Publicly released: November 12, 2019
The objective of this audit was to determine whether the U.S. Army Corps of Engineers (USACE) complied with Public Law 113-101, “Digital Accountability and Transparency Act of 2014” (DATA Act). We assessed the completeness, accuracy, timeliness, and quality of USACE’s first quarter FY 2019 financial and award data submitted for publication on USAspending.gov. We also assessed the USACE implementation and use of the Government-wide financial data standards (data elements) established by the Office of Management and Budget (OMB) and the Department of the Treasury (the Treasury).
On May 9, 2014, the President signed the DATA Act into law, expanding the Federal Funding Accountability and Transparency Act of 2006 (FFATA). The FFATA required OMB to establish a single searchable public website that disclosed information on Federal contract and grant awards to enable the public to track how their tax dollars are spent. To meet the FFATA requirement, OMB established the website USAspending.gov, and Federal agencies began reporting their data to the website in 2008. The DATA Act expands the FFATA by requiring Federal agencies to submit their spending data quarterly and to link that data to the contract and grant award data to enable taxpayers and policy makers to track Federal spending more effectively.
OMB requires Federal agencies to designate a Senior Accountable Official, who is required to certify that the data in each DATA Act file submitted for display on USAspending.gov are valid and reliable.
The Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, designated the Deputy Chief Financial Officer as the USACE Senior Accountable Official.
The DATA Act also directed OMB and the Treasury to develop joint Government-wide financial data standards to ensure consistent DATA Act reporting across the Federal agencies. To meet the DATA Act requirement, OMB and the Treasury developed financial data standards that define the 57 data elements that agencies must report under the DATA Act.
In addition, OMB and the Treasury developed standard reporting formats and issued guidance to Federal agencies on how to meet the DATA Act reporting requirements.
Federal agencies submit their financial and award data to the Treasury’s DATA Act Broker application, which compiles agency data for publication on USAspending.gov. Agencies are required to use the DATA Act Broker to upload three files containing data from their internal financial systems and records.
• File A – Appropriations Account. File A contains the fiscal year cumulative appropriations account summary data.
• File B – Object Class and Program Activity. File B contains the appropriation account data listed in File A but is further defined by object class code and program activity name.
• File C – Award Financial or Financial Data for Procurement and Grant Awards. File C contains transaction-level financial data for all procurements and grants processed during the quarter.
The DATA Act Broker extracts spending data from Government-wide award reporting systems that contain data on Federal contracts, grants, and award recipients.
• File D1 – Procurement. File D1 contains procurement award and awardee data extracted from the Federal Procurement Data System‑Next Generation.
• File D2 – Grants. File D2 contains grant award and awardee data extracted from the Financial Assistance Broker Submission system on grant and financial assistance awards.
• File E – Additional Awardee Data. File E includes information extracted from System for Award Management on the award recipients.
• File F – Sub-award Data. File F contains information extracted from FFATA Sub‑award Reporting System on awards made to sub‑recipients under a prime contract or grant award.
USACE did not comply with all DATA Act requirements. Although USACE implemented and used the required Government-wide data standards, and the USACE DATA Act submission for the first quarter of FY 2019 was timely, but not complete. In addition, File B (Object Class and Program Activity) contained 51 program activity names and codes that were inaccurate. Furthermore, although the File C data elements (Financial data elements for Procurement and Grant Awards) tested were complete, the projected error rates for accuracy and timeliness were 46.3 percent and 9.3 percent, respectively. Based on the highest projected error rate of 46.3 percent, the USACE data element quality level was low when using the Inspectors General guide developed by the Council of the Inspectors General on Integrity and Efficiency.
USACE did not comply with all DATA Act requirements because:
• the DATA Act Broker could not separate Files D1 (Procurement), D2 (Grants), E (Additional Awardee data), and F (Sub-award Data) from the DoD date submitted to the DATA Act Broker through the Government‑wide award reporting systems; and
• the USACE data quality plan did not contain processes for identifying, managing, and mitigating risk related to data quality.
We recommend that the USACE Chief of Engineers and Commanding General revise and implement the USACE data quality plan in accordance with OMB M-18-16, “Appendix A to OMB Circular No. A-123, Management of Reporting and Data Integrity Risk.” The revised plan should include, at a minimum:
a. assignment of roles and responsibilities for ensuring DATA Act data quality;
b. a risk assessment process;
c. definition of the control environment and control activities specific to the DATA Act submission;
d. a mitigation and monitoring plan for the data elements determined to be high risk; and
e. a testing plan for ensuring that financial and award data in Files A, B, C, D1, D2, E, and F are accurate before making USACE quarterly DATA Act submissions.
Management Comments and Our Response
The USACE Resource Management Director, responding for the USACE Chief of Engineers and Commanding General, generally agreed with our finding and recommendations but provided additional information to add context for our finding on data completeness and accuracy. The Director addressed the specifics of all recommendations; therefore, the recommendations are resolved but will remain open. We will close the recommendations once USACE provides a revised DATA Act data quality plan that addresses each of the minimum requirements identified in the recommendations.
This report is the result of Proj. No. D2019-D000CS-0062.000.