oversight

U.S. Department of the Interior DATA Act Submission for First Quarter FY 2019

Published by the Department of the Interior, Office of Inspector General on 2019-11-07.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                      AUDIT




                           OF
               INSPECTOR GENERAL
               U.S.DEPARTMENT OF THE INTERIOR




 U.S. DEPARTMENT OF THE INTERIOR
 DATA ACT SUBMISSION FOR FIRST
 QUARTER FY 2019




Report No.: 2019-FIN-043
                - -                             November 2019
                 OFFICE OF
                 INSPECTOR GENERAL
                 U.S.DEPARTMENT OF THE INTERIOR


Memorandum

To:            Andrea Brandon
               Deputy Assistant Secretary, Budget, Finance, Performance, and Acquisitions

From:          Mark L. Greenblatt
               Inspector General

Subject:       Final Audit Report – U.S. Department of the Interior DATA Act Submission
               for First Quarter FY 2019
               Report No. 2019-FIN-043

        This memorandum transmits the results of our final audit of the U.S. Department of
the Interior’s (DOI’s) fiscal year (FY) 2019 first quarter financial and award data
submission in accordance with the Digital Accountability and Transparency Act of 2014
(DATA Act) and submission standards developed by the U.S. Department of the Treasury
(Treasury) and the Office of Management and Budget (OMB).

        We assessed the data and found that, while they contained most of the required
information and conformed to the OMB and Treasury standards, there were small
deficiencies in completeness, timeliness, and accuracy of the data submissions we sampled.
The table on page 1 of our report explains the files we reviewed. Specifically, we found in
the 57 data elements for each of the 385 transactions that 3.45 percent were incomplete,
2.84 percent were not timely, and 11.34 percent were not accurate. These results were
projected to the DOI’s FY 2019, first quarter submission. Based on the Council of the
Inspectors General on Integrity and Efficiency Federal Audit Executive Council’s
standards, we consider the DOI’s FY 2019, first quarter data displayed on
USASpending.gov to meet the higher quality standard.

       We offer three recommendations to help the DOI improve its submissions and
comply with standards. In response to our draft report, the DOI concurred with all three
recommendations. Based on this response, we consider all three recommendations to be
resolved but not implemented.

      We will refer the recommendations to the Assistant Secretary for Policy,
Management and Budget for implementation tracking.

      If you have any questions concerning this report, please contact me at
202-208-5745.



                     Office of Audits, Inspections, and Evaluations | Washington, DC
       The legislation creating the Office of Inspector General requires that we report to
Congress semiannually on all audit, inspection, and evaluation reports issued; actions taken
to implement our recommendations; and recommendations that have not been
implemented.




                                             2
Table of Contents

File Names and Descriptions ...........................................................................................................1
Results in Brief ................................................................................................................................2
Introduction......................................................................................................................................3
   Objective ......................................................................................................................................3
   Background ..................................................................................................................................3
      DATA Act File Creation ..........................................................................................................4
Findings............................................................................................................................................6
   Broker Software Warnings...........................................................................................................6
      Procurement Award Cross Warning Report .............................................................................7
      Financial Award Cross Warning Report ..................................................................................9
      Program Activity Warning Report .........................................................................................10
      Financial Award Warning Report...........................................................................................11
      Appropriations Program Activity Cross Warning Report ......................................................11
   Deficiencies in the Statistical Sample ........................................................................................11
      Attribute Testing Results ........................................................................................................12
      Completeness..........................................................................................................................12
      Timeliness...............................................................................................................................12
      Accuracy.................................................................................................................................13
      Quality ....................................................................................................................................13
Conclusion and Recommendations................................................................................................14
Appendix 1: Scope and Methodology............................................................................................16
Appendix 2: DOI Internal Controls over the DATA Act Creation and Submission .....................19
Appendix 3: FY 2017, Second Quarter DATA Act Audit Recommendations..............................23
Appendix 4: Response to Draft Report ..........................................................................................25
Appendix 5: Status of Recommendations......................................................................................26
File Names and Descriptions
    File
  Name      File Description                Contents                     What We Found
File A     Appropriations       Appropriation is setting aside      Amounts in File A were
           Account Detail       money for a specific purpose.       less than the amounts in
                                The U.S. Department of the          File B.
                                Interior (DOI) appropriates
                                funds to delegate cash needed
                                for operations.
                                These accounts show the
                                details of the appropriations.
File B     Object Class and     Object classes are categories of    The object classes and
           Program Activity     items or services purchased by      program activity detail did
           Detail               the U.S. Government. Program        not match the Office of
                                Activity Detail is a specific       Management and Budget
                                activity or project listed in the   classes and detail. The
                                Government’s annual budget.         DOI’s File B direct
                                This file contains more details     appropriation amount did
                                about the items or services         not match the DOI’s
                                purchased by the Government.        SF-133 line 2004 per the
                                                                    Treasury Account Symbol
                                                                    for the same reporting
                                                                    period.

File C     Award Financial      This file contains the totals of    Information entered did
           Detail               the DOI’s awards to each            not match the same
                                awardee.                            information in external
                                                                    agency systems, obligation
                                                                    amounts in File C did not
                                                                    match those in Files D1
                                                                    and D2, and obligations
                                                                    occurred in File C that
                                                                    were not active in the
                                                                    reporting period or were
                                                                    for other periods.
File D1    Award and            This file contains the DOI’s        Information entered did
           Awardee Attributes   awardee names, addresses, and       not match departmental
           (Procurement)        award amounts for                   systems.
                                procurement contracts.
File D2    Award and            This file contains the DOI’s        Information entered did
           Awardee Attributes   awardee names, addresses, and       not match departmental
           (Financial           award amounts for financial         systems.
           Assistance)          assistance awards.




                                                                                                  1
Results in Brief
We audited the fiscal year (FY) 2019 first quarter financial and award data that the U.S.
Department of the Interior (DOI) submitted to the U.S. Department of the Treasury (Treasury)
and displayed on www.USASpending.gov in accordance with the Digital Accountability and
Transparency Act of 2014 (DATA Act), Pub. L. No. 113-101, 128 Stat. 1146. The DATA Act
requires U.S. Government agencies to make Federal spending data accessible, searchable, and
reliable.

We assessed the DOI’s implementation and use of the Governmentwide financial data standards
established by the Office of Management and Budget (OMB) and the Treasury. We determined
that the DOI met the March 20, 2019 deadline for submitting its financial data to Treasury,
implemented the Governmentwide standards 1 for those data that the OMB and Treasury
developed as directed by the DATA Act, and improved its data quality. We did, however, find
discrepancies in some of the files, which would affect the display of information on
USASpending.gov.

We also assessed the completeness, timeliness, accuracy, and quality of data DOI submitted. We
reviewed a statistical sample of transactions from the DOI’s FY 2019 first quarter data to
determine whether the DOI reported all summary-level financial data for the proper reporting
period and if those transactions contained all applicable data elements required by the DATA
Act. We found that some files contained most of the required summary-level data and all data
elements conformed to the OMB and Treasury standards. While there were deficiencies in
completeness, timeliness, and accuracy of the data submissions we sampled, they were small
enough to meet the Council of the Inspectors General on Integrity and Efficiency Federal Audit
Executive Council’s “higher” quality standard.

We offer three recommendations to improve the DOI’s DATA Act reporting process. In response
to our draft report, the DOI concurred with all three of our recommendations. Based on this
response, we consider all three recommendations to be resolved but not implemented.




1 The DATA Act, which expanded requirements in the Federal Funding Accountability and Transparency Act of 2006,

31 U.S.C. § 6101, outlines the information required to ensure transparent Federal spending reporting. From these requirements
identified in the DATA Act, Treasury developed 57 standards (called DATA Act elements) that agencies use to create and submit
their DATA Act files.


                                                                                                                           2
Introduction
Objective
In our audit of the U.S. Department of the Interior’s (DOI’s) fiscal year (FY) 2019 first quarter
financial and award data submitted in accordance with the Digital Accountability and
Transparency Act of 2014 (DATA Act), Pub. L. No. 113-101, 128 Stat. 1146, we focused on
these objectives:

   1. Assessing the DOI’s implementation and use of the Governmentwide financial data
      standards established by the Office of Management and Budget (OMB) and the U.S.
      Department of the Treasury (Treasury)

   2. Assessing the completeness, timeliness, accuracy, and quality of financial and award data
      submitted for publication on USASpending.gov

The scope and methodology are included in Appendix 1.

Background
The DATA Act requires Government agencies to make Federal spending data more accessible,
searchable, and reliable. The Act required the OMB and Treasury to establish Governmentwide
data standards. It also required Federal agencies to have begun reporting financial and payment
data by March 20, 2019, in accordance with these standards. The data standards define the data
elements and formats required for reporting data from both agency financial systems and
Governmentwide procurement systems. The data files include:

   •   File A, “Appropriations Account Detail”

   •   File B, “Object Class and Program Activity Detail”

   •   File C, “Award Financial Detail”

   •   File D1, “Award and Awardee Attributes (Procurement)”

   •   File D2, “Award and Awardee Attributes (Financial Assistance)”

   •   File E, “Additional Awardee Attributes”

   •   File F, “Subaward Attributes”

Files A, B, and C are created by agency systems; Files D1 and D2 by agency systems and
external systems; and Files E and F by external systems. Upon submission, each agency’s senior
accountable official (SAO) documents his or her assurance of internal controls over data
reliability and accuracy for these seven files. The SAOs, however, are not responsible for
certifying the quality of the data the awardees report to the General Services Administration



                                                                                                    3
(GSA). Reported data is displayed on a public website, www.USASpending.gov, to help increase
transparency in Federal spending by linking grant, contract, loan, and other financial data to
program results. Inspectors general are required to submit oversight reports to Congress by
November 8, 2019. 2

DATA Act File Creation
The DATA Act, which expanded requirements in the Federal Funding Accountability and
Transparency Act of 2006, 31 U.S.C. § 6101, outlines the information required to ensure
transparent Federal spending reporting. From these requirements identified in the DATA Act,
Treasury developed 57 standards (called DATA Act elements) that agencies use to create and
submit their DATA Act files.

Agencies are expected to use the Treasury broker software that compiles agency data for
publication on USASpending.gov, to upload Files A, B, and C. These files contain data pulled
from internal financial and award management systems. Once the agencies upload these files,
they use the broker software to create the remaining Files D1, D2, E, and F. The broker software
validates Files A, B, and C using two types of validation checks—data element validations and
complex validations—before submitting the files to Treasury. These checks ensure the required
standard format and correct calculations for the files. For seemingly invalid data, the broker
software can either produce a warning message while still accepting the data for submission or
produce a critical error, which prevents submission of the data altogether. Figure 1 illustrates the
operation of the broker software after the agencies upload DATA Act Files A, B, and C.




2 CIGIE [Council of the Inspectors General on Integrity and Efficiency] FAEC [Federal Audit Executive Council] Inspectors

General Guide to Compliance under the DATA Act, February 2019.


                                                                                                                            4
                                                                                                     FIio 01 w~I be
                                                                                                   extracted lrom the
                                                                                                 Federal Procuromont
                                                                                               Data System
                                                                                             (FPDS-NO)

                                                                                        FIio 02 r,om the Award
                                                                                      Submissions Portal (ASP)

                                                                                 FIio e from the System for Award
                                                                                Ma039emen1 (SAM)

                                                                             FIie F lrom the Federal Funding
                                                                          Accountab1llty and Transparency Act
                                                                         Subrecipient Reporting System (FSRS)
               include fleld length and ~
          data type to ensure data are                                       Flies D1, D2. E, and F will not be
           consistent and comparable
                                                                    - - -i validated in the brokera
                                                                             Senior Accountable Officials (SAO)
                                                 Agency                      document their assurance of data
                                               certification                 refiability and accuracy



                                                                                . go archdecturo designed to hold
                                                                             Stora
                                                                             data extraoted from transacbonat
                                                                             systems, operational data stores, and
                                                                             external sources


                                            USASpendlng.gov
      ~      D~ta ~vbmlswn from             (or successor system)
  [          ogencies
             Data extracted from existing
             award data system


Note: The Award Submissions Portal (ASP) is now called Financial Assistance Broker Submission (FABS).

Figure 1. Operation of the broker software

Source: Government Accountability Office analysis of Treasury’s technical documents, GAO-17-156




                                                                                                                        5
Findings
We determined that the DOI submitted financial data (Files A, B, and C) to the broker software
and created and submitted Files D1, D2, E, and F with the broker software by the March 20,
2019 deadline. We found that the DOI implemented the Governmentwide standards 3 for those
data that the OMB and Treasury developed as directed by the DATA Act; however, we found
that the broker software warnings occurred for the following element linkages and calculations:

    •    The amounts in File A were less than amounts in File B.

    •    Object classes and program activity detail did not match OMB classes and detail.

    •    The DOI’s File B direct appropriation amount did not match the DOI’s SF-133 line 2004
         per the Treasury Account Symbol (TAS) for the same reporting period.

    •    Information entered in File C did not match the external agency systems.

    •    Obligation amounts in File C did not match those in Files D1 and D2.

    •    Obligations occurred in File C that were not active in the reporting period or were for
         other periods.

    •    Information entered in File D1 and D2 did not match the departmental systems.

We also found deficiencies in completeness, timeliness, quality, and accuracy of the data
submissions we sampled. 4 Specifically, we found in the 57 data elements for each of the 385
transactions that 3.45 percent were incomplete, 2.84 percent were not timely, and 11.34 percent
were not accurate. These results were projected to the DOI’s FY 2019, first quarter submission.
Based on the Council of the Inspectors General on Integrity and Efficiency (CIGIE) Federal
Audit Executive Council (FAEC) standards (higher, moderate, and lower), we consider the
DOI’s FY 2019, first quarter data displayed on USASpending.gov to meet the higher quality
standard.

Broker Software Warnings
The broker software delivers warnings to users when it cannot validate data elements or values, a
condition that ultimately would affect the display of information on USASpending.gov. Treasury
3 The DATA Act, which expanded requirements in the Federal Funding Accountability and Transparency Act of 2006,
31 U.S.C. § 6101, outlines the information required to ensure transparent Federal spending reporting. From these requirements
identified in the DATA Act, Treasury developed 57 standards (called DATA Act elements) that agencies use to create and submit
their DATA Act files.
4 FY 2019 CIGIE FAEC Inspectors General Guide to Compliance under the DATA Act. Completeness is measured based on

whether all required data elements were reported. Timeliness is measured based on the reporting schedules defined by the
procurement and financial assistance requirements (Federal Funding Accountability and Transparency Act (FFATA), Federal
Acquisition Regulation (FAR), Federal Procurement Data System - Next Generation (FPDS-NG), and DATA Act Information
Model Schema (DAIMS). Accuracy is measured based on when amounts and other data relating to recorded transactions were
recorded in accordance with the DAIMS, Interface Definition Document, and the online data dictionary, and agree with
authoritative sources. Quality is defined as data that is reported on a timely basis and is complete and accurate.


                                                                                                                           6
allows some validation rules to give warnings so that the agencies can resolve these issues prior
to certifying. If they do not correct the issues, agencies can submit their data with the warnings,
but will be required to correct the problems in future uploads. In the future, Treasury will change
these warnings to fatal errors, requiring the agencies to correct them before submission.5

We accessed and reviewed the Treasury DATA Act submission portal in the broker software for
the DOI’s submitted files and identified that there were 438 warnings in 5 reports. Of the 5
reports—

    •   The procurement award cross warning report had 240 warnings

    •   The financial award cross warning report had 186 warnings

    •   The program activity report had 5 warnings

    •   The appropriations program activity cross warning report had 5 warnings

    •   The financial award warning report had 2 warnings

Procurement Award Cross Warning Report
The DOI had 240 Treasury broker software warnings in this report, consisting of:

    •   98 C11 warnings indicating that the obligations in File C did not exist or did not match
        those in File D1

    •   64 C12 warnings indicating that the obligations in File D1 did not exist or did not match
        those in File C

    •   78 C23.2 warnings indicating that the obligation amounts in File C did not match those in
        File D2.

During our detailed testing, we identified that the DOI’s File C submission contained purchase
order postings relevant to the DATA Act that should not be included in first quarter FY 2019
data. These incorrect inclusions resulted from obligations or deobligations that were not active in
the first quarter, or from transactions that were not recorded in the proper period. We also
identified that the DOI’s File C submission contained obligation amounts that did not match File
D2 obligation amounts.

We identified these issues in our sample (see Deficiencies in the Statistical Sample section
below) when we tested DATA Act element linkages from File C to Files D1 to identify whether
the procurement instrument identifier (PIIDs) and obligation amounts in File C were also in File
D1. The DATA Act requires the PIIDs and obligation amounts to be included and match in both
files. We identified that:

5
 GAO-17-156, DATA ACT: OMB and Treasury Have Issued Additional Guidance and Have Improved Pilot Design but
Implementation Challenges Remain, December 2016.


                                                                                                             7
   •   Three PIIDs in our File C sample were not in File D1. These PIIDs were not timely
       because they were outside of the first quarter FY 2019 timeframe and, therefore, should
       not have been included in File C.

   •   Ten PIID obligation amounts in our File C sample did not match those in File D1.

The DOI’s Data Act Operational Plan (DAOP) indicated that the large proportion of C11 and
C12 rule warnings relate to timing challenges caused by discrepancies between the “Obligation
Date” in the DOI’s Financial and Business Management System (FBMS) and the “Date Signed –
Element 2A” in the GSA’s Federal Procurement Data System (FPDS). The DOI also told us that
the broker software extracts FPDS data using the “Date Signed – Element 2A” field on the
purchase order that sometimes does not represent the FBMS obligation date. The “Date Signed –
Element 2A” can vary based on when the contracting officer signs the original obligation and
then adds a modification. The DOI also told us that the FPDS does not have a static date field
that identifies when an award (original or modification) posting is finalized. As a result, the
difference in obligation date within FBMS and date signed within FPDS cause these warnings.

The C23.2 rule warnings occurred because the transaction obligated amount (award amount) in
File C did not match the Federal action obligation amount in File D2. The DATA Act Program
Management Office issued guidance to agencies indicating that for each unique award ID in File
C, the sum of each Transaction Obligated Amount reported for the period should match the sum
of the Federal Action Obligation amounts reported in D2 for the same timeframe, regardless of
modifications. Due to timing challenges, however, the amounts may not match and only a
warning message will be included in the validation report.

The DAOP also indicated that the C23.2 warnings were due to obligation rounding differences of
less than $50.00 between FBMS and FPDS. The DOI told us that the FBMS’ Procurement
Information System for Management uses more dollar decimal places than its SAP software and
as a result, obligation change amounts may differ (see Figure 2). We identified that the DOI is
working on a solution to resolve the rounding differences, and due to the materiality level, it does
not warrant a recommendation. These warnings can cause procurement award obligation
information on USASpending.gov to be inaccurate.




                                                                                                  8
                          PRISM                                    SAP
                            •                                         •
                              $1.545                                $1.54


                            Rounds to                             Rounds to
                               $1.55                                $1.54

Figure 2. Rounding differences between two of DOI’s financial management software systems: Procurement
Information System for Management (PRISM) and SAP.

Source: OIG


 Recommendation

 We recommend that the DOI:

     1. Issue guidance to contracting officers on determining accurate obligation dates


Financial Award Cross Warning Report
The DOI had 186 Treasury broker software warnings in this report, consisting of:

    •   57 C8 warnings indicating that awards in File C did not exist or did not match those in
        File D2

    •   63 C9 warnings indicating that awards in File D2 did not exist or did not match those in
        File C

    •   66 C23.3 warnings indicating that the obligation amounts in File C did not match those
        in File D2

During our detailed testing, we identified that DOI’s File C submission contained purchase order
postings relevant to the DATA Act that should not have been included in first quarter, FY 2019
data. These incorrect inclusions resulted from obligations or deobligations that were not active in
the second quarter, or from transactions that were not recorded in the proper period.

We identified these issues in our sample (see Deficiencies in the Statistical Sample section
below) when we tested DATA Act element linkages from File C to File D2 to identify whether
the Federal award identification numbers (FAINs) and obligation amounts in File C were also in




                                                                                                         9
File D2. The DATA Act requires that the FAINs and obligation amounts be included and match
in both files. We identified that:

   •     Five FAINs in our File C sample were not in File D2. These FAINs were not timely
         because they were outside of the first quarter FY 2019 timeframe and, therefore, should
         not have been included in File C.

   •     All FAIN obligation amounts in our File C sample matched those in File D2.

The C8 and C9 rule warnings relate to FAINS and are similar in nature to the C11 and C12
warnings for acquisitions awards above. The DOI’s Data Act Operational Plan (DAOP)
indicated that the large proportion of C8 and C9 rule warnings relate to challenges caused by
discrepancies between DOI’s FBMS FAIN obligation date and the release date in its
Procurement Information System for Management, which interfaces with the FBMS system.

The 66 C23.3 rule warnings occurred because the transaction obligated amount (award amount)
in File C did not match the Federal action obligation amount in File D2. The DATA Act Program
Management Office issued guidance to agencies indicating that for each unique award ID in File
C, the sum of each transaction obligated amount reported for the period should match the sum of
the Federal Action Obligation amounts reported in D2 for the same timeframe, regardless of
modifications. Due to timing challenges, however, the amounts may not match and only a
warning message will be included in the validation report. These warnings can cause financial
award obligation information on USASpending.gov to be inaccurate.

 Recommendation

 We recommend that the DOI:

       2. Issue guidance to grant officers on determining accurate obligation dates


Program Activity Warning Report
The program activity report had five rule warnings, consisting of:

    •     Three B9 warnings indicating a difference between the DOI’s program activity (PA)
          description in the DOI’s FBMS and the OMB PA description

    •     Two B14 warnings indicating that the File B direct appropriation amount does not match
          the inverse of the DOI’s SF-133 line 2004 per the Treasury Account Symbol (TAS) for
          the same reporting period

The DOI responded to these warnings by identifying that the DOI had PA descriptions that were
not aligned with the OMB PA descriptions. The DOI told us that some PA descriptions tend to
“drop-off” the OMB PA descriptions, causing the warnings. Because transactions were not
recorded in the proper period, File B direct appropriation amounts did not match the inverse of
the DOI’s SF-133 line 2004 per the TAS for the same reporting period. We identified that the


                                                                                                10
DOI has taken steps to identify and resolve transactions not being recorded in the proper period.
These warnings can cause PA descriptions and obligation amounts on USASpending.gov to be
inaccurate.

Financial Award Warning Report
The DOI had two B9 rule warnings in this report. The DAIMS indicated that the B9 warnings
were due to incorrect or misspelled PA names. Program activity names must be valid for the
corresponding funding TAS as defined in Section 82 of OMB Circular A-11. The DOI told us
that these were due to differences between the DOI’s PA descriptions configured in the DOI’s
FBMS and the OMB PA descriptions. These warnings can cause PA descriptions and obligation
amounts on USASpending.gov to be inaccurate.

 Recommendation

 We recommend that the DOI:

    3. Update the FBMS to align with the OMB PA descriptions or contact the OMB to
       update its descriptions


Appropriations Program Activity Cross Warning Report
The DOI had five warnings, consisting of one A18, three A19, and one A35. Based on the
DAIMS, the A18 and A19 warnings indicate that the Government TAS Trial Balance shows an
ending balance different than the DOI’s FBMS ending balance, and the A35 warning indicates
that File A’s deobligations, recoveries, or refunds do not equal those in File B. These warnings
can cause obligation, recoveries, or refund information to be inaccurate on USASpending.gov.

The DOI responded to these warnings by analyzing the accounts that are causing the differences
and identifying timing differences among FBMS entries. The differences occurred because
transactions were included in the incorrect period. To resolve the warnings, the DOI has a
process to identify incorrect period transactions and adjusts as needed.

Deficiencies in the Statistical Sample
The DATA Act required us to review a sample of the DOI’s File C—or Files D1 and D2 if File
C was found inadequate—to assess the completeness, timeliness, accuracy, and quality of the
data submitted. We determined that the DOI’s File C provided an adequate sample, based on
preliminary review. Using Teammate Analytics, a statistical sampling program, we selected 385
of 10,467 transactions from the DOI’s File C and performed attribute testing on each to
determine completeness, timeliness, accuracy, and quality. We used the testing spreadsheet tool
included in the FY 2019 CIGIE FAEC Inspectors General Guide to Compliance under the DATA
Act to test the 57 elements against source systems and documents. We set the estimated number
of errors expected in the sampled population based on the DOI’s FY 2017 second quarter
average error rate of 38 percent.




                                                                                               11
Attribute Testing Results
We found in the 57 data elements for each of the 385 transactions that 3.45 percent were
incomplete 6, 2.84 percent were not timely 7, and 11.34 percent were not accurate 8. These results
were projected to the DOI’s FY 2019, first quarter submission. Based on the CIGIE FAEC
standards (higher, moderate, lower), we consider the DOI’s FY 2019, first quarter data displayed
on USASpending.gov to meet the higher quality standard (see Figure 2).


          Completeness                                  Timeliness                                   Accuracy
                   3.45%                                       2.84%                                     11.34%




               96.55                                      97.16                                     88.66
                 %                                          %                                         %



               • Fail • Pass                              • Fail • Pass                               • Fail • Pass

Figure 2. Percentage of passed and failed transactions in each category. We sampled 385 of 10,467
transactions that the DOI submitted in its File C in compliance with the DATA Act requirements.


Completeness
We considered a data element complete if it included the required data. We tested completeness
by comparing transactions and various awardee attributes to source documents, as well as to
internal and external source systems. For example, we verified that the sample transactions
contained all applicable elements required by the DATA Act.

Timeliness
We based the timeliness of data elements on the reporting schedules defined by the procurement
and financial assistance requirements (Federal Funding Accountability and Transparency Act
(FFATA), Federal Acquisition Regulation (FAR), Federal Procurement Data System - Next
Generation (FPDS-NG), Financial Assistance Broker Submission, and DATA Act Information
Model Schema (DAIMS). We tested the sample back to source documents and the DOI’s FBMS
to determine whether the obligations and deobligations occurred in the FY 2019, first quarter
period. Many of the contracts and grant agreements the DOI provided to us were not signed or
dated; therefore, we had to locate and obtain either the original signed contracts and grant


6 Based on a 95 percent confidence level, the projected error rate for the completeness of the data elements is between
3.437 percent and 3.463 percent.
7 Based on a 95 percent confidence level, the projected error rate for the timeliness of the data elements is between 2.828 percent

and 2.851 percent.
8 Based on a 95 percent confidence level, the projected error rate for the accuracy of the data elements is between 11.327 percent

and 11.353 percent.


                                                                                                                                12
agreements or match contract line item numbers or purchase order line items to transactions in
the FBMS’ Procurement Information System for Management.

Accuracy
We considered a data element accurate when users recorded amounts and other data relating to
transaction records in accordance with the DAIMS Reporting Submission Specifications,
Interface Definition Document, and the online data dictionary, and agree with the authoritative
source records. We verified accuracy, which included comparing transaction amounts and
various awardee attributes with source documents, internal and external source systems, and
USASpending.gov to see if they agree with source documents and source systems.

Quality
We used the guidance in the FY 2019 CIGIE FAEC Inspectors General Guide to Compliance
under the DATA Act to rate the quality of the sample. If the highest error rate of completeness,
timeliness, and accuracy was between 0 percent and 20 percent, we would consider the quality
higher; between 21 percent and 40 percent, moderate; and 41 percent or more, lower. The DOI’s
highest error rate was 11 percent indicating that it met the higher quality standard.




                                                                                                  13
Conclusion and Recommendations
Conclusion
Based on our audit, we found that the DOI has improved the completeness, timeliness, accuracy,
and quality of its financial and award data submitted to USASpending.gov. The data the DOI
submitted to USASpending.gov, however, can improve. If it does not, the website will continue
to display DOI award and financial information incorrectly or not at all. Implementing the
recommendations to the DOI’s creation and submission of its DATA Act files will assist its
compliance with the DATA Act guidelines and provide the public DOI spending data that is
accessible, searchable, and reliable, as required. We found in the 57 data elements for each of the
385 transactions that 3.45 percent were incomplete, 2.84 percent were not timely, and 11.34
percent were not accurate. These results were projected to the DOI’s FY 2019, first quarter
submission. Based on the CIGIE FAEC standards, we consider the DOI’s FY 2019, first quarter
data displayed on USASpending.gov to meet the higher quality standard.


Recommendations Summary
We issued a draft version of this report to the DOI to review and respond. Based on the response,
we consider all three recommendations resolved but not implemented. See Appendix 4 for the
full text of the DOI’s response and Appendix 5 for the status of recommendations.

We recommend that the DOI:

        1. Issue guidance to contracting officers on determining accurate obligation dates

            DOI Response: The DOI concurred with our finding and recommendation. The
            Business Integration Office (BIO) will work with the Office of Acquisition and
            Property Management (PAM) to issue guidance on determining accurate obligations
            dates with a target completion date of December 31, 2020.

            OIG Reply: Based on the DOI’s response, we consider Recommendation 1 resolved
            but not implemented.

        2. Issue guidance to grant officers on determining accurate obligation dates

            DOI Response: The DOI concurred with our finding and recommendation. The BIO
            will work with the Office of Grants Management (PGM) to issue guidance on
            determining accurate obligation dates with a target completion date of December 31,
            2020.

            OIG Reply: Based on the DOI’s response, we consider Recommendation 2 resolved
            but not implemented.

        3. Update the FBMS to align with the OMB PA descriptions or contact the OMB to
           update its descriptions



                                                                                                14
DOI Response: The DOI concurred with our finding and recommendation. In
collaboration with the Office of Budget (POB), the BIO will evaluate the broker
software warnings to determine appropriate adjustments to existing processes,
including OMB’s quarterly BDR [budget data request] process to capture updates in
OMB MAX [the budget information system] with a target completion date of
December 31, 2021.

OIG Reply: Based on the DOI’s response, we consider Recommendation 3 resolved
but not implemented.




                                                                               15
Appendix 1: Scope and Methodology
Scope
Our audit scope included performing and reviewing a statistical sample of 385 out of 10,467 items
in the U.S. Department of the Interior’s (DOI’s) Fiscal Year (FY) 2019, first quarter financial and
award data submitted in accordance with the Digital Accountability and Transparency Act of 2014
(DATA Act) for publication on USASpending.gov. We checked the sample against the standard 57
DATA elements and any applicable procedures, certifications, documentation, and controls to
achieve this process. We projected the results of our statistical sample testing to the DOI’s entire
FY 2019, first quarter submission. According to the Office of Management and Budget’s (OMB’s)
Management Procedures Memorandum No. 2016-03, data reported by Federal agencies in FY
2019, first quarter will be displayed on USASpending.gov by May 2019.

We also assessed the DOI’s internal controls by consulting the Generally Accepted Government
Auditing Standards, the FY 2019 CIGIE [Council of Inspectors General on Integrity and
Efficiency] FAEC [Federal Audit Executive Council] Inspectors General Guide to Compliance
under the DATA Act, and the five components for Federal Government internal controls (see
Appendix 2) in the Government Accountability Office’s (GAO’s) Green Book.

Methodology
We conducted the audit in accordance with Generally Accepted Government Auditing Standards.
Those standards require that we plan and perform the 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 we obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.

To accomplish our objectives, we—

   •   Reviewed 385 statistical sample selections of 10,467 total entries in the DOI’s FY 2019,
       first quarter File C submission against the 57 standard DATA elements established by
       OMB and the U.S. Department of the Treasury.

       The sample size of 385 is mathematical, based on the sampling formula for attribute
       sampling using the following criteria:

       1. Confidence Interval: 95 percent

       2. Desired Precision: 5 percent

       3. Expected Error Rate: 38 percent

       The GAO and CIGIE FAEC DATA Act group selected the percentages for confidence
       level and precision. We based the sample size on these parameters and the error rate on
       the DOI’s FY 2017, second quarter DATA Act error rate of 38 percent.


                                                                                                 16
   •   Reviewed laws, legislation, directives, and any other regulatory criteria (and guidance)
       related to the DOI’s responsibilities to report financial and payment information under
       the DATA Act

   •   Reviewed the DOI’s governance structure, processes, and controls planned and/or
       established

   •   Conducted interviews and walkthroughs with the DOI’s DATA Act working groups
       responsible for implementing the DATA Act at the agency level

   •   Assessed the DOI’s systems, processes, and internal controls in place over data
       management under the DATA Act

   •   Assessed the DOI’s internal controls in place over the financial and award data reported
       to USASpending.gov per OMB Circular No. A-123, Management’s Responsibility for
       Internal Control

   •   Traced the 385 statistical sample selections and their data elements established by the
       OMB and Treasury back to source systems and/or performed alternate procedures
       consisting of matching contract line item numbers or purchase order line items to
       transactions in the Procurement Information System for Management

   •   Assessed the completeness, timeliness, accuracy, and quality of the financial and award
       data sampled in files A, B, C, D1, and D2. (We did not audit files E and F because they
       are compiled from information provided by the General Services Administration’s
       systems.)

   •   Assessed DOI’s implementation and use of the 57 data elements established by the OMB
       and Treasury

   •   Interviewed DOI officials responsible for data creation and reporting

We used data from the DOI’s Financial and Business Management System (FBMS) in
conducting this audit. We also used data from the General Services Administration’s (GSA’s)
FPDS system. The controls over the FBMS were being evaluated as part of the FY19 DOI
financial statement audit conducted by KPMG with oversight by the Office of Inspector General
during the time we were reviewing the data from the FBMS. Because the KPMG was not
finished with its evaluation of the controls over the FBMS, we were only able to partially rely on
the KPMG’s assessment of the controls pertaining to the financial management systems (i.e.,
grants, loans, procurement) from which the data elements were derived and linked. As a result,
we also traced transactions back to source documents. In addition, under the General Services
Administration’s FPDS contract, the FPDS was subject to Government certification and
accreditation assessments. Consequently, we believe that the data from the GSA system was
sufficiently reliable given our audit objectives.



                                                                                                  17
Testing Limitations for Data Reported from Files E and-F
File E of the DATA Act Information Model Schema contains additional awardee attribute
information the Treasury broker software extracts from the System for Award Management
(SAM). File F contains sub-award attribute information the broker software extracts from the
Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System
(FSRS). Files E and F data remain the responsibility of the awardee in accordance with terms
and conditions of Federal agreements, and the quality of these data remains the legal
responsibility of the recipient. Therefore, agency senior accountable officials 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.

Criteria and Best Practices
   •   CIGIE FAEC Inspectors General Guide to Compliance under the DATA Act,
       February 14, 2019

   •   Digital Accountability and Transparency Act of 2014, May 9, 2014

   •   The DATA Act Information Model Schema Version 1.3, June 29, 2018

   •   OMB Memorandum M-15-12, Increasing Transparency of Federal Spending by Making
       Federal Spending Data Accessible, Searchable, and Reliable, May 8, 2015

   •   OMB Memorandum M-17-04, Additional Guidance for DATA Act Implementation:
       Further Requirements for Reporting and Assuring DATA Reliability, November 4, 2016

   •   OMB Management Procedures Memorandum No. 2016-03, Additional Guidance for
       DATA Act Implementation: Implementing Data Centric Approach for Reporting Federal
       Spending Information, May 3, 2016

   •   GAO, Standards for Internal Controls, Report No. GAO-14-704G, September 2014




                                                                                                18
Appendix 2: DOI Internal Controls over the
DATA Act Creation and Submission
Results of our Assessment over Internal Controls
Based on our review of the U.S. Department of the Interior’s (DOI’s) internal controls over the
Digital Accountability and Transparency Act of 2014 (DATA Act) requirements, we found that
we are unable to fully rely on the internal controls over the data’s source systems because our
contracted financial statement auditors had not completed the general and application control
testing over the DOI’s Financial and Business Management System (FBMS). As a result, we
traced our sample selection back to the data’s source documents to test the completeness,
timeliness, accuracy, and quality of the DOI’s submitted DATA Act Fiscal Year (FY) 2019, first
quarter data. Since the DOI was timely in providing the requested source documentation, we
completed fieldwork steps on time.

The following sections outline the DOI’s processes for each of the five internal control
components.

Control Environment
The control environment is the foundation for an internal control system. It provides the
discipline and structure to help an agency achieve its objectives.

The DOI appointed the Principal Deputy Assistant Secretary for Policy, Management and
Budget as the senior accountable official (SAO) to oversee the DOI’s implementation of the
DATA Act. The Principal Deputy Assistant Secretary for Policy, Management and Budget
delegated the operational responsibilities to the Director of the Business Integration Office (BIO)
to manage the project across multiple DOI bureaus and Federal spending communities.

The financial reporting for the DOI comes from the FBMS, and the DATA Act elements are
implemented into the FBMS structure. Governance for the DATA Act requirements falls under
and is performed by the existing FBMS executive governance structure, which is led by the SAO
and includes members from each bureau. The BIO heads the DATA Act implementation team
and communicates information to the SAO through the FBMS executive structure meetings.

Risk Assessment
We reviewed the DOI’s risk assessment efforts to identify its basis for developing risk responses
and identified that the DOI does not have an enterprise risk management risk profile. The DOI,
however, incorporated an outlined risk assessment covering risk areas of the DATA Act in its
DATA Quality Plan, which encompasses enterprise risk management principles.

The BIO performs assessments on the FBMS and the requirements of the DATA Act through
gap analysis and frequent communication with the Office of Management and Budget (OMB)
and the U.S. Department of the Treasury (Treasury). For example, the gap analysis tracks data
element differences and challenges between the FBMS, the General Services Administration
(GSA), and Treasury systems. These three Federal agencies have systems that assist in creating
Federal agency DATA Act files. This analysis helps the DOI report to any implementation


                                                                                                19
challenges it faces to Treasury and OMB and request feedback. Once the DOI obtains feedback
or guidance, it implements any necessary changes in the FBMS or relies on other source systems
the GSA owns, such as the System for Award Management (SAM), based on guidance from
Treasury.

The FBMS executive structure, which oversees DATA Act implementation, meets to discuss and
address challenges with DATA Act implementation identified through gap analysis and external
communication.

Control Activities
We reviewed the DOI’s control activities—actions established by management through policies
and procedures to achieve objectives and respond to risk—in the internal control system, which
includes the DOI’s information system.

The DOI updated its DATA Act Operation Plan to address FY 2017, second quarter DATA Act
findings (see Appendix 3 for our 2017 recommendations), which discusses how to create and
review Files A, B, C, D1, and D2 and then submit them to the broker software. We also reviewed
the DOI’s policy about reporting information to the Federal Procurement Data System – Next
Generation (FPDS-NG), a system from which the broker software extracts data to create the
agency’s DATA Act files. The policy establishes requirements for the entry, review, and
certification of FPDS-NG data. We also reviewed the DOI’s policy and procedures used to guide
reporting information to the Procurement Information System for Management. These policies
and procedures appear to be adequate.

We partially relied on our contractor’s internal control work on the DOI’s general and
application controls over the FBMS for the FY 2019 financial statement audit. We also traced
our sample selection back to source documents to ensure the accuracy of the reported
information. We did not perform an internal control review over the DOI’s FBMS general and
application controls for data reporting because we would have been duplicating the contractor’s
efforts.

The DOI also told us that it partially relies on the GSA’s assurance statement on the quality of
the data pulled from GSA’s systems, SAM, and the Federal Subaward Reporting System (FSRS).
The statement indicates that SAM and FSRS successfully passed the security controls assessment
at the Federal Information Processing Standards 199 moderate impact level, in accordance with
the Federal Information Security Management Act and National Institute of Standards and
Technology policy guidelines, as well as the GSA security assessment and authorization process.

OMB Circular No. M-17-04, Additional Guidance for DATA Act Implementation: Further
Requirements for Reporting and Assuring Data Reliability.
For the DATA Act, this document requires that agencies identify intergovernmental transfers
(IGTs) and personally identifiable information (PII). We reviewed the Circular and found that
the DOI has a process for identifying and reporting IGTs. The DOI identifies an allocation
transfer via the Treasury Account Symbol (TAS) and buys/sells transactions via a data element.
The DOI uses the TAS two-digit agency identifier to determine whether the transaction is an
IGT. The first two-digit TAS indicates the awarding agency and the second two-digit TAS



                                                                                              20
indicates the funding agency. For example, Files A, B, and C have two included elements named
“Allocation Transfer Agency Identifier” and “Agency Identifier.” The former indicates the
awarding agency and the latter indicates the funding agency.

The DOI identified buy/sell transactions by setting up a reimbursable agreement and accounted
for it using an included file element called “By Direct Reimbursable Funding Source,”
identifying the transactions with either a “D” for “direct” or an “R” for “reimbursable.” These
transactions were pulled into File C using these indicators.

We inquired as to how the DOI identifies and reports classified and sensitive data and found that
it has a process in place to assist in identifying PII. The DOI compared each DATA Act element
with customer information to identify whether the data may contain PII.

OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk. Management and
Internal Control
The DOI also relied on its contracted external auditors to identify internal control weaknesses in
its FBMS via the Financial Statement Audit. This audit assesses Federal agencies’ compliance
with OMB Circular No. A-123. The DOI does not perform its own internal audits of the FBMS.

Information and Communication Efforts
We reviewed the information that management and personnel communicate and use to support
the internal control system. We found that the DOI appointed a DATA Act SAO who oversees
DATA Act implementation for all bureaus and most offices. The DATA Act SAO delegated the
operational responsibilities to the Director of the BIO to manage the project across multiple DOI
bureaus and Federal spending communities. Each bureau has an executive sponsor for DATA
Act implementation, who meets regularly with the DOI’s DATA Act implementation team, led
by the BIO, to provide guidance and receive status updates. The BIO also provides periodic
updates to the SAO, the bureau sponsors, and other executives, as appropriate, via memos,
telephone calls, and monthly meetings.

Further, we identified that the DOI communicated with external sources, including Treasury, the
OMB, vendors, and DATA Act working groups, to obtain information supporting its internal
controls over the DATA Act. These sources discuss challenges to comply with the DATA Act
and work together to resolve them.

Monitoring Activities
We reviewed the DOI’s monitoring activities to identify how DOI management assessed the
quality of its performance over time and resolved the findings of audits and other reviews. We
identified that both the SAO and DOI management monitor DATA Act process through regular
meetings, as well as through review of processes and procedures. If the DOI identifies a risk, the
DOI DATA Act group meets to identify potential solutions and then leverage the group’s
expertise to execute a course of action. For example, the DOI identified that certain broker
software warnings were associated with small dollar obligation modifications that were not
closed out after the period of performance ended. The DOI gives priority to closing out higher
dollar obligation modifications due to the resources and time it takes to close them out. In
attempts to resolve the challenge, the BIO is currently working on a series of processes to



                                                                                                21
automate certain acquisition award closeouts that have a less than $100 balance and +120 days
after the period of performance end date. Once the series of automated processes closes out an
award, the contract officers can review the closeouts prior to certifying them.




                                                                                                 22
Appendix 3: FY 2017, Second Quarter DATA
Act Audit Recommendations
Results of our assessment over the Department of the
Interior’s progress to implement and resolve audit
recommendations
Based on our review of the U.S. Department of the Interior’s (DOI’s) policies, procedures, and
Digital Accountability and Transparency Act of 2014 (DATA Act) Operational Plan, we
consider the following recommendations implemented and resolved:

   1. DOI resolve Treasury broker warnings in its DATA Act files prior to SAO [senior
      accountable official] certification

       OIG Reply: We consider this recommendation partially resolved and implemented.
       While warnings are still accepted by the Treasury broker, they may cause information to
       be displayed incorrectly or not at all on USASpending.gov as indicated in this report’s
       discussion of the File C to Files D1 and D2 cross-validation warnings. The DOI should
       continue to attempt to resolve Treasury broker warnings as they occur.

   2. DOI resolve the summation problem to report File C per the DATA Act guidelines

       DOI Response: DOI concurred with this recommendation. BIO [Business Integration
       Office] worked with SAP and resolved the summation problem prior to the third quarter
       submission.

       OIG Reply: We consider this recommendation resolved and implemented.

   3. DOI develop and implement written procedures to avoid pulling obligation modifications
      that are not active in the reporting period

       OIG Reply: We consider this recommendation resolved and implemented. We reviewed
       the DOI’s DATA Act Operational Plan and other procedures and identified that the DOI
       developed and implemented written procedures to avoid pulling obligation modifications
       that are not active in the reporting period.

   4. DOI develop and implement written procedures to ensure that transactions are included in
      the proper period

       OIG Reply: We consider this recommendation resolved and implemented. We reviewed
       the DOI’s DATA Act Operational Plan and other procedures and identified that the DOI
       developed written procedures to ensure that transactions are included in the proper
       period.



                                                                                                 23
5. DOI require ONRR [Office of Natural Resource Revenue] and OTFM [Office of Trust
   Funds Management] to attend the DATA Act meetings and include IBC [Interior
   Business Center] in the DATA Act governance structure

   OIG Reply: We consider this recommendation resolved, but not implemented.

6. DOI develop and implement written procedures over ensuring data accuracy after
   compiling DOI’s DATA Act File B and OTFM and ONRR Excel spreadsheets

   OIG Reply: We consider this recommendation resolved and implemented. We reviewed
   the DOI’s DATA Act Operational Plan and procedures over the compilation of the DOI’s
   DATA Act File B and identified it implemented written procedures over ensuring the
   accuracy after compiling the DOI’s DATA Act File B and OTFM and ONRR Excel
   Spreadsheet.

7. DOI develop and implement written procedures to review Files D1, D2, E, and F prior to
   SAO certification

   OIG Reply: We consider this recommendation resolved and implemented. We recognize
   that agencies do not have to ensure data quality for GSA [General Services
   Administration] systems; however, they are required to perform reviews on the files to
   resolve warnings before submission. We reviewed the DOI’s DATA Act Operational
   Plan and identified that it has procedures to review files D1, D2, E, and F validation
   warnings.

8. ONRR develop and implement written procedures on its DATA Act file creation

   OIG Reply: We consider this recommendation resolved and implemented. We reviewed
   ONRR’s policies and procedures and identified that it documented its process on its
   DATA Act file creation.




                                                                                       24
Appendix 4: Response to Draft Report
The DOI’s response to our draft report follows on page 26.




                                                             25
                             United States Department of the Interior
                                                 OFFICE OF THE SECRETARY
                                                    Washington, D.C. 20240




MEMORANDUM

To:             Mark L. Greenblatt
                Inspector General


From:           Andrea L. Brandon
                Deputy Assistant Se


Date:           10/31/2019

Subject:        Response to Draft Audit Report - U.S. Department of the Interior DATA Act
                Submission for First Quarter FY 2019. Report No. 2019-FIN-043

This memorandum is written in response to your memorandum of October 29, 2019 which
pertains to the U.S. Department of the Interior's (DOI's) fiscal year 2019 first quarter financial
and award data submission audit; which was completed in accordance with the Digital
Accountability and Transparency Act of2014 (DATA Act) and submission standard developed
by the U.S. Department of the Treasury (Treasury) and the Office of Management and Budget
(0MB).

As is evident in the audit report, the process for quarterly DATA Act submissions is complex
and a certain percentage of errors are expected. Based on DOI's FY 2017 error rate of 38
percent; an estimated average error rate of 38 percent was expected for FY 2018. However, we
were very pleased to learn that DOI's highest error rate was only 11 percent during this
evaluation period. This represents a significant improvement and that DOI has met the CIGIE
FAEC standard for "higher" quality.

DOI was assessed on the completeness, timeliness, accuracy, and quality of its data submitted for
first quarter FY 2019. A comparison of these results to those from the previous audit conducted
for FY 201 7 reveals a pattern of improvement:

      •   completeness improved from 96% to 96.55%
      •   timeliness improved from 86% to 97 .16%
      •   accuracy improved from 62% to 88.66%

DOI improved their attribute testing results from the audit conducted for FY 2017; completeness
improved from 96% to 96.55%; timeliness improved from 86% to 97.16%; accuracy improved
from 62% to 88.66%; and moved from a moderate quality standard to a higher quality standard.



                                                                                                 26
Report No. 2019-FIN-043 offers three recommendations to help DOI improve its submissions
and comply with standards. Our response to each is as follows:

   Recommendation # 1 - Issue guidance to contracting officers on determining accurate
    obligation dates.
    • RESPONSE: DOI concurs with the recommendation. The Business Integration Office
        (BIO) will work with the Office of Acquisition and Property Management (PAM) to
        issue guidance on determining accurate obligation dates.
    • Target Completion Date: December 31, 2020
    • Responsible Official: BIO Director/PAM Director



   Recommendation #2 - Issue guidance to grant officers on determining accurate obligation
    dates
    • RESPONSE: DOI concurs with the recommendation. The BIO will work with the Office
        of Grants Management (PGM) to issue guidance on determining accurate obligation
        dates.
    • Target Completion Date: December 31, 2020
    • Responsible Official: BIO Director/PGM Director



    Recommendation #3 - Update the FBMS to align with the 0MB PA descriptions or contact
     the 0MB to update its descriptions
    •    RESPONSE: DOI concurs with the recommendation. In collaboration with the Office of
         Budget (POB), the BIO will evaluate the "warnings" to determine appropriate
         adjustment(s) to existing processes, including OMB's quarterly BDR process to capture
         updates in 0MB MAX.
    • Target Completion Date: December 31 , 2021
    • Responsible Official: BIO Director/POE Director

DOI places a high priority on providing high-quality, transparent Federal spending information
to the public and using this data to achieve a more effective and efficient allocation of resources
to meet mission needs and improve overall agency performance. We are proud of the efficiency
and timeliness of Interior's DATA Act implementation and ongoing efforts to support quarterly
submissions. Thank you for your interest in this important endeavor.




                                                                                                  27
Appendix 5: Status of Recommendations
In response to our findings, the DOI concurred with all 3 recommendations.

 Recommendations                     Status                       Action Required
1. Issue guidance to
   contracting                                            We will refer this recommendation
   officers on                                              to the Assistant Secretary for
                         Resolved but not implemented
   determining                                            Policy, Management and Budget for
   accurate obligation                                         implementation tracking.
   dates
2. Issue guidance to
                                                          We will refer this recommendation
   grant officers on
                                                            to the Assistant Secretary for
   determining           Resolved but not implemented
                                                          Policy, Management and Budget for
   accurate obligation
                                                               implementation tracking.
   dates
3. Update the FBMS
   to align with the
                                                          We will refer this recommendation
   OMB PA
                                                            to the Assistant Secretary for
   descriptions or       Resolved but not implemented
                                                          Policy, Management and Budget for
   contact OMB to
                                                               implementation tracking.
   update its
   descriptions




                                                                                         28
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