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    Subject Term: "Data elements"

    12 publications with a total of 34 open recommendations including 10 priority recommendations
    Director: J. Christopher Mihm
    Phone: (202) 512-6806

    6 open recommendations
    Recommendation: The Director of OMB should continue to provide ongoing technical assistance that significantly contributes to agencies making their own determinations about their DATA Act reporting requirements and monitor agency submissions. (Recommendation 1)

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: The Director of OMB should clarify and align existing guidance regarding the appropriate definitions agencies should use to collect and report on Primary Place of Performance and establish monitoring mechanisms to foster consistent application and compliance. (Recommendation 2)

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: The Secretary of the Treasury should reasonably assure that the process for determining whether required agencies are submitting spending data is in place and operating as designed. (Recommendation 3)

    Agency: Department of the Treasury
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: The Secretary of the Treasury should reasonably assure that ongoing monitoring controls to help ensure the completeness and accuracy of agency submissions are designed, implemented, and operating as designed. (Recommendation 4)

    Agency: Department of the Treasury
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: The Secretary of the Treasury should disclose known data quality issues and limitations on the new USAspending.gov. (Recommendation 5)

    Agency: Department of the Treasury
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Recommendation: The Secretary of the Treasury should make the known data limitations found in Senior Accountable Official certifications more accessible and evident to users of the new USAspending.gov. (Recommendation 6)

    Agency: Department of the Treasury
    Status: Open

    Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
    Director: Jennifer Grover
    Phone: (202) 512-7141

    3 open recommendations
    Recommendation: To enhance CBP's identification of high-risk cargo shipments and its enforcement of the ISF rule, the Commissioner of CBP should enforce the ISF rule requirement that carriers provide CSMs to CBP when targeters identify CSM noncompliance.

    Agency: Department of Homeland Security: United States Customs and Border Protection
    Status: Open

    Comments: CBP's Office of Field Operations is developing an enforcement strategy for container status messages (CSM) that it plans to complete by August 31, 2017. Once the strategy is completed, OFO plans to provide CSM enforcement guidance to the Advance Targeting Units. This recommendation will remain open until CBP's planned actions are completed and meet the intent of GAO's recommendation.
    Recommendation: To enhance CBP's identification of high-risk cargo shipments and its enforcement of the ISF rule, the Commissioner of CBP should evaluate the ISF enforcement strategies used by ATUs to assess whether particular enforcement methods could be applied to ports with relatively low submission rates.

    Agency: Department of Homeland Security: United States Customs and Border Protection
    Status: Open

    Comments: CBP plans to discuss enforcement strategies during monthly conference calls held by the National Targeting Center-Cargo with all Advance Targeting Units (ATU) in order to identify the factors that are impacting ports with lower Importer Security Filing (ISF) compliance rates. In addition, CBP plans to leverage the strategies employed by ATUs overseeing ports with higher ISF compliance rates in order to increase the ISF submission rates at the ports with lower compliance rates. This recommendation will remain open until CBP's planned actions are completed and meet the intent of GAO's recommendation.
    Recommendation: The Commissioner of CBP should identify and collect additional performance information on the impact of the ISF rule data, such as the identification of shipments containing contraband, to better evaluate the effectiveness of the ISF program.

    Agency: Department of Homeland Security: United States Customs and Border Protection
    Status: Open

    Comments: CBP is developing a plan (by August 31, 2017) to assess additional performance metrics to evaluate the effectiveness of the Importer Security Filing Program. After the plan has been developed, CBP will extract the performance data for analysis and, if needed, take actions to implement changes to the Program. This recommendation will remain open until CBP's planned actions are completed and meet the intent of GAO's recommendation.
    Director: Clowers, Angela N
    Phone: (202) 512-7114

    2 open recommendations
    Recommendation: To make it more likely that HHS will achieve its goals to reduce quality measure misalignment and associated provider burden, the Secretary of HHS should direct CMS and the Office of the National Coordinator for Health Information Technology to prioritize their development of electronic quality measures and associated standardized data elements on the specific quality measures needed for the core measure sets that CMS and private payers have agreed to use.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: In January 2017, HHS told us that ONC and CMS are prioritizing efforts to understand challenges associated with the development and implementation of electronic clinical quality measures. However, we determined that the actions did not fully address the recommendation because they focus on efforts to understand the challenges associated with electronic clinical quality measures as opposed to efforts to prioritize their development of measures from the core measure sets that CMS and private payers have agreed to use. As of August 2017, HHS officials have not informed us of any additional actions taken to implement this recommendation. We will update the status of this recommendation when we receive additional information.
    Recommendation: To make it more likely that HHS will achieve its goals to reduce quality measure misalignment and associated provider burden, the Secretary of HHS should direct CMS to comprehensively plan, including setting timelines, for how to target its development of new, more meaningful quality measures on those that will promote greater alignment, especially measures to strengthen the core measure sets that CMS and private payers have agreed to use.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: In January 2017, HHS told us that it considers this recommendation open and CMS will continue to explore ways for greater alignment through its planning efforts. As of August 2017, HHS officials have not informed us of any additional actions taken to implement this recommendation. We will update the status of this recommendation when we receive additional information.
    Director: Paula M. Rascona
    Phone: (202) 512-9816

    3 open recommendations
    including 3 priority recommendations
    Recommendation: To help ensure effective government-wide implementation and that complete and consistent spending data will be reported as required by the DATA Act, the Director of OMB, in collaboration with the Secretary of the Treasury, should establish or leverage existing processes and controls to determine the complete population of agencies that are required to report spending data under the DATA Act and make the results of those determinations publicly available.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open
    Priority recommendation

    Comments: OMB stated that each agency is responsible for determining whether it is subject to the DATA Act. To help agencies make that determination, OMB published guidance in the form of frequently asked questions and stated that the agencies may consult with OMB for additional counsel. In response to our recommendation, OMB staff told us they have reached out to federal agencies to identify which agencies have determined that they are exempt from reporting under the DATA Act and prepared a list of such agencies. However, OMB has not provided us the list or the procedures for reviewing agency determinations and compiling the results. In addition, OMB has not established procedures for ensuring non-exempt agencies are reporting spending data as required. Finally, OMB has not stated whether it will make the results of the determinations publicly available. Further, additional clarification would improve the usefulness of the frequently asked questions. For example, they state "Any Federal agency submitting data that OMB posts on its SF 133 Report on Budget Execution and Budgetary Resources is required to comply with DATA Act reporting." However, the SF 133 Report for the third quarter of 2016 includes entities such as the Postal Service which are not required by the DATA Act to report financial and payment information. In explaining the frequently asked questions to us, OMB officials clarified that they meant that an entity is required to report if its data appears on the SF 133 and it meets the applicable statutory definition of agency. The frequently asked questions document does not clearly communicate this two-prong approach. Additionally, OMB's verbal clarification when meeting with us does not account for those entities that meet the statutory definition of agency and are required by the DATA Act to report financial and payment information but do not appear on the SF 133. We will continue to assess OMB's efforts to address this recommendation.
    Recommendation: To help ensure effective government-wide implementation and that complete and consistent spending data will be reported as required by the DATA Act, the Director of OMB, in collaboration with the Secretary of the Treasury, should reassess, on a periodic basis, which agencies are required to report spending data under the DATA Act and make appropriate notifications to affected agencies.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open
    Priority recommendation

    Comments: OMB does not have plans to reassess, on a periodic basis, which agencies are required to report spending data under the DATA Act. We continue to believe action on this recommendation is important to effectively implement the DATA Act. We will continue to assess OMB's efforts to address this recommendation.
    Recommendation: To help ensure effective implementation of the DATA Act by the agencies and facilitate the further establishment of overall government-wide governance, the Director of OMB, in collaboration with the Secretary of the Treasury, should request that non-CFO Act agencies required to report federal spending data under the DATA Act submit updated implementation plans, including updated timelines and milestones, cost estimates, and risks, to address new technical requirements.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open
    Priority recommendation

    Comments: On June 15, 2016, OMB directed CFO Act agencies to update key components of their implementation plans by August 12, 2016. The requirement did not extend to non-CFO Act agencies. OMB stated that it is monitoring non-CFO Act agencies by providing feedback to non-CFO Act agencies through workshops instead of requesting updated implementation plan information. According to OMB officials, OMB has not followed-up with non-CFO Act agencies or requested updated implementation plan information because they are working with the CFO Act agencies which comprise approximately 90 percent of federal spending. In addition to these outreach efforts, OMB has worked with Treasury to engage with small and independent agencies through weekly phone calls and other forms of communication. However, the DATA Act applies to most federal agencies, and we believe that it is important to monitor smaller agencies' implementation plans as well as large agencies. We will continue to assess OMB's efforts to address this recommendation.
    Director: Mihm, J Christopher
    Phone: (202) 512-3236

    1 open recommendations
    including 1 priority recommendation
    Recommendation: To help ensure that agencies report consistent and comparable data on federal spending, the Director of OMB, in collaboration with the Secretary of the Treasury, should provide agencies with additional guidance to address potential clarity, consistency, or quality issues with the definitions for specific data elements including Award Description and Primary Place of Performance and that they clearly document and communicate these actions to agencies providing this data as well as to end-users.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open
    Priority recommendation

    Comments: In May 2016, OMB issued guidance for DATA Act Implementation entitled, Implementing Data-Centric Approach for Reporting Federal Spending Information (Management Procedures Memorandum No. 2016-03). This memorandum provided guidance on new federal prime award reporting requirements, agency assurances, and authoritative sources for reporting. In August 2016, OMB released additional draft guidance describing how agencies should report financial information involving intragovernmental transfers and personally identifiable information, as well as how agency Senior Accountable Officials should provide quality assurances for submitted data. Despite these positive steps, we continue to have concerns about the need for additional guidance to facilitate agency implementation of certain data definitions (such as "primary place of performance" and "award description") in order to produce consistent and comparable information, and whether the guidance provides sufficient detail in areas such as the process for providing assurance on data submissions.
    Director: J. Alfredo Gómez
    Phone: (202) 512-3841

    2 open recommendations
    Recommendation: To help federal, state, local, and private sector decision makers access and use the best available climate information, the Executive Office of the President should designate a federal entity to develop and periodically update a set of authoritative climate change observations and projections for use in federal decision making, which state, local, and private sector decision makers could also access to obtain the best available climate information.

    Agency: Executive Office of the President
    Status: Open

    Comments: As of 6/7/17, the Executive Office of the President has yet to take action in response to this recommendation.
    Recommendation: To help federal, state, local, and private sector decision makers access and use the best available climate information, the Executive Office of the President should designate a federal entity to create a national climate information system with defined roles for federal agencies and nonfederal entities with existing statutory authority.

    Agency: Executive Office of the President
    Status: Open

    Comments: As of 6/7/17, the Executive Office of the President has yet to take action in response to this recommendation.
    Director: Mihm, J Christopher
    Phone: (202) 512-6806

    2 open recommendations
    including 2 priority recommendations
    Recommendation: To ensure that federal program spending data are provided to the public in a transparent, useful, and timely manner, the Director of OMB should accelerate efforts to determine how best to merge DATA Act purposes and requirements with the GPRAMA requirement to produce a federal program inventory.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open
    Priority recommendation

    Comments: OMB staff stated that they expect to issue new guidance on the Program Management Improvement Accountability Act by the end of 2017. According to these staff, OMB expects that, within a year of issuing the new guidance, they will be able to move forward with plans to resume implementation of the federal program inventory. In October 2017, OMB staff told us they believe there are opportunities to leverage the DATA Act taxonomy in service to the goals of GPRAMA and they continue to work with their performance management colleagues on this effort. However, they said no formal progress has been made to identify programs for the purposes of DATA Act reporting.
    Recommendation: To ensure that the integrity of data standards is maintained over time, the Director of OMB, in collaboration with the Secretary of the Treasury, should establish a set of clear policies and processes for developing and maintaining data standards that are consistent with leading practices for data governance.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open
    Priority recommendation

    Comments: OMB and Treasury have taken some initial steps to build a data governance structure standardizing data elements and definitions, conducting interviews with key stakeholders and developing a set of recommendations for decision-making authority. In September 2016, OMB and Treasury established a Data Standards Committee (DSC) that is responsible for advising OMB and Treasury, and providing recommendations on DATA Act data standards to the Executive Steering Committee (ESC) -- the decision making body regarding DATA Act and other data standards. According to OMB staff, the DSC meets on a monthly basis, but has not yet provided recommendations to OMB or to the ESC. OMB staff told us in October 2017 that, in accordance with their broader data governance mandates and overall transparency efforts, they are reviewing opportunities to incorporate and leverage other mandates and existing governance structures. As part of our ongoing feedback with OMB, we shared 5 key practices that we believe should inform their plans to develop a data governance framework moving forward.
    Director: James Cosgrove
    Phone: (202) 512-7114

    2 open recommendations
    including 2 priority recommendations
    Recommendation: To ensure that MA encounter data are of sufficient quality for their intended purposes, the Administrator of CMS should establish specific plans and time frames for using the data for all intended purposes in addition to risk adjusting payments to MAOs.

    Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
    Status: Open
    Priority recommendation

    Comments: HHS was in general agreement with this recommendation. In January 2017 we reported that CMS had made progress in defining its objectives for using MA encounter data for risk adjustment and in communicating its plans and time frames to MAOs. However, although CMS had formed general ideas of how it would use MA encounter data for purposes other than risk adjustment, it had not specified plans and time frames for most of the additional purposes for which encounter data may be used. These other purposes include activities to support program integrity. As of July 2017, CMS officials told us that the agency had not taken any further actions in response to this July 2014 recommendation.
    Recommendation: To ensure that MA encounter data are of sufficient quality for their intended purposes, the Administrator of CMS should complete all the steps necessary to validate the data, including performing statistical analyses, reviewing medical records, and providing MAOs with summary reports on CMS's findings, before using the data to risk adjust payments or for other intended purposes.

    Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
    Status: Open
    Priority recommendation

    Comments: While in general agreement with this recommendation, HHS did not commit to completing data validation before using MA encounter data for risk adjustment. In January 2017 we reported that CMS had made limited progress toward validating encounter data by having begun compiling basic statistics on the volume and consistency of data submissions and preparing automated summary reports for MAOs indicating the diagnosis information used for risk adjustment. However the agency had not yet taken other important steps identified in its Medicaid encounter data validation protocol, such as establishing benchmarks for completeness and accuracy. In July 2017, CMS officials told us that the agency had not taken any further actions in response to this July 2014 recommendation.
    Director: Carol R. Cha
    Phone: (202) 512-4456

    3 open recommendations
    including 2 priority recommendations
    Recommendation: To improve the completeness and accuracy of data submissions to the USASpending.gov website, the Director of the Office of Management and Budget, in collaboration with Treasury's Fiscal Service, should clarify guidance on (1) agency responsibilities for reporting awards funded by non-annual appropriations; (2) the applicability of USASpending.gov reporting requirements to non-classified awards associated with intelligence operations; (3) the requirement that award titles describe the award's purpose (consistent with our prior recommendation); and (4) agency maintenance of authoritative records adequate to verify the accuracy of required data reported for use by USASpending.gov.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open
    Priority recommendation

    Comments: As of July 2017, OMB and Treasury were working to implement the DATA Act, which includes several provisions that may address these recommendations once fully implemented. 1) OMB staff said they continue to deliberate on agency responsibilities for reporting awards funded by non-annual appropriations. 2) OMB staff provided a Frequently Asked Question (FAQ) addressing the applicability of USASpending.gov reporting requirements for recipient information related to classified or sensitive information. GAO reviewed the FAQ and determined that additional guidance is still needed to ensure complete reporting of unclassified awards as required by FFATA. 3) OMB staff have agreed that it will be important to clarify guidance on how agencies can report on award titles that appropriately describes the awards' purposes and noted that they are working on providing additional guidance to agencies as part of their larger DATA Act implementation efforts. 4) OMB released policy guidance in May 2016 (MPM 2016-03) that identifies the authoritative sources for reporting procurement and award data. However, GAO's review of this policy guidance determined that it does not address the underlying source that can be used to verify the accuracy of non-financial procurement data or any source for data on assistance awards.
    Recommendation: To improve the completeness and accuracy of data submissions to the USASpending.gov website, the Director of the Office of Management and Budget, in collaboration with Treasury's Fiscal Service, should develop and implement a government-wide oversight process to regularly assess the consistency of information reported by federal agencies to the website other than the award amount.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open
    Priority recommendation

    Comments: As part of their DATA Act implementation efforts, OMB issued policy guidance in May 2016 (MPM 2016-03) that identifies authoritative systems to validate agency spending information. The guidance also directs agency DATA Act Senior Accountable Officials (SAOs) to provide a quarterly assurance regarding the data reported to USASpending.gov and specifies that this assurance should leverage data quality and management controls established in statute, regulation, and Federal-wide policy and be aligned with the internal control and risk management strategies in Circular A-123, and provides information on how agency DATA Act SAOs are to provide assurances over the spending data reported to USASpending.gov. In addition, Treasury's broker is to provide an additional set of validation rules to further ensure the proper formatting of data submitted to USAspending.gov. OMB staff noted that OMB and Treasury had prioritized the linking of financial data to award data as a means of addressing the issue of unreported awards we previously identified. We agree that linking financial and award data can help agencies identify gaps in reporting. However, as of July 2017, OMB did not identify any new or revised processes aimed at addressing the accuracy concerns we addressed other than citing agencies' responsibility to certify the accuracy of their data.
    Recommendation: To improve the completeness of foreign recipient data on the USASpending.gov website, the Chief Executive Officer of the Millennium Challenge Corporation should direct responsible officials within the Corporation's Department of Administration and Finance to report spending information on all assistance award programs to USASpending.gov for prior and future fiscal years in accordance with statutory requirements and OMB guidance.

    Agency: Millennium Challenge Corporation
    Status: Open

    Comments: The Millennium Challenge Corporation has begun reporting awards made in fiscal year 2015. As of July 2017, it has not yet reported awards for previous fiscal years, as we had recommended. We will continue to follow up.
    Director: Charlie Jeszeck
    Phone: (202) 512-7215

    4 open recommendations
    Recommendation: To improve IRS's enforcement and compliance efforts, decrease the administrative and financial burden of maintaining both electronic and paper-based form processing systems, and reduce plan reporting costs, Congress should consider providing the Department of the Treasury with the authority to require that the Form 5500 series be filed electronically.

    Agency: Congress
    Status: Open

    Comments: As of 5/31/17, Congress has taken no action.
    Recommendation: To improve the usefulness, reliability, and comparability of Form 5500 data for all stakeholders while limiting the burden on the filing community, the Secretaries of DOL and Treasury, and the Director of PBGC should consider implementing the findings from our panel when modifying plan investment and service provider fee information, including: (1) revising Schedule H plan asset categories to better match current investment vehicles and provide more transparency into plan investments; (2) revising the Schedule of Assets attachments to create a standard searchable format; (3) developing a central repository for EIN and PN numbers for filers and service providers to improve the comparability of form data across filings; (4) clarifying Schedule C instructions for direct, eligible indirect, and reportable indirect compensation so plan fees are reported more consistently and, as we recommended in the past, better align with the 408(b)(2) fee disclosures; and (5) simplifying and clarify Schedule C service provider codes to increase reporting consistency.

    Agency: Department of Labor
    Status: Open

    Comments: In 2016, DOL in coordination with IRS and PBGC has implemented cross-year edit checks into EFAST in an effort to improve the consistency in key identifying information, such as the EIN, Plan Number and Plan Name. These checks aim to verify identifying information submitted on the Form 5500 and to notify the filer and government agencies of inconsistencies, which affords filers the ability to review and modify crucial identifying information prior to submission. Additionally, if the filer chooses to submit data that may contain inconsistent information, the edit test indicators provide government users with the ability to more readily detect filings containing potential errors in the identifying information for further review and correction. DOL has also collaborated with PBGC and IRS in issuing proposed revisions to the Form 5500 Series in a Notice of Proposed Forms Revisions. The deadline for public comment ended December 5, 2016. The proposed revisions in the Notice reflect efforts of DOL, IRS, and PBGC to improve the Form 5500 reporting for filers, the public, and the agencies by among other things, (1) modernizing financial information filed by regarding plans; (2) updating fee and expense information on plan service providers with a focus on harmonizing annual reporting requirement with DOL's 408(b)(2); financial disclosure requirements; (3) enhancing the ability to mine data files on annual returns/reports; and (4) improving compliance with ERISA and the Code through selected new questions regarding plan operation, service provider relationships, and financial management of plans. Specifically, in the Notice the agencies propose that Schedule H report assets held and assets disposed of during the plan year to provide more transparency and a more complete report of plan's annual investments and that that the Schedule of Assets be revised to require reporting of assets held through direct filing entities. Additionally, the agencies are proposing revisions to the Schedule H, Schedule of Assets that require filers to complete standardized Schedules in a format enabling data to captured electronically. This requirement would enable importation of information from the Schedules of Assets into structured databases that DOL would make available to the public from each year's Form 5500 Series filing. The agencies are also proposing to add clarifying definitions and instructions to improve the consistency of Form 5000 responses. This includes clarification of conventions to identify filers by name and identifying numbers to help mitigate confusion about legal identities with which plans transact and improve comparability of form data across filings. In addition, the agencies also propose revisions to Schedule C to require reporting of indirect compensation for service provider subject to 408(b)(2) requirements and for all compensation that is required to be disclosed. Further, the Schedule C instructions would be clarified to track more closely with the language of the 408(b)(2) regulations. The agencies are also proposing to limit the codes for Schedule C and requiring the filer to more simply indicate all types of services for each provider identified. Additionally, they propose a requirement to indicate all the types of fees/compensation separately when reporting sources of compensation from parties other than plan and plan sponsor. The agencies are reviewing the public comments and expect the process to continue through 2017. While the Agencies have made considerable efforts to address our recommendation in the proposed revisions to the Form 5500, they have not made any decisions on whether to make changes to the forms or DOL regulations, and have not decided on a timeline for implementation of any changes to the form or DOL regulations that the Agencies ultimately may decide to adopt. We will close this recommendation once the revision is final.
    Recommendation: To improve the usefulness, reliability, and comparability of Form 5500 data for all stakeholders while limiting the burden on the filing community, the Secretaries of DOL and Treasury, and the Director of PBGC should consider implementing the findings from our panel when modifying plan investment and service provider fee information, including: (1) revising Schedule H plan asset categories to better match current investment vehicles and provide more transparency into plan investments; (2) revising the Schedule of Assets attachments to create a standard searchable format; (3) developing a central repository for EIN and PN numbers for filers and service providers to improve the comparability of form data across filings; (4) clarifying Schedule C instructions for direct, eligible indirect, and reportable indirect compensation so plan fees are reported more consistently and, as we recommended in the past, better align with the 408(b)(2) fee disclosures; and (5) simplifying and clarify Schedule C service provider codes to increase reporting consistency.

    Agency: Department of the Treasury
    Status: Open

    Comments: In 2016, DOL in coordination with IRS and PBGC has implemented cross-year edit checks into EFAST in an effort to improve the consistency in key identifying information, such as the EIN, Plan Number and Plan Name. These checks aim to verify identifying information submitted on the Form 5500 and to notify the filer and government agencies of inconsistencies, which affords filers the ability to review and modify crucial identifying information prior to submission. Additionally, if the filer chooses to submit data that may contain inconsistent information, the edit test indicators provide government users with the ability to more readily detect filings containing potential errors in the identifying information for further review and correction. IRS has also collaborated with DOL and PBGC in issuing proposed revisions to the Form 5500 Series in a Notice of Proposed Forms Revisions. The deadline for public comment ended December 5, 2016. The proposed revisions in the Notice reflect efforts of DOL, IRS, and PBGC to improve the Form 5500 reporting for filers, the public, and the agencies by among other things, (1) modernizing financial information filed by regarding plans; (2) updating fee and expense information on plan service providers with a focus on harmonizing annual reporting requirement with DOL's 408(b)(2); financial disclosure requirements; (3) enhancing the ability to mine data files on annual returns/reports; and (4) improving compliance with ERISA and the Code through selected new questions regarding plan operation, service provider relationships, and financial management of plans. Specifically, in the Notice the agencies propose that Schedule H report assets held and assets disposed of during the plan year to provide more transparency and a more complete report of plan's annual investments and that that the Schedule of Assets be revised to require reporting of assets held through direct filing entities. Additionally, the agencies are proposing revisions to the Schedule H, Schedule of Assets that require filers to complete standardized Schedules in a format enabling data to captured electronically. This requirement would enable importation of information from the Schedules of Assets into structured databases that DOL would make available to the public from each year's Form 5500 Series filing. The agencies are also proposing to add clarifying definitions and instructions to improve the consistency of Form 5000 responses. This includes clarification of conventions to identify filers by name and identifying numbers to help mitigate confusion about legal identities with which plans transact and improve comparability of form data across filings. In addition, the agencies also propose revisions to Schedule C to require reporting of indirect compensation for service provider subject to 408(b)(2) requirements and for all compensation that is required to be disclosed. Further, the Schedule C instructions would be clarified to track more closely with the language of the 408(b)(2) regulations. The agencies are also proposing to limit the codes for Schedule C and requiring the filer to more simply indicate all types of services for each provider identified. Additionally, they propose a requirement to indicate all the types of fees/compensation separately when reporting sources of compensation from parties other than plan and plan sponsor. The agencies are reviewing the public comments and expect the process to continue through 2017. While the Agencies have made considerable efforts to address our recommendation in the proposed revisions to the Form 5500, they have not made any decisions on whether to make changes to the forms or DOL regulations, and have not decided on a timeline for implementation of any changes to the form or DOL regulations that the Agencies ultimately may decide to adopt. We will close this recommendation once the revision is final.
    Recommendation: To improve the usefulness, reliability, and comparability of Form 5500 data for all stakeholders while limiting the burden on the filing community, the Secretaries of DOL and Treasury, and the Director of PBGC should consider implementing the findings from our panel when modifying plan investment and service provider fee information, including: (1) revising Schedule H plan asset categories to better match current investment vehicles and provide more transparency into plan investments; (2) revising the Schedule of Assets attachments to create a standard searchable format; (3) developing a central repository for EIN and PN numbers for filers and service providers to improve the comparability of form data across filings; (4) clarifying Schedule C instructions for direct, eligible indirect, and reportable indirect compensation so plan fees are reported more consistently and, as we recommended in the past, better align with the 408(b)(2) fee disclosures; and (5) simplifying and clarify Schedule C service provider codes to increase reporting consistency.

    Agency: Pension Benefit Guaranty Corporation
    Status: Open

    Comments: In 2016, DOL in coordination with IRS and PBGC has implemented cross-year edit checks into EFAST in an effort to improve the consistency in key identifying information, such as the EIN, Plan Number and Plan Name. These checks aim to verify identifying information submitted on the Form 5500 and to notify the filer and government agencies of inconsistencies, which affords filers the ability to review and modify crucial identifying information prior to submission. Additionally, if the filer chooses to submit data that may contain inconsistent information, the edit test indicators provide government users with the ability to more readily detect filings containing potential errors in the identifying information for further review and correction. PBDC has also collaborated with DOL and IRS in issuing proposed revisions to the Form 5500 Series in a Notice of Proposed Forms Revisions. The deadline for public comment ended December 5, 2016. The proposed revisions in the Notice reflect efforts of DOL, IRS, and PBGC to improve the Form 5500 reporting for filers, the public, and the agencies by among other things, (1) modernizing financial information filed by regarding plans; (2) updating fee and expense information on plan service providers with a focus on harmonizing annual reporting requirement with DOL's 408(b)(2); financial disclosure requirements; (3) enhancing the ability to mine data files on annual returns/reports; and (4) improving compliance with ERISA and the Code through selected new questions regarding plan operation, service provider relationships, and financial management of plans. Specifically, in the Notice the agencies propose that Schedule H report assets held and assets disposed of during the plan year to provide more transparency and a more complete report of plan's annual investments and that that the Schedule of Assets be revised to require reporting of assets held through direct filing entities. Additionally, the agencies are proposing revisions to the Schedule H, Schedule of Assets that require filers to complete standardized Schedules in a format enabling data to captured electronically. This requirement would enable importation of information from the Schedules of Assets into structured databases that DOL would make available to the public from each year's Form 5500 Series filing. The agencies are also proposing to add clarifying definitions and instructions to improve the consistency of Form 5000 responses. This includes clarification of conventions to identify filers by name and identifying numbers to help mitigate confusion about legal identities with which plans transact and improve comparability of form data across filings. In addition, the agencies also propose revisions to Schedule C to require reporting of indirect compensation for service provider subject to 408(b)(2) requirements and for all compensation that is required to be disclosed. Further, the Schedule C instructions would be clarified to track more closely with the language of the 408(b)(2) regulations. The agencies are also proposing to limit the codes for Schedule C and requiring the filer to more simply indicate all types of services for each provider identified. Additionally, they propose a requirement to indicate all the types of fees/compensation separately when reporting sources of compensation from parties other than plan and plan sponsor. The agencies are reviewing the public comments and expect the process to continue through 2017. While the Agencies have made considerable efforts to address our recommendation in the proposed revisions to the Form 5500, they have not made any decisions on whether to make changes to the forms or DOL regulations, and have not decided on a timeline for implementation of any changes to the form or DOL regulations that the Agencies ultimately may decide to adopt. We will close this recommendation once any revision are made final.
    Director: Belva Martin
    Phone: (202) 512-4841

    1 open recommendations
    Recommendation: To help improve reporting of federal procurement data and strengthen oversight of contracts awarded on the basis of an unusual and compelling urgency, the Secretaries of Defense and State and the Administrator of the U.S. Agency for International Development should develop an oversight mechanism when the cumulative value of noncompetitive contracts awarded on the basis of unusual and compelling urgency increases considerably beyond the initial contract award value.

    Agency: Department of Defense
    Status: Open

    Comments: In April 2015, the Acting Director of Defense Procurement and Acquisition Policy issued a memorandum instructing contracting officers to notify management when the cumulative dollar value of a contract awarded on the basis of urgency increases beyond the initial value at award. Further, the memorandum instructs components to establish an oversight mechanism to ensure the appropriate approval level is obtained. This memorandum was incorporated into the Defense Federal Acquisition Regulations by reference. As of August 2017, the Defense Procurement and Acquisition Policy office had not followed up to determine whether components had implemented this recommendation. We will continue to follow up with DOD to determine how and whether the oversight mechanisms were established at the component level.
    Director: Kohn, Linda T
    Phone: (202) 512-7114

    5 open recommendations
    Recommendation: To help ensure that qualified CDRs promote improved quality and efficiency of physician care for Medicare beneficiaries, the Secretary of Health and Human Services should direct Centers for Medicare & Medicaid Services (CMS) to establish key requirements for qualified CDRs that focus on improving quality and efficiency. These requirements could include, for example, having CDRs (1) identify key areas of opportunity to improve quality and efficiency for their target populations and collect additional measures designed to address them, (2) collect a core set of measures established by CMS, and (3) demonstrate that their processes for auditing the accuracy and completeness of the data they collect are systematic and rigorous.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: As it has since initiation of the qualified CDR program, CMS continues to allow qualified CDRs to choose what quality measures they will track within very broad parameters. While it has developed a PQRS cross-cutting measure set requirement for physicians using other reporting mechanisms, this requirement does not apply to qualified CDRs. CMS officials report that they have addressed data accuracy and completeness by sharing with qualified CDRs issues and discrepancies that have been found in the data submitted so far.
    Recommendation: To help ensure that qualified CDRs promote improved quality and efficiency of physician care for Medicare beneficiaries, the Secretary of Health and Human Services should direct CMS to establish a requirement for qualified CDRs to demonstrate improvement on key measures of quality and efficiency for their target populations.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: CMS officials report that they are working to implement this recommendation, but they have not yet put forward any specific proposals to address it.
    Recommendation: To help ensure that qualified CDRs promote improved quality and efficiency of physician care for Medicare beneficiaries, the Secretary of Health and Human Services should direct CMS to establish a process for monitoring compliance with requirements for qualified CDRs that draws on relevant expert judgment. This process should assess CDR performance on each requirement in a way that takes into account the varying circumstances of CDRs and their available opportunities to promote quality and efficiency improvement for their target populations.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: The limited changes for qualified clinical data registries that CMS outlined in its CY2016 proposed rule in July 2015 do not address this recommendation. CMS officials report that they are working to implement this recommendation, but the approach they describe focuses on assessing changes in the data submitted by qualified CDRs over several years.
    Recommendation: To help ensure that qualified CDRs promote improved quality and efficiency of physician care for Medicare beneficiaries, the Secretary of Health and Human Services should determine and implement actions to reduce barriers to the development of qualified CDRs, such as (1) developing guidance that clarifies Health Insurance Portability and Accountability Act requirements to promote participation in qualified CDRs; (2) working with private sector entities to make relevant multipayer cost data available to qualified CDRs; (3) testing one or more models of shared savings between Medicare and qualified CDRs that achieve reduced Medicare expenditures with improved quality of care, and (4) providing technical assistance to qualified CDRs.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: The limited changes for qualified clinical data registries that CMS outlined in its CY2016 proposed rule in July 2015 do not address the specific barriers to the development of qualified CDRs that we identified in our report. However, CMS officials report that they have provided technical assistance to qualified CDRs through monthly support calls and an annual kick-off meeting held in spring 2015.
    Recommendation: To help ensure that qualified CDRs promote improved quality and efficiency of physician care for Medicare beneficiaries, the Secretary of Health and Human Services should determine key data elements needed by qualified CDRs--such as those relevant for a required core set of measures--and direct Office of the National Coordinator for Health Information Technology and CMS to include these data elements, if feasible, in the requirements for certification of EHRs under the EHR incentive programs.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: The limited changes for qualified clinical data registries that CMS outlined in its CY2016 proposed rule in July 2015 do not address this recommendation.