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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Financial Management
Status of EPA's
Implementation of the
DATA Act
Report No. 17-P-0050
December 2, 2016
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Report Contributors: Paul Curtis
Meg Hiatt
Kevin Ross
Jennifer Hutkoff
Abbreviations
CIGIE Council of the Inspectors General on Integrity and Efficiency
DATA Act Digital Accountability and Transparency Act of 2014
EPA U.S. Environmental Protection Agency
GAO U.S. Government Accountability Office
OCFO Office of the Chief Financial Officer
OIG Office of Inspector General
OMB U.S. Office of Management and Budget
Cover image: EPA OIG graphic depicting EPA implementation of the DATA Act.
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
17-P-0050
December 2, 2016
Why We Did This Review
We performed this audit to gain
an understanding of the
processes, systems and controls
that the U.S. Environmental
Protection Agency (EPA) has
implemented, or plans to
implement, to report financial
and payment data in accordance
with the requirements of the
Digital Accountability and
Transparency Act of 2014
(DATA Act); and to provide
recommendations on how to
improve the likelihood of
compliance with the
requirements of the DATA Act
prior to full implementation.
The Council of the Inspectors
General on Integrity and
Efficiency encouraged the
Inspector General community to
undertake DATA Act readiness
reviews at their respective
agencies.
The Office of Technology
Solutions in the EPA's Office of
the Chief Financial Officer
oversees EPA implementation of
the DATA Act.
This report addresses the
following EPA goal or
cross-agency strategy:
Embracing EPA as a high-
performing organization.
Send all inquiries to our
public affairs office at
(202) 566-2391 or visit
www.epa.gov/oiq.
Status of EPA's Implementation of the
DATA Act
What We Found
We found that the EPA has taken steps to
implement the DATA Act. The EPA plans to
go live in May 2017 using partial data and a
phased-in approach to comply with the key
legislative milestone.
The EPA is following the U.S. Office of Management and Budget's and
U.S. Department of the Treasury's eight-step DATA Act implementation
strategy. Regarding the progress on these steps, the EPA:
Established a DATA Act work group with the right mix of personnel
needed to oversee implementation of the act.
Performed a review of the data elements, and determined where the data
will be extracted in the EPA's systems.
Documented an initial inventory of EPA data elements and systems
against data elements.
The EPA is currently in Step 4, Design & Strategize, and Step 5, Prepare Data
for Submission to the Broker, and plans to complete Steps 6 through 8Test
Broker Implementation, Update Systems, and Submit [partial] Datain May
2017.
The EPA identified key risks to the DATA Act implementation, such as linking
award identification among the EPA's financial and procurement systems;
submitting complete data files to Treasury; timing differences, data
inconsistencies and reconciling data between the EPA internal and external
systems; and funding to support the consolidation and preparation of agency
data for reporting under the DATA Act. The EPA has identified mitigations to
address these risks.
Agency Response and Office of Inspector General Evaluation
The agency submitted an updated DATA Act Implementation Plan to the U.S.
Office of Management and Budget and U.S. Department of the Treasury on
August 11, 2016, that outlines the EPA's approach to implement the DATA Act
reporting requirements in May 2017. Since that implementation plan is
designed for the EPA to meet the statutory deadline with a partial data
submission, we have no recommendations.
The EPA plans to implement
the DATA Act with partial
data in May 2017 to comply
with the act.
Listing of OIG reports.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
December 2, 2016
MEMORANDUM
SUBJECT: Status of EPA's Implementation of the DATA Act
Report No. 17-P-005P
FROM: Arthur A. Elkins Jr.
TO:
David Bloom, Deputy Chief Financial Officer
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). The project number for this audit was OA-FY16-0077.
This report represents the opinion of the OIG and does not necessarily represent the final EPA position.
The Office of Technology Solutions, within the Office of the Chief Financial Officer, oversees EPA
implementation of the DATA Act.
Action Required
Because this report contains no recommendations, you are not required to respond to this report.
However, if you submit a response, it will be posted on the OIG's public website, along with our
memorandum commenting on your response. Your response should be provided as an Adobe PDF file
that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as
amended. The final response should not contain data that you do not want to be released to the public;
if your response contains such data, you should identify the data for redaction or removal along with
corresponding justification.
We will post this report to our website at www.epa.gov/oig.
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Status of EPA's Implementation
of the DATA Act
17-P-0050
Table of C
Purpose 1
Background 1
Responsible Offices 3
Scope and Methodology 3
Prior Audit Coverage 3
Results of Review 5
Agency Response and OIG Evaluation 7
Appendices
A CIGIE DATA Act Letter 8
B Agency Response to Draft Report 10
C Distribution 14
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Purpose
The objectives of our audit were to gain an understanding of the processes,
systems and controls that the U.S. Environmental Protection Agency (EPA) has
implemented, or plans to implement, to report financial and payment data in
accordance with the requirements of the Digital Accountability and Transparency
Act of 2014 (DATA Act); and to provide recommendations on how to improve
the likelihood of compliance with the requirements of the DATA Act prior to full
implementation.
Background
The DATA Act was enacted on May 9, 2014, and requires that federal agencies
report financial and payment data in May 2017, in accordance with data
standards established by the U.S. Office of Management and Budget (OMB)
and U.S. Department of the Treasury. The data reported will be displayed on a
website available to taxpayers and policy makers.
OMB issued guidance1 that directed agencies to:
Implement data definition standards for the collection and reporting of
agency-level and award-level data.
Implement a standard data exchange format for providing data to
Treasury, to be displayed on lJSAspending.gov or a successor site.
Link agency financial systems with award systems by continuing the
use of specified unique identification numbers for financial assistance
awards and contracts.
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 on a
quarterly basis.
OMB and Treasury also issued a DATA Act Implementation Playbook,
Version 2.0, in June 2016, which recommended eight key steps for agencies to
fulfill their requirements under the DATA Act, as noted in Table 1.
1 OMB M-15-12, Increasing Transparency of Federal Spending by Making Federal Spending Data Accessible,
Searchable, and Reliable; and OMB Management Procedures Memorandum No. 2016-03, Additional Guidance for
DA TAAct Implementation: Implementing a Data-Centric Approach for Reporting Federal Spending Information.
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Table 1: OMB's and Treasury's eight-step implementation plan for agencies
Step
Steps for agencies
1
Organize Team
Create an agency DATA Act work group including impacted communities (e.g., Chief Information
Officer, Budget, Accounting, etc.) and identify Senior Accountable Official.
2
Review Elements
Review list of DATA Act elements and participate in data definitions standardization.
3
Inventory Data
Perform inventory of agency data and associated business processes.
4
Design & Strategize
Plan changes (e.g., adding Award IDs to financial systems) to systems and business processes to
capture data that are complete multi-level (e.g., summary and award detail) fully-linked data.
5
Prepare Data for Submission to the Broker
Implement system changes and extract data (includes mapping of data from agency schema to the
DATA Act Schema) iteratively.
6
Test Broker Implementation
Test broker outputs to ensure data are valid iteratively.
7
Update Systems
Implement other changes iteratively (e.g., establish linkages between program and financial data,
capture any new data).
8
Submit Data
Update and refine process (repeat 5-7 as needed).
Source: OMB's and Treasury's DATA Act Implementation Playbook (June 2016).
The DATA Act provides for oversight by Inspectors General and the
U.S. Government Accountability Office (GAO), and requires a series of oversight
reports to include an assessment of the completeness, timeliness, quality and
accuracy of data submitted. The first set of Inspector General reports are due to
Congress in November 2016. However, agencies are not required to submit
spending data in compliance with the DATA Act until May 2017.
The Council of the Inspectors General on Integrity and Efficiency (CIGIE)
identified a timing anomaly with the oversight requirements in the DATA Act.
The Inspectors General plan to provide Congress with their first required reports
in November 2017, a 1-year delay from the statutory due date, with subsequent
reports following on a 2-year cycle. Although CIGIE determined the best course
of action was to delay the Inspector General reports, CIGIE is encouraging
Inspectors General to undertake DATA Act "Readiness Reviews" at their
respective agencies well in advance of the first November 2017 report. On
December 22, 2015, CIGIE's chair issued a letter memorializing the strategy for
dealing with the Inspector General reporting date anomaly, and communicated it
to the Senate Committee on Homeland Security and Government Affairs and the
House Committee on Oversight and Government Reform. Appendix A provides a
copy of this letter.
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Responsible Offices
The Office of Technology Solutions, within the EPA's Office of the Chief
Financial Officer (OCFO), maintains responsibility over EPA implementation of
the DATA Act. Other offices involved in implementing the DATA Act include
OCFO's Office of Controller and Office of Budget, the Office of Administration
and Resources Management, and the Office of Environmental Information.
Scope and Methodology
We conducted this audit from February through August 2016. We conducted the
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 objectives. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on our audit
objectives.
To gain an understanding of the EPA's processes for implementing the DATA
Act, we:
Reviewed laws, legislation, directives, and other regulatory criteria and
guidance related to the EPA's responsibilities to report financial and
payment information under the DATA Act.
Conducted interviews with the EPA's DATA Act work group responsible
for implementation of the DATA Act at the agency level.
Assessed the EPA's efforts and formal implementation plan to report
financial and payment information under the DATA Act.
We did not review the internal controls over the EPA's systems used to generate
data; our review was limited to the EPA's progress in implementing the DATA Act.
Prior Audit Coverage
We researched prior reports related to implementing the DATA Act. The following
GAO reports disclosed findings pertinent to our review:
Data Standards Established, but More Complete and Timely Guidance
Is Needed to Ensure Effective Implementation, GAO-16-261. issued
January 29, 2016. The report found that while the OMB and Treasury
issued definitions for 57 federal spending data elements as required,
several data element definitions are subject to interpretation that could
lead to inconsistent reporting. Without more interpretive clarification,
agencies run the risk of reporting data that cannot be aggregated
17-P-0050
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governmentwide. GAO's review of selected implementation plans found
that agencies need the technical guidance and intermediary service to be
finalized before they can develop detailed agency-level plans. If this
guidance is not aligned with agency implementation timelines, agencies
may delay taking key steps, or may need to revise existing plans once
final technical guidance is released, thereby hindering their ability to meet
DATA Act requirements and timelines. GAO recommended that OMB
and Treasury provide agencies with clarifications to address potential
quality issues with the definitions, and take steps to align the release of
finalized technical guidance with agency implementation time frames.
Progress Made but Significant Challenges Must Be Addressed to Ensure
Full and Effective Implementation, GAO-16-556T. issued April 19, 2016.
The GAO's ongoing review of required implementation plans submitted to
OMB indicates that federal agencies have identified significant challenges in
implementing the DATA Act, including competing priorities, resources,
systems integration and guidance. Some agencies identified strategies to
mitigate identified challenges, including effective communication and
information sharing, and leveraging of existing resources; they reported that
additional support from OMB and Treasury is needed for successful
implementation. The GAO identified seven overarching categories of
challenges reported by agencies to effectively and efficiently implement the
DATA Act.
Table 2: Challenges identified by federal agencies
Category
Description of reported challenges
Competing
Priorities
Statutory, regulatory, policy or other agency-specific matters that have competing priorities or
conflicting requirements.
Resources
Lack of funding or human resources reported by agencies as needed for implementation.
Systems
Integration
Technology issues, including challenges with integrating multiple existing and disparate financial
and management systems, or the need to install new systems or modify existing systems to
implement the DATA Act.
Guidance
Incomplete, unclear and evolving guidance on requirements, including data elements, technical
schema, and other key policies issued by OMB and Treasury.
Dependencies
Agency implementation activities that are dependent on other parties or actions being taken
before the agency can proceed (i.e., additional guidance issued, resource limitations, financial
systems being integrated, or resolution of competing priorities).
Timeframes
Short length of time for agencies to implement DATA Act requirements.
Other
Other reported challenges by agencies relating to project or program management, reporting
frameworks and data issues.
Source: GAO analysis of agency implementation plans (GAO-16-556T).
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Results of Review
We found that the EPA has taken steps to implement the DATA Act and plans to
implement the act with a partial data submission. The EPA has identified risks to
completely implementing the act as mandated by the statutory deadline.
The EPA is following the OMB's and Treasury's eight-step DATA Act
implementation strategy, and has completed the first three steps. Specifically the
EPA:
1. Established a DATA Act work group; the group has the right mix of
contracts, grants and information technology personnel needed to oversee
the implementation of the DATA Act.
2. Performed a review of the data elements, and determined where the data
will be extracted in the EPA's systems.
3. Documented an initial inventory of data elements and systems.
The EPA is currently in Step 4, Design & Strategize, and Step 5, Prepare Data for
Submission to the Broker, referenced in the DATA Act Implementation Playbook
Version 2.0. The EPA plans to complete Steps 6 through 8Test Broker
Implementation, Update Systems and Submit [partial] Datain May 2017, to
comply with the key legislative milestone.
The EPA identified the following key risks to the DATA Act:
Award Identification Linkage: Compass Financials (the EPA's financial
system), Integrated Grants Management System, EPA Acquisition System,
and other linked systems or databases must be modified to share a standard
Award Identification to allow full financial and procurement reporting.
Delivery of Reporting Submission Specification Files A, B and C2 in
May 2017: Since the EPA's general ledger beginning balances currently
do not contain requested fields in File B, there may be gaps in data at the
object class and program activity level. The agency will not be able to
submit a complete File B, which may have to be delivered in partial scope
to Treasury in May 2017. The agency will need to identify, track and be
able to explain these differences.
Timing Differences Associated With Data Reconciliation: The EPA
recognizes the risk to accurate data reconciliation due to differences in the
timing of data extraction from external systems. For example, Federal
2 Required Submission Specification Files A, B and C represent the following: File A = Appropriation Accounts,
File B = Object Class Program Activity, and File C = Award and Financial Data.
17-P-0050
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Procurement Data System data is extracted on the first day of the month,
but the EPA data collected for Required Submission Specification File C
is from the second day of the month.
Data Inconsistencies: The EPA recognizes the risk associated with data
source issues and reconciling data between the EPA internal systems and
external systems to the EPA. The agency will need to be able to clearly
explain the data discrepancies between its overall financial balances and
the figure being shown in the beginning balances.
Funding: The EPA requires funding resources to support the consolidation
and preparation of agency data for reporting under the standards of the
DATA Act. Agency efforts to comply with the requirements of the DATA
Act have not received funding support through the appropriations process.
Subsequent to our fieldwork, the agency met with OMB and Treasury to review
the agency issues and meeting the May 2017 reporting requirement. OMB and
Treasury recommended that the EPA consider a phased-in approach to reporting,
and communicated that the submission of a partial file still fulfills the May 2017
DATA Act requirement. As an outcome of the OMB and Treasury meeting, the
EPA updated the schedule and milestones, and submitted an updated
Implementation Plan to OMB on August 11, 2016. The EPA also established data
governance to address any discrepancies or issues that may arise when data is
being reconciled, improved or validated. Additionally, the EPA has drafted a Data
Management Plan that outlines a set of roles, processes and tools to effectively
manage EPA systems to govern financial, mixed-financial and non-financial data.
The major change to the updated implementation plan is that the EPA now plans to
implement the DATA Act with partial data in May 2017, to comply with the key
legislative milestone. The EPA has revised its major milestones to reflect what the
agency expects to complete as part of the updated DATA Act Implementation Plan.
Table 3: EPA major milestones
Milestones
Start
Finish
1
Requirements
Oct. 2015
Aug. 2016
2
Design
Jul. 2016
Nov. 2016
3
Phase I Award ID Linkage
Aug. 2016
Jan. 2017
4
Governmentwide Treasury Account Symbol Adjusted
Trial Balance System Implementation
Oct. 2016
Dec. 2016
5
Development
Nov. 2016
Apr. 2017
6
Phase II Testing and Training
Mar. 2017
Apr. 2017
7
Phase II File Submission (Go Live)
May 2017
8
Phase III Testing
Jun. 2017
Aug. 2017
9
Phase III Implementation (File Submission,
Unique Procurement Instrument Identifier)
Aug. 2017
Oct. 2017
Source: EPA's DATA Act Implementation Plan (August 11, 2016).
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The EPA's updated Implementation Plan includes a three-phased approach:
Phase I - Implement the Award Identification linkage requirement by
January 2017.
Phase II - Go live with submission of partial data files in May 2017.
Phase III - Implement the unique Procurement Instrument Identifier and
fully submit data files by October 2017.
In Phase I, as part of the solution to address gaps in agency data, the EPA plans
to link the data contained in its financial and management systems via a
common Award Identification.
In Phase II, the EPA plans to consolidate the requested financial data from
Compass Financials, grants data from the Integrated Grants Management
System, and procurement data from the EPA Acquisition System into the
DATA Act Evaluation and Approval Repository prior to submission to the
Treasury's Data Broker.
In Phase III, the EPA plans to perform additional testing and data
reconciliation, implement a unique Procurement Instrument Identifier, and
submit complete data files by October 2017.
Since the EPA's DATA Act implementation plan is designed to meet the
statutory deadline with a partial data submission, we do not have any
recommendations that would increase the likelihood of compliance with the
May 2017 financial and payment data reporting requirements of the DATA Act.
Agency Response and OIG Evaluation
The OCFO response to the draft report is based on its revised August 11, 2016,
implementation plan. The OIG draft report outlined the EPA's status of
implementing the DATA Act as of July 2016 when we completed the collection
of information for our audit fieldwork.
In its response, the agency stated that, in line with the OMB and Treasury
guidance, the EPA submitted an updated DATA Act Implementation Plan to
OMB and Treasury on August 11, 2016. The EPA's updated DATA Act
Implementation Plan outlines the EPA's approach to implement the DATA Act
reporting requirements with partial data submission in May 2017. The EPA
believes the OIG draft report did not fully leverage the agency's position. As
stated above, the OIG draft report was based on work performed and collection of
information prior to completion of the EPA's revised implementation plan.
The agency subsequently provided information about meeting with OMB and the
Treasury. Based on the agency's updated implementation plan and this additional
information, we revised our report.
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Appendix A
CIGIE DATA Act Letter
Council of the
INSPECTORS GENERAL
on INTEGRITY and EFFICIENCY
December 22, 2015
The Honorable Ron Johnson
Chairman
The Honorable Thomas Carper
Ranking Member
Committee on Homeland Security
and Governmental Affairs
United States Senate Washington, D.C.
The Honorable Jason Chaffetz
Chairman
TheHonorableElij ah Cummings
Ranking Member
Committee on Oversight and Government Reform
U.S. House of Representatives
Washington, D.C.
Dear Mr. Chairmen andRankingMembers:
The Council of the Inspectors General on Integrity and Efficiency (CIGIE) recognizes and
appreciates your leadership on issues of Government transparency and accountability. In
particular, we believe the enactment last year of the Digital Accountability and Transparency Act of
2014 (DATA Act) will significantly improve the quality of Federal spending data available to
Congress, the public, and the accountability community if properly implemented. To make sure this
happens, the DATA Act provides for strong oversight by way of the Federal Inspectors General
and the Government Accountability Office (GAO). In particular, the DATA Act requires a series
of reports from each to include, among other things, an assessment of the completeness,
timeliness, quality, and accuracy of data submitted by agencies under the DATA Act.
I am writing this letter on behalf of CIGIE to inform you of an important timing anomaly with the
oversight requirement for Inspectors General in the DATA Act. Your staffs have been briefed
on this timing anomaly, which affects the first Inspector General reports required by the DATA Act.
Specifically, the first Inspector General reports are due to Congress in November 2016. However,
the agencies we oversee are not required to submit spending data in compliance with the DATA Act
until May 2017. As a result, Inspectors General would be unable to report on the spending data
submitted under the Act, as this data will not exist until the following year. This anomaly would cause
the body of reports submitted by the Inspectors General in November 2016 to be of minimal use to the
public, the Congress, the Executive Branch, and others.
To address this reporting date anomaly, the Inspectors General plan to provide Congress with their
first required reports in November 2017, a one-year delay from the due date in statute, with subsequent
reports following on a two-year cycle, in November 2019 and November 2021. We believe that
moving the due dates back one year will enable the Inspectors General to meet the intent of the
1717 H Street, NW, Suite 825, Washington, DC 20006
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Page 2
oversight provisions in the DATA Act and provide useful reports for the public, the Congress, the
Executive Branch, and others.
Although we think the best course of action is to delay the Inspector General reports, CIGIE is
encouraging the Federal Inspector General Community to undertake DATA Act "readiness
reviews" at their respective agencies well in advance of the first November 2017 report. Through
a working group, CIGIE has developed guidance for these reviews. I am pleased to report that
several Inspectors General have already begun reviews at their respective agencies, and many
Inspectors General are planning to begin reviews in the near future. We believe that these reviews,
which are in addition to the specific oversight requirements of the Act, will assist all parties in helping
to ensure the success of the DATA Act implementation.
We have kept GAO officials informed about our plan to delay the first Inspector General reports for
one year, which they are comfortable with, and our ongoing efforts to help ensure early engagement
through Inspector General readiness reviews.
Should you or your staffs have any questions about our approach or other aspects of our
collective DATA Act oversight activities, please do not hesitate to contact me at (202) 514-3435.
Sincerely,
Michael E. Horowitz
Chair, Council ofthe Inspectors General on Integrity and Efficiency
Inspector General, U.S. Department ofJustice
cc: The Honorable David Mader, Controller, OMB
The Honorable Gene Dodaro, Comptroller General, GAO
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Appendix B
Agency Response to Draft Report
September 13, 2016
MEMORANDUM
SUBJECT: Draft Report: Status of EPA's Implementation of the DATA Act as of July 2016
Project No. OA-FY16-0077 dated August 23, 2016
FROM: David A. Bloom, Deputy Chief Financial Officer
TO: Paul C. Curtis, Director, Financial Audits
Thank you for the opportunity to respond to the draft report on Status of EPA's Implementation
of the DATA Act as of July 2016, Project No. OA-FY16-0077. The following is a summary of
the agency's overall position, along with its response to each of the report recommendations.
AGENCY'S OVERALL POSITION
The agency does not concur with the draft report and found several inaccuracies in the report
findings.
AGENCY'S RESPONSE TO DRAFT REPORT STATUS
In line with the OMB and Treasury guidance, the EPA submitted an updated DATA Act
Implementation Plan to OMB and Treasury on August 11, 2016. The updated DATA Act
Implementation Plan outlines EPA's approach to implement the DATA Act reporting
requirements in May 2017. The OCFO response to the draft report is based on the current
implementation plan. The draft report that was issued on August 23, 2016, did not take into
account the agency's updated implementation plan. Therefore, we believe it does not fully
leverage the agency's position and provide an opportunity for the OIG review which we believe
it's critical to evaluate the current implementation plan and issue the applicable findings.
Disagreements
No.
Page / Section /Sub-
Section
OIG Finding
OCFO Response
1
At a Glance / What
We Found / Paragraph
3 and "call-out box"
"The EPA did not intend to
implement the DATA Act by
the May 2017 statutory
deadline because it will not
implement its new Account
Code Structure until after the
deadline."
Please reference the updated
DATA Act Implementation Plan
(p.l, Introduction) from
8/11/2016. EPA will meet the
May 2017 statutory deadline and
all references to the ACS project
were removed.
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No.
Page / Section /Sub-
Section
OIG Finding
OCFO Response
2
At a Glance / What
We Found / Paragraph
4
"The EPA DATA Act
implementation plan was not
designed for the EPA to meet
the statutory deadline."
The project planning effort
included changes in assumptions
and an evolving understanding of
the requirements. There was no
explicit intention of missing the
May 2017 deadline.
3
p.3 / Responsible
Offices
"The EPA's Office of the
Controller within the OCFO
maintains responsibility over
implementing the DATA Act."
In April 2016, OCFO shifted
DATA Act Implementation
responsibility from the Office of
the Controller (OC) to the Office
of Technology Solutions (OTS).
4
p.4 / Results of
Review / Paragraph 1
"As of July 29, 2016, we found
that the EPA did not intend to
meet the May 2017 statutory
deadline to submit spending
data because the EPA has not
completed a new ACS."
Although the OIG draft report is
dated 8/23/2016, and "anything
that comes to the OIG's attention
up to the report date should be
included in the report", OIG is
not crediting the EPA with its
changed strategy that ACS no
longer impacts DATA Act
implementation and that the EPA
will implement DATA Act in
May 2017. Please reference the
updated DATA Act
Implementation Plan from
8/11/2016 (p.l, Introduction).
5
p.5 / Results of
Review / Paragraph 1,
#2
"Performed a review of the
data elements, and determined
where the data will be
extracted in the EPA's systems
in May 2015."
The date accomplished is April
2016 per updated EPA Agency
Progress Dashboard reported to
OMB/Treasury. Please reference
the 7/21/2016 email and attached
Dashboard file.
6
p.5 / Results of
Review / Paragraph 1,
#4
"Completed the planning and
strategizing for a data broker
design and construction using
existing EPA systems for
pulling data in July 2015."
The anticipated date to
accomplish this task is January
2017 per updated EPA Agency
Progress Dashboard reported to
OMB/Treasury. Please reference
the 7/21/2016 email and attached
Dashboard file.
7
p.5 / Results of
Review / Paragraph 2
"In addition, we determined
that the EPA adequately
addressed the following topics
in the EPA's Implementation
Plan:
While the report addresses
establishing a DATA Act work
group the establishment of a Data
Governance Board is not
addressed in the report.
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No.
Page / Section /Sub-
Section
OIG Finding
OCFO Response
8
pp.5-6 / Results of
Review / Paragraph 5
"Due to the new ACS..."
"Timely implementation of the
DATA Act at EPA is reliant on
implementing the new ACS..."
The EPA is not delaying DATA
Act Implementation due to ACS.
Please reference the 7/18/2016
email from Eva Ripollone to OIG
on the issue. Please also reference
the updated DATA Act
Implementation Plan from
8/11/2016 (p.l, Introduction).
9
p.6 / Results of
Review / Paragraph 3
"As of July 29, 2016, the
EPA's DATA Act
Implementation Plan was not
designed to meet the statutory
deadline."
As of the date of this draft audit
report (8/23/2016), the EPA
submitted an updated Data Act
Implementation Plan that states it
will meet the May 2017 statutory
deadline for implementation.
10
p.6 / Subsequent
Events
"Subsequent to our audit
work..."
On 7/18/2016, OTS informed
OIG that ACS was "removed
from the Data Act
Implementation Plan". Please
reference the 7/18/2016 email
from Eva Ripollone to OIG on
the issue.
There is no mention of EPA
providing OMB/Treasury with
the updated DATA Act
Implementation Plan on
8/11/2016 even though the date
of this audit report is 8/23/2016.
11
p.6 / Subsequent
Events
"We have not received
sufficient information and
documentation to support
OMB's and Treasury position
that the submission of a partial
file fulfills the DATA Act
requirement as intended by
Congress."
Meeting notes and follow-up
confirmation with Treasury was
provided. Additionally, on the
9/9/2016 DATA Act Monthly
SAO Meeting Treasury indicated
they are not providing any
additional details to the reporting
guidance that supports the
guidance provided during
individual agency discussions and
Treasury offered their assistance
if additional information was
needed for OIG Readiness
Reviews / Audits.
17-P-0050
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CONTACT INFORMATION
If you have any questions regarding this response, please contact Eva Ripollone, 202-564-6768.
4 Attachments
1. Updated DATA Act Implementation Plan, dated August 11, 2016
2. Agency Progress Dashboard
3. Email Correspondence, between Treasury and EPA
4. DATA Act Meeting Notes from June 30, 2016
cc: Howard Osborne
Randy Thornton
Donna Vizian
John Showman
Stefan Silzer
Jeanne Conklin
Carol Terris
Quentin Jones
Rob Hill
Denise Polk
Howard Corcoran
Christopher Osborne
Eva Ripollone
Nic Grzegozewski
Sherri Anthony
Meshell Jones-Peeler
17-P-0050
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Appendix C
Distribution
Office of the Administrator
Chief Financial Officer
Agency Audit Foilow-Up Coordinator, Office of the Chief Financial Officer
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Associate Chief Financial Officer, Office of the Chief Financial Officer
Controller, Office of the Controller, Office of the Chief Financial Officer
Deputy Controller, Office of the Controller, Office of the Chief Financial Officer
Director, Office of Budget, Office of the Chief Financial Officer
Director, Office of Technology Solutions, Office of the Chief Financial Officer
Director, Financial Services Division, Office of the Chief Financial Officer
Chief, Management Integrity and Accountability Branch, Office of the Chief Financial Officer
Director, Policy and Communications Staff, Office of the Chief Financial Officer
17-P-0050
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