Data Quality Playbook 2018

Transcript

1 Data Quality Playbook Working Group d eveloped and issued th Leveraging Data as a Strategic Asset Playbook in collaboration The is gencies to assist with developing Data Quality Plan s in support of the DATA Act implementation . with federal a This is a result of extensive collaboration between agencies, OMB, and the Department of the playbook The final document and subsequent versions will be posted to the CFOC website. The use of the Treasury. playbook format is a practice to gather, define, and illustrate concepts in federal financial management. The DATA Quality playbook joins a library of management resources developed for agency use to include the ERM - Playbook and the Program Integrity; Anti fraud Playbook. As with these playbooks, nothing in this Playbook should be considered prescriptive. All examples provided should be modified to fit the circumstances, conditions, and structure of each agency (or other gover nment organization). The Leveraging Data as a Strategic Asset Working Group extends its gratitude to our colleagues within the This financial management, procurement, and financial assistance communities for their contributions. is intended for m anagement ; it is not audit guidance . Playbook November 30, 2018

2 Data Quality Playbook Executive Summary , OMB ) Circular No. A - 123 Since 1981 Management’s the Office of Management and Budget ( , Internal Control , has been at the center of f ederal requirements to improve Responsibility for ederal programs and operations . Even before the Federal Managers’ Financial Integrity Act and f Government Accountability Office the Standards for Internal Control in the Federal overnment - 123 ’ s first requirements was to develop internal control plans across the G , one of A ederal G overnment . I F Chief Financial Officer ( CFO ) Council worked n 2004, OMB and the together to develop internal control plan s and implementation guidance to im prove internal control over financial reporting (ICOFR) . As a result, most CFO Act agencies have strengthened their internal controls over financial reporting n the spirit of executing the President’s I Leveraging Data as a Strategic Asset Management Agenda Cross Agency Priority goals to , this working group aim s to support the Working Group on of Digital Accountability and integrati Transparency Act of 2014 ( DATA Act ) with existing Enterprise Risk Management processes and through improving reporting cont rols and data quality by providing agencies with this D ata Quality Playbook (The Playbook) . The cover memo of Management of - 18 - 16) of Appendix A of OMB Circular A - 1 23, (M reporting agencies implement a data to Reporting and Data Integrity Risk requires DATA Act quality plan (DQP) effective fiscal year (FY) 2019 through FY 2021 minimum . Th is at a of insights gained by multiple f ederal a gencies, each with represents a compilation Playbook perspectives and lessons learned as DATA Act reporting a gencies . Agencies may find unique when developing a these scenarios useful to consider . DQP This Playbook i s a collection of examples and use - cases agencies have proposed based on agency specific risk assessments at a given time . This P laybook and accompanying appendices - - encies . It is not a n all are designed to provide practical information and helpful scenarios for ag all inclusive catalog of the only acceptable options for developing a DQP and does not address an agency may face potential situations Rather, the with respect to DATA Act implementation . solutions Playbook provides compendium of potential approaches, a , and explanations that provide context aligned with policy and business operations to focus the conversation on the utility of the data submitted the DATA Act rather than a compliance - focused in accordance with exercise . Each agency will need to develop a DQP that is tailored to their unique operating environments challenges and risk s to achieving missions . Our goal is to support agencies in making their own determinations about how best to meet the reporting requirements DATA Act improve the quality of and USA s pending.gov . spending data submitted to Nothing in this laybook supersedes or replaces existing regulations, policies , guidance , or the P The Playbook uirements outline d in the DATA Act Information Model Schema . submission req to federal agencies, as together we strive to accomplish may be updated periodically, if helpful the underlying objectives of the DATA Act. ii

3 Data Quality Playbook Table of Contents ... ... ... ... ... 1 Introduction Applicability ... ... ... ... 1 A. Accountability for Quality Reporting ... ... ... 1 B. C. ... ... ... ... 2 Data Quality Actions Data Quality Plan Illustrative Scenarios ... ... ... 6 ... ... Illustrative Scenario 1: Agency XYZ 7 ... Illustrative Scenario 2: Agency MBT ... ... ... 19 23 Illustrative Scenario 3: Agency ABC ... ... ... ... ... ... 28 Illustrative Scenario 4: Department of JFK ... ... ... 31 Illustrative Scenario 5: Department of WNB Illustrative Scenario 6: Department of NCR ... ... ... 45 Exceptions Representing Valid Business Processes and Statutory Allowances ... 49 - Specific Considerations Award 59 ... ... ... ... ... ... ... 61 Certification Illustrative Examples ... Glossary of Acronyms ... ... ... 68 70 Acknowle dgments and Considerations ... ... ... iii

4 Data Quality Playbook Introduction Applicability A. or “Playbook The Data Quality Playbook ” i s intended to assist Senior Accountable Officials , , s ) (SAO with developing D ata Q uality P lans (DQP s ) to achieve reasonable assurance over internal controls and processes that support overall data quality for the input and validation of agency data submitted to USAspending.gov. The cover memo o f Appendix A of Office of Management and Budget (OMB) Circular A - 1 23, Management of Reporting and Data Integrity Risk (Appendix A) , is the authoritative source on th e (DATA Digital Accountability and Transparency Act of 2014 , and requires DATA Act reporting agencies to implement a DQP . Consideration of this Act) DQP s' existing annual assurance statement over internal controls over plan must be included in agencie reporting ( ) beginning in fiscal year ( FY ) 2019 and continuing through the statement ICOR covering FY 2021 at a minimum, or until agencies determine that they can provide reasonable assuranc es over the data quality controls that support achievement of the reporting objectives in accordance with the DATA Act. This P laybook is intended to clarify concepts that can be overly complex and operationalize how to address such complexity while balanc ing burden and costs . The P laybook uses information gathered in previous DATA Act assessments . It should be understood that this P laybook document issuance and 123 - has no authoritative standing. It is not associated with the OMB Circular A was should not be considered guidance pertaining to Circular A - 123. This Playbook authoritative written by federal agencies to assist preparers by providing s cenarios and illustrative examples to achieve the reporting objectives of the DATA Ac t . Therefore, the Playbook can and should be modified to fit the circumstances, conditions, strategic priorities, and structure of each particular agency . B. Accountability for Quality Reporting Federal agencies recognize the importance of confirming that data related to the spending and stewardship of taxpayer money is collected in an efficient and standardized manner by the agencies receiving the appropriations assessed , for overall quality , and published for maximum transparency and public ease of use. Spending data that is consolidated in an interoperable and consistent format not only provides visibility to taxpayers, but also enables ederal leaders to make f informed decisions for mission accomplishment and positive performance outcomes. Since the the Federal Funding Accountability and Transparency Act ( FFATA ) in 2006, implementation of there have been meaning and significant improvements towards transparency in f ederal ful spending data. The passage of the DATA Act in 2014 and the focus on open data transparency has steered governance bodies, agencies, and other stakeholders toward the common goal of producing In accordance with existing DATA Act guidance issued by OMB quality, published spending data. and the Department of the Treasury (Treasury) , a gencies are required to report spending data for publication on USA s pending.gov on a recurring schedule based on the submission process outlined DATA Act Information Model Schema (DAIMS) . The financial attributes must be generated in the 1

5 Data Quality Playbook ’ by the agencies financial systems of record, the award attributes required by FFATA from the identification ( ID ) carried in the age of these using the award authoritative sources, and the link financial system . C. Data Quality Actions Appendix A - 123 states agencies’ responsibility for the management of to OMB Circular A reporting and data integrity risk The DATA Act is not the first or only transparency and reporting . , as shown in the table below federal agencies requirement for data ’ . Memorandum 18 - 16 spending also states : “Quarterly certifications of data submitted by agency SAO should be based on the consideration of the data xisting controls that may be in quality plan and the internal controls documented in their plan as well as other e place, in the annual assurance statement process.” randum M - Per OMB Memo - 04, the quarterly SAO assurances over the DATA Act submission 17 are to (1) assure that the alignment among F iles A - F is valid and reliable, and (2) the DATA Act files submitted for d isplay on USASpending.gov are valid and reliable . M - 17 - 04 , Additional Guidance for DATA Act Implementation: Further Requirements for Reporting and Assuring Data further provides that existing data quality measures required by regulation and/or OMB Reliability guidance will be sufficient for SAO reliance on individual data files . The table below identifies many preexisting validations , to support quarterly DATA Act certification s on internal controls over their DATA Act submissions . Assurances for Each DATA Act File Submitted DATA Act File Existing Assurances or Internal Controls DATA Act Senior Accountable Official over Authoritative Source Data Authoritative Assurance Required DATA Act) (Pre - Source The reporting objective is that the data reported Pursuant to A - 136, the reporting agency File A: rd must reconcile 3 Quarter and year end SF - in File A match the authoritative source (i.e., - Appropriations 133 data to their Statement of Budgetary SF 133) and that all - Treasury Account Symbols Account are reported. Resources (SBR). TAS ( ) The Report on Budget Execution Year To increase the likelihood that this objective will - end data are audited financial data, and Budgetary be met the agency S AO will provide assurance subject to management which are Resources (SF - 133) that data integrity processes and controls are in assurances of internal controls over derived from place and align with A 123. These assurances - 123. - reporting under A - wide Government must be made on a quarterly basis and should Treasury Account OMB Circular No. A Pursuant to the leverage the existing processes and other - 11 (A - Symbol Adjusted assurances listed in the column “ 11) Section 130.2, for Executive branch Existing Trial Balance System Assura nces or Internal Controls over agencies, agencies must report all Treasury (GTAS) data Appropriation Fund Symbols (TAFSs) in Authoritative Source Data. ” reporting window. each GTAS 2

6 Data Quality Playbook DATA Act File Assurances or Internal Controls Existing DATA Act Senior Accountable Official over Authoritative Source Data Authoritative Assurance Required - DATA Act) (Pre Source 136, the reporting agency Pursuant to A - The reporting objective is that the total amount File B: Object Class rd Quarter and year - end SF - must reconcile 3 reported in File B matches the authoritative and Program 133) and that Program Activity - source (i.e., SF 133 to their SBR. Activity and Codes are reported based on the OC 1 11 Year end data are audited financial data, President’s Budget as executed - and A - respectively. which are subject to management 133 derived - The SF assurances of internal controls over from GTAS data To increase the li kelihood that this objective will 123. - reporting under A be met the agency SAO will provide assurance The Prog that data integrity processes and controls are in ram Activity names and codes are - place and align with A embedded in the President’s Budget . On a 123. These assurances must be made on a quarterly basis and should quarterly basis, agencies work with OMB to ther leverage the existing processes and o send updates to Program Activity through Existing assurances listed in the column “ the Budget Data Request (BDR) process in alignment with the President’s Budget. Assurances or Internal Controls over OMB then passes th ” Authoritative Source Data. e Program Activity validation list to Treasury as the validation list for the Broker. DATA Act Broker will validate against The 11 - odes in A C . (OC) the list of Object Class Year - end data are audited financial data. All The reporting objective is that data reported in File C: Award financial data, including the obligations File C match the authoritative source (i.e., Financial agency financial systems). reported in this file, are subject to - 123. management assurances under A Financial Systems ll To increase the likelihood that this objective wi 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. Pursuant to the Federal Acquisition The reporting objective is that for data reported File D1: 282) as amended FFATA pursuant to - Regulation (FAR) and OMB memoranda (P.L. 109 Procurement Award 2 - , agencies are required by the DATA Act (P.L. 113 beginning in 2009 to 101, they are Attributes Data NG - sourced from and match FPDS at the time submit an annual FPDS NG - Federal Procurement Verification and Validation of quarterly reporting. Report (V&V) Next – Data System to OMB and General Services the - Generation (FPDS Administration (GSA) . The report includes rease the likelihood that this objective will To inc NG) be met, the agency SAO will rely on internal assurances over the timeliness and controls (A V&V 123) based on FAR required - completeness of the data and sampling of for the assurance over Federal procurement elements, the core DATA Act required data awards. - comparing contract files to FPDS NG . 1 A - 11 Section 82.5 (a) contains information about how program activities should be created, and provides that agencies obtain OM B approval for any changes in activity structure. If for any reason, such as funding changes made during the appropriations proc ess, an agency needs to change their program activities in the current fiscal year; such changes should be coordinated through their OMB Resource Management Offic e. In the future, corresponding validations for program activity in the DATA Act Broker may be implemented. 2 policy/ - Relevant OMB memoranda can be found at: https://www.whitehouse.gov/omb/management/office - federal - procurement 3

7 Data Quality Playbook DATA Act File Assurances or Internal Controls Existing DATA Act Senior Accountable Official over Authoritative Source Data Authoritative Assurance Required - DATA Act) (Pre Source The reporting objective is that data reported in No current certification or assurance D2: Financial File is performed by agencies. OMB is File D2 match the authoritative source (i.e., process Assistance Award agency award - managem ent systems) for award - reviewing opportunities to enhance Attributes level data and the authoritative source (i.e., assurances over this data. SAM) at the time of the award for prime awardee information. Agencies may also leverage the data Agency Management validations included in the Financial Systems/Files (for To increase the likelihood that this objective will Assistance Broker Submission (FABS) as a award description, control that their data follows the standard be met the agency SAO will provide assurance award title, etc.) format. es and controls are in that data integrity process Financial Assistance place and align with A - 123. These assurances Awardee data in must be made on a quarterly basis and should For entities required to register in SAM or System for Award leverage the existing processes and other otherwise registered, a validation of key ) SAM Management ( data is performed to assure for the purposes assurances listed in the column “ Existing at the time of award Assurances or Internal Controls over of SAM data quality that the entity (for prime financial ata. registration data are accurate. Agencies may ” Authoritative Source D assistance awardee leverage this existing validation as a control information) . over the data submitted to SAM 3 Contracts and financial assistance awards Agencies will be able to leverage assurances File E: Highly contain terms and conditions requiring based on the internal controls of the system Compensated In . 123 - . owner, the GSA in accordance with A reporting of executive compensation Officer Data 4 wards, related a - addition, for procurement SAM guidance of May agencies will leverage the existing OMB For procurement OMB guidance on subaward data quality. 2011 , requires agency Senior Procurement (SPE) Executives to certify that agency policies, procedures, and internal controls assess include reviews of contractor data to compliance and completeness . Contractual remedies exist to address any gaps. 14 Contracts and financial assistance awards Agencies will be able to leverage assurances File F: Subaward contain terms and conditions requiring based on the internal controls of the system Attributes reporting of executive compensation . 123. - wner, GSA, in accordance with A o OMB is FFATA Subaward reviewing mechanisms to further enhance Reporting System guidance of May assurances over these data for financial For procurement, OMB ( ) FSRS assistance awards. to certify that SPEs requires agency 2011 In addition, for procurement - agency po leverage the related awards, agencies may licies, procedures, and internal controls include reviews of contractor data existing OMB guidance on subaward data . to assess compliance and completeness quality. Contractual remedies exist to address any gaps. 3 CFR 170 only required agencies to include this term and condition on grants and Playbook cooperative agreements. At the time this was issued, 2 In the future, this requirement may be expanded to include loans and other forms of financial assistance. 4 d to be applied to Not all award recipients are required to register in SAM. Controls and assurances associated with SAM data are not expecte recipients who are exempt from SAM registration or who are not required to register. 4

8 Data Quality Playbook Regarding File E and File F, 48 Code of Federal Regulations ( CFR ) states “an agency is not required to address data for which the agency would not normally have supporting information . ” - 17 04 statement that agencies must comply with Appendix A of Circular A - 123 enhances the M - , by adding: current regulatory requirements “ Consistent with terms and conditions of Federal awards, entities receiving federal awards are required by 2 C.F.R. Part 25 and the Fe deral Acquisition Regulation (FAR) to submit accurate data to the System for maintained by the General Award Management (SAM) and the FFATA Subaward Reporting System (FSRS) Services Administration (GSA). The quality of this data is the legal responsibility of the recipient. GSA provides an assurance statement that the systems are maintained appropriately and can therefore be used for public reporting. Agencies are responsible for assuring controls are in place to verify current registration in SAM at the ti me of the financial assistance award. Pursuant to 2 C.F.R. Part 200.513, agencies are responsible for resolving audit findings which may indicate if recipients are not complying with their requirements to register or report Subawards. Agencies are not resp onsible for certifying the quality of data reported by awardees to GSA and made available on USA s pending.gov. ” 5

9 Data Quality Playbook Scenarios Illustrative Data Quality Plan Scenarios The following pages contain representative agency approaches to inform the development of by DATA Act reporting agencies using the Playbook . These DQPs are intended to assist federal agencies in meeting the requirements of Appendix A of OMB Circular A - 123 , as well as the agency SAO certification requirements under OMB M - 17 - 04 . Each approach was developed by contributors representing agencies of various sizes, missions, and operating environments. The is data scenarios are designed to increase the value of th in making management decisions and support transparency objectives . Readers of this Playbook may consider these scenarios as potential approache s for developing DQPs . DQPs will be unique to each agency, so the duplication in some scenarios shown here and . There may be components of each that is representative of this variety unique solutions in others are more useful depending on the reporting agency he strategic priorities and mission of each . T is unique and should not be taken agency as static options these scenarios or requirements . Readers may also note that some methodologies and themes repeat in more than one scenario, while some definitions and approaches vary across the scenarios. These variations the illustrate flexibility provided to agenci es to develop plans best suited to meet their needs , while meeting the common SAO assurance requirements and direction on sufficient validations included in 04 OMB M - 17 - . A brief description of the agency operating environment is offered as an introduction for each of the scenarios displayed. OMB’s requirement for implementing the DQP is FY2019. Each agencies’ DQP effective for will be representative of their existing DATA Act process maturity. Plans will differ vastly depending on the strength of controls in place over the reporting processes for the agency. Due to of this maturity mode l, agencies should prioritize and reassess their plans as the flexibility appropriate. In cases where agencies have significant data quality internal control weaknesses , the interim focus should be on adequately executing corrective actions in areas where controls ffective and then identifying significant reporting areas where assurance can be provided. are ine Agencies have the flexib ility or to modify their DQP as changes in strategic priorities, new risks , and deemed appropriate by the agenc y. business needs are identified 6

10 Data Quality Playbook Scenario 1 Scenario 1 Illustrative : Agency XYZ The following DQP outline was developed for a small, centralized agency with a robust control modern and data quality and governance structure. The integrated financial systems are ace to facilitate reconciliations of information reported in standards had previously been in pl - wide systems. Readers may be able to leverage some of the processes or government described methodologies in this scenario depending on their DATA Act operating environment. I. Introduction ederal agencies to report financial and award data in accordance f The DA TA Act requires with the established Government wide financial data standards. In May 2015, the OMB - and Treasury published 57 data definition standards , most from existing data standards, and required f ederal agencies to report financial data in accordance with these standards s for DATA Act reporting to be displayed on USA pending .gov for taxpayers and policy makers. The DATA Act requires the ral agency to Inspector General ( O IG) of each f ede Office of ederal agency f review a statistically valid sample of the spending data submitted by its and to submit to Congress a publicly available report assessing the completeness, timeliness, quality, and accuracy of the data sampled and the implement ation and use of wide data standards by the ederal agency when reporting the data . - f the Government XYZ’s objective is to develop a process that assures data is submitted timely, contains all of the required 57 data elements, and ensures data accuracy for information published on .gov. The objective will be met through training on the definition and USAspending business processes and standardization of data elements and underlying categories, d periodic reviews that provide feedback that can be leveraged systemic controls, an for improving data quality. XYZ will follow the general concepts presented in OMB Circular A 123 , Appendix A and an approach in accordance with the five components in the U.S. - Government Accoun tability Office’s (GAO), Green book . II. Control Environment XYZ will use a control environment as a foundation to provide discipline and structure to DATA Act submission process. This will include the oversight body made up of the leadership positions that have the ability to influence objectives and activities being performed to ensure the quality of submissions . DATA Act III. Agency - wide Roles and Responsibilities Chief Financial Office r – A. DATA Act SAO submissions.  Senior official responsible for certifying XYZ DATA Act 7

11 Data Scenario 1 Quality Playbook Required by M - 17 to provide, on a quarterly basis, reasonable assurance that 04 -  the agency's internal controls support the reliability and validity of the agency accoun t - level and award - level data reported to USAspending.gov. Per OMB M - 17 04, the SAO is to leverage existing data quality and management controls - established in statute, regulation, and Federal - wide policy . D ata certifications that are based in regulation an d policy are sufficient for quarterly certifications and is not the Quarterly SAO assurance that includes three certification levels: o F is valid and reliable , including the The alignment among Files A - E and A, B, C, D 1 , D2, iles , F interconnectivity/linkages across all the data in F. o The data in each DATA Act file submitted for display on USAspending.gov are valid and reliable and existing data quality measures required by regulation and/or OMB guidance will be sufficient for SAO reliance on individual data files . o Data reported to USAspending.gov matches , or is directly provided by , its authoritative sources outlined in M - 17 - 04 (reference to Management . Procedures Memorandum ( MPM ) 2016 - 03) B. m Offices Financial Assistance (grants, loans, surety bonds) Awarding Progra  Responsible for data entry into source systems that feed the DATA Act submission.  Design and implement control activities over the input of financial and award spending data into relevant source systems to ensure completeness, timeliness , and ac curacy.  Heads of Financial Assistance Awarding Program Offices certify the accuracy of financial assistance award data entered into source systems by the office monthly to the SAO. Grants : o  Executive Director of the Office of Executive Management, Installat ion & Support Services .  Associate Administrator for the Office of Entrepreneurial Development . o Loans and Surety Bonds :  . Associate Administrator for the Office of Disaster Assistance  . Associate Administrator for the Office of Capital Access Administrator for the Office of Investments and Innovation .  Associate Senior Procurement Executive and Chief Acquisition Officer C.  The SPE , in coordination with the head of the contracting activity, is responsible for developing and monitoring a process to ensure ti mely and accurate reporting of contractual actions to FPDS - NG.  Within 120 days after the end of each FY , the SPE reports an annual certification of whether, and to what degree, agency contract data for the preceding FY is 5 complete and accurate to the GSA . 5 and OMB Memoranda of 2009, 2010, 2011 Federal Acquisition Regulation Section 4.604 Responsibilities 8

12 Data Scenario 1 Quality Playbook Certifies the accuracy of procurement award data entered into the contract writing  NG monthly to the SAO - is in alignment with the system and FPDS provided this agency’s risk management strategy and until such time that this agency is . the DQP of quality comfortable with the data per D. Acquisition Division Responsible for data entry into source systems that are used by the DATA Act  submission.  Contracting Officers that award a contract action are responsible for the 6 - NG . completion and accuracy of the individual contract action report to FPDS  Designs and implements control activities over the input of contract award , spending data into relevant source systems to ensure completeness, timeliness and accuracy. Chief Data Officer E. Will maintain and oversee implementation of the agency  wide DQP . - Responsible for oversight of data quality of the DATA Act submission.   Supports any training necessary to promote compliance with the DATA Act . , the review and resolution, if necessary  of Treasury validation warning Oversees and error messages. F. Office of the Chief Financial Officer submission.  Compiles and submits DATA Act  - wide data validations. Completes agency - related discrepancies in awards data.  Monitors and resolves any system Supports  . automation of system edit checks that support data quality IV. Risk Assessment Members of XYZ’s control environment will continue to assess and monitor risks both to XYZ’s DATA Act submission process. XYZ will follow a risk - internal and external based appro ach in reviewing the processes used to compile the data and assess the existence of risks :  Identify the r isk .  p Determine the robability of o ccurrence .  i mpact ( s everity) . Analyze the itigation r isk m  s trategies . Develop  Communicate the r isk i nformation to a ll the r elated Offices . Risk will be assessed using the following classifications: 6 1) Federal Acquisition Regulation Section 4.604(b)( 9

13 Data Quality Playbook Scenario 1 Low Control Risk The control procedures and policies will prevent or detect  : errors . aggregate Moderate Control Risk : The control procedures and policies will , more likely than  not , prevent or detect aggregate errors . :  The control procedures and policies are unlikely to be effective High Control Risk errors in preventing or detecting aggregate . The XYZ will evaluate whether existing controls over the information areas with high impact risks are adequate. The primary risks for DATA Act reporting relate to completeness, timeliness, accuracy , and quality of the data. The 2017 DATA Act Audit leveraged the following definiti ons when evaluating these risks: Completen ess  is measured in two ways: (1) all transactions that should have been recorded are recorded in the proper reporting period and (2) as the percentage of transactions containing all applicable data elements required by the DATA Act .  Timeliness is measured as the percentage of transactions reported within 30 days of award .  Accuracy is measured as the percentage of transactions that are complete and agree with the systems of record or other authoritative sources.  Quality is defined as a combination of util ity, objectivity, and integrity. Utility refers to the usefulness of the information to the intended users. Objectivity refers to whether the disseminated information is being presented in an accurate, clear, to the protection of information from complete, and unbiased manner. Integrity refers unauthorized access or revision. In May 2018, XYZ performed an element based risk assessment and identified 12 data - elements as high risk. These elements will be the focus of data quality processes moving forward alignment with any other statutory or regulatory requirements . Elements were in assigned a final risk rating through a three - step process: 1. Initial Risk Assessment: Elements were assigned an initial risk score based on the element’s listing in the (FFATA – the underlying statute as amended by the FFATA DATA Act ), 2017 DATA Act Audit findings related to the element, and the element’s importance relative to XYZ’s mission and/or the usability of the data by the public . ependency Assessment: 2. Data D Elements w here the selected value affects other elements were assigned a higher recommended risk rating. Elements - populated auto based on other elements were assigned a lower recommended risk rating. Final Risk Rating Review: 3. for DATA Act The Chief Data Officer met with the SAO (the CFO) , Deputy CFO , and the SPE on May 25 , 2018 to review the recommended risk ratings for the elements. Additional consideration was given to DATA Act whether the element provides funding amount information, the likelihood of the element being incorrect (e.g., since nearly all awards are in the U . S . , country - related elements are likely to be correct), and whether the data is entered/supplied by XYZ DATA Act Broker). During this review, 12 data (e.g., is the element calculated by the 10

14 Data Scenario 1 Quality Playbook DQP . Table 1 elements were identified as high risk and selected to be included in the . presents the selected elements . High Risk Data Elements Table 1 Award Types Data Element Loans SBG Contracts Grants X X X X Action Type X X X Award ID Number X X X X X Award Type 7 Catalog of Federal Domestic Assistance (CFDA) Number X X X X X Period of Performance Current End Date X X Period of Performance Start Date Primary Place of Performance Address X X X X - X Non Federal Funding Amount X Awardee/Recipient Legal Entity Name X X X Awardee/Recipient Unique Identifier X X X Address X X X Legal Entity X X X X Action Date As more guidance on government - wide materiality thresholds, acceptable risk tolerances, DATA definitions of completeness, accuracy and timeliness, key data elements and other Act submission risk considerations become available, this plan will be updated to remain in compliance with current guidance. Control Activities V. Through policy, procedures and training, XYZ leadership along with individual program offices will design contro l activities at various levels to meet o bjectives and respond to The Control activities are designed around meeting the following criteria: risks.  Top - level reviews of actual performance . .  Reviews by management at the functional and activity level Specific controls over information processing  .  Establishment and regular review of performance measures and indicators .  Segregation of Duties .  . Proper Execution of transactions to include accuracy and timeliness  Appropriate documentation of transactions . A. Data Input to Source Systems The Acquisition Division and Financial Assistance Awarding offices will follow the policies and procedures established in statute and regulation with respect to the 7 It is understood that ‘ CFDA will change to ‘Assistance Listing’ but we are keeping the CFDA text until the DATA ACT officially changes the title. 11

15 Data Scenario 1 Quality Playbook tion outlined in their business process for making awards and any additional informa individual Data Quality Assurance plans. Each Data Quality Assurance plan will be , take into consideration existing data unique to the offices’ processes and procedures issues quality requirements in regulation, 2017 DATA Act and found during the t . And , audi steps to mitigate completeness, timeliness, accuracy , if appropriate, take and quality risks through training, continu ous monitoring, and monthly certification SAO until such time as the data improves in of their respective award data to the accordance with the published DQP . Submission Process B. Quarterly DATA Act (OCFO) compiles and submits the required The Office of the Chief Financial Officer data to the DATA Act and Financial Assistance Brokers. Figure 1 depicts the data flows from XYZ source systems, through the B roker ’ s to the public interface: Submission Data Flow Figure 1 . DATA Act OCFO relies on both the DATA Act Broker and internal validation processes to financial ensure that the data reconciles to the agency general ledger, is submitted timely and completely and that valid linkages exist between the files. The following a gency - wide validations provide these con trols. File A and File B C. 12

16 Data Scenario 1 Quality Playbook FY f ederal appropriations account summary data . File B File A includes cumulative and program summary ederal OC f - level data. Validation of FY cumulative includes are the responsibility of the OCFO throu Files y Assurance A and B gh the Qualit The following tests are conducted. team. 8 DATA Act : Broker when data is submitted  Reconcile File A to SF133 excluding Loan Financing Accounts by agency identifier, main account code, sub account code, budget authority appropriated amount, budgetary authority amount, gross outlay TAS and unobligated balance. Reconcile File B to File A b y Main account codes a nd sub account codes  quarterly . Verify all OC codes from File B match Section 83 OMB Circular A - 11 .  Office of Planning and Budget :  Verify program activity names and codes quarterly from File B match names and codes in the Program and Financing Schedule in the President’s Budget. Updates will be made via the MAX collect exercise quarterly, as needed. Financial Reporting Branch:  governmental transfer is an allocation transfer or buy/sell - ntra Verifies I transaction. Verifies that File A and File B were reported within 30 days of quarter end.  Quality Assurance Team  - 133 to the S BR s on a quarterly basis. Reconciles OMB SF D. C File B and File File C reflects and links to reportable award - ID level transactions via an award number. File C is a subset of F ile B, so all items in File C (Awards) should be in File B , but not all of File B (all obligations) shoul d be in File C. For example, salarie s are obligations reported in File B but salaries are not awards reported in File C. Therefore, salaries would be a reconciling item between File B and File C. gh the Quality Comparison of File C to File B is the responsibility of the OCFO throu eam. The following tests are conducted. Assurance t Broker when data is submitted : DATA Act  Validates that File C includes applicable TAS by matching main account codes, sub account codes, codes found in File B. OC Quality Assurance Team : 8 DATA Act validation rules are available here https://broker.usaspending.gov/#/validations?_k=gy8w41 13

17 Data Quality Playbook Scenario 1  Compares B to C F ile s quarterly . ystems (OFS) the Director O ffice of F inancial S  , Shares results from validation to Director of Administrative Accounting, Director of Acquisitions, and Chief Data Officer to drive improvements in data quality. E. File C and File D1 File D1 is extracted by the Broker from FPDS - NG and reports the award DATA Act awardee details for contract awards reported in File C. and DATA Act Broker when data is submitted :  Validates all reportable contract awards and amounts in File C match the contracts and amounts in File D1.  Validates all reportable contract awards in File D1 with non - zero dollar obligations matching to the contracts and amounts in File C. : Financial Reporting Branch  Generates DataActJAAMSPRISMRecon file daily. Report mimi cs some DATA by identifying any differences in transaction amounts or Act Broker validations dates between XYZ’s financial system and contract writing system. File C is generated from XYZ’s financial system data and File D1 is generated from FPDS - NG, which is partially populated by data from XYZ’s contract writing system.  Distributes report to the Office of Financial Systems, Administrative Accounting Branch, Financial Reporting Branch, and Acquisition Division. Office of Financial Systems, Administrative Accounting Branch, and Acquisition Division :  Reviews DataActJAAMSPRISMRecon report daily. Researches reconciliation items and resolves items  that are deemed not allowable .  unallowable and unresolvable reconciliation items in preparation Documents any or quarterly submission. f F. File C and File D2 File D2 reports the award and awardee details for financial assistance awards reported in File C . DATA Act Broker when data is submitted :  Validates all reportable awards and amounts in File C match the nonzero grants, and surety bond and amounts in File D2. loans , 14

18 Data Quality Playbook Scenario 1 reportable awards in File D2 with non - zero dollar obligations match  Validates all the awards and amounts in File C. : Financial Reporting Branch  Generates DataActJAAMSPRISMRecon file daily. report to the Office of Financial the DataActJAAMSPRISMRecon  Distributes Systems, Administrative Accounting Branch, Financial Reporting Branch, and Acquisition Division. Office of Financial Systems and Administrative Accounting Branch :  DataActJ AAMSPRISMRecon report daily. Report mimics some DATA Reviews Act by identifying any differences in transaction amounts or Broker validations dates between XYZ’s financial system and other source systems. File C is generated from XYZ’s financial system data and Fil e D2 is generated from XYZ’s financial and financial assistance award systems.  Researches reconcil iation items and resolves actionable variances.  Documents any unallowable and unresolvable reconciliation items in preparation for quarterly submission. G. File D2 and Agency Data File D2 reports the awardee details for financial assistance awards reported in File C . Office of Financial Systems :  Generates a monthly Excel file that provides a reconciliation of Loan data, Grants . Data and SBG data from the s ource systems to D2 Provides the file to a designated list of recipients including Chief Data Officer,  Manager of Financial Reporting, and Manager of Quality Assurance to monitor. . Any variances noted are addressed with OFS SAO relies on these agency - The wide validations as controls to ensure the data is complete, timely and that valid linkages exist between the files when certifying the submission. VI. Certification 17 M - - 04 3 requires the DATA Act SAO to provide, on a quarterly basis , reasonable assurance that their agency's internal controls support the reliability and validity of the - level and award - level data reported for display on USAspending.gov. M - agency account 17 - 04 specifies that this assurance should leverage data quality a nd management controls established in statute, regulation, and f ederal - wide policy , and be aligned with the 04 further states 17 - internal control and risk management strategies in Circular A - 123 . M - 15

19 Data Scenario 1 Quality Playbook and/or OMB guidance will be that existing data quality measures required by regulation sufficient for SAO reliance on individual data files . Agency’ s quarterly SAO assurance includes three certification levels: The alignment among the Files A - F is valid and reliable . Since a DATA Act  submission contains a combination of many data sets, the SAO attests to the validity DATA Act submission and the and reliability of the complete appropriate ( across all the data in F iles A, B, C, D, interconnectivity/linkages linkage) , and F . For F iles E and F, M - 17 - 04 clarifies that agencies will leverage assurances E provided over the systems by the owner . DATA Act F ile reported in the quarterly submission to  The data in each are valid and reliable. To provide this assurance , the SAO USAspending.gov conf irms that internal controls over data quality mechanisms are in place for the data DATA Act files submitted quarterly. Existing data quality measures submitted in the required by regulation and/or OMB guidance will be sufficient for SAO reliance on individual data files. Data reported to USAspending.gov matches  or is directly provided by , its , . ) authoritative sources outlined in M - 17 - 04 (reference to MPM 2016 - 03 XYZ’s SAO relies on agency wide validations of the submission files , DATA Act ertification statements from the heads of the Acquisition Division monthly c (if applicable) and each of the Financial Assistance Awarding Offices – Office of Capital Access, Office of Disaster Assistance, Office of Entrepreneurial Development, Office of Executive M anagement, Installations & Support Services - which provide reasonable assur the completeness, accuracy , and timeliness of the data when certifying ance over XYZ’s quarterly submission. Further, the SAO provides the following content by file during the cert ification process in the DATA Act Broker: ,  File A: Pursuant to OMB Circular No. A - 11 Section 130.2, for Executive branch agencies, XYZ reported all TAFS in each GTAS reporting window. The data in File - ll required XYZ TAS are A match the authoritative source (i.e., SF 133) and a reported. Credit program financing account activity is not required to be reported under the DATA Act . Face Values for loans often come from the financing for files A and B accounts. Face values are reportable on file D2. Funding for these subsidy costs is reflected in the program account, per the Federal Credit Reform Act, as outlined in Section 185 of OMB Circular A 11. -  File B: The total amount reported in File B matches th e authoritative source (SF - 133), Program Activi ty, and Budget Object Class Codes are reported based on the President’s Budget as executed and A - 11, respectively. The Program Activity names and codes are embedded in the President’s Budget. On a Program Activity quarterly basis, agencies work with OMB to send updates to 16

20 Data Scenario 1 Quality Playbook through the BDR process in alignment with the President’s Budget. OMB then passes the Program Activity validation list to Treasury as the validation list for the Broker. All financial data, including the obligations in this file, are subject to File C:  123. The data reported in File C match the management assurances under A - authoritative source (i.e., agency financial systems). , File D1: Data reported pursuant to FFATA (P.L. 109 - 282) as amended by the DATA  (P.L. 113 - 101) , are sourced from FPDS - NG and the key data elements are Act aligned at the time of quarterly reporting. The data reported in File D1 are subject to V&V f ederal internal controls based on FAR required for the assurance over procurement awards. DATA Act pull data from multiple sources. Each of these Agency submissio ns for the sources has a different frequency for updating the relevant data to USAspending.gov. These timing differences can result in data being displayed at different intervals throughout the quarte r, at times resulting in potential delays in awards matching - appropriations account level data. : The data in File D2 match the authoritative source (i.e., agency award  File D2 - management systems) for award e., SAM) at level data and the authoritative source (i. the time of award. However, XYZ was unable to submit some records due to data and/or validation errors. The data included in File E are subject to the internal controls of the system  File E: owner, the GSA in accordance with A - ing on the assurance of GSA 123. XYZ is rely - that data integrity processes are in place and align with A 123. File F:  The data included in File F are subject to the internal controls of the system owner, the GSA in accordance with A - 123. XYZ is relying on the assurance o f GSA that data integrity processes are in place and align with A - 123. Information and Communication VII. Members of XYZ’s control environment will effectively communicate and distribute quality information from both internal and external sources that is rel evant t o meet the agency’s objectives. A variety of factors will be considered when distributing information including: — m  Audience . aking sure it gets to the intended recipients —  Nature of information p urpose and type of information . sure information is readily available when communicating  Availability — m aking . .  Cost — r esources used for the effective communication  Lega l or regulatory requirements — a ny laws and regulations that may impact the . communication 17

21 Data Quality Playbook Scenario 1 The Chief Data Officer recognizes that currently the Acquisitions Division, Office of Executive Management, Installation & Support Services Office of Grants Management, – Office of Entrepreneurial Development, Office of Disaster Assistance and Office of pital Access are the primary offices that would be receiving the majority of DATA A ct Ca relevant to th communications but will also notify other offices if any issues eir work ; needs to be addressed. This may also include establishing meetings and potential t rainings depending on the level of the communications being transmitted. Acquisition Division and Financial Assistance Awarding Office officials will also be responsible for updating the SAO and Chief Data Officer of issues with data accuracy, testing res DATA ults, training activities and any other material changes that affect the . Act VIII. Monitoring Members of XYZ’s control environment along with the Chief Data Officer will continuously monitor internal and external process and make necessary changes to ma ke sure the agency continues to meet DATA Act data quality objectives. This includes monitoring the control activities to make sure processes are being followed and to making required adjustments in the case where they may not be. In addition, members of XYZ’s control environment will follow updates to laws and regulations to make objectives, processes where needed, and properly appropriate adjustments to communicate adjustments to all parties affected. XYZ’s SAO will require cert ification statements from all office heads that award and surety bond guarantees gra nts, contracts, loans, and will leverage any existing regulatory certifications done by these functions . These statements certify to the SAO the accuracy of the data that h as been entered for the month and will be based on the results Findings from the quality of the quality assurance proce sses established in the office. and assurance process reviews will be used to add training , develop desktop guides , th day of These certifications are required no later than the 5 create future review criteria. the month during the month following the submission period. As outlined above in the control activities section, XYZ OCFO has created a method to DATA Act duplicate some Broker validations between Files D1 and D2 and File C . Each transaction identified by the reconciliation report will be researched to identify the issue and determine whi ch functional area is capable of resolving the issue and then communicate the issue and discuss possible remedies. Issues that can be corrected will be addressed timely to ensure the most complete submission. Any issues that cannot be with the cause and reasoning corrected will be doc umented and reported to the SAO behind the issue and lack of ability to correct. 18

22 Data Quality Playbook Scenario 2 Scenario 2 MBT Illustrative : Agency The following DQP outline was developed for a medium, centralized agency with a mature ernance and control structure. While its programs are diverse and its operations gov a gency does maintain an integrated financial management geographically disbursed, the may be able to leverage some of the processes or methodologies described in system. Readers this scenario de pending on their DATA Act operating environment. Overview A. The Department of MBT incorporates Enterprise Risk Management (ERM) principl e s to focus on high - g cost with benefit and leveraging risk, high impact areas, balancin existing controls, processing, and testing. Participation of the appropriate technical experts, field personnel, and agency B. . leadership is critical to defining objectives and clarifying roles and responsibilities C. Identifying and quantifying risks; acc urately mapping these risks to exi s ting controls or identifying deficiencies; and implementing or enhancing new controls is key. Step 1 – Governance Structure develop, implement, and monitor the Ensure a governance structure to effective ly A. Control Plan (DACP). A key consideration is the (1) right participants DATA Act with subject matter expertise in systems, acquisitions, financial assistance, financial manag and policy and (2) representation from both the a gency and field levels. ement, B. Clearly de lineate who has responsibility for the quality of data that is generated by the business process and reported to authoritative sources for publication to USA s pending.gov . OMB Memo randum M - 17 - 04 and t he revised appendix A of the OMB Circular No. A - 123 , Mana gement’s Responsibility for Enterprise Risk covers this point Management and Internal Control . (Circular A - 123) in its footnotes 3 – 6 C. Establish the appropriate governing bodies.  Executive Sponsors with a broad range of subject matter expertise noted above . The Executive Sponsors (1) oversee the development and implementation of the DACP; (2) review risk assessments and testing summaries; and (3) approve and monitor corrective action plans .  DACP Wo rkgroup to develop and ma nage the overall DACP process. The workgroup consists of business process policy experts, internal control experts; DATA Act Reporting (querying of data from agency systems and reporting to the Data Broker) personnel; and su bject m atter experts in IT systems, acquisitions, . , etc financial assistance, financial management 19

23 Data Quality Playbook Scenario 2 Data Quality Te m with responsibility and oversight of financial and non -  a financial data at the detail level. Members include data owners/responsible parties who have first - hand knowledge of the data. DACP Workgroup members also based on their areas of expertise . participate in this group Step 2 DATA Act Objectives – Define the A. a gency’s overall DATA Act objectives. The overarching objective should focus on the co mpleteness, accuracy, and timeliness of data reported to the Data Broker and ultimately available on USAspending.gov. An important consideration is the different groups of data users: ( 1) agency leadership, managers, and other internal - staff; (2) government OMB, Congress, o ther a gencies , etc.; wide users, to include, the (3) USA s pend ing.gov data consumers with a consideration for taxpayers and other stakeholders . B. Leverage the GAO Green Book, Sta ndards for Internal Control in the Federal as guidance for , particularly Section 2 OV2.16 - Objectives of an Entity Government this area . Step 3 Risk Assessment – A. Based on the DATA Act Objectives outlined above, perform a risk assessment. The outcome of the risk assessment is an assurance tool to identify and quantify risks and map existing cont rols that mitigate those risks. For any identified gaps in the design of controls, management considers the cost/benefit of imp lementing additional controls. The operating effectiveness of controls will be tested later . Determine quantitative and qualitative material ity. Materiality is a key input to r isk B. a ppetite and t olerance . T he Data Quality Team, in conjunction with Executive Sponsorship , shou ld document how much risk the agency is willing to take, weighing the costs versus the benefits of accepting deficiencies within the process and . balancing with the agency’s strategic mission priorities Input from the field (data owners) is critical in thi s area. C. Identify a systematic approach to identify areas with the potential of undesirable and bucket into these like categories . outcomes  The first risk category is the DATA Act governance structure discussed above . Bucketing the data  accuracy of the underlying data. The second category is the int o similar subcategories is key. For example, consider bucketing financial assistance obligations and attributes separately from acquisition attributes if the data is processed on different systems or b y different groups and as the data have different underlying statutes and regulations that must be followed in making and . managing awards 20

24 Data Scenario 2 Quality Playbook The third category is the reporting of the data, starting with the extraction of data  and auth through to final submission to oritative sources from agency databases roker. B the Treasury identified D. . Quantify Analyze and evaluate risks guided by the established risk appetite Qualitatively speaking, risk the impact (likelihood vs. consequence) of each risk. the s if , and when impact the data is incorrect . should be measured by considering , Identify existing controls that mitigate each risk in order to isolate control gaps that E. may exist. A the methodology outlined in Ci rcular No. Leverage - 123 and guida nce provided in F. - 17 - 0 4 M This includes documenting management’s risk appetite and tolerance, . identifying risks, assessing inherent and residual risks, identifying controls, existing . and documenting possible control gaps – Testing Step 4 A. Design and c onduct testing based on the risk assessment to determine whether data roker meets the completeness, accuracy, and timeliness objectives reported to the as B modified by the statutory and regulatory allowances or flexibilities for the business processes unde . r which the awards were made B. Agencies should leverage exi s ting testing techniques, templates, and sampling DATA Act approaches as customized for testing. C. Typically, testers should choose from the 57 requisite elements (if they are not already validated through another process) and sample data from the B roker and trace back to the FPDS - NG for procurement) or other System of authoritative source ( Record and to validate acc uracy. The testing approach should be based on cos t/benefit analysis and ERM principles. – Step 5 Evaluating the Results and Providing Assurance Determine if an internal control deficiency exists whereby the design or operation of A. the control does not allow management to prevent or timely detect incorrect data - up and significant to data users. requiring follow B. Determine the level of severity for each deficiency . C. A ggregate all results to analyze the deficiencies collectively . D. Report any material weakness along with the corrective action plan i n the a gency’s . assurance statement published in the A gency Financial Report 21

25 Data Scenario 2 Quality Playbook Remediation, Monitoring, and Communication  identified, i mplement new or enhance existing controls base d For any deficiency principles and cost/benefit analysis. upon ERM any deficiencies and  Develop and monitor corrective action plans to remediate improve the overall control environment .  Use continuous monitoring to identify new issues and controls that do not continue to operate effectively.  Communicate test results to al l relevant parties, including the Data Quality Team, the agency levels. - DACP workgroup, and leadership at the agency and s ub 22

26 Data Scenario 3 Quality Playbook Scenario 3 Illustrative : Agency ABC DQP outline was developed for a small , c entralized agency with an effective and The following Readers may be able to leverage some of the processes optimized internal control environm ent. operating on their DATA Act in this scenario depending described or methodologies environment. ABC Chief Financial Officer/ DATA Act Senior Accountable Official To: Through: Financial Assistance Systems Director Procurement Director Information Technology and System Security Director Deputy Chief Financial Officer and Financial Management Director From: ABC Data Quality Plan Subject: Background The purpose of this DQP is to document ABC’s FY 2019 approach to achieve reasonable quarterly assurance for internal control over DATA Act reporti ng. The DQP was prepared in 18 123, Management of - accordance with OMB M - Appendix A to OMB Circular No. A - 16, Reporting and Data Integrity Risk and includes a five - step process covering as well as 48 CFR significant milestones and major decisions pertaining to: Organizational structure and key processes providing internal controls for spending  reporting of the 57 requisite elements .  Management’s responsibility to supply quality data to meet the reporting objectives for the DATA Act in accordance with OMB Ci rcular No. A - 123.  Testing plan and identification of high - risk elements that are explicitly referenced by the DATA Act , confirmation that this data is linked through the inclusion of the award identifier in the agency’s financial system and properly report ed. Step One: DATA Act Working Group (October 2018) Update the Charter of the Since June 2015, ABC established a robust governance structure for st rategic DATA Act direction and guidance. This structure seeks to maximize existing management architectures , information technology (IT) , and business processes to meet DATA Act requirements. The governance structure includes the following components:  The SAO provides executive leadership level functional and technical oversight of the project as well as executive guidance on the management of the project. Interface with the DATA Act Steering Committee, OMB, Treasury , and other internal and external olders as necessary. stakeh 23

27 Data Scenario 3 Quality Playbook DATA Act Working Group (DAWG) provides technical and subject matter expertise to  initiative. execute the implementation of the ABC DATA Act ABC OIG attends in ex . officio capacity  Steering Committee provides advice as needed to the SA O and DAWG with regard to the making of the DATA Act initiative’ s scope, schedule, strategic direction and decision - and risks. Approve or disapprove recommendations as necessary. cost s al aspects of Project Manager oversees the DAWG and manage the day - - day operation s  to the implementation initiative; ensure execution of project tasks to meet project objectives. Monitor project resources and risks. Liaise with SAO and Steering Committee to communicate project progress and receive guidance. M - 17 - With the issuance of and Appendix A to OMB A - 123, the DAWG’s charter will be 04 updated to include oversight of the ABC DQP and responsibilities for:  rly communicated throughout ABC. Ensuring that assessment objectives are clea Ensuring that the asses h, effective, and timely manner. sment is carried out in a thoroug  Identifying and ensuring adequa te resources are made available.  Identifying staff to perform the assessment.   Determining and understanding the scope of the a ssessment (See Step Two below).  D etermining the assessment design and methodology. Step Two: Determine and Understand the Scope of Internal Control Over DATA Act Reporting (October 2018) DATA Act Reporting: Reporting objectives pertain to the preparation of reports for Definition of DATA Act External reporting objectives are driven by the use by o rganizations and stakeholders. quarterly and data quality practices and procedures . For by Treasury DATA Act recommended nal Control over Reporting purposes, ABC leverages the GAO Green Book definitions of Inter eporting (GAO - 14 - 704G/OV2.21). In addition, ABC External Financial and Nonfinancial R - M - 17 04, leverages related OMB implementation guidance provided in Appendix A to OMB Circular No. A 123, Management of Reporting and Data Integrity Ris k a nd the FAR . - Objectives of Internal Control Over DATA Act Reporting: Internal control over quarterly DATA reporting is a process designed to provide reasonable assurance regarding the reliability of Act DATA Act reporting means that reporting of the 57 requisite elements . Rel iability of DATA Act management can reasonably make the following assertions: reasonable  All s pending transactions that should be reported for the quarter have been included and no unauthorized transactions are includ ed (completeness) . k  Reportable s pending transactions and e y data elements agree to ABC system s of record (or off icial contract file) (accuracy).  Reportable s pending transactions are reported in a timely manner (timeliness).  Spending data is reported in compliance with the objectives of the DATA Act . (compliance) and regulations governing awards 24

28 Data Quality Playbook Scenario 3 DATA Act Reporting will focus on the ABC’s approach for evaluating internal control over DA IMS Broker Submission process. The DAIMS Broker submission process includes the procedures used to submit files into the Treasury Broker and procedures used to initiate, cord, and process adjustments. In assessing internal control over submission via the authorize, re roker reporting, the DAWG w B ill plan to evaluate:  The automated and manual inputs, procedures performed, and outputs of the processes ABC uses to produce its monthly and quarterly data submissions to Treasury.  The extent of IT involvement in each reporting process element. .  Who parti cipates from management  The types of adjusting entries.  The nature and extent of the oversight of the process by ABC, OMB, Treasury, including the O IG .  The controls over the consolidation process.  The methods for establishing and monitoring the consistent application of DATA Act reporting.  The use of manually compiled data in the DATA Act reporting process.  Quantitative and qualitative materiality considerations .  The regulations and policies governi ng the making and managing of awards reported via . the DATA Act to explain variations Materiality: - 123, Management of Reporting As provided by Appendix A to OMB Circular No. A ; materiality for controls over reporting is defined as and Data Integrity Risk the risk of error or misstatement that could occur in a report that would impact management’s or users’ decisions, or conclusions based on the report. In order to determine the materiality of control deficiencies noted , ABC plans to leverage the materialit y concepts described below . ABC will accumulate errors identified during management’s assessment process , other than those that are clearly trivial, and evaluate misstatements individually and in the aggregate in both quantitative and qualitative terms . Illustrative examples of quantitative materiality calculations include:  Calculating materiality base for spending classes of transactions.  Planning materiality.  Design materiality. Illustrative examples of qualitative considerations include: Is conside  USAspending users, that is, the Congress, the public, influential red sensitive to special interest or stakeholder groups, and interested foreign governments.  Affects compliance with the DATA Act . agree  Affects compliance with financial assistance or other ments.  Heightens the sensitivity of the circumstances surrounding the misstatement (for example, the implications of misstatements involving fraud and possible instances of noncompliance with laws, regulations, or contracts conflicts of interest). proprietary or sensitive information, such as federal taxpayer information.  Involves 25

29 Data Scenario 3 Quality Playbook These circumstances are only illustrative examples — not all are likely to be present in all situations nor is the list necessarily complete. (December 2018) Leverage Enterprise Risk Management Step Three: To meet the 123, ABC will incorporate DATA ERM requirements of Appendix A to OMB A - reporting into ABC’s Risk Profile process Act and leverage Committee of Sponsoring 9 COSO ) ERM concepts o ( Organizations f risk appetite, tolerance, strategy, and objectives as a In addition, the DAWG will develop a portfolio view of DATA precondition of internal control. 10 repor ABC’s risk profile Act will include a composite view of ting within ABC’s risk profile. r DATA Act eporting risk throughout management functions of ABC (e.g., procurement, and security functions). The composite view IT financial management, financial assistance, and will allow ABC to consider the type, severity, and interdependencies of risk and how the y impact performance as well as existing internal controls required by regulation (such as the DATA Act . ABC will leverage the risk profile as a whole when evaluating alternative strategies for FAR) decision making on assessing internal control over DATA A Reporting. ct ABC’s ERM approach will also include a risk assessment and prioritization of the data elements DATA Act reporting including: within Impact on DATA Act reporting.  C  omplexity of the processes.  Volumes of transactions. ization of proce sses.  Central Inherent risk in processes   Existing controls over elements . ABC’s ERM approach will also consider extended enterprise (EE) considerations (e.g., risks between ABC , Treasury , General Service Administration, Universities, or other external stakeholders) These EE considerations may include risks, which cannot be directly controlled, . and ABC will develop contingency plans for its risk management strategy. In addition to leveraging a risk profile process , ABC’s approach to developing assurance will also include a maturity model to guide short and long - term effectiveness of internal control that through FY 2021 or until ABC can determine they can provide reasonable assurances over the data quality controls that support DATA A reporting objectives. ct Step Four Management’s Internal Control Over DATA Act Reporting Evaluation : Appro ach (June 2019) ABC’s evaluation of Internal Control over DATA Act Reporting will comply with the GAO Standards for Internal Control in the Federal Government (GAO - 14 - 704G) and OMB Circular 9 COSO Enterprise Risk Management Integrating with Strategy and Performance , June 2017 10 The format of the risk profile will be in compliance with the format required by OMB Circular No. A - 123, Management’s Responsibility for Internal Control , July 2016 Enterprise Risk Management and 26

30 Data Quality Playbook Scenario 3 - Management’s Responsibility for Enterprise Risk Management and Internal Control , No A 123, The evaluation approach will include the following steps: July 2016. Conduct an assessment of internal control for each of the Green Book’s principles as they 1. relate to DATA Act Reporting Objectives. 2. Prepare a summary of internal control deficiencies. 3. internal control principle evaluation. Conclude on Conclude on internal c ontrol component evaluation. 4. 5. Conclude on Overall Assessment of a system of internal control. Note ‒ ABC will leverage existing methodologies for testing, e.g.:  Entity Level Review Assessments d May e t  The FAR and OMB Memoran da related to p rocurement data quality such as , d a – Guidance for Annual Improving Federal Procurement Data Quality 31, 2011, Verification and Validation . via Assessments of ICOR DAIMS  and other business cycles . Step Five: Provide Assurance and Implement Corrective Actions (November 2019 to January 2020) VI of OMB ABC will leverage the reporting on internal control approach provided by section Circular No. A deficiencies, - 123. The approach will determine control deficiencies, significant r DATA Act compliance and reporting based on and material weakness for internal control ove quantitative and qualitat ive materiality considerations. In addition, the ABC Director’s SAO Assurance Statement will be supported by the DQP and quarterly certification process. Finally, corrective action plans will be developed for control deficiencies identified in accordance with section V of OMB Circular No. A - 123 . 27

31 Data Quality Playbook Scenario 4 Illustrative Department of JFK Scenario 4 : DQP outline was developed for a medium, very diverse agency with an effective The following . Readers and optimized internal control environment may be able to leverage some of the processes or methodologies in this scenario dep ending on their DATA Act operating described environment. I. Background In June 2018, the OM B issued Memorandum M - 18 - 16 Appendix A to OMB Circular No. A - Management Reporting of Data and Data Integrity Risk directing agencies to 123, DQP develop a DATA Act – producing quality, publish ed to achieve the objective of the spending data. In addition, the Depart ment of JFK (the “Department”) OIG completed its 2017 as required by the first audit of the Department’s submission in FY DATA Act DATA Act . A 123 - Th e Department’s DQP is guided by the principles presented in OMB Circular No. and the GAO Standards for Internal Control in the Federal Government , and the results DATA Act audit. of prior year JFK Organizational Chart II. The Department comprises multiple bureaus and an independent authority within s o m e of the bureaus, with the broad responsibility to achieve the agency’s overall mission of service to the American people. The Department utilizes a shared service model for accounting and contracti ng/financial assistance services in which two larger bureaus provide services for smaller bureaus within separate instances of the Depar tment’s core financial system. Two additional instance of bureaus maintain their own accounting and contracting services on another the Department’s core financial system while the other maintains an entirely separate financial system. While accounting and contracting/financial assistance functions at the are four bureaus have the responsibility for the creation of th e data elements that statutory used by the DATA Act submission; the CFO and Assistant Secretary for Administration responsibility (ASA) designee, the Deputy Chief Financial Officer (DCFO), has for the alignment of the data in the quarterly DATA Act files and the assurance for the quarterly submission of the 57 DATA Act elements . Two directorates within the Office of the CFO/ASA: Office of Financial Management (OFM) and Office of Acquisition Management (OAM) are primarily responsible for developing the D epartmen t’s DQP . OFM, which is led by the DCFO, includes the processing functions and OAM includes procurement and internal control and DATA Act financial assistance and ERM. 28

32 Data Scenario 4 Quality Playbook Furthermore, oversight responsibility for the programmatic (non - financial) and financial internal control programs is split between OAM and OFM, respectively, with the overall y for t Federal Managers’ Financial Integrity Act ( FMFI A ) responsibilit assurance he and the responsibility over acquisition management with the Chief belonging to OAM The Department’s approach to this DQP Acquisition Officer per 41 USC . included all functional groups responsible for the key processing and underlying assurances. Data Quality on Finan cial Data Elements (Note: Table of Data Elements in III. Appendix) Enacted in September 1982, the FMFIA requires federal agencies to perform ongoing In response to the FMFIA, OMB evaluations of the adequac y of their financial controls. al controls in Circular A - s responsibility for intern In outlined federal management’ 123. December 2004, OMB revised the Circular A - 123 and introduced Appendix A, which prescribed a strengthened process to assess the effectiveness of the internal control over (ICOF financial reporting . Since the introduction of Appendix A, the Department has R) put forth considerable efforts to mature their processes around . Today, the ICOFR internal control system over financial reporting in the Department includes automation, training, documented proc edures, benchmarking and best practice reviews, continuous monitoring and improvement, management reviews, Departmental policies, risk assessments and annual testing. Furthermore, the Department has obtained 19 clean audit opinions with no significant prio r year findings . key , the DATA Act After reviewing the 57 reportable data elements under the Department has determined that the data quality of nine (9) of those elements are covered under our curre and regulatory processes associated with procurement . nt financial control The Department will leverage the processes behind our strong control environment and clean audit opinions to report complete, timely , and accurate financial data elements . IV. Data Quality on Procurement Related Data Elements conducted Pr ior year findings and Current independent V &V process A. in accordance with 48 CFR and OMB policy B. Leverage ERM to perform a risk assessment over the procurement related data elements; , agency strategic mission priorities, and re turn on investment , C. Based on risk level define the phased approach (based on risks and data element) V. Data Submission and Certification A. Prior to the quarterly file submissions, the TAS reported in the DATA Act files are validated against the GTAS SF 133 files for that quarter; - B. File A to GTAS/ SF 133 Validation based on a list of data elements that are cross walked to SF133; C. Reconcile File A and B based on a summation check; nce validation; File B and C data element and bala D. 29

33 Data Quality Playbook Scenario 4 E. Working with bureaus on program activity, OC and percent allocation validation prior to generation of the quarterly files to Treasury; Upload preliminary File A, B, and C to the Treasury DATA Act F. Broker and download Validation reports for initial analysis; and Quarterly certification from bureau CFOs, head of Procurement certification G. (if appropriate) prior to DCFO final sign off and file submission to Treasury. VI. Monitoring existing 48 CFR and A - 123 Appendix A testing process es and JFK will leverage the 04 regarding existing certifications - 17 - and Senior Assessment Team information in M (SAT) to discuss the key testing steps for DATA Act . The SAT will also work with the Acquisition community and th e DATA Act submission group to determine if any The additional testing is necessary for procurement via the annual FAR required process . group will d evelop testing steps to determine whether data reported to Treasury Broker meets the timeliness, completen ss and accuracy requirements without conflicting with e regulatory requirements or flexibilities . The testing steps should cover sample data fr o m USA s pending .gov and track back to the appropriate documents or authoritative sources . (FPDS NG for procurement) t o validate the accuracy - VII. Reporting and Tracking Like other type of assurances covered under FMFIA, at the end of the testing and reporting phase, JFK and other applicable SAT will work with the JFK components offices to collectively report and determine the level of internal control deficiencies under the DATA Act :  If a Material Weakness is determined, it will be reported through the Secretary’s and published FMFIA assurance statement along wit h ident ified corrective actions in the Agency Financial Report. If the findings are lower than material weakness, it will be included in the overall A - 123 Appendix A findings list and a corrective action plan will be developed and tracked to s each finding. addres 30

34 Data Quality Playbook Scenario 5 Illustrative : Department of WNB Scenario 5 DQP The following outline was developed for a large, decentralized agency where the largest known risk is related to the financial system configurations for accepting the award attributes. Another unique attribute for this agency is its use of aggregated data for financial assistance. Readers may be able to leverage some of the processes or methodologies described in this scenario depending on their DATA Act operating environment. Introduction I. This Administration is committed to delivering improved results to the public, while maintaining accountability to taxpayers for sound fiscal stewardship and mission results. This supports the President’s Management Agenda goal to shift from low - value to high - value work. The Department of WN B shares the Administration’s commitment to creating an unprecedented level of openness in government, ensuring the public trust, and establishing a system of transparency, public participation, and collaboration. Aspending.gov, it is essential that To submit high quality spending data to US the Department of WN B develop and implement a Data Quality Framework to empower key governance to oversee internal controls for data submitted for publication. Our governance for spending data quality is led by the SAO. II. DATA Act Operating Environment The DATA Act operating environment is comprised of three pillars that each contribute equally to upholding the reporting objectives of the DATA Act. The first pillar is the stakeholders and accountable parties for organizational structure, which defines the key collaboratively publishing quality data. The second pillar encompasses the lifecycle of the information and transactions behind the records reported for publication. The final pillar is data management, as agencies’ have the responsibility to ensure the reliability of systems that collect and report data and compliance with the statutory and regulatory frameworks for making and managing the awards reported under FFATA and the DATA Act . Organizational Structure A. The DATA Act is one of the first legislative requirements to bridge multiple federal agency functions. As a result, communication channels that may not have existed in strive the past were forged to reach reporting compliance. WNB s to maintain the accountability in meeting the objectives of providing the public with - wide agency high quality data while maintaining the integrity of the Federal awarding process under which taxpayer dollars are spent . Many of the key stakeholders in this process belong within ex isting governance structures, such as the Budget Officers Advisory Council, Chief Information Officers 31

35 Data Scenario 5 Quality Playbook Council (CIOC), CFOC, the Chief Acquisition Officers Council, and the Award Committee for E - Government. The governance structure supporting the data qu ality framework will leverage WNB senior leadership is committed to existing agency organizations and processes. increasing agency - wide accountability and transparency of our financial data and fostering a greater public understanding of the work we do and the costs associated s with carrying out the agency mission. To achieve this, WNB ha an organizational structure related specifically to DATA Act reporting. As shown in Table 1, reporting components and begins at the award and obligation level within sub - ends with the SAO. Table 1: DATA Act Organizational Structure 32

36 Data Quality Playbook Scenario 5 The key stakeholders for ensuring successful implementation of the Data Quality Framework include the SAO, file owners, system owners, and data owners. The DATA Act Consortium serves as the agency - level oversight body for the DATA Act scope. Membership includes file and system owners. File owners are the primary party for ensuring that data is collected timely from the correct system, validated per d timely for publication. File owners are government - wide standards, and submitte the also responsible for summarizing the results of each quarterly submission, quantifying and explaining variances, and adding context to the SAO certification recommendation where necessary. Accountability for varian ces in the submissions are assigned to the File owners, just as weaknesses in the system - operating operating WNB environment are assigned to system owners. Overall gaps in the environment are addressed at the Consortium and SAO level. B. Information Process flow The DATA Act reporting process is an amendment to existing information flow under the FFATA. As shown in Table 2 below, both the DATA Act and the FFATA reporting processes capture only the back end of the lifecycle of the transaction they represent. Table 2: DAIMS Information Flow Diagram The genesis of these records lie within the sub - component level functional offices such as contracting offices, budget offices, grant offices, and finance offices. Process owners have existing procedures and controls that align with statutory and regulatory to ensure that transactions are subjected to the requirements for such awards appropriate level of controls to ensure that approvals, data entries, validations, closeouts, reconciliations, and reporting pro cesses are all completed in a repeatable, 33

37 Data Quality Playbook Scenario 5 efficient, and reliable manner. These business cycles are documented under the Federal Financial Manager’s Information Act of 1996 (FFMIA) requirements over , 48 CFR for Federal acquisition, and 2 internal controls CFR for Federal financial assistance C. Data Management USA s pending .gov is drawn from the sources WNB data submitted for publication to financial systems are required to identified in Table 3. Department carry the award ID to ard transactions with associated financial details to assure award linkage for all aw awa rds made after January 1, 2017. Linkages are based on specifications of the award ID, such as mandated schematic, uniqueness, and length, as defined by the FAR for assistance awards. For technical procurement awards and the DAIMS fo r financial efer to the DAIMS guidance . on reporting of data, r For guidance on generation of the data reported via the DAIMS, refer to the FAR for procurement and 2 CFR and OMB . guidance for financial assistance Table 3 : DATA Act File Overview Summary System of Record (source) File Financial System Agency Appropriations Accounts A Agency Program Activity and Object Class Data Financial System B Financial System Agency Award Financial Data C Next – Federal Procurement Data System Procurement Award and Awardee D1 Attributes NG) - Generation (FPDS Financial Assistance Award and Awardee Grant System(s) via the FABS D2 Attributes System for Award Management (SAM) Prime Awardee Attributes E Award Attributes - Sub A - ward Reporting System (FSRS) Sub FFATA F One of the primary indicators of quality data is the ability to extract it from a reliable system. According to the Green Book’s Information and Communication principle for using quality information; “Management obtains relevant data from reliable internal and external sources in a timely manner based on the identified information requirements. Relevant data have a logical connection with, or bearing ble internal and upon, the identified information requirements. Relia external sources provide data that are reasonably free from error and bias and faithfully represent what they purport to represent. Management evaluates both internal and external sources of data for reliability. Sources of data can be ope rational, financial, or compliance related. Management obtains data on a timely basis so that they can be used for effective monitoring.” The reliability of external sources lies with the system owner. Our responsibility is limited to ensuring that awarde es are given adequate instructions at the time of award for completing data input to these systems. 34

38 Data Scenario 5 Quality Playbook systems align with the type of file for DATA Act systems. Files A and Internal WNB D1 and D2 are exclusively award information. Files B are exclusively financial, while The purpose of File C is to link the two primary data elements, financial data and award data, a across the Federal G overnment. Therefore, the scope of link that is new WNB Files A – C data can be defined as the Oracle financial systems. systems for The feeder and mixed systems sourcing award data varied by sub component and - WNB s specific platforms of varying types for the contracting function. operate sub - components have specific instances, the writing systems. While individual FPDS overall purpose is to interface output data to both the Oracle system and NG - (the authoritative source for DATA Act procurement elements) on a nightly batch basis. WNB also leverages our business warehous e system collecting financial assistance component grant offices. - data fro There are multiple grant award systems m sub feeding the business warehouse. Other ancillary systems exist for additional financial d agreement; as well as a few assistance award types such as loans, stipends, an manual flat - file uploads for aggregated data. III. Data Quality Framework The Department of WNB represents a collaboration of multiple critical stewardship activities across a diverse population of sub - components and programs. In an organization with such varied and distinctive missions, it is necessary to establish an understanding of the unique na ture of our programmatic lines of business. It is equally critical in meeting the DATA Act reporting objectives to develop a common agreement on the criteria for ensuring data quality at its source and throughout its lifec ycle of use and dissemination. WNB sees this criteria as a framework on which to gauge and improve reporting quality. The cornerstones of this framework are shown in Table . 4 Table 4: Data Quality Framework Determine Materiality Define Data Quality and Risk Tolerance Data Quality Framework Establish a Quality Develop a Quality Plan Baseline A. Define Data Quality Each agency subject to the DATA Act is required to appoint an SAO. It is the reasonably assure through quarterly certification, that responsibility of the SAO to 35

39 Data Quality Playbook Scenario 5 management has used quality information to DATA manage the risk of not meeting reporting a nd compliance objectives. WNB has defined that quality as follows: Act  Data submitted meets the DATA Act repo rting objectives.  Data is generated from the appropriate sour ce systems.  Data is subjected to exist ing system and process controls.  ts were considered during the annual risk - based assessment of Key data elemen . ICOR Reportable records are submitted and linked across files, where appropriate, in  accordance with the DAIMS. The quarterly SAO certification communicates reasonable assurance that these com pon ents of quality have been met. Within this metric of quality, is the concept that data attributes carry varying levels of impact on the overall reporting process. , as DATA Act submissions must comply with DAIMS display standards WNB applicable. However, this agency aims to create reporting efficiencies by focusing on key components of individual records. Specifically, these elements are essential in determining who the funds were paid to, where the assistance was received, how what purpose. much was obligated, and for An initial list of - identified key data elements that demonstrate quality for WNB Appendix I presentation to the taxpayer is provided in of this memorandum. A majority of these key elements are considered complete, timely, and accurate via their inclusion in existing agency and oversight control environments. These control environments include, but are not limited to policy and procedure d ocumentation, reconciliations, testing, audits, and independent reviews. At a minimum, the WNB requires all data elements that meet the Department of following criteria to be considered key elements.  The data element is a GTAS - reportable financial att ri bute.  The data element serves as a link between DATA Act Files .  d, or externally supplied field. The data element is not a propagated, derive The File D1 data element is currently reviewed as part of the ann  ual procurement V&V process.  The File D2 data elem ent is the same as (or comparable to) one currently reviewed as part of the annual procurement V&V process. Additional Elements may be included with those that fall under these criteria if identified as part of the baseline and risk assessment process es . B. Determine Materiality and Risk Tolerance Throughout the submission process, all critical errors must be remediated immediately. This includes all financial source file variances (File A to GTAS and file errors). - cross 36

40 Data Quality Playbook Scenario 5 Warnings are further assessed to , but are determine the appropriate course of action as they do not consider the statutory or generally not an indicator of data quality, regulatory variations allowed for awards . File owners will refer to the Materiality Threshold Chart (Table 5 ) to determ ine the prescribed action and attention paid to each variance. All variances require documentation, at a minimum, in the form of an explanation. In some cases, documentation takes the form of a Risk Acceptance a availability, or inherent nature of the Memo due to limitations such as resources, dat variance. Table 5 : Materiality Threshold Chart Variance Threshold Action Type Any variance Source File Requires explanation  File does not include  Variance: all required TAS; or Return source file to  A – C File C does not  process owner for include all reportable remediation, if awards applicable Any variance Financial File  File B to GTAS/SF Requires review and  - Variance: File explanation 133; or to File File A to File B   Contact process/data owner for remediation or adjustment, if applicable/feasible 11 , < $XM D1: > = $XM Award File   Requires review Award in File D1 or File absolute value Variance: D2, missing from File  Send variances to File individual variance to File C; Owners D2: > = $XM, < $XM Obligation in File C   Determine if source absolute value missing from File D1 adjustment s file(s) need individual variance or D2 ; or D1: > $XM absolute Requires  review and Award and Obligation  individual variance, but explanation prior to sum does not tie <$XM recommendation D2: >$XM absolute Send variances to File  individual variance, but Owners < $XM  Determine if source to be/can s file(s) need be resubmitted Net or Absolute Value Any  Any individual action  Communicate the issue Variance Over $XM U nexplainable to agency - level or Variance stakeholders at and associated A variance  above Director levels, with a specific set of up to and including the actions SAO ervasiveness, and Explanations should consider impact to the agency submission, p critical or sensitive nature of the issue in addition to quantitative factors in the determination of materiality. 11 ile value and SAO risk tolerance. f Based on the individual analysis performed at th is agency and is dependent on the total 37

41 Data Quality Playbook Scenario 5 C. Establish a Quality Baseline Success in achieving continuous quality starts with establishing a baseline of internal . This self - control measures against which future progress can be gauged assessment of the DATA Act operating environment needs to be comprehensive, objective, and must identify areas to strengthen. This is consistent with the activities described in the Gr een Book regarding the establishment of a baseline, as follows: “ Management establishes a baseline to monitor the internal control system. The baseline is the current state of the internal control system compared against management’s design of the interna l control system. The baseline represents the difference between the criteria of the design of the internal control system and condition of the internal control system at a specific point in time. In other words, the baseline consists of issues and deficie ncies identified in an entity’s internal control ” system. “ Once established, management can use the baseline as criteria in evaluating the internal control system and make changes to reduce the duces this difference between the criteria and condition. Management re difference in one of two ways. Management either changes the design of the internal control system to better address the objectives and risks of the entity or improves the operating effectiveness of the internal control system. As part of monito ring, management determines when to revise the baseline to reflect changes in the internal control system . ” WNB will include the following results at a minimum in establishing the DATA Act quality baseline. The results of each will be reviewed for applica bility to the DATA Act operating environment, remediation status, and risk to the DATA Act reporting objectives. Res ults of OIG Audits and Reviews.   Results of GAO Audits and Reviews; for results specifically related to t his agency; if any.  Results of the Federal Procurement Da ta V&V .  Results of the A - 123 Internal Control Assessments; for any cycles and findings specifically related to the DATA Act operating environment.  Results of the ERM agency risk profile process for cycles and business processes within the scope of the DATA Act operating environm ent.  Any additional assessments related to the systems, data, processes, or stakeholders within the DATA Act operating environment. The baseline will also include a snapshot of current internal control structures, both on the existing FFATA reporting side and the newer DATA Act reporting side. The result will be an assessment of the current quality level of data reported to .gov. USAspending 38

42 Data Quality Playbook Scenario 5 Develop a Quality Plan D. The final cornerstone of the agency Data Quality Framework is to develop a plan for n USAspend increasing the quality of the data submitted for publication o .gov. ing This involves three steps; conducting a risk analysis to id entify gaps, developing procedures to address gaps identified, and establishing monitoring processes. i. Assess Risk To improve the quality of federal spending data , WNB will develop and utilize a risk - systems used to based approach for assessing the existing processes and compile spending data and assess the probability of occurrence and impact of inherent and potential risks. The risk assessment process facilitates the identification of risks related to federal spending information, rating of risks identifi ed and rating the probability of occurrence and impact of these risks. The identification of the risks related to the quality of federal spending information will provide a basis for developing a comprehensive approach to reducing data mitigation strategy to improve the quality of federal spending quality risks and a data shared with the public. For the purposes of developing the risk based approach, the Department will limit - the scope of the approach to the 57 federal spending elements submitted to USAsp ending.gov in response to the DATA Act by WNB . We will leverage the based approach for assessing - work and results of the analysis to develop a risk existing processes and systems. The risk based approach will focus primarily on - significant data quality and integrity problems, such as the timeline for integrating the award identifier and Aggregated Direct Payments. Additional activities will the business warehouse to Treasury’s Broker. focus on data submission from the probability of occurrence of the risk Identified risks will be scored based on and the impact of the risk. Impact is based on the materiality, as determined by the agency and approved by the SAO. Materiality will be both qualitative and quantitative dependent on the nature of the data element or attribute. Because this is a subjective process, the agency will leverage some of the tools and techniques used to assess risk under the previously executed as part of the OMB Circular A - 12 Management’s Responsibility for Internal Control , Appendix A 123, , Assessment, as well as tools and techniques used to perform the risk profile for ERM. ii. Address Gaps Department of WNB The will focus on high - risk areas by performing a Root Cause Analysis for each identified risk, develop a risk mitigation strategy, and establish a process for monitoring progress to reduce the risks, thereby improving the quality and integrity of the data sha red with the public. This will include 12 Risk assessments conducted under the revised 2018 Circular A will 123, Appendix A are not explicitly defined by OMB ; however, this agency - . e existing practices leverag 39

43 Data Quality Playbook Scenario 5 - risk areas and it may be supplemented sample testing for key attributes in the high by the implementation of additional preventative controls, if applicable. iii. Continuous Monitoring WNB will monitor financial and awar d data quality for accuracy, timeliness, and completeness utilizing existing reviews, processes, testing, and risk mitigation activities to the greatest extent possible. WNB will monitor the plan throughout FYs 2019, 2020, and 2021 for updates based on new reports and the results of testing. Updates to existing procedures or development of new ones will be DQP . dependent on the periodic review of the IV. Conclusion In addition to sharing the Administration’s commitment to increasing accessibility to Governmen t spending data, ensuring the public trust and establishing a system of committed to ensuring transparency, public participation, and collaboration, WNB is successful transformation across this agency to yield real and lasting improvement to the spending d ata quality of our organization. Our governance structures, plans for – outlined in this Data Quality Framework – immediate action, and monitoring strategy will improve the quality of spending data, address known deficiencies, and facilitate a greater publ ic understanding of the programmatic results we achieve and the value of our business operations. The results of the analysis conducted in accordance with this framework are included in minimum, for Appendix II, however will be reviewed annually through FY 2021, at a appropriateness and potential updates. 40

44 Data Scenario 5 Quality Playbook Appendix I List of Key Data Elements DQP For the purposes of the WNB , the chart below contains the data elements considered key to meeting the DATA Act reporting objectives for the respective record. Additional elements may be added dependent on the results of the risk analysis. These fields are considered accurate for DATA Act submissions matches to the within the reported record when the value provided authoritative source.  Identifies elements included in existing quality procedures (e.g., Governmentwide Treasury – Trial Balance System [GTAS] Account Symbol Adjusted validations , or annual V&V , FAR assessment) and indicates that duplicative and/or additional testing for the sole purpose of DATA Act reporting is not necessary based on OMB M - 17 - 04 . X – Identifies elements not currently incl uded in a government - wide or agency - specific data quality requirement and as a the element may be at higher risk for not addressing data result, quality standards. ∞ – Identifies elements serving as a primary link between Files that shall be assessed base d on effectiveness in linking the files. File Data Element Labels Link B C D1 D2 E F A       Allocation Transfer Agency Identifier ∞       Agency Identifier ∞       Beginning Period Of Availability ∞       Ending Period Of Availability ∞       Availability Type Code ∞ Main Account Code       ∞ Sub Account Code       ∞ Fiscal Year Budget Authority Unobligated Balance Brought Forward     ) FYB Beginning ( Current Period Adjustments To Unobligated Balance Brought Forward     ) Ending ( CPE Budget Authority Appropriated Amount CPE       Borrowing Authority Amount Total CPE     Contract Authority Amount Total CPE     From Offsetting Collections Amount Total CPE Spending Authority     Other Budgetary Resources Amount CPE     Total Budgetary Resources CPE     Gross Outlay Amount By TAS CPE     Obligations Incurred Total By TAS CPE     Recoveries Refunds By TAS CPE Deobligations     Unobligated Balance CPE     Status Of Budgetary Resources Total CPE   41

45 Data Quality Playbook Scenario 5 File Data Element Labels Link C D1 D2 E F B A X Program Activity Name   X Program Activity Code   X   Object Class ∞ By Direct Reimbursable Funding Source     Obligations Undelivered Orders Unpaid Total CPE     United States Standard General Ledger ( USSGL ) 480100 Undelivered     Orders Obligations Unpaid CPE USSGL 483100 Undelivered Orders Obligations Transferred Unpaid CPE     Obligations Delivered Orders Unpaid Total CPE      USSGL 490100 Delivered Orders Obligations Unpaid CPE      USSGL 493100 Delivered Orders Obligations Transferred Unpaid CPE       Gross Outlay Amount By Program Object Class CPE    Gross Outlays Undelivered Orders Prepaid Total CPE      USSGL 480200 Undelivered Orders Obligations Prepaid Advanced CPE      USSGL 483200 Undelivered Orders Obligations Transferred Prepaid     Advanced CPE  Gross Outlays Delivered Orders Paid Total CPE      USSGL 490200 Delivered Orders Obligations Paid CPE      USSGL 490800 Authority Outlayed Not Yet Disbursed FYB       Deobligations Recoveries Refunds Of Prior Year By Program Object Class   CPE  USSGL 497100 Downward Adjustments Of Prior Year Unpaid Delivered     Orders Obligations Recoveries CPE  USSGL4 97200 Downward Adjustments Of Prior Year Paid Delivered     Orders Obligations Refunds Collected CPE   Obligations Incurred By Program Object Class CPE    Obligations Undelivered Orders Unpaid Total FYB      USSGL 480100 Undelivered Orders Obligations Unpaid FYB      USSGL 488100 Upward Adjustments Of Prior Year Undelivered Orders     Obligations Unpaid CPE  Obligations Delivered Orders Unpaid Total FYB      USSGL 490100 Delivered Orders Obligations Unpaid FYB      USSGL 498100 Upward Adjustments Of Prior Year Delivered Orders     Obligations Unpaid CPE   Gross Outlay Amount By Program Object Class FYB    Gross Outlays Undelivered Orders Prepaid Total FYB      USSGL 480200 Undelivered Orders Obligations Prepaid Advanced FYB      Orders USSGL 488200 Upward Adjustments Of Prior Year Undelivered     Obligations Prepaid Advanced CPE  Gross Outlays Delivered Orders Paid Total FYB      USSGL 490800 Authority Outlayed Not Yet Disbursed CPE      USSGL 498200 Upward Adjustments Of Prior Year Delivered Orders     Obligations Paid CPE  USSGL 487100 Downward Adjustments Of Prior Year Unpaid     Undelivered Orders Obligations Recoveries CPE 42

46 Data Scenario 5 Quality Playbook File Data Element Labels Link C D1 D2 E F B A  USSGL 487200 Downward Adjustments Of Prior Year Prepaid Advanced     Undelivered Orders Obligations Refunds Collected CPE Procurement Instrument Identifier (PIID) X   ∞ (Referenced PIID or Indefinite Delivery Vehicles [IDV] D Parent Award I   ∞ X ID) Federal Award Identification Number (FAIN) X X  ∞ Unique Record Indicator (URI)  X X ∞ Action Date X   X Transaction Obligated Amount X   Face Value Of Direct Loan Or Loan Guarantee X   Original Loan Subsidy Cost X Award Modification Amendment Number X   Action Type X   Assistance Type  X Award Description (Description of Requirement) X   North American Industry Classification System (NAICS)    CFDA Number X Awardee Or Recipient Unique Identifier (DUNS) X   Awarding Agency Code (Contracting Agency Code/ID) X   Funding Office Code X   Funding Agency Code X   Primary Place Of Performance Country Code X   Primary Place Of Performance ZIP+4 X   43

47 Data Scenario 5 Quality Playbook Appendix II FY 2019 Department of WNB Data Quality Baseline Department of WNB Data Quality Baseline Assessment, our Based on the results of the FY 2019 agency has determined that the Financial Assistance and IT cycles carry the largest risk to reporting objectives . meeting our DATA Act on plan’ s lead - time, resource However, an assessment of their respective corrective acti requirements, and ancillary impacts has led the SAO to conclude that WNB will focus the FY19 will develop risks. In the meantime, efforts on remediating or lowering the DATA Act IT WNB a V&V assessment tool for implementation in the financial assistance community. The results of the assessment will provide the agency with targeted weaknesses for correction in out years. Risks: 1 - Very Low, 2 - Low, 3 - Medium, 4 - High, 5 - Very High FY 2019 Agency Data 3 Weight 4 3 2 2 2 3 3 Quality Baseline Assessable Units (AU) Changes Risk Rating Compliance Human Capital Centralized /Decentralized Blended Cycle Materiality Complexity Information Technology Known Deficiencies Recent Process 1 DATA Act Operating Environment 2.14 1 3 2 1 5 3 2 Financial Reporting 3.28 2 1 5 4 4 2 5 2 1.72 1 2 1 5 2 2 1 Budget 1 3.39 3 1 5 5 5 4 3 3 Acquisition 4.72 5 3 5 5 5 5 5 Financial Assistance 5 Information Technology 3.92 4 4 3 3 5 2 5 5 Certification 1 1 1 1 5 1 3 1 1.64 Average Risk 2.98 2.9 2.1 2.9 2.4 5.0 3.0 3.3 2.7 Total AU 7 % of Total 100% Ke y Low Risk Risk ratings from 1 up to 2.24 Moderate Risk Risk ratings from 2.25 up to 3.74 High Risk Risk rating from 3.75 up to 5 44

48 Data Quality Playbook Scenario 6 Sce : Departm ent of N CR Illustrative nario 6 DQP midsize outline was developed for a The following agency with a significant grant and loan ERM capability. Readers may be able to leverage some of the portfolio and a maturing scenario depending on their DATA Act operating approaches or methodologies describe d in this environment I. Overview link financial and award data to The DATA Act established requirements for agencies to - in M 17 promote open data transparency. OMB issued additional requirements - 04 and under Circular A 123 Appendix A, Management of Reporting and Data Integrity Risk, - issued in June 2018, to help ensure all reported data are of sufficient quality to provide visibility to taxpayers as well as enable government leaders to make informed decis ions for achieving mission outcomes. in support of achieving One of the OMB requirements is for agencies to develop a DQP the objectives of the DATA Act. The purpose of the plan is to help guide the internal controls, to achieve implementation of effective risk management, including quality reporting of financial data. This document serves as Department of NCR ’s framework for ensuring data quality for externally reported financial data, are aligned with the DQP efforts, including the objectives, and informed by risk. Department’s missio has enterprise - wide n NCR strategic objectives focused on strengthening the quality, and use of data. accessibility, These objectives include but are not limited to externally reported financial data, which is the focus of the DATA Act. of NCR Department will use this framework to guide the development and implementation of the DQP in support of externally reported financial data, as well as to guide all other Department risk management strategies and internal control activities related to data quality. II. Enterprise View of Data Quality As NCR matures its ERM capability, risk information and enterprise - wide risk management strategies will increasingly guide decision - making across throughout the organization. This strategic mission priorities, includes balancing consideration of risks, and the focus of internal controls, across all strategic, operational, compliance and reporting objectives. The newly issued OMB Circular A - 123, Appendix A reinforces this approach. It provides greater flexibility than before in requirements related to internal controls over data and reporting so agencies can most effectively prioritize resource allocations to ensure . The newly issued guidance builds on pri or OMB guidance successful mission delivery 45

49 Data Quality Playbook Scenario 6 - - 04) that supports agencies’ use of existing statutory and regulatory approaches for (M 17 data quality in meeting the DATA Act quality efforts. ’s enterprise risk appetite and tolerances, as well as integrated risk Department NCR will be used to ensure the appropriate balance of risk management activities portfolio related to data quality. This includes balancing cost, performance, and risk considerations - financial (largely performance) related to financial data management activities and non data management activities. Given limited Department resources, data management NCR ’s efforts to activities must be aligned across the enterprise to maximize the value of strengthen the quality, accessibility, and use of its data. III. Data Quality Internal C ontrols To provide open data transparency as well as enable leaders and stakeholders to make Department of NCR data are managed and reported internally and informed decisions, externally. These activities can be grouped into four broad categories: al Financial Data External Non Financial Data - Extern • Includes DATA Act requirements, • Includes Government Performance and Results Act requirements, strategic and , agency financial reports and DQP annual plans/reports budget • Supported by internal controls over data • Supported by Internal Controls sources /manag e ment including Over Financial Reporting (ICOFR) grant/loan recipient performance data /procurement V&V dat a Internal Financial Data Financial Data - Internal Non Includes spending plans, • Includes operational plans, program and • management performance and risk data operational data on expenditures Supports internal Supports internal controls over strategic, controls over • • program, and risk management operations including loan monitoring grant/contract/ initiatives including grant/contract/loan perfo r mance monitoring Framework for Data Quality Management IV. Step 1 – Governance NCR  Create linkages between existing bodies and offices within to improve communication and coordination across all data quality efforts. Leverage existing Data Strategy Team to help promote consistent approaches and discussions of data management — completeness, tim eliness, accuracy, and quality — across external and financial data categories. - in ternal, financial and non 46

50 Data Scenario 6 Quality Playbook  Integrate data quality into ERM and internal control governance discussions to promote strategic, coordinated decisions on data management activities including risk treatments, trol monitoring. internal controls, and con Step 2 – Identify Objectives .  Define Department of NCR ’s overall reporting objectives with respect to the DATA Act Leverage the GAO Green Book, Standards for Internal Control in the Federal and OMB Circular No A - Government Management’s Responsibility for Enterprise 123, . Risk Management and Internal Control DATA Act Ensure and other data quality objectives are aligned to  NCR ’s Strategic Plan goal and objectives including those focused on strengthening the quality, accessibility, s and use of data at the enterprise level. Objectives for individual offices should cascade down the organization from the Department - level objectives, and capture the unique rt of the functions , statutory, regulatory, and business processes of those offices in suppo broader mission. Step 3 Risk Identification and Assessment –  Each office should identify and conduct an assessment of the most significant risks to achieving its unique data quality objectives. Materiality as well as other quantitative and qual itative factors will be used to evaluate the likelihood and potential impact of risks.  Develop an integrated portfolio view of the significant risks that may affect external and internal, financial and non financial data. This assessment should include con sideration - of existing risk treatments. Step 4 – Risk Management ERM  Incorporate data quality into discussions and decisions on risk appetite and tolerances. enterprise risk appetite and tolerances will guide risk management  Department of NCR decisions across and at lower levels of the organization. Each office should align data management activities to risk appetite and tolerances. This includes developing target risk nd implementing risk treatments (including internal controls to ensure data levels a quality) to achieve those targeted levels of risk. Step 5 – Monitoring C ontrols and Providing Assurance Each office should monitor and test the key internal controls in their ris k treatment  strategies. The number of data quality controls tested and samples taken will be informed by the office’s risk management strategy and the enterprise - wide portfolio view of data quality risk. To maximize value, NCR seeks to achieve a strategic balance in its implementation of internal controls and testing over the various external and internal, financial data. - financial and non 47

51 Data Scenario 6 Quality Playbook  Department of NCR will leverage exi s ting internal control processes including testing techniques, templates, and sampli ng approaches to support monitoring of all data quality controls including DATA Act implementation. Department of NCR will document the specific controls and monitoring procedures for  the in its DQP . DATA Act  Deficiencies related to external and internal, financial and non - financial controls will be reported, aggregated, and analyzed across the enterprise to inform NCR ’s overall management assurance statement regarding the efficiency and effectiveness of reporting. Step 6 – Remediating Deficiencies and Con tinuous Improvement Offices will implement corrective actions to remediate data quality internal control  deficiencies. 48

52 Data Quality Playbook Valid Business Process and Statutory Allowance Exceptions Representing Valid Business Processes Exceptions and Statutory Allowances I. Introduction The DATA Act provided a unique opportunity to present the lifecycle of a Federal dollar . As the statutes, regulations, and policies governing the integrity through Federal awards of such processes differ across business lines, presenting such data in a comprehensive and cohesive view required making adjustments in the collection of such data This . Playbook is designed to provide oversight and compliance man section of the agers with examples of such variations as described in each condition. or agency - The examples here are drawn from existing oversight and compliance reviews specific internal control processes over Files A, B, and C in preparation of submission to Treasur y’ s Brok er and linkage to award files . The limitations present in the timing and reporting structure of the initial DATA Act implementation has d opportunities for create . P further improvements laybook provides context around data In the interim, this diffe rences, context that cannot be easily understood from a comparison of data elements but for which there is longstanding and recognized policy or process rationale . As used in this P laybook, t he terms ‘explainable warnings’, ‘valid variances’, and ‘justif are all used to communicat e that there is a policy basis for iable exceptions’ dismissing a system - generated warning ( edit check ) that is limited to quarterly comparisons of data across all files. As such, the Broker warnings may not indicate in the data, as the warning logic cannot assess all possible policy parameters inaccuracies . This is not a quality assessment but rather an indication of an anomaly. Agencies can rely d on existing guidance and regulation citations to direct review teams for reference an avoid developing additional documentation requirements, unless required . This list INCLUSIVE but rather provides examples of when technology IS NOT ALL - on any vulnerabilities or risk Future updates to the warnings may not actually be based . Broker may change, add to, or mitigate this list. Explainable warnings : include  File Warning s : An attribute(s) within an individual record that does not meet the criteria of a validation rule in the agency’s quarterly assurance process or in the Broker, but are eit her accurate per the authoritative sou rce or are an allowable option based in policy or regulation . - File Warning  : Cross The corresponding record in one f ile does not match either the s primary key or all comparable data fields (e.g., TAS, Award ID, obligat ion amount) in the c ross - f ile validation; however, despite the mismatch, the submi tted record itself is valid.  Data Fix es options agencies may take to This final category represents examples of : must be taken to correct data that would otherwise ge nerate correct critical errors that 49

53 Data Quality Playbook Valid Business Process and Statutory Allowance Exceptions in contrast to the ile and c ross - f ile warnings, which are groups a critical error. This is f , as of variances that require explanation, but do not require that the input be changed they do not represent critical errors. possible explainable differences for each The fo f ile , by the llowing displays DATA Act warning type. File A II. A. File Warnings are related to There are no significant examples of warnings specific to File A that . business processes, policy, or regulation Cross - File Warnings B. prior year adjustment (PYA) Variances (Broker File A to B Variances Due to Validations A18, A19, and A35)  Variances between File A and File B will be noted by Treasury’s Broker when USSGL accounts 48XX - 49XX are submitted with a PYA attribute of ‘B’ or ‘P’. walked to - cross In the GTAS Adjusted Trial Balance System , these amount s are Line #1020 (Adjustment to unobligated balance brought forward, Oct 1) on the standard f r m (SF) - 133 instead of the normal Obligations Incurred, Recoveries, or o . Since the PYA attribute is not part of the File B submission, Gross Outlays lines the calculated change in GL balances will not reconcile to the SF - 133 lines. When comparing File A to File B, the Broker wil l generate warnings for these explainable differences in these cases based on the type of balance submitted; Outlays (A18), Obligations incurred (A19), and Deobligations, Recoveries, and Refunds (A35). C. Data Fix There are no significant examples of critical errors specific to File A that would require agencies to update the input data and are related to business processes, policy, or regulation. III. File B File Warnings A. Program Activity Validation (Broker Validation B9)  While OMB and Treasury have a pr ocess to obtain updates to the list of program activity codes and names, there are instances where valid program activitie s were most recent update not included on the . Therefore, explainable differences are observed is cases where a B9 warning is received even though the program activity is valid as confirmed with the agency budget office and OMB.  Final funding allocations for centrally funded activities are not known until the . Current Plan is finalized 50

54 Data Quality Playbook Valid Business Process and Statutory Allowance Exceptions nd B15) File B to GTAS Variances (Broker Validations B14 a When the scenario exists in File A generat ing an A19 warning (see  PYA attribute above), the agency will incur corresponding B14 an explainable difference for the and/or B15 (reimbursable) warning due to the Broker validation (direct) obligations for those TAS in File B to GTAS comparing the . - File Warnings B. Cross File A to B Variances Due to PYA Variances (Broker Validations A18, A19, and A35)  See Section II.B for details . File A to B Variances Due to Program Activity Rounding (Broker Validations A18, A19, and A35)  For agencies with Program Activity allocations, small rounding differences (e.g., one or two cents) explainable differences may be noted when the Broker flags in warnings comparing the Outlays (A18), Obligations incurred (A19), and Deobl igations, Recoveries, and Refunds (A35) reported by the agency in File B to File A. o Example: F unds for centrally funded initiatives come from a number of contributing program activities on a pro - rata basis; the obligations for those activities must be re allocated back to the contributing program activities on - the same pro - rata basis . This causes slight explainable rounding differences when the Broker compares File A to File B . C. Data Fix idation Program Activity Val  n obligation activity has not yet occurred for a TAS reported in File A; there Whe Broker will be no corresponding File B record. To pass the critical error validation , comparing all TAS in File A to File B (A30) , agencies must insert a row into Fi le B (manually or through system configurations) with a zero dollar balance and use the Other/Unknown” program activity code and name. These “ rows are reported with “0000” in the program code and “000” for the OC. For these explainable differences, t he B ro ker does not display a warning if the o ther/ u nknown values are submitted and the row contains all zero balances but u review of the File will show the o ther/ nknown values .  reportable record in File C associated with a TAS and OC It is possible to have a explainable difference combination that does not exist in File B. This can be the result of an initial obligation being recorded in one quarter and either corrected or er the Broker’s Cross deobligated in a subsequent quarter. Howev File, - comparison will trigger this as a critical error (B20) when there is no corresponding File B TAS and OC combination . Agencies can mitigate this error by adding o r through system configurations) a corresponding zero (manually bal ance record to File B with the o ther/ u nknown program activity name and codes. o Example, FY 2018 TAS obligation recorded for $100 to OC 252 in Q2 and this is the only transaction for this TAS and OC combination Correction of . 51

55 Data Quality Playbook Valid Business Process and Statutory Allowance Exceptions posted in Q3 . the OC from 252 to 257 was As a result, there is reportable activity in File C for that TAS and OC combination. Yet, the beginning and ending balances are both zero for the TAS and 252 OC, preventing the need for a File B record . IV. File C File Warnings A. related to nificant examples of warnings specific to File C that are There are no sig business processes, policy, or regulation. Cross - B. File Warnings Reporting Threshold (Broker Validations C11, C8, and/or C23) 48 CFR (the FAR ) does not require agencies to report contract actions below the  micro - . The broker compare s File C with File D1 and as purchase threshold (MPT) , identifying these explainable differences and will generate warnings (C11 a result and C23) when a PIID is found in File C under the MPT and no corresponding (C11 and C23) . PIID is found in File D1  Firm fixed price contract actions that meet the simplified acquisition threshold can have funds deobligated and are not complex after the final invoice payment . In these case s, without requiring a contract modification the explainable difference is between the File C entry for a deobligation without a corresponding File D1 record in the period of the deobligation, triggering a Broker warning (C11 and C23). threshold the are not required to be  Financial assistance awards under reporting reported in File D2; however, may be determined to be reportable for File C. This explainable difference c ross - file comparison will result in Broker warnings for the (C8 and C23). (Broker Validations C11, C12, Procurement: Post Date and Award Date Differences and/or C23)  The quarterly nature of the DATA Act reporting introduces timing differences in reporting across files, and these differences may not require further explanation or documentation. If documentation is required, it should be done in accordance with policy or internal controls. Financial obligations are recorded in the financial system upon receipt . The FAR requires reporting of contract obligations within certain timeframes (3 - 30 days depending on FAR flexibilities) . A contract could Q2 be awarded in - and reported to FPDS NG to meet FAR requirements yet the nature of the financial reporting is such that the financial obligations are recorded . Likewise, a contract for an urgent and compelling need could be awarded in Q3 and recorded in the financial system before it is required to be recorded in FPDS - NG , crossing DATA Act reporting quarters. As the broker matching occurs within a single quarter , th e explainable difference will generate a warning (C11, C12, and C23) in th e current reporting period .  When a TAS is canceling , the outstanding unpaid obligations are closed out in the , - 11) financial system in the current reporting period (in accordance with A 52

56 Data Quality Playbook Valid Business Process and Statutory Allowance Exceptions canceling funds . e de obligat i on is for If th on triggering a reportable File C record will be no corresponding contract action in File D1 until the FAR a contract, there closeou administrative (in another reporting period) , including any t procedures audits or litigation, have been completed As the broker matching occurs within a . single quarter, the explainable difference will generate a warning (C11, C12, and C23) in the current reporting period. Financial Assistance: Post Date and Award Date Differences (Broker Validations C8, C9, and/or C23)  Some entitlement programs are authorized via statu t e to make funds available to the recipient on the first day of the quarter. The agencies with these programs certify the funds in the period prior to their availability to the recipient with a date it is available for the recipient. As a result ‘release date’ corresponding to the , the File C obligation reported in the current period of this explainable difference File D2 award, which will trigger Broker warnings will have no corresponding (C8 and C23). The reverse will occur in th e following reporting period when the File D2 record is present without a corresponding File C record for that award (C9 and C23).  Some agencies release the Notice of Award to recipients prior to the award start date (e.g., up to 15 days) and explainable If this activit y crosses quarters . difference is noted where the obligation post date will be associated with a File C record for one period (C8 and C23 warnings in the first period) and the corresponding File D2 record will appear unmatched in the subsequ ent period (C9 and C23 warnings in the subsequent period). When a TAS is canceling , the outstanding unpaid obligations are closed out in the  financial system in the current reporting period (in accordance with A - 11) , triggering a reportable File C record. There is no corresponding award record in File D2 for that single quarterly reporting period , as financial assistance will keep the award open administratively until it has satisfied the agreement’s closeout procedures. As the broker matching occurs withi n a single quarter, the explainable difference will generate a warning (C8, C9, and C23) in the current reporting period o Example: Closeouts for award s can be delayed due to award audits or pending litigation that would prevent final closeout ahead of the f und cancellation . C. Data Fix Program Activity Validation  See section III.C for details on the B20 validation data fix. V. File D1 A. File Warnings There are no warnings for File D1 in the DATA Act Broker as these are based on the FPDS - NG authoritative source for procurement (FPDS - NG) . Records that pass 53

57 Data Quality Playbook Valid Business Process and Statutory Allowance Exceptions the FAR are passed to USA pending .gov on a daily validations in accordance with s as authoritative . basis Cross B. File Warnings - Reporting Threshold (Broker Validations C11 and/or C23) See section IV.B  for details Post Date and Award Date Differences (Broker Validations C11, C12, and/or C23)  See section IV.B for details Award ID Referential Integrity (Broker Validations C11, C12, and/or C23) delivery, the FAR provides  To reduce administrative burden and expedite mission . agencies with the flexibility to do “express reporting” (FAR 4.606) Such reporting will result in one contract action record in FPDS - NG but multiple financial obligations in the financial system (for example, purchase of prosthe tics ) . This explainable difference will generate warnings (C11, C12, and/or C23) as a result of this flexibility . C. Data Fix Any future changes to capture data or reporting would need to occur when the data are generated as no edits to D1 procurement data can be made without appropriate review at the source. File D2 VI. A. File Warnings D2 in the DATA Act Broker after There are no examples of warnings specific to File file generation , as these validations are performed in accordance with the FABS validation rules. Records that pass these validations are interfaced to USAspending.gov to populate rep orting File D2 in accordance with the appropriate period action date. - File Warnings Cross B. Reporting Threshold (Broker Validations C8 and/or C23) See section IV.B for details .  Post Date and Award Date Differences (Broker Validations C8, C9, and/or C23)  See section IV.B for details . Administrative Modifications or corrections - monetary a  modifications Non will populate in File D 2 for the ward quarter associated with the action date and may represent explainable differences, as they not expected to have a corresponding record in Fil e C. are and Example: Non - financial closeouts where funds have already canceled o been removed from the finance system. The current period File D2 entry represents a valid administrative modification. 54

58 Data Quality Playbook Valid Business Process and Statutory Allowance Exceptions Example: Modifications processed to extend the period of o performance are considered (among many other examples) as administrative only, with no expected corresponding File C record. The current period File D2 entry represents a valid administrative modification. Award ID Referential Integrity (Broker Validation s C8, C9, and/or C23) Some agencies have specific statutory authority  to report financial assistance awards in a consolidated manner to reduce reporting burden. The result is one , or record in the period’s File D2 and many transactional records in File C vice . The one - to - versa, depending on the agency’s situation relationship is an many explainable difference that may trigger Broker warnings on the referential integrity and will generate warnings ( C8, C9, and/or C23). C. Data Fix FABS Data submitted to alidation in accordance with existing FFATA guidance for v is not available for edit at the point of quarterly DATA Act reporting. Any necessary changes identified through reconciliations or Broker cross - file validations should be referred to the financial assis tance stakeholders for review and corrective action determination if a file needs to be resubmitted to FABS and a new File D2 generated . VII. File E File Warnings A. There are no examples of warnings specific to File E . Per in the DATA Act Broker the FAR, agencies “are not required to address data for which the agency would not normally have supporting information, such as the compensation information required - tier subcontractors.” In addition, OMB Circular A - 123 of contractors and first ix A : provides Append “Consistent with terms and conditions of Federal awards, entities receiving federal awards are required by 2 C.F.R. Part 25 and the FAR to submit accurate data to the SAM and the FSRS maintained by the GSA. The quality of this data is the l egal responsibility of the recipient. GSA provides an assurance statement that the systems are maintained appropriately and can therefore be used for public reporting. Agencies are responsible for assuring controls are in place to verify current registrati on in SAM at the time of the financial assistance award. Pursuant to 2 C.F.R. Part 200.513, agencies are responsible for resolving audit findings which may indicate if recipients are not complying with their requirements to register or report Subawards. Ag encies are not responsible for certifying the quality of data reported by awardees to GSA and made available on USAspending .gov.” B. Cross - File Warnings There are no c ross - f ile validations between File E and any other f ile . C. Data Fix this The agency has no action or responsibility on DATA Act f ile . File F VIII. 55

59 Data Quality Playbook Valid Business Process and Statutory Allowance Exceptions File Warnings A. in the DATA Act Broker Per There are no examples of warnings specific to File F . the FAR, agencies “are not required to address data for which the agency would not supporting information, such as the compensation information required normally have of contractors and first 123 - tier subcontractors.” In addition, OMB Circular A - : Appendix A provides wards are “Consistent with terms and conditions of Federal awards, entities receiving federal a required by 2 C.F.R. Part 25 and the FAR to submit accurate data to the SAM and the FSRS maintained by the GSA. The quality of this data is the legal responsibility of the recipient. ined appropriately and can GSA provides an assurance statement that the systems are mainta therefore be used for public reporting. Agencies are responsible for assuring controls are in place to verify current registration in SAM at the time of the financial assistance award. Pursuant to 2 C.F.R. Part 200.513, agencies are responsible for resolving audit findings which may indicate if recipients are not complying with their requirements to register or report Subawards. Agencies are not responsible for certifying the quality of data reported by ailable on USAspending.gov.” awardees to GSA and made av B. - File Warnings Cross and any other c f ile validations between File F - f ile . There are no ross Data Fix C. this DATA Act or responsibility The agency has no action f ile on IX. Contract Policy Clarifications are several examples where oversight reports included observations that following The explainable differences as inaccuracies. The following policy have mischaracterized context is provided for in an attempt to provide information on the these observations policy, process, and technology solutions that support reliance on the data quality in a dynamic operating environment. A. Vendor Information contract file at time  Contractor information collected in FPDS - NG is based on the uses the of award, which entity identifier and associated s unique contractor ’ information at the time of the contract award Such information, along with other . statutorily required registration data, may change over time . Such changes will be reflected in the contract record if appropriate modificati ons are warranted . As FPDS - NG is the authoritative data source for US Federal procurement, including s display on USA pending.gov and DATA Act reporting, the contractor information in FPDS NG is the authoritative data for that contract . Contractor - informatio n on USAspending.gov is sourced directly from FPDS - NG and a s a result, comparison of contractor information from USAspending.gov to the SAM or to the contract file or contract writing system may return explainable differences and discrepancies as FPDS - NG i s the authoritative source for contract . awards 56

60 Data Quality Playbook Valid Business Process and Statutory Allowance Exceptions (or task NG records data at the time of award until appropriate contract -  As FPDS adjustments are made, there may be differences in information on a order) \ delivery order, blanket purchase agreement (BP A), or a BPA call reported to task and the contractor information in SAM - ( File D1) NG . The task/delivery FPDS order contractor information will be aligned to the information on the base (referenced indefinite delivery vehicle) award, not the vendor’s current registration in SAM . As FPDS - NG is the authoritative source for procurement data there is no s pending.gov required and it additional review of SAM to USA risks returning information or observations that are not aligned with regulatory requirements .  Similar to the previous two examples, comparing addresses for a contractor across multiple data sources may return explainable differen ces . The S AM must collect multiple addresses for companies seeking contracts from the Federal government. he physical address of the company’s location, the mailing address These include t where official documents are to be sent, and even a payment address for payments that are not electronic . The contract documentation may include yet another address, that of the place of pe rformance of the predominance of the contract . Each is based in certain regulatory or statutory needs . The FFATA and DATA Act require only two addresses to display to whom the money was awarded . mance) As all ( physical address ) and where the work is done (place of perfor these data are keyed together by the unique entity identifier and are used in may different situations, comparing the addresses across multiple sources return . different information Deviations from Regulations B.  The FAR (48 CFR) provides agency officials with flexibilities designed to accommodate emergent needs, mission requirements, and statutory changes Such . flexibilities include the ability to deviate from the FAR (1.4) . Deviations from the FAR may be granted unless they are precluded by law, executive order, or regulation . Some deviations may be authorized by the agency head (1.403) while others require consultation with the Civilian Agency Acquisition Council prior to authorization . In both cases, procedures and requirements for issui ng and ing document such deviations can be found in the FAR (1.4) and questions regarding deviations should be directed to the agency Chief Acquisition Officer or SPE .  T FPDS - NG will here are situations where the contract information reported to contain a generic name and address for privacy and security reasons. Explainable contract writing systems d File D1 and contract f iles \ ifferences between may be permissible as defined in FAR 4.605(c). Administrative Modifications C. 57

61 Data Quality Playbook Valid Business Process and Statutory Allowance Exceptions monetary c -  ontract awards and modifications will populate in File D1 for the Non quarter associated with the action date and not have a corresponding record may in File C for the same period . o Example: Non - financial c loseouts where funds have already expired and been rem oved from the finance system in a prior reporting period . The current period File D1 entry represents a valid administrative modification. Modifications processed to change the contracting officer are Example: o considered (among many other examples) as admi nistrative only, with no The current period File D1 entry expected corresponding File C record. valid administrative modification. represents a D. Appropriated funds – the FAR requires reporting of procurement actions using appropriated funds . E. Emergency acquisitions – the FAR provides flexibilities to support contingenc y operations when the President issues an emergency declaration (among other items) . When such flexibilities are authorized, numerous FAR requirements can be delayed and/or waived to include dollar thresholds, documentation , and reporting requirements, ven dor registration requirements, etc . If such flexibilities are exercised, . Files C and D1 this may result in explainable differences between 58

62 Data Award - Specific Considerations Quality Playbook - Specific Considerations Award DATA Act Agency submissions to USAspending.gov must comply with the requirements set s to provide assurances to their agency randum forth in the following OMB Memo reasonable SAO in support of certification that the agency’s internal controls support the reliability and level data reported : validity of the agency’s financial assistance award - - 03 “Additional Guidance for DATA Act Implementation: Implementing MPM No. 2016  Centric Approach for Reporting Federal Spending Information” - Data ( https://obamawhitehouse.archives.gov/sites/default/files/omb/financial/memos/managem - procedures - memorandum - no - 2016 ent 03 - additional - guidance - for - data - act - - implementation.pdf ). DATA Act 17 - 04 “Additional Guidance for - Implementation: Further Requirements  M for Reporting and Assuring Data Reliability” https://obamawhitehouse.ar chives.gov/sites/default/files/omb/memoranda/2017/m ( 17 - - 04.pdf ).  - 18 - 16 “Appendix A to OMB Circular No. 123, Management of Reporting and Data M - . Integrity Risk” ( https://www.whi tehouse.gov/wp - content/uploads/2018/06/M ) 18 - 16.pdf For Financial Assistance certification process, the Treasury Broker generates File D2 based on .gov via the ongoing submissions to the FABS for the data previously provided to USAspending File D2 is generated using the action date field by specifying the date range for the that quarter. File D2 is comprised of transactional financial assistance award data as quarter in the Broker. well as aggregated financial assistance award d ata (depending on the agenc y). In accordance with OMB submission guidance, the agency should be submitting financial assistance data to the F ABS at least twice each month. Any financial assistance data that cannot be reported at the transactional level should be aggregated according to DATA Act reporting requirements . Award ID Linkage : The Broker executes cross - file validation rules to compare the financial data contained in File C with the financial assistance aw ard data contained in File D2. There are D2 that validate the presence of an Award several Broker cross - file va lidations for Files C to File ID linkage between the files. The requirement to report the Award IDs (i.e., FAIN , and Unique [ for financial assistance) in File C necessitates that this Award ID linkage ] Record Indicator URI nancial and management systems exist in agency fi . Agency Data Quality Processes : Each agency is encouraged to develop and continuously refine its processes to collect, validate, and submit data to USAspending.gov via the FABS, and should consider developing a validation results report that identifies any withheld records that did not lidations or FABS validations. These reports can then be used to pass agency internal system va co mmunicate issues to the data owners (e.g., at the Sub - Tier Agency level) and track each record to a resolution and explanation of why a resolution cannot be achieved within this quarterly sub mission . Scenarios Affecting Agency Ability to Establish File C to D2 Award ID Linkages : Agency reviews of Award ID linkages between Files D2 and C may take into consideration that that there 59

63 Data Quality Playbook Award - Specific Considerations . Possible explainable are limited exceptions to any 100% match between files D2 and C outlined below : differences between the two files as are  Timing Differences: One of the predominant cross o file alignment differences are timing differences - due to the current business processes used by the finance and financial assistance communities for data reporting. After conducting analysis of prior periods, agencies may recognize that some timing differences will always exist between File C and File D2, but may expect that a great deal of these cross - file variances g additional reporting can be explained by examinin periods. Over time, agencies should re - examine these existing processes to ascertain whether they should be adjusted for DATA Act reporting or will remain explainable differences , based on the needs of the various communities . o For example: a financial as sistance award is made on March 31 but does not get posted to the financial system until April 1, resulting in a Q2 record in File D2 Q3. explainable While these and its corresponding File C record appearing in differences 2 within the FY , they will not align may net between File C and File D within the single certification periods. Additional Recommendations : Each agency should ensure its financial assistance office(s) responsible for reporting to the FABS and USAspending .gov are engaged and attentive to upcoming updates and opportunities to review drafts of future releases of Treasury’s DAIMS and the technical reporting specifications for USAspending .gov . Agencies can request to be added to Program the distribution list for DAIMS releases by sending an email to the Treasury DATA Act [email protected] . Management Office (PMO) at Additionally, given the reliance on the Federal Hierarchy (managed by GSA’s In DATA Act ) for tegrated Award Environment reporting, agencies should ensure their Change Control Board (CCB) representatives or their participating in CCB meetings. The Federal designees are current, engaged, and actively Hierarchy is comprised of Funding Agency Codes/Names, Funding Sub - Tier Agen cy Codes/Names, Funding Office Codes/Names, Awarding Agency Codes/Names, Awarding Sub - Tier Agency Codes/Names, and Awarding Offi Agency CCB reps (or their ce Codes/Names. designees) should review their respective agency’s Federal Hierarchy data for accuracy as it is used for both financial assistance data reporting as well as procurement data reporting, and may be used in the near future to facilitate reduced agency reporting requirements. Agency CCB reps [email protected] to request help with reviewing their respective Federal may email Hierarchy data as well as to designate an alternate agency rep to manage the Federal Hierarchy data. 60

64 Data Quality Playbook NOT FOR DISTRIBUTION Certification Illustrative Examples – Certification Illustrative Examples Certification of the quarterly DATA Act submission occurs in Treasury’s Broker, in accordance with the schedule released by Treasury, but no later than 45 days after the end of each quarter . SAO must have a certifier role activated in the Broker to acc ess this feature. Once all files The - pass critical errors and the cross file validations have been performed, SAOs may select the – certification option. Treasury provides SAOs comment boxes for each File (A the SAO F) for to include additional language, if th ey so choose. Below are some examples that SAO may choose to provide in these comment boxes based on their discretion, knowledge of the status of the quality of their data, and reliance on controls in place over the reported data. The examples below are il lustrative only, but demonstrate the flexibility provided by OMB to agencies in providing reasonable assurance over their data. - Scenario 1 Agency XYZ File A As the SAO for XYZ’s DATA Act submission, I assure that File A, B, C, D1 , and D2 of XYZ’ s DATA Act submission for the X quarter of FY20 XX are appropriately aligned and the underlying data are being managed in accordance with internal control practices outlined a I assure that the DATA Act dat . in OMB memoranda, Federal regulation, and OMB A - 123 are valid and reliable for display on s pending . Pursuant to OMB Circular No. A - 11 USA XYZ reported all TAFS in each GTAS Section 130.2, for Executive branch agencies, reporting window. The data in File A match the authoritative source (i.e., SF - 133) and a ll required TAS are reported. Credit program financing account activity is not required to be reported under the DATA Act. Funding for these costs is reflected in the program account, per the Federal Credit Reform Act, as outlined in Section 185 of OMB Cir cular A - 11. File B - The total amount reported in File B matches the authoritative source (SF 133), Program Activity, and Budget Object Class Codes are reported based on the President ’ s Budget as - executed and A 11 respectively. codes are embedded in the President’s Budget. On a The Program Activity names and quarterly basis, agencies work with OMB to send updates to Program Activity through the BDR process in alignment with the President’s Budget. OMB then passes the Program Activity validation list to Treasu ry as the validation list for the Broker. File C All financial data, including the obligations in this file, are subject to management assurances 123. The data reported in File C match the authoritative source (i.e., OMB Circular A - under agency financial s ystems). Agency submissions for the DATA Act pull data from multiple sources. The sources for Files C, D1 , and D2 have different frequencies for updating the These timing differences can result in data being relevant data to USAspending.gov . 61

65 Data – NOT FOR DISTRIBUTION Certification Illustrative Examples Quality Playbook ifferent intervals throughout the quarter, at times resulting in potential delays in displayed at d and D2 that are not awards matching across sources. There are a few records in Files C, D1 , inable expla linked directly. However, the steps management is taking to resolve these are reasonable and sufficient. differences File D1 - 282) as amended by the DATA Act (P.L. The d ata reported pursuant to FFATA (P.L. 109 101) are sourced from FPDS - NG and the key data elements are aligned at the time of - 113 quarterly reporting. The da ta reported in File D1 are subject to internal controls based on V&V FAR required . for the assurance over Federal procurement awards File D2 he data in File D2 match the authoritative source (i.e., agency award management systems) T level data and the authoritative source (i.e., SAM) at the time of award for prime for award - awardee information. File E The data included in File E are subject to the internal controls of the system owner, the GSA in accordance with A 123. XYZ is relying on the assurance of GSA that data integrity - processes are in place and align with A - 123. File F The data included in File F are subject to the internal controls of the system owner, the GSA is relying on the assur XYZ in accordance with A - 123. ance of GSA that data integrity processes are in place and align with A - 123. - Scenario 2 Agency MBT File A - MBT Pursuant to OMB Circular No. A 11 Section 130.2, for Executive branch agencies, reports all TAFSs i assures D ATA Act File A n each GTAS reporting window, MBT - 133 per A - 136 guidelines, and data is audited and subject to reconciles to the GTAS SF management assurances of internal controls over reporting under A - 123. File B Pursuant to OMB Circular No. A - 11 Section 130.2, for Executive branch agencies, MBT reports all TAFSs in each GTAS reporting window. MBT assures this data is audited and - 123 subject to management assurances of internal controls over reporting under A MBT . assures the Program Activity codes utilized in DATA Act File B are validated against the President's budget, and the OC codes cited are validated against A - 11. File C MBT assures that data is audited and subject to management assurances of internal controls ct pull data from multiple Agency submissions for the DATA A over reporting under A - 123. 62

66 Data – NOT FOR DISTRIBUTION Certification Illustrative Examples Quality Playbook sources. Each of these sources has a different frequency for updating the relevant data to USAspending.gov. These timing differences can result in explainable differences for data the quarter, at times resulting in potential being displayed at different intervals throughout ppropriations account - level data. MBT is aware of a variance a delays in awards matching - NG with regard to the Parent Award between our financial/procurement system and FPD S ID. File D1 FAR and O MB memoranda begi n n in g in 2009, MBT Pursuant to the is required to submit ann - NG Data V&V Report to OMB and GSA. The report includes assurances over ual FPDS the timeliness and completeness of the data and sampling of the core DATA Act required data elements, comparing con - NG. Agencies are not required by statute or tract files to FPDS policy to report awards below the MPT (as defined by FAR 2.101) or any classified, MBT is aware of a variance be tween our sensitive, or personally identifiable information. nt financial/procureme system and FPDS - NG with regard to the Parent Award ID. File D2 MBT assures that data is audited and subject to management assurances of internal controls FABS over reporting under A to ensure - 123. MBT is reliant upon the validations within the data follows the standard format. File E In FY 2016, the Procurement Management Review (PMR) Division of the Procurement Management Division (reporting directly to the GSA SPE in the Office of Acquisition Policy), Office of Government - wide Polic y and the OCFO A - 123 Internal Control Review team conducted parallel financial and acquisition reviews across the agency. PMR reviews assessed the effectiveness of internal controls over procurement management. By analyzing activities from both an acquisit ion and financial perspective, GSA addressed control issues that involved financial and acquisition functions. The SAM and FSRS successfully passed the security controls assessment at the Federal Information Processing Standards (FIPS) 199 Moderate impact level, in accordance with the Federal Information Security Management Act ( FISMA ) National Institute of Standards and Technology and ( NIST ) policy guidelines and GSA Security Assessment and Authorization (A&A) process. GSA has determined that the risk to F ederal Agency operations, data, and/or assets resulting from the operation of the common controls of SAM and FSRS information systems are acceptable and meet all the security controls required for DATA Act reporting. Accordingly, agencies can rely on data from SAM and FSRS for DATA Act reporting. File F In FY 2016, the PMR Division of the Procurement Management Division (reporting directly to the GSA SPE in the Office of Acquisition Policy), Office of Government - wide Policy and the OCFO A - 123 Internal Contr ol Review team conducted parallel financial and acquisition reviews across the agency. PMR reviews assessed the effectiveness of internal controls over procurement management. By analyzing activities from both an acquisition and financial perspective, GSA addressed control issues that involved financial and acquisition functions. FIPS 199 FSRS successfully passed the security controls assessment at the The SAM and 63

67 Data – NOT FOR DISTRIBUTION Certification Illustrative Examples Quality Playbook Moderate impact level, in accordance with FISMA and NIST policy guidelines and GSA Security A& A process. GSA has determined that the risk to Federal Agency operations, data, and/or assets resulting from the operation of the common controls of SAM and FSRS information systems are acceptable and meet all the security controls required for DATA Act re porting. Accordingly, agencies can rely on data from SAM and FSRS for DATA Act reporting. Scenario 3 Agency ABC - The following comments apply to all Files in this submission for Agency ABC. multiple sources. Timing Issues ABC submissions for the DATA Act pull data from :  Each of these sources has a different frequency for updating the relevant data to USAspending.gov. These timing differences can result in data being displayed at different intervals throughout the quarter, at times resulting in potential delays in awards - level data. matching appropriations account  Award ID Linkage - As required in OMB Memorandum M - 16 - 03 and M - 17 04 on - DATA Act reporting to USAspending.gov, agencies must link their financial account by carrying the Federal award ID in the agency financial data to their the award data January 1, 2017. For data system and using this to link with award data for reporting as of submitted prior to that date, award data may not be linked to financial account data . Missing Awards: ired by statute or policy to report awards below the is not requ  ABC MPT (as defined by FAR 2.101) or any classified, sensitive, or personally identifiable information. Scenario 4 Department of JFK - File A Pursuant to OMB Circular No. A - 11 , Section 130.2, for Executive branch agencies, JFK reports all TAFSs in each GTAS reporting window, JFK assures DATA Act File A reconciles to the GTAS SF - 133 per A - 136 guidelines, and data is audited and subject to 123 management assurances of internal control s over reporting under A - Optional Data: . Some agencies have chosen to provide optional data elements not required when it is beneficial to their own recordkeeping or reporting purposes, or to pilot possible areas of . cing Accounts & Program Accounts for Credit: Credit expanded reporting capability Finan program financing account activity is not required to be reported under the DATA Act, and as a result, award information for certain contract costs paid out of those accounts will not y linked to account data. Funding for these costs is reflected in the appear to be directl program account, per the Federal Credit Reform Act, as outlined in Section 185 of OMB Circular A - 11. File B JFK Pursuant to OMB Circular No. A 11 , Section 130.2, for Executive branch agenci es, - reports all TAFSs in each GTAS reporting window, JFK assures DATA Act File A - 136 guidelines, and data is audited and subject to 133 per A reconciles to the GTAS SF - 64

68 Data – NOT FOR DISTRIBUTION Certification Illustrative Examples Quality Playbook - 123 JFK assures t he management assurances of internal controls over reporting under A . Program Activity codes utilized in DATA Act File B are validated against the President’s OC codes cited are validated against A budget, and the 11 . - Financing Accounts & Program Accounts for Credit: Credit program financing account red to be reported under the DATA Act, and as a result, award activity is not requi information for certain contract costs paid out of those accounts will not appear to be directly linked to account data. Funding for these costs is reflected in the program account, per the ral Credit Reform Act, as outlined in Section 185 of OMB Circular A - 11. Fede FY do not have Default Object Classes: Beginning balances brought forward from the prior OC due to known system limitations of JFK ’s financial system. the associated - Top Adjustments: The JFK is aware that some of the balances do not include On details OC due to on top adjustments made during the GTAS reporting process outside of the financial system during the FY . File C Data Completeness: on 04 - • Award ID Linkage: As requi red in OMB Memorandum M - 16 - 13 and M - 17 DATA Act reporting to USAspending.gov, financial account data must be linked to their award data carrying the Federal award ID in the agency financial systems and using this as of January 1, ID to link to awards 2017. For data submitted prior to that date, award data may not be linked to financial account data . The JFK is aware that the agency JFK was not appropriately reporting the PIID in FPDS - NG . As of May 1, 2018, JFK has implemented the new PIID logic in acc FAR requirements. ordance with the • Parent Award ID: The JFK has implemented changes to begin capturing the federal award ID of the parent award owned by another agency in JFK ’s financial system as of June 22, 2018. Award data prior to this date may not h ave other a gency parent award information. • Missing URI: As of Month X , 20 XX , a URI field has been made available in the JFK’ s financial system. The JFK is in the process of implementing changes to start populating this field. • Timing Issues: The JFK pul ls data from multiple sources for the DATA Act submission. Each of these sources has a different frequency for updating the relevant data to USAspending.gov. These timing differences can result in data being displayed at different intervals throughout the quarter, at times resulting in potential delays in awards matching appropriations account - level data File D1 See Award ID Linkage and Timing I ssues in File C Section. Data Completeness: • Micro - Threshold: As defined by FAR 2.101, JFK is not required by sta tute or policy to . MPT report awards below the 65

69 Data Quality Playbook NOT FOR DISTRIBUTION Certification Illustrative Examples – nally identifiable • PII: Agencies are not required to report classified, sensitive, or perso information. • Inconsistent PIID Logic: The JFK is aware that JFK was not appropriately reporting the in FPDS - N G PIID . As of Month X, 20XX, JFK has implemented the new PIID logic in accordance with the requirements. FAR File D2 See Award ID Linkage and Ti ming Issues in File C Section. Data Completeness: • Missing De de - obligations are not obligations: At this time, the JFK is aware that - always reported to the FABS. Corrective actions are in process to begin consistently orting de - obligations in FY19. rep • Incorrect Dollar Value: At times, obligation amounts have been reported to FABS as a rounded dollar value. As of Month X, 20XX, exact obligation amounts with dolla rs and cents will be reported. • Missing URI: Beginning on Month X, 20XX, financial assistance data will begin to report relevant URI information to FABS. File E OMB has stated that the Department may cert ify based on GSA assurance per guidance in M - 17 - 04. File F OMB has stated that the Department may certify based on GSA assurance per guidance in - 17 - 04. M Scenario 5 - Department of W N B As the SAO for Agency ’s DATA Act submission, I assure that Files A, B, C, D1 and WNB D2 of W N B ’ s DATA Act submission for the X quarter of FY 20XX are appropriately aligned and valid and reliable for display on USA s pending.gov per OMB Circular A - 123, 17 Management’s Responsibility for and Internal Control . Per OMB M - - 04, WN B ERM relies on the internal controls of the system owners for Files E and F to ensure data quality. 6 - Department of NCR Scenario The Department of NCR considers the act of selecting the certification feature in Tre asury’s Broker sufficient to indicate that the SAO has certified the data and therefore does not interpret the comment boxes provided to be necessary enhancements to the certification, unless otherwise noted by NCR to indicate an anomoly or exception. Fil e A 66

70 Data Quality Playbook NOT FOR DISTRIBUTION Certification Illustrative Examples – None File B None File C Agencies are not required by statue or policy to report awards below the MPT (as defined by FAR 2.101) or any classified, sensitive, or personally identifiable information. Agency tiple sources. Each of these sources has a submissions for the DATA Act pull data from mul different frequency for updating the relevant data to USAspending.gov. These timing differences can result in data being displayed at different intervals throughout the quarter, at times resulting in potential del ays in awards matching appropriations account - level data. File D1 Credit program financing account activity is not required to be reported under the DATA Act, and as a result, award information for certain contract costs paid out of those accounts will not appear to be directly linked to account data. Funding for those costs is reflected in the program account, per the Federal Credit Reform Act, as outlined in Section 185 of OMB - 11. Circular A File D2 As required in OMB Memorandum M - 15 - 12 on Data Act report ing to USAspending.gov, agencies must link their financial account data to their award data using a Federal award ID as of January 1, 2017. For data submitted prior to that date, award data may not be linked to financial account data. Incomplete or missing Zip+4 and/or address data received from SAM.GOV was corrected where possible by using the database. United States Postal Service This correction also included incidental changes to place of performance and Congressional Districts. Data that could not be c orrected, in some cases, was rejected by the USA Spending error checks and could not be included in the monthly submissions. File E None File F None 67

71 Data Quality Playbook Acronyms Glossary of Acronyms Assessment and Authorization A&A Assessable Units AU Assistant Secretary for Administration ASA Blanket Purchase Agreement BPA BDR Budget Data Request CAR Contract Action Report Catalog of Federal Domestic Assistance CFDA CCB Change Control Board CFO Chief Financial Officer CFOC Chief Financial Officer Council CFR Code of Federal Regulations tion Officers Council CIOC Chief Informa Digital Accountability and Transparency Act of 2014 DATA Act DACP DATA Act Control Plan DAIMS DATA Act Information Model Schema DAWG DATA Act Working Group DCFO Deputy Chief Financial Officer DQP Data Quality Plan EE Extended Enterpri se ERM Enterprise Risk Management FAIN Federal Award Identification Number Financial Assistance Broker Submission FABS FAR Federal Acquisition Regulation FFATA Federal Funding Accountability and Transparency Act FFMIA Federal Financial Manager’s Information Act Federal Information Processing Standards FIPS FISMA Federal Information Security Management Act FMFIA Federal Managers’ Financial Integrity Act FPDS - NG Federal Procurement Data System - Next Generation FSRS FF ATA Subaward Reporting System FY Fiscal Year GAO Government Accountability Office Green book Standards for Internal Control in the Federal Government GSA General Services Administration - wide Treasury Account Symbol GTAS Government Internal Control O ver Financial Reporting ICOFR ICOR Internal Control Over Reporting ID Identification IG Inspector General IGT Intra - Governmental Transfer IT Information Technology MPT Micro - purchase Threshold NAICS North American Industry Classification System titute of Standards and Technology National Ins NIST 68

72 Data Quality Playbook Acronyms OC Object Class Office of Acquisition Management OAM OCFO Office of the Chief Financial Officer OFM Office of Financial Management OIG Office of Inspector General OMB Office of Management and Budget PIID Procurement Instrument Identifier PMO Program Management Office PMR Procurement Management Review PYA Prior Year Adjustment Data Quality Playbook Playbook SAM System for Award Management Senior Accountable Official SAO SAT Senior Assessment Team SBR Statement of Budge tary Resources SF - 133 Standard Form 133, Report on Budget Execution SPE Senior Procurement Executive Treasury U.S. Department of the Treasury TAFS Treasury Appropriation Fund Symbols TAS Treasury Account Symbol URI Unique Record Indicator USSGL United Stat es Standard General Ledger Verification and Validation V&V 69

73 Data Acknowledgements and Considerations Quality Playbook Acknowledgments and Considerations and The Playbook is a result of extensive collaboration between agencies, OMB, The Treasury. Leveraging Data as a Strategic Asset Working Group also extends its gratitude to our colleagues within the financial management, procurement, and financial assistance communities for their contributions . We would like to thank the following individuals specifically, for their direct input and collaboration, whose hard work, dedication, and significant contributions have made this possible. document Julie Tao, Department of Commerce Steve Kunze, Department of Commerce Lisa Romney, Department of Defense Phillip Juengst, Department of Education Andrea Brandon, Department of Health and Human Services David Horn, Department of Health and Human Services Kate Oliver, Department of Homeland Security Allen Lawrence, Department of Interior Teresa Hun ter, Department of Interior Dale Bell, National Science Foundation Mike Wetklow, National Science Foundation Emily Knickerbocker, Small Business Administration Tim Gribben, Small Business Administration e Tyson Whitney, United States Department of Agricultur 70

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