records displayed beginning May
2017 may manually link the award and
4
financial data in their submission (award financial file - file C) using URI. All Federal
financial service providers and agencies will be required to achieve the automatic linkage for
new aggregate records between the financial and award management systems by
October
1,
2018.
3. Quarterly SAO Assurance over DATA Act Data
As stated in MPM 2016-03 agency DAT A Act SA Os or their designees must provide a
quarterly assurance
8
that their agency's internal controls support the reliability and
validity
of
the agency account-level and award-level data reported for display on
USASpending.gov. MPM 2016-03 specifies that this assurance should leverage data
quality and management controls established in statute, regulation, and Federal-wide
policy and be aligned with the internal control and risk management strategies in
OMB
Circular No. A-123 (A-123).
Agency's
SAO assurance will be submitted quarterly through the forthcoming DATA
Act Broker process.
9
The quarterly process will require the SAO to assure the following:
• The alignment among the Files
A-Fis
valid and reliable. Since a DATA Act
submission contains a combination
of
many data sets, the SAO will be required to
attest to the validity and reliability
of
the complete DAT A Act submission,
including the interconnectivity/linkages (e.g. award ID linkage) across all the data
in files
A,
B,
C,
D, E, and F. Where there are legitimate differences between files,
the
SAO should have categorical explanations for misalignments. To provide this
assurance, agencies should have internal controls in place over all
of
the data
reported for display
USASpending.gov per A-123.
• The data in each DATA Act file submitted for display on USASpending.gov
are valid and reliable.
To provide this assurance, the SAO will confirm that
internal controls over data quality mechanisms are in place for the data submitted
in DATA Act files. Existing data quality measures required by regulation and/or
OMB guidance will be sufficient for SAO reliance on individual data files.
Consistent with MPM
2016-03, Appendix A summarizes the authoritative sources
for each file and existing validations and assurances over the data and files
reported to
USASpending.gov.
The SAO is responsible and accountable for their agency's data submission.
Appendix A explains how the
SAO should leverage the existing requirements to
support the assurance
of
data reported for display on USASpending.gov. An
integral component
of
the existing requirements is the guidance in A-123, which
directs agencies to establish internal tools and processes as necessary in support
of
the
SAO's
assurance. OMB
is
also reviewing opportunities to enhance assurances
over specific DA TA Act data and files and provide additional guidance, as
appropriate.
8
In
general,
an
assurance
is
a statement
of
accountability
to
confirm
an
agency's efforts
to
supporting data quality.
9
More information about the technical process
for
submitting the
SAO
quarterly will
be
provided when this policy
is
implemented.
5
Agencies are responsible for providing assurances over the data they submit for display
on
USASpending.gov. In the case
of
an IGT, agencies are responsible for assuring the
data in the files they submit in accordance with the reporting requirements summarized
in
Section 1 above.
Consistent with the Federal Acquisition Regulation and 2
C.F.R.,
Federal prime
awardees (i.e., prime recipients) are responsible for reporting subaward and executive
compensation data regarding their first-tier subawards in FFATA
Subaward Reporting
System (FSRS) and System for Awards Management (SAM), respectively, to meet the
FF ATA reporting requirements.
10
Agencies must continue to comply with current
regulatory requirements, such as requiring Federal prime awardees report to
FSRS and
SAM as part
of
the terms and conditions
of
the award, to promote accurate and complete
awardee and subawardee data in
FSRS and SAM. More detail about SAO assurance
related to awardee reported data in
FSRS and SAM data can be found in Appendix
A.
If
you have any policy questions about this guidance, contact
SpendingTransparency@omb.eop.gov.
If
you have any technical questions about
USASpending.gov, please contact the Department
of
the Treasury's
DAT
A Act Program
Management Office
(PMO) at [email protected].
10
https://www.fsrs.gov/documents/OMB Guidance
on
FFATA
Subaward
and
Execut
i
ve
Compensati
on
Reporti
ng
08272010.pdf
6
APPENDIX
A-Assurances
for Each
DATA
Act File Submitted
DATA
Act Authoritative
Existing
DATA
Act SAO Assurance Required
File Source (consistent Assurances or Internal Controls over
with
MPM
2016-03 Authoritative Source Data (Pre-DA
TA
Act)
and regulation)
A: The SF-133 Report on
Pursuant to A-136, the reporting agency must
The reporting objective is that the data
Appropriations Budget Execution and
reconcile
3rd
Quarter and year-end SF-133 data
reported in
File A match the authoritative
Account
Budgetary Resources to their Statement
of
Budgetary Resources source (i.e., SF-133) and that all TAS are
derived from
(SBR). reported.
Government-wide
Treasury Account Year-end data are audited
financial data which To increase the likelihood that this objective
Symbol Adjusted
are subject to management assurances
of
will be met, the agency SAO will provide
Trial Balance System
internal controls over reporting under A-123. assurance that data integrity processes and
(GTAS) data
controls are
in
place and align with A-123.
Pursuant to
OMB Circular No. A-11 (A-11)
These assurances must be made on a
Section 130.2, for Executive branch agencies, quarterly basis and should leverage the
agencies must report all Treasury
existing processes and other assurances
Appropriation Fund Symbols (TAFSs) in each
listed in the column "Existing
GTAS
reporting window.
Assurances or Internal Controls over
Authoritative
Source Data."
7
DATAAct
Authoritative
Existing
DATA Act
SAO Assurance Required
File Source (consistent Assurances or Internal Controls over
with MPM 2016-03
Authoritative Source Data (Pre-DATA Act)
and regulation)
B:
Object The SF-133 Report on
Pursuant to A-136, the reporting agency must
The reporting objective is that the total
Class and Budget Execution and reconcile
3rd
Quarter and year-end SF-133 to
amount reported in File B matches the
Program Budgetary Resources
their Statement
of
Budgetary Resources (SBR).
authoritative source (i.e., SF-133) and that
Activity derived from
Program Activity and
Object Class Codes
Government-wide
Year-end data are audited financial data which
are reported based on the President's Budget
Treasury Account are subject to management assurances
of
as executed
11
and A-11 respectively.
Symbol Adjusted internal controls over reporting under A-123.
Trial Balance
System
To increase the likelihood that this objective
(GTAS) data The Program Activity names and codes are
will be met, the agency
SAO will provide
embedded in the
President's Budget, not a
assurance that data integrity processes and
separate list that can be used for validation.
controls are in place and align with A-123.
Consequently, there is no current validation These assurances must be made on a
that the names and codes match the list.
quarterly basis and should leverage the
existing processes and other assurances
DATA Act Broker will validate against the list listed in the column
"Existing
of
Object Class codes in A-11. Assurances or Internal Controls over
Authoritative
Source Data."
C:
Award Financial Systems Year-end data are audited financial data. All
The reporting objective is that data reported
Financial
financial data, including the obligations
in File C match the authoritative source (i.e.,
reported in this file, are subject to management
agency financial systems).
assurances under A-123.
11
A-11 Section
82.S
(a)
contains information about how program activities should
be
created, and provides
that
agencies obtain OMB approval
for
any changes
in activity structure.
If
for
any reason, such
as
funding changes made during
the
appropriations process,
an
agency needs
to
change
their
program activities in
the
current fiscal year, such changes should
be
coordinated through
their
OMB Resource Management Office.
In
the
future, corresponding validations
for
program activity in
the
DATA
Act Broker may be implemented.
8
DATA Act
Authoritative Existing
DATA Act SAO Assurance Required
File
Source (consistent Assurances or Internal Controls over
with MPM
2016-03 Authoritative Source Data (Pre-DATA Act)
and regulation)
To
increase the likelihood that this objective
will be met, the agency
SAO shall provide
assurance that data integrity processes and
controls are in place and align with A-123 .
These assurances must be made on a
quarterly basis and should leverage the
existing processes and other assurances
listed in the column
"Existing
Assurances or Internal Controls over
Authoritative
Source Data."
DI:
Federal Procurement
Pursuant
to the Federal Acquisition Regulation The reporting objective is that for data
Procurement
Data
System-
Next
and
OMB memoranda beginning in 2009,
12
reported pursuant to FF ATA (P .L. 109-282)
Award
Generation
(FPDS- agencies are required to submit an annual
as amended by the DATA Act
(P.L. 113-
Attributes NG)
FPDS-NG Data Verification and Validation I
01
), they are sourced from and match
Report to
OMB and GSA. The report includes FPDS-NG at the time
of
quarterly reporting.
assurances over the timeliness and
completeness
of
the data and sampling
of
the
To
increase the likelihood that this objective
core
DATA
Act required data elements, will be met, the agency SAO will rely on
comparing contract files to
FPDS-NG. internal controls (A-123) based on
FAR
required verification and validation for the
assurance over Federal procurement awards.
12
Relevant
OMB
memoranda
can
be
found at:
https://www
.whitehouse.gov/omb/procurement_index_pro_data
9
DATAAct
Authoritative
Existing
DATA Act
SAO Assurance Required
File Source (consistent Assurances or Internal Controls over
with MPM 2016-03
Authoritative Source Data (Pre-DATA Act)
and regulation)
D2: Financial Agency Management No current certification or assurance process
The reporting objective is that data reported
Assistance
Systems/Files (for
performed by agencies.
OMB is reviewing
in File D2 match the authoritative source
Award
award description,
opportunities to enhance assurances over this
(i.e., agency award management systems)
Attributes
award title, etc.)
data.
for award-level data and the authoritative
Financial Assistance
source (i.e.,
SAM) at the time
of
the award
Awardee data in
SAM Agencies may also leverage the data
for prime awardee information.
at the time
of
award validations included in the Award Submission
(for prime financial
Portal as a control that their data follows the
To increase the likelihood that this objective
assistance awardee standard format.
will be met, the agency
SAO will provide
information)
assurance that data integrity processes and
For
entities required to register in SAM or controls are in place and align with A-123.
otherwise registered, a validation
of
key data is
These assurances must be made on a
performed to assure for the purposes
of
SAM quarterly basis and should leverage the
data quality that the entity registration data are existing processes and other assurances
accurate. Agencies may leverage this existing listed in the column "Existing
validation as a control over the data submitted Assurances or Internal Controls over
to
SAM. Authoritative Source Data."
E: Highly SAM
13
Contracts and financial assistance awards
14
Agencies will be able to leverage assurances
Compensated contain terms and conditions requiring based on the internal controls
of
the system
Officer Data
reporting
of
executive compensation.
owner, the General
Services Administration
13
Not all award recipients are required
to
register in SAM. Controls and assurances associated
with
SAM
data are
not
expected
to
be
applied
to
recipients
who
are exempt from
SAM
registration
or
who are
not
required
to
register.
14
At
the
time
this Memorandum was issued,
2CFR
170 only required agencies
to
include this
term
and condition on grants
and
cooperative agreements.
In
the
future, this requirement may
be
expanded
to
include loans and
other
forms
of
financial assistance.
10
DATA Act
Authoritative Existing DATA Act SAO Assurance Required
File
Source (consistent Assurances or Internal Controls over
with MPM 2016-03
Authoritative Source Data (Pre-DATA Act)
and regulation)
(GSA) in accordance with A-123. In
For procurement,
OMB guidance
of
May 2011 , addition, for procurement-related awards,
requires agency Senior
Procurement Executives agencies will leverage the existing OMB
to certify that agency policies, procedures, and
guidance on subaward data quality.
internal controls include reviews
of
contractor
data to assess compliance and completeness.
Contractual remedies exist to address any gaps.
F: Subaward FSRS
Contracts and financial assistance awards
14
Agencies will be able to leverage assurances
Attributes
contain terms and conditions requiring
based on the internal controls
of
the system
reporting
of
executive compensation.
owner, GSA, in accordance with A-123.
OMB is reviewing mechanisms to further
For procurement,
OMB guidance
of
May 2011 ,
enhance assurances over these data for
requires agency Senior
Procurement Executives
financial assistance awards.
In
addition, for
to certify that agency policies, procedures, and
procurement-related awards, agencies will
internal controls include reviews
of
contractor
leverage the existing
OMB guidance on
data to assess compliance and completeness.
subaward data quality.
Contractual remedies exist to address any gaps.
11
