OMB Proposes Changes to A-11 to Accommodate DATA Act Implementation

Published: July 02, 2014

OMBPolicy and Legislation

The DATA Act warrants major changes to the way agencies prepare and submit their annual budget documents to OMB. OMB drafted changes to circular A-11, the federal instructions for agency budget submissions, which will support DATA Act implementation over the next several years.

Federal News Radio recently obtained this draft document detailing proposed changes and a timeline for implementation.

Agencies are expected to implement the complex requirements of the DATA Act with no new funding.  However, Congress is giving civilian agencies three years for implementation and DOD five years.

Overall major agency DATA Act requirements include:  

  • Expansion of data posted on  
  • Establishment of data standards for  
  • Recommendations for streamlining recipient reporting  
  • Establishment of a Data Analysis Center  
  • Reporting of non-tax debt

The proposed changes to the A-11 address the DATA Act requirement for agencies to report obligations and outlays in three different ways:  program activity, object class, and program activity by object class. 

OMB has named their SF 133 Report on Budget Execution and Budgetary Resources as a common starting point for data to be used to fulfill requirements of the DATA Act.  OMB’s proposed A-11 changes state, “The SF 133 provides a solid foundation to respond to two requirements in the DATA Act: (1) reporting all data, government-wide, and (2) reporting accurate data.”

The DATA Act calls for agencies to report obligations outlays by program activity, however these program activities do not necessarily track directly to the detailed data in agency financial systems.  OMB’s response to Congress requests that agencies be able to characterize “program activity,” as one of the following, not the current definition of program activity used in the president’s budget:

  • An entire Treasury Appropriation Fund Symbol (TAFS), e.g. DOT’s Surface Transportation Priorities (69-0538 /X)  
  • A single Category B project in a given TAFS  
  • Each of several Category B projects in a given TAFS  
  • A Category B project from each of two TAFSs, e.g. ED’s Career, Technical, and Adult Education account has a program, Regional Education Labs, funded in two TAFSs (91-1100 14\15 and 91-1100 13\14)  
  • A program reporting category (used on the apportionment and typically housed as an allotment or sub-allotment in the agency system) used in one TAFS or two or more TAFSs.

OMB would like to be able to refer to any of the above as a “DATA Act program” and use them to fulfill the requirement for reporting outlays and obligations by program activity.

Additionally, OMB recommends not to immediately implement the requirement for reporting program spending by object class.  Object classes categorize federal spending into specific product and service categories.  Major object classes include personnel compensation and benefits; contractual services and supplies; acquisition of assets; grants and fixed charges; and other.

According to OMB, past efforts to capture program spending by object class have failed.  OMB is concerned about the infrastructure necessary to support accurate and consistent reporting of object class data by program.  However, OMB believes agencies will be able to supply outlays and obligations by overall object class to in the nearer term. 

In the long run, DATA Act requirements should make federal spending data more transparent, but due to the lack of funding to support this effort, implementation will be a challenge and will take a number of years.