DATA Act Implementation: Four Guiding Principles

Enactment of the Digital Accountability and Transparency Act in May, 2014 provides many opportunities for the Office of Management and Budget and the Department of Treasury to improve the public transparency of Federal spending while simultaneously reducing the overall reporting burden on both Principal Investigators and institutional Research Administrators. However, there are also many implementation scenarios that may end up increasing burden and reducing research efficiency if the new requirements are not handled appropriately.

Below are four key principles that should guide any future requirements:

1. Reduce and Eliminate Duplicative Reporting

2. Minimize Data Collected by Principal Investigators

3. Maximize Use of Electronic Reporting Systems

4. Adopt Standard Data Definitions

The details of how these principles are implemented is also crucial. The Federal Demonstration Partnership (FDP) stands ready with volunteers to participate in the legislatively-mandated demonstration pilot and our members are available to talk with OMB and Treasury about their previous transparency reporting experiences.

1. Reduce and Eliminate Duplicative Reporting

Federal award recipients are required to report programmatic, financial, and subaward information through a number of different agency systems and interfaces. The DATA Act provides a unique opportunity to continue consolidating these systems. A first step would be to consolidate Federal Financial Reporting (through the SF425) with subaward reporting. These data elements are common amongst Federal agencies and could be joined as a single report submission from recipients. Additionally, recipients are required under previous transparency reporting systems to submit information on data elements (e.g. Treasury Account Symbol) that are already maintained by Agency systems. These should be eliminated so that the agencies, not individuals, provide the maximum amount of transparency act reporting information as they can, which is only then supplemented by reports from recipients on data that only the recipient would have access to.

2. Minimize Data Collected by Principal Investigators

The FDP has shown through its Faculty Workload Survey (both in 2005 and 2012) the increasing burden of Federal reporting and administrative requirements on researcher productivity. To help ensure that the new DATA Act requirements will not add additional faculty burden, the following should be considered:

• Restrict DATA Act reporting to financial and administrative data that does not require input from Principal Investigators, and can instead be handled by institutional officials and research assistants.

• Utilize narrative programmatic reporting provided as part of the existing agency reporting system and exclude it from the DATA Act reporting. Agencies will then be responsible for submitting this to a central DATA Act transparency system. For example, Principal Investigators already provide performance updates through their agency RPPR submissions. Simply modifying this requirement to allow a public version of the reporting data in the RPPR would allow PIs to only report once with information summarized from their full report.

3. Maximize Use of Electronic Reporting Systems

The recent GRIP (Grant Reporting Information Project) pilot demonstrated one way that electronic reporting could be implemented that would both reduce duplicative financial reporting and provide agencies rapid access to reports for oversight and monitoring purposes. However, limitations of the pilot provide a number of lessons to be learned.

• Currently, not all agencies accept electronic financial reporting through the SF425. The DATA Act implementation is a prime opportunity to continue this implementation. We propose OMB consider either 1) a central reporting of SF425 data through a single portal with the data subsequently forwarded to agencies for processing, or 2) require decentralized reporting of SF425 data to agencies with a required submission of financial data to a central DATA act transparency system.

• Allow batch submission of data through a web-service or XML data stream from recipient institutions to a central DATA Act transparency site.

4. Adopt Standard Data Definitions

Current efforts through OMB's development of Uniform Guidance to agency efforts creating the Research Performance Progress Report, progress has been made in standardizing the use of data elements amongst agencies. However, more work needs to be done as agency-specific reporting requirements continue to overlap existing data elements or significantly redesign existing elements so that recipients are able to collect them in a consistent manner.

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Contractors and Grantees
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Reporting compliance requirements shared by prime and subawardees of Federal procurements and grants
Key Participants: contractors, grantees, cooperative agreement holders, and subawardees
- Question: If you could change one thing that would ease your reporting burden associated with your awards, what would it be (e.g. time, cost, resource, other)?
- Question: If you have reporting requirements to the Federal government, how are those met?
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities or functions would you include?
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Procurement practices, processes, and reporting
Key Participants: Contractors and subcontractors
- Question: If you could change one thing that would ease your reporting burden associated with your awards, what would it be (e.g. time, cost, resource, other)?
- Question: If you have reporting requirements to the Federal government, how are those met?
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities or functions would you include?
- Question: Are there any reporting areas in the FAR that are similar in nature to those in Federal agency supplements?
- Question: What other compliance information are you providing to the Federal government outside of the procurement process that could be used in procurement reporting and reduce duplication?
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Grantees
*To participate in the dialogue, you can submit a new idea by clicking "Submit New Idea" to the right, or you can vote and comment on existing ideas below.

Grants practices and processes
Key Participants: grantees, cooperative agreement holders, subgrantees
- Question: If you could change one thing that would ease your reporting burden associated with your grants or subgrants, what would it be (e.g., time, cost, resource burden)?
- Question: If you have reporting requirements to the Federal government, how are those met? (feel free to be specific about what is reported to whom and through what mechanism)
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities/functions would you include?
OMB circular A-133:
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditee?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditor?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting to the Federal Audit Clearinghouse?
Uniform Guidance (2 CFR 200):
- Question: Are there requirements in the new 2 CFR 200 that need additional clarification for improved implementation with reduced administrative burden ?
- Question: What are the perceived burdens associated with the new standards such as the documentation of salaries & wages and time & effort (2 CFR 200.430), subrecipient monitoring (2 CFR 200.331), procurement standards (2 CFR 200.317- 2 CFR 200.324)?
- Question: How can the administrative burden associated with standards compliance be lowered?
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