And down the stretch they come! That’s how it must feel for federal agencies preparing to comply with the Digital Accountability and Transparency Act (DATA Act) (Pub. L. 113-101), as they now have about one more month to get ready to meet the DATA Act’s requirement that federal agencies begin reporting spending data in accordance with the act by May 9, and publicly post spending data in machine-readable formats by May 2018.
Late last year, then Office of Management and Budget (OMB) Controller David Mader told members of the House Committee on Oversight and Government Reform’s Subcommittee on Government Operations that “in spite of resource challenges, system integration issues and changes to business processes, 19 of 24 of the Chief Financial Officer Act agencies expect that they will fully meet the May 2017 deadline for DATA Act implementation.” However, he did not say which five were not expected to meet the deadline.
Recently, the Department of Housing and Urban Development’s Office of Inspector General (OIG) reported that HUD wasn’t on track to meet the May deadline, even though HUD officials contended that they expected to be in substantial compliance with the deadline. The OIG found that as of Dec. 16, 2016, HUD could not demonstrate that it completed key steps in the DATA Act Playbook for its contract, grant and subsidy programs. In particular, the OIG noted that the agency would not be able to report most of its required data files for its Federal Housing Administration (FHA) and Government National Mortgage Association (Ginnie Mae) components before the May 2017 deadline.
HUD officials told the OIG in February that they had made significant progress in meeting reporting requirements including completing: (1) an inventory of data elements for the systems and processes; (2) mapping of the data elements to the DATA Act schema; (3) modifications to its systems and processes to capture the FAIN data elements; (4) testing of system changes in the governmentwide broker; and (5) system changes for deriving the program activity data element from the accounting structure. However, the OIG said that it had not received any additional evidence from HUD after the release of its December 2016 review indicating that HUD had resolved these data quality issues.
HUD and the rest of the federal agencies now have five more weeks to fully prepare to meet the reporting deadline. Whether they all can make it remains to be seen, and it will be interesting to see what actions OMB and the Department of the Treasury will take against any agency that does not fully comply. However, this isn’t a simple race to a finish line; it’s more of a race to the starting line. Federal agencies must be compliant with the DATA Act requirements at that point forward. “We will have years of work in front of us to build out an integrated approach to comply with the DATA Act,” Matt Roper, deputy director of the finance staff at the Department of Justice (DOJ), recently said. “This will ultimately be a multiple-year effort.”
Let’s not forget that the federal government is not the only one interested in this act. The Department of Health and Human Services’ Section 5 DATA Act pilot program to test standardized reporting by grantees and contractors must end as of May 9. And by Aug. 7, 2018, OMB must decide whether to impose DATA Act standards on all grantee and contractor reporting. These will be keys date that all recipients of federal awards should keep their eyes on. The next year portends to be very exciting as we see how DATA Act events shake out.
Let us know what you think about the approaching DATA Act deadline. We’d love to hear from you.