Summary of Responses to the Treasury Bureau of the Fiscal

Service Notice in the Federal Register on 9/26/2014 for “Public

Input on the Establishment of Financial Data Standards (Data

Exchange)”

January 30, 2015

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Background

Overview of responses

Summary of responses for each question

Topics

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Background

On 9/26/2014, the Treasury Bureau

of the Fiscal Service issued a notice

in the Federal Register on “Public

Input on the Establishment of

Financial Data Standards (Data

Exchange)”

The notice requested comments from

private and public stakeholders on

several data standard topics and

questions “to better ensure the data

standards to be established by

Treasury and OMB are informed and

useful, and to ensure compliance with

DATA Act consultation requirements.”

Comments were due on November 25,

2014.

The notice requested comments on the following:

A. Examples of data standards on data exchange that could ensure the

data is “open.”

B. Examples of data standards on data exchange that could ensure that

“availability” goals are met.

C. Examples of data standards on data exchange that could ensure the

data provides efficient “business reach” to foster private sector

innovation.

D. Examples of data standards on data exchange that could ensure the

implementation of appropriate “validation” processes.

E. Examples of data standards on data exchange that could ensure

appropriate “extensibility.”

F. Examples of data standards on data exchange that could ensure Ease

of Implementation.

G. How would the data standards benefit or add value to your

constituent group or pertinent stakeholders?

H. What use cases would you anticipate or envision?

I. What impact would data standards have on you, your business,

constituent group, or pertinent stakeholders and investments?

J. What other criteria should be considered by Treasury and OMB in

establishing the data standards on data exchange?

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Record metadata from all responses

– Name of respondent, organization, posted date, unique identifier, etc.

Determine number of responses for each question

Summarize information provided for each question, without validation

or assessment of response content

Approach

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Overview of Responses

Fiscal Service received 34 unique responses*

– 12 responses answered all the questions

– 6 responses answered some of questions

– 16 responses did not answer any questions

In addition, a number of respondents provided

useful recommendations for establishing

Financial Data Standards for Data Exchange**

that went beyond the scope of the questions

FRN

Question

Number of

Responses

A 16

B 14

C 13

D 16

E 16

F 14

G 16

H 16

I 14

J 14

* Two of the 35 responses were identical

** Based on the Data Management Association (DAMA) Guide to the Data Management Body of Knowledge (DMBOK)

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Question A: Open DataSummary of Responses

Respondents

Ambur Publish What You Fund Mark V Systems Limited P3 Data Systems, Inc. OASIS Universal Business Language

Technical Committee AICPA CGI Federal, Inc. Hoffman IRIS Business Services Limited PWC Sunlight Foundation Booz Allen Hamilton AGA Data Transparency Coalition XBRL.US Center for Organizational Analysis

Summary of Responses

An open standard should be selected and prescribed.

Many standards are available: most commonly recommended were

XML, XBRL, JSON, NIEM, and extending XML.*

Both information technology (IT) systems and humans should be able to

read and process the data.

Standard should use implementation practices that support open

implementation. This includes human readable labels, license free data,

and sharing of tools and software that support data standards.

Please describe or provide examples of data standards on data exchange that could ensure the data is “open.” Open in this context means anyone can access, use, or re-use posted information, including the public, Federal agencies, local and state governments, academia, media, industry, standard-setting bodies, transparency groups, on a worldwide scale.

* XML: Extensible Markup Language – http://www.w3.org/XML/

XBRL: eXtensible Business Reporting Language) – https://www.xbrl.org/

UBL: Universal Business Language – https://www.oasis-open.org/committees/tc_home.php?wg_abbrev=ubl

JSON: JavaScript Object Notation – http://www.json.org/

NIEM: National Information Exchange Model – https://www.niem.gov/Pages/default.aspx

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Question B: Available DataSummary of Responses

Respondents

Ambur Mark V Systems Limited P3 Data Systems, Inc. OASIS Universal Business Language

Technical Committee AICPA CGI Federal, Inc. Hoffman IRIS Business Services Limited PWC Sunlight Foundation Booz Allen Hamilton Data Transparency Coalition XBRL.US Center for Organizational

Excellence

Summary of Responses

Several standards are available that are generally free of charge: XML,

XBRL, UBL, JSON, and NIEM.

Recommended practices to enable creation of an implementation

environment that supports free access and availability include:

– Engaging software vendors to support implementation

– Maximizing explicit common definitions

– Implementing community tools and practices

– Implementing strong governance

What are examples of data standards on data exchange that could ensure that “availability” goals are met? Availability in this context means free access to the data standard, both during development, at final stage, and for translations. Availability is assurance that core technologies can be implemented royalty-free.

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Question C: Business ReachSummary of Responses

Summary of Responses

Using open standards will enable leveraging the contributions of the

business community by increasing its ability to collaborate.

Examples include XML, XBRL, UBL, JSON, and NIEM.

Use common exchange formats to enable leveraging existing business

capabilities: REST* application programming interfaces (APIs) and

JSON.

Standardize data to the greatest practical extent to enable common

exchange and engagement with the business community.

What are examples of data standards on data exchange that could ensure the data provides efficient “business reach” to foster private sector innovation? Business reach refers to the global reach of the business community with either local or global integration opportunities. The end points of business reach are regional (business integration remains a regional area of opportunity) or international (business integration has the potential for direct links to the international community).

Respondents

Ambur Mark V Systems Limited P3 Data Systems, Inc. OASIS Universal Business Language

Technical Committee AICPA CGI Federal, Inc. Hoffman IRIS Business Services Limited PWC Booz Allen Hamilton Data Transparency Coalition XBRL.US Center for Organizational Excellence

* REST: Representational State Transfer: http://www.restapitutorial.com/lessons/whatisrest.html

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Question D: ValidationSummary of Responses

Summary of Responses

Several data standards have built in features for the rules and

document supported validation: XBRL, UBL, WS-Security, Schematron,

and RULEML.*

Some commercial products also include rules-based validation.

Several respondents recommended approaches to enable validation

processes:

– Address the major types of validation: identity verification, source validation,

data format validation, rule-based validation for data consistency, validation

across multiple data submissions, and validation across the federal spending

life cycle

– Seek to strike a balance between easily achievable, rules-based validations

and those that might be more difficult to automate or require agency-specific

approaches

– Establish a governing board, which is an important step to implementing

validation processes

Please describe or provide examples of data standards on data exchange that could ensure the implementation of appropriate “validation” processes. Validation means an ongoing process for validation and integration. Validation has spectrum end points that are rules-based or document-based. Rules-based refers to business rules which are interwoven into the standard output and governance body. Document-based end points are business rules separately stored, not entirely contained within the standard output or governance body.

Respondents

Ambur Publish What You Fund Mark V Systems Limited P3 Data Systems, Inc. OASIS Universal Business Language

Technical Committee AICPA CGI Federal, Inc. Hoffman IRIS Business Services Limited PWC Texas Education Agency Booz Allen Hamilton AGA Data Transparency Coalition XBRL.US Center for Organizational Excellence

* Schematron – http://www.schematron.com/

RULEML: Rule Markup Language – http://wiki.ruleml.org/index.php/RuleML_Home

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Question E: ExtensibilitySummary of Responses

Summary of Responses

XBRL is extensible and flexible. The capability to add elements to the

taxonomy can provide unique definitions and labels so that the

information can be transparent to anyone consuming the data.

– Allows for the continuing growth and change necessitated by changes in

reporting requirements

– Allows individual reporting entities to report information that is unique to their

organizations and that has not been included in the standard set of

concepts/terms available to use in the standard

UBL is extensible in that it enables the validation of user-defined

additions to the standard schemas.

Please describe or provide examples of data standards on data exchange that could ensure appropriate “extensibility.” “Extensibility” in this context is defined as functionality for flexibility (maintenance) of future modification to the data standard. The end points of the spectrum for these criteria are flexible and rigid. Flexible references extensibility and implementation ease, whereas rigid relates to the pliability of the construction and rules integration.

Respondents

Ambur Publish What you Fund Mark V Systems Limited P3 Data Systems, Inc. OASIS Universal Business Language

Technical Committee AICPA CGI Federal, Inc. Hoffman IRIS Business Services Limited PWC Texas Education Agency Booz Allen Hamilton AGA Data Transparency Coalition XBRL.US Center for Organizational Excellence

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Question F: Ease of ImplementationSummary of Responses

Summary of Responses

XBRL is an example of a data standard that supports ease of implementation.

– Respondent recommends adoption of a specific profile of XBRL that limits the complexity

(tuples, excess dimensions) while retaining the powerful metadata in consistent format.

– Implementing XBRL for the reporting of business information requires the development of a

taxonomy to be used for the reporting application.

– The XBRL standard has been adopted across a wide range of domains, including stock

exchanges, central banks, business registries, securities commissions, tax authorities, and

other federal and local government agencies.

UBL is another example of a data standard that supports ease of implementation.

– UBL is designed to plug directly into existing business, legal, auditing, and records

management practices, eliminating the re-keying of data in existing fax- and paper-based

supply chains.

Other examples of data standards on data exchange include REST/JSON, CSV, and TXT.

– Respondent believes these standards are much more developer friendly and are increasingly

becoming the preferred mechanisms for information sharing in IT environments.

– Respondent considers JSON a great standard for mobile devices, which are the common

medium of information processing by citizens and other public organizations.

– Respondent considers that CSV and/or TXT may be better for data statistical analysis

processes.

Respondent recommends building on standards currently being used by Treasury.

Please describe or provide examples of data standards on data exchange that could ensure Ease of Implementation. Ease of Implementation refers to integration and interoperability within a given environment. The related end points are simple (easily integrates into environment) or difficult (integration into environment necessitates extra steps).

Respondents

Ambur Mark V Systems Limited P3 Data Systems, Inc. OASIS Universal Business Language

Technical Committee AICPA CGI Federal, Inc. Hoffman IRIS Business Services Limited PWC Booz Allen Hamilton AGA Data Transparency Coalition XBRL.US Center for Organizational Excellence

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Question G: BenefitsSummary of Responses

Summary of Responses

Increases consistency in data that is fully interoperable

Reduces the amount of errors that can occur in manual processes

Reduces burden of reporting on recipients receiving federal funds

Reduces nonconformance to complex financial reporting rules

Optimizes development for a single standardized implementation by decreasing the number

of APIs, which increases the overall productivity of the software development process

Improves the public’s ability to access and share Federal spending data

Easier to analyze the accuracy and completeness of the data, ensuring its reliability

Better data to support their own benchmarking and competitive analysis

States with central grant office functions or state comptrollers would be able to easily view

and download data from USASpending.gov for all state data

Enhanced data analytics

Enhanced data presentation to myriad stakeholder groups, including policy makers, subject

matter experts, taxpayers, and citizens

Private industry (large and small businesses) and not-for-profit organizations would be better

able to mine and analyze data and identify business opportunities and focus areas

Achieve better accountability, better management, and automatic compliance in federal

spending reports. Providing trustworthy data to watchdogs both inside and outside the

government.

How would the data standards examples or descriptions on data exchange you provided in A-F above, if implemented, benefit or add value to your constituent group or pertinent stakeholders? Respondents

Ambur Mark V Systems Limited P3 Data Systems, Inc. OASIS Universal Business Language

Technical Committee AICPA CGI Federal, Inc. Hoffman IRIS Business Services Limited PWC Texas Education Agency Sunlight Foundation Booz Allen Hamilton AGA Data Transparency Coalition XBRL.US Center for Organizational Excellence

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Question H: Use CasesSummary of Responses

Summary of Responses

Implementing a solution that creates an environment of consolidated

data that is available to the government and private sector communities

(i.e., a data centric environment).

Enabling greater analytics and better decision making through greater

data consolation/association, access, and quality.

– Examples of Consolidation/Association: enabling the comparison of data from a

contractor supporting multiple contracts; and accessing enterprise view of

federal spending across agencies and programs

– Example of Access: viewing data from multiple sources at the same time

– Example of Quality: comparing data with other sources of Federal spending

information to determine data quality

Improve the private sectors’ accountability, management, and

compliance in federal spending reports.

Enable improved views or reports of financial data (for example: full life-

cycle, geospatial, information hierarchies; and conducting oversight on

specific contracts).

What use cases would you anticipate or envision for information with data structured in accordance with established data standards on data exchange? Respondents

REI Systems Ambur Mark V Systems Limited P3 Data Systems, Inc. OASIS Universal Business Language

Technical Committee AICPA CGI Federal, Inc. Hoffman IRIS Business Services Limited PWC Sunlight Foundation Booz Allen Hamilton AGA Data Transparency Coalition XBRL.US Center for Organizational Excellence

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Question I: ImpactSummary of Responses

Summary of Responses

Provide greater clarity into Government goals and the effectiveness of

grant programs, resulting in better allocation of resources and more

effective results.

Implementation of standards will cause increased costs for some

private and government entities due to changes in their processes or

technology from legacy implementations.

Greater access to data and standardization will enable private sector

entities to focus their resources on better solutions or priorities for the

government.

Audit reporting and related processes may be more effective with

standardized data and a standardized rules processing environment.

What impact would established and implemented data standards on data exchange have on you, your business, constituent group or pertinent stakeholders, and investments? Respondents

Ambur Mark V Systems Limited P3 Data Systems, Inc. OASIS Universal Business Language

Technical Committee AICPA CGI Federal, Inc. Hoffman IRIS Business Services Limited PWC Texas Education Agency Booz Allen Hamilton Data Transparency Coalition XBRL.US Center for Organizational Excellence

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Question J: Other CriteriaSummary of Responses

Summary of Responses

Supporting functions/capabilities will be critical to the effectiveness of establishing

data standards:

– Stewardship of the data

– Security

– Data management/data governance

– Metadata

– Outreach and change management

Ensure that the developed data standards remain flexible (for example, integrating

with other standards and ability to account for related kinds of reporting that are not

strictly financial).

Planning for implementation should take into account potentially significant and

complex changes required by supporting systems and organizations.

Leverage best practices for data standardization and for implementing systems that

will use the data:

– Consolidate data elements based on requirements of other reporting needs where

possible (i.e., Standard Business Reporting).

– Leverage incremental and iterative development for new or modernized systems.

– Semantic linkages are crucial to connecting financial data to other sources of data.

A robust review and validation process for data standards is important, and as part

of the process, some amount of manual effort to evaluate the quality of the data will

be necessary.

What other criteria should be considered by Treasury and OMB in establishing the data standards on data exchange? Respondents

Ambur REI Systems P3 Data Systems, Inc. OASIS Universal Business Language

Technical Committee AICPA CGI Federal, Inc. Hoffman IRIS Business Services Limited PWC Booz Allen Hamilton AGA Data Transparency Coalition XBRL.US Center for Organizational Excellence