8.2 Open Government, DATA Act of 2014 & Citizen-Centric Reporting

4.3 Open Government, DATA Act of 2014 & Citizen-Centric Reporting

Government transparency is an indispensable pillar of constitutional democracy. In the United States, the mandate for fiscal openness traces its origins directly to Article I, Section 9, Clause 7 of the U.S. Constitution: "...and a regular Statement and Account of the Receipts and Expenditures of all public Money shall be published from time to time."

In the modern digital era, public expectations of transparency have evolved far beyond the passive publication of multi-hundred-page paper accounting reports. Citizens, legislators, journalists, and civic watchdogs expect proactive, searchable, machine-readable, and near-real-time access to government financial data. Today's public financial managers must navigate a sophisticated regulatory and technological landscape defined by the DATA Act of 2014, the Evidence Act of 2018, digital open checkbook systems, and innovative reporting standards such as the AGA Citizen-Centric Reporting (CCR) initiative.

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The Paradigm Shift to Digital Government Transparency

Historically, public disclosure was primarily reactive. Under statutes such as the Freedom of Information Act (FOIA) of 1966 (5 U.S.C. § 552) and state-level public records acts, governments released information only upon formal request by an individual or organization, often subject to administrative delays and legal disputes over statutory exemptions.

Over the last two decades, public administration transitioned decisively toward proactive digital disclosure. Under this paradigm, governments publish structured datasets, contract registries, and expenditure ledgers openly on the internet by default, enabling automated aggregation, civic analysis, and algorithmic oversight without requiring formal FOIA filings.

REACTIVE TRANSPARENCY (Past)           PROACTIVE OPEN DATA (Present)
• Paper-based reports                  • Machine-readable digital formats (JSON, CSV)
• Released only upon formal FOIA request• Published openly by default
• Fragmented agency silos              • Standardized government-wide data schemas
• Multi-hundred-page technical ACFRs   • Standardized 4-Page Citizen-Centric Reports

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The Digital Accountability and Transparency Act (DATA Act) of 2014

The landmark statute driving digital federal financial transparency is the Digital Accountability and Transparency Act of 2014 (DATA Act, Public Law 113-101), which amended the Federal Funding Accountability and Transparency Act (FFATA) of 2006.

The Core Problem the DATA Act Solved

Prior to the DATA Act, federal spending data was severely siloed:

• Agency accounting systems tracked spending using internal accounting codes and the United States Standard General Ledger (USSGL).
• Budget execution was reported to OMB at the account level via the SF 133 / GTAS (Governmentwide Treasury Account Symbol Adjusted Trial Balance System).
• Federal awards (contracts and grants) were tracked in separate procurement and assistance databases—such as the Federal Procurement Data System-Next Generation (FPDS-NG) and Grants.gov—using completely different identifiers.

Consequently, it was practically impossible for Congress or the public to track a single tax dollar from a congressional appropriation bill down through agency budget allocations, out to a specific federal contract or grant award, and ultimately to the end recipient in a local congressional district.

Statutory Mandates of the DATA Act

The DATA Act resolved this fragmentation by enacting three revolutionary requirements:

1. Government-Wide Financial Data Standards: Directed the Department of the Treasury and OMB to establish government-wide data standards for financial data and spending information reported by federal agencies.
2. Linking Awards to Appropriations: Required agencies to report federal award data (contracts, grants, loans, direct payments) linked directly to the underlying agency budget accounts, program activities, and Treasury Account Symbols (TAS).
3. Universal Public Transparency via USAspending.gov: Mandated the transformation of USAspending.gov (managed by Treasury's Bureau of the Fiscal Service) into a comprehensive, searchable, accessible public website displaying all federal spending.

The DAIMS Architecture and the Six Data Files

To implement the DATA Act, the Treasury Department developed the DATA Act Information Model Schema (DAIMS). The DAIMS standardizes federal spending data across seven interrelated data files submitted or extracted into the DATA Act Broker:

┌────────────────────────────────────────────────────────────────────────┐
│                    DATA ACT BROKER DATA ARCHITECTURE                   │
├────────────────────────────────────────────────────────────────────────┤
│ File A: Budget Execution (SF 133 / GTAS by Treasury Account Symbol)    │
│ File B: Budget Object Class & Program Activity                         │
│ File C: Award Financial (Links TAS to specific Award Identifiers)      │
│ File D1: Award Procurement (Contract award attributes from FPDS-NG)    │
│ File D2: Award Financial Assistance (Grants & loans from agency systems)│
│ File E: Executive Compensation Data (Extracted from SAM.gov)           │
│ File F: Sub-Award Reporting Data (Subgrants & subcontracts from FSRS)  │
└────────────────────────────────────────────────────────────────────────┘

• File A (Budget Execution): Captures total agency budget authority, obligations, and unobligated balances by Treasury Account Symbol (TAS), extracted directly from GTAS trial balances.
• File B (Program Activity and Object Class): Breaks down budget obligations by OMB program activity codes and federal object classes (e.g., personnel compensation, travel, equipment) for each TAS.
• File C (Award Financial): The crucial linking pin of the DATA Act. It connects the financial general ledger transactions (TAS, program activity, object class) directly to individual federal award identifiers—the Procurement Instrument Identifier (PIID) for contracts or the Federal Award Identification Number (FAIN) for grants.
• File D1 (Procurement / Contracts): Contains detailed contract attributes (vendor name, Dun & Bradstreet / Unique Entity Identifier [UEI], award description, place of performance, contracting office), extracted from FPDS-NG.
• File D2 (Financial Assistance / Grants): Contains detailed grant and assistance attributes submitted directly by agency grant systems.
• File E and File F: Capture highly compensated executive compensation and sub-award (subcontract and subgrant) transactions.

The DATA Act Broker and Statutory Oversight

The DATA Act Broker is an automated validation engine operating at the Treasury Department. When federal agencies submit Files A, B, and C each quarter, the Broker executes hundreds of automated validation rules (e.g., verifying that obligations in File C do not exceed obligations in File B, and ensuring all FAINs and PIIDs exist in Files D1 and D2) before the data can be certified by the agency Senior Accountable Official (SAO) and published to USAspending.gov.

To ensure data integrity, the DATA Act mandated that each agency's Inspector General conduct biennial audits evaluating the completeness, accuracy, timeliness, and quality of the agency's spending data submissions, with the Government Accountability Office (GAO) preparing government-wide synthesis reports for Congress.

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Foundations for Evidence-Based Policymaking Act of 2018 (Evidence Act)

Signed into law as Public Law 115-435, the Evidence Act established an integrated framework requiring federal agencies to systematically build and use administrative data to evaluate program effectiveness.

The Evidence Act is organized into three major titles:

• Title I: Federal Evidence-Building Activities: Requires major agencies to develop a 4-year Learning Agenda (identifying priority research questions), an Annual Evaluation Plan, and a Capacity Assessment. It mandates the appointment of a dedicated, non-political Evaluation Officer in each CFO Act agency.
• Title II: Open Government Data Act: Formally codifies the presumption that all federal government data assets must be open, public, and machine-readable by default, unless restricted by law (e.g., national security, privacy, trade secrets). It mandates that agencies maintain a Comprehensive Data Inventory, establish automated application programming interfaces (APIs), and designate a statutory Chief Data Officer (CDO) to oversee data lifecycle governance.
• Title III: Confidential Information Protection and Statistical Efficiency Act of 2018 (CIPSEA): Strengthens legal protections for confidential statistical data and mandates the appointment of a senior agency Statistical Official to coordinate statistical methodologies.

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FOIA, Sunshine Laws, and Digital Open Checkbooks

Public accountability at state and municipal levels is reinforced by traditional statutory guarantees alongside innovative open data platforms:

Freedom of Information and Sunshine Laws

• Freedom of Information Act (FOIA): Ensures public access to executive agency records, subject to nine statutory exemptions (such as national defense, personal medical privacy, trade secrets, and law enforcement files). Under 1996 electronic amendments (E-FOIA), agencies must proactively maintain online reading rooms containing frequently requested documents.
• State Sunshine Laws: Every state maintains open public records statutes and Open Meetings Acts. Sunshine laws mandate that governing bodies (city councils, school boards, county commissions, state boards) conduct public business, deliberate, and cast votes in open sessions that are publicly noticed in advance, with closed executive sessions strictly limited to sensitive matters such as litigation or property acquisition.