Audit of VA’s Compliance under the DATA Act of 2014

Continue the system modernization efforts that provide VA with the capability to generate the required DATA Act reporting files containing the necessary elements to meet compliance with the DATA Act. Ensure the modernization will provide the following:

a. Accurate reporting of object class, program activity codes, program activity names, and all other elements required by the DATA Act.

b. Award identification to allow VA to be able to develop a File C and reconcile the File C to both summary level data (Files A and B) and award level data (File D).

c. Reconciliations with subsidiary systems.

d. A mechanism to ensure transactions are reported that currently may be excluded due to the use of 1358s.

e. Standardized data fields to allow management to record an award ID across financial and supporting systems.

f. Subsidiary systems that are consistent with USSGL or adequately mapped to USSGL to ensure transactions contain the necessary data elements/field required to meet DATA Act reporting.

g. Differentiation between direct and reimbursable amounts.

Implement a grants management solution across all of VA’s grant programs and develop processes to ensure integration with the new reporting system.

Improve researching of all root causes of differences between the VBA source systems and the monthly GTAS balances as part of their File B reconciliations. Also, differences should be accumulated and assessed at an aggregate level. The total differences either allocated to programs, reclassified out of other programs, or attributed to MinX JVs should be researched and reported as part of the SAO sub-certification process.

Continue mapping efforts and ensure programs without entitlement codes are recorded with the correct program activity codes and names rather than defaulting to Compensation.

Work with component level SAO’s to ensure timely receipt of signed certifications.

Include more information in the SAO certifications, the Data Quality Plan document and the data submission about the costing and aggregation methodologies VA uses to report VHA data to increase transparency.

Implement internal controls and update policies and procedures to improve the accuracy of and completeness of the information submitted for DATA Act reporting. The internal controls should ensure the following: a. Excluded payments not reported due to zip code issues are researched, cleared, and reported in VBA’s life insurance FABS submission. b. The default code “90” for Congressional District is not used when the county or zip code are unknown; instead, perform research to obtain the required data. c. Guidance from OMB and Treasury is requested on the proper reporting of the face amount of insurance policies in VBA’s FABS submissions. d. Management’s policies and procedures (e.g., Standard Operating Procedures) and narratives are updated on a timely basis in coordination with the VA PMO for the most current DATA Act submission procedures and reporting requirements.

Ensure that reconciliations are complete, reconciling items are identified and researched, and any resolutions are clearly documented.

Investigate potential controls or processes that could identify 1358s that should be reported until the system modernization can implement a solution.

Implement internal controls and update policies and procedures to improve the accuracy of and completeness of the information submitted for FABS reporting. The update should include and adhere to all FABS and DAIMS reporting requirements.

Improve reviewing and validating eCMS actions to underlying contract documentation to assess the completeness and accuracy of data stored in eCMS. Identified exceptions should continue to be documented, and appropriate corrective actions (e.g., adequate training and guidance) should be completed to ensure and improve completeness and accuracy of data stored in eCMS.

Coordinate and report system errors to Treasury on an as needed basis to ensure all required or derivable data elements are reported for FABS submission.