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Implementing the DATA Act: Working Across Boundaries

May 19, 2017





The Executive branch was given three years to implement its key provisions. A key deadline was to post all federal spending data on a single website by May 9, 2017.

The DATA Act requires all federal spending data, including for the first time interagency transfers, to be posted on at least a quarterly basis. That includes more than $3.8 trillion in annual federal spending and the public will be able to track these funds from Congressional appropriations to local communities and businesses for the first time.

The scale of this initiative was huge and required significant stakeholder engagement, including transparency and advocacy groups. What technical and administrative strategies were used to develop the standards, collect and display the data, insure its reliability, and to engage stakeholders in a meaningful way to ensure their support in the collection and use of the resulting data? What lessons were learned that could be applied to other large-scale, governmentwide initiatives in the future?

Background Reading

Context

Implementing the DATA Act successfully looked to be daunting in the beginning. It was not a popular piece of legislation among executive branch agencies, who were skeptical about its value and because there was little funding to help agencies implement the legislation (the Congressional Budget Office estimated that implementation efforts would cost agencies about $300 million in its first five years). When the project started, only one other country – Finland – had tried anything this ambitious, to pull meaningful info from existing financial, acquisition, and grant systems.

However, there were some bright spots facing those charged with implementing the law – chiefly that the top leaders responsible in both the Office of Management and Budget and the Treasury were long-time, executives who had worked together before, and trusted and respected each other. They approached their joint challenge from the perspective of what was good in the long run for the government, not the institutional perspectives of their respective organizations. Other significant success factors include: (1) a full-time Treasury implementation team, (2) its use of innovative and open approaches to developing the key deliverables, and (3) a commitment to proactively engagement a wide range of stakeholders – external advocacy groups, congressional advocates, and the audit community.

Success Factors 

The speakers described ten factors that they attribute to the initial success of launching the first reporting cycle of the DATA Act on May 9, 2017 – the launch date set in law three years earlier. These factors may be applicable to the implementation of other governmentwide initiatives:

Mandates 

There were clear legal mandates and timeframes for agencies set in the statute. Having a law in place was critical to making progress and motivating agency compliance.

Leadership 

OMB and Treasury are jointly accountable under the law for implementation and the leadership of both were on the same page. The initial leaders, Danny Werfel (OMB) and Dick Gregg (Treasury), were long-time career executives who knew each other and respected each other before they were appointed to their positions. The subsequent leaders, David Mader (OMB) and David Lebryk (Treasury) were also long-time career executives who knew each other and had worked together in Treasury over 20 years before each received their respective jobs. This good working relationship, and their willingness to stick their necks out in their own respective organizations for each other, cascaded down within their teams.

Vision

The top leaders created a common strategic intent/ vision for the overall project – “Better data, better decisions, better government” – that helped guide the effort overall.

Business Case

Because of agency antipathy to a mandate that was perceived as costly busy-work, the leadership of the DATA Act implementation initiative set out to make a business case for why this initiative is important. For example, they created a common “sales pitch” to agency CFOs, laying out a future vision for federal financial management and explaining how the data under this law could elevate their role and allow them to use data to inform decision-making. If CFOs want to shift from a focus on auditing and transactions to a role of being a strategic leader in their agencies, they needed to have access to near real-time financial data, which the DATA Act will produce.

Governance Structure

The implementation team created a governance structure to ensure effective execution: Executive steering committee, comprised of OMB and Treasury officials.

An interagency advisory committee, comprised of representatives of the business and functional communities across the government that have stakes in DATA Act implementation (e.g., the CFO, CIO, and CAO Councils).

An identified Senior Accountable Officials at each federal agency who is accountable for certifying the data submitted to Treasury, and convened them on a regular basis, as well.

Program Management Office (PMO). The leadership team created a program management office in Treasury with full-time staff dedicated to implementing this law. Deputy assistant secretary Christina Ho, was charged with leading a small team. She recruited a mix of talent from different perspectives (e.g., former congressional staff, the Sunlight Foundation advocacy group, former DATA Act staff, contractors, and detailees from other agencies and 18F). They saw themselves as advocates for transparency, and providing value to the agencies and public – not just compliance with the law. As such, they did not see themselves bound by traditional thinking on how to implement things in government. They were all “problem-solvers, not process-focused.”

External Pressure

Several congressional sponsors of the legislation -- including, Sen. Mark Warner, Rep. Darrell Issa and the leadership of the House Oversight and Government Reform Committee remained actively engaged. The House held hearings and the bipartisan oversight and interest was critical to the success of the project. External advocacy groups, notably the DATA Coalition, provided expertise and public oversight. This external attention was seen as useful. In addition, the law included statutory requirements for GAO and the agency IG to assess progress and the quality of the data. These actions helped focus agency attention.

Robust Communications/Engagement Strategy

Individual members of the leadership team and the PMO invested a lot of time and effort in consulting with a wide range of stakeholders, both inside and outside government.

For example, existing relationships of individual team members with the different professional communities within the federal government – e.g., financial assurance, procurement.

Regular engagement with external stakeholders, not just meetings with agencies. Including an online collaboration webpage, an open beta site and monthly external stakeholder calls (e.g., after May 9th launch, the team received a public comment about the functionality of the website, and one week later, it had incorporated that change into the site).

Data-Centric Approach 

Christina Ho had a data-centric vision that allowed agencies to map the required data from their existing systems and submit the data to Treasury based on a standard format. This lower-cost approach minimized IT system changes which was key to the project’s success and significantly reduced the burden and costs to agencies. Ho sought counsel from the experts at 18F and the U.S. Digital Services to help advise and build support for the data-centric approach.

Open Implementation Strategy/ Agile Methodology

The key reason Treasury met the deadline is because it strategically chose to implement an agile development approach, rather than use a traditional waterfall development approach, and to leverage existing resources to the greatest extent practicable. Unlike the traditional waterfall development approach, which requires defining the requirements up-front, the agile method requires making decisions and changes based on the circumstances observed as the project is being implemented.

The PMO team felt the implementation approach it used – based on agile principles -- was “revolutionary” and since this is the first governmentwide agile project it was not well-understood in regard to its potential impact. It took a leap of faith within the government community to adopt the agile approach, along with some conviction in the vision the team had. For example:

  • They typically did not seek permission to do things. They just did it.
  • Every two weeks, there were new deliverables, then adjustments based on user feedback.
  • The PMO team focused its approach on user-centered design, where they consulted widely and frequently with agencies, public, stakeholders.
  • The PMO team used an Open Development approach, where the code is open source and anyone can look at it and offer tweaks.

Role of the Auditors

The law included significant amount of oversight requirements during the implementation phase (which was not common in other government wide laws). This caused agencies to better document what they were doing re: implementation. For example, there were 18 GAO audits of the progress of the implementation. Because the project used agile techniques, the Treasury PMO team was able to pivot quickly to respond to recommendations.

Within the IG community, the Treasury IG took the governmentwide lead, in concert with the cross-agency Council of the Inspectors General for Integrity and Efficiency. The law had a mis-step in timing, asking for an audit before standards were in place, so in lieu of that, the IGs conducted “readiness reviews” in their agencies: 48 IGs assessed whether their agencies were meeting requirements. A GAO report summed up the IGs’ work and concluded most agencies were on track as of January 2017.

Traditionally, IGs audit progress in implementing IT projects based on whether they met “waterfall” standards, but realized they needed to shift their approach to conform to the “agile” approach being used by the PMO (see GAO guide on use of agile in government). Treasury’s IG developed an audit standards guide that accommodated the agile approach for other IGs to use in assessing their agencies’ DATA Act implementation progress.

The IG community had to learn Agile lingo, and methodology. They had to develop their own guides, conduct training, workshops, iterative guides, so there wouldn’t be different IG interpretations of progress across agencies.

It Wasn’t Easy, and There’s Still a Lot to Do. While there has been a significant amount of progress, it wasn’t easy. For example, in setting standards, there was significant debate among different professional communities as to who “owned” a term.

Still need to get the financial management systems in different agencies to change their cadence as to when they produce data.

The “door opened” on May 9 for the public’s new view and use of federal spending data, but there is more to do, through 2022 according to a report by the DATA Foundation and Deloitte, when the act is to be fully implemented.

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