ML21312A020

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DNFSB-22-A-02-Audit of the Dnfsb'S Compliance Under the Digital Accountability and Transparency Act of 2014 Dated November 5th, 2021
ML21312A020
Person / Time
Issue date: 11/05/2021
From: Rivera E
NRC/OIG/AIGA
To: Spangenberg J
NRC/EDO
References
DNFSB-22-A-02
Download: ML21312A020 (34)
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November 5, 2021 MEMORANDUM TO: Joel C. Spangenberg Executive Director of Operations FROM: Eric Rivera /RA/

Acting Assistant Inspector General for Audit

SUBJECT:

AUDIT OF THE DNFSBS COMPLIANCE UNDER THE DIGITAL ACCOUNTABILITY AND TRANSPARENCY ACT OF 2014(DATA ACT) (DNFSB-22-A-02)

The Office of the Inspector General (OIG) contracted CliftonLarsonAllen (CLA) to conduct an audit of the DNFSBs Implementation of DATA Act of 2014. Attached is CLAs audit report titled Audit the DNFSBs Compliance Under the Digital Accountability and Transparency (DATA) Act of 2014. The objectives of this audit were to assess (1) the completeness, accuracy, timeliness, and quality of the DNFSBs fiscal year (FY) 2020 quarter 4 financial and award data submitted for publication on USASpending.gov, and (2) the DNFSBs implementation and use of the Government-wide financial data standards established by the Office of Management and Budget (OMB), 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 formal comments for inclusion in this report. Appendix 1 of this report contains the DNFSBs formal comments, and CLAs response to those comments.

CLA found that the DNFSBs FY 2020 quarter 4 submission was not timely, complete, or accurate. CLA determined that the quality of the DNFSBs data was of lower quality overall. Additionally, CLA found that the DNFSB, for the quarter reviewed, was not in compliance with Government-wide financial data standards established by the OMB and the Department of Treasury.

Please provide information on actions taken or planned on each of the recommendation(s) within 30 calendar days of the date of this memorandum. 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 Defense Nuclear Facilities Safety Board (DNFSB)

Performance Audit Report The DNFSBs Compliance under the Digital Accountability and Transparency (DATA) Act of 2014 Fiscal Year 2020, Quarter 4, DATA Act Submission Prepared by:

CliftonLarsonAllen LLP 901 North Glebe Road, Suite 200 Arlington, VA 22203 October 14, 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 9 III.4 Implementation and Use of the Data Standards 9 III.5 Assessment of Internal Control 10 III.6 Recommendations 11 IV. Report Distribution 12 APPENDICES 13 APPENDIX I - DNFSBs MANAGEMENT COMMENT AND CLAs RESPONSE 14 APPENDIX II - DNFSBs RESULTS OF THE DATA ELEMENTS TEST 18 APPENDIX III - COMPARATIVE RESULTS 20 APPENDIX IV - STATUS OF FISCAL YEAR 2019 DATA ACT RECOMMENDATIONS 22 APPENDIX V - SCOPE AND METHODOLOGY 23 APPENDIX VI - FEDERAL SPENDING TRANSPARENCY DATA STANDARDS 25 APPENDIX VII - DATA ACT SUBMISSION REQUIREMENTS 27 APPENDIX VIII - CIGIEs DATE ANOMALY LETTER 29 DNFSB 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 (U.S.) Nuclear Regulatory Commission Office of the Inspector General (OIG) to conduct a performance audit on the Defense Nuclear Facilities Safety Boards (DNFSB) compliance under the Digital Accountability and Transparency Act (DATA Act). This report represents the results of our performance audit of the DNFSBs compliance under the DATA Act, the objectives of which are to assess (1) the completeness, accuracy, timeliness and quality of DNFSBs fiscal year (FY) 2020 quarter 4 financial and award data submitted for publication on USASpending.gov, and (2) DNFSBs 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 DNFSBs FY 2020 quarter 4 submission was not timely, complete, or accurate. We determined that the quality of DNFSBs data was of lower quality1 overall. We also found that DNFSB was not in compliance with Governmentwide financial data standards established by OMB and Treasury. DNFSBs FY 2020 quarter 4 DATA Act File D1, Award and Awardee Attributes for Procurement, was incorrectly blank.

We provided a discussion draft report to DNFSB on October 21, 2021. An exit conference was held subsequently with DNFSB on October 28, 2021. After reviewing the discussion draft, DNFSB management provided comments that have been incorporated into this report, as appropriate.

DNFSB management stated their agreement with the results and recommendations in this report and provided formal comments for inclusion in this report. Additional comments or explanations provided by DNFSB that were included in our audit report were not subjected to our audit procedures, and therefore, we do not provide conclusion on their responses. See Appendix 1, DNFSBs Management Comment. 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 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 lower, moderate, higher, and excellent based on points range. The scorecard is formatted to calculate quality based on weighted scores of both statistical testing and nonstatistical testing results.

For the quality scorecard, statistical testing results are valued at 60 points and nonstatistical testing results are valued at 40 points, for a total of 100 points.

CLA is an independent member of Nexia International, a leading, global network of independent accounting and consulting firms. See nexia.com/memberfirmdisclaimer for details.

DNFSB 2021 Data Act Audit Report 1lPage

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 DNFSB on or before October 14, 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 14, 2021.

The purpose of this audit report is to report on DNFSBs FY 2020 quarter 4 financial and award data for publication on USASpending.gov compliance with the DATA Act and is not suitable for any other purpose.

CliftonLarsonAllen LLP Arlington, VA October 14, 2021 DNFSB 2021 Data Act Audit Report 2lPage

ABBREVIATIONS AND SHORT REFERENCES 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 DNFSB Defense Nuclear Facilities Safety Board FABS Financial Assistance Broker Submission FAEC Federal Audit Executive Council 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 FSSP Federal Shared Service Provider FY Fiscal Year GAO Government Accountability Office GTAS Governmentwide Treasury Account Symbol IDD Interface Definition Document IG Inspector General OIG Office of the Inspector General OMB Office of Management and Budget PFS Pegasys Financial Group PIID Procurement Instrument Identifier Number RSS Reporting Submission Specification SAM System for Award Management SAO Senior Accountable Official SOC Service Organization Controls TAS Treasury Account Symbol Treasury Department of the Treasury U.S. United States USDA U.S. Department of Agriculture Working Group FAEC DATA Act Working Group DNFSB 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 4 financial and award data submitted by DNFSB for publication on USASpending.gov, and (2) DNFSBs 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. DNFSB did not receive COVID19 funding. Therefore, COVID19 outlay testing was not applicable.

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.

DNFSB 2021 DATA Act Audit Report 4lPage

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.

DNFSB contracts through an interagency agreement with the U.S. Department of Agriculture (USDA), Pegasys Financial Group (PFS), a federal shared service provider (FSSP), for its financial management services. Those services consist of financial management systems services, financial management reporting and accounting support, optional financial management services, budgeting and analysis support, travel system operations services, and other service. Included in the FSSPs scope of services is DATA Act preparation support. Although the FSSP performs specific DATA Act financial reporting duties, DNFSB is primarily responsible to ensure that the integrity and quality of the data reported is complete, accurate and timely.

III. ANALYSIS OF RESULTS AND QUALITY ASSESSMENT Our audit found that DNFSBs FY 2020 quarter 4 submission was not timely, complete, or accurate. We determined that the quality of DNFSBs data was of lower quality2 overall. In addition, DNFSB was not in compliance with Governmentwide financial data standards established by OMB and Treasury. DNFSBs FY 2020 quarter 4 DATA Act File D1 was incorrectly blank.

III.1 NONSTATISTICAL RESULTS A. Timeliness of the Agency Submission We evaluated DNFSBs DATA Act submission to Treasury DATA Act Broker and determined that the submission was not timely. We verified that DNFSBs Senior Accountable Official (SAO) certified its submission in the Treasury DATA Act Broker on May 17, 2021, which was six months after the November 16, 2020 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. We found the total dollar amounts in File A and B were not equal. CLA identified a difference between obligations of $4 million, gross outlays of $4.4 million and deobligations of $400 thousand.

2 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 lower, moderate, higher, and excellent based on points range. The scorecard is formatted to calculate quality based on weighted scores of both statistical sampling and nonstatistical testing results.

For the quality scorecard, statistical testing results are valued at 60 points and nonstatistical testing results are valued at 40 points, for a total of 100 points. Testing of File C and D1 data elements, linkages between File C and D1 and other evaluation criteria were reflected in the DNFSB FY 2020 quarter 3 scorecard. Since File D1 was blank all data elements related to File D1 testing were considered exceptions.

DNFSB 2021 DATA Act Audit Report 5lPage

Completeness of the agency submission is defined as transactions and events that should have been recorded are recorded in the proper period.

Per DNFSB, due to high staff turnover and limited staff, reconciling items between File A and B were not research and resolved on a timely basis 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.

All summarylevel data from File A matched the GTAS SF133 data elements within an immaterial difference.

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 found that the total dollar amounts in File A and B were not equal as described above. We noted all object class codes from File B match the codes defined in Section 83 of OMB Circular A11.3 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 was complete and was suitable for sampling.

D. RecordLevel Linkages for Files C and D1/D2 We assessed the linkage between File C and File D1 to ensure that all Award Identification (Award ID) Numbers that exist in File C, exist in File D1 and viceversa. We found there was no data in file D1. Per DNFSB, File D1 was incorrectly blank due to DNFSB not having an account login to submit data to populate File D1. Additionally, DNFSB did not have a process in place at the time to ensure contracts awarded and input into FPDSNG had the correct Procurement Instrument Identifier Number (PIID). Since the beginning of FY 2021, DNFSB has been coordinating to establish a process.

DNFSB did not have financial assistance awards and therefore, there were no Award IDs in File D2.

E. COVID19 Outlay Testing and Results Not Applicable to DNFSB DNFSB did not receive COVID19 funding. Therefore, COVID19 outlay testing was not applicable.

3 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 DNFSB 2021 DATA Act Audit Report 6lPage

III.2 STATISTICAL RESULTS Data Element (DE) Analysis We selected a sample of 33 records from the population in File C and tested 1,551 data elements for completeness, accuracy, and timeliness. DNFSB did not have financial assistance awards. 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 testing is shown in Table 1:

Sample Total # # Incomplete # Inaccurate # Untimely Record # DEs 1 47 41 87.23% 41 87.23% 47 100.00%

2 47 41 87.23% 41 87.23% 47 100.00%

3 47 41 87.23% 41 87.23% 47 100.00%

4 47 41 87.23% 41 87.23% 47 100.00%

5 47 41 87.23% 41 87.23% 47 100.00%

6 47 41 87.23% 41 87.23% 47 100.00%

7 47 41 87.23% 41 87.23% 47 100.00%

8 47 41 87.23% 41 87.23% 47 100.00%

9 47 41 87.23% 41 87.23% 47 100.00%

10 47 42 89.36% 42 89.36% 47 100.00%

11 47 41 87.23% 41 87.23% 47 100.00%

12 47 41 87.23% 41 87.23% 47 100.00%

13 47 41 87.23% 41 87.23% 47 100.00%

14 47 41 87.23% 41 87.23% 47 100.00%

15 47 41 87.23% 41 87.23% 47 100.00%

16 47 41 87.23% 41 87.23% 47 100.00%

17 47 41 87.23% 41 87.23% 47 100.00%

18 47 41 87.23% 41 87.23% 47 100.00%

19 47 41 87.23% 41 87.23% 47 100.00%

20 47 41 87.23% 41 87.23% 47 100.00%

21 47 41 87.23% 41 87.23% 47 100.00%

22 47 41 87.23% 41 87.23% 47 100.00%

23 47 41 87.23% 41 87.23% 47 100.00%

24 47 41 87.23% 41 87.23% 47 100.00%

25 47 41 87.23% 41 87.23% 47 100.00%

26 47 41 87.23% 41 87.23% 47 100.00%

27 47 41 87.23% 41 87.23% 47 100.00%

28 47 41 87.23% 41 87.23% 47 100.00%

29 47 41 87.23% 41 87.23% 47 100.00%

30 47 42 89.36% 42 89.36% 47 100.00%

31 47 41 87.23% 41 87.23% 47 100.00%

DNFSB 2021 DATA Act Audit Report 7lPage

Sample Total # # Incomplete # Inaccurate # Untimely Record # DEs 32 47 41 87.23% 41 87.23% 47 100.00%

33 47 41 87.23% 41 87.23% 47 100.00%

Total DEs 1551 Tested Total Errors 1355 1355 1551 Error Rate 87.36% 87.36% 100.00%

Table 1: Summary Results of PIID Testing for Completeness, Accuracy, Timeliness See Appendix II for the DNFSBs Results of the Data Element Test.

Completeness - Actual Error Rate The actual error rate for the completeness of the data elements tested is 87.36%4. A data element was considered complete if the required data element that should have been reported was reported.

Accuracy - Actual Error Rate The actual error rate for the accuracy of the data elements tested is 87.36%5. 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 error rate for the timeliness of the data elements tested is 100%6. 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.

Exception #1: There were no records in File D1 DNFSB did not submit data to the DATA Broker system that was necessary to generate File D1.

Per DNFSB, due to high turnover and limited staff, DNFSB did not have a login account to populate 4

Based on a 95% (exact) confidence level, the confidence interval is between 85.6%89.0%.

5 Based on a 95% (exact) confidence level, the confidence interval is between 85.6%89.0%.

6 Based on a 95% (exact) confidence level, the confidence interval is between 93.1%100.0%.

DNFSB 2021 DATA Act Audit Report 8lPage

File D1. Additionally, DNFSB did not have a process in place at the time to ensure contracts awarded and input into FPDSNG had the correct PIID. DNFSB management explained that since the beginning of FY 2021, DNFSB coordinated and finalized a process with their FSSP to ensure timely submission of information for files, including information used to populate File D1, and has a process in place to ensure contracts awarded and input into FPDSNG have the correct PIID.

Exception #2: For two (2) PIIDs, the Object Classes reported in File C were not reported on the contracts.

DNFSB will work to endure Object Class Code is consistently documented on the contract.

Analysis of the Accuracy of the Dollar ValueRelated Data Elements File D1 was incorrectly blank when procurement award detailed information should have been reported. See Error 1.

Analysis of Errors in Data Elements Not Attributable to DNFSB All errors were attributed to DNFSB.

III.3 OVERALL DETERMINATION OF QUALITY Based on the results of our statistical and nonstatistical testing, DNFSB scored 24.17 points, which is a quality rating of lower quality. 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 Level7 III.4 IMPLEMENTATION AND USE OF THE DATA STANDARDS DNFSB is not incompliance with governmentwide financial standards for spending information as developed by OMB and Treasury. DNFSB File D1 for FY 2020 quarter 4 was incorrectly blank.

7 Source of table 3 and quality rating determination is the IG Guide, Section 820, Quality Assessment Scorecard DNFSB 2021 DATA Act Audit Report 9lPage

III.5 ASSESSMENT OF INTERNAL CONTROLS Assessment of Internal Control over Source Systems The DNFSB uses USDA as its FSSP and USDAs Pegasys system for its financial management processes including reporting. This system is the source of information used to report theFY 2021 quarter 4 financial data as required by the DATA Act.

In performing DNFSBs FY 2020 financial statement audit, CLA assessed the internal controls over the Pegasys and determined that the controls are properly designed, implemented, and operating effectively. Our assessment included the review of Pegasys Service Organization Controls (SOC) 1, Type 2 report. A SOC 1, Type 2 Report is intended to meet the needs of a broad range of users that need detailed information and assurance about the controls at a service organization relevant to security, availability, and processing integrity of the systems the service organization uses to process users data; and the confidentiality and privacy of the information processed by these systems. We relied on this assessment of internal controls over source systems for the DATA Act.

Assessment of Internal Control over the Data Management and Processes (DATA Act Submission)

Through review of DNFSBs DATA Act process narratives and discussions with management, CLA obtained an understanding of DNFSBs 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 DNFSBs Files AD for FY 2020 quarter 4 DATA Act submission. Additionally, DNFSB provided their final Broker warnings for the same period. We reviewed DNFSBs final Broker warnings files they reviewed to evaluate DNFSBs performance of internal control over the data quality, accuracy, timeliness, and completeness prior to the final data certification. Per DNFSB they reviewed the warning reports but did not make any corrections to resolve the warning for FY 2020 quarter 4. Furthermore, CLA did not receive any evidence that DNFSB reconciled the data files. Per DNFSB, data file reconciliations and resolution of warnings were not done for the FY 2020 DATA Act submission due to staff turnover and limited staff.

We assessed internal controls and compliance with laws and regulations necessary to satisfy the audit objective. In particular, we assessed whether DNFSB has sufficient controls in place to ensure that the FY 2020 quarter 4 DATA Act submission was complete, accurate and timely in accordance with applicable OMB and Treasury guidance. We found that DNFSB was not in compliance with DATA Act reporting deadlines and the FY 2020 quarter 4 DATA Act submission was incomplete as File D1 was blank. While DNFSB has documented control procedures to ensure DATA Act submission are complete, accurate and timely DNFSB did not perform key control procedures such as documenting a reconciliation between files and resolving significant warnings before SAO certification.

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.

DNFSB 2021 DATA Act Audit Report 10 l P a g e

III.6 RECOMMENDATIONS We recommend that DNFSB:

1) Enhance internal control and detective procedures surrounding DATA Act submissions.

Procedures should include documenting reconciliations between DATA Files A, B, C, and D1, researching and resolving differences between files including resolving warning reports on a timely basis, and submitting DATA Act information timely to the DATA Act Broker in accordance with the reporting schedule established by the Treasury DATA Act Program Management Office.

(Partial repeat of 2019 DATA Act audit report recommendation two)

2) Ensure Object Class Code is consistently documented on the contract.

Additionally, see 2019 recommendations and status based on the FY 2020 quarter 3 testing in Appendix IV.

DNFSB 2021 DATA Act Audit Report 11 l P a g e

IV. REPORT DISTRIBUTION DNFSB Distribution Office of the General Manager Office of the Chief Finance Officer Office of the General Counsel NonDNFSB 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 DNFSB 2021 DATA Act Audit Report 12 l P a g e

APPENDICES DNFSB 2021 DATA Act Audit Report 13 l P a g e

APPENDIX I - DNFSBs MANAGEMENT COMMENT AND CLAS RESPONSE DEFENSE NUCLEAR FACILITIES SAFETY BOARD Washington, DC 20004-2901 DNFSB COMMENTS ON THE DIGITAL ACCOUNTABILITY AND TRANSPARENCY ACT AUDIT OCTOBER 2021 The Nuclear Regulatory Commissions Office of the Inspector General (OIG) provides inspector general services to the Defense Nuclear Facilities Safety Board (DNFSB). The OIG contracted an accounting firm to conduct its third required review of the DNFSBs compliance with Government-wide financial data standards as required by the DATA Act. Despite being a small independent agency, the DNFSB is required to meet the same financial data standards as much larger agencies.

For this particular review, the accounting firm chose the 4th Quarter of Fiscal Year (FY) 2020 for its data sample. At that time, the DNFSB was substantially understaffed across the agency including in key positions necessary to comply with the Government-wide financial data standards. Key positions such as a Principal Accountant, a Chief Financial Officer, Contracting Officers, and a Director of Operational Services were all vacant. As a result, DNFSBs FY 2020 4th Quarter reporting was not timely, accurate, or complete as described in the DATA Act audit report. With the support of Congress requiring a minimum level of Federal staff and turnover in agency leadership, a renewed focus on rebuilding agency staff led to DNFSB onboarding the key personnel in Quarter 1 and Quarter 2 of FY 2021. Since that time, DNFSB has made significant progress in ensuring timely completion and certification of the monthly DATA Act files. The agency cleared the backlog of DATA Act files, established ongoing working group sessions with USDA, continues to perform root cause analysis of its file warnings, and now publishes its monthly submission files on a timely basis. As a result of these actions, the following improvements have been made in DATA Act reporting and compliance for FY 2021:

  • Number of total monthly DATA Act Warnings decreased from an average of 70 a month down to 36 for the September submission;
  • Number of total unique warning types decreased from 14 down to 9; and
  • DNFSB continues to work closely with USDA, its Federal Shared Service Provider to identify root causes and implement solutions.

DNFSB 2021 DATA Act Audit Report 14 l P a g e

The DATA Act audit report describes concerns regarding the completeness and accuracy of financial data submitted to the Treasury DATA Act Broker. There were differences between File A and File B with regard to Obligations, Outlays, De-obligations, and Recoveries in the amount of $4 million. DNFSB has identified the root cause as prior period worksheet adjustments, and their subsequent reversals. The worksheet adjustments were accurately reflected in the File A submission file but were not accurately reflected in the File B submission file. As a result, the File A figures were accurate and tied back to the SF-133 form for the reporting period. Overall, DNFSB activities were accurately reported in File A, and the $4 million dollar difference was due to an accounting adjustment made by USDA. The DNFSB also failed to enter any contracting data into file D1 for the 4th Quarter of FY 2020. With experienced and trained contract officers now onboard, the agency is properly populating the system with contracting data.

DNFSB is fully committed to build upon the improvements made in FY 2021 for compliance with the DATA Act and strengthening its key internal controls for reconciliation of the DATA Act submission files and timely identification, review, and resolution of warning notifications when possible. This DATA Act audit reveals two important lessons for DNFSB: 1) that as a small agency, the agency is one-person deep for important administrative functions, and 2) that manual accounting and reconciliation of financial data increases the potential for errors that are time consuming to resolve. In part to address these concerns, the agency will be initiating a comprehensive human capital strategy plan in FY 2022. Although this strategic effort is not intended to increase the size of the operational support staff in the agency, it will allow for better personnel development, training, and succession planning. In FY 2022, the agency also intends to conduct market research and select an enterprise financial accounting system to automate budget formulation, budget execution, and financial accounting processes. A complimentary software suite of tools to assist in the contracting process will facilitate the agency contracting processes and contract tracking. These combined efforts will institutionalize financial controls and automate processes currently completed manually, thereby reducing financial control risks and resolving issues identified though OIG audits. The support of Congress and DNFSB leadership has been crucial in planning for these enhancements.

James P. Biggins General Manager Defense Nuclear Facilities Safety Board DNFSB 2021 DATA Act Audit Report 15 l P a g e

Comments on OIG Discussion Draft Report:8 Audit of the DNFSBs Compliance with the Digital Accountability and Transparency Act of 2014 (DATA Act)

October 2021 No Page Reviewer Comment Rationale CLA s Response

1. Page7, DBF ANALYSIS OF RESULTS The auditors draft report states, We determined As noted in footnote 2 of the section AND QUALITY that the quality of DNFSBs data was of lower quality report, the scoring was based on III ASSESSMENT overall, with a reference to a footnote stating, The testing of File C and D1 data IG Guide includes a scorecard spreadsheet that elements, the linkages between calculates the quality of the data based on the File C and D1, and other answers to questions and data input by auditors. evaluation criteria reflected in Quality of data is categorized as low, moderate, the CIGIE IG Guides quality higher, and excellent based on points range. The assessment scorecard for FY 2020 scorecard is formatted to calculate quality based on quarter 3 testing period. Since weighted scores of both statistical sampling and File D1 was blank all data nonstatistical testing results. For the quality elements related to File D1 scorecard, statistical testing results are valued at 60 testing were considered points and nonstatistical testing results are valued at exceptions.Section III mentions 40 points, for a total of 100 points. the reasons for the lower scoring and results of tests.

Based on the draft report, the scoring was based on review of the D1 file, which was blank, due to various reasons previously mentioned above. It is unclear how scoring was performed against a blank entry where data was not provided.

Accordingly, the scoring criteria should be updated to specify the reason for incompleteness and/or inaccuracy be identified as being specifically related to D1 files, and not any other file, since these should have been marked as N/A due to there being no data in the D1 file for most of the submissions.

8 The column CLAs Response is added by CLA to respond to the Comment/Rationale provided by DNFSB in their comment to the draft report. The other columns were provided by DNFSB verbatim.

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No Page Reviewer Comment Rationale CLA s Response

2. Page 5 DBF Section B. Regarding the statement, Per DNFSB they are in the During our audit and when the Completeness of process of researching the reason for the differences. draft report was prepared in SummaryLevel Data Completeness of the agency submission is defined as October 2021, DNFSB could not for Files A and B transactions and events that should have been provide the status and was still recorded are recorded in the proper period. researching the reason for the $4 million differences between File Please update to, DNFSB researched the differences A and B related to obligations and provided explanations that they were due to and outlays, although this was in differences between File A and File B with regard to broker warning report since FY Obligations, Outlays and Deobligations and 2020 quarter 3 submission. CLA Recoveries. The root cause was related to prior period only obtained the root cause of worksheet adjustments, and their subsequent the difference in their response reversals. The worksheet adjustments were to the draft report. This issue is accurately reflected in the File A submission file, but related to linkages between File were not accurately reflected in the File B submission A and B, and not file A and SF file. As a result, the File A figures were accurate and 133. Report Section III.1B tied back to the SF133 for the reporting period. mentions File A agrees to the SF Overall, DNFSB activities were accurately reported in 133.

File A, and the $4 Million dollar difference was due to an accounting adjustment made by USDA.

3. Page 8 DBF Exception 1 Regarding Exception 1, Since the beginning of FY CLA has updated our audit report 2021, DNFSB has been coordinating with the FSSP to to incorporate DNFSBs proposed finalize the implementation of the process. verbiage.

Please update the above statement to read, Since the beginning of FY 2021, DNFSB coordinated and finalized a process with their FSSP to ensure timely submission of information for files, including for File D1, and has a process in place to ensure contracts awarded and input into FPDSNG have the correct PIID.

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APPENDIX II - DNFSBs RESULTS OF THE DATA ELEMENTS TEST DNFSB results of the data elements test listed in descending order by accuracy error rate percentage.

File Data Element Data Element Name Error Rate Number A C T D1 DE 26 Period of Performance Start Date 100% 100% 100%

D1 DE 5 Legal Entity Address 100% 100% 100%

D1 DE 4 Ultimate Parent Legal Entity Name 100% 100% 100%

D1 DE 17 NAICS Code 100% 100% 100%

D1 DE 18 NAICS Description 100% 100% 100%

D1 DE 6 Legal Entity Congressional District 100% 100% 100%

D1 DE 3 Ultimate Parent Unique Identifier 100% 100% 100%

D1 DE 1 Awardee/Recipient Legal Entity Name 100% 100% 100%

D1 DE 2 Awardee/Recipient Unique Identifier 100% 100% 100%

D1 DE 24 Parent Award ID Number 100% 100% 100%

D1 DE 30 Primary Place of Performance Address 100% 100% 100%

D1 DE 31 Primary Place of Performance Congressional District 100% 100% 100%

D1 DE 14 Current Total Value of Award 100% 100% 100%

D1 DE 15 Potential Total Value of Award 100% 100% 100%

D1 DE 11 Federal Action Obligation 100% 100% 100%

D1 DE 16 Award Type 100% 100% 100%

D1 DE 22 Award Description 100% 100% 100%

D1 DE 23 Award Modification / Amendment Number 100% 100% 100%

D1 DE 25 Action Date 100% 100% 100%

D1 DE 28 Period of Performance Potential End Date 100% 100% 100%

D1 DE 29 Ordering Period End Date 100% 100% 100%

D1 DE 32 Primary Place of Performance Country Code 100% 100% 100%

D1 DE 33 Primary Place of Performance Country Name 100% 100% 100%

D1 DE 34 Award ID Number 100% 100% 100%

D1 DE 36 Action Type 100% 100% 100%

D1 DE 38 Funding Agency Name 100% 100% 100%

D1 DE 39 Funding Agency Code 100% 100% 100%

D1 DE 40 Funding Sub Tier Agency Name 100% 100% 100%

D1 DE 41 Funding Sub Tier Agency Code 100% 100% 100%

D1 DE 42 Funding Office Name 100% 100% 100%

D1 DE 43 Funding Office Code 100% 100% 100%

D1 DE 44 Awarding Agency Name 100% 100% 100%

D1 DE 45 Awarding Agency Code 100% 100% 100%

D1 DE 46 Awarding Sub Tier Agency Name 100% 100% 100%

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File Data Element Data Element Name Error Rate Number A C T D1 DE 47 Awarding Sub Tier Agency Code 100% 100% 100%

D1 DE 48 Awarding Office Name 100% 100% 100%

D1 DE 49 Awarding Office Code 100% 100% 100%

D1 DE 7 Legal Entity Country Code 100% 100% 100%

D1 DE 8 Legal Entity Country Name 100% 100% 100%

D1 DE 27 Period of Performance Current End Date 100% 100% 100%

D1 DE 163 National Interest Action 100% 100% 100%

C DE 50 Object Class 6% 6% 100%

C DE 53 Obligation 0% 0% 100%

C DE 430 Disaster Emergency Code 0% 0% 100%

C DE 34 Award ID Number (PIID) 0% 0% 100%

C DE 51 Appropriations Account 0% 0% 100%

C DE 56 Program Activity 0% 0% 100%

C DE 24 Parent Award ID Number 0% 0% 0%

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APPENDIX III - COMPARATIVE RESULTS Error Rate File Data Element Data Element Name 2021 2019  % Change Number D1 DE 163 National Interest Action 100% 0% 100%

D1 DE 17 NAICS Code 100% 35% 65%

D1 DE 18 NAICS Description 100% 35% 65%

D1 DE 6 Legal Entity Congressional District 100% 35% 65%

D1 DE 1 Awardee/Recipient Legal Entity Name 100% 35% 65%

D1 DE 2 Awardee/Recipient Unique Identifier 100% 35% 65%

D1 DE 24 Parent Award ID Number 100% 35% 65%

D1 DE 30 Primary Place of Performance Address 100% 35% 65%

D1 DE 31 Primary Place of Performance 100% 35% 65%

Congressional District D1 DE 11 Federal Action Obligation 100% 35% 65%

D1 DE 16 Award Type 100% 35% 65%

D1 DE 22 Award Description 100% 35% 65%

D1 DE 23 Award Modification / Amendment Number 100% 35% 65%

D1 DE 29 Ordering Period End Date 100% 35% 65%

D1 DE 32 Primary Place of Performance Country Code 100% 35% 65%

D1 DE 33 Primary Place of Performance Country 100% 35% 65%

Name D1 DE 34 Award ID Number 100% 35% 65%

D1 DE 36 Action Type 100% 35% 65%

D1 DE 38 Funding Agency Name 100% 35% 65%

D1 DE 39 Funding Agency Code 100% 35% 65%

D1 DE 40 Funding Sub Tier Agency Name 100% 35% 65%

D1 DE 41 Funding Sub Tier Agency Code 100% 35% 65%

D1 DE 42 Funding Office Name 100% 35% 65%

D1 DE 43 Funding Office Code 100% 35% 65%

D1 DE 44 Awarding Agency Name 100% 35% 65%

D1 DE 45 Awarding Agency Code 100% 35% 65%

D1 DE 46 Awarding Sub Tier Agency Name 100% 35% 65%

D1 DE 47 Awarding Sub Tier Agency Code 100% 35% 65%

D1 DE 48 Awarding Office Name 100% 35% 65%

D1 DE 49 Awarding Office Code 100% 35% 65%

D1 DE 7 Legal Entity Country Code 100% 35% 65%

D1 DE 8 Legal Entity Country Name 100% 35% 65%

D1 DE 5 Legal Entity Address 100% 41% 59%

D1 DE 4 Ultimate Parent Legal Entity Name 100% 41% 59%

D1 DE 3 Ultimate Parent Unique Identifier 100% 41% 59%

D1 DE 25 Action Date 100% 41% 59%

D1 DE 28 Period of Performance Potential End Date 100% 41% 59%

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Error Rate File Data Element Data Element Name 2021 2019  % Change Number D1 DE 27 Period of Performance Current End Date 100% 41% 59%

D1 DE 14 Current Total Value of Award 100% 47% 53%

D1 DE 15 Potential Total Value of Award 100% 47% 53%

D1 DE 26 Period of Performance Start Date 100% 53% 47%

C DE 50 Object Class 37% 0% 37%

C DE 430 Disaster Emergency Code 33% 0% 33%

C DE 34 Award ID Number (PIID) 33% 0% 33%

C DE 51 Appropriations Account 33% 0% 33%

C DE 56 Program Activity 33% 0% 33%

C DE 53 Obligation 33% 24% 9%

C DE 24 Parent Award ID Number 0% 47% 47%

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APPENDIX IV - STATUS OF FISCAL YEAR 2019 DATA ACT RECOMMENDATIONS We reviewed FY 2019 recommendations to evaluate DNFSBs implementation of the corrective actions. DNFSB 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 Recommendation Corrective Action Recommendation

1. Work with its FSSP to correct Per DNFSB, DNFSB is currently working with their Open the PIIDs for new obligations in Federal Shared Service Provider (FSSP) to correct its accounting system and to the PIIDs and mapping of data elements. DNFSB correct the mapping of certain implementation of this recommendation is still in data elements to ensure that progress, with a tentative completion date of the data elements are in quarter 1, FY 2022.

accordance with the data standards established by OMB and the Treasury

2. Perform an effective quality In April 2020, the OIG closed this recommendation Closed control review of the data and as DNFSBs corrective action was implemented Partial Repeat linkages in the files received based on documentation at the time. Although carried over to from the FSSP aimed at DNFSB reviewed and researched discrepancies 2021 identifying root causes to that appeared on the warning reports for quarter recommendation warnings and errors, if any, 4 FY 2020, reconciliations between Files A to D1 1 prior to the SAO certification were not documented. CLA noted a $4 million difference for obligations and outlays between File A and B for quarter 4 2020 and DNFSB did not resolve this issue or others on the warning reports timely.

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APPENDIX V - SCOPE AND METHODOLOGY Scope The scope of this performance audit is DNFSBs FY 2020 Quarter 4 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 DNFSBs responsibilities to report financial and award data under the DATA Act;
  • Reviewing DNFSBs 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 4 summarylevel data submitted by the agency for publication on USASpending.gov;
  • Reviewing a statically valid sample the records from FY 2020, quarter 4 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 DNFSBs 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 DNFSBs 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 more than one error rate was determined in the November 2019 DATA Act audit, use the error rate closest to 50%. CLA used the expected error rate of 36% based on the results of November 2019 DATA Act audit report. We statistically selected 33 records reported in File C out of 45 records using the following parameters to calculate our randomly selected sample size:

  • Population size of 45 records
  • Confidence level of 95%
  • Expected error rate of 36%
  • Sample precision of 5%

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APPENDIX VI - FEDERAL SPENDING TRANSPARENCY DATA STANDARDS (59 standards)

Number9 Data Element Data Standards1011 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 9

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.

10 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.

11 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 DNFSB 2021 DATA Act Audit Report 25 l P a g e

Number9 Data Element Data Standards1011 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 DNFSB 2021 DATA Act Audit Report 26 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 Broker12 (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.

12 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 DNFSB 2021 DATA Act Audit Report 29 l P a g e

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