CUSTOMER SERVICE ~ INTEGRITY ~ ACCOUNTABILITY
U.S. Chemical Safety Board
Contractor-Produced Report:
U.S. Chemical Safety and
Hazard Investigation Board
Independent Auditor's Report
on Compliance with the Digital
Accountability and
Transparency Act of 2014
Submission Requirements for
Fiscal Year 2021
Report No. 22-P-0002
November 8, 2021
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Abbreviations
CIGIE Council of the Inspectors General on Integrity and
Efficiency
CSB U.S. Chemical Safety and Hazard Investigation Board
DATA Act Digital Accountability and Transparency Act of 2014
EPA U.S. Environmental Protection Agency
FAEC Federal Audit Executive Council
OIG Office of Inspector General
Pub. L. Public Law
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Office of Inspector General
U.S. Environmental Protection Agency
At a Glance
22-P-0002
November 8, 2021
Why This Audit Was Done
The Digital Accountability and
Transparency Act of 2014
requires the inspector general to
review a statistically valid sample
of the spending data submitted
under the Act by the
U.S. Chemical Safety and
Hazard Investigation Board and
to assess the completeness,
accuracy, timeliness, and quality
of the data sampled, as well as
the CSB's implementation and
use of the data standards
established by the Office of
Management and Budget and
U.S. Department of the Treasury.
The U.S. Environmental
Protection Agency's Office of
Inspector General, which also
serves as the OIG for the CSB,
contracted with Allmond &
Company to audit the CSB's
fiscal year 2021 compliance with
the Act. Allmond and Company
selected fiscal year 2020
third-quarter data as the data
sampled for this audit.
This audit supports a CSB goal:
• Create and maintain an
engaged, high-performing
workforce.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
Contractor-Produced Report: U.S. Chemical Safety
and Hazard Investigation Board Independent
Auditor's Report on Compliance with the Digital
Accountability and Transparency Act of 2014
Submission Requirements for Fiscal Year 2021
The DATA Act requires the
CSB to report accurate
financial and award data
on USAspending.gov.
What Allmond & Company Found
Allmond & Company found that the CSB's fiscal
year 2020 third-quarter financial and award data
submitted under the Digital Accountability and
Transparency Act of 2014 were of "excellent"
quality, as defined by the CIGIE FAEC
Inspectors General Guide to Compliance under the DATA Act, dated December
4, 2020. The CIGIE DATA Act Guide outlines four levels of data quality:
excellent, higher, moderate, and lower.
Allmond & Company found that the CSB complied with the DATA Act reporting
requirements of completeness and timeliness and that the CSB's internal
controls over the fiscal year 2020 third-quarter DATA Act submission were
effective. Specifically, Allmond & Company determined that all data contained
in the data elements for statistical samples tested were complete and timely. It
also evaluated the CSB's fiscal year 2020 third-quarter DATA Act submission to
Department of the Treasury's DATA Act Broker for nonstatistical samples and
determined that the submission was complete and timely.
When assessing accuracy, Allmond & Company could not locate one data
element in three instances in the System for Award Management, or SAM.gov,
which is the official government website for people who make, receive, and
manage federal contracts. That data element is automatically populated in the
Federal Procurement Data System-Next Generation from SAM.gov, and not
manually entered by the CSB. Allmond & Company attributed the error to
extracting data from SAM.gov. As a result of these three instances, the
projected error rate for the accuracy of the data elements was 0.73 percent.
Allmond & Company made no recommendations to the CSB.
Allmond & Company is responsible for the enclosed audit report and the
conclusions expressed in that report.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
November 8, 2021
Katherine A. Lemos, Ph.D.
Chairperson and Chief Executive Officer
U.S. Chemical Safety and Hazard Investigation Board
1750 Pennsylvania Avenue NW, Suite 910
Washington, D.C. 20006
Dear Dr. Lemos:
RE: Report No. 22-P-0002, Contractor-Produced Report: U.S. Chemical Safety and Hazard
Investigation Board Independent Auditor's Report on Compliance with the Digital Accountability
and Transparency Act of 2014 Submission Requirements for Fiscal Year 2021
This letter transmits the audit report on the U.S. Chemical Safety and Hazard Investigation Board's fiscal
year 2021 compliance with the Digital Accountability and Transparency Act of 2014, Pub. L. 113-101,
known as the DATA Act. The audit is required by the DATA Act.
The independent public accounting firm of Allmond & Company, LLC, selected fiscal year 2020 third-
quarter financial and award data to perform this audit. The audit was conducted in accordance with the
Government Auditing Standards, issued by the comptroller general of the United States, and the CIGIE
FAEC Inspectors General Guide to Compliance under the DATA Act, issued by the Council of the
Inspectors General on Integrity and Efficiency's Federal Audit Executive Council. Allmond & Company
is responsible for the enclosed auditor's report, which is dated November 1, 2021, and the opinions and
conclusions expressed in that report.
Because the 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 Office of Inspector General'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 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.
Sincerely,
Sean W. O'Donnell
Enclosure
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CSB- 2021 DATA Act Audit
Contract: GS23F0111L/68HERH21F0086
Final Independent Auditors' Report
Submitted for review and acceptance to:
Sheree James
Contracting Officer Representative
Office of Inspector General
Environmental Protection Agency
Submitted by:
Jason L. Allmond, CPA, CGFM, CISA, CISM
Engagement Partner
Allmond & Company, LLC
7501 Forbes Blvd., Suite 200
Lanham, Maryland 20706
301-918-8200
mailto:iallmond(a)allmondcpa.com
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U.S. CHEMCIAL SAFETY AND HAZARD INVESTIGATION BOARD
INDEPENDENT AUDITOR'S REPORT ON COMPLIANCE WITH THE
DIGITAL ACCOUNTABILITY AND TRANSPARENCY ACT OF 2014
SUBMISSION REQUIREMENTS FOR FISCAL YEAR 2021
-«^ O/.
\ f\
S'n ovS*
ALLMOND & COMPANY, LLC
Certified Public Accountants
7501 Forbes Boulevard, Suite 200
Lanham, Maryland 20706
(301) 918-8200
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U.S. Chemical Safety and Hazard Investigation Board
Independent Auditors' Report on the Compliance with the
Digital Accountability and Transparency Act of 2014
Submission Requirements for Fiscal Year 2021
Table of Contents
Independent Auditors' Report 1
Executive Summary 2
Background 2
Purpose 3
Objective 3
Scope and Methodology 3
Assessment of Internal Control and Compliance with Laws and Regulations 4
Data Act Date Anomaly 5
Testing Limitations for Files E and F 5
Reporting of the Results of the Sample Testing 6
Appendix A - Objectives, Scope, Methodology, and Criteria 9
Appendix B - Summary of Results for Record-Level Data Elements 11
Appendix C- Accuracy of Dollar-Value Related Data Elements 14
Appendix D - CIGIE's DATA Act Anomaly Letter 15
Appendix E - Management's Response 17
Appendix F - Glossary of Abbreviations and Acronyms 18
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Allmond & Company, LLC
Certified Public Accountants
750 1 Forbes Boulevard, Suite 200
Lanham, Maryland 20706
(30 I ) Q I 8-8 200
Facsimile (30 1)91 8-820 I
Independent Auditors' Report
Chairman and CEO U.S. Chemical Safety and Hazard Investigation Board
Inspector General, Environmental Protection Agency
The Environmental Protection Agency (EPA) Office of Inspector General (OIG) contracted Allmond and
Company, LLC, to conduct a performance audit of the Chemical Safety and Hazard Investigation Board
(CSB) third quarter financial and award data as of June 30, 2020, in accordance with the Digital
Accountability and Transparency Act of 2014 (DATA Act). To clarify the reporting requirements of the
DATA Act, the Office of Management and Budget (OMB) and Department of Treasury (Treasury)
published 59 data definition standards and required Federal agencies to report financial and award data on
U S Aspending .gov.
The objectives of the audit were to assess (1) completeness, timeliness, quality, and accuracy of CSB FY
2020 third quarter financial and award data submitted to Treasury for publication on USASpending.gov;
and (2) CSB's implementation and use of the Government-wide financial data standards established by
OMB and Treasury. CSB's management is responsible for reporting financial and award data in
accordance with these standards, as applicable.
We conducted the audit in accordance with the standards applicable to performance audits contained in
Government Auditing Standards issued by the Comptroller General of the United States, collectively
referred to as generally accepted government auditing standards (GAGAS); and the Council of the
Inspector Generals on Integrity and Efficiency (CIGIE) Federal Audit Executive Council (FAEC)
Inspectors General Guide to Compliance under the DATA Act (DATA Act Audit Guide). Those standards
and the DATA Act Audit Guide require that we plan and perform the audit to obtain sufficient and
appropriate audit evidence to provide a reasonable basis for our findings and conclusions based on our
audit objectives. Our performance audit involved performing procedures to obtain evidence about the FY
2020 third quarter financial and award data. The nature, timing, and extent of the procedures selected
depended on our judgement, including an assessment of the risks of material misstatement of the FY 2020
third quarter financial and award data, whether due to fraud or error. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.
We found that the FY 2020 third quarter financial and award data of CSB for the quarter ended June 30,
2020, is presented in accordance with OMB and Treasury published 59 data definition standards, as
applicable, for DATA Act reporting in all material respects. We did however, note that the data CSB
submitted did not always comply with the requirements for accuracy. As we attributed the errors noted to
a third party, no recommendations were made to CSB.
The purpose of this report is solely to describe the scope of our testing and the results of that testing.
Accordingly, the report is not suitable for any other purpose.
This report is intended solely for the information and use of the CSB management, EPA OIG and the
U.S. Congress, and is not intended to be, and should not be, used by anyone other than these specified
parties.
Landover, MD
November 1, 2021
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Independent Auditors' Report on Compliance with DATA Act
Executive Summary
For fiscal year (FY) 2021, the Environmental Protection Agency (EPA) Office of Inspector General (IG)
contracted with Allmond and Company, LLC to conduct an independent audit of CSB's compliance with
the provisions of the Digital Accountability and Transparency Act of 2014 (DATA Act). The DATA Act
requires the OIG of each federal agency to review a statistically valid sample of the certified spending
data submitted by the agency and to submit to Congress a publicly available report assessing the
completeness, accuracy, timeliness and quality of the data sampled and the implementation and use of the
Government-wide financial data standards by the Federal agency.
Our audit was conducted in accordance with generally accepted government auditing standards. Our
audit approach measured completeness, accuracy and timeliness of 59 data elements, as applicable to
CSB. CSB's submission is considered complete when transactions and events that should have been
recorded are recorded in the proper period. CSB's data elements are considered accurate when amounts
and other data relating to recorded transactions have been recorded in accordance with the DATA Act
Information Model Schema (DAIMS) v 2.0 Reporting Submission Specification (RSS), Interface
Definition Document (IDD), and the online data dictionary; and agree with the authoritative source
records. CSB's submission is considered timely when the submission by the CSB to the DATA Act
Broker is in accordance with the reporting schedules established by the Treasury DATA Act Project
Management Office, no later than August 14, 2020. CSB's data elements are considered timely when
reported in accordance with the reporting schedules defined by the financial, procurement and financial
assistance requirements. Based on the results of our testing, we determined the quality of the data.
Our statistical sample size was 14 of 15 records from File C. Our assessment included testing compliance
with OMB and Treasury published 59 data definition standards, as applicable. We concluded that CSB
complied with the DATA Act reporting requirements. Based on the audit procedures performed, we
determined that the completeness error rate is 0.00%, accuracy error rate is 0.73% and timeliness error
rate is 0.00%. We determined that CSB's data was generally of excellent quality - that is, significant
amounts of the data were complete, timely, and accurate.
Background
Chemical Safety and Hazard Investigation Board
The Chemical Safety and Hazard Investigation Board (CSB) is an independent federal agency charged
with investigating industrial chemical accidents. Headquartered in Washington, DC, the agency's board
members are appointed by the President and confirmed by the Senate.
The CSB was created by Section 303 of the Clean Air Act Amendments of 1990; however, it was not
until 1997 that the CSB was first funded. The principal role of the CSB is to investigate accidents to
determine the conditions and circumstances which led to the event and identify the cause so that similar
events might be prevented. The focus of a CSB investigation is mainly on determining the cause and
prevention of such incidents, rather than upon enforcement actions of violations of law or regulation.
Congress gave the CSB a unique statutory mission and provided in law that no other agency or executive
branch official may direct the activities of the Board. Following the successful model of the National
Transportation Safety Board and the Department of Transportation, Congress directed that the CSB's
investigative function be completely independent of the rulemaking, inspection, and enforcement
authorities of the Environmental Protection Agency (EPA) and the Occupational Safety and Health
Administration (OSHA). Although the Board was created to function independently, it also collaborates
in important ways with EPA, OSHA, and other agencies. The Board has entered into a number of
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Independent Auditors' Report on Compliance with DATA Act
memorandums of understanding (MOUs) that define the terms of collaboration and allows the CSB to
carry out its statutory mission efficiently and without unnecessary duplication of effort.
DATA ACT
In 2006, Congress passed, and the President signed the Federal Funding Accountability and Transparency
Act of 2006 (FFATA). The purpose of FFATA was to increase transparency and accountability surrounding
federal contracts and financial assistance awards. In accordance with FFATA, in December 2007, OMB
established a federal government website, USAspending.gov that contains obligation data on federal awards
and sub awards.
The DATA Act was enacted May 9, 2014, to expand the reporting requirements pursuant to FFATA. The
DATA Act, in part, requires Federal agencies to report financial and award data in accordance with the
established government wide financial data standards. In May 2015, OMB and Treasury published 57
data definition standards (commonly referred to as data elements) and required Federal agencies to report
financial and award data in accordance with these standards for DATA Act reporting in January 2017.
Subsequently, and in accordance with the DATA Act, Treasury began displaying Federal agencies' data
on USAspending.gov for taxpayers and policymakers in May 2017.
In April 2020, OMB issued M-20-21, Implementation Guidance for Supplemental Funding Provided in
Response to the Coronavirus Disease 2019 (COVID-19), which requires agencies to use a disaster
emergency fund code (DEFC) to include covered funds in the Coronavirus Aid, Relief, and Economic
Security Act (CARES Act) that are not designated as emergency pursuant to the Balanced Budget and
Emergency Deficit Control Act of 1985, in order to provide similar transparency for CARES Act funding.
As such, there are now 59 applicable data elements to be tested for all agencies.
The DATA Act also requires Inspectors General to issue a report to Congress assessing the completeness,
timeliness, accuracy, and quality of a statistical sample of spending data submitted by the agency and the
agency's implementation and use of the data standards. The 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 in November 2016; however, federal agencies were not required to report spending data until
May 2017. To address this reporting date anomaly, Inspectors General provided Congress with their first
required reports in November 2017, a 1-year delay from the statutory due date, with subsequent reports
due on a 2-year cycle, in November 2019 and November 2021.
Purpose
The DATA Act, in part, requires Federal agencies to report financial and award data in accordance with
the established government wide financial data standards.
Objective
The objectives of the performance audit of the CSB's compliance with the DATA Act were to assess the
(1) completeness, timeliness, quality, and accuracy of CSB FY 2020 third quarter, financial and award
data submitted to Treasury for publication on USASpending.gov; and (2) CSB's implementation and use
of the Government-wide financial data standards established by the OMB and Treasury.
Scope and Methodology
We followed guidance from the CIGIE's Inspectors General Guide to Compliance under the DATA Act,
dated December 4, 2020. The DATA Act guide documents a common methodological framework,
developed in consultation with the U.S. Government Accountability Office (GAO), for Inspectors General
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Independent Auditors' Report on Compliance with DATA Act
to conduct required DATA Act reviews. We also reviewed applicable laws, regulations, CSB policies and
procedures, and other documentation related to the DATA Act. We randomly selected and analyzed a
statistically valid sample of the CSB's FY 2020 third quarter spending data submitted by the agency for
publication on USAspending.gov.
We conducted our fieldwork from April 15, 2021 through October 22, 2021 in accordance with generally
accepted government auditing standards. Those standards require that we plan and perform the audit to
obtain sufficient and 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. Additional details on our scope and methodology
are outlined in Appendix A.
Assessment of Internal Control and Compliance with Laws and Regulations
We assessed internal controls and compliance with laws and regulations necessary to satisfy the audit
objective. Specifically, we assessed the CSB's control environment, risk assessment, control activities,
information and communication, and monitoring controls. We determined that internal and information
system controls as it relates to the extraction of data from the source systems and the reporting of the data
to the DATA Act Broker have been properly designed and implemented and are operating effectively to
allow us to assess audit risk and design our audit procedures. However, because our review was limited to
these internal control components and underlying principles, it may not have disclosed all internal control
deficiencies that may have existed at the time of this audit.
Work Performed Related to Federal Shared Service Provider (FSSP)
CSB uses Oracle Federal Financials (OFF), Procurement Request Information System Management
(PRISM) as its source systems for processing and recording procurement and financial data and for
generating its DATA Act submission. Oracle is hosted by CSB's shared service provider Bureau of Fiscal
Service, Administrative Resource Center (BFS/ARC). We performed procedures to determine whether
internal controls over the DATA Act submission process and these systems, as they relate to its FY 2020
third quarter DATA Act submission, were properly designed, implemented, and operating effectively.
Those procedures consisted of:
• Assessing CSB's DATA Act reporting roles and responsibilities as documented in the service
agreement with BFS/ARC.
• Gaining an understanding of the source systems used for recording procurement transactions
and reporting under the DATA Act.
• Reviewing U.S. Department of the Treasury's Description of Oracle Federal Financials Systems
and Suitability of the Design and Operating Effectiveness of Its Controls (SSAE 18 SOC 1-Type
2 Report), forthe Period July 1, 2019 to June 30, 2020 for Oracle Federal Financial and
determining whether any issues were noted that could have an impact on the accuracy,
timeliness, or quality of the DATA Act submission.
• Obtaining an understanding of Complementary User Entity Controls (CUECs) required by the
SOC report and implemented by CSB to determine whether gaps exist that might impact the
accuracy, timeliness, or quality of the DATA Act submission.
• Reviewing CSB's FY 2020 Financial Statements to identify findings that could affect the
reliability of the source system or data produced from it.
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Independent Auditors' Report on Compliance with DATA Act
Assessment of Internal Controls over DATA Act Submission
We performed inquiry and inspection of documents to determine whether internal controls over the
DATA Act submission were operating effectively. We found that overall, controls over the FY 2020 third
quarter DATA Act submission were effective.
Data Act Date Anomaly
The CIGIE identified a timing anomaly with the oversight requirements contained in the DATA Act. That
is, the first Inspector General (IG) reports were due to Congress in November 2016; however, Federal
agencies were not required to report spending data until May 2017. To address this reporting date
anomaly, the IGs provided Congress with their first required reports by November 8, 2017, 1 year after
the statutory due date, with two subsequent reports to be submitted following on a 2-year cycle. This is
the third and final report required under the DATA Act. On December 22, 2015, CIGIE's chair issued a
letter (See Appendix D) detailing the strategy for dealing with the IG reporting date anomaly and
communicated the strategy to the Senate Committee on Homeland Security and Governmental Affairs
and the House Committee on Oversight and Government Reform.
Testing Limitations for Files E and F
File E of the DATA Act Information Model Schema contains additional awardee attribute information the
Treasury DATA Act Broker software extracts from the System for Award Management (SAM). File F
contains sub-award attribute information the broker software extracts from the Federal Funding
Accountability and Transparency Act (FFATA) Sub-award Reporting System (FSRS). As CSB does not
receive financial assistance/grants, CSB has no required reporting data for File F. Files E and F data
remain the responsibility of the awardee in accordance with terms and conditions of Federal agreements,
and the quality of these data remains the legal responsibility of the recipient. Therefore, agency senior
accountable officials are not responsible for certifying the quality of File E and F data reported by
awardees, but they are responsible for assuring controls are in place to verify that financial assistance
awardees register in SAM at the time of the award. As such, we did not assess the completeness,
timeliness, quality, and accuracy of the data extracted from SAM and FSRS via the Treasury broker
software system.
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Independent Auditors' Report on Compliance with DATA Act
Reporting of the Results of the Sample Testing
Non-Statistical Results
Completeness of the Agency DATA Act Submission
We evaluated CSB's DATA Act submission to Treasury's DATA Act Broker and determined that the
submission was complete. To be considered a complete submission, we evaluated Files A, B and C to
determine that all transactions and events that should have been recorded were recorded in the proper
period.
Timeliness of the Agency DATA Act Submission
We evaluated CSB's fiscal year 2020 3rd quarter DATA Act submission to Treasury's DATA Act Broker
and determined that the submission was timely. To be considered timely, it had to be submitted and
certified within 45 days of quarter end. CSB completed their DATA Act submission on August 6, 2020.
Completeness of Summary-Level Data for Files A and B
We performed summary-level data reconciliations and linkages for Files A and B and did not identify any
variances. The test results verified: (1) summary-level data from File A matched the Agency's GTAS SF-
133; (2) the totals and TAS identified in File A matched File B; and (3) all object class codes from File B
match codes defined in Section 83 of OMB Circular No. A-11.
Record-Level Linkage for Files (C to B/D1/D2)
We tested the linkages between File C to File B by TAS, object class, and program activity, the linkages
between File C to File D1 by both the PUD and Parent Award ID. We noted that File D2 is not applicable
to CSB, as such we did not test the linkages between File C to D2 by the FAIN or URL All of the TAS,
object class, and program activity data elements from File C existed in File B and all of the PIIDs/Parent
Award IDs from File C existed in File Dl; and all PIIDs/Parent Award IDs in Files D1 existed in File C.
Statistical Results
We selected a sample of 14 records and tested 59 data elements (as applicable) for completeness,
accuracy, and timeliness.
Completeness of the Data
All data contained in the applicable elements were complete. The projected error rate for the
completeness of the data elements is 00.0%'. A data element was considered complete if the
required data element that should have been reported was reported.
Timeliness of the Data
All data contained in the applicable elements were timely. The projected error rate for the
timeliness of the data elements is 00.0%2. The timeliness of data elements was based on the
reporting schedules defined by the financial, procurement, and financial assistance requirements
(FFATA, FAR, FPDS-NG, FABS, and DAIMS).
1 Based on a 95% confidence level, the projected error rate for completeness of the data element is between
00.0% and 20.0%
2 Based on a 95% confidence level, the projected error rate for timeliness of the data element is between 00.0%
and 20.0%
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Independent Auditors' Report on Compliance with DATA Act
Accuracy of the Data
The projected error rate for the accuracy of the data elements is 0.73%3. A data element was
considered accurate when amounts and other data relating to recorded transactions were
recorded in accordance with the DAIMS RSS, IDD, and the online data dictionary, and agree
with the originating award documentation/contract file.
We noted 3 instances where the Ultimate Unique Parent Identifier Data Element could not be
located in the System for Award Management (SAM). As this field is automatically populated in
the Federal Procurement Data System-Next Generation (FPDS-NG) from SAM, and not
manually entered by CSB or CSB's service provider, we concluded that this discrepancy was
attributed to FPDS-NG extracting from SAM. See Table 1.
Table 1 - Errors in Data Elements Not Attributable to the Agency
PHD
DE#
Data Element
Errors
Attributed to Third Party
20356219F00008
20356220PQ0010
95315818F0015
3
Ultimate Parent Unique
Identifier
3
Unable to find the Ultimate
Parent Unique Identifier in
SAM
Overall Quality of the Data
The quality of the data elements was determined using weighted scores of both statistical sampling results
and nonstatistical testing results. Table 2 provides a sum man of quality per the Quality Scorecard. Table
3 provides the range of score for the quality of the data elements.
Table 2 - Quality Scorecard
Chemical Safety and Hazard Investigation
Board
Maximum Point* Possible
FY 2021 DATA Act
Quality Scorecard
Without Oudtyi
(NoCOVIO-19
Fundfe*)
With Outlay*
|COVH> 19
lundtnf}
Crit«rl»
Scort
Non-Statistical
tintlfttH ol Agency
SubmKuod
40
40
so
(ompMfMU ol Summary
llMl Data (Fife* A * 0)
ISO
SIjO
100
Suability ol fiteC lot
Sample Selection
130
ISO
too
Nevoid itvH linkage*
[f a#* c 4 Di/oi)
90
to
10
C OVID 19 Outlay letting
Non Statistical Sample
Ho COVT&-19 funding
00
to
Statistical
CompJetene**
ISO
ISO
ISO
Accuracy
19 9
900
900
Timeline**
ISO
ISO
ISO
Quality
Scor*
Excellent
99.856
1000
1000
3 Based on a 95% confidence level, the projected error rate for accuracy of the data element is between 00.0% and
20.0%
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Independent Auditors" Report on Compliance with DATA Act
Table 3 - Range of Score for Data Quality
Quality Level
Range
Level
0
69.999
Lower
70
84.999
Moderate
85
94.999
Higher
95
100
Excellent
Based on the results of our statistical and non-statistical testing for CSB's DATA Act audit for FY 2020
3rd quarter, CSB scored 99.856 points, which is a quality rating of Excellent.
Implementation and Use of the Data Standards
We have evaluated CSB's implementation of the government-wide financial data standards for award and
spending information and determined the CSB is using the standards as defined by OMB and Treasury.
CSB linked by common identifiers (e.g., PUD, FAIN), all of the data elements in their procurement,
financial, and grants systems, as applicable. For the Treasury's DATA Act Broker files tested, we
generally found that the required elements were present in the file and that the record values were
presented in accordance with the standards.
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Independent Auditors' Report on Compliance with DATA Act
Appendix A - Objectives, Scope, Methodology, and Criteria
Appendix A - Objectives, Scope, Methodology, and Criteria
Objectives
The objectives of the performance audit of the CSB's compliance with the DATA Act are to assess the (1)
completeness, timeliness, quality, and accuracy of CSB FY 2020 third quarter, financial and award data
submitted to Treasury for publication on USASpending.gov; and (2) CSB's implementation and use of
the Government-wide financial data standards established by the OMB and Treasury.
Scope
The scope of this engagement is the CSB's FY 2020 third quarter financial and award data submitted for
publication on USAspending.gov. The work performed was in accordance with the standards applicable to
performance statement audits contained in Government Auditing Standards issued by the Comptroller
General of the United States, relevant DATA Act guidance and policies issued by the GAO, OMB, and
CIGIE, including the Inspectors General Guide to Compliance under the DATA Act, dated December 4,
2020.
The scope includes examining DATA Act information reported in the CSB's FY 2020 third quarter
financial and award data files listed below, as applicable:
• File A: Appropriations Account,
• File B: Object Class and Program Activity,
• File C: Award Financial,
• File D1: Award (Procurement)
• File D2: Award (Financial Assistance),
• File E: Additional Awardee Attributes, and
• File F: Sub-award Attributes
Files A, B, and C are submitted by the CSB's DATA Act Accountant group. Files A and B are summary-
level financial data. File C is reportable award-level data. Files D1 through F contain detailed
demographic information for award-level records reported in File C. Files D1 through F are submitted by
external award reporting systems (FPDS.gov, SAM.gov, and Federal Subaward Reporting System) to
Treasury's DATA Act Broker. The CSB did not have any required reporting data for File D2. The Senior
Accountable Officer (SAO) for the CSB is required to certify these seven data files for its agency's
financial and award data to be published on USASpending.gov. The CSB SAO did not disclose any data
limitations in the FY 2020 Q3 DATA Act submission certification, and we did not note any data
limitations during our audit.
Methodology
To accomplish our objectives, we:
• obtained an understanding of any regulatory criteria related to the CSB's responsibilities to report
financial and award data under the DATA Act. (See below for a list criteria);
• assessed the internal and information system controls in place as they relate to the extraction of
data from the source systems and the reporting of data to Treasury's DATA Act Broker, in order
to assess audit risk and design audit procedures;
• assessed internal controls over financial reporting for the DATA Act;
• reviewed and reconciled the FY 2020 third quarter summary-level data submitted by the CSB for
publication on USAspending.gov;
• assessed the CSB's implementation and use of the 59 data elements/standards (as applicable)
established by OMB and Treasury; and
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Independent Auditors' Report on Compliance with DATA Act
Appendix A - Objectives, Scope, Methodology, and Criteria
• assessed the completeness, timeliness, accuracy, and quality of the financial and award data
sampled; this included testing the CSB's submission of Files A through Dl.
To test the CSB's DATA Act submission of Files A through Dl, we:
• reviewed the CSB's certification and submission process;
• determined the timeliness of the CSB's submission;
• determined the completeness of summary level data for Files A and B;
• determined whether File C is complete and suitable for sampling;
• randomly selected and examined a statistically valid sample of 14 records from a population of 15
total records in the CSB's FY 2020 third quarter certified spending data reported in File C;
• tested detailed record-level linkages for Files C and Dl;
• tested detailed record-level data elements for Files C and D1 for completeness, accuracy,
timeliness, and quality; and
• analyzed results.
Criteria
We determined the following criteria in the table below were applicable to the CSB DATA Act audit:
Criteria
1
Digital Accountability and Transparency Act of 2014 (DATA Act), PL 113-101
2
Federal Funding Accountability and Transparency Act of 2006 (FFATA), PL 109-282
3
Federal Managers' Financial Integrity Act of 1982 (PL 97-255, 96 USC Sec. 807)
4
OMB Circular No. A-123
5
OMB Management Procedures Memorandum No. 2016-03
6
OMB M-17-04 Additional Guidance for DATA Act Implementation: Further Requirements for
Reporting and Assuring DATA Reliability
7
OMB M-20-21 Implementation Guidance for Supplemental Funding Provided in Response to the
Coronavirus Disease 2019 (COVID-19)
8
OMB Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of
Information Disseminated by Federal Agencies
9
OMB Open Government Directive-Framework for the Quality of Federal Spending Information
10
DATA Act Information Model Schema (DAIMS) v. 2.0 (including RSS, IDD, and Practices and
Procedures)
11
DATA Quality Playbook
12
Federal Spending Transparency Data Standards and Whitepapers
13
DATA Act Broker Validation Rules
14
U.S. Digital Services Playbook
15
Government Auditing Standards (The Yellow Book)
16
Standards for Internal Control in the Federal Government
17
Federal Acquisition Regulation (FAR)
18
Federal Procurement Data System (FPDS)-Next Generation (NG) Data Dictionary
19
FPDS-NG User Guide
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Independent Auditors" Report on Compliance with DATA Act
Appendix B - Summary of Results for Record-Level Data Elements
Appendix B - Summary of Results for Record-Level Data Elements
Table 4 - Summary of Results for Record-Level Data Elements
Summary of the results of the detailed record-level test of data elements for Files C and Dl. CSB's results
listed in descending order by accuracy error rate percentage. We determined that the identified risks in
CSB's Data Quality Plan (DQP) were consistent with the results of testing for reported data.
CSB's Results for Data Elements
in Descending Order by Accuracy Error Rate
DAIMS
Element #
Data Element Name
A
Accu racy
c
Completeness
T
Timeliness
3
Ultimate Parent Unique Identifier
21%
0%
0%
1
Awardee/Recipient Legal Entity Name
0%
0%
0%
2
Awardee/Recipient Unique Identifier
0%
0%
0%
4
Ultimate Parent Legal Entity Name
0%
0%
0%
5
Legal Entity Address
0%
0%
0%
6
Legal Entity Congressional District
0%
0%
0%
7
Legal Entity Country Code
0%
0%
0%
8
Legal Entity Country Name
0%
0%
0%
11
Amount of Award
0%
0%
0%
12
Non-Federal Funding Amount
0%
0%
0%
13
Federal Action Obligation
0%
0%
0%
14
Current Total Value of Award
0%
0%
0%
15
Potential Total Value of Award
0%
0%
0%
16
Award Type
0%
0%
0%
17
NAICS Code
0%
0%
0%
18
NAICS Description
0%
0%
0%
19
Catalog of Federal Domestic Assistance (CFDA) Number
0%
0%
0%
20
Catalog of Federal Domestic Assistance (CFDA) Title
0%
0%
0%
22
Award Description
0%
0%
0%
23
Award Modification / Amendment Number
0%
0%
0%
4 These error rates do not reflect projected error rates to the population, but error rates from the sample alone
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Independent Auditors" Report on Compliance with DATA Act
Appendix B - Summary of Results for Record-Level Data Elements
DAIMS
Element #
Data Element Name
A
Accu racy
c
Completeness
T
Timeliness
24
Parent Award ID Number
0%
0%
0%
25
Action Date
0%
0%
0%
26
Period of Performance Start Date
0%
0%
0%
27
Period of Performance Current End Date
0%
0%
0%
28
Period of Performance Potential End Date
0%
0%
0%
29
Ordering Period End Date
0%
0%
0%
30
Primary Place of Performance Address
0%
0%
0%
31
Primary Place of Performance Congressional District
0%
0%
0%
32
Primary Place of Performance Country Code
0%
0%
0%
33
Primary Place of Performance Country Name
0%
0%
0%
34
Award ID Number (PIID/FAIN)
0%
0%
0%
35
Record Type
0%
0%
0%
36
Action Type
0%
0%
0%
37
Business Types
0%
0%
0%
38
Funding Agency Name
0%
0%
0%
39
Funding Agency Code
0%
0%
0%
40
Funding Sub Tier Agency Name
0%
0%
0%
41
Funding Sub Tier Agency Code
0%
0%
0%
42
Funding Office Name
0%
0%
0%
43
Funding Office Code
0%
0%
0%
44
Awarding Agency Name
0%
0%
0%
45
Awarding Agency Code
0%
0%
0%
46
Awarding Sub Tier Agency Name
0%
0%
0%
47
Awarding Sub Tier Agency Code
0%
0%
0%
48
Awarding Office Name
0%
0%
0%
49
Awarding Office Code
0%
0%
0%
50
Object Class
0%
0%
0%
51
Appropriations Account
0%
0%
0%
53
Obligation
0%
0%
0%
54
Unobligated Balance
0%
0%
0%
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Independent Auditors" Report on Compliance with DATA Act
Appendix B - Summary of Results for Record-Level Data Elements
DAIMS
Element #
Data Element Name
A
Accu racy
C
Completeness
T
Timeliness
56
Program Activity
0%
0%
0%
57
Outlay (Gross Outlay Amount By Award CPE)
0%
0%
0%
163
National Interest Action
0%
0%
0%
430
Disaster Emergency Fund Code
0%
0%
0%
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Independent Auditors' Report on Compliance with DATA Act
Appendix C - Accuracy of Dollar-Value Related Data Elements
Appendix C- Accuracy of Dollar-Value Related Data Elements
Table 5 - Accuracy of Dollar-Value Related Data Elements
The Accuracy of Dollar-Value related Data Elements is presented in Table 4 below.
PI ID/FA IN
#
Data
Element
Accurate
Not
Accurate
Not
Applicable
Total
Tested
Error
Rate
Absolute Value
of Errors
PUD
DE
11
Federal Action
Obligation
14
0
0
14
0%
$0
PUD
DE
14
Current Total
Value of Award
14
0
0
14
0%
$0
PUD
DE
15
Potential Total
Value of Award
14
0
0
14
0%
$0
PUD
DE
53
Obligation
14
0
0
14
0%
$0
FAIN
DE
11
Federal Action
Obligation
0
0
0
0
0%
$0
FAIN
DE
12
Non-Federal
Funding Amount
0
0
0
0
0%
$0
FAIN
DE
13
Amount of Award
0
0
0
0
0%
$0
FAIN
DE
14
Current Total
Value of Award
0
0
0
0
0%
$0
FAIN
DE
53
Obligation
0
0
0
0
0%
$0
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Independent Auditors' Report on Compliance with DATA Act
Appendix D - CIGIE s DATA Act Anomaly Letter
Appendix D - CIGIE's DATA Act Anomaly Letter
Council af the
tP Inspectors General
an INTEGRITY and EFFICIENCY
Decttfilwr 22, 2D 15
The HiTniri-uble Ron Jolsfiu gnsirc* . 11 «f'
¦spptree ibics your leadership nn i«u«.i of fEovcmrneul transparency arid acoou&tabality. In
jinrhcii 'sr. fcditvc- ihe rnHill wrm ! a*l vcai «>f°lhc Diutui: .VrcnLMitahiliiy arJ Trareparer . v Ail
of 2034 (DATA Acovt.ll -si&n ifk.rnllj improvr rhequ :15iy of Federal spending data available tu.
Co Kg rtis, tile public. ajyd (he S£>c™nt.ibilil} cornnnumlj Ef putipe rly !r.pl-_'ioer4c+F To mike £i*rc
thi* happens, "lie DATA Ad provides. Sir strong ovetsi^lii Tjj waj of ihe Federal Inqwciww
General aisd ll« (mvcrnncnl AcCtiurtabilily Office {CJAO;< Jn particular, the DATA M
ro(it; rc-, a icik-s of reports from ead-i it» iii-.-ijJe, jcriong L'lhsr *li:ry.>- jm nvmi of i-ha
mtnpM^nc^ nmelibeEj, quality. and accuracy of data srAmlitsd by ogs«nei« under cfu* DA IA
Atx.
[ am writing this leiscr on behalf of CIGJE io bafcpr® vou af an important ifenlnc, acamoly with
lis werssthi re>jui rcme®; fci Inspectors General ;n the DATA Act, Your staffs hov« b«n
IMilCixI Cfi "ti;r timing 2nram.il>1., Which iiKcti die- fiisi frjspC'Scr timcn; repeats rt_qLifted try lba
DATA Act Specifically, Hie first Inspector Ucnctal repe.is arc due lo Congress in November
201 fi. Hc«e«er. ihe n®cn.«« we ¦pversec are n«i required r-n >i ->ni»1 spend he data hi con-|diance
with Hi..' IJATA Avt until Mut SI 17, Asa fcuik. Fn^rectcni {n(
ot% die «f«adin^ data s-uhrmilcd undrr die- Act. « this dalu will i*t)i exist until the fcjBowing y««.
This ai»rt»Fil> wmi.ild cause the body of re^Kwts * tibmniied bj- rhe Imprvtor* 4 sernral >n Nravcrnber
2036 Id be of nil niiM ^I use to the pufcdii'. llsc Con |acsi. ihc EsCLTJliifd Onusi-ls. and C^l ttfii
To iltlrMts ihii rtf|vin inu dnce anotTuilj ihr Inapoclora \ ii'ivji,! plan Co f«ov».lc CoragrfSi wilh
-Jiltt ftttt rMiubvU an Nuv«- 281:7, onc-vcw delay frons die due dale in *uti.ie, vrith
ssifton iaenl it^Hrrls pr-lli'-tvi nn on si livo-year irjcle. in NuveniTitr 2019 and Kintr:il'<-: 2021. We
believe lltil moving the due Jultrs L^k out yenr will ei^Wr das l««pec|i:irK Cleneral to mtw-l the
I f I? H '' I.Tl Si lA s I..' H""*. V, -J. T-liT: . ' I In
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Independent Auditors' Report on Compliance with DATA Act
Appendix D - CIGIE s DATA Act Anomaly Letter
Page 2
intent of ihc oversight provisions in (he DATA Aci and provide useful reports far the public, *he
Congress* the Executive Qiaach. arid others.
Although we think Hk best course of action is to delay the inspector General reports, CIG1E is
encouraging tl«- Federal Jjaspeciut General Community 10 undertake DATA Act "readiness
reviews" at iheii respective amende* well in advance of the fim November 2017 report.
Through n working group. GIG IE has developed guidance for these reviews-. 1 am pleased to
report thai several [nspeciors General have already begun, reviews at their respective agencies*
and many Inspectors General are planning £l> begin reviews in the near future. We believe that
flwse reviews, which are in addition to the specific oversight requirements uflhc Aet, will assist
jill parlies in helping to ensure the snceea of ttic DATA AM implcrnentniinn
We have kept GAG officiate informed ateul our plan so delay the Krai Inspector General reports
fot one year, which they are oomfonable wll&. and out ongdng efforts to help ens'iire early
engagement ihmiiuh inspector General readiness reviews.
Should you or your staffs have any questions about our approach or otliej aspects of out
collective DATA Act oversight activities, please do not hesitate to contact me at (202) 5140435-
Michael Ei. Horowitz
Chair, Council of the Inspectors General nn Integrity and Efficiency
lit peelor Genenak LIS. Department of Justice
ce: The I Uirwmiblii David Mader, Controller. OMB
The Honorable Gene Poclaro, CcwriptreJler General, GAO
Sincerely,
jula
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Independent Auditors' Report on Compliance with DATA Act
Appendix E - Management's Response
Appendix E - Management's Response
U.S. Chemical Safety and Hazard Investigation Board
U.S. Chemical Safety and
Hazard Investigation Board
Memorandum
To:
Paul C. Curtis, Director - Financial Directorate, Office of Audit, Office of Inspector
General
From: Katherine A. Lemos, Chairman and CEO'
Cc: David LaCerte - Acting Managing Director
Bruce Walker - Senior Advisor and Audit Liaison
Michele Lawson — Finance Director
Chuong Dai Nguyen - Acting Chief Financial Officer
Subject: Management Response to the Office of Inspector General (OIG) Fiscal Year 2021 DATA
Act Performance Audit Report
Date: October 27, 2021
The U.S. Chemical Safety and Hazard Investigation Board (CSB or "Agency") has performed
significant work since the passage of the Digital Accountability and Transparency Act (DATA
Act) in FY 2014. This work includes the development and implementation of enhanced guidance
and processes to review, identify, and determine discrepancies, and address potential data quality
issues on a monthly basis. This work also includes reporting to OMB and certifying the
accuracy rate of the CSB's USAspending.gov data on a quarterly basis. These accomplishments
are a testament to the Agency's commitment to improved transparency and accountability of
spending data.
The CSB is fully compliant with the DATA Act reporting requirements and exerts effective
controls over our DATA Act reporting process. The OIG's draft report identified the following
results for the transactions sampled in the audit: 0.00% for the completeness error rate; 0.73%
for the accuracy error rate; and 0.00% for the timelines error rate. Based upon our review of the
draft OIG report, we concur with the audit determination that the CSB's data was generally of
excellent quality - that is, significant amounts of the data were complete, timely, and accurate.
We are also very pleased to note that the accuracy error was attributed to a third party (namely,
FPDS-NG, which extracted data from SAM; the error did not involve data that was manually
entered either by the CSB or by the CSB's service provider), and that no recommendations were
made to the CSB.
We appreciate the opportunity to respond to the OIG draft report. Please contact Chuong Dai
Nguyen in the Office of Financial Operations at (202) 302-9090 with any questions.
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Independent Auditors' Report on Compliance with DATA Act
Appendix F - Glossary of Abbreviations and Acronyms
Appendix F - Glossary of Abbreviations and Acronyms
BFS/ARC
Bureau of Fiscal Service, Administrative Resource Center
CARES Act
Coronavirus Aid, Relief, and Economic Security Act of 2020
CIGIE
The Council of the Inspector General on Integrity and Efficiency
COVID-19
Coronavirus Disease 2019
CSB
Chemical Safety and Hazard Investigation Board
DAIMS
DATA Act Information Model Schema
DATA Act
The Digital Accountability and Transparency Act of 2014
DE
Data Element
DQP
Data Quality Plan
DEFC
Disaster Emergency Fund Code
EPA
Environmental Protection Agency
FABS
Financial Assistance Broker Submission
FAEC
Federal Audit Executive Council
FAIN
Federal Award Identification Number
FAR
Federal Acquisition Regulations
FFATA
Federal Funding Accountability and Transparency Act of 2006
FPDS-NG
Federal Procurement Data System Next Generation
FY
Fiscal Year
GAO
Government Accountability Office
GTAS
Government-wide Treasury Account Symbol Adjusted Trial Balance System
IDD
Interface Definition Document
IG
Inspector General
OFF
Oracle Federal Financials
OMB
Office of Management and Budget
PUD
Procurement Instrument Identifier
PRISM
Procurement Request Information System Management
RSS
Reporting Submission Specification
SAM
System for Award Management
SAO
Senior Accountable Official
TAS
Treasury Account Symbol
Treasury
The United States Department of the Treasury
URI
Unique Record Identifier
18
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