ML21302A078
| ML21302A078 | |
| Person / Time | |
|---|---|
| Issue date: | 10/28/2021 |
| From: | Rivera E NRC/OIG |
| To: | Dan Dorman NRC/EDO |
| References | |
| Download: ML21302A078 (31) | |
Text
October 28, 2021 MEMORANDUM TO: Daniel H. Dorman Executive Director for Operations Cherish K. Johnson Chief Financial Officer FROM: Eric Rivera /RA/
Acting Assistant Inspector General for Audit
SUBJECT:
AUDIT OF THE NRCS COMPLIANCE WITH THE DIGITAL ACCOUNTABILITY AND TRANSPARENCY ACT OF 2014 (OIG-22-A-02)
The Office of the Inspector General (OIG) contracted CliftonLarsonAllen (CLA) to conduct an independent audit of the NRCs implementation of the DATA Act of 2014 (DATA Act). Attached is CLAs audit report titled Audit of the NRCs Compliance with the Digital Accountability and Transparency Act of 2014. The audit objectives were to assess (1) the completeness, accuracy, timeliness, and quality of the fiscal year (FY) 2020 quarter 3 financial and award data submitted for publication on USASpending.gov, and (2) the NRCs implementation and use of the Government-wide financial data standards established by the Office of Management and Budget and the U.S. Department of the Treasury.
The findings and conclusions presented in this report are the responsibility of CLA.
The OIGs responsibility is to provide adequate oversight of the contractors work in accordance with Generally Accepted Government Auditing Standards.
The report presents the results of the audit. Following the exit conference, agency staff indicated that they had no formal comments for inclusion in this report.
CLA found that the NRCs FY 2020, quarter 3 submission was generally complete, accurate, and timely. Although CLA noted some minor errors in record-level data linkages between Files C and D1, which were also identified by the NRC, and some accuracy errors in record-level data elements tested for completeness, accuracy, and NRC Headquarters l 11555 Rockville Pike l Rockville, Maryland 20852 l 301.415.5930
timeliness, CLA determined that the quality of the NRCs data was of excellent quality overall.
Please provide information on actions taken or planned on each of the recommendation(s) within 30 calendar days of the date of this memorandum.
Actions taken or planned are subject to OIG follow-up as stated in Management Directive 6.1. We appreciate the cooperation extended to us by members of your staff during the audit. If you have any question or comments about our report, please contact me at (301) 415-5915 or Terri Cooper, Team Leader, at (301) 415-5965.
CliftonLarsonAllen LLP CLAconnect.com Nuclear Regulatory Commission (NRC)
Performance Audit Report The NRCs Compliance under the Digital Accountability and Transparency (DATA) Act of 2014 Fiscal Year 2020, Quarter 3, DATA Act Submission Prepared by:
CliftonLarsonAllen LLP 901 North Glebe Road, Suite 200 Arlington, VA 22203 October 8, 2021
Table of Contents Independent Auditors Report 1 Abbreviations and Short References 3 I. Objectives 4 II. Background 4 III. Analysis of Results and Quality Assessment 5 III.1 NonStatistical Results 5 III.2 Statistical Results 7 III.3 Overall Determination of Quality 11 III.4 Implementation and Use of the Data Standards 11 III.5 Assessment of Internal Control 11 III.6 Recommendation 12 IV. Report Distribution 13 APPENDICES 14 APPENDIX I - NRCs MANAGEMENT COMMENT 15 APPENDIX II - NRCs RESULTS OF THE DATA ELEMENTS TEST 16 APPENDIX III - COMPARATIVE RESULTS 17 APPENDIX IV - STATUS OF FISCAL YEAR 2019 DATA ACT FINDINGS 19 APPENDIX V - SCOPE AND METHODOLOGY 20 APPENDIX VI - FEDERAL SPENDING TRANSPARENCY DATA STANDARDS 22 APPENDIX VII - DATA ACT SUBMISSION REQUIREMENTS 24 APPENDIX VIII - CIGIEs DATE ANOMALY LETTER 26 NRC 2021 Data Act Audit Report i
CliftonLarsonAllen LLP CLAconnect.com INDEPENDENT AUDITORS REPORT Inspector General United States Nuclear Regulatory Commission CliftonLarsonAllen LLP (CLA), an independent certified public accounting firm, was contracted by the United States Nuclear Regulatory Commission (NRC) Office of the Inspector General (OIG) to conduct a performance audit on the NRCs compliance under the Digital Accountability and Transparency Act (DATA Act). This report represents the results of our performance audit of the NRCs compliance under the DATA Act, the objectives of which are to assess (1) the completeness, accuracy, timeliness and quality of NRCs fiscal year (FY) 2020 quarter 3 financial and award data submitted for publication on USASpending.gov, and (2) NRCs implementation and use of the Governmentwide financial data standards established by Office of Management and Budget (OMB) and the U.S. Department of the Treasury (Treasury).
We conducted our performance audit in accordance with auditing standards generally accepted in the United States of America, as applicable to performance audits contained in the Government Auditing Standards issued by the Comptroller General of the United States. Those standards require that we plan and perform our audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.
Our audit found that NRCs FY 2020 quarter 3 submission was generally complete, accurate and timely. Although we noted some minor errors in recordlevel data linkages between Files C and D1 which were also identified by NRC and some accuracy errors in recordlevel data elements tested for completeness, accuracy, and timeliness, we determined that the quality of NRCs data was of excellent quality1 overall. We also found that NRC implemented and used the Governmentwide financial data standards established by OMB and Treasury.
We provided a discussion draft report to NRC on October 19, 2021. An exit conference was held subsequently with NRC on October 26, 2021. After reviewing the discussion draft, NRC management provided comments that have been incorporated into this report, as appropriate.
NRC management stated their agreement with the results and recommendation in this report and opted not to provide formal comments for inclusion in this report.
1 The IG Guide includes a scorecard spreadsheet that calculates the quality of the data based on the answers to questions and data input by auditors. Quality of data is categorized as low, moderate, higher, and excellent based on points range.
NRC 2021 Data Act Audit Report 1lPage
Our work did not include an assessment of the sufficiency of internal control over financial reporting or other matters not specifically outlined in the enclosed report. CLA cautions that projecting the results of our performance audit to future periods is subject to the risks that conditions may materially change from their current status. The information included in this report was obtained from NRC on or before October 8, 2021. We have no obligation to update our report or to revise the information contained herein to reflect events and transactions occurring subsequent to October 8, 2021.
The purpose of this audit report is to report on NRCs FY 2020 quarter 3 financial and award data for publication on USASpending.gov in compliance with the DATA Act, and is not suitable for any other purpose.
CliftonLarsonAllen LLP Arlington, VA October 8, 2021 NRC 2021 Data Act Audit Report 2lPage
ABBREVIATIONS AND SHORT REFERENCES ADM Office of Administration Award ID Award Identification CIGIE Council of the Inspectors General on Integrity and Efficiency CLA CliftonLarsonAllen LLP COVID19 Coronavirus Disease 2019 DAIMS DATA Act Information Model Schema DATA Act Digital Accountability and Transparency Act of 2014 DE Data Element FABS Financial Assistance Broker Submission FAEC Federal Audit Executive Council FAIMIS Financial Accounting and Integrated Management Information System FAIN Financial Assistance Identifier Number FAR Federal Acquisition Regulation FFATA Federal Funding Accountability and Transparency Act of 2006 FPDSNG Federal Procurement Data System - Next Generation FSRS FFATA Subaward Reporting System FY Fiscal Year GAO Government Accountability Office GTAS Governmentwide Treasury Account Symbol IDD Interface Definition Document IDV Indefinite Delivery Vehicles IG Inspector General NRC Nuclear Regulatory Commission OCFO Office of the Chief Financial Officer OIG Office of the Inspector General OMB Office of Management and Budget PIID Procurement Instrument Identifier Number RSS Reporting Submission Specification SAM System for Award Management SAO Senior Accountable Official STAQS Strategic Acquisition System TAS Treasury Account Symbol Treasury Department of the Treasury Working Group FAEC DATA Act Working Group NRC 2021 Data Act Audit Report 3lPage
I. OBJECTIVES The objectives of our performance audit were to assess the:
(1) completeness, accuracy, timeliness and quality of the FY 2020 quarter 3 financial and award data submitted by NRC for publication on USASpending.gov, and (2) NRCs implementation and use of the Governmentwide financial data standards established by the OMB and the Treasury.
II. BACKGROUND The DATA Act requires Federal agencies to report financial and award data in accordance with the established Governmentwide financial data standards. In May 2015, the OMB and Treasury published 57 data definition standards (commonly referred to as data elements or DEs) and required Federal agencies to report financial and award data in accordance with these standards for DATA Act reporting starting in January 2017. Subsequently, and in accordance with the DATA Act, Treasury began displaying Federal agencies data on USASpending.gov for taxpayers and policy makers in May 2017.
In April 2020, OMB issued M2021, Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease (COVID19), which made changes to DATA Act reporting. Agencies that received COVID19 supplemental relief funding must submit DATA Act files A, B, and C on a monthly basis starting with the June 2020 reporting period. These monthly submissions must also include a running total of outlays for each award in File C funded with COVID19 supplemental relief funds.
The DATA Act also requires the Inspector General (IG) of each Federal agency to audit a statistically valid sample (for noncovid obligations) and nonstatistically valid sample (for COVID outlays) of the spending data submitted by its Federal agency and to submit to Congress a publicly available report assessing the completeness, accuracy, timeliness, and quality of the datasampled, and the implementation and use of the Governmentwide financial data standards by the Federal agency.
The Council of the Inspectors General on Integrity and Efficiency (CIGIE) identified a timing anomaly with the oversight requirement contained in the DATA Act. That is, the first IG reports were due to Congress in November 2016; however, Federal agencies were not required to report spending data until May 2017. To address this reporting date anomaly, the IGs provided Congress with their first required reports by November 8, 2017, one year after the statutory due date, with two subsequent reports to be submitted following on a 2year cycle. On December 22, 2015, CIGIEs chair issued a letter detailing the strategy for dealing with the IG reporting date anomaly and communicated the strategy to the Senate Committee on Homeland Security and Governmental Affairs and the House Committee on Oversight and Government Reform. The CIGIEs date anomaly letter memorializing this strategy can be found in Appendix VIII.
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Following the results of the 2017 and 2019 audits, the CIGIE Federal Audit Executive Council (FAEC) Working Group compiled a listing of lessons learned and incorporated this feedback into the CIGIE FAEC Inspectors General Guide to Compliance under the DATA Act, referred to as the IG Guide. In consultation with the Government Accountability Office (GAO), as required by the DATA Act, the Working Group developed the IG Guide to set a baseline framework for the required reviews performed by the IG community and to foster a common methodology for performing these mandates. The IG Guide was updated for the third required report, due November 8, 2021, based on feedback from the IG community, GAO, and other stakeholders.
III. ANALYSIS OF RESULTS AND QUALITY ASSESSMENT Our audit found that NRCs FY 2020 quarter 3 submission was generally complete, accurate and timely. Although we noted some minor errors in recordlevel data linkages between Files C and D1 which were also identified by NRC, and accuracy errors in recordlevel data elements tested for completeness, accuracy, and timeliness, we determined that the quality of NRCs data was of excellent quality overall. In addition, NRC implemented and used the Governmentwide financial data standards in accordance with the standards established by OMB and Treasury.
III.1 NONSTATISTICAL RESULTS A. Timeliness of the Agency Submission We evaluated NRCs DATA Act submission to Treasury DATA Act Broker and determined that the submission was timely. We verified that NRCs Senior Accountable Official (SAO) certified its submission in the Treasury DATA Act Broker on August 14, 2020, which was the submission due date.
B. Completeness of SummaryLevel Data for Files A and B We performed reconciliation of summarylevel data and linkages for Files A and B and found NRCs submission to be complete. Completeness of the agency submission is defined as transactions and events that should have been recorded are recorded in the proper period.
To assess the completeness of File A, we verified that File A included all Treasury Account Symbols (TAS) from which funds were obligated as reflected in the Governmentwide TAS (GTAS) SF133 without error. All summarylevel data from File A matched the GTAS SF133 data elements.
To assess the completeness of File B, we compared the data in File B to the TASs listed in File A and verified that all TASs in File A are accounted for in File B without error. We verified that the totals of File A and B were equal, and all object class codes from File B match the codes defined in Section 83 of OMB Circular A11.2 2
OMB A11, Preparation, Submission, and Execution of the Budget (July 1, 2016); Section 83 of OMB A11 can be found at https://obamawhitehouse.archives.gov/sites/default/files/omb/assets/a11_current_year/s83.pdf NRC 2021 DATA Act Audit Report 5lPage
C. Suitability of File C for Sample Selection File C links to File B through the TAS, object class, and program activity data elements. We assessed this linkage by tracing these elements from File C to File B to ensure they exist in File B.
We found that File C is complete and was suitable for sampling.
D. RecordLevel Linkages for Files C and D1/D2 File C links to File D1 by the Award Identification (Award ID) Number. We assessed the linkage between the File C and File D1 to ensure that all Award ID Numbers that exist in File C, exist in File D1 and viceversa.
CLA was not able to test the linkages between File C and File D1 by matching the Procurement Instrument Identifier Numbers (PIIDs)3 and Parent Award IDs, as the formatting differs between the files. CLA materially agreed the "TransactionObligatedAmount" in File C to "FederalActionObligation" in file D1. We determined the variance would not have an adverse impact on the overall quality of the DATA Act submission as it represents an insignificant portion of the overall population. As such, we also determined that it did not have an impact on the suitability of File C for testing.
We assessed the linkage between File C and File D2 to ensure that all Award ID Numbers that exist in File C, exist in File D2 and viceversa.
E. COVID19 Outlay Testing and Results We selected a nonstatistical sample of 8 records out of 41 File C outlay records from the third month of the FY 2020 quarter 3 DATA Act submission. We utilized similar parameters to the statistical sample in order to determine an appropriate sample size, and then selected a random sample of outlays for testing. Our testing included assessing the Parent Award ID number, PIID, object class, appropriations account, obligation, program activity, outlay, and File C outlays data elements for completeness, accuracy, and timeliness. Based on our testing, we found that File C outlays for our sample of 8 records were complete, accurate, and timely. This nonstatistical sample design did not allow projection of the test results to the universe from which the sample were selected.
3 PIIDs are the Award ID for procurement awards NRC 2021 DATA Act Audit Report 6lPage
III.2 STATISTICAL RESULTS Data Element (DE) Analysis We selected a sample of 60 records from the population in File C and tested 2,744 data elements for completeness, accuracy, and timeliness. One of the 60 samples related to a grant (sample 13).
See Appendix V Scope and Methodology for description of the sampling methodology. The test results are consistent with the risks identified in the agencys data quality plan. The summary result of PIID/Financial Assistance Identifier Number (FAIN) testing is shown in Table 1:
Sample Total # # Incomplete # Inaccurate # Untimely Record # DEs 1 45 0 0.00% 0 0.00% 0 0.00%
2 45 0 0.00% 0 0.00% 0 0.00%
3 45 0 0.00% 0 0.00% 0 0.00%
4 46 0 0.00% 0 0.00% 0 0.00%
5 45 0 0.00% 0 0.00% 0 0.00%
6 47 0 0.00% 0 0.00% 0 0.00%
7 47 0 0.00% 0 0.00% 0 0.00%
8 47 0 0.00% 0 0.00% 0 0.00%
9 45 0 0.00% 0 0.00% 0 0.00%
10 44 0 0.00% 0 0.00% 0 0.00%
11 45 0 0.00% 0 0.00% 0 0.00%
12 47 0 0.00% 0 0.00% 0 0.00%
13 39 0 0.00% 0 0.00% 0 0.00%
14 47 0 0.00% 0 0.00% 0 0.00%
15 45 0 0.00% 0 0.00% 0 0.00%
16 47 0 0.00% 0 0.00% 0 0.00%
17 47 0 0.00% 0 0.00% 0 0.00%
18 45 0 0.00% 0 0.00% 0 0.00%
19 47 0 0.00% 0 0.00% 0 0.00%
20 47 0 0.00% 0 0.00% 0 0.00%
21 45 0 0.00% 0 0.00% 0 0.00%
22 47 0 0.00% 0 0.00% 0 0.00%
23 45 0 0.00% 0 0.00% 0 0.00%
24 47 0 0.00% 0 0.00% 0 0.00%
25 45 0 0.00% 0 0.00% 0 0.00%
26 44 0 0.00% 0 0.00% 0 0.00%
27 45 0 0.00% 0 0.00% 0 0.00%
28 45 0 0.00% 0 0.00% 0 0.00%
29 46 0 0.00% 2 4.35% 0 0.00%
30 46 0 0.00% 0 0.00% 0 0.00%
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Sample Total # # Incomplete # Inaccurate # Untimely Record # DEs 31 47 0 0.00% 0 0.00% 0 0.00%
32 45 0 0.00% 0 0.00% 0 0.00%
33 45 0 0.00% 0 0.00% 0 0.00%
34 47 0 0.00% 1 2.13% 0 0.00%
35 47 0 0.00% 0 0.00% 0 0.00%
36 47 0 0.00% 0 0.00% 0 0.00%
37 46 0 0.00% 2 4.35% 0 0.00%
38 47 0 0.00% 0 0.00% 0 0.00%
39 47 0 0.00% 2 4.26% 0 0.00%
40 47 0 0.00% 0 0.00% 0 0.00%
41 45 0 0.00% 0 0.00% 0 0.00%
42 45 0 0.00% 0 0.00% 0 0.00%
43 47 0 0.00% 0 0.00% 0 0.00%
44 47 0 0.00% 1 2.13% 0 0.00%
45 47 0 0.00% 0 0.00% 0 0.00%
46 45 0 0.00% 0 0.00% 0 0.00%
47 44 0 0.00% 0 0.00% 0 0.00%
48 47 0 0.00% 1 2.13% 0 0.00%
49 45 0 0.00% 0 0.00% 0 0.00%
50 45 0 0.00% 1 2.22% 0 0.00%
51 45 0 0.00% 0 0.00% 0 0.00%
52 44 0 0.00% 0 0.00% 0 0.00%
53 45 0 0.00% 0 0.00% 0 0.00%
54 45 0 0.00% 0 0.00% 0 0.00%
55 45 0 0.00% 0 0.00% 0 0.00%
56 45 0 0.00% 0 0.00% 0 0.00%
57 47 0 0.00% 0 0.00% 0 0.00%
58 45 0 0.00% 0 0.00% 0 0.00%
59 47 0 0.00% 0 0.00% 0 0.00%
60 47 0 0.00% 1 2.13% 0 0.00%
Total DEs 2,744 Tested Total Errors 0 11 0 Error Rate 0.0% 0.4% 0.0%
Table 1: Summary Results of PIID/FAIN Testing for Completeness, Accuracy, Timeliness See Appendix II for the NRCs Results of the Data Element Test.
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Completeness - Actual Error Rate The actual overall error rate for the completeness of the data elements tested is 0.0%. A data element was considered complete if the required data element that should have been reported was reported.
Accuracy - Actual Error Rate The actual overall error rate for the accuracy of the data elements tested is 0.4%4. A data element was considered accurate when amounts and other data relating to recorded transactions were recorded in accordance with the DATA Act Information Model Schema (DAIMS), Reporting Submission Specification (RSS), Interface Definition Document (IDD), and the online data dictionary, and agree with the originating award documentation/contract file. See Description of Errors below for description of root cause of the error.
Timeliness - Actual Error Rate The actual overall error rate for the timeliness of the data elements tested is 0.0%. The timeliness of data elements was based on the reporting schedules defined by the financial, procurement, and financial assistance requirements (Federal Funding Accountability and Transparency Act (FFATA), Federal Acquisition Regulation (FAR), Federal Procurement DATA System Next Generation (FPDSNG), Financial Assistance Broker Submission (FABS), and DAIMS).
Descriptions of Errors The following errors were identified during the test of the detailed recordlevel data elements.
Error 1: For three (3) records, the NAICS code per File D1 did not agree to the NAICS code per the STAQS procurement system.
Per NRCs Analysis of the exceptions, the NAICS codes per Strategic Acquisition System (STAQS) is correct. The NAICS code in File D1 is being populated from the master (IDV) award. Since these task orders are created from an IDV award, FPDSNG references the code from the master contract. The NAICS code cannot be changed on the task order under the IDV. IDV contracts are large contracts that include large scopes of work that can cover several NAICS codes. The NAICS code selected covers the majority of the work in the IDV, and a task order may have a different one. This is a known issue with FPDSNG.
Error 2: For four (4) records, the Period of Performance Start Date per File D1 did not agree to the Period of Performance Start Date per STAQS.
Per NRCs Analysis of the exceptions related to samples 34, 44, and 48, STAQS is sending over the STAQS System Award Date to FPDSNG because the Effective Date was not completed. This is an NRC oversight and will be addressed by NRC via continuous training.
4 Based on a 95% (exact) confidence level, the confidence interval is between 0.17%0.79%.
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Per NRCs Analysis of the exception related to sample 60, there was a typo made when NRC personnel entered the summary level period of performance start date information in STAQS.
This is an NRC error which NRC will correct.
Error 3: For one (1) record, the Period of Performance Current End Date per File D1 did not agree to the Period of Performance Current End Date per STAQS.
Per NRCs Analysis of the exception related to sample 50, the STAQS date is correct; however, there appears to be a typo in the Override Date section in STAQS, which was transmitted to FPDS NG for the Current End Date appearing in D1. The End Date per D1 should be 2021 not 2020. This was an NRC error which NRC will correct.
Analysis of the Accuracy of the Dollar ValueRelated Data Elements We did not find errors in our analysis of the accuracy of the dollar valuerelated data elements.
Analysis of Errors in Data Elements Not Attributable to NRC Table 2 shows errors that were caused by an entity other than NRC. See Error 1 above.
PIID/FAIN DATA Element Attributed To PIID DE NAICS Code FPDSNG extracting from master contract instead of 17 individual task order PIID DE NAIC Description FPDSNG extracting from master contract instead of 18 individual task order Table 2: Analysis of Errors in Data Elements Not Attributable to NRC NRC explained the NAICS codes per the STAQS procurement system is correct. The NAICS code in File D1 is being populated from the master (IDV) award by FPDSNG rather than the task order.
See explanation in Error 1.
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III.3 OVERALL DETERMINATION OF QUALITY Based on the results of our statistical and nonstatistical testing, NRC scored 99.88 points, which is a quality rating of excellent5. The quality of the data elements was determined using the midpoint of the range of the proportion of errors (error rate) for completeness, accuracy and timeliness. The highest of the three error rates was used as the determining factor of quality.
Table 3 provides the range in determining the quality of the data elements.
Quality Level Range Level 0 69.999 Lower 70 84.999 Moderate 85 94.999 Higher 95 100 Excellent Table 3: Range of Quality Level6 III.4 IMPLEMENTATION AND USE OF THE DATA STANDARDS We have evaluated and determined that NRC fully implemented and use the governmentwide financial standards for spending information as developed by OMB and Treasury. This is evidenced through NRCs use of common identifiers to link all of the data elements in their procurement, financial, and grants systems.
III.5 ASSESSMENT OF INTERNAL CONTROLS Assessment of Internal Control over Source Systems The NRC uses the STAQS and the Financial Accounting and Integrated Management Information System (FAIMIS) for processing and recording its procurement and financial award activities. The STAQS is a procurement system that supports NRCs purchase requisition and contract award processes. FAIMIS is the financial system used to record the accounting transactions related to the contract award and contract modification activities. Transactions entered through STAQS interface realtime with FAIMIS. Collectively, these systems are the sources of information used to report the FY 2020 quarter 3 financial data as required by the DATA Act.
In performing NRCs FY 2020 financial statements audit, CLA assessed the internal controls over the STAQS and FAIMIS and determined that the controls were properly designed, implemented, and operating effectively. We relied on this assessment of internal controls over source systems for the DATA Act.
5 A scorecard spreadsheet is included in the IG Guide which is used to calculate the quality of the data based on the answers to questions and data input by auditors.
6 Source of table 3 and quality rating determinations is the IG Guide, Section 820, Quality Assessment Scorecard NRC 2021 DATA Act Audit Report 11 l P a g e
Assessment of Internal Control over the Data Management and Processes (DATA Act Submission)
Through review of NRCs DATA Act process narratives, review of NRCs DATA Act Desk Guide and discussions with management, CLA obtained an understanding of NRCs processes for reconciling data variances, identifying root causes of errors, and certifying the data submitted to the DATA Act broker.
CLA obtained readonly access to the Treasurys DATA Act Broker submission portal for purposes of reviewing NRCs Files AF for FY 2020 quarter 3 DATA Act submission. Additionally, NRC provided their final Broker warnings and Final DATA Act reconciliation for the same period. We reviewed NRCs final Broker warnings files and the reconciliations they performed to evaluate NRCs performance of internal control over the data quality, accuracy, timeliness and completeness prior to the final data certification.
We assessed internal controls and compliance with laws and regulations necessary to satisfy the audit objective. In particular, we assessed whether NRC has sufficient controls in place to ensure that the FY 2020 quarter 3 DATA Act submission was complete, accurate and timely in accordance with applicable OMB and Treasury guidance.
Our review was limited to these internal controls relevant to our performance objectives and will not disclosed all internal control deficiencies that may have existed at the time of this audit.
III.6 RECOMMENDATION
- 1. NRC should improve controls around information in STAQS to ensure data in file D1 included in USAspending.gov is accurate. The control should ensure contract information agrees to STAQS summary information submitted to FPDSNG.
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IV. REPORT DISTRIBUTION NRC Distribution Executive Director for Operations Office of the Chief Financial Officer Office of the General Counsel NonNRC Distribution United States Senate Committee on Homeland Security and Governmental Affairs The Honorable Gary C. Peters, Chairman The Honorable Robert J. Portman, Ranking Member United States House Committee on Oversight and Reform The Honorable Carolyn B. Maloney, Chairwoman The Honorable, James R. Comer, Ranking Member United States Senate Committee on the Budget The Honorable Bernard Sanders, Chairman The Honorable Lindsey O. Graham, Ranking Member United States House Committee on the Budget The Honorable John A. Yarmuth, Chairman The Honorable Jason T. Smith, Ranking Member United States Senate Committee on Finance The Honorable Ronald Lee Wyden, Chairman The Honorable Michael D. Crapo, Ranking Member United States House Committee on Financial Services The Honorable Maxine Waters, Chairman The Honorable Patrick T. McHenry, Ranking Member GAO Report electronically submitted to DATAActImplementation@gao.gov Treasury OIG Report electronically submitted to DATAAct@oig.treas.gov NRC 2021 DATA Act Audit Report 13 l P a g e
APPENDICES NRC 2021 DATA Act Audit Report 14 l P a g e
APPENDIX I - NRCs MANAGEMENT COMMENT We provided a discussion draft report to NRC on October 19, 2021. An exit conference was held subsequently with NRC on October 26, 2021. After reviewing the discussion draft, NRC management provided comments that have been incorporated into this report, as appropriate.
NRC management stated their agreement with the results and recommendation in this report and opted not to provide formal comments for inclusion in this report.
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APPENDIX II - NRCs RESULTS OF THE DATA ELEMENTS TEST NRC results of the data elements test listed in descending order by accuracy error rate percentage.
Error Rate File Data Element Number Data Element Name A C T D1 DE 26 Period of Performance Start Date 7% 0% 0%
D1 DE 17 NAICS Code 5% 0% 0%
D1 DE 18 NAICS Description 5% 0% 0%
D1 DE 27 Period of Performance Current End Date 2% 0% 0%
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APPENDIX III - COMPARATIVE RESULTS Error Error Rate Rate File Data Element Data Element Name 2021 2019 %
Number Change D1 DE 26 Period of Performance Start Date 2% 28% 26%
D1 DE 5 Legal Entity Address 0% 17% 17%
D1 DE 4 Ultimate Parent Legal Entity Name 0% 15% 15%
D1 DE 17 NAICS Code 2% 17% 15%
D1 DE 18 NAICS Description 2% 15% 13%
D1 DE 6 Legal Entity Congressional District 0% 5% 5%
D1 DE 3 Ultimate Parent Unique Identifier 0% 4% 4%
D1 DE 1 Awardee/Recipient Legal Entity Name 0% 4% 4%
D1 DE 2 Awardee/Recipient Unique Identifier 0% 4% 4%
D1 DE 24 Parent Award ID Number 0% 4% 4%
D1 DE 30 Primary Place of Performance 0% 3% 3%
Address D1 DE 31 Primary Place of Performance 0% 3% 3%
Congressional District D1 DE 14 Current Total Value of Award 0% 3% 3%
D1 DE 15 Potential Total Value of Award 0% 3% 3%
D1 DE 11 Federal Action Obligation 0% 3% 3%
D1 DE 16 Award Type 0% 3% 3%
D1 DE 22 Award Description 0% 3% 3%
D1 DE 23 Award Modification / Amendment 0% 3% 3%
Number D1 DE 25 Action Date 0% 3% 3%
D1 DE 28 Period of Performance Potential End 0% 3% 3%
Date D1 DE 29 Ordering Period End Date 0% 3% 3%
D1 DE 32 Primary Place of Performance 0% 3% 3%
Country Code D1 DE 33 Primary Place of Performance 0% 3% 3%
Country Name D1 DE 34 Award ID Number 0% 3% 3%
D1 DE 36 Action Type 0% 3% 3%
D1 DE 38 Funding Agency Name 0% 3% 3%
D1 DE 39 Funding Agency Code 0% 3% 3%
D1 DE 40 Funding Sub Tier Agency Name 0% 3% 3%
D1 DE 41 Funding Sub Tier Agency Code 0% 3% 3%
D1 DE 42 Funding Office Name 0% 3% 3%
D1 DE 43 Funding Office Code 0% 3% 3%
D1 DE 44 Awarding Agency Name 0% 3% 3%
D1 DE 45 Awarding Agency Code 0% 3% 3%
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Error Error Rate Rate File Data Element Data Element Name 2021 2019 %
Number Change D1 DE 46 Awarding Sub Tier Agency Name 0% 3% 3%
D1 DE 47 Awarding Sub Tier Agency Code 0% 3% 3%
D1 DE 48 Awarding Office Name 0% 3% 3%
D1 DE 49 Awarding Office Code 0% 3% 3%
D1 DE 7 Legal Entity Country Code 0% 3% 3%
D1 DE 8 Legal Entity Country Name 0% 3% 3%
D1 DE 27 Period of Performance Current End 1% 3% 2%
Date C DE 53 Obligation 0% 1% 1%
C DE 24 Parent Award ID Number 0% 0% 0%
D1 DE 163 National Interest Action 0% 0% 0%
C DE 430 Disaster Emergency Code 0% 0% 0%
C DE 34 Award ID Number (PIID) 0% 0% 0%
C DE 50 Object Class 0% 0% 0%
C DE 51 Appropriations Account 0% 0% 0%
C DE 56 Program Activity 0% 0% 0%
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APPENDIX IV - STATUS OF FISCAL YEAR 2019 DATA ACT FINDINGS We reviewed FY 2019 recommendations to evaluate NRCs implementation of the corrective actions. NRC has implemented the recommendations made in FY 2019 Data Act report; however, as shown in the errors we noted in the 2021 testing, additional corrective actions are still needed.
Status of FY 2019 Finding Corrective Action Finding The Office of Administration (ADM) worked
- 1. We recommend that NRC enhance its with the Office of the Chief Financial Officer internal control and detective (OCFO) to enhance internal controls and procedures surrounding DATA Act detective procedures surrounding DATA Act submissions. Procedures should include submissions. Procedures included reviewing all reviewing all records in File C and records in File C and verifying they have verifying that they have corresponding corresponding transaction in Files D1 and D2. Closed transactions in Files D1 and D2. NRC considered increasing the size of samples Additionally, NRC should consider selected for record level testing between Files increasing the size of samples selected C, D1, and D2. In 2021, CLA noted for record level testing between Files C, improvements in NRCs DATA Act controls and D1, and D2. DATA act submission accuracy, timeliness, and completeness.
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APPENDIX V - SCOPE AND METHODOLOGY Scope The scope of this performance audit is NRCs FY 2020 Quarter 3 financial and award data submitted to the DATA Act Broker system.
File E of the DAIMS contains additional awardee attribute information the Treasury DATA Act Broker software extracts from the System of Award Management (SAM). File F contains sub award attribute information the Broker software extracts from the FFATA Subaward Reporting System (FSRS). Files E and F data remain the responsibility of the awardee in accordance with the terms and conditions of the Federal agreements, and the quality of these data remains the legal responsibility of the recipient. Therefore, agency SAOs are not responsible for certifying the quality of File E and F data reported by awardees, but they are responsible for assuring controls are in place to verify that financial assistance awardees register in SAM at the time of the award.
As such, we did not assess the completeness, timeliness, quality, and accuracy of the data extracted from SAM and FSRS via the Treasury broker software system.
Methodology Our audit methodology is prescribed in the CIGIE FAEC Inspectors General Guide to Compliance under the DATA Act (IG Guide) dated December 4, 2020. We performed our audit in accordance with the Government Audit Standards. A general summary of audit procedures consistent with the IG Guide include:
- Obtaining an understanding of any regulatory criteria related to NRCs responsibilities to report financial and award data under the DATA Act;
- Reviewing NRCs data quality plan;
- Assessing the internal and information system controls in place as they relate to the extraction of data from the source systems and the reporting of data to Treasurys DATA Act Broker, in order to assess audit risk and design audit procedures;
- Reviewing and reconciling the FY 2020 quarter 3 summarylevel data submitted by the agency for publication on USASpending.gov;
- Reviewing a statically valid sample the records from FY 2020, quarter 3 financial and award data submitted by the agency for publication on USASpending.gov;
- Assessing the completeness, accuracy, timeliness, and quality of the financial and award data sampled;
- Assessing NRCs implementation and use of the 59 data elements/standards established by OMB and Treasury; and
- Obtaining the SAO certification to determine whether the quarterly assurance on NRCs controls supporting the reliability and validity of the agencys summarylevel and award level data reported for publication on USAspending.gov is supported.
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Sampling Methodology Our sampling methodology was based on the guidance in Appendix 5, Technical Statistical Sampling Technique, of the IG Guide. The IG Guide (Section 720) indicated that the estimated percentage of error rate in the population to be sampled will be determined based on the results of the November 2019 and subsequent testing of the DATA Act information, and additional information that the IG has accumulated related to the agencys internal controls and corrective actions from previous audits. If all error rates are less than 20%, then a 20% expected error rate should be used. CLA used the expected error rate of 20% based on the results of November 2019 DATA Act audit report. We statistically selected 60 records reported in File C out of 625 records using the following parameters to calculate our randomly selected sample size:
- Population size of 625 records
- Confidence level of 95%
- Expected error rate of 20%
- Sample precision of 5%
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APPENDIX VI - FEDERAL SPENDING TRANSPARENCY DATA STANDARDS (59 standards)
Number7 Data Element Data Standards89 1 Appropriations Account Account Level 2 Budget Authority Appropriated Account Level 3 Object Class Account Level 4 Obligation Account Level 5 Other Budgetary Resources Account Level 6 Outlay Account Level 7 Program Activity Account Level 8 Treasury Account Symbol (excluding subaccount) Account Level 9 Unobligated Balance Account Level 10 Action Date Award Characteristic 11 Action Type Award Characteristic 12 Award Description Award Characteristic 13 Award Identification (ID) Number Award Characteristic 14 Award Modification/Amendment Number Award Characteristic 15 Award Type Award Characteristic 16* Business Types Award Characteristic 17 CFDA Number Award Characteristic 18 CFDA Title Award Characteristic 19 NAICs Code Award Characteristic 20 NAICS Description Award Characteristic 21 Ordering Period End Date Award Characteristic 22 Parent Award Identification (ID) Number Award Characteristic 23 Period of Performance Current End Date Award Characteristic 24 Period of Performance Potential End Date Award Characteristic 25 Period of Performance Start Date Award Characteristic 26 Primary Place of Performance Address Award Characteristic Primary Place of Performance Congressional 27 District Award Characteristic 28 Primary Place of Performance Country Code Award Characteristic 29 Primary Place of Performance Country Name Award Characteristic 30 Record Type Award Characteristic 7
This is a sequential numbering and does not correspond to the data element number in test results. This information is presented to show the data standards by group.
8 Source: https://fedspendingtransparency.github.io/dataelements/. All federal agencies are required to report financial and award data for these 59 data elements in accordance with the published data standards.
9 The National Interest Action and Disaster Emergency Fund Code were required as part of the DATA Act submissions for FY21; however, they are not included as part of the Federal Spending Transparency Data Standards NRC 2021 DATA Act Audit Report 22 l P a g e
Number7 Data Element Data Standards89 31 Amount of Award Award Amount 32 Current Total Value of Award Award Amount 33 Federal Action Obligation Award Amount 34 NonFederal Funding Amount Award Amount 35 Potential Total Value of Award Award Amount Awardee and 36 Awardee/Recipient Legal Entity Name Recipient Awardee and 37 Awardee/Recipient Unique Identifier Recipient Awardee and 38 Highly Compensated Officer Name Recipient Awardee and 39 Highly Compensated officer Total Compensation Recipient Awardee and 40 Legal Entity Address Recipient Awardee and 41 Legal Entity Congressional District Recipient Awardee and 42 Legal Entity Country Code Recipient Awardee and 43 Legal Entity Country Name Recipient Awardee and 44 Ultimate Parent Legal Entity Name Recipient Awardee and 45 Ultimate Parent Unique Identifier Recipient 46 Awarding Agency Code Awarding Entity 47 Awarding Agency Name Awarding Entity 48 Awarding Office Code Awarding Entity 49 Awarding Office Name Awarding Entity 50 Awarding Sub Tier Agency Code Awarding Entity 51 Awarding Sub Tier Agency Name Awarding Entity 52 Funding Agency Code Funding Entity 53 Funding Agency Name Funding Entity 54 Funding Office Code Funding Entity 55 Funding Office Name Funding Entity 56 Funding Sub Tier Agency Code Funding Entity 57 Funding Sub Tier Agency Name Funding Entity 163 National Interest Action NA 430 Disaster Emergency Fund Code NA NRC 2021 DATA Act Audit Report 23 l P a g e
APPENDIX VII - DATA ACT SUBMISSION REQUIREMENTS Data Standards, Schema, and Submission The DATA Act requires Treasury and OMB to:
- Establish Governmentwide financial data standards for any Federal funds made available to or expended by Federal agencies and entities receiving Federal funds
- Include common data elements for financial and payment information to be reported The DATA Act Information Model Schema V.2.0 (DAIMS, Schema), dated May 6, 2020, guides agencies in the production and submission of the required data. Appendix VI lists the 59 data standards. Federal agencies are required to submit their financial data to Treasury using the DATA Act Broker10 (broker) software. The broker also pulls procurement and financial assistance award and subaward information from governmentwide systems, as agencies are already required to submit such data. Those systems are:
- Federal Procurement Data System Next Generation (FPDSNG) - Repository for Federal procurement award data operated by the General Services Administration
- Financial Assistance Broker Submission (FABS) - Repository for financial assistance transactions on awards of more than $25,000 operated by Treasury
- Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) - Reporting tool prime awardees use to capture and report subaward and executive compensation data operated by the General Services Administration
- Federal Acquisition Regulations (FAR) - Primary regulation for use by all Federal Executive agencies in their acquisition of supplies and services with appropriated funds.
- System for Award Management (SAM) - System that collects registration information from entities doing business with the Federal government.
Reporting Submission Specification (RSS) and the Interface Definition Document (IDD)
The DATA Act schema includes two documents that contain specifications for reporting required data the RSS and the IDD.
This includes appropriations account, object class, program activity, and award financial data.
Federal agencies must generate and submit three files to the broker:
- File A - Appropriations Account Detail - Contains appropriation summary level data that are aligned with OMB Standard Form 133, Report on Budget Execution and Budgetary Resources (SF133) reporting.
- File B - Object Class and Program Activity Detail - Includes obligation and outlay information at the program activity and object class level.
10 The broker is a virtual data layer developed by the U.S. Department of Treasury that maps, ingests, transforms, validates, and submits agency data into a format consistent with the DATA Act Schema (i.e., data exchange standards).
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- File C - Award Financial Detail - Reports the obligation and outlay information at the award level.
The IDD provides detail on data that will be extracted by the broker from other governmentwide systems pertaining to procurement and financial assistance data, recipient attributes, and sub award information. The following four files are generated by this process:
- File D1 - Award and Awardee Attributes for Procurement (from FPDSNG) - Award and awardee details are to be linked to File C
- File D2 - Award and Awardee Attributes for Financial Assistance (i.e., direct loans, loan guarantees, grants, etc.) (from Financial Assistance Broker Submission) - Award and awardee details are to be linked to File C
- File E - Additional Awardee Attributes (from SAM) - Includes additional prime awardee attributes
- File F - Subaward Attributes (from Federal Funding Accountability and Transparency Act Subaward Reporting System) - Includes subaward information CIGIE FAEC Inspectors General Guide to Compliance under the DATA Act (IG GUIDE)
The IG Guide requires auditors to perform procedures in the following areas:
- Internal and information system control over agency source systems - Auditors are to determine the extent to which agency systems can be relied on as authoritative sources for the information reported in accordance with the DATA Act.
- Internal control over DATA Act submission - Auditors are to assess the effectiveness of the internal controls implemented to reasonably assure that the data submitted are complete, accurate, timely, and of quality.
- Detail testing of data submitted to the broker: Auditors are to select a quarter within the prescribed range and test an agencys submission, which is used to populate USASpending.gov.
o Summary level financial data -test summary level data for Files A and B.
o Record level linkages - test whether recordlevel linkages for Files C and D.
o Record level data elements -test a statistically valid sample at the record data element level to determine the completeness, accuracy, timeliness, and overall quality of the data submitted.
o COVID19 outlays - for those agencies that received COVID19 funds, test a nonstatistical sample at the record data element level to determine the completeness, accuracy, timeliness, and overall quality of the data submitted.
- Implementation and use of the data standards - review the agencys data inventory/mapping for Files A, B, C, D1 and D2 to ensure that the standardized data elements and OMB and Treasury definitions per the DAIMS are used across agency processes, systems, and applications.
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APPENDIX VIII - CIGIEs DATE ANOMALY LETTER NRC 2021 DATA Act Audit Report 26 l P a g e
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