Personally identifiable information and data “validity” are the focus of the Office of Management and Budget’s latest DATA Act guidance.

In a Nov. 6 memo to agencies, OMB delves into detail for reporting certain types of federal financial assistance and awards under the Digital Accountability and Transparency Act.

The guidance does not change or affect any existing policy, OMB clarifies, but does “further [specify] (1) responsibilities for reporting financial information for awards involving Intragovernmental Transfers (IGTs), (2) guidance for reporting financial assistance award records containing personally identifiable information (PII), and (3) guidance for agencies to provide the Senior Accountable Official (SAO) assurance over quarterly submissions to USASpending.gov,” the memo states. “Agency SAOs will coordinate with ongoing efforts governmentwide and across appropriate partner agencies, OMB, and Treasury to ensure the protection of classified or protected information.”

Sen. Mark Warner (D-Va.), an original sponsor of the bill, told Federal News Radio in a statement that “data integrity will be a critical objective” as the May 2017 implementation deadline draws near.

“I’m pleased that OMB continues to provide clarity to agencies in their work to implement the DATA Act, including on important issues related to data reliability and integrity,” Warner said.

Christian Hoehner, policy director for the Data Coalition, said OMB’s clear guidance on both the agency and recipient is a good thing.

“For years [the Government Accountability Office] has been pointing to the importance of the DATA Act for tracking interagency payments,” Hoehner said in a statement to Federal News Radio. “Before the DATA Act there was no financial data model able to consistently track these types of internal government money flows. Now it looks like there is.”

Intragovernmental transfers

According to the latest guidance, two types of intragovernmental transfers are included under DATA Act reporting: allocation transfers and buy/sell transactions.

OMB directs agencies that starting with their first DATA Act reporting on allocation transfers, the agency will “submit and assure the appropriations information, program activity and object class, and award financial information for allocation transfers for display on USASpending.gov.”

As for buy/sell transactions, both the awarding and funding agencies must submit information for spending reports.

Keeping PII private

While federal spending transparency is a key part of the DATA Act, OMB directs agencies to ensure that personally identifiable information is not reported to USASpending.gov.

Under the new guidance, if a Federal Award Identification Number (FAIN) is included in details for a single award, the agency should report that award to USASpending “as a single, discrete record.”

If single award-level reporting isn’t possible, agencies can report aggregated awards at a county or state level.

As of the Nov. 6 guidance, however, the DAIMS [DATA Act Information Model Schema] only offers guidance for aggregate county level.

OMB directs agencies to continue the county-level reporting practice until that schema is modified.

“More technical guidance about reporting at the single award level and the state award level will be shared when the DATA Act Schema is modified to accept these records,” OMB said.

SAO reporting

The DATA Act requires senior accountable officials to make quarterly reports on “reliability and validity” of data reported by agencies  to USASpending.gov.

The guidance reminds these SAOs that they should have “categorical explanations for misalignments” of data file organization, and ensure that internal controls are in place to oversee data quality mechanisms.

“The SAO is responsible and accountable for their agency’s data submission,” OMB states. “Agencies are responsible for providing assurances over the data they submit for display on USASpending.gov.”

A long line of guidance

The guidance is the latest in a  series of OMB memos and updates for agencies, as they prepare for the May 2017 implementation of the DATA Act.

Officials with OMB and Treasury — the two agencies spearheading the DATA Act’s implementation — stand by the progress toward full adoption, while GAO auditors have repeatedly warned that the federal spending standardization could fall behind if agencies don’t get in line with the legislation’s requirements.

In early August, a GAO report warned that Treasury’s 4-month delay for releasing its schema version 1.0, triggered the delay of industry software patches while companies waited for a “stable version of the schema.”

That assessment came on the heels of another GAO report that said the full rollout of the DATA Act is at risk if OMB and Treasury don’t take steps to improve the review of agency plans and monitoring of progress updates.

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