The Justice Department is on schedule to meet the DATA Act implementation deadline — sort of.

DOJ’s Office of Inspector General recently issued a review of the department’s progress toward standardizing its financial spending  reports, and according to the internal watchdog, “nothing came to our attention that caused us to believe that a material modification should be made” to Justice’s plans to meet the May 2017 deadline.

But the IG did note “areas of concern that potentially could impact the department’s ability to most effectively meet all the requirements within the requisite timeframe.”

Those areas of concern range from completing a full inventory, mapping and gap analysis of the department to an incomplete data extraction standard.

In its response to the IG, the Justice Department said in a letter that it had made “substantial strides” since the IG review was conducted in the summer and is taking additional steps to address the watchdog’s concerns.

More work to be done

The inspector general looked at the first four steps of the eight-step plan recommended by the Treasury Department for DATA Act implementation. Treasury and the Office of Management and Budget are the agencies spearheading the work.

“We reviewed the department’s status through step 4 because the implementation of the DATA Act requires an iterative and agile approach, and the department’s initial implementation plan indicated that the majority of the resource requirements would occur between steps 3 and 4,” the IG said. “The DOJ OIG will review the remaining steps, including the data submitted pursuant to the DATA Act, in its November 2017 OIG report.”

Within the Digital Accountability and Transparency Act is a requirement that agency IGs report on the law’s implementation. The first set of reports was due in November, however, the Council of Inspectors General on Integrity and Efficiency (CIGIE) recommended last December that because the spending data would not be available for November 2016, that the first required reports be due November 2017, with additional reports in 2019 and 2020.

According to the Justice Department’s IG review, the office has five concerns. The concerns are that:

1. A full inventory, mapping, and gap analysis is not yet completed for the entire department.
2. The department has not performed an impact analysis of the Federal Prison Industries’ lack of budgetary accounting at the transaction level.
3. No direct/reimbursable funding source indicator is present in the legacy accounting system.
4. The current solution for standardized extraction of data is incomplete.
5. The department plans to use a manual process to capture the Procurement Instrument Identifier for the Financial Management Information System 2; and the Systems, Applications, and Products System.

According to the review, the Department has three financial systems: the Unified Financial Management System (UFMS); the Financial Management Information System 2 (FMIS2), a legacy financial system; and the Systems, Applications, and Products (SAP) system.

Instead of inventorying these systems, DOJ inventoried the Drug Enforcement Administration’s (DEA) procurement information in UFMS and an initial inventory of the Office of Justice Programs’ (OJP) grant award information in FMIS2 — with the hope that the lessons learned could be applied to the other financial systems.

“However, the department did not fully foresee the issues that would arise due to the different components’ configurations of the financial systems and the inconsistencies in the way that components capture and report financial data,” the IG said. “Further, the department did not anticipate the impact of the delayed release of the DAIMS v1.07 guidance from Treasury.”

In its written response, DOJ said that since the August IG review, it continued to work to complete a full inventory of its systems and has “identified all major gaps and issues and are actively working to implement solutions.”

The U.S. Marshals Service has completed mapping and gap analysis for UFMS, DOJ said.

When it comes to not having a direct/reimbursable funding source indicator for its legacy accounting system, DOJ said it agreed with its IG’s concerns.

To address that worry, the Justice Department said it would continue to move “remaining components” off its legacy accounting system, but in the meantime would default to “Direct” when Direct/Reimbursable (D/R) code is not available.

Included in the DATA Act is a broker system that will:

• Check that submitted data follows a standardized format that will allow for aggregation and comparison across government.

• Validate selected data elements to ensure that the data are accurate.

Treasury updated the system in September, and according to the DOJ IG review, Justice “submitted actual data files for a small department component to the broker to test usability of the broker, but not to test the data extracted from the component’s financial system.”

“The test data was taken from the financial system and manually reconfigured to be consistent with the reporting requirements,” the IG said. “This was possible for the department to accomplish with a small component; however, manual reconfiguration of the data for all components could be risky.”

DOJ said additional component testing would be completed by January 2017, allowing the standardized extraction process to be completed.

The Justice Department said it is exploring other ways to reduce its manual process for collecting the Procurement Instrument Identifier (PIID), and also said in its written response that it is working on the budgetary accounting of Federal Prison Industries. A PIDD is a alpha or numeric code used in federal acquisition.

The IG did acknowledge the Justice Department’s progress toward implementation, including DOJ’s distinction as one of the first agencies to set a plan for DATA Act governance structure.

DOJ also provided feedback on the DATA Act Information Model Schema (DAIMS) and partnered with Treasury to lead a Product Control Board Momentum (financial system vendor) working group,” the IG review stated.

“The department DATA Act working group’s participation played an instrumental role in encouraging Treasury to directly pull data from various source systems to which Treasury already has access, rather than the agencies pulling information from those systems themselves and resubmitting the information to Treasury manually,” the review stated.

‘Just the beginning’

DOJ isn’t the only agency to hit some potholes on the road to full DATA Act implementation.

The Housing and Urban Development Department’s inspector general said in its August review that the department was at risk of missing the deadline due to, among other things, management turnover and an incomplete inventory of data elements.

Treasury Department and OMB officials also testified on Capitol Hill in early December that Congress shouldn’t expect perfect data nor financial reporting come May.

Treasury Fiscal Assistant Secretary David Lebryk told lawmakers that while much attention has been paid to the implementation deadline, “I think it is important to note that May is just the beginning.”

A new report from the Government Accountability Office found that 19 of the 24 CFO Act agencies are having trouble implementing the DATA Act because of systems integration, a lack of resources and guidance, and more complex reporting requirements.

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