oversight

Audit of RRB's First Quarter of Fiscal Year 2019 DATA Act Submission

Published by the Railroad Retirement Board, Office of Inspector General on 2019-11-06.

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

U.S. RAILROAD RETIREMENT BOARD
OFFICE OF INSPECTOR GENERAL




  Audit of Railroad Retirement
  Board’s Digital Accountability
  and Transparency Act of 2014
  Submission for First Quarter of
  Fiscal Year 2019
  Report No. 20-01               November 6, 2019
OFFICE OF INSPECTOR GENERAL
U.S. RAILROAD RETIREMENT BOARD
Audit of RRB’s DATA Act Submission for First Quarter of
Fiscal Year 2019


What We Found                                                        What We Did
Our audit determined that the Railroad Retirement Board (RRB)        The DATA Act required the
generally submitted complete, accurate, and high quality             Inspector General of each federal
financial and award data for its first quarter of fiscal year 2019   agency to review a statistically
publication on USASpending.gov, which consisted of $4.1 billion      valid sample of the spending data
in obligations. As of December 2018, the RRB’s obligation            submitted under the DATA Act;
amount was in the top 20 for the Federal Government.                 and submit to Congress and make
However, we determined improvements could be made to                 publicly available a report
internal controls over the Digital Accountability and                assessing the completeness,
Transparency Act of 2014 (DATA Act) submission, the                  timeliness, quality, and accuracy of
completeness and accuracy of the agency’s File B submission,         the data sampled and the
the timeliness of the Senior Accountable Official’s (DATA Act)       implementation and use of data
certification, and the completeness and accuracy of Files D1 and     standards by the federal agency.
D2.
                                                                     The objectives of this audit were to
Further, we determined that the RRB generally implemented            assess the completeness, accuracy,
and used the governmentwide financial data standards                 timeliness, and quality of the first
established by the Office of Management and Budget and the           quarter of fiscal year 2019 financial
Department of the Treasury, in accordance with standards.            and award data submitted by the
However, we did identify improvements that could be made to          RRB for publication on
the reporting of financial assistance awards containing              USASpending.gov; and assess the
personally identifiable information and resolving gaps between       RRB’s implementation and use of
authoritative data sources and RRB’s actual data sources.            the governmentwide financial data
                                                                     standards established by the Office
What We Recommend                                                    of Management and Budget and
                                                                     the Department of the Treasury.
To address the exceptions identified in this audit, we made
11 recommendations for improving the RRB’s DATA Act policies         The scope of the audit was first
and procedures, internal controls, and the overall DATA Act          quarter of fiscal year 2019 data the
submission.                                                          RRB submitted for publication on
                                                                     USASpending.gov, and any
RRB management concurred with all of our recommendations.            procedures, certifications,
The Bureau of Fiscal Operations has provided target completion       documentation, and controls to
dates in its management comments as provided in the                  achieve this process.
appendix. However, the Bureau of the Actuary and Research
has not provided target completion dates in its management
comments.




Report Summary                               November 6, 2019                    Report No. 20-01
OFFICE OF INSPECTOR GENERAL – U.S. RAILROAD RETIREMENT BOARD



Contents
INTRODUCTION                                                                               1
       OBJECTIVES, SCOPE, AND METHODOLOGY                                                  1
       BACKGROUND                                                                          2
               RRB DATA ACT REPORTING PRIMARY ROLES AND RESPONSIBILITIES                   6
RESULTS OF AUDIT                                                                           8
       RRB’S INTERNAL CONTROLS OVER DATA ACT REPORTING WERE GENERALLY EFFECTIVE BUT NEED
       IMPROVEMENT                                                                         9
               CONSIDERATION AND USE OF THE RRB’S DATA QUALITY PLAN NEEDS IMPROVEMENT      9
               MANAGEMENT’S WRITTEN ASSURANCE AND STATEMENT OF ACCOUNTABILITY WAS
               INCOMPLETE                                                                  10
               RRB’S DATA ACT POLICIES AND PROCEDURES NEED IMPROVEMENT                     11
               RECOMMENDATIONS                                                             12
               MANAGEMENT’S COMMENTS AND OUR RESPONSE                                      13
       RRB’S DATA ACT CERTIFICATION AND SUBMISSION WERE GENERALLY COMPLETE BUT NEED
       IMPROVEMENT ON TIMELINESS AND ACCURACY                                              13
               THE AGENCY’S SUBMISSION FOR FILES A, B, AND C WAS GENERALLY COMPLETE        13
               ACCURACY OF SUMMARY-LEVEL DATA FOR FILES A AND B AND LINKAGES NEED
               IMPROVEMENT                                                                 14
               THE AGENCY’S SUBMISSION WAS NOT TIMELY                                      18
               SAMPLE RESULTS – THE RRB’S DATA WAS OF HIGHER QUALITY                       18
               RECOMMENDATIONS                                                             20
               MANAGEMENT’S COMMENTS AND OUR RESPONSE                                      20
       THE RRB’S IMPLEMENTATION AND USE OF THE DATA STANDARDS COULD BE IMPROVED            20
               SOME FINANCIAL ASSISTANCE AWARDS CONTAINING PERSONALLY IDENTIFIABLE
               INFORMATION WERE INCORRECTLY REPORTED                                       21
               GAPS EXIST BETWEEN AUTHORITATIVE SOURCES AND ACTUAL SOURCES                 21
               RECOMMENDATIONS                                                             23
               MANAGEMENT’S COMMENTS AND OUR RESPONSE                                      23
APPENDIX I: MANAGEMENT COMMENTS                                                            24
APPENDIX II: MANAGEMENT COMMENTS                                                           27
APPENDIX III: SAMPLING METHODOLOGY                                                         29
OFFICE OF INSPECTOR GENERAL – U.S. RAILROAD RETIREMENT BOARD

        SCOPE                                                                                     29
        REVIEW METHODOLOGY                                                                        29
        RESULTS                                                                                   30
        CONCLUSION                                                                                31
APPENDIX IV: RRB’S RESULTS FOR THE DATA ELEMENTS                                                  33
APPENDIX V: BASIC VALIDATION RULES FOR AGGREGATE AND NON-AGGREGATE REPORTING                      36
APPENDIX VI: ANOMALY LETTER                                                                       37

LIST OF TABLES
TABLE 1.          RRB’S DATA ACT FILES                                                             5
TABLE 2.          RRB’S REPORTED AMOUNTS BY FEDERAL ACCOUNT – FIRST QUARTER OF FISCAL YEAR 2019    6
TABLE 3.          QUALITY, COMPLETENESS, ACCURACY, AND TIMELINESS DEFINITIONS                      8
TABLE 4.          OIG EVALUATION OF FILES A, B, AND C                                             14
TABLE 5.          FILE A TO FILE B VARIANCES RULE A18                                             15
TABLE 6.          FILE A TO FILE B VARIANCES RULE A19                                             16
TABLE 7.          LEVELS OF DATA QUALITY                                                          18
TABLE 8.          DATA ACT AUTHORITATIVE SOURCE AND RRB’S SOURCE SYSTEM                           22
TABLE 9.          RRB RESULTS PER SAMPLE RECORD                                                   31
TABLE 10.         RRB’S RESULTS FOR DATA ELEMENTS                                                 33
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD



                                             INTRODUCTION
This report presents the results of the Office of Inspector General’s (OIG) audit of the Railroad
Retirement Board’s (RRB) compliance with the Digital Accountability and Transparency Act of
2014 (DATA Act), as mandated. 1 The RRB reported $4.1 billion in obligations on
USASpending.gov for the first quarter of fiscal year 2019. At that time, the RRB’s obligated
amount was in the top 20 for the Federal Government.

Objectives, Scope, and Methodology
The objectives of this audit were to

       assess the completeness, accuracy, timeliness, and quality of the first quarter of fiscal
        year 2019 financial and award data submitted by the RRB for publication on
        USASpending.gov; and
       assess the RRB’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).
The scope of the audit was first quarter of fiscal year 2019 financial and award data the RRB
submitted for publication on USASpending.gov, and applicable procedures, certifications,
documentation, and controls to achieve this process.

To accomplish the audit objectives, we

       identified criteria from the law as well as OMB governmentwide guidance;
       reviewed the Council of the Inspectors General on Integrity and Efficiency (CIGIE) Federal
        Audit Executive Committee (FAEC) Inspectors General Guide to Compliance under the
        DATA Act (CIGIE FAEC Guide); 2
       interviewed applicable management, staff, and key personnel;
       assessed the internal and information system controls in place for the extraction of data
        from the source systems and for the reporting of data to Treasury’s DATA Act Broker;
       reviewed and reconciled the first quarter of fiscal year 2019 summary‐level data
        submitted by the RRB for publication on USASpending.gov, including Files A, B, and C;




1
 Pub. L. No. 113-101 (2014).
2
 Unless otherwise indicated, from this point forward in the report the term “CIGIE FAEC Guide” will imply Council
of the Inspectors General on Integrity and Efficiency (CIGIE) Federal Audit Executive Committee (FAEC) Inspectors
General Guide to Compliance under the Digital Accountability and Transparency Act of 2014 (DATA Act),
(Washington, D.C.: February 14, 2019).
Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01                       1
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

       reviewed a statistically valid sample from first quarter of fiscal year 2019 financial and
        award data submitted by the RRB for publication on USASpending.gov, including
        Files A, B, C, D1, and D2;
       assessed the completeness, accuracy, timeliness, and quality of the financial and award
        data sampled; and
       assessed the RRB’s implementation and use of the 57 data elements and standards
        established by OMB and Treasury.
We did not assess Files E or F as the quality of this data is the legal responsibility of the awardee
in accordance with terms and conditions of federal agreements. The RRB and other federal
agencies are not responsible for certifying the quality of data reported by awardees.

We adhered to the overall methodology, objectives, and audit procedures outlined in the CIGIE
FAEC Guide.

We considered the DATA Act date anomaly as determined by CIGIE. CIGIE identified a timing
anomaly with the oversight requirements contained in the DATA Act. That is, the first Inspector
General reports were due to Congress on November 2016; however, federal agencies were not
required to report spending data until May 2017. To address this reporting date anomaly, the
Inspectors General provided Congress with their first required reports by November 2017,
one year after the statutory due date, with two subsequent reports to be submitted following a
2-year cycle. On December 22, 2015, CIGIE’s chair issued a letter detailing the strategy for
dealing with the Inspector General 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. 3 A copy of the CIGIE letter can be found in
Appendix VI.

We conducted this performance 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 objective. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objectives.

We conducted our fieldwork at RRB headquarters in Chicago, Illinois, from May 2019 through
October 2019.

Background
The RRB is an independent agency in the executive branch of the Federal Government. The
agency administers comprehensive retirement/survivor and unemployment/sickness insurance
benefit programs for railroad workers and their families under the Railroad Retirement Act and
the Railroad Unemployment Insurance Act. These programs provide income protection during
old age and in the event of disability, death, temporary unemployment, or sickness.


3
 CIGIE FAEC Guide.
Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01          2
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

During fiscal year 2018, RRB paid retirement and survivor benefit payments totaling
approximately $13.1 billion to about 540,000 retirement and survivor beneficiaries. RRB also
paid net unemployment/sickness benefits of $100.2 million to about 25,000 claimants.

The DATA Act requires

    …the Inspector General of each Federal agency, in consultation with the Comptroller
    General of the United States, shall—‘‘(A) review a statistically valid sampling of the
    spending data submitted under this Act by the Federal agency; and ‘‘(B) submit to
    Congress and make publically available a report assessing the completeness,
    timeliness, quality, and accuracy of the data sampled and the implementation and use
    of data standards by the Federal agency. 4
The DATA Act amended the Federal Funding Accountability and Transparency Act of 2006
(FFATA), which required OMB to “…ensure the existence and operation of a single searchable
website, accessible by the public at no cost….” 5 The Act expanded FFATA in various aspects
such as

       requiring the disclosure of direct federal agency expenditures and linkage of federal
        contract, loan, and grant spending information to federal programs so taxpayers and
        policy makers can more effectively track federal spending;
       establishing governmentwide data standards for financial data to provide consistent,
        reliable, and searchable governmentwide spending data that are displayed accurately
        for taxpayers and policy makers;
       simplifying reporting for entities receiving federal funds by streamlining reporting
        requirements and reducing compliance costs while improving transparency;
       improving the quality of data submitted by holding federal agencies accountable for the
        completeness and accuracy of the data submitted; and
       applying approaches developed by the Recovery Accountability and Transparency Board
        to spending across the Federal Government.
The DATA Act charged OMB and Treasury with issuing guidance on the data standards needed
to implement the DATA Act and required full disclosure of federal funds on the public website
USASpending.gov no later than May 2017.6 The DATA Act further required the Secretary of the
Treasury, in consultation with the Director of OMB, to ensure that the information is posted to
the public website at least quarterly, but monthly when practicable. The DATA Act did not
provide any additional funding dedicated to its implementation.

Treasury published 57 data definition standards and required federal agencies to report
financial data in accordance with these standards for DATA Act reporting, beginning
January 2017. 7 These standards ensure consistency across departments and agencies and

4
  Pub. L. No. 113-101 (2014).
5
  Pub. L. No. 109-282 (2006).
6
  Office of Management and Budget (OMB), Increasing Transparency of Federal Spending by Making Federal
Spending Data Accessible, Searchable, and Reliable, OMB Memorandum M-15-12 (Washington, D.C.: May 8, 2015).
7
  Pub. L. No. 113-101 (2014).
Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01              3
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

define the specific data elements agencies must report under the DATA Act, such as
appropriation account, object class, expenditures, and program activity. Not all data elements
are required for every file. This information is published in the DATA Act Information Model
Schema (DAIMS), which provides agencies an overall view of the hundreds of distinct data
elements included in agencies’ DATA Act files.

According to OMB guidance, to ensure maximum transparency in federal spending, agencies
must report each financial assistance award at the most granular level practicable while
protecting personally identifiable information (PII). 8 Given the required data collections, if
reporting at the single award level is not practicable, agencies may report at the county level,
and if not practicable, aggregated at the state level, consistent with the following:

       Single Awards Containing PII: Agencies should report single awards at the award-level to
        the maximum extent practicable. If an agency captures a Federal Award Identification
        Number (FAIN) and other details for an award to an individual, the agency should report
        that award to USASpending.gov as a single, discrete record. Records reported in this
        way will be linked using the FAIN as the award identification, with any PII redacted by
        the agencies before submission.
       Aggregated Awards - County Level: If single award-level reporting is not practicable,
        agencies may report at the county level. If an agency does not capture a FAIN or other
        individual details for an award to an individual, the agency should include that award in
        a county-level aggregate record with other similar awards. Records reported in this way
        must be linked using the Unique Record Identifier (URI).
       Aggregated Awards - State Level: If neither single award-level reporting nor county-level
        reporting is practicable, agencies may report at the state level. Records reported in this
        way must be linked using the URI.
The RRB reported its financial assistance awards by aggregating the data at the county level.

The RRB’s DATA Act submission was comprised of the following files, as shown in Table 1.




8
 OMB, Additional Guidance for DATA Act Implementation: Further Requirements for Reporting and Assuring DATA
Reliability, OMB Memorandum M-17-04 (Washington, D.C.: November 4, 2016).
Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01                4
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Table 1. RRB’s DATA Act Files
             File Name                                       Description                                Number of
                                                                                                         Records
File A – Appropriations                Included the appropriations account detail                            34
Account                                information aligned to SF-133 Report on Budget
                                       Execution and Budgetary Resources (SF-133).
File B – Program Activity and          Included the object class and program activity                       331
Object Class                           detail information based on the SF-133s.
File C – Award Financiala              Included the award level financial detail                           33,125
                                       information from agency financial and award
                                       systems (FMIS, PREH, MBF, and MACRO).b
File D1 – Award Attributes             Contained the award and awardee attributes for                        70
(Procurement)                          procurement sourced from Federal Procurement
                                       Data System – Next Generation (FPDS-NG).
File D2 – Award Attributes             Contained the award and awardee attributes for                      33,057
(Financial Assistance)                 financial assistance from Financial Assistant
                                       Broker Submission (FABS) submission process.c
Source: RRB OIG Analysis of Files A through D2 and OMB M-17-04, Additional Guidance for DATA Act Implementation: Further
Requirements for Reporting and Assuring DATA Reliability, November 4, 2016.
a To view the additional details and attributes of File C, see Files D1/D2 in combination with File C.
b Financial Management Integrated System (FMIS) is the RRB’s financial system, whereas, Payment, Rate and Entitlement

History File (PREH) is the system of record for payment, rates, and entitlement history. The Master and Clearance Records
Online (MACRO) is a DB2 database which parallels the contents of the Railroad Unemployment Insurance Act master and
clearance files, the system of record for unemployment and sickness benefits.
c The Financial Assistance Broker Submission (FABS) portal replaced the Award Submission Portal (ASP).



Files A through C were generated by the RRB, and Files D1 and D2 were generated from the
DATA Act Broker. The DATA Act Broker extracted the agency’s information from the Federal
Procurement Data System – Next Generation (FPDS-NG) and the Financial Assistance Broker
Submission (FABS) portal for Files D1 and D2, respectively. During the submission process, the
DATA Act Broker generates warnings and errors based on Treasury-defined rules. The results of
validations are displayed in severity as a separate file, which contains errors and warning
messages per DAIMS Validation Rules v1.3.1, dated February 8, 2019:

        Errors must be corrected before proceeding to the next step because these validations
         indicate incorrect values for fundamental data elements. Agencies are unable to submit
         data containing errors.
        Warnings will not prevent continuing to the next step because these messages may not
         indicate inaccuracies in the data. The warning messages were created to alert the
         agency to possible issues worth further review.
We determined that File B was the primary file that fed into USASpending.gov’s spending
explorer. Using the explorer, a user could quickly view the RRB’s first quarter of fiscal year 2019
spending as shown in Table 2.



Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01                                 5
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Table 2. RRB’s Reported Amounts by Federal Account – First Quarter of Fiscal Year 2019
    Name and Federal Treasury Account Symbol (TAS)                          Obligated Amount Percent of Total
    Social Security Equivalent Benefit Account                               $1,894,233,965             46.20 %
    060-8010
    Railroad Retirement Account                                              $1,486,791,721             36.26 %
    060-8011
    National Railroad Retirement Investment Trust                             $377,004,812               9.20 %
    060-8118
    Federal Payments to the Railroad Retirement Accounts                      $231,294,627               5.64 %
    060-0113
    Limitation on Administration                                               $57,007,164               1.39 %
    060-8237
    Railroad Unemployment Insurance Trust Fund, Administrative                 $45,305,894               1.11 %
    Expenses
    060-8051a
    Dual Benefit Payments Account                                               $4,536,252               0.11 %
    060-0111
    Limitation on the Office of the Inspector General                           $3,764,331               0.09 %
    060-8018
    Railroad Unemployment Insurance Extended Benefit Payments                     $2,141           Less than 0.01 %
    060-0117
    Total                                                                       $4.1 billion             100 %
Source: Data as of December 31, 2018 as it appeared on USASpending.gov.
a Railroad Unemployment Insurance Trust Fund, Administrative Expenses full account number was 060X8051.002.



On June 6, 2018, OMB issued new guidance that required agencies to develop a Data Quality
Plan (DQP). According to Appendix A to OMB Circular No. A-123, Management of Reporting and
Data Integrity Risk (OMB M-18-16), DATA Act reporting agencies were required to implement a
DQP effective fiscal year 2019 through fiscal year 2021 at a minimum. The guidance became
effective immediately. The DQP must consider incremental risks to data quality in federal
spending data and any controls that would manage such risks in accordance with
OMB Circular No. A-123. Once developed by the agency, quarterly certifications of data
submitted by the Senior Accountable Official (SAO), or the designee should be based on the
consideration of the DQP and the internal controls documented by the agency. 9

RRB DATA Act Reporting Primary Roles and Responsibilities

First quarter of fiscal year 2019 RRB DATA Act reporting was accomplished through
coordination and cooperation efforts of the Bureau of Fiscal Operations (BFO), the Bureau of
the Actuary and Research (Actuary), the Office of Administration’s Division of Acquisition

9
 OMB, Appendix A to OMB Circular No. A-123, Management of Reporting and Data Integrity Risk, OMB M-18-16
(Washington, D.C.: June 6, 2018).
Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01                       6
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Management (AM), and RRB’s contractor, CGI Federal Incorporated (CGI). According to the RRB,
they assigned the following bureaus and offices with primary roles and responsibilities:

        RRB’s Chief Financial Officer was designated as the SAO for RRB’s DATA Act activities.
         OMB’s DATA Act implementation guidance states that “[o]n a quarterly basis, agency
         Senior Accountable Officials must provide reasonable assurance that their internal
         controls support the reliability and validity of the agency account-level and award-level
         data they submit to Treasury for publication on USASpending.gov.” 10
        The RRB’s SAO designee, also the DATA Act Certifier (Certifier), was appointed to certify
         the DATA Act files for publishing on USASpending.gov on behalf of the SAO. The Certifier
         was responsible for ensuring that any warnings or errors returned by the DATA Act
         Broker had been acknowledged and signed off by the corresponding bureau points of
         contact, that the summary procurement and financial assistance awards matched the
         summary amounts provided in File C, and they add any comments to the submission as
         necessary. This individual works in BFO’s accounting section and reports to the SAO.
        BFO was assigned as the primary organizational unit that was responsible for compiling
         and reporting all applicable data for the RRB’s DATA Act submission (Files A through D2).
         In addition, they conducted tasks associated with the roles of pre-broker reviewer, file
         submitter, bureau point of contact, post-broker reviewer, and contracting officer’s
         representative for CGI.
        AM was the organizational unit that certified procurement records as complete,
         accurate, and timely (Files C and D1). Additionally, they were responsible for verifying,
         addressing, and investigating any discrepancies identified by pre and post-broker
         reviewers.
        Actuary was the organizational unit that certified financial assistance records as
         complete, accurate, and timely (Files C, D2, and their External Source FAADS+ File).
         Additionally, they were responsible for verifying, addressing, and investigating any
         discrepancies identified by pre and post-broker reviewers.
        CGI was the RRB contractor that assisted in the file generation process, performed
         maintenance on the pre-broker validation queries, performed maintenance on the
         DATA Act structured query language (SQL), assisted in the pre and post-broker review,
         assisted in resolving warnings or errors with the bureau points of contact, and assisted
         in certifying data.




10
  OMB, Additional Guidance for DATA Act Implementation: Implementing Data-Centric Approach for Reporting
Federal Spending Information, OMB Management Procedures Memorandum (MPM) 2016-03 (Washington, D.C.:
May 3, 2016).
Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01                7
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                                           RESULTS OF AUDIT
Our audit determined that the RRB generally submitted complete, accurate, and high quality
financial and award data for its first quarter of fiscal year 2019 publication on USASpending.gov
and had generally effective internal controls over its DATA Act submission. However, we
identified exceptions with the 1) internal controls related to the use of a DQP, management’s
written assurance and statement of accountability, and the RRB’s DATA Act policies and
procedures, 2) accuracy of the agency’s Files B submission, 3) process in addressing DATA
Broker validation warnings and completing reconciliations, 4) timeliness of the SAO’s DATA Act
certification, and 5) completeness and accuracy of Files D1 and D2.

Quality, completeness, accuracy, and timeliness are defined in Table 3.

Further, we determined the RRB generally implemented and used the governmentwide
financial data standards established by OMB and Treasury. However, we did identify
improvements that could be made to the reporting of financial assistance awards containing PII
and resolving gaps between authoritative data sources and RRB’s actual data sources.


Table 3. Quality, Completeness, Accuracy, and Timeliness Definitions
   Attribute                                                Definition
Quality                    Data that is complete, accurate, and reported on a timely basis.

Completeness               Agency Submission – Transactions and events that should have been
                            recorded were recorded in the proper period.
                           Data Elements – For each of the required data elements that should have
                            been reported, the data element was reported in the appropriate Files A
                            through D2.

Accuracy                   Data Elements – Amounts and other data relating to recorded transactions
                            have been recorded in accordance with the DAIMS, Reporting Submission
                            Specification, Interface Definition Document, the online data dictionary, and
                            agree with the authoritative source records.

Timeliness                 Agency Submission – Reporting of the agency DATA Act submission to the
                            DATA Act Broker is in accordance with the schedule established by the
                            Treasury DATA Act Project Management Office.
                           Data Elements – For each of the required data elements that should have
                            been reported, the data elements were reported in accordance with the
                            reporting schedules defined by the financial, procurement, and financial
                            assistance requirements.
Source: CIGIE FAEC Guide.

We made 11 recommendations to address the exceptions identified. The full text of
management’s responses to these recommendations has been included in Appendix I and II.

Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01                 8
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RRB’s Internal Controls over DATA Act Reporting were Generally
Effective but Need Improvement
We determined that RRB’s internal controls over its DATA Act submission were generally
effective. The internal and information system controls for (1) the extraction of data from
source systems and (2) the reporting of data to the DATA Act Broker were designed,
implemented, and operating effectively to the extent of producing the financial assistance and
award data necessary for DATA Act reporting. However, we determined the RRB could make
internal control improvements related to the use of a DQP, management’s written assurance
and statement of accountability, and documentation of the RRB’s DATA Act policies and
procedures.

Consideration and Use of the RRB’s Data Quality Plan Needs Improvement

The agency SAO did not base the first quarter’s DATA Act submission and certification of data
on the DQP because its first DQP was not prepared until August 9, 2019 – four and half months
after the submission was made on March 21, 2019.

Starting in fiscal year 2019, OMB guidance established that agencies must develop a DQP to
identify a control structure tailored to address identified risks. SAO quarterly certifications
should be based on the considerations of the agency’s DQP. Additionally, OMB guidance
requires that agencies consider their DQP in their annual assurance statement on internal
controls over reporting, beginning in fiscal year 2019. 11 According to OMB:

     The Data Quality Plan should cover significant milestones and major decisions
     pertaining to:
        •    Organizational structure and key processes providing internal controls for
             spending reporting.
        •    Management’s responsibility to supply quality data to meet the reporting
             objectives for the DATA Act in accordance with OMB Circular No. A-123.
        •    Testing plan and identification of high-risk reported data, including specific
             data the agency determines to be high-risk that are explicitly referenced by
             the DATA Act, confirmation that these data are linked through the inclusion
             of the award identifier in the agency’s financial system, and reported with
             plain English award descriptions.
        •    Actions taken to manage identified risks.12
Because the DQP did not exist when the first quarter 2019 data was submitted, risks to data
quality in the RRB’s spending data may not have been identified or managed. The RRB may also
have imposed duplicative and unnecessary processes to publish their quarterly submissions,
due to the lack of a clear organizational structure and key processes to provide internal controls
over financial and award data reporting. If the conditions we described are not corrected, the


11
  OMB, M-18-16.
12
  OMB, M-18-16.
Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01       9
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completeness, accuracy, timeliness, and quality of the data submitted, or implementation and
use of the data standards in future DATA Act submissions may be adversely impacted.

Management’s Written Assurance and Statement of Accountability was
Incomplete

During the RRB’s DATA Act submission, the RRB’s management (1) leveraged data quality and
management controls established in statute, regulation, and governmentwide policy,
(2) aligned data quality controls with the internal control and risk management strategies in
OMB M-18-16, and (3) did not identify any deficiencies in internal control or other limitations
that would prevent the SAO from certifying that the data submitted for publication on
USASpending.gov was complete, accurate, timely, of quality, and complied with the established
governmentwide financial and award data standards. However, the SAO’s quarterly assurance
statement, obtained from USASpending.gov, did not contain a statement of accountability to
confirm the RRB’s efforts to support data quality and assurances on interconnectivity/linkages
across all the data files.

According to OMB guidance, “[a]s stated in MPM 2016-03 agency DATA Act SAOs or their
designees must provide a quarterly assurance that their agency's internal controls support the
reliability and validity of the agency account-level and award-level data reported for display on
USASpending.gov.” 13 In general, the required assurance is a statement of accountability to
confirm an agency’s efforts to support data quality. According to OMB guidance, the agency
SAO assurances should be submitted quarterly through the DATA Act Broker process. This
process requires the SAO to assure that the alignment among Files A through F and the data in
each file submitted for display on USASpending.gov were valid and reliable. 14

During the DATA Act submission process, the RRB identified misalignments when comparing
File C and File D1; but, they did not provide comments regarding this in the quarterly assurance
statement comment boxes available on the DATA Act Broker. The misalignments were among
Procurement Instrument Identifier Numbers (PIID)

        60RRBH19P0080 – $9,324.07, which appeared in File C but not in File D1;
        RRB15C006 A00005 – $86,591, which appeared in File D1 but not File C; and
        RRB17A0046 P00002 and RRB17D0001 P00002 – $0.00, which each appeared in File D1
         but not in File C.
OMB guidance and DAIMS v 1.3 Practices and Procedures explain where there are legitimate
differences between files, the SAO should provide categorical explanations for misalignments.15



13
   OMB, M-17-04 and MPM 2016-03.
14
   Since a DATA Act submission contains a combination of many data sets, assurance over alignment requires the
Senior Accountable Official (SAO) to attest to the interconnectivity/linkages (e.g. award ID linkage) across all the
data in Files A, B, C, D, E, and F.
15
   OMB M-17-04 and Department of Treasury (Treasury), DATA Act Information Model Schema (DAIMS) Practices
and Procedures For DATA Broker Submissions v 1.3 (June 29, 2018).
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These explanations can be entered into a separate comment box available for each file being
certified. These comments are made public along with the certified files on USASpending.gov.

Further, the SAO did not attest to the interconnectivity/linkages across all the data files. We
discuss linkage issues in the sections titled The Agency did not Achieve Automatic Linkage for
New Aggregate Records and Gaps Exist Between Authoritative Sources and Actual Sources.

Neither the SAO nor designee knew that a statement of accountability was a quarterly
requirement when they developed written statements certifying the completeness, accuracy,
and timeliness of the data submitted to address previous OIG audit recommendations. 16
Instead, they attempted to address it once by stating, “[a]s the Senior Accountable Official, it is
my opinion that RRB’s comprehensive review process for Data Act file submissions provides the
internal controls to support the reliability and validity of the data submitted to Treasury for
publication on USASpending.gov under the DATA Act.” Additionally, the SAO thought the
designee’s certification for each quarterly submission through the DATA Act Broker application
was adequate.

As a result, taxpayers and policy makers could be led to believe the alignment among the RRB’s
Files A through F were valid and reliable, and the RRB’s data in each DATA Act file submitted for
display on USASpending.gov were also valid and reliable. If the conditions we described are not
corrected, they may adversely impact the completeness, accuracy timeliness, and quality of the
data submitted, or implementation and use of the data standards in future DATA Act
submissions.

On August 9, 2019, the RRB provided OIG auditors with a draft of the SAO quarterly assurance
statement that they planned to use during the next DATA Act submission. The statement was
not evaluated as it was not within the scope of this audit.

RRB’s DATA Act Policies and Procedures Need Improvement

The RRB’s policies and procedures contained minimum standards and information for the RRB
to manage and facilitate the reporting of financial and award data in accordance with the
requirements of the DATA Act. 17 Even though the procedures included various controls to
ensure overall quality of the data, deficiencies were identified and improvements could be
made. We determined that BFO did not include Actuary’s efforts in preparing File D2 in BFO’s
revised procedures titled, Data Act Process Flow, last updated on May 22, 2019.18 Actuary
compiled and reported the benefit payment information using various preexisting processes,
then uploaded it to the Financial Assistance Broker Submission (FABS) portal. Once it was


16
   Railroad Retirement Board (RRB) Office of Inspector General (OIG), Railroad Retirement Board’s Initial DATA Act
Submission, While Timely, Was Not Complete or Accurate, Report No. 18-01 (Chicago, IL; November 8, 2017).
17
   Pub. L. No. 113-101 (2014).
18
   According to the RRB, the Data Act Process Flow established comprehensive controls and procedures covering
the submission and certification of RRB’s DATA Act files, to include review of source and resulting data to be
submitted. They explained that these procedures detail the contractor staff responsibilities; and the roles and
responsibilities associated with ensuring accurate and complete DATA Act files for all responsible or designated
RRB staff.
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uploaded to FABS, it was available for download as File D2. The D2 file is the foundation of the
RRB’s DATA Act reporting because File C is created and generated based on information
contained in Files D1 and D2. File C contained 33,125 records, of which 33,057 of them came
from File D2. The 33,057 records accounted for $3.2 billion of the $4.1 billion reported on the
USASpending website.19 Additionally, we determined there were no procedures established to
ensure File A and B totals matched.

Throughout our fieldwork, we had to request supplemental documentation, including flow
charts, as there were limited details in the RRB’s Data Act Process Flow on how the RRB’s
contractor CGI, BFO, Actuary, and AM actually compiled and converted the source data into the
governmentwide financial data standards established by the OMB and Treasury.

According to Government Accountability Office (GAO), Standards for Internal Control in the
Federal Government, “[i]nternal control comprises the plans, methods, policies, and procedures
used to fulfill the mission, strategic plan, goals, and objectives of the entity.” 20 Management
should implement control activities through policies, which should be documented in the
appropriate level of detail to allow management to effectively monitor the activity. Accordingly,
management is responsible for designing policies and procedures to fit the agency’s situation.

BFO did not object to our observation relating to BFO not including Actuary’s effort in preparing
Files C and D2 in its revised procedures. But, they did not provide an explanation regarding why
this omission occurred. On August 9, 2019, the RRB provided OIG auditors with an updated
Data Act Process Flow. We did not evaluate the new Data Act Process Flow because it was not
within the scope of this audit.

The risk of the RRB’s controls failing at anytime is high due to the lack of written, detailed, and
inclusive procedures, which may adversely impact the completeness, accuracy timeliness, and
quality of the data submitted, or implementation and use of the data standards in future DATA
Act submissions.

Recommendations

We recommend that the Bureau of Fiscal Operations

     1. base the Railroad Retirement Board’s DATA Act quarterly submission and certification
        on the Railroad Retirement Board’s Data Quality Plan;
     2. provide a quarterly assurance statement that the agency’s internal controls support the
        reliability and validity of the agency account-level and award-level data reported for
        display on USASpending.gov in accordance with Office of Management and Budget
        Management Procedures Memorandum 2016-03 and Memorandum M-17-04. This
        statement should include assurances on interconnectivity/linkages across all the data in
        Files A, B, C, D, E, and F;


19
  See Table 1 and Table 2 for additional details.
20
  Government Accountability Office (GAO), Standards for Internal Control in the Federal Government,
GAO 14-704G (Washington, D.C.: September 2014).
Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01           12
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    3. ensure the Senior Accountable Official or the Senior Accountable Official’s designee,
       including the DATA Act Certifier, obtain DATA Act training to ensure they have an
       understanding of the DATA Act’s required written assurance statement, including the
       statement of accountability; and
    4. update and expand the Railroad Retirement Board’s DATA Act Process Flow to include
       the Bureau of Actuary and Research’s efforts in preparing the financial assistance award
       portion of the DATA Act submission.

Management’s Comments and Our Response

For recommendations 1, 2, 3, and 4, BFO concurred with our recommendations. For
recommendation 4, BFO stated

    We concur that the DATA Act Process Flow needed to be updated to include discussion
    of Bureau of Actuary and Research’s efforts in preparing the financial assistance
    award portion of the DATA Act submission. As such, corrective action was taken during
    the course of your audit and the updated document was provided to your office on
    August 9, 2019.
We were able to conduct a review of the August 9, 2019 documents after the exit conference
and issuance of the draft report. We determined that the updated DATA Act Process Flow in
conjunction with the RRB’s DQP met the intent of recommendation 4. Therefore, we consider
recommendation 4 implemented and closed. Please note that a full review of the RRB’s new
DQP was not completed during the course of this audit. In our opinion, auditors must consider
both documents when referring to the RRB’s policies and procedures as they related to
DATA Act reporting. This should be noted for future reviews and audits.

RRB’s DATA Act Certification and Submission were Generally Complete
but Need Improvement on Timeliness and Accuracy
The RRB’s first quarter of fiscal year 2019 DATA Act submission was generally complete and
partially accurate at the summary-level, but not timely. We determined the SAO designee
submitted and certified the data for publication on USASpending.gov one day late. To be
considered timely, the SAO’s certification should have been provided on or before
March 20, 2019. Even though the submission was generally complete and partially accurate,
there is need for improvement in addressing DATA Broker validation warnings, conducting
reconciliations, obtaining interconnectivity/linkages across all data files, and timeliness.

The Agency’s Submission for Files A, B, and C was Generally Complete

The RRB’s first quarter of fiscal year 2019 DATA Act submission was generally complete. We
evaluated RRB’s Files A, B, and C that were submitted to the DATA Act Broker. Our evaluation
consisted of Treasury Account Symbol (TAS) to SF-133 comparisons, file to file comparisons, and
a review of Broker warnings. Table 4 summarizes our comparisons.




Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01    13
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Table 4. OIG Evaluation of Files A, B, and C
      File   Was the File                                                                                          Percent
                                                   If yes or no, why?                               Effect
     Name    Complete?                                                                                            Complete
 File A      Yes                  Matched SF-133s.                                                                  100 %

 File B      Yes                  All TASs in File A were accounted for in File B.                                  100 %
 File C      No                   Micro-purchases were included in File D1 but                 Understated           99 %
                                   not File C.                                                  by $86,591a
Source: RRB OIG analysis of Files A, B, and C.
a After examining File C for completeness, linkage to File B, and linkage to Files D1/D2, we determined File C was missing one

record in an amount of $86,591. However, this record was not required to be reported in File C per DAIMS v 1.3 Practices and
Procedures. Micro-purchase transactions are not required to be entered into FPDS-NG. Information entered into FPDS-NG
directly effects File D1 which directly effects File C.

Accuracy of Summary-Level Data for Files A and B and Linkages Need
Improvement

We determined that BFO submitted inaccurate data for File B on USASpending.gov and did not
ensure linkages were automatic between the RRB’s financial and award systems. There is need
for improvement in addressing Broker validation warnings and conducting reconciliations. Our
test work noted variances between Files A, B, and C. See Tables 5 and 6 for details pertaining to
Files A and B.

The Agency’s File B was Inaccurate
We determined that File A was accurate when matched against comparable information found
in the RRB’s SF-133. However, File B was inaccurate when matched against File A and when
matched against the President’s Budget.21

We conducted two different comparisons between Files A and B. In the first, we compared
gross outlays and in the second, we compared obligation amounts. According to
USASpending.gov, an outlay occurs when federal money is actually paid out, not just promised
to be paid. A promise to pay is known as an obligation and is a binding agreement. An agency
incurs an obligation, for example, when it places an order, signs a contract, awards a grant,
purchases a service, or takes other actions that require it to make a payment.

As shown in Table 5, we compared gross outlay amounts and determined File B was
understated by $8.1 million. According to DAIMS validation rule A18, gross outlay amount by
TAS found in File A should be equal to the sum of all gross outlay amount by program object
class in File B.




21
  OMB, Appendix, Budget of the United States Government, Fiscal Year 2019, Detailed Budget Estimates
(Washington, D.C.: February 2018).
Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01                                  14
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Table 5. File A to File B Variances Rule A18
           File A’s Sum of Gross Outlay           File B’s Sum of Gross Outlay                     Difference
  TAS
                      Amount                                 Amount                              (File A - File B)
8010             (1,823,287,650.45)                     (1,824,741,891.22)                        1,454,240.77
8011             (1,402,765,534.79)                     (1,402,827,144.22)                          61,609.43
8118              (377,004,811.87)                       (377,004,811.90)                              0.03
0113              (231,294,626.89)                       (231,294,626.90)                              0.01
8237               (37,534,268.34)                        (28,035,199.47)                        (9,499,068.87)
8051               (32,045,783.21)                        (31,884,543.59)                         (161,239.62)
0111                (4,506,286.34)                        (4,540,128.61)                            33,842.27
8018                (3,445,140.51)                        (3,445,140.51)                               0.00
0114                  (5,561.95)                                0.00                                (5,561.95)
0117                  (3,280.02)                               907.18                               (4,187.20)
Total            (3,911,892,944.37)                     (3,903,772,579.24)                       (8,120,365.13)
Source: RRB OIG analysis and review of Files A and B. DATA Act Information Model Schema (DAIMS) Validation Rules v1.3.1,
revision date February 8, 2019.

As shown in Table 6, we compared obligation amounts and determined File B was overstated by
$1.15 million. According to DAIMS validation rule A19, File A’s obligations incurred total by TAS
should be equal to the negative sum of obligations incurred by program object class in File B as
of the same reporting period.




Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01                                15
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Table 6. File A to File B Variances Rule A19
                                        File A’s Sum of                 File B’s Sum of                  Difference
     TAS    USASpending.gov
                                      Obligations Incurred            Obligations Incurred             (File A - File B)
 8010         1,894,233,965             1,894,233,964.92                (1,894,233,965.04)                  (0.12)
 8011         1,486,791,721             1,486,791,720.77                (1,486,791,720.98)                  (0.21)
 8118         377,004,812                377,004,811.87                  (377,004,811.90)                   (0.03)
 0113         231,294,627                231,294,626.89                  (231,294,626.90)                   (0.01)
 8237          57,007,164                 56,562,459.30                  (57,007,164.40)                (444,705.10)
 8051          45,305,894                 45,305,894.07                  (45,305,894.07)                    (0.00)
 0111           4,536,252                  4,537,830.46                   (4,536,252.45)                  1,578.01
 8018           3,764,331                  3,057,376.36                   (3,764,331.30)                (706,954.94)
 0117             2,141                      2,141.32                        (2,141.32)                     (0.00)
 0114                --                           --                              --                           --
 Total        4,099,940,908             4,098,790,825.96                (4,099,940,908.36)             (1,150,082.40)
Source: RRB OIG analysis and review of Files A, B, and USASpending.gov’s Spending Explorer tool. DATA Act Information Model
Schema (DAIMS) Validation Rules v1.3.1, revision date February 8, 2019.

During RRB’s pre-certification process through the Broker, misalignments were identified
between Files A and B but not addressed. The SAO designee could not support why this
occurred and claimed that the differences between Files A and B were due to timing and were
not material. Further, the designee did not reconcile or validate File B to ensure it was accurate.
During our fieldwork, BFO tried to determine the cause of the differences and claimed that the
same issue has not recurred since they revised their reconciliation procedures. After further
review, we determined that the raw File B CGI generated matched File A. This led us to believe
that CGI could have potentially used the wrong File B or had a breakdown in their SQL coding
and that it was not a timing issue. We shared this information with RRB management during
the exit conference.

Additionally, we determined File B’s program activity names and codes were inaccurate when
compared to the President’s Budget: 22

          In File B, TAS 0114 and 0117 had a code of 0003 (Railroad Unemployment Insurance
           Trust Fund), yet neither fund in the President’s Budget contained that code.
          The President’s Budget contained code 0002 (Railroad Social Security Equivalent
           Benefit) under TAS 8237 and 8018 yet this code was absent from File B.




22
  OMB, Appendix, Budget of the United States Government, Fiscal Year 2019, Detailed Budget Estimates.
Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01                                16
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        File B contained a code that did not match the program activity name under TAS 8237.
         The code 0001 was used for (Medicare and other reimbursements) instead of the
         correct code 0801.23
We believe the discrepancies with File B and the President’s Budget was attributable to CGI’s
SQL command statement used to query the Financial Management Integrated System (FMIS) to
prepare File B as the program activity names and codes were populated based on a conditional
script.

Lack of reconciliation procedures and inaction towards Broker warnings resulted in the
submission of inaccurate, unreliable, and inconsistent summary level data. Since File B was
inaccurate, the primary USASpending.gov screen for the RRB was also inaccurate and
overstated by $1.15 million or 0.03 percent of total obligations reported.24 As a result,
taxpayers and policy makers could not fully rely on the RRB’s data to track federal spending
more effectively. If left unchecked, this could lead to decreased accountability and
transparency in federal spending across the Federal Government.

The Agency did not Achieve Automatic Linkage for New Aggregate Records
The RRB did not meet OMB’s deadline for automatic linkages. BFO did not ensure URI linkages
were automatic between the RRB’s financial and award systems in accordance with OMB
guidance.25 For the RRB’s DATA Act reporting, URIs are used only for financial assistance awards
and not procurement awards. 26

According to OMB guidance, agencies that are unable to include the URI in management and
financial systems for county level aggregate records displayed beginning May 2017 may
manually link the award and financial data in their submission (award financial file - File C) using
URI. All agencies will be required to achieve the automatic linkage for new aggregate records
between the financial and award management systems by October 1, 2018. 27

Actuary explained that URIs were manually created when they prepared the financial assistance
awards data for the monthly FABS reporting. BFO explained that the RRB is not currently in a
position to use FMIS as the source of data for financial assistance awards because there is no
automated interface between FMIS and its benefit paying systems. We discuss this further in
the section titled Gaps Exist Between Authoritative Sources and Actual Sources.

Lack of automatic linkages, could lead to decreased user capability. According to OMB, they
want users to have the same spending lifecycle view as provided through use of the Award ID
linkage.


23
   Potentially stemming from the same program activity name issue, we found a variance between File C and
File B’s program activity names for PIID 60RRBH19F0079, Parent Award ID GS35F198CA.
24
   We were unable to view the effect of the understated gross outlay total of $8.1 million through the
USASpending.gov’s spending explorer tool.
25
   OMB, M-17-04.
26
   As defined per DATA.gov, a Unique Record Identifier (URI) is an agency defined identifier that (when provided) is
unique for every reported action.
27
   OMB, M-17-04.
Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01                      17
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The Agency’s Submission was not Timely

The SAO designee submitted and certified the RRB's first quarter of fiscal year 2019 financial
and award data for publication on USASpending.gov one day late. The submission and
certification occurred on March 21, 2019.

According to the CIGIE FAEC guide, an agency submission should be considered timely when the
submission by the agency to the DATA Act Broker is in accordance with the reporting schedule
established by the Treasury DATA Act Project Management Office, which is traditionally within
45 days of quarter end. Due to a government shutdown, the due date for agency submissions
for first quarter of fiscal year 2019 was extended to March 20, 2019.

In response to our entrance conference, BFO provided us DATA Act submission documents and
emails. One email included the new due date of Wednesday, March 20, 2019, which the SAO
designee forwarded to the appropriate RRB DATA Act points of contact. In contradiction to the
emails, the SAO designee stated they were confused about the due date as it was changed due
to a partial government shutdown. According to the SAO designee, they tried to obtain the
submission deadline schedule from MAX.gov but could not access it at the time.

Late DATA Act submissions could contribute to decreased accountability and transparency in
federal spending across the Federal Government and the prevention of taxpayers and policy
makers to track federal spending more effectively.

Sample Results – The RRB’s Data was of Higher Quality

We determined that RRB’s data was considered of Higher quality based on the CIGIE FAEC
Guide. The Higher quality rating was determined as a result of our statistically random sample
shown in Appendix III.

Based on the sample, the RRB’s projected error rates for completeness, accuracy, and
timeliness were 0.00 percent, 0.43 percent, and 0.00 percent, respectively. The highest of the
three error rates was used as the determining factor of quality, which was 0.43 percent. Using
Table 7, the rate of 0.43 percent placed the RRB in the Higher category.


Table 7. Levels of Data Quality
 Error Rate                 Quality Level
       0% - 20%             Higher
      21% - 40%             Moderate
 41% and above              Lower
Source: CIGIE FAEC Guide.

As part of the statistically valid random sample of 385 records, we tested 52 of the 57 data
elements for completeness, accuracy, and timeliness. 28 To conduct the data element analysis,

28
  Per CIGIE FAEC Guide, we were not required to test all 57 data elements. See Appendix IV for details.
Audit of RRB’s DATA Act Submission for First Quarter of Fiscal Year 2019 - Report No. 20-01               18
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we first had to determine if the element was required or applicable per award type,
aggregation type, and CIGIE FAEC guidance. See Appendix IV for information on the 52 tested
data elements.

The substantial decrease in error rate for the sample was attributed to CIGIE’s 2019 prescribed
sampling approach, the aggregation of data, and the RRB’s existing financial assistance award
reporting process. The RRB improved its accuracy error rate for the sample from 91 percent to
0.43 percent in two years.

This occurred partially because the composition of the sample universe changed from 2017,
including the approach. The 2017 auditors were limited to sampling solely from File D1, which
consisted of procurement awards only, rather than from the preferred File C, which also
included financial assistance awards. For the 2017 audit, the team determined they could not
sample from File C because it was missing two months of financial assistance award data.
Therefore, it was incomplete and not suitable for sampling. When we conducted our suitability
for sampling test of File C in 2019, we determined it was complete and could follow CIGIE’s
sampling methodology. Therefore, we sampled from File C which contained 384 financial
assistance awards and 1 procurement award. Further, the 2017 sampling results were
concluded on a pass or fail basis, whereas, this audit’s error rate conclusion was based on the
numerical average of the percentage of actual errors of individual data elements in each
sample.

Additionally, we attributed the improved error rate to the financial assistance award reporting
requirements which allowed for an aggregation of data. This reduced the amount of individual
information reported and the amount of unique data to be tested. In contrast, procurement
transactions contained a variety of information unique to each transaction and criteria. Lastly,
the RRB compiled its financial assistance award data based on previously established FAADS+
reporting process, which was already consistent with DATA Act requirements.

For the fiscal year 2019 errors, we determined the majority of the errors found pertained to the
inaccurate use of FAIN, data element (DE) 34, while reporting aggregate records. 29 As described
in the section titled Some Financial Assistance Awards Containing Personally Identifiable
Information were Incorrectly Reported, Actuary did not appropriately apply OMB guidance
when reporting financial assistance awards containing PII as they used FAIN to distinguish
foreign benefit payments from domestic instead of using FAIN to report a single award
containing PII. 30 FAIN is intended to be used for individual records not aggregates.

Additionally, we found a few errors pertaining to the one procurement transaction sampled.
We found accuracy errors with Appropriations Account (DE 51) in File C and Legal Entity
Address (DE 5), Award Type (DE 16), Period of Performance Start Date (DE 26), Ordering Period



29
   As defined on DATA.gov, a Unique Record Identifier (URI) is an agency defined identifier that (when provided) is
unique for every reported action. The Federal Award Identification Number (FAIN) is the unique ID within the
Federal agency for each (non-aggregate) financial assistance award.
30
   OMB, M-17-04.
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End Date (DE 29), and Primary Place of Performance Address (DE 30) in File D1. The remaining
errors pertained to other financial assistance awards. For details refer to Appendices III and IV.

Recommendations

We recommend Bureau of Fiscal Operations

    5. ensure a reconciliation between Files A, B, C, D1, and D2 occur before the Railroad
       Retirement Board’s DATA Act submission and certification is finalized each quarter;
    6. ensure DATA Act Broker warnings are addressed each quarter, if necessary, document
       any misalignments among Files A, B, C, D1, and D2 that were submitted for display on
       USASpending.gov;
    7. update and expand the Railroad Retirement Board’s DATA Act Process Flow to include
       the Railroad Retirement Board’s DATA Act reconciliation processes for Files A, B, C, D1,
       and D2; and
    8. develop a process to ensure the DATA Act Certifier provides the Railroad Retirement
       Board’s DATA Act submission and certification on or before each quarterly due date.

Management’s Comments and Our Response

For recommendations 5, 6, 7, and 8, BFO concurred with our recommendations. For
recommendation 7, BFO stated

    We concur that the DATA Act Process Flow needed to be updated to include discussion
    of Railroad Retirement Board’s DATA Act reconciliation processes for Files A, B, C, D1,
    and D2. As such, corrective action was taken during the course of your audit and the
    updated document was provided to your office on August 9, 2019.
We were able to conduct a review of the August 9, 2019 documents after the exit conference
and issuance of the draft report. We determined that the updated DATA Act Process Flow in
conjunction with the RRB’s DQP met the intent of recommendation 7. Therefore, we consider
recommendation 7 implemented and closed. Please note that a full review of the RRB’s new
DQP was not completed during the course of this audit. In our opinion, auditors must consider
both documents when referring to the RRB’s policies and procedures as they related to
DATA Act reporting. This should be noted for future reviews and audits.

The RRB’s Implementation and Use of the Data Standards Could be
Improved
We determined the RRB generally implemented and used the governmentwide financial data
standards for spending information as developed by OMB and Treasury. However, we noted
that improvements could be made to the reporting of financial assistance awards containing PII
and resolving gaps between authoritative sources and actual sources.




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Some Financial Assistance Awards Containing Personally Identifiable
Information were Incorrectly Reported

As previously cited, Actuary did not appropriately apply OMB M-17-04 guidance when reporting
financial assistance awards containing PII as they used FAIN to distinguish foreign benefit
payments from domestic instead of using FAIN to report a single award containing PII. 31

According to OMB guidance, to ensure maximum transparency in federal spending, agencies
must report each financial assistance award at the most granular level practicable while
protecting PII. 32 Given the required data collections, if reporting at the single award level is not
practicable, agencies may report at the county level, and if not practicable, aggregated at the
state level. Actuary reports RRB’s financial assistance awards aggregated at the county level,
therefore, records reported this way must be linked using the URI.

According to Actuary, Treasury advised the RRB to report foreign financial assistance awards
using FAIN. Actuary obtained this advice from Treasury when DATA Act reporting first started.

The RRB’s erroneous use of FAIN in DATA Act reporting could lead to user misinterpretation as
a specific bundle of awards would be mistakenly presented as a single award.

Gaps Exist Between Authoritative Sources and Actual Sources

BFO and Actuary did not resolve gaps between the DATA Act authoritative sources and RRB’s
actual sources. BFO explained the financial assistance data elements do not reside in the
agency’s financial system (FMIS) because there is no automated interface between the RRB’s
benefit paying systems and the financial system. Conversely, BFO explained the required data
elements for the financial assistance portion of File C were extracted from the benefit paying
systems and sent to CGI as comma separated value files; and, they were the same files that
were uploaded, validated, and published to FABS. 33

According to OMB guidance, the authoritative source for File C’s data is the agency’s financial
system. Our evaluation and comparison of authoritative sources versus actual sources for
DATA Act is shown in Table 8, which includes a condensed version of RRB’s DATA Act File A
through D2 creation and generation process. 34




31
   As defined per DATA.gov, a Unique Record Identifier (URI) is an agency defined identifier that is unique for every
reported action. The Federal Award Identification Number (FAIN) is the unique ID within the federal agency for
each (non-aggregate) financial assistance award.
32
   OMB, M-17-04.
33
   According to Microsoft, comma separated value files, often known as a .CSV, are simple text files with rows of
data where each value is separated by a comma.
34
   OMB, MPM 2016-03 and M-17-04.
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Table 8. DATA Act Authoritative Source and RRB’s Source System
      File Name               DATA Act                          RRB’s DATA Act Reporting Process
                             Authoritative                         (Source Systems and Files)
                                Source
File A                   SF-133 derived from CGI generates File A from GTAS-133.
Appropriations           GTAS dataa
File B                   SF-133 derived from CGI generates File B from FMIS database using SQL, which
Object Class             GTAS dataa          matches GTAS-133.
Program Activity
File C                   Financial Systems         BFO/CGI generates this portion of File C from RRB’s
Award Financial -                                  Financial System (FMIS) using SQL.
Procurement
                                                   Acquisitions reviews the FMIS extracted File C for
                                                   accuracy.
File C               Financial Systems             BFO/CGI generates this portion of File C from conversion
Award Financial -                                  files derived from an Actuary produced external source
Financial Assistance                               file.
File D1           Federal                          BFO/CGI generates File D1 from DATA Act Broker. DATA
Procurement Award Procurement Data                 Act Broker generates D1 from FPDS-NG.
Attributes        System – Next
                  Generation (FPDS-                Acquisitions verifies accuracy of File D1 against their paper
                  NG)                              contract files and electronic contract files in FMIS.
File D2              Agency Award         BFO/CGI generates File D2 from DATA Act Broker. DATA
Financial Assistance Management           Act Broker generates D2 from FABS. Actuary produces the
Award Attributes     Systems or Files and FABS file also known as the external source file FAADS+.
                     SAM
                                          Actuary prepares the FAADS+ file from PREH, MBF, and
                                          MACRO, the RRB’s applicable systems of record.
Source: RRB OIG analysis of the RRB’s DATA Act reporting process, OMB MPM 2016-03, and OMB M-17-04.
a Governmentwide Treasury Account Symbol Adjusted Trial Balance System (GTAS)



According to BFO, they did not identify any other gaps except the ones described in Table 8
since the remaining required data elements in File A, File B, and File C (procurement only)
reside in the RRB’s financial system (FMIS).

The gaps occurred because the RRB is not currently in a position to use FMIS as the source of
data for financial assistance awards. BFO stated that it may be possible to request a
modification of the system to periodically accept and store financial assistance data for File C
processing in order to fit the prescribed definition of authoritative source. BFO said that such a
system modification would have any effect on the timeliness or accuracy of DATA Act reporting
beyond the current process. Gaps could have a negative impact on the timeliness or
effectiveness of RRB’s DATA Act reporting and could complicate the reporting for the RRB.




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Recommendations

We recommend the Bureau of Actuary and Research

    9. ensure financial assistance awards containing personally identifiable information are
       reported in accordance with Office of Management and Budget Memorandum M-17-04;
       and
    10. ensure DATA Act file assistance award preparers obtain training over the reporting of
        financial assistance awards containing personally identifiable information. For example,
        financial assistance award should be reported at the most granular level practicable
        while protecting personally identifiable information. The RRB and Bureau of Actuary and
        Research should consider the different available Record Types as described in
        Appendix V.
We recommend the Bureau of Fiscal Operations

    11. develop a plan to obtain an automated interface between the RRB’s benefit paying
        systems and the RRB’s financial system that would ensure the RRB is in compliance with
        Office of Management and Budget Management Performance Memorandum 2016-03
        and Office of Management and Budget Memorandum M-17-04.

Management’s Comments and Our Response

For recommendations 9 and 10, Actuary concurred with our recommendations. However,
Actuary has not provided target completion dates in its management comments.

For recommendation 11, BFO concurred with our recommendation and stated

    As agreed to by the Audit Manager via discussion on October 30, 2019, RRB will meet
    the intent of this recommendation by discussing this matter further with the Office of
    Management Budget.




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                           APPENDIX I: MANAGEMENT COMMENTS




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                          APPENDIX II: MANAGEMENT COMMENTS




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                         APPENDIX III: SAMPLING METHODOLOGY
This appendix presents the methodology and results of our statistical sample to assess the
completeness, accuracy, timeliness, and overall quality of selected required data fields
submitted as part of Railroad Retirement Board’s (RRB) Digital Accountability and Transparency
Act of 2014 (DATA Act) for File C.

Scope
As recommended by the Council of the Inspectors General on Integrity and Efficiency (CIGIE)
Federal Audit Executive Committee (FAEC) Inspectors General Guide to Compliance under the
DATA Act (CIGIE FAEC Guide), our sample was selected from the award financial detail data
included in RRB’s DATA Act File C submission for the first quarter of fiscal year 2019, submitted
for publication on USASpending.gov. This file consisted of financial assistance awards (benefit
payments) and procurement transactions for the period October 1, 2018 through
December 31, 2018. This universe included financial assistance awards (benefit payments) and
procurement award transactions (new awards and modifications to existing awards) made by
RRB. The universe consisted of 33,125 award financial detail records found in File C. Of the
33,125 records, 68 were procurement award and 33,057 were financial assistance awards.

Review Methodology
We used attribute sampling to test the completeness, accuracy, and timeliness of data reported
for each record in File C. A record is considered a row in the data file within File C. A record
could be a portion of a transaction or award activity and not necessarily the whole transaction
or award activity. In our sample, a sampling unit is either a procurement award identified with
unique Procurement Instrument Identifier Numbers (PIID) or financial assistance award
identified with the Financial Assistance Identifier Numbers (FAIN) or Unique Record Identifiers
(URI). All sampling units in the universe were eligible for random sample selection.

We selected our sample from procurement and benefit payment transactions in File C because
the file was deemed suitable for sampling according to the CIGIE FAEC Guide.

Based on sampling criteria contained in guidance for this audit, the sample had an expected
error rate of 50 percent, desired precision rate of 5 percent, and desired confidence level of
95 percent. This resulted in a sample size of 385 transactions, which is at the limit according to
the CIGIE FAEC Guide. We selected a statistically valid simple random sample using TeamMate
Analytics software. OIG transactions were not selected in our sample. Once the sample was
selected from File C, we

    1. confirmed the sample selected was included in File D1 to test corresponding D1 data
       elements;
    2. confirmed the financial assistance awards selected matched the FAIN/URI in File D2 to
       test corresponding data elements;
    3. determined the aggregate records were reported consistently with OMB M-17-04;
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     4. determined if the data element was required and included for the record selected;
     5. determined the accuracy of applicable data elements in Files D1 and D2;
     6. determined the timeliness of data elements;
     7. calculated and projected the overall error rates; and
     8. determined the overall quality of data sampled based on a scale of Higher, Moderate, or
        Lower.
We used CIGIE FAEC’s Testing Results Spreadsheet tool in summarizing the results of the
detailed record-level test of each sample and each of the data elements for Files C, D1, and D2.
According to the CIGIE FAEC Guide, completeness, accuracy and timeliness of data elements
will be tested independently of each other but may overlap.35 An error of one kind does not
preclude nor assume an error of another kind.

For completeness, we considered the sample item or data element to be an error when the
data element fields was left empty or if a data element that was required to be reported, was
not reported. For accuracy, we considered the sample item or data element to be an error if the
data did not agree with the authoritative source records. For timeliness, we considered the
sample item or data element to be an error if the data reported was not reported within the
quarter in which it occurred; was not reported in FPDS-NG within 3 business days after contract
award; or was not reported within 30 days after award, in accordance with FFATA.

During our sampling, we made a decision to test the 384 financial assistance award records
against Treasury’s Record Type 1 criteria because the RRB erroneously used FAIN instead of
URI, therefore, incorrectly reported the associated record as Record Type 2. 36 This effected 5 of
the 384 financial assistance award records sampled. Aggregate reporting criteria is shown in
Appendix V.

We calculated the overall error rate for completeness, accuracy, and timeliness for each sample
item and data element based on the results of the testing of the data elements found in
Appendix IV and CIGIE FAEC’s Testing Results Spreadsheet tool as shown in Table 9.

For quality, we used the results of the statistical sample in order to provide a range of results. If
the highest error rate of completeness, accuracy and timeliness is between 0 percent and
20 percent then the quality would be considered Higher. If the highest error rate is between
21 percent and 40 percent then the quality would be considered Moderate. If the highest error
rate is 41 percent or more, then the quality would be considered Lower.

Results
We reviewed a sample of 385 award financial detail, drawn from a population of 33,125 records
in File C. The data element tested and results of tests for the attributes of completeness,
accuracy, and timeliness for each data element are detailed in Appendix IV. The sample tested

35
  Refer to Appendix IV for data element analysis.
36
  Source: U.S. Dept. of Treasury, DATA Act Information Model Schema (DAIMS) Practices and Procedures for DATA
Act Broker Submissions Version 1.3, (June 29, 2018).
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and results of each individual sample was based on CIGIE FAEC’s Testing Results Spreadsheet
tool and maintained in our audit files. In order to provide the stakeholders with easy to discern
information regarding the 385 samples, we provided an extract of our testing spreadsheet in
Table 9.


Table 9. RRB Results Per Sample Record
         A                     B                 C             D             E               F    G            H
      Sample              Total #                # Incomplete                # Inaccurate         # Untimely
     Record #          Data Elements
         27                    40                0          0.00 %           8          20.00 %   0         0.00 %
         60                    40                0          0.00 %           8          20.00 %   0         0.00 %
         92                    40                0          0.00 %           2          5.00 %    0         0.00 %
        127                    40                0          0.00 %           2          5.00 %    0         0.00 %
        137                    40                0          0.00 %           2          5.00 %    0         0.00 %
        138                    40                0          0.00 %           8          20.00 %   0         0.00 %
        159                    40                0          0.00 %           8          20.00 %   0         0.00 %
        161                    44                0          0.00 %           6          13.64 %   0         0.00 %
        190                    40                0          0.00 %           2          5.00 %    0         0.00 %
        239                    40                0          0.00 %           2          5.00 %    0         0.00 %
        285                    40                0          0.00 %           2          5.00 %    0         0.00 %
        323                    40                0          0.00 %           2          5.00 %    0         0.00 %
        330                    40                0          0.00 %           2          5.00 %    0         0.00 %
        332                    40                0          0.00 %           2          5.00 %    0         0.00 %
        350                    40                0          0.00 %           2          5.00 %    0         0.00 %
        380                    40                0          0.00 %           8          20.00 %   0         0.00 %
All Others                     40                0          0.00 %           0          0.00 %    0         0.00 %
Total Errors                                            0                         66a                   0
Error Rate                                           0.00 %                      0.43 %b              0.00 %
Source: RRB OIG Analysis of 385 samples and CIGIE FAEC’s Testing Results Spreadsheet tool.
a Total errors of 66 = Sum of column E.
b Error rate of 0.43 = Sum of column F divided by 385.



Conclusion
Based on the sample of 385 records, we determined the RRB’s overall projected error rates for
completeness, accuracy, and timeliness were 0.00 percent, 0.43 percent, and 0.00 percent,
respectively.
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The highest error rate was 0.43 percent, which is considered a quality of Higher since it was
between 0 percent and 20 percent as shown in Table 7. Therefore, the RRB’s data was
determined to be of Higher quality.




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             APPENDIX IV: RRB’S RESULTS FOR THE DATA ELEMENTS
Table 10 summarizes the results of our data element testing. We sorted the results by error
rate in order to provide the stakeholders with easy to discern information regarding which data
elements were determined to have the highest instances of error. Table 10 is based on the
results of our testing of 384 financial assistance records and 1 procurement record submitted in
RRB’s first quarter of fiscal year 2019 DATA Act submission. Since the RRB did not have a DQP at
the time of submission, we were unable to determine whether these risks were consistent with
the risks identified in its applicable DQP.


Table 10.          RRB’s Results for Data Elements
                             Completeness (C), Accuracy (A), and Timeliness (T)
                                                                                              Error Ratea
   Data       Errors
 Element      Found                       Data Element Name                             #     C%     A%     T%
 Number       in File
     6       D2         Legal Entity Congressional District                            10     0.00   2.60 0.00
    31       D2         Primary Place of Performance Congressional District            10     0.00   2.60 0.00
    34       C/D2       Award ID Number (PIID/FAIN/URI)                                10     0.00   2.60 0.00
     5       D1/D2      Legal Entity Address                                            6     0.00   1.56 0.00
    26       D1/D2      Period of Performance Start Date                                6     0.00   1.56 0.00
     1       D2         Awardee/Recipient Legal Entity Name                             5     0.00   1.30 0.00
    27       D2         Period of Performance Current End Date                          5     0.00   1.30 0.00
    35       D2         Record Type                                                     5     0.00   1.30 0.00
    36       D2         Action Type                                                     5     0.00   1.30 0.00
    16       D1         Award Type                                                      1     0.00   0.26 0.00
    29       D1         Ordering Period End Date                                        1     0.00   0.26 0.00
    30       D1         Primary Place of Performance Address                            1     0.00   0.26 0.00
    51       C          Appropriations Account                                          1     0.00   0.26 0.00
     2       n/a        Awardee/Recipient Unique Identifier                             0     0.00   0.00 0.00
     3       n/a        Ultimate Parent Unique Identifier                               0     0.00   0.00 0.00
     4       n/a        Ultimate Parent Legal Entity Name                               0     0.00   0.00 0.00
     7       n/a        Legal Entity Country Code                                       0     0.00   0.00 0.00
     8       n/a        Legal Entity Country Name                                       0     0.00   0.00 0.00
    11       n/a        Federal Action Obligation                                       0     0.00   0.00 0.00

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                             Completeness (C), Accuracy (A), and Timeliness (T)
                                                                                              Error Ratea
   Data       Errors
 Element      Found                       Data Element Name                             #     C%     A%     T%
 Number       in File
    12       n/a        Non-Federal Funding Amount                                      0     0.00   0.00 0.00
    13       n/a        Amount of Award                                                 0     0.00   0.00 0.00
    14       n/a        Current Total Value of Award                                    0     0.00   0.00 0.00
    15       n/a        Potential Total Value of Award                                  0     0.00   0.00 0.00
    17       n/a        NAICS Code                                                      0     0.00   0.00 0.00
    18       n/a        NAICS Description                                               0     0.00   0.00 0.00
    19       n/a        Catalog of Federal Domestic Assistance Number                   0     0.00   0.00 0.00
    20       n/a        Catalog of Federal Domestic Assistance Title                    0     0.00   0.00 0.00
    22       n/a        Award Description                                               0     0.00   0.00 0.00
    23       n/a        Award Modification/Amendment Number                             0     0.00   0.00 0.00
    24       n/a        Parent Award ID Number                                          0     0.00   0.00 0.00
    25       n/a        Action Date                                                     0     0.00   0.00 0.00
    28       n/a        Period of Performance Potential End Date                        0     0.00   0.00 0.00
    32       n/a        Primary Place of Performance Country Code                       0     0.00   0.00 0.00
    33       n/a        Primary Place of Performance Country Name                       0     0.00   0.00 0.00
    37       n/a        Business Types                                                  0     0.00   0.00 0.00
    38       n/a        Funding Agency Name                                             0     0.00   0.00 0.00
    39       n/a        Funding Agency Code                                             0     0.00   0.00 0.00
    40       n/a        Funding Sub Tier Agency Name                                    0     0.00   0.00 0.00
    41       n/a        Funding Sub Tier Agency Code                                    0     0.00   0.00 0.00
    42       n/a        Funding Office Name                                             0     0.00   0.00 0.00
    43       n/a        Funding Office Code                                             0     0.00   0.00 0.00
    44       n/a        Awarding Agency Name                                            0     0.00   0.00 0.00
    45       n/a        Awarding Agency Code                                            0     0.00   0.00 0.00
    46       n/a        Awarding Sub Tier Agency Name                                   0     0.00   0.00 0.00
    47       n/a        Awarding Sub Tier Agency Code                                   0     0.00   0.00 0.00
    48       n/a        Awarding Office Name                                            0     0.00   0.00 0.00
    49       n/a        Awarding Office Code                                            0     0.00   0.00 0.00
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                                Completeness (C), Accuracy (A), and Timeliness (T)
                                                                                                        Error Ratea
   Data        Errors
 Element       Found                           Data Element Name                                  #      C%       A%    T%
 Number        in File
     50       n/a         Object Class                                                            0     0.00      0.00 0.00
     53       n/a         Obligation                                                              0     0.00      0.00 0.00
     54       n/a         Unobligated Balance                                                     0     0.00      0.00 0.00
     56       n/a         Program Activity                                                        0     0.00      0.00 0.00
     57       n/a         Outlay                                                                  0     0.00      0.00 0.00
      9       n/a         Not Tested – Highly Compensated Officer Nameb                           --         --    --   --
     10       n/a         Not Tested – Highly Compensated Officer Total                           --         --    --   --
                          Compensationb
     21       n/a         Not Tested – Treasury Account Symbolc                                   --         --    --   --
     52       n/a         Not Tested – Budget Authority Appropriatedd                             --         --    --   --
     55       n/a         Not Tested – Other Budgetary Resourcesd                                 --         --    --   --
Source: RRB OIG Analysis – Sampling of Files C, D1, and D2.
a All estimates from the sample have a margin of error no greater than plus or minus 5 percentage points.
b We did not test DE 9 and DE 10 because they are reported in Files E and F and not in Files C, D1, or D2.
c We did not test DE 21 because it was included in DE 51 testing.
d We did not test DE 52 and DE 55 because they are reported in File A and not Files C, D1 or D2.




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           APPENDIX V: BASIC VALIDATION RULES FOR AGGREGATE AND
                        NON-AGGREGATE REPORTING
Note: Blanks in the following picture indicate the element is optional.




Source: U.S. Dept. of Treasury, DATA Act Information Model Schema (DAIMS) Practices and Procedures for DATA Act Broker
Submissions Version 1.3, (June 29, 2018)


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                                APPENDIX VI: ANOMALY LETTER
Council of the Inspectors General on Integrity and Efficiency’s DATA Act Anomaly Letter
submitted to the Senate Committee on Homeland Security and Government Affairs and the
House Committee on Oversight and Government Reform.




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