Do These 6 Things Now to Prepare for the DATA Act

by Steve Goodrich

March 18, 2015

By now everyone is familiar with the Digital Accountability and Transparency Act (DATA Act) passed by Congress last year with specific deadlines and know that Treasury, OMB, and others are busy preparing to address its requirements to disclose direct expenditures and link them to contracts, loans and grants. It requires the establishment of standards, improvements in the quality of data and streamlined reporting through the use of It may also, at the discretion of the Secretary of Treasury, establish a data analysis center to facilitate better analysis and increase efficiency. If implemented correctly, the act could provide an underlying framework to support not only transparency and accountability in government, but the improvement in efficiency and effectiveness of government programs.

To be prepared to meet the requirements and deadlines, agencies need to act immediately. Waiting until implementation time will be too late. Several critical management activities you can initiate right now include:

Profile your functions and systems and identify gaps. From contracts (and grants) to financial systems, to program and contractor systems, agencies should profile all functional and technical systems. Determine how various offices, functions, and systems currently define, house, prepare, and report on the data. Assess how they align with the Data Act requirements and standards and identify what will have to be done to comply. This is also an opportunity to take a hard look at your associated business processes and improve them for efficiency and effectiveness. Given that all agencies must comply, this also can be a time to share best practices and accelerate the improvements.

The heavy lift will be in data accuracy, compliance, and the rectification of multiple sources reporting the same data differently. For example, contract data (both obligated and spent) is reported through different systems and does not necessarily align with fiscal year spending that is required of the finance offices. All agencies have different systems, processes, and policies for doing this which contributes to the inaccuracies of reporting and the capacity to analyze. In a letter from the CBO to U.S. Rep. Chris Van Hollen dated March 11, 2015, the CBO essentially said it is difficult to identify, capture, and assess contract data related to the cost and size of the contract workforce. Agencies have their work cut out for them.

Figure out how your systems will talk to each other. Disparate systems may need to be funneling data to a central repository that cleanses and prepares the data to meet the required standards and reporting requirements. I know of several agencies who keep contract and financial data in separate systems requiring the data to be keyed and rekeyed into each other. This will be too heavy a lift under the Data Act. How will you get these systems to talk to one another effectively, timely, and at low cost.

Have a seat at the table. Treasury, the Data Transparency Coalition, OMB and others are very active in preparing for the Data Acts implementation. Meetings, conferences, and working groups are continually engaged. Participating in these sessions, agency managers can get ahead of the game and allows you to contribute to the thinking. This can also help agencies establish a Data Act program management office, directing the transition with real time and critical knowledge. To do so, put someone in charge that can get the job done, integrate all systems, as well as all sub organizations.

Leverage Others. As the implementation requirements slowly firm up, some agencies will be ahead of the game (internally or with contractor support). Since this is another unfunded mandate, seek out these organizations and learn from them so that you can increase efficiency, effectiveness, and minimize disruption as you plan for and conduct your transition.

Prepare for data analytics. This is the critical time to think about what you will do with the data and therefore how you want it to be structured, analyzed, and reported. The data will be fed into, but will also provide a gold mine for agencies to manage and make better decisions. You may for the first time see duplicative programs, underutilized grant funds, wide variations in the cost of goods and services, etc. Thinking through now how you may be able to use this as a management tool will help you better prepare for the future.

Prepare for change. Meeting the Data Act requirements will be very disruptive to your people, systems, policy, processes, etc. It is not just another compliance exercise. It will be an involved undertaking that will require significant change and disruption while you keep the trains running. Now is the time to be thinking about the Act's impact and the change management program required. Start by communicating this now. Incorporate in your message, the value of the Act to the agency and its programs, and be truthful about the impact it will have as you go through the transition. Designate a leader and put a plan in place. A program management office (PMO) will need to be established, people trained, policy written, resources assigned, and procedures prepared. New technologies may need to be implemented. New management tools will be created and data analytics will become a bona fide profession.

Don't get caught short. The mandated due dates will be upon you before you know it. Agency leaders should act now and perhaps be the ones others will learn from.



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