1. TOIG Required Review Approach June 8, 2017
DATA Act Required Review Updates
Pauletta P. Battle, Deputy Assistant Inspector General for Financial Management and Transparency Audits
Treasury, Office of Inspector General

2. What We’ll Talk About Today
DATA Act Brief Overview
Oversight Mandatory Requirements
Type of Engagement
Audit Objectives and Scope
Audit Approach
Audit Steps
Assessing Internal Controls
Document Requests
Managing the Challenge and Complexity of the DATA Act

3. DATA Act Brief Overview
Digital Accountability and Transparency Act of 2014
Expands Section 3 of the Federal Funding Accountability and Transparency Act (FFATA) of 2006 to increase accountability and transparency in Federal spending.
General Requirements:
By May 2015 – OMB/Treasury to issue Government-wide financial data standards
By May 2017 – Agencies to report financial data on USASpending.gov in accordance with OMB/Treasury established data standards
By May 2018 – OMB/Treasury to ensure that the established data standards are applied to the data reported on USASpending.gov

4. Oversight Mandatory Requirements
Agency Inspectors General, in consultation with GAO
Review a statistically valid sampling of the spending data submitted by the Federal agency
Submit to Congress and make publically available, a report assessing
completeness, accuracy, timeliness, and quality of the data sampled
implementation and use of Data Standards by the Federal agency
3 reviews originally due November 2016, November 2018, November 2020
Now due November 8, 2017; November 8, 2019, and November 8, 2021

5. Type of Engagement
TOIG is conducting:
A performance audit in accordance with the requirements of GAGAS as described in Chapters 6 and 7 (performance audits)

6. Audit Objectives & Scope
(1) Determine the completeness, timeliness, quality, and accuracy of fiscal year 2017, second quarter financial and payment information submitted for publication on USASpending.gov; and (2) Assess Treasury’s implementation and use of the data standards.

7. Audit Approach Coordination with TIGTA
Treasury made a single submission for publication on Beta.USASpending.gov for all Treasury bureaus and offices, including the IRS
TOIG audit assesses the implementation and use of the Government-wide financial data standards established by the OMB and Treasury for Treasury bureaus/offices, except the IRS
TOIG meets with TIGTA weekly to coordinate its audit and responsibilities with TIGTA, which has direct responsibilities for IRS

8. Audit Steps Conducted a walk through with Treasury
Treasury’s reporting entities DATA Act submissions
Broker validation checks – warnings or errors
Agency certification process – for completeness, timeliness, accuracy and quality

9. Audit Steps Statistical Sampling
We stratified Treasury’s certified data submission for File C (second quarter Treasury financial and award data) as IRS and non-IRS transactions
We then selected our sample using:
Confidence level – 95 %
Expected error rate – 50 %
Sample Precision – +/- 5 %
Resulted in approximately 366 transactions
TIGTA auditors will test IRS transactions and TOIG will test non-IRS transactions
Definition of an error and any variances will be closely coordinated and noted

10. Audit Steps Reconciliation
TOIG performed reconciliations for files A and B
File A to SF 133
File B to Object Class Codes
Following up with Treasury on variances and will assess the reasonableness of Treasury’s process to resolve variances

11. Assessing Internal Controls
As part of its review, TOIG intends to assess Treasury’s internal controls:
over financial management systems (e.g. grants, loans, procurement) from which the data elements were derived
over its data management process used to extract financial and award data reported under the DATA Act
TOIG is responsible for internal control testing of Treasury systems and processes
TIGTA is responsible for internal control testing of IRS systems and processes

12. Document Requests
Inventory of source systems – to confirm Treasury's submission inventory is up-to-date
SSAE 18/SOC 1 reports related to DATA Act source systems
Internal Control Testing performed by management as outlined in OMB A-123 (management responsibility for internal control)
Validation for 2nd Quarter submitted data – Treasury-wide and bureaus
Reconciliation for 2nd quarter submitted data – Treasury-wide and bureaus

13. Document Requests
2nd quarter validation reports for the following systems:
FPDS – Federal Procurement Data System (D1)
ASP - Award Submission Portal (D2)
SAM – System for Award Management (E)
FSRS – Federal Sub-award Reporting System (F)
Treasury's most recent Federal Managers’ Financial Integrity Act of 1982 (FMFIA) Statement of Assurance/Report

14. Managing the Challenge & Complexity of the DATA Act
Common mistakes to avoid for a successful Required Review:
Not Being Directly Involved with the Project
Not Adequately Selling the Problem
Inconsistent Messaging/Poor Communication
Not Providing Adequate Resources
Shifting Focus or Changing Priorities too Soon
Ignoring Organizational Culture
Ignoring or Underestimating Impact on Employees

15. DATA Act oversight questions can be sent to DATAAct@oig.treas.gov