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Record of Changes

Change
Number
Date
Reference
A = Add
M = Modify
D = Delete
Change Description

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Executive Summary
The Pandemic Response Accountability Committee (PRAC) seeks to understand whether, and if
so, to what extent, the existing publicly available award-level data is sufficiently comprehensive
to provide transparency into Coronavirus Aid, Relief, and Economic Security Act of 2020
(CARES Act) and subsequent pandemic-related spending. Over a six-week period, MITRE, a
not-for-profit organization and operator of federally funded research and development centers
authorized by the Federal Acquisition Regulation 35.017, completed an independent assessment
of existing, publicly available information related to federal pandemic financial assistance and
procurement awards. In this assessment, MITRE analyzed materials related to
USAspending.gov, Small Business Administration’s Paycheck Protection Program (SBA PPP),
and the U.S. Department of the Treasury’s (Treasury) Coronavirus Relief Fund (CRF). In this
assessment, MITRE 1) confirmed whether gaps exist in USAspending.gov, SBA PPP, or CRF
data collections1 and 2) analyzed the impact of any such gaps to meet the CARES Act
transparency requirements.
Comparing COVID-19-related spending to American Recovery and Reinvestment Act of 2009
(Recovery Act) investments, MITRE notes significant differences in the scope and nature of
federal spending. While the Recovery Act embodied $282 billion in federal funding, with the
goal of “shovel ready” projects intended to spur economic growth, COVID-19-related funding,
in contrast, amounts to more than $2.6 trillion dollars and is intended to provide a wide array of
social services, economic/small business, scientific research, and healthcare needs. Unlike
Recovery Act funded awards, the government’s coronavirus response is more opaque: the
activities funded to respond to the impacts of COVID-19 are less visible on a daily basis to the
public. Given the nature of federal investments to respond to the coronavirus, transparency is
critical to manage and oversee the trillions in federal spending.
Findings
Leveraging a combination of USAspending.gov, SBA PPP, and the Treasury Office of Inspector
General (OIG) CRF data sources, publicly available data exists to satisfy a substantial portion
of the CARES Act transparency requirements.
Nevertheless, MITRE found key gaps in these existing data sources as they were evaluated for
completeness, accuracy, and timeliness. These key gaps may impair the PRAC’s ability to meet
all COVID-19-related spending transparency requirements, pursuant to the Sections 15010 and
15011 of the CARES Act. Such gaps are identified as findings below, based on analysis of the
completeness, accuracy, and timeliness of USAspending.gov, SBA PPP, and CRF data
collections as they relate to CARES Act transparency requirements. It should be noted that the
findings below are organized by dimension of data quality but not prioritized in any way.
Completeness
1. No award-level source of data is available to estimate number of jobs created or retained
by the project or activity within USAspending.gov. The Office of Management and

1 At the time of this assessment, CRF data was not publicly available and could not be assessed in its current state by MITRE and
under the proposed approach and methodology applied to the other data sources.

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Budget (OMB) has represented that its source of data to compile this information is based
on program-level information, not award-level data. Further, it is uncertain whether this
reporting requirement is satisfied for SBA PPP based on its “jobs” data element.
2. USAspending.gov publishes federal spending at the procurement- and financial-
assistance award level. For large covered funds, the CARES Act requires reporting of a
“detailed list of all projects or activities” to include the name and description of each
project or activity and associated financial information. Unless reporting at the award
level is deemed sufficient, more information about projects and activities by financial
assistance and procurement award may need to be required beyond what MITRE
understands will be available for CRF awards.
3. USAspending.gov provides first-tier subaward obligation related financial and other
descriptive subaward information for federal grants and contracts. However, no first-tier
subaward loan information is available on USAspending.gov.2
4. Neither USAspending.gov, SBA PPP data, nor CRF data collection provide transparency
into subawards below the first-tier subaward level, similar to the reporting requirements
applied in the Recovery Act.
5. USAspending.gov does not provide subaward expenditure information.3
6. MITRE found there were missing values of the National Interest Action code for federal
procurements on USAspending.gov.
7. With respect to SBA’s PPP loans more than $150,000, SBA does not publish specific
loan amounts, instead publishing only a “loan range” for each loan award. Further,
neither PPP loan expenditures nor information regarding loan forgiveness are published
by SBA.4
8. With respect to SBA’s PPP loans less than $150,000, SBA does not publish identifying
information about the recipients, including names or addresses.56
Accuracy

9. The “award description” data elements continue to lack specificity about the intent or
purpose of the award. Award descriptions often provide brief titles in the award
description field or acronyms that fail to offer details regarding the award. OMB’s
August 2020 guidance to federal agencies intends to improve the quality of this data, but
such improvements have not yet manifested into currently available USAspending.gov.

2 Treasury OIG requires collection and reporting of CRF awards.  It should be noted that the PRAC has plans to make this
information available on its public-facing website scheduled for launch in November 2020.
3 Ibid.
4 Finding #7 may no longer apply, depending on the outcome of pending SBA litigation, Case 1:20-cv-01240-JEB, Documents
14 & 19 (August 18, 2020 and September 22, 2020).
5 MITRE recognizes that recipient information is not required under the CARES Act, but the level of transparency potentially
increases by considering actions to address.
6 Finding #8 may no longer apply, depending on the outcome of pending SBA litigation, Case 1:20-cv-01240-JEB, Documents
14 & 19 (August 18, 2020 and September 22, 2020).

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10. MITRE sampled the U.S. Department of Health and Human Services’ (HHS) COVID-
19-related federal grants awards from USAspending.gov and compared it to HHS
Tracking Accountability in Government Grants System (TAGGS) data, finding a
mismatch of approximately 30 percent of the award amounts published, between TAGGS
and USAspending.gov data. MITRE compared awards using award IDs; however, it is
recommended that further analysis be conducted to determine whether and the extent to
which true data quality issues exist.
11. MITRE identified mismatches between various location-related data elements (e.g., zip
code and congressional district) on USAspending.gov and in SBA’s PPP data.
12. USAspending.gov publishes data regarding the top-five highly compensated employees
of an awardee. The “name” field does not allow for filtering of “first name,” “middle
name,” and “last name,” because it is unstructured. This may impair the transparency of
the top-five highly compensated executives of the recipient organization.
13. MITRE was unable to conclude the accuracy of first-tier subaward data, based on the
data made available for the purposes of this assessment.
14. CRF detailed data was not available for the data quality analysis. In lieu of a data quality
analysis, MITRE reviewed the published validation rules and GrantSolutions Prime
Recipient User Guide. MITRE found the on-line data collection solution provides a
structured, web-based information system that guides recipient users through the process
of data capture, validation, certification, and final approval along with Treasury OIGs
review, to ensure completion and accuracy. This review indicates the expected data
quality of information provided would be high.
Timeliness
15. Pursuant to the Federal Funding Accountability and Transparency Act of 2006, amended
by the Digital Accountability and Transparency Act of 2014, USAspending.gov requires
agencies and prime recipients to report awards and first-tier subawards within two weeks
of the award. The data model requires reporting more frequent than that required by the
CARES Act.
16. With respect to SBA’s PPP data, MITRE was unable to determine whether SBA moving
forward will report data on a quarterly basis, pursuant to the CARES Act.
The final section of this report provides options for consideration to address the gaps identified
herein.
Other Observations
During the course of analysis, MITRE noted other observations that while not statutorily
required by the CARES Act are gaps that should be noted as possibly beneficial to the goal of
transparency. The following observations apply only to USAspending.gov and SBA PPP due to
the lack of available CRF data at the time of the assessment.
• No information about what is required in the award (that is measurable/observable)
The Award/SubAward Description may provide high-level information regarding what is
required in the award. However, this element is unstructured, and while these elements

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have a 100 percent completion rate, the lack of structure or consistency in what is
captured leads to degradation to the value of the elements.
Structured data elements regarding measurable objectives, goals, and performance
measures would increase the transparency to understand the purpose of an award.
• No progress information
For USAspending.gov reported awards and SBA PPP awards, progress information is not
collected or reported for prime awards or subawards. Access to progress information
would enhance transparency on how the funds are being spent and whether they are being
used as intended. As seen with the Recovery Act, transparency is increased when the
information is integrated with measurable objectives, goals, and performance measures.
• No information about whether the award has delivered what is required (that is
measurable/observable)
Related to the lack of information regarding measurable description of what is required in
an award/subaward and progress information, there also exists a gap on outcomes.
Measurable outcomes supported by objectives, goals, performance metrics, and progress
toward those outcomes closes the gap on a true understanding of not just how funds are
appropriated and obligated but whether the expected or anticipated outcomes were met.
• Project/Activity reporting information
With respect to USAspending.gov and SBA PPP, there is uncertainty of satisfying
“Project or Activity” level reporting. Information is provided by federal award (grant,
contract, loan). If it is interpreted that the provision's term "project or activity" is more
detailed than that of a federal "award," this may not be satisfied.
• Subcontract or Subgrant reporting information
There is uncertainty of satisfying the reporting requirement for detailed information on
any level of subcontracts or subgrants awarded by the covered recipient or its
subcontractors or subgrantees. Information on USAspending.gov is provided by federal
award (grant, contract, loan) at the first-tier subaward award level only. Depending on
how the provision is interpreted, for the last phrase "as prescribed by the Director of
OMB," the provision may be interpreted as requiring this detailed information on "any
level" as "prescribed by OMB." In this case, OMB may say that its guidance prescribes
"any" to mean "first tier" subaward reporting only (to meet the current statute).

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Table of Contents

Preface ................................................................................................................................. 1-1

Overview ....................................................................................................................... 1-1

Purpose .......................................................................................................................... 1-2

CARES Act Stakeholders – Relevant Roles and Responsibilities ................................ 1-2

Developing an Informed and Independent Assessment .................................................. 2-1

Approach ....................................................................................................................... 2-1

Objectives ..................................................................................................................... 2-2

Assumptions .................................................................................................................. 2-3

Constraints .................................................................................................................... 2-4

Identification of Themes from Prior Federal Spending Transparency Efforts ............ 3-1

Identifying Relevant Data Elements to Assess CARES Act Transparency
Requirements ...................................................................................................................... 4-1

USAspending.gov ......................................................................................................... 4-1

Small Business Administration Paycheck Protection Program .................................... 4-3

Department of Treasury Coronavirus Relief Fund ....................................................... 4-5

Assessment of Existing Data Sources Based on CARES Act Transparency
Requirements ...................................................................................................................... 5-1

Summary – Alignment Areas........................................................................................ 5-1
5.1.1
USAspending.gov (Alignment Areas) .................................................................... 5-1
5.1.2
Small Business Administration Paycheck Protection Program .............................. 5-3
5.1.3
Department of Treasury Coronavirus Relief Fund ................................................. 5-3

Summary – Gaps ........................................................................................................... 5-3

USAspending.gov ......................................................................................................... 5-4
5.3.1
Data Sources and Data Elements ............................................................................ 5-5
5.3.2
Completeness .......................................................................................................... 5-6
5.3.3
Accuracy ................................................................................................................. 5-7
5.3.4
Timeliness ............................................................................................................. 5-10

Small Business Administration Paycheck Protection Program .................................. 5-10
5.4.1
Data Sources and Data Elements .......................................................................... 5-11
5.4.2
Completeness ........................................................................................................ 5-12
5.4.3
Accuracy ............................................................................................................... 5-13
5.4.4
Timeliness ............................................................................................................. 5-14

Department of Treasury Coronavirus Relief Fund ..................................................... 5-15

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5.5.1
Data Sources and Data Elements .......................................................................... 5-16
5.5.2
Accuracy ............................................................................................................... 5-17
5.5.3
Timeliness ............................................................................................................. 5-17

Options to Address Gaps ................................................................................................... 6-1

Alternative 1 – Status Quo ............................................................................................ 6-1

Alternative 2 – Low/Moderate System/Policy Changes ............................................... 6-3

Alternative 3 – Complex System/Policy Changes ........................................................ 6-6

Summary of Analyses of Alternatives ........................................................................ 6-12

Bibliography ........................................................................................................................ 7-1

References and Source Documentation ............................................................................ 8-1
 Mapping of Data Validation Rules to USAspending.gov Data
Elements ............................................................................................................. A-1
 Data Quality Analysis Detail ............................................................................ B-1
 Risk Areas .......................................................................................................... C-1
 Acronyms and Abbreviations .......................................................................... D-1

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List of Tables
Table 1-1. Primary Stakeholders Requiring Coordination .......................................................... 1-2
Table 4-1. USAspending.gov Data Element Analysis ................................................................. 4-1
Table 4-2. SBA PPP Data Element Analysis ............................................................................... 4-3
Table 4-3. CRF Data Element Analysis  ...................................................................................... 4-5
Table 5-1. Definitions of the Domains Used for Data Requirements Assessment ...................... 5-1
Table 5-2. USAspending.gov Data Element Completion Rate .................................................... 5-6
Table 5-3. HHS TAGGS Appropriation Codes ........................................................................... 5-7
Table 5-4. USAspending.gov COVID-19 DEFC Codes ............................................................. 5-8
Table 5-5. SBA PPP Loan Ranges ............................................................................................. 5-13
Table 5-6. Example Congressional District to Geographic Location Mapping ......................... 5-14
Table 5-7. CRF Reporting Timeline .......................................................................................... 5-18
Table 6-1. Alternative 1 – Status Quo ......................................................................................... 6-1
Table 6-2. Alternative 2 – Low/Moderate System/Policy Changes ............................................ 6-4
Table 6-3. Alternative 3 – Complex System/Policy Changes...................................................... 6-6
Table 6-4. Summary of Analysis of Alternatives ...................................................................... 6-12
Table A-1. Mapping of Data Validation Rules to USAspending.gov Data Elements ................ A-1
Table B-1. Data Quality Analysis Source Files .......................................................................... B-2
Table B-2. USAspending.gov Analysis ...................................................................................... B-3
Table B-3. Zip Code Metrics Analysis for USAspending.gov ................................................... B-6
Table B-4. HHS TAGGS to USAspending.gov Comparison Analysis ...................................... B-6
Table B-5. Effect of OMB Clarification of Award Description in USAspending.gov
Analysis............................................................................................................... B-7
Table B-6. SBA PPP Loans >= $150K Completeness Checks Results ...................................... B-8
Table B-7. SBA PPP Loans < $150k Completeness Checks Results ......................................... B-9
Table B-8. SBA PPP Loans >= $150K Accuracy Checks Results ........................................... B-10
Table B-9. SBA PPP Loans < $150k Accuracy Checks Results .............................................. B-10
Table C-1. Excerpt of Payment Integrity High Risk Areas ........................................................ C-1

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List of Figures
Figure 2-1. MITRE Approach for the Assessment ...................................................................... 2-1
Figure 5-1. Data Quality Process Flow for USAspending.gov .................................................... 5-5
Figure 5-2. HHS and USAspending.gov Comparison Process .................................................... 5-8
Figure 5-3. CRF Reporting Times ............................................................................................. 5-10
Figure 5-4. Data Quality Analysis Process for SBA PPP Data ................................................. 5-11

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 Preface
 Overview
The Coronavirus Aid, Relief, and Economic Security Act of 2020 (CARES Act) was signed into
law on March 27, 2020. This law provides more than $2 trillion in emergency economic relief
for individuals, families, and businesses affected by the 2020 coronavirus pandemic [1] [2] [3]
[4]. The appropriations are made available to those in need, in the form of stimulus payments,
grants, loans, and procurement actions related to coronavirus relief efforts. To provide oversight
and transparency of coronavirus-related spending, the CARES Act mandates the establishment of
the Pandemic Response Accountability Committee (PRAC) organized under the Council of the
Inspectors General on Integrity and Efficiency (CIGIE) with a defined five-year mission.
Further, the CARES Act requires the PRAC to establish and maintain a user-friendly, public-
facing website to foster greater accountability, transparency, and oversight in the use of covered
funds. Key functions of the website include:
• Information explaining the coronavirus response and how covered funds are being used
• Accountability information such as findings from Inspectors General (IGs), progress
reports, audits, and inspections
• Data on operational, economic, financial, grant, subgrant, contract, and subcontract
information
• Data on any federal government awards that expend covered funds more than $150,000,
and information about the process used to award the funds
• Reports on covered funds obligated by month to each state and congressional district
• Public and confidential feedback on the performance of any covered funds
• Federal government awards that expend covered funds under the Federal Funding
Accountability and Transparency Act of 2006 (FFATA) (31 U.S.C. 6101 note), allowing
aggregate reporting on awards less than $50,000
• Estimates of the jobs sustained or created by the CARES Act to the extent practicable
• Appropriate links to government websites with information concerning covered funds and
the coronavirus response, including federal agency and state websites
• A plan from each federal agency for using covered funds
• Federal allocations of mandatory and other entitlement programs by state, county, or
other geographical unit, related to covered funds or the coronavirus response
• Recommendations made to agencies relating to covered funds and the coronavirus
response, as well as the status of each recommendation
The PRAC will exclude posting information to the website that is necessary to protect national
security or to protect information not subject to disclosure under Sections 552 and 552a of Title
5, United States Code.

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To provide the necessary transparency in federal spending, the PRAC required assistance to
better understand the landscape of existing reporting to USAspending.gov, pursuant to the
Digital Accountability and Transparency Act of 2014 (DATA Act), and requirements set forth in
OMB M-20-21 [5], “Implementation Guidance for Supplemental Funding Provided in Response
to the Coronavirus Disease 2019 (COVID-19).” In addition, MITRE assessed the extent to which
SBA Paycheck Protection Program (PPP) spending data and Coronavirus Relief Fund (CRF)-
related information collected by the Department of the Treasury (Treasury) could be leveraged to
meet the CARES Act transparency requirements. The PRAC engaged MITRE, a not-for-profit
operator of federally funded research and development centers authorized by the Federal
Acquisition Regulation 35.017, to determine the requisite data gaps limiting the PRAC’s ability
to satisfy the statutory mandate for transparency in CARES Act and subsequent pandemic-
related federal spending requirements as contained in this report.
 Purpose
This report provides an analysis of the CARES Act transparency requirements and the extent to
which these statutory requirements can be satisfied through three publicly available data sets:
USAspending.gov, SBA PPP, and CRF. To conduct this analysis, MITRE leveraged its
knowledge from previous government-wide federal spending transparency efforts, with a focus
on identifying gaps and data quality in the available data sets. Section 2 of this report provides
MITRE’s approach for performing this analysis, including assumptions and constraints
associated with the analysis. Section 3 identifies themes from prior federal spending
transparency efforts. Section 4 references the CARES Act transparency requirements from
Section 15011. Section 5 contains MITRE’s assessment of USAspending.gov, SBA PPP data,
and Treasury CRF as aligned with the CARES Act transparency requirements, identifying
alignment areas and gaps. Section 6 provides options to address the gaps.
 CARES Act Stakeholders – Relevant Roles and
Responsibilities
Table 1-1 summarizes the primary stakeholders that require coordination to impact data
transparency requirements under the CARES Act:
Table 1-1. Primary Stakeholders Requiring Coordination
Stakeholder
Relevant Role(s) and Responsibilities
CIGIE
Independent entity within executive branch that addresses
integrity, economy, and efficiency issues across the Office of
Inspector General (OIG) community.
PRAC
Independent oversight committee under the CIGIE established
under the CARES Act to promote transparency and provide
oversight of funds provided under the CARES Act.
Office of Management and Budget
(OMB)
Office within the Executive Office of the President that
provides budget policy direction oversight; issues guidance to
federal agencies on implementation of the CARES Act.

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Stakeholder
Relevant Role(s) and Responsibilities
General Services Administration
(GSA)
Manages and operates systems that support federal acquisition
activities and reporting of financial assistance subaward
reporting to USAspending.gov; responsible for multiple
appropriations accounts under the CARES Act, including
managing the federal governments’ buildings and assets in
response to coronavirus, such as cleaning services, labor,
supplies, and operations.
Treasury – OIG
Assigned responsibility under CARES Act to conduct
monitoring and oversight of the receipt, disbursement, and uses
of CRF payments.
Treasury, Bureau of Fiscal Service –
Office of Data Transparency
Administers USAspending.gov to increase access and use of
federal spending data for transparency; promotes transparency
of data through improvement of value, quality, and availability
of data by collaborating across stakeholders to define data
standards and requirements.
Small Business Administration (SBA)
Administers loan programs established under the CARES Act
to provide emergency economic relief to small businesses.
Department of Health and Human
Services (HHS)
Administers Provider Relief Funds established under the
CARES Act to support hospitals and healthcare providers.

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 Developing an Informed and Independent Assessment
 Approach
MITRE consulted a variety of resources to inform the approach for conducting this assessment.
Reviews of source documentation, stakeholder interviews, and lessons learned from prior federal
spending transparency efforts surfaced key themes that guided the statutory and data quality
analysis for the assessment.
Findings from the statutory and data quality analysis were evaluated against the three dimensions
of data quality—completeness, accuracy, and timeliness—to determine if the requisite data
requirements sufficiently meet the statutory mandate for CARES Act transparency as articulated
in Sections 15010 and 15011. Additionally, an assessment was completed for CRF by reviewing
information available on www.Treasury.gov and www.grantsolutions.com.
The evaluation of findings against the dimensions of data quality resulted in the identification of
alignment areas, observations, and key gaps.
MITRE identified and defined three alternatives for consideration for remedying identified gaps
and addressing observations.
Figure 2-1 outlines MITRE’s approach to conducting the assessment.

Figure 2-1. MITRE Approach for the Assessment
The assessment is further described in detail below.

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Source Document Reviews
MITRE reviewed source documentation to understand and document the transparency
publication requirements of the CARES Act. Source documents include the legislation itself,
OMB memoranda providing implementation guidance, other OMB correspondence, and
information curated from stakeholder interviews. Source document reviews provided an
understanding of related information and publicly available definitions to satisfy the PRAC
objective of transparency and informed the assessment approach.
Stakeholder Interviews
MITRE conducted stakeholder interviews with the following organizations: PRAC; OMB,
Office of Federal Financial Assistance; OMB, Office of Federal Procurement Policy (OFPP);
Treasury, Bureau of Fiscal Service; Treasury, OIG; and the GSA, Federal Acquisition
Service Office of Systems Management. The interviews were used to identify additional data
sources and to gain an understanding of potential data limitations and gaps of existing data
elements.
Prior Federal Spending Transparency Efforts Analysis
MITRE conducted a review of lessons learned and recommendations based on
implementation of the Recovery Act [6] and other national disaster response implementations
(e.g., Sandy Recovery Improvement Act [2013] [7]) and the DATA Act (2014) [8] to inform
the transparency approach. Data sources included Government Accountability Office (GAO)
reports, Inspector General (IG) reports, Recovery Board reports and documentation, and
congressional hearings.
Statutory and Data Quality Analysis
MITRE conducted a detailed review of CARES Act Section 15011 to determine the data that
would be needed by the PRAC to satisfy transparency. These evaluations included an
assessment of USAspending.gov, SBA PPP, and CRF data satisfaction of the statute.
MITRE evaluated a subset of data elements identified as either statutorily required and
reported to and available on USAspending.gov for CARES Act and SBA.gov for PPP.
Additionally, an assessment was completed on data available on www.treasury.gov for CRF.
Gap Identification and Alignment
MITRE documented identified gaps and areas of alignment in support of this assessment.
Options for Curing Identified Gaps
MITRE proposed alternatives for the PRAC to consider in an effort to cure and remedy
identified gaps and deficiencies.
 Objectives
The objectives of this assessment follow:
• Assess and determine the requisite data requirements necessary to satisfy the statutory
mandate for transparency in CARES Act and subsequent pandemic-related spending.

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• Identify alignment areas and key data gaps of current government-wide reporting
requirements pursuant to:
o The CARES Act
o FFATA (2006) as amended by the DATA Act (2014)
o OMB M-20-21 [9], “Implementation Guidance for Supplemental Funding
Provided in Response to the Coronavirus Disease 2019 (COVID-19)”
• Provide the PRAC with sufficient information to make informed strategic decisions on
the policies, procedures, operations, and engagement with both federal and non-federal
stakeholders that advance its mission of providing transparency and oversight of
pandemic response-related federal spending.
 Assumptions
MITRE has identified the following assumptions for this assessment:
• Government-wide publication of federal spending data (e.g., USAspending.gov) is
intended to both provide the public with visibility on how federal dollars are spent and
address ongoing government management challenges by expanding the quality and
availability of federal spending data. The published data is not intended to embody the
full set of information necessary to conduct a complete inquiry into whether fraud, waste,
abuse, or mismanagement has occurred. Additional information would be required for
such an investigation.
• USAspending.gov is not intended to capture information for program-specific
requirements; it is intended to capture the information that would be applicable across
most programs.
• The federal spending transparency requirements required pursuant to the CARES Act
Sections 15010 and 15011 formed the basis of the requirements evaluated in this
assessment.
• To assess the sufficiency to existing information to meet the requirements under the
CARES Act Sections 15010 and 15011, MITRE analyzed two published data sources:
USAspending.gov and SBA PPP data. MITRE also had access to summary-level CRF
data.
• The scope of this MITRE assessment is limited to federal grants, loans, procurement, and
loan awards and does not include payments to individuals.
• In general, MITRE did not conduct an independent re-evaluation of GAO and IG audits
documenting data limitations provided by USAspending.gov. [10]. To the extent
subsequent Executive Branch guidance has been issued to address data limitations,
MITRE has taken such actions into consideration when assessing data quality.
• MITRE assumed the statutory analysis loans that are not forgiven will not have associated
expenditures.
• The data quality analysis performed in service of this assessment informs whether
published data is of sufficient quality to meet the transparency requirements of the

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CARES Act. The analysis does not attempt to answer whether the information is
sufficient to identify potential fraud, waste, abuse, and mismanagement risk.
• MITRE’s methodological approach identified key data elements from USAspending.gov,
SBA PPP data, and CRF data relevant to meet the CARES Act Sections 15010 and 15011
transparency requirements and, for the purposes of this assessment, only performed its
full analysis on these data elements.
 Constraints
MITRE has identified the following constraints for this assessment:
• The timeframe for this assessment limited the number of stakeholder interviews MITRE
could perform. Over this assessment’s two-month period, MITRE was able to conduct a
total of eight group interviews with the following stakeholders: PRAC, OMB/Office of
Federal Financial Management (OFFM), OMB/OFPP, Treasury OIG, Treasury Bureau of
Fiscal Service, and GSA personnel to assess publicly available government-wide data,
SBA PPP data, and Treasury CRF. MITRE did not have an opportunity to interview
representatives from SBA.
• Given the timeframe provided, MITRE’s assessment of award-level data quality
(completeness, timeliness, accuracy) was based on publicly available information. No
additional agency or recipient data and authoritative source materials (e.g., Federal
Procurement Data System [FPDS], agency grants management systems, agency
procurement systems) were provided to conduct an independent validation of agency- or
recipient-reported data.
• At the time of this assessment, CRF data was not publicly available and could not be
assessed in its current state by MITRE and under the proposed approach and
methodology applied to the other data sources.

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 Identification of Themes from Prior Federal Spending
Transparency Efforts
MITRE conducted an analysis of recommendations, successes, and improvement areas from
former and ongoing efforts to provide transparency in federal spending (i.e., Recovery Act,
FFATA/DATA, Hurricane Sandy Relief) including guidance documents (i.e., OMB
memorandums), GAO and IG reports, congressional testimony, and key stakeholder interviews.
MITRE assessed prior federal-spending transparency efforts to identify themes to inform the
CARES Act funding transparency assessment.
MITRE identified and considered the following themes (lessons) from prior efforts to provide
transparency in federal spending:
1. Data Quality is highest when it is collected from the authoritative source and there is a
repeatable process with appropriate certifications to validate the data.
Data quality is measured based on evaluating the completeness, accuracy, and timeliness
of the information reported.7 Identifying authoritative sources for the data is critical to
ensuring collection of the most accurate, timely, and complete data. Authoritative sources
for data must be validated through a data quality process or internal controls. These can
include review of the data through system validated checks, review of individual data
elements compared to aggregate amounts (e.g., award-level financial data compared to
total award amounts by Treasury Account Symbol), and engagement with the reporting
entity to identify the basis of any perceived data discrepancies and validate the data.
Under the Recovery Act, two separate models existed for reporting and reviewing the
quality of federal spending data. MITRE refers to these models as Model A and Model B,
for the purposes of this assessment. Model A includes financial data regarding
obligations and outlays sourced from agency systems of record based on the Treasury
Accounting System and posted quarterly as required by the Recovery Act. For this
category of federal spending information, data quality validation was based on the
Treasury and agency review. In contrast, Model B was used for quarterly reported award-
level data sourced directly from prime recipients of Recovery Act-funded awards. OMB
memoranda [11] to implement collection of Recovery Act spending and the Recovery
Board’s efforts established an approach for implementing consistent reporting that was
critical for providing transparency to the public. To validate the quality of this award-
level data, in addition to system-based checks, the Recovery Board executed a process of
reviewing award data reported on a quarterly basis from financial assistance and contract
recipients. To facilitate the quality of the data, the White House complex and the
Recovery Board established and executed an extensive engagement strategy to provide
reporting recipients with trainings on quarterly award-specific reporting requirements,
one-on-one call-center support to answer recipient reporting questions, and proactive
outreach to individual reporters to collect data not yet submitted and address

7 The definitions for completeness, accuracy, and timeliness for the purposes of this assessment are referenced in
Table 5-1. Definitions of the Domains Used for Data Requirements Assessment.

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completeness/accuracy data questions that arose based on review of the data. Federal
awarding-agency review of the data was limited, but as Recovery Act reporting
progressed, agencies were provided additional opportunities to review award-level data
prior to publication [12].
The Recovery Act’s data quality approach required significant resources to provide near-
weekly outreach and engagement as well as individual engagement with specific
recipients on award-level reporting. While the Recovery Act embodied $840 billion in
Federal funding, with the goal of “shovel ready” projects intended to spur economic
growth, COVID-19 related funding, in contrast, amounts to over $2.6 trillion dollars, and
is intended to provide a wide array of social services, economic/small business, scientific
research, and health care needs.  Different than Recovery Act funded awards, such as
road improvements, the activities funded in response to the impacts of coronavirus are
less visible to the public. Examples of CARES Act awards include sanitation services for
public spaces, the development and supply of personal protective equipment, and making
public in-person services available online, to name a few. The lack of measures to
evaluate the intended effect of relief provided by the CARES Act presents a significant
concern to the public and requires a greater level of transparency than the Recovery Act.
To implement the requirements under FFATA and the subsequent DATA Act,
USAspending.gov sources financial data regarding obligations and outlays at the
Treasury Account Symbol level and all prime award data from federal agency systems of
record. First-tier subaward data is submitted by prime recipients.  The USAspending.gov
approach follows the reasoning that federal agencies are accountable and therefore should
serve as the authoritative source of federally funded prime awards, to include the award
description and award amount, among other award-specific data. With respect to first-tier
subaward data, OMB determined that prime recipients, in awarding first-tier subawards,
are directly accountable for reporting accurate and complete data over the funds they
have sub-granted or sub-contracted to third parties, in furtherance of their federal award
requirements/outcomes [13]. In addition to agency system-based and USAspending.gov
checks, this data is subjected to data quality assessments pursuant to OMB Memoranda
for both financial assistance and procurement award data and is certified by agency Chief
Financial Officers and Chief Procurement Officers, respectively.
After the launch of USAspending.gov in December of 2007, OMB issued guidance to
improve the quality of USAspending.gov reported data, requiring agencies to develop
and implement data quality plans. With the adoption of the DATA Act, along with
additional OMB guidance, agencies are providing recurring reporting to Treasury and
applying additional rigor to evaluate and certify reported information to improve the data
quality. Continuing to maximize and optimize the existing infrastructure (i.e.,
USAspending.gov and DATA Act Information Model Schema) will help achieve the
balance between burden and quality, while creating a sustainable data environment.
2. Data Quality is a function of not only how the data is collected and validated but how it
is presented for publication.
The way the data is displayed and then interpreted has potential to confuse stakeholders.
Identifying and communicating scenarios associated with the published data can help

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minimize misinterpretations and erroneous conclusions on how dollars were spent.
Translating federal spending data onto a public-facing website requires an understanding
of both what the data represents and the users’ level of understanding of the federal
procurement and financial assistance programs and programmatic requirements.
3. Reporting Burden must be balanced with existing available data and utility of
requirements for new information.
OMB implemented the requirements of FFATA in 2006, which provided unprecedented
transparency of government-wide federal spending and laid the foundations to establish
an authoritative source for recipient reporting, USAspending.gov. For the first time, the
federal government had a one-stop website that provided transparency in spending across
all government programs.
Per GAO, reporting requirements under the Recovery Act had to be met quickly. Under
the Recovery Act, the amount of time dedicated by recipients to collect and report the
required information to satisfy the minimum level of transparency was a fundamental
area of concern. The need for additional information was evaluated based on the
Paperwork Reduction Act of 1995’s requirement to balance burden versus utility data
from fund recipients.
Subsequent efforts to provide transparency in appropriations-specific federal spending,
such as Hurricane Sandy, leveraged USAspending.gov. Specific to Hurricane Sandy, the
Recovery Board was provided specific requirements to track and display spending data.
With the onset of the CARES Act transparency reporting requirements, an opportunity
exists to leverage additional data sets and sources outside of USAspending.gov that were
not readily available after the Recovery Act.
4. Data standardization is critical to providing transparency of government-wide federal
spending.
GAO found that data standardization is critical to integrate systems and improve
transparency and accountability but did not recommend and prescribe a preferred data
standard [14] [15]. GAO found that data quality is limited by challenges in the
implementation and use of some data standards. While improvements have been seen
over the last few years, additional work is still needed to improve the understanding of
standard data-element definitions that may be open to interpretation [15]. In August 2020,
OMB sent Controller Alert: Award Description Data Quality for Financial Assistance
Awards [16] as a reminder of the policy on financial-assistance requirements on award
descriptions. Also, in August 2020 the OFPP sent an email to senior procurement
executives, with additional information to facilitate the development of clear descriptions
for COVID-contract awards [17].
5. Standardize data to integrate systems and enhance accountability.
OMB and the Recovery Board recognized that “standardized data would be more usable
by the public and the Recovery Board for identifying potential misuse of federal funds.”
OMB and Treasury have engaged in efforts to continue to standardize and improve the

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consistency of the data, through the DATA Act Information Model Schema (DAIMS)
and OMB reporting guidance and alerts to the reporting community.

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 Identifying Relevant Data Elements to Assess CARES
Act Transparency Requirements
MITRE conducted a detailed review of CARES Act Section 15011 against USAspending.gov,
SBA PPP, and CRF to determine what data is required to satisfy transparency requirements.
MITRE mapped statutory language to data elements to understand which elements from each
data source need to be analyzed to evaluate transparency requirements. During this assessment,
MITRE identified gaps in required USAspending.gov data that included information regarding:
• Jobs created or retained
• Loans subawards
• First-tier subaward outlays
• Second to Nth tier subawards
Additionally, MITRE assessed data not directly specified in the CARES Act statutes, such as
data elements from HHS Tracking Accountability in Government Grants System (TAGGS) data
and other available data elements from USAspending.gov. The expansion of the data elements
reviewed was to better inform the data quality assessment provided. Information regarding the
HHS TAGGS data assessment can be found in Appendix B Data Quality Analysis Detail.
The tables below represent relevant data elements identified across the data sources, and those
data elements inform the data assessment detailed in Section 6 Assessment of Existing Data
Sources Based on CARES Act Transparency Requirements.
 USAspending.gov
Table 4-1. USAspending.gov Data Element Analysis
ID

Transparency Requirements -
CARES Act, Section 15011
Relevant Data Element(s) in USAspending.gov
1
(b)(1)(A) On a monthly basis until September 30, 2021,
each agency shall report to the Director of the Office of
Management and Budget, the Bureau of Fiscal Service in
the Department of the Treasury, the Committee, and the
appropriate congressional committees on any obligation
or expenditure of large covered funds, including loans
and awards.
FederalActionObligation
ObligatedAmountFundedByCOVID19Supplementals
PotentialTotalValueOfAward (for procurements)
PrimeAwardAmount
2
(b)(1)(A) On a monthly basis until September 30, 2021,
each agency shall report to the Director of the Office of
Management and Budget, the Bureau of Fiscal Service in
the Department of the Treasury, the Committee, and the
appropriate congressional committees on any obligation
or expenditure of large covered funds, including loans
and awards.
OutlayedAmountFundedByCOVID19Supplementals
3
(B) Not later than 90 days after the date of enactment of
this Act, each agency shall submit to the Committee a
plan describing how the agency will use covered funds.
 N/A

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ID

Transparency Requirements -
CARES Act, Section 15011
Relevant Data Element(s) in USAspending.gov
4
(2) Not later than 10 days after the end of each calendar
quarter, each covered recipient shall submit to the agency
and the Committee a report that contains—
Reference the data schema8

5
(2) Not later than 10 days after the end of each calendar
quarter, each covered recipient shall submit to the agency
and the Committee a report that contains—
AwardeeOrRecipientLegalEntityName
AwardeeOrRecipientUniqueIdentifier
6
(A) the total amount of large covered funds received from
the agency;
Total of data element: FederalActionObligation
Total of data element:
ObligatedAmountFundedByCOVID19Supplementals
Total of data element: PotentialTotalValueOfAward (for
procurements)
Total of data element: PrimeAwardAmount
Total of data element:
OutlayedAmountFundedByCOVID19Supplementals
7
(B) the amount of large covered funds received that were
expended or obligated for each project or activity;
Total of data element: FederalActionObligation
Total of data element:
ObligatedAmountFundedByCOVID19Supplementals
Total of data element: PotentialTotalValueOfAward (for
procurements)
Total of data element: PrimeAwardAmount
Total of data element:
OutlayedAmountFundedByCOVID19Supplementals
8
(B) the amount of large covered funds received that were
expended or obligated for each project or activity;
FederalActionObligation
ObligatedAmountFundedByCOVID19Supplementals
PotentialTotalValueOfAward (for procurements)
PrimeAwardAmount
OutlayedAmountFundedByCOVID19Supplementals
9
(C) a detailed list of all projects or activities for which
large covered funds were expended or obligated,
including—
 No data element available.
10
(i) the name of the project or activity;
 No data element available.
11
(ii) a description of the project or activity; and
AwardDescription
SubAwardDescription
12
(iii) the estimated number of jobs created or retained by
the project or activity, where applicable; and
 No data element available.

8 https://www.usaspending.gov/download_center/data_dictionary

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ID

Transparency Requirements -
CARES Act, Section 15011
Relevant Data Element(s) in USAspending.gov
13
(D) detailed information on any level of subcontracts or
subgrants awarded by the covered recipient or its
subcontractors or subgrantees, to include the data
elements required to comply with the Federal Funding
Accountability and Transparency Act of 2006 (31 U.S.C.
6101 note) allowing aggregate reporting on awards below
$50,000 or to individuals, as prescribed by the Director of
the Office of Management and Budget.
Reference the data schema9
No data element available on loans first-tier subawards
available.
No data element on first-tier subaward outlays available.
No data element for  second- to Nth-tier subawards available.
 Small Business Administration Paycheck Protection Program
Table 4-2. SBA PPP Data Element Analysis
ID
Transparency Requirements -
CARES Act, Section 15011
Relevant Data Element(s) in SBA
1
(b)(1)(A) On a monthly basis until September 30, 2021,
each agency shall report to the Director of the Office of
Management and Budget, the Bureau of Fiscal Service in
the Department of the Treasury, the Committee, and the
appropriate congressional committees on any obligation
or expenditure of large covered funds, including loans
and awards.
LoanAmount (More than $150,000)
LoanRange (Less than $150,000)
2
(b)(1)(A) On a monthly basis until September 30, 2021,
each agency shall report to the Director of the Office of
Management and Budget, the Bureau of Fiscal Service in
the Department of the Treasury, the Committee, and the
appropriate congressional committees on any obligation
or expenditure of large covered funds, including loans
and awards.
Data element information is not provided and required of SBA
(See Options to Address Gaps ).
3
(B) Not later than 90 days after the date of enactment of
this Act, each agency shall submit to the Committee a
plan describing how the agency will use covered funds.
 No data element available.
4
(2) Not later than 10 days after the end of each calendar
quarter, each covered recipient shall submit to the agency
and the Committee a report that contains—
 No data element available.
5
(2) Not later than 10 days after the end of each calendar
quarter, each covered recipient shall submit to the agency
and the Committee a report that contains—
Business name (Loans more than $150,000)
6
(A) the total amount of large covered funds received from
the agency;
LoanAmount (Loans less than $150,000)
LoanRange (Loans more than $150,000)
7
(B) the amount of large covered funds received that were
expended or obligated for each project or activity;
Data element information is required of SBA.

9 https://www.usaspending.gov/download_center/data_dictionary

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ID
Transparency Requirements -
CARES Act, Section 15011
Relevant Data Element(s) in SBA
8
(B) the amount of large covered funds received that were
expended or obligated for each project or activity;
LoanAmount (Loans less than $150,000)
LoanRange (Loans more than $150,000)
9
(C) a detailed list of all projects or activities for which
large covered funds were expended or obligated,
including—
  No data element available.
10
(i) the name of the project or activity;
  No data element available.
11
(ii) a description of the project or activity; and
  No data element available.
12
(iii) the estimated number of jobs created or retained by
the project or activity, where applicable; and
JobsReported (note that SBA does not have a data dictionary,
and it is unclear whether this data element reports jobs created
or retained).
13
(D) detailed information on any level of subcontracts or
subgrants awarded by the covered recipient or its
subcontractors or subgrantees, to include the data
elements required to comply with the Federal Funding
Accountability and Transparency Act of 2006 (31 U.S.C.
6101 note) allowing aggregate reporting on awards below
$50,000 or to individuals, as prescribed by the Director of
the Office of Management and Budget.
  No data element available.

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 Department of Treasury Coronavirus Relief Fund
Table 4-3. CRF Data Element Analysis
ID
Transparency Requirements -
CARES Act, Section 15011
Relevant Data Element(s) in Treasury1011
1
(b)(1)(A) On a monthly basis until September 30, 2021, each
agency shall report to the Director of the Office of Management
and Budget, the Bureau of Fiscal Service in the Department of the
Treasury, the Committee, and the appropriate congressional
committees on any obligation or expenditure of large covered
funds, including loans and awards.
FederalActionObligation
ObligatedAmountFundedByCOVID19Supplementals
PotentialTotalValueOfAward (for procurements)
PrimeAwardAmount
2
(b)(1)(A) On a monthly basis until September 30, 2021, each
agency shall report to the Director of the Office of Management
and Budget, the Bureau of Fiscal Service in the Department of the
Treasury, the Committee, and the appropriate congressional
committees on any obligation or expenditure of large covered
funds, including loans and awards.
OutlayedAmountFundedByCOVID19Supplementals

3
(B) Not later than 90 days after the date of enactment of this Act,
each agency shall submit to the Committee a plan describing how
the agency will use covered funds.
  No data element available to evaluate transparency.
4
(2) Not later than 10 days after the end of each calendar quarter,
each covered recipient shall submit to the agency and the
Committee a report that contains—
DUNS
Legal Entity Name
5
(A) the total amount of large covered funds received from the
agency;
Total Amount Coronavirus Relief Funds Received by Prime Recipients

10  Documents 14 & 19 (August 18, 2020 and September 22, 2020).
11 ID nos. 1 & 2 are reported to and published on USAspending.gov, pursuant to Department of Treasury compliance with OMB Memoranda implementing FFATA & DATA Act
reporting requirements. All other data elements are collected pursuant to Treasury OIG directives.

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ID
Transparency Requirements -
CARES Act, Section 15011
Relevant Data Element(s) in Treasury1011
6
(B) the amount of large covered funds received that were
expended or obligated for each project or activity;
For Subrecipients with transactions>=$50,000
Expenditures by Category for Subrecipients with transactions >=$50,000
Contracts Awarded for >=$50,000: Current Quarter Obligations and Expenditure/Payments
Contracts Awarded for >=$50,000: Cumulative Obligations and Expenditure/Payments
Grants Awarded for >=$50,000: Current Quarter Obligations and Expenditure/Payments
Grants Awarded for >=$50,000: Cumulative Obligations and Expenditure/Payments
Loans Issued for >=$50,000: Current Quarter Obligations and Expenditure/Payments
Loans Issued for >=$50,000: Cumulative Obligations and Expenditure/Payments
Direct Payments >=$50,000: Current Quarter Obligations and Expenditure/Payments
Direct Payments >=$50,000: Cumulative Obligations and Expenditure/Payments
Transfers to Governments >=$50,000: Current Quarter Obligations and
Expenditure/Payments
Transfers to Governments >=$50,000: Cumulative Obligations and Expenditure/Payments

Aggregate of Contracts Awarded for <$50,000: Cumulative and Current Quarter Obligation
and Expenditure/Payments
Aggregate of Grants Issued for <$50,000: Cumulative and Current Quarter Obligation and
Expenditure/Payments
Aggregate of Loans Issued for <$50,000: Cumulative and Current Quarter Obligation and
Expenditure/Payments
Aggregate of Direct Payments <$50,000: Cumulative and Current Quarter Obligation and
Expenditure/Payments
Aggregate of Transfers to Governments <$50,000: Cumulative and Current Quarter
Obligation and Expenditure/Payments
Total Current Quarter Obligations and Expenditures by Funding Vehicle
Total Cumulative Obligation and Expenditure/Payments by Funding Vehicle
Total CRF Received by Prime Recipients

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ID
Transparency Requirements -
CARES Act, Section 15011
Relevant Data Element(s) in Treasury1011
7
(B) the amount of large covered funds received that were
expended or obligated for each project or activity;
Project Name
(Plus all data elements related to obligations & expenditures above at the project/activity
level)
8
(C) a detailed list of all projects or activities for which large
covered funds were expended or obligated, including—
Project Name
(Plus all data elements related to obligations & expenditures above at the project/activity
level)
9
(i) the name of the project or activity;
Project Name
(Plus all data elements related to obligations & expenditures above at the project/activity
level)
10
(ii) a description of the project or activity; and
Project description
Expenditure category
11
(iii) the estimated number of jobs created or retained by the project
or activity, where applicable; and
  No data element available.
12
(D) detailed information on any level of subcontracts or subgrants
awarded by the covered recipient or its subcontractors or
subgrantees, to include the data elements required to comply with
the Federal Funding Accountability and Transparency Act of 2006
(31 U.S.C. 6101 note) allowing aggregate reporting on awards
below $50,000 or to individuals, as prescribed by the Director of
the Office of Management and Budget.
Obligation and expenditure data elements
No data element for second- to Nth-tier subawards available.

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 Assessment of Existing Data Sources Based on
CARES Act Transparency Requirements
Based on the requirements that define CARES Act transparency, MITRE conducted a data
quality review on the completeness, accuracy, and timeliness of existing sources to meet the
CARES Act requirements for transparency in COVID-19-related spending:
• USAspending.gov
• SBA PPP
• CRF information
A data quality analysis framework was utilized to analyze three quality dimensions:
Completeness, Accuracy, and Timeliness. Table 5-1 defines and lists the type of assessments
performed for each dimension.
Table 5-1. Definitions of the Domains Used for Data Requirements Assessment
Three Defined Data Quality Domains for Assessment [18]
Dimension
Description
Assessments
Completeness
Criteria related to the availability of
required data attributes or the degree of
population with data values.
Assess whether the data required by statute is
available in the identified source.
For identified elements assess the current population
rate of the element.
Accuracy
Criteria related to affinity with original
intent, veracity as compared to an
authoritative source, and measurement
precision or the degree that data factually
represents its associated real-work object,
event, or concept.
Level 1
Assesses the accuracy of data within a single data set
against known requirements. For example, does the
data meet expected standards, formats, and ranges of
valid values?

Level 2
Assesses the accuracy of data by evaluating its
consistency against other authoritative data sets.
Timeliness
The frequency that data is reported and
published. Criteria related to the currency
of content and availability to be used when
needed or a measure of the time between
when data is expected versus made
available.
Timeliness assesses the statutory expectation for
when data will be made available for reporting
versus when the data has actually been made
available.
 Summary – Alignment Areas
5.1.1 USAspending.gov (Alignment Areas)
In addition to identifying potential gaps in data requirements not meeting transparency thresholds
under the CARES Act statute, MITRE identified specific areas of effective data collection,
reporting, and publishing as exemplars. These current areas validate a positive correlation of

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information between USAspending.gov and the CARES Act transparency requirements, from
guidance, collection and reporting, and accessibility of the data to the public. The data serves as
a solid foundation from which to source information and provide transparency in COVID-19-
related spending.
OMB Guidance
To provide additional transparency in pandemic-related spending, OMB issued guidance to
federal agencies. OMB’s April 10, 2020 implementation guidance for supplemental funding
provided in response to COVID-19 acknowledged the opportunity to leverage existing data
reporting/publication and data quality measures to satisfy pandemic-related award transparency
requirements while adding new requirements to support COVID-19-specific spending
transparency. These include:
• Expanded use of the Disaster Emergency Fund Code (DEFC) to track COVID-19
Supplemental Funding
• Requirement to report monthly and outlay reporting at the award level
• Requirement to use the National Interest Act (NIA) code to allow for consistent and clear
tracking of COVID-19 procurement actions
• Reminder to agencies to apply existing data quality procedures to identify and assess data
quality risks
These requirements were broadly applied to all awards, regardless of funded amount, and
therefore offer insights into awards outside of the “large covered funds,” awards amounting to
more than $150,000. On June 10, 2020, to further clarify OMB M-20-21 requirements, OMB
issued “Frequently Asked Questions” on the CARES Act and its April 2020 implementation
guidance. OMB’s policy and reporting changes have provided critical insights into federal
spending transparency, allowing the public to not only easily identify awards associated with
COVID-19-related efforts but also view award-level outlays.
In addition to OMB M-20-21 and accompanying FAQs, OMB issued both a Controller Alert to
Chief Financial Officers and procurement-specific guidance to the federal agencies to improve
the quality of “award description” information on USAspending.gov. Specifically, for financial-
assistance awards, OMB directed agencies to provide information regarding purpose of the
award, deliverable, and intended recipient or beneficiary.12 Similarly, OMB directed agencies to
provide “succinct and clear award descriptions” for procurement awards.13 OMB direction to
federal agencies was intended to improve the transparency of pandemic-related spending.
Prime Award Data: Collection and Reporting from Authoritative Sources
Based on the Treasury USAspending.gov data model and data schema, federal prime-award data
is sourced from agency financial management systems, agency financial assistance systems of
record (e.g., agency grants management systems), and agency procurement systems, which feed
into the FPDS. These authoritative sources serve as the basis of the federal government’s legal

12 OMB Controller Alert (August 2020)
13 OMB, Email from Lesley Fields to Federal Procurement Community (August 10, 2020)

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funding obligations and can be reasonably relied on to provide accurate data regarding federal
award spending.
Publication of Data
USAspending.gov data is highly accessible. Raw data published by USAspending.gov is
accessible via searching and exporting or via the download center or API. A complete database
of USAspending.gov is also available. Finally, the submitted files from the agencies are
available. In addition, data offered on USAspending.gov, such as entity information, provides the
foundation for further inquiry, especially when integrated with other publicly available data sets.
5.1.2 Small Business Administration Paycheck Protection Program
SBA PPP has collected and independently publishes its award-level data regarding the PPP. The
data published includes some foundational information regarding the recipient, such as name and
address for loans greater than $150,000. The data provides a high-level understanding of where
the loans were applied, geographical and industry, and what lenders provided the loans.
5.1.3 Department of Treasury Coronavirus Relief Fund
While data was not available at the time of analysis, MITRE reviewed the data validation rules
as defined in GrantSolutions’ “Treasury OIG & PRAC Financial Reporting OLDC Form: Prime
Recipient User Guide” (August 20, 2020). The analysis identified strong validation rules and
control processes for most of the data, which should result in a highly complete and accurate data
set. Examples include validation of grantees and Data Universal Numbering System (Dun and
Bradstreet) (DUNS) numbers, and addresses and location information. Further, the system uses a
highly structured workflow comprising user certifications, reviews, and approvals. That structure
would seem to produce a higher quality of financial reported data, given the number of “eyes” in
the review of each record and the attestations enforced.
 Summary – Gaps
Improving the quality of the data remains a steadfast and high-priority challenge for the federal
government. Evidence of lower standards of data quality (measured by completeness, accuracy,
and timeliness) represents gaps in transparency that must be addressed to meet the sufficient
transparency requirements mandated under the CARES Act.
The statutory analysis and supporting data quality analysis indicate areas that are potential
existing gap collection that may degrade the transparency of data reported under the CARES
Act:
Insufficient information describing the purpose of the award
OMB provided additional guidance in August 2020 to agencies regarding how to improve the
award descriptions. A quantitative analysis reviewing length of the completed elements and a
subjective review of the contents indicate that at the time of the analysis, there was not a relevant

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improvement in the quality of the information. There was still a significant use of abbreviations
and program-level descriptions that do not aid in the understanding of the purpose of the award.
Lack of loan information
DAIMS and, as a result, USAspending.gov, support some loan-specific information at the prime-
award level: face value of the loan, original loan subsidy, and total loan cost. Other loan
information elements, such as terms and conditions and default status, would increase the
transparency of executed loans. This information, as well as other data, may be available directly
from the awarding agency. No information is captured for first-tier loan subaward reports.
SBA PPP data publishes individual loan award information associated with “loan ranges,” and
not specific loan amounts for loans more than $150,000. While specific loan amounts are listed
for amounts less than $150,000, loan recipients are not listed for those loans.
No Second- to N-tier award information
Data is collected for the first-tier subawards, but no information is collected or reported at
subsequent n-tier subawards. CARES Act Section 15011 states [3]:
“detailed information on any level of subcontracts or subgrants awarded by the covered
recipient or its subcontractors or subgrantees, to include the data elements required to
comply with the Federal Funding Accountability and Transparency Act of 2006 (31 U.S.C.
6101 note) (FFATA) allowing aggregate reporting on awards below $50,000 or to
individuals, as pre-scribed by the Director of the Office of Management and Budget.”
The requirement for collection of the n-tier data is subject to the interpretation of “any.” If
interpreted that “any” implies all levels, then this data is required to be collected. If “any” is
interpreted to be only first-tier subaward reporting, consistent with requirements for reporting
pursuant to FFATA, then the existing collection of first-tier only meets the intent of the statute.
No First-tier awards outlay information
Information regarding subaward expenditures is not collected or reported. Collecting and
reporting subaward outlay information would provide transparency into the use of funds by the
contractors and subgrantees to help ensure proper use. It is unclear, however, whether these
subaward outlays are considered required information to satisfy the CARES Act transparency
requirements under Section 15011.
No information about jobs created or retained by award
USAspending.gov does not provide data regarding jobs created or retained by award, as required
under the CARES Act, by award. While SBA PPP data includes a “job” data element, it is
unclear what this data element represents.
Each of the identified gaps, proposed options to remedy said gaps, and the potential impacts are
further explored in Section 7.
 USAspending.gov
Improving the quality of data has been an OMB focus [19]for tracking federal spending under
the FFATA (as amended in 2010) and was strengthened through the DATA Act of 2014.

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Pursuant to the DATA Act, the Executive Branch established government-wide data standards
for spending information that agencies report to Treasury, OMB, and GSA and mandated the
publishing of federal spending data to public consumption through USAspending.gov.
Figure 5-1. Data Quality Process Flow for USAspending.gov shows the high-level process flow
used in the analysis of USAspending.gov quality assessment.

Figure 5-1. Data Quality Process Flow for USAspending.gov
5.3.1 Data Sources and Data Elements
Data sources reviewed for USAspending.gov:
• USASpending.gov award search extracts
• HHS TAGGS extracts
Data elements reviewed for USAspending.gov:
• North American Industry
Classification System (NAICS) Code
• Recipient Location – State
• Place of Performance Location –
State
• Recipient Congressional District
• Place of Performance Congressional
District
• Entity Name
• Number of Employees
• DUNS Number
• Compensated Employee Name
• Compensated Employee Amount
• Award
• DEFC

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• Catalog of Domestic Financial
Assistance
• NIA Code
• Award Type
• Product or Service Code (PSC)
• Award Description
• Award ID
• Awarding Agency
• SubAward/subcontract
• n-tier subaward/subcontract
• Obligated Amount
• Progress
• Expended Amount
• Progress reports
• Recipient zip code
• Primary-place-of-performance zip
code
5.3.2 Completeness
The statutory analysis identified elements in the USAspending.gov schema that aligned with the
statutory requirements. An analysis of the rate of population for those elements was completed
using files extracted from USAspending.gov. The completion rate was fairly complete with only
a few elements not 100 percent completed and the majority of those with a low incomplete rate
(as show in Table 5-2. USAspending.gov Data Element Completion Rate).
Table 5-2. USAspending.gov Data Element Completion Rate
ID
Data Element
Completion Rate
1
Recipient Location – State
Highly collected and reported (contract transactions <1% blank;
assistance transaction < 4% blank- based on city)
2
Place of Performance
Location – State
Contracts transactions: < 10% blank
Assistance transactions: < 0.25% blank
3
Recipient Congressional
District
Contracts transactions: <5% blank
assistance transactions: < 0.03 % blank
4
Place of Performance
Congressional District
Contracts transactions: <10% blank
assistance transactions: < 0.25% blank
5
Number of Employees
Not Collected
6
Compensated Employee
Name
<15% reported by USAspending.gov in transaction query at prime
level*
7
Compensated employee
Amount
<15% reported by USAspending.gov in transaction query at prime
level*
8
NIA Code
Approximately 44% populated in prime transactions; 55% in
prime summary
*Data is self-reported by the prime recipient.
In addition, MITRE conducted an analysis on data validation rules, because agencies are
required to report within the Government-wide Treasury Account Symbol Adjusted Trial
Balance System (GTAS) an attribute called a DEFC that classifies funding as non-emergency or

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non-disaster-designated appropriations, or with a unique DEFC value that OMB provides for
other specific appropriation act and designation.
These submissions include summary financial data ("File A"), obligation and outlay data by
program activity and budget object class ("File B"), and summary award-level obligation data
("File C"). Monthly submissions of Files A, B, and C flow through the DATA Act broker to
populate USAspending.gov. Field-level validations in Files A, B, and C are performed by the
DATA Act broker.
MITRE reviewed and extracted the validation rules for DATA Act submissions and mapped the
data elements from USAspending.gov.
Please reference Mapping of Data Validation Rules to USAspending.gov Data Elements for the
detailed mapping analysis.
5.3.3 Accuracy
Prime Grants Award Data
Accuracy of data is often best assessed by comparing data sets representing the same information
published from different sources. According to the DAMA Guide to the Data Management Body
of Knowledge [20]:
Data accuracy refers to the degree that data correctly represents the “real-life” entities
they model. In many cases, measure accuracy by how the values agree with an identified
reference source of correct information, such as comparing values against a database of
record or a similar corroborative set of data values from another table, checking against
dynamically computed values, or perhaps applying a manual process to check value
accuracy.”
Leveraging this best practice, MITRE evaluated the consistency of selected HHS pandemic-
related grants prime-award data on USAspending.gov with the HHS TAGGS. Within TAGGS,
spending is coded as part of COVID-19-related grants with the following Appropriation Code (as
referenced in Table 5-3. HHS TAGGS Appropriation Codes).
Table 5-3. HHS TAGGS Appropriation Codes
Appropriation
Code
Description
CV
Emergency Supplemental Appropriation Funding Act:
Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020
C2
Emergency Supplemental Appropriation Funding Act:
Families First Coronavirus Response Act
C3
Emergency Supplemental Appropriation Funding Act:
CARES Act (Coronavirus Aid, Relief, and Economic Security Act)
C4
Emergency Supplemental Appropriation Funding Act:
Paycheck Protection Program and Health Care Enhancement Act

The element in USAspending.gov used to identify COVID-19-related spending is DEFC (as
shown in Table 5-4. USAspending.gov COVID-19 DEFC Codes, below).

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Table 5-4. USAspending.gov COVID-19 DEFC Codes
DEFC
Description
L
Coronavirus Preparedness and Responses Appropriations Act, 2020; Emergency
Public Law 116-123 Coronavirus Preparedness and Response Supplemental
Appropriations Act, 2020
Emergency Public Law 116-123 Coronavirus Preparedness and Response
Supplemental Appropriations Act, 2020
Emergency Public Law 116-123 Coronavirus Preparedness and Response
Supplemental Appropriations Act, 2020
Emergency Public Law 116-123 Coronavirus Preparedness and Response
Supplemental Appropriations Act, 2020
Emergency Public Law 116-123
M
Families First Coronavirus Response Act, Emergency Public Law 116-127
N
Coronavirus Aid, Relief Economic Security Act (CARES Act); Emergency Public
Law 116-136
O
Coronavirus Aid, Relief Economic Security Act (CARES Act); Non-Emergency
Public Law 116-136
Paycheck Protection Program and Healthcare Enhancement Act; Non-Emergency
Public Law 116-139
P
Paycheck Protection Program and Healthcare Enhancement Act; Emergency Public
Law 116-139

An extract was created from TAGGS that contained grant information associated with the
CARES Act, Appropriation Code = C3. A corresponding extract was created from
USAspending.gov that contained grants reported from the HHS that were coded as part of the
CARES Act (DEFC = “N” or “O”). In this Level 2 comparative assessment, it would be expected
that these extracts should be equivalent in the grants reported.
The process depicted in Figure 5-2 was followed while completing this analysis.

Figure 5-2. HHS and USAspending.gov Comparison Process

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MITRE compared the following TAGGS data with similar data elements on USAspending.gov
to determine consistency between the two data sets:14
• Award Number
• Action Date
• City
• State
• Approp Code
The results of this analysis show a generally high consistency between HHS’ TAGGS and
USAspending.gov data for HHS prime grants awards. While the one possible exception is in the
30 percent of the records in TAGGS that had award amounts that did not match the amount in
USAspending.gov, this discrepancy can possibly be due to timing or other factors. Additional
analysis could help identify whether and the extent of this inconsistency as an issue. Based on
the overall consistency between HHS TAGGS data and USAspending.gov, MITRE concludes
that USAspending.gov, with relative accuracy, reflects the HHS COVID-19-related awards
based on review of HHS TAGGS. The details of this analysis are shown in  source files to assess
data quality are listed in the table below.
Prime Awards “Award Description”
In August of 2020, OMB issued both its Controller Alert and correspondence to the federal
procurement community to provide guidance on how to create a meaningful project description.
Based on the timing of August 2020 guidance and reporting cycle timelines, MITRE determined
the earliest data that can implement this guidance was September 2020. A review of award
descriptions was performed to assess whether the usability of the field was improved.
Review of the “award description” data field reported for pandemic-related prime award found
that a preponderance of such fields included acronyms and minimal words to describe the award.
As an example, MITRE performed a query of the “award description” data element and found a
significant number of descriptions contained acronyms, content that does not support the
outcome of providing information about the purpose of the award, in accordance with OMB’s
Controller Alert.
Based on MITRE’s assessment of the pandemic-related “award description” data reported in
USAspending.gov, current “award descriptions” do not adequately describe the intent of the
award. Comparing the counts between the two timeframes, it does not appear as if, for this
agency, changes have been implemented.
First-Tier SubAward Data
MITRE did not conduct an accuracy assessment of subaward data, given that it did not have an
authoritative or comparable source on which to base such an assessment.

14 It should be noted that the granularity of information from the TAGGS extract only contains 11 elements and not congressional
district. Further, the TAGGS data element “award amount” provides summary- level information, rendering it useful for
comparison from a high-level transparency level but not at a detailed or subaward level.

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5.3.4 Timeliness
Under Section 15011 (b)(1)(A) of the CARES Act, each agency is required to provide obligation
or expenditure data of large covered funds on a monthly basis. Further, Section 15011 (b)(2) and
(b)(3) provide that award-level data must be provided no later than 10 days after the end of each
calendar quarter, and within 30 days after the end of the calendar quarter, such information shall
be made publicly available.

Figure 5-3. CRF Reporting Times
In light of the CARES Act statutory requirements for timely reporting, MITRE evaluated the
extent to which USAspending.gov data is published within the requisite CARES Act timeframes
for spending transparency. As of October 9, 2020, MITRE reviewed available files to include
September 2020 DATA Act agency submission files, the most current agency files available, in
addition to current subaward documentation. Based on review of USAspending.gov
documentation, USAspending.gov requires and publishes monthly agency financial data, bi-
weekly finance assistance prime-award data, daily procurement award data, and monthly first-
tier subaward data.
While data is required to be reported within a timeframe that meets the CARES Act
requirements, MITRE notes that USAspending.gov does not provide a time stamp to identify
when information was last updated. Further, there does not appear to be an indicator of whether
downloaded files have been updated or replaced.
 Small Business Administration Paycheck Protection Program
In addition to USAspending.gov data, a second source of publicly available data that may be
leveraged to provide transparency in pandemic-related federal spending is the SBA’s PPP.
Where SBA PPP loans are not reported on USAspending.gov but instead made available on
SBA’s website, MITRE assessed the extent to which this data could be used to satisfy CARES
Act transparency requirements.

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MITRE analyzed the two SBA PPP data sets (loans less than $150,000; loans more than
$150,000) made available on the Treasury website.15 Figure 5-4. Data Quality Analysis Process
for SBA PPP  below illustrates MITRE’s approach to assess PPP data quality.

Figure 5-4. Data Quality Analysis Process for SBA PPP Data
5.4.1 Data Sources and Data Elements
MITRE reviewed the following data sources to assess the quality of SBA PPP data:
• SBA published extracts of $150,000 or more in PPP loans
• SBA published extracts of less than $150,000 in PPP loans
With respect to the specific SBA PPP data sets, MITRE reviewed the following data elements:

15 https://home.treasury.gov/policy-issues/cares-act/assistance-for-small-businesses/sba-paycheck-protection-program-loan-level-
data

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• LoanRange
• BusinessName
• Address
• City
• State
• Zip
• NAICSCode
• BusinessType
• RaceEthnicity
• Gender
• Veteran
• NonProfit
• JobsReported
• DateApproved
• Lender
• CD
Note that demographic data (e.g., race/ethnicity, gender, business type) are not explicitly
required under Section 15011 of the CARES Act. Nevertheless, given the small number of data
elements included in the SBA PPP data sets, MITRE analyzed all data.
5.4.2 Completeness
MITRE conducted an analysis of the completeness of SBA PPP data. The full results of this
analysis are represented in Appendix B, Tables 21-24, which present detailed, element-level
findings for PPP loans both more than and less than $150,000. Where SBA PPP loans less than
$150,000 were published by individual state, MITRE merged this data into a single file to
facilitate efficient analysis.
Recipient Information
In general, for loans greater than $150,000, SBA PPP data regarding recipient information
(name, address) had near 100 percent completeness rates. For loans less than $150,000, SBA did
not publish data regarding recipient name or full address (only state is provided).
Separately, while not explicitly required by the CARES Act, MITRE notes that demographic
information of awards was not as well-populated:
• For loans greater than $150,000, the following elements have a significant null or blank
rate:
Characteristic
Rate of Blank/Unanswered
RaceEthnicity
85%
Gender
71%
Veteran
79%
NonProfit
94%

• For loans less than$150,000 the following elements have a significant null or blank rate:
Characteristic
Rate of Blank/Unanswered
RaceEthnicity
90%
Gender
80%

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Characteristic
Rate of Blank/Unanswered
Veteran
86%
NonProfit
97%
Obligation/Loan amount and outlay information
SBA PPP data does not provide specific loan-amount information for loans more than $150,000.
Instead, it provides a “loan range” for each award. Loans less than $150,000 do provide loan
amount. Further, it is uncertain whether the reporting of “outlays” is satisfied. The data sets did
not provide any insights into whether and when PPP loans were forgiven, which would
constitute, in spirit, an outlay of funds.
5.4.3 Accuracy
MITRE could not obtain a publicly available authoritative data source to conduct a Level 2
accuracy assessment of loan amounts. Further, for recipient-specific data, because a unique
recipient identifier was not published, only a recipient name, no analysis of the accuracy of the
recipient name, as compared with other associated information, could be performed.
For the aforementioned reasons, MITRE limited its accuracy assessment to the data elements as
provided below.
Loan Amounts
MITRE found that SBA PPP data did not include specific loan amounts. Instead, each loan
award was associated with a “loan range,” as noted below:
Table 5-5. SBA PPP Loan Ranges
Loan Range
Count
$5-10 million

4,734
$2-5 million

24,248
$1-2 million

53,218
$350,000-1 million

199,679
$150,000-350,000

380,636

The lack of specific loan obligations and outlays was a significant gap in SBA PPP loan data.
Geographic Location: Zip Code
MITRE performed a comparative analysis of SBA PPP data related to geographic location (zip
code) with the U.S. Postal Service (USPS) zip codes.
Loans with a value more than $150,000 showed the following findings:
• 29 potentially invalid zip codes found in a total of 29 records
• 111 potentially mismatched zip code to state code found in a total of 500 records

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Loans with a value less than $150,000 showed the following findings:
• 309 potentially invalid zip codes found in a total of 4,840 records
• 740 potentially mismatched zip code to state code found in a total of 5,364 records
Geographic Location: Congressional District
For the data sets of loans both less than and greater than $150,000, MITRE found congressional
districts that did not match the corresponding state code. In some cases, through a subjective
human review, there appear to be cities that matched the state in the congressional district but not
the state code. For example:
Table 5-6. Example Congressional District to Geographic Location Mapping
City
State
Zip
CD
TUCSON
AK
85711
AZ-02
ANCHORAGE
AK
99507
TX-15
MOBILE
AK
36608
AL-01
SAN JOSE
AL
95125
CA-19

MITRE could not find publicly available data validation rules for the published SBA.gov PPP
data. The “Paycheck Protection Program (PPP) Loan Data – Key Aspects – Updated August 20,
2020” [21] document provides some high-level insight:
• “SBA made no changes to the numbers provided by lenders in the “JobsReported”
column.
• The lender then reviews the borrower’s application, and if all the paperwork is in order,
approves the loan and submits the information to SBA.
• All PPP loans are subject to SBA review, and all loans over $2 million will automatically
be reviewed.
• Eligibility and compliance will be reviewed during the loan-forgiveness process.
• The public PPP data includes only active loans.
• PPP loan data reflects the information submitted by lenders to the SBA for PPP loans.
Approximately 75 percent of all PPP loans did not include any demographic information
at the time of loan application. The loan forgiveness application expressly requests
demographic information for borrowers so that SBA can better understand which small
businesses are benefiting from PPP loans.
This information seems to indicate that the federated process is dependent on the lenders for data
validation prior to submission to SBA, until such time as loan forgiveness. Receipt of data
validation rules and processes would allow for more detailed analysis on sufficiency.
5.4.4 Timeliness
Under Section 15011 (b)(1)(A) of the CARES Act, each agency is required to provide obligation
or expenditure data of large covered funds on a monthly basis. Further, Section 15011 (b)(2) and

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(b)(3) provide that award-level data must be provided no later than 10 days after the end of each
calendar quarter, and within 30 days after the end of the calendar quarter, such information shall
be made publicly available.
As of October 9, 2020, the data available on the SBA website is stated as being through August
8, 2020. Based on MITRE’s analysis, SBA PPP data available meets the CARES Act reporting
timeframes. However, MITRE notes that SBA has not publicly established a cadence for
publishing future data sets.
 Department of Treasury Coronavirus Relief Fund
The Treasury OIG determined that, for the purposes of the CRF, it would require specific
information to be reported and then made publicly available. Summary information is available
on the Treasury website to satisfy interim reporting of expenditures through June 30, 2020.
While MITRE did not review specific award-level transaction data, MITRE’s review of Treasury
OIG recipient reporting requirements found that reporting requirements largely aligned to a
preponderance of CARES Act transparency requirements pursuant to Section 15011. Per OIG
memo OIG-CA-20-021: “Coronavirus Relief Fund Reporting and Record Retention
Requirements,” the Treasury OIG established the following interim reporting requirements [22]:
• Total amount of payments from the CRF received from Treasury
• Amount of funds received that were expended or obligated for each project or activity
• Detailed list of all projects or activities for which funds were expended or obligated,
including the name of the project or activity and a description of the project or activity
• Detailed information on any loans issued, contracts and grants awarded, transfers made to
other government entities, and direct payments greater than $50,000 made by the
recipient
• Amount spent on payroll for public health and safety of employees
• Amount spent on budgeted personnel and services diverted to a substantially different use
• Amount spent to improve telework capabilities of public employees
• Amount spent on medical expenses
• Amount spent on public health expenses
• Amount spent to facilitate distance learning
• Amount spent providing economic support
• Amount spent on expenses associated with the issuance of tax anticipation notes
• Amount spent on items not listed above
This information is to be reported to the GrantSolutions reporting portal and will be subject to
validation rules.
It should be noted that Treasury OIG issued memo OIG-CA-20-025 on July 31, 2020 which
identified the following expenditure categories prime recipient must use to identify obligations
and expenditures [23]:

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• Administrative Expenses
• Budgeted Personnel and Services Diverted to a Substantially Different Use
• COVID-19 Testing and Contact Tracing
• Economic Support (Other than Small Business, Housing, and Food Assistance)
• Expenses Associated with the Issuance of Tax Anticipation Notes
• Facilitating Distance Learning
• Food Programs
• Housing Support
• Improve Telework Capabilities of Public Employees
• Medical Expenses
• Nursing Home Assistance
• Payroll for Public Health and Safety Employees
• Personal protective Equipment
• Public Health Expenses
• Small Business Assistance
• Unemployment Benefits
• Worker’s Compensation
• Items Not Listed Above – to include other eligible expenses that are not captured n the
available expenditure categories
5.5.1 Data Sources and Data Elements
MITRE reviewed the following materials to assess the sufficiency of Treasury CRF to meet
CARES Act transparency requirements:
• Validation Rules spreadsheet
• GrantSolutions.gov
• “Treasury OIG & PRAC Financial Reporting OLDC Form: Prime Recipient User Guide”
To conduct its analysis, MITRE evaluated the types of controls, as described in the
GrantSolutions’ “Treasury OIG & PRAC Financial Reporting OLDC Form: Prime Recipient
User Guide” (August 20, 2020).
Overall, Treasury’s OLDC solution appears to be a structured, web-based information system
that guides users through the process of data capture, validation, certification (i.e., with
electronic signature for accountability), and final approval. Only registered users may enter the
data and perform subsequent reviews and approvals. Important contextual organizational data,
such as grantees and the funding sub-recipients (e.g., borrowers), are validated using reference
lists, and in the case of prime recipients, DUNS numbers are validated in real-time against

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SAM.gov, and addresses are validated against USPS data. By validating the address, the
quality of locational data should be high, because presumably only valid state, city, zip, and
congressional district information would be populated. It would seem, but has not been verified,
that it is up to the prime recipient who prepares the report data to ensure the quality of what has
been reported, including the allocations to recipients and the total dollars indicated. Evidence
was not provided that the solution validates the dollars reports are in sync with granted and
expended amounts. However, because multiple “layers” of review, certification, and
approval of those amounts (including obligations and expenditures) exist, the data should
be complete and accurate. Further, other contextual data use standardized lists for organization
type, payment method, loan category, and expenditure category as examples that should be
validated through other data sources to ensure their accuracy instead of human inspection.
An area of data that poses a data-quality concern is the concept of “projects.” The user is
expected to define one or more projects for the use of funds referenced throughout the system to
characterize obligations and expenditures. Furthermore, a project can be entered as “No
Assigned Project,” which suggests the possibility of skirting that data capture altogether. It is
important to better understand the use of project data across the data set, as it may serve mostly
as an aid to the recipients for organizing their use of funds, versus a way to characterize data
across recipients. Thus, the quality of that data could be low, given its intended use. However,
because the concept of project, defined as “a grouping of related activities that together are
intended to achieve a specific goal (e.g., building a temporary medical facility, offering an
economic support program for small businesses, offering a housing support program)” could
have analytical value across the data set, it should be further evaluated.
Another area of data quality concern is the type of issuance to a sub-recipient, including contract,
grant, loan, direct payment, or transfer. It would seem this is an important data element to be
accurate so that proper reporting can be made. Based on Treasury OIG’s validation rules, internal
controls exist to determine the completeness of the data.
Summary information is available on the Treasury website for interim reporting. The interim
reports indicate the data for the first detailed reporting will be available in November 2020.
5.5.2 Accuracy
As previously discussed, CRF data is not publicly available or available to MITRE, therefore
MITRE did not perform an assessment of the accuracy of specific data elements or controls.
5.5.3 Timeliness
Under Section 15011 (b)(1)(A) of the CARES Act, each agency is required to provide obligation
or expenditure data of large covered funds on a monthly basis. Further, Section 15011 (b)(2) and
(b)(3) provide that award-level data must be provided no later than 10 days after the end of each
calendar quarter, and within 30 days after the end of the calendar quarter, such information shall
be made publicly available.
Pursuant to Treasury requirements, CRF data was due to be reported by recipients by September
21, 2020 to the GrantSolutions portal. After the initial reporting, data will be due 10 days after
the close of the quarter.

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Recipients are required to initially report to the Department of Treasury for Coronavirus Relief
Fund for the time period of March 1, 2020 to September 30, 2020. After this, reporting is
required 10 days after the end of each calendar quarter. The reporting schedule is shown in Table
5-7. CRF Reporting Timeline below.
Table 5-7. CRF Reporting Timeline
Reporting Timeline
Reporting Cycle
Reporting Period
Reporting Due Date
OIG Review Period
Data Extract to
PRAC
Cycle 1
3/1 – 06/30/2020
09/21/2020
09/22 – 09/29/2020
09/30/2020
Cycle 2
7/1 – 09/30/2020
10/31/2020
10/14 – 10/20/2020
10/21/2020
Cycle 3
10/1 – 12/31/2020
01/11/2021
01/12 – 01/20/2021
01/21/2021
Cycle 4
1/1 – 03/31/2021
04/12/2021
04/13 – 04/20/2021
04/21/2021
Cycle 5
4/1 – 06/30/2021
07/12/2021
07/13 – 07/20/2021
07/21/2021
Cycle 6
7/1 – 09/30/2021
10/12/2021
10/13 – 10/20/2021
10/21/2021

At the time of this analysis the initial reporting period has closed. While data may have been
provided to the PRAC, it was not yet publicly available to analyze for this assessment.

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Report of Alignment and Gaps

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6-1
 Options to Address Gaps
MITRE has assessed the impact on COVID-19 federal-spending transparency in three alternative scenarios determined by level of effort
and committed actions to resolve.
• Alternative 1 – Status Quo: Summarizes the data transparency issues that will continue to persist if no actions are implemented.
• Alternative 2 – Low System/Policy Changes: Summarizes the impact of low-level efforts to address data transparency issues.
• Alternative 3 – Complex System/Policy Changes: Summarizes the impact of high-level efforts and significant actions to address
data transparency issues.
Low system policy changes yield rapid results, with a relatively low level of effort on the part of stakeholders. Complex system/policy
changes, on the other hand, may require significant resources and entail an extended timeline.
The alternative scenarios and impacts are characterized in the following tables:
 Alternative 1 – Status Quo
Table 6-1. Alternative 1 – Status Quo
ID
Data Transparency Issue16
Impact on Data Transparency with No Action
1
No award-level source of data is available to estimate number of jobs created or
retained by the project or activity within USAspending.gov. The OMB has
represented that its source of data to compile this information is based on
programmatic level-information, not award-level data. Further, it is uncertain
whether this reporting requirement is satisfied for SBA PPP based on its “jobs”
data element.
There is no clear quantitative basis for jobs created and retained.
There is limited ability to determine the economic impact of COVID-19-related
funding.

16 Findings #7 and #8 may no longer apply, depending on the outcome of pending SBA litigation, Case 1:20-cv-01240-JEB, Documents 14 & 19 (August 18, 2020 and September 22,
2020).

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6-2
ID
Data Transparency Issue16
Impact on Data Transparency with No Action
2
USAspending.gov publishes federal spending at the procurement- and financial-
assistance award level. For large covered funds, the CARES Act requires
reporting of a “detailed list of all projects or activities” to include the name and
description of each project or activity. Unless reporting at the award level is
deemed sufficient, more information about projects and activities by financial
assistance and procurement award may need to be required.
This results in reduced public understanding of specific short and intermediate
impacts of financial assistance and procurement actions.
3
USAspending.gov provides first-tier subaward information for federal grants
and contracts. However, no first-tier subaward loan information is available on
USAspending.gov.
No transparency on loans’ subaward data.
4
Neither USAspending.gov, SBA PPP data, nor CRF data collection provide
transparency into subawards below the first-tier subaward level, similar to the
reporting requirements applied in the Recovery Act.
No transparency on how dollars are ultimately spent, down to the final recipient.
This would be important for prime awards that essentially pass through or in
instances where a substantial amount of spending is in the second tier and
below.
5
USAspending.gov does not provide subaward expenditure information.
No transparency on ultimate spending of federal dollars. The public will only
see that subawards have legal obligations, but it will remain unclear on whether
these obligations materialize in actual spending.
6
MITRE found that there were missing values of NIA code for federal
procurements on USAspending.gov.
No significant impact if this is not cured, where the DEFC may also be able to
sufficiently identify COVID-19-related procurement actions.
7
With respect to SBA’s PPP loans more than $150,000, SBA does not publish
specific loan amounts, instead publishing only a “loan range” for each loan
award. Further, neither PPP loan expenditures nor information regarding loan
forgiveness are published by SBA.
No transparency in specific financial data related to federal spending. Without
specific loan amount information, the public is unaware of how much was
awarded to any given recipient.
8
With respect to SBA’s PPP loans less than $150,000, SBA does not publish
identifying information about the recipients, including names or addresses.
No transparency in identifying information of recipients of federal spending in
the form of SBA PPP loans less than $150,000. Without specific identifying
information, the public is unaware of which recipients received SBA PPP loans.
9
The “award description” data elements continue to lack specificity about the
intent or purpose of the award. Award descriptions often provide brief titles in
the award description field or acronyms that fail to offer details regarding the
award. OMB’s August 2020 guidance to federal agencies intends to improve the
quality of this data, but such improvements have not yet manifested into
currently available USAspending.gov.
Continued lack of transparency into the award's purpose and the federal
agency's investment or procurement, by award. Current data within this data
field is too generic to provide sufficient understanding to the public.

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ID
Data Transparency Issue16
Impact on Data Transparency with No Action
10
MITRE sampled the HHS COVID-19-related federal grants awards in USA
spending.gov and compared it to HHS TAGGS data, finding a mismatch of
approximately 30% of the awards published. Further analysis is needed to
determine the extent that true accuracy and completeness issues exist.
Uncertainty of the accuracy of prime award data; however, where all
USAspending.gov data is certified by Senior Accountable Officials and internal
control/data quality measures established for this data, and given GAO and IG
audits that have identified improvement in data accuracy, this additional inquiry
may not be necessary.
11
MITRE identified mismatches between various location-related data elements
(e.g., zip code and congressional district) on USAspending.gov. and in SBA’s
PPP data.
If accuracy of the location data cannot be relied on, the geographic impact of
COVID-19 spending is unclear.
12
USAspending.gov publishes data regarding the top-five highly compensated
employees of an awardee. The “name” field does not allow for filtering of “first
name,” “middle name,” and “last name,” because it is unstructured. This may
impair the transparency of the top-five highly compensated executives of the
recipient organization.
Potential inability to execute data analytics on individuals associated with the
awarded work, to identify risks of fraud, waste, abuse.
13
MITRE was unable to conclude the accuracy of first-tier subaward data, based
on the data made available in USAspending.gov for the purposes of this
assessment.
If accuracy of subaward data cannot be confirmed, the data is not useful.
14
CRF detailed data was not available for the data quality analysis. In lieu of a
data quality analysis, MITRE reviewed the published validation rules and
GrantSolutions Prime Recipient User Guide. MITRE found the OLDC solution
provides a structured, web-based information system that guides users through
the process of data capture, validation, certification, and final approval along
with Treasury OIGs review, to ensure completion and accuracy. This review
indicates that the expected data quality of information provided would be high.
CRF has a validation plan and an approach for addressing data quality issues.
15
Pursuant to the FFATA, amended by the DATA Act, USAspending.gov
requires agencies and prime recipients to report awards and first-tier subawards
within 30 days of the award. The data model requires reporting that is more
frequent than required by the CARES Act.
Given the longstanding nature of the bi-weekly reporting requirement,
timeliness issues as the root of data quality concerns are minimal.
16
With respect to SBA’s PPP data, MITRE was unable to determine whether SBA
moving forward will report data on a quarterly basis, pursuant to the CARES
Act.
It is unclear what continued transparency will exist for SBA PPP data.
 Alternative 2 – Low/Moderate System/Policy Changes
Table 6-2 below highlights recommended actions that require a low/moderate-level of effort to remedy/cure identified findings.

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Report of Alignment and Gaps

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Table 6-2. Alternative 2 – Low/Moderate System/Policy Changes
ID
Data Transparency Issue
Actions and Level of Effort to Remedy – Low/Moderate
6
There were missing values of the NIA code for federal procurements on
USAspending.gov.
GSA and OMB assess and implement potential system modification to require
code with soft validation rules to maximize tagging with NIA codes, as
appropriate.
Treasury considers addition of soft validation rules to flag to agencies that NIA
codes have not been submitted for COVID-19-related funded procurements
(based on DEFC reporting).
7
With respect to SBA’s PPP loans more than $150,000, SBA does not publish
specific loan amounts, instead publishing only a “loan range” for each loan
award. Further, neither PPP loan expenditures nor information regarding loan
forgiveness are published by SBA.
SBA publishes individual loan amounts associated with loans more than
$150,000.
SBA publishes PPP loan expenditures and relevant information on loan
forgiveness, associated with each award more than $150,000.

8
With respect to SBA’s PPP loans less than $150,000, SBA does not publish
identifying information about the recipients, including names or addresses.
SBA publishes individual loan names or addresses associated with loans less
than $150,000.
9
The “award description” data elements continue to lack specificity about the
intent or purpose of the award. Award descriptions often provide brief titles in
the award description field or acronyms that fail to offer details regarding the
award. OMB’s August 2020 guidance to federal agencies intends to improve the
quality of this data, but such improvements have not yet manifested into
currently available USAspending.gov.
Federal awarding agencies incorporate additional specific internal controls to
their data quality plans to ensure enforcement of existing OMB guidance on
award descriptions for prime awards.
Treasury develops and implements approach (e.g., sampling, use of data
analytics) to determine extent to which award descriptions provide meaningful
descriptions to the public. The intent is to provide a data quality review to
determine if recipients are adhering to OMB’s August 2020 guidance.
Treasury and OMB (in concert with the federal awarding community) develop a
“transparency” dashboard to assess the level of transparency provided by prime-
award descriptions.
10
MITRE sampled the HHS COVID-19-related federal grants awards from
USAspending.gov and compared it to HHS TAGGS data, finding a mismatch of
approximately 30% of the awards published. Further analysis is needed to
determine the extent that true accuracy and completeness issues exist.
Further analysis is required.

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ID
Data Transparency Issue
Actions and Level of Effort to Remedy – Low/Moderate
14
CRF detailed data was not available for the data quality analysis. In lieu of a
data quality analysis, MITRE reviewed the published validation rules and
GrantSolutions Prime Recipient User Guide. MITRE found the OLDC solution
provides a structured, web-based information system that guides users through
the process of data capture, validation, certification, and final approval along
with Treasury OIGs review, to ensure completion and accuracy. This review
indicates that the expected data quality of information provided would be high.
Further analysis required.
15
Pursuant to the FFATA, amended by the DATA Act, USAspending.gov
requires agencies and prime recipients to report awards and first-tier subawards
within 30 days of the award. The data model requires reporting that is more
frequent than required by the CARES Act.
Further analysis required to review meta data to determine when files were
produced or modified.
For prime awards, Treasury displays dates of data submission to
USAspending.gov, alongside already-published award action dates. This will
allow for confirmation of whether award actions are submitted within the 30-
days period required.
16
With respect to SBA’s PPP data, MITRE was unable to determine whether SBA
moving forward will report data on a quarterly basis, pursuant to the CARES
Act.
PRAC engages with SBA to understand frequency of publication and recurring
release of information.

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Report of Alignment and Gaps

UNCLASSIFIED
6-6
 Alternative 3 – Complex System/Policy Changes
Table 6-3 below highlights recommended actions that require a high-level of effort to remedy/cure impacted findings.
Table 6-3. Alternative 3 – Complex System/Policy Changes
ID
Data Transparency Issue17
Actions and Level of Effort to Remedy – High
1
No award-level source of data is available to estimate number of jobs created or
retained by the project or activity within USAspending.gov. OMB has
represented that its source of data to compile this information is based on
programmatic-level information, not award-level data. Further, it is uncertain
whether this reporting requirement is satisfied for SBA PPP based on its “jobs”
data element.
For financial assistance awards, OMB issues guidance to federal awarding
agencies to collect this information from all prime recipients;
For financial assistance awards, GSA, in collaboration with OMB, modify
existing information collection requests, consistent with the Paperwork
Reduction Act, to require addition collection of award-level jobs data.
OMB/OIRA to provide approval of revised information collection request
pursuant to the Paperwork Reduction Act process (estimated 9-12 months);
For procurement awards, OMB and GSA, in concert with the federal
procurement community, determine whether government-wide changes in
FPDS are required to collect this information. Additional data may need to be
submitted to FPRS and if so, OMB and procurement agency guidance may need
to be issued guidance;
Federal awarding agencies develop and execute operationalization plan to
collect the data, including policy guidance, revisions to existing information
collection requests pursuant to the Paperwork Reduction Act, system changes,
outreach, training, and oversight of the data collected;
Treasury, in coordination with OMB, develops and executes implementation
strategy to modify data schema and ensure file structures allow for new data
elements and publish data;
Federal awarding agencies, with support from OMB and Treasury,
develop/execute training to prime recipients to ensure reporting of  timely,
accurate, and complete data.

17 Findings #7 and #8 may no longer apply, depending on the outcome of pending SBA litigation, Case 1:20-cv-01240-JEB, Documents 14 & 19 (August 18, 2020 and September 22,
2020).

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Report of Alignment and Gaps

UNCLASSIFIED
6-7
ID
Data Transparency Issue17
Actions and Level of Effort to Remedy – High
2
USAspending.gov publishes federal spending at the procurement- and financial-
assistance award level. For large covered funds, the CARES Act requires
reporting of a “detailed list of all projects or activities” to include the name and
description of each project or activity and associated financial information.
Unless reporting at the award level is deemed sufficient, more information
about projects and activities by financial assistance and procurement award may
need to be required.
OMB issues guidance to federal awarding agencies to collect this information
from all prime recipients OR prime recipients and for prime recipients to report
such information for any subawards, consistent with the approach taken by
Treasury OIG;
Treasury, in coordination with OMB, develops and executes implementation
strategy to modify data schema and ensure file structures allow for reporting of
information by project/activity and publish data;
Agencies develop and execute operationalization plan to collect the data,
including policy guidance, revisions to existing information collection requests
pursuant to the Paperwork Reduction Act, system changes, outreach, training,
and oversight of the data collected;
Federal awarding agencies, with support from OMB and Treasury,
develop/execute training to prime recipients to ensure reporting of  timely,
accurate, and complete data.

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
6-8
ID
Data Transparency Issue17
Actions and Level of Effort to Remedy – High
3
USAspending.gov provides first-tier subaward information for federal grants
and contracts. However, no first-tier subaward loan information is available on
USAspending.gov.
OMB issues guidance to federal awarding agencies to collect this subaward
information from all prime recipients;
GSA, in collaboration with OMB, modify existing information collection
requests, consistent with the Paperwork Reduction Act, to require addition
collection of first-tier loans subaward data. OMB/OIRA to provide approval of
revised information collection request pursuant to the Paperwork Reduction Act
process (estimated 9-12 months);
GSA, in coordination with OMB, develops and executes implementation
strategy to modify FSRS data schema and ensure file structures allow for
reporting of loan subaward information;
Treasury, in coordination with OMB and GSA, develops and executes
implementation strategy to modify data schema and transmission of GSA data
to Treasury and publish data;
Federal awarding agencies develop and execute operationalization plan to
collect the data, including policy guidance, revisions to existing information
collection requests pursuant to the Paperwork Reduction Act, system changes,
outreach, training, and oversight of the data collected;
Federal awarding agencies, with support from OMB and Treasury,
develop/execute training to prime recipients to ensure reporting of  timely,
accurate, and complete data.

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
6-9
ID
Data Transparency Issue17
Actions and Level of Effort to Remedy – High
4
Neither USAspending.gov, SBA PPP data, nor CRF data collection provide
transparency into subawards below the first-tier subaward level, similar to the
reporting requirements applied in the Recovery Act.
OMB issues guidance to federal awarding agencies to collect additional
subaward data;
GSA, in collaboration with OMB, modify existing information collection
requests, consistent with the Paperwork Reduction Act, to require addition
collection of additional subaward data. OMB/OIRA to provide approval of
revised information collection request pursuant to the Paperwork Reduction Act
process (estimated 9-12 months);
GSA, in coordination with OMB, develops and executes implementation
strategy to modify FSRS data schema and ensure file structures allow for
reporting of this subaward data;
 For procurement awards, OMB and GSA, in concert with the federal
procurement community, determine whether government-wide changes in
FPDS are required to collect this information. Additional data may need to be
submitted to FPRS and if so, OMB and procurement agency guidance may need
to be issued guidance;
Treasury, in coordination with OMB and GSA, develops and executes
implementation strategy to modify data schema and transmission of GSA data
to Treasury and publish data;
Federal awarding agencies develop and execute operationalization plan to
collect the data, including policy guidance, revisions to existing information
collection requests pursuant to the Paperwork Reduction Act, system changes,
outreach, training, and oversight of the data collected;
Federal awarding agencies, with support from OMB and Treasury,
develop/execute training to prime recipients to ensure reporting of  timely,
accurate, and complete data.

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Report of Alignment and Gaps

UNCLASSIFIED
6-10
ID
Data Transparency Issue17
Actions and Level of Effort to Remedy – High
5
USAspending.gov does not provide subaward expenditure information.
OMB issues guidance to federal awarding agencies to collect additional
subaward data;
GSA, in collaboration with OMB, modifies existing information collection
requests, consistent with the Paperwork Reduction Act, to require addition
collection of additional subaward data. OMB/Information and Regulatory
Affairs to provide approval of revised information collection request pursuant to
the Paperwork Reduction Act process (estimated 9-12 months);
GSA, in coordination with OMB, develops and executes implementation
strategy to modify FSRS data schema and ensure file structures allow for
reporting of this subaward data;
For procurement awards, OMB and GSA, in concert with the federal
procurement community, determine whether government-wide changes in
FPDS are required to collect this information. Additional data may need to be
submitted to FPRS and if so, OMB and procurement agency guidance may need
to be issued guidance;
Treasury, in coordination with OMB and GSA, develops and executes
implementation strategy to modify data schema and transmission of GSA data
to Treasury and publish data;
Federal awarding agencies develop and execute operationalization plan to
collect the data, including policy guidance, revisions to existing information
collection requests pursuant to the Paperwork Reduction Act, system changes,
outreach, training, and oversight of the data collected;
Federal awarding agencies, with support from OMB and Treasury,
develop/execute training to prime recipients to ensure reporting of  timely,
accurate, and complete data.

11
MITRE identified mismatches between various location-related data elements
(e.g. zip code and congressional district) on USAspending.gov and in SBA’s
PPP data.
Further analysis is required (many to many data relationships);
Treasury collaborates with Congress to publish historic congressional districts
to ensure accuracy of reporting;
PRAC confirms with SBA the validation checks of PPP data;
SBA conducts data quality review of congressional district data associated with
SBA PPP awards and determine whether additional validations are needed to
address data quality issues (potentially high level of effort - dependent of
complexity of business rules).

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Report of Alignment and Gaps

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6-11
ID
Data Transparency Issue17
Actions and Level of Effort to Remedy – High
12
USAspending.gov publishes data regarding the top five highly compensated
employees of an awardee. The “name” field does not allow for filtering of “first
name,” “middle name,” and “last name,” because it is unstructured. This may
impair the transparency of the top-five highly compensated executives of the
recipient organization.
Treasury implements systematic change to USAspending.gov database to
separate fields into granular fields and migrate data into fields;
Treasury, in collaboration with federal agencies and OMB, retroactively
corrects existing information after systematic change, as appropriate.
13
MITRE was unable to conclude the accuracy of first-tier subaward data, based
on the data made available for the purposes of this assessment.
OMB engages with federal awarding agencies to conduct performance reports
and sample FSRS data to enhance data quality framework by including
subaward reporting;
Based on results of the aforementioned work, PRAC engages with OMB to
determine whether the current approach for subaward reporting and internal
controls to address data quality issues is sufficient to meet transparency needs.

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 Summary of Analyses of Alternatives
Table 6-4. Summary of Analysis of Alternatives
ID
Data Transparency Issue18
Actions and Level of
Effort to Remedy
1
No award-level source of data is available to estimate number of jobs created or retained by the project or activity within
USAspending.gov or required for reporting under Treasury CRF. The OMB has represented that its source of data to compile this
information is based on programmatic level-information, not award-level data. Further, it is uncertain whether this reporting
requirement is satisfied for SBA PPP based on its “jobs” data element.
HIGH
2
USAspending.gov publishes federal spending at the procurement- and financial-assistance award level. For large covered funds, the
CARES Act requires reporting of a “detailed list of all projects or activities” to include the name and description of each project or
activity and associated financial information. Unless reporting at the award level is deemed sufficient, more information about
projects and activities by financial assistance and procurement award may need to be required.
HIGH
3
USAspending.gov provides first-tier subaward information for federal grants and contracts. However, no first-tier subaward loan
information is available on USAspending.gov.
HIGH
4
Neither USAspending.gov, SBA PPP data, nor CRF data collection provide transparency into subawards below the first-tier
subaward level, similar to the reporting requirements applied in the Recovery Act.
HIGH
5
USAspending.gov does not provide subaward expenditure information.
HIGH
6
There are missing values of the NIA code for federal procurements on USAspending.gov.
LOW/MODERATE
7
With respect to SBA’s PPP loans (more than $150,000), SBA does not publish specific loan amounts, instead publishing only a
“loan range” for each loan award. Further, neither PPP loan expenditures nor information regarding loan forgiveness are published
by SBA.
LOW/MODERATE
8
With respect to SBA’s PPP loans less than $150,000, SBA does not publish identifying information about the recipients, including
names or addresses.
LOW/MODERATE
9
The “award description” data elements continue to lack specificity about the intent or purpose of the award. Award descriptions
often provide brief titles in the award description field or acronyms that fail to offer details regarding the award. OMB’s August
2020 guidance to federal agencies intends to improve the quality of this data but such improvements have not yet manifested into
currently available USAspending.gov.
LOW/MODERATE

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ID
Data Transparency Issue18
Actions and Level of
Effort to Remedy
10
MITRE sampled the HHS COVID-19-related federal grants awards in USAspending.gov and compared it to HHS TAGGS data,
finding a mismatch of approximately 30% of the awards published. Further analysis is needed to determine the extent that true
accuracy and completeness issues exist.
LOW/MODERATE
11
MITRE identified mismatches between various location-related data elements (e.g., zip code and congressional district) on
USAspending.gov and in SBA’s PPP data.
HIGH
12
USAspending.gov publishes data regarding the top-five highly compensated employees of an awardee. The “name” field does not
allow for filtering of “first name,” “middle name,” and “last name,” because it is unstructured. This may impair the transparency of
the top-five highly compensated executives of the recipient organization.
HIGH
13
MITRE was unable to conclude the accuracy of first-tier subaward data, based on the data made available for the purposes of this
assessment.
HIGH
14
CRF detailed data was not available for the data quality analysis. In lieu of a data quality analysis, MITRE reviewed the published
validation rules and GrantSolutions Prime Recipient User Guide. MITRE found the OLDC solution provides a structured, web-based
information system that guides users through the process of data capture, validation, certification, and final approval along with
Treasury OIGs review, to ensure completion and  accuracy. This review indicates that the expected data quality of information
provided would be high.
LOW/MODERATE
15
Pursuant to the FFATA, amended by the DATA Act, USAspending.gov requires agencies and prime recipients to report awards and
first-tier subawards within  30 days of the award. The data model requires reporting that is more frequent than required by the
CARES Act.
LOW/MODERATE
16
With respect to SBA’s PPP data, MITRE was unable to determine whether SBA moving forward will report data on a quarterly
basis, pursuant to the CARES Act.
LOW/MODERATE

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Report of Alignment and Gaps

UNCLASSIFIED
7-1
 Bibliography

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United States 116th Congress, "CORONAVIRUS PREPAREDNESS AND RESPONSE
SUPPLEMENTAL APPROPRIATIONS," PUBLIC LAW 116–123, 2020.
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[4]
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[5]
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[6]
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[14]  United States Government Accountability Office, "Federal Data Transparency Effective
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Challenges and Improve Oversight," United States Government Accountability Office
(GAO -15-241T), 2014.
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[17]  M. E. Wooten, Information on COVID Contracting Descriptions, e-mail from Office of
Federal Procurement Policy, 2020.
[18]  Conformed Dimensions of Data Quality, "List of Conformed Dimensions of Data
Quality," [Online]. Available: http://dimensionsofdataquality.com/alldimensions.
[19]  Office of Management and Budget, "Memorandum M-19-23 Phase 1 Implementation of
the Foundations for Evidence-Based Policymaking Act of 2018: Leaming Agendas,
Personnel, and Planning Guidance," Office of Management and Budget, Washington
D.C., 2019.
[20]  DAMA International, DAMA Data Management Body of Knowedge, S. E. L. S. Deborah
Henderson, Ed., Basking Ridge, NJ: Technics Publications, 2017.
[21]  U.S. Small Business Administration, "Paycheck Protection Program (PPP) Loan Data
Key Aspects," August 2020. [Online]. Available:
https://www.sba.gov/sites/default/files/2020-08/PPP%20Loan%20Data%20-
%20Key%20Aspects%2008212020-508.pdf. [Accessed September 2020].
[22]  Department of the Treasury, "Coronavirus Relief Fund Reporting and Record Retention,
OIG memo OIG-CA-20-021," 2 July 2020. [Online]. Available:
https://www.treasury.gov/about/organizational-
structure/ig/Audit%20Reports%20and%20Testimonies/OIG-CA-20-021.pdf.
[23]  Department of the Treasury; Richard K. Delmar, Deputy Inspector General, "U.S.
Department of the Treasury; Office of the Inspector General; MEMORANDUM FOR
CORONAVIRUS RELIEF FUND RECIPIENTS," 31 July 2020. [Online]. Available:
https://www.treasury.gov/about/organizational-
structure/ig/Audit%20Reports%20and%20Testimonies/OIG-CA-20-025.pdf. [Accessed
2020].

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
8-1
 References and Source Documentation

ID
Title / Name
Author
Date
Description
1
$454 Billion Treasury Fund Goes Mostly
Unused
Wall Street Journal
August 2020
Website Article
2
Accountability and Transparency
Template for the Future
Pandemic Response Accountability
Committee provided
 None
Document
3
Achieving Transparency and
Accountability in Federal Spending
Hearing before the Committee on
Oversight and Government Reform
House of Representatives One Hundred
Twelfth Congress
June 2011
Testimony
4
An Overview of Data Quality Frameworks
IEEEAccess
March 2019
Paper
5
Appendix A to OMB Circular No. A-123,
Management of Reporting and Data
Integrity Risk -– Memorandum 18-16
OMB
June 2018
Memorandum
6
CARES Act Flash Report • No. 2020-FIN-
037
OIG -– U.S. Department of the Interior
May 2020
Report
7
Coalition letter to OMB on COVID
Disclosure
Coalition
June 2020
Letter
8
Coalition letter to OMB on COVID
Disclosure
Coalition
June 2020
Letter
9
Congressional investigation finds over $1
billion in coronavirus aid fraud
NBC News
September 2020
Website Article
10
Controller Alert: Award Description Data
Quality for Financial Assistance Awards
PRAC provided
 August 2020
Document
11
Coronavirus Roundup: Watchdogs Report
on Safeguards Against Fraud in TRICARE
Payments, Contractor Reimbursements
Government Executive
September 2020
Article
12
COVID-19 EIDL Advance Report
Small Business Administration
July 2020
Report
13
COVID-19 Opportunities to Improve
Federal Response and Recovery Efforts
United States Government
Accountability Office -– Report to the
Congress (GAO-20-625)
June 2020
Report
14
COVID-19:
Federal Efforts Could Be Strengthened by
Timely and Concerted Actions
GAO -– Report to Congressional
Committees (GAO-20-701)
September 2020
Report
15
Data Act Reported Quality of Agencies’
Spending Data Reviewed by OIGs Varied
Because of Government-wide and Agency
Issues
GAO Report to Congressional
Addressees
July 2018
Report
16
Data Transparency Oversight Needed to
Address Underreporting and
Inconsistencies on Federal Award Website
GAO Report to Congressional
Requesters
June 2014
Report

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
8-2
ID
Title / Name
Author
Date
Description
17
Executive Office of the President, Office
of Management and Budget
Office of Federal Procurement Policy:
Office of Federal Financial
Management
September 2020
Interviews
18
Federal Data Transparency
Opportunities Remain to Incorporate
Recovery Act Lessons Learned
GAO Testimony Before the
Government Performance Task Force,
Committee on Budget, U.S. Senate
September 2013
Report
19
Federal Spending Accountability -–
Preserving Capabilities of Recovery
Operations Center Could Help Sustain
Oversight of Federal Expenditures
GAO -– Report to Congressional
Addressees
September 2015
Report
20
Flash Report Small Business
Administration's Implementation of the
Paycheck Protection Program
Requirements
SBA IG
May 2020
Report
21
Frequently Asked Questions:
USAspending.gov and Subaward
Reporting
Corporation for National & Community
Service
May 2019
Report
22
General Services Administration
Federal Acquisition Service Office of
Systems Management
September 2020
Interview
23
Guidance Regarding Identification and
Reporting of Suspicious Activity in the
COVID-19 EIDL Loan Program
SBA
July 2020
Information
Notice
24
Improving Federal Procurement Data
Quality -– Guidance for
Annual Verification and Validation
OMB
May 2011
Memorandum
25
Information on COVID Contracting
Descriptions
Michael E. Wooten, Administrator for
Federal Procurement Policy
August 2020
E-Mail
26
Interim Audit Update – Coronavirus Relief
Fund Recipient Reporting
OIG -– Department of Treasury
May 2020
Memorandum
27
Leveraging Data & Analytics and
Partnering with IGs to Prevent and Detect
Fraud in Pandemic Relief Spending
Concept Paper for the Fraud Data &
Analytics Center of Excellence PRAC
 None
Document
28
Managing Federal Contract Performance
Issues Associated with the Novel
Coronavirus (COVID-19)
OMB
March 2020
Memorandum
29
Non Data Act Reporters and Programs
PRAC provided
 None
MS Excel
Spreadsheet
30
Non Data Act Reporters FAQs
PRAC provided
 None
MS Excel
Spreadsheet
31
One Year Later: Examining the ongoing
recovery from hurricane sandy
Hearing before the Subcommittee on
Emergency Management,
Intergovernmental Relations, and the
District of Columbia of the Committee
on Homeland Security and
Governmental Affairs
November 2013
Testimony

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
8-3
ID
Title / Name
Author
Date
Description
32
Oversight In '‘Extraordinary Times'’: A
Q&A With the Executive Overseeing
Pandemic Spending
Government Executive
September 2020
Website Article
33
Pandemic Oversight
Pandemic Oversight
 August 2020
(Accessed)
Website
34
Pandemic Response Accountability
Committee
Ballotpedia
 August 2020
(Accessed)
Website Article
35
Pandemic Response Accountability
Committee
Ballotpedia
 August 2020
(Accessed)
Website Article
36
Pandemic Response Accountability
Committee Letter to Administrator
Carranza
Pandemic Response Accountability
Committee
August 2020
Letter
37
Pandemic Response Accountability
Committee Letter to Chairs, Vice-Chair,
and Ranking Members
Pandemic Response Accountability
Committee
June 2020
Letter
38
Pandemic Response Accountability
Committee
Various Stakeholders
August 2020;
September 2020
Interviews
39
Preliminary Analysis of Paycheck
Protection Program Data
Majority Staff
September 2020
Memorandum
40
Preserving the Resilience of the Federal
Contracting Base in the Fight Against the
Coronavirus Disease 2019 (COVID-19)
OMB
April 2020
Memorandum
41
President Trump Signs into Law the
Coronavirus Aid, Relief, and Economic
Security (CARES) Act
The National Law Review Article by
Katie P. Reed and Monica P. Schulteis
Greenberg Traurig, LLP
September 2020
Website Article
42
Recipient reported compared to FFATA
PRAC provided
 None
MS Excel
Spreadsheet
43
Reporting Challenges
PRAC provided
 None
Document
44
SBA Accused of Skirting Financial
Disclosure Rule
Wall Street Journal
August 2020
Website Article
45
Specific reporting for CARES Act
Division A programs
PRAC provided
June 2020
Document
46
The Honorable Carolyn B Maloney
Chairwomen Committee on Oversight and
Reform
Department of Treasury
July 2020
Letter
47
Transparency before American Recovery
and Reinvestment Act of 2009
PRAC provided
 None
Document
48
U.S. Small Business Administration P.L.
116-136 – Sec. 15010/15011 Plan for Use
of Covered Funds
SBA
 June 2020
Table
49
U.S. Department of Treasury
Various Stakeholders
September 2020
Interviews

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
8-4
ID
Title / Name
Author
Date
Description
50
USAspending.gov
USAspending.gov
September 24,
2020 (as of)
October 4, 2020
(as of)
Content

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
A-1

Mapping of Data Validation Rules to USAspending.gov Data
Elements
Table A-1 below maps the data elements MITRE reviewed from USAspending.gov to the validation rules found within the Excel
validation rules specification file.
Table A-1. Mapping of Data Validation Rules to USAspending.gov Data Elements
ID
Business Data Element
or Concept
Schema Data Label
Applicable
File(s)
Extracted Validation Rules
Severity
1
North American Industry
Classification System (NAICS)
NAICS
N/A
None found
N/A
2
Recipient Location – State
LegalEntityStateCode
N/A
None found
N/A
3
Place of Performance Location -
State
PrimaryPlaceOfPerformanceSt
ateCode
N/A
None found
N/A
4
Recipient Congressional District
LegalEntityCongressionalDistr
ict
FABS
FABS44.1 For foreign recipients (LegalEntityCountryCode
is not USA), LegalEntityCongressionalDistrict must be
blank.
Fatal Error
5
Recipient Congressional District
LegalEntityCongressionalDistr
ict
FABS
FABS44.2 For non-aggregate and personally identifiable
information (PII)-redacted non-aggregate records
(RecordType = 2 or 3) with domestic recipients
(LegalEntityCountryCode = USA): If LegalEntityZIPLast4 is
not provided and LegalEntityZIP5 is,
LegalEntityCongressionalDistrict must be provided.
Fatal Error
6
Recipient Congressional District
LegalEntityCongressionalDistr
ict
FABS
FABS44.3 If LegalEntityCongressionalDistrict is provided, it
must be valid in the state or territory indicated by
LegalEntityZIP5. Districts that were created under the 2000
census or later are considered valid for purposes of this rule.
Fatal Error
7
Recipient Congressional District
LegalEntityCongressionalDistr
ict
FABS
FABS44.4 LegalEntityCongressionalDistrict must be blank
for aggregate records (RecordType = 1).
Fatal Error

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
A-2
ID
Business Data Element
or Concept
Schema Data Label
Applicable
File(s)
Extracted Validation Rules
Severity
8
Place of Performance
Congressional District
PrimaryPlaceOfPerformanceC
ongressionalDistrict
FABS
FABS43.1 For foreign places of performance
(PrimaryPlaceOfPerformanceCountryCode is not USA),
PrimaryPlaceOfPerformanceCongressionalDistrict must be
blank.
Fatal Error
9
Place of Performance
Congressional District
PrimaryPlaceOfPerformanceC
ongressionalDistrict
FABS
FABS43.2 For aggregate and non-aggregate records
(RecordType = 1 or 2), with domestic place of performance
(PrimaryPlaceOfPerformanceCountryCode = USA): if 9-
digit PrimaryPlaceOfPerformanceZIP+4 is not provided,
PrimaryPlaceOfPerformanceCongressionalDistrict must be
provided.
Fatal Error
10
Place of Performance
Congressional District
PrimaryPlaceOfPerformanceC
ongressionalDistrict
FABS
FABS43.3
PrimaryPlaceOfPerformanceCongressionalDistrict must be
blank for PII-redacted non-aggregate records (RecordType =
3).
Fatal Error
11
Place of Performance
Congressional District
PrimaryPlaceOfPerformanceC
ongressionalDistrict
FABS
FABS43.4 If
PrimaryPlaceOfPerformanceCongressionalDistrict is
provided, it must be valid in the state or territory indicated by
the PrimaryPlaceOfPerformanceCode. Districts that were
created under the 2000 census or later are considered valid
for purposes of this rule.
Fatal Error
12
Entity Name
AwardeeOrRecipientLegalEnti
tyName
FABS
FABSREQ9 AwardeeOrRecipientLegalEntityName is
required for all submissions but was not provided in this row.
Fatal Error
13
Entity Name
AwardeeOrRecipientLegalEnti
tyName
FABS
FABS9.1 AwardeeOrRecipientLegalEntityName must
contain "MULTIPLE RECIPIENTS" for aggregate records
(RecordType = 1).
Fatal Error
14
Entity Name
AwardeeOrRecipientLegalEnti
tyName
FABS
FABS9.2 AwardeeOrRecipientLegalEntityName must
contain "REDACTED DUE TO PII" for PII-redacted non-
aggregate records (RecordType = 3).
Fatal Error
15
Number of Employees
N/A
N/A
None found
N/A

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
A-3
ID
Business Data Element
or Concept
Schema Data Label
Applicable
File(s)
Extracted Validation Rules
Severity
16
Data Universal Numbering
System (Dun and Bradstreet)
(DUNS)
AwardeeOrRecipientUniqueId
entifier
FABS
FABS31.1 AwardeeOrRecipientUniqueIdentifier Field must
be blank for aggregate and PII-redacted non-aggregate
records (RecordType = 1 or 3, regardless of the
BusinessTypes value) and individual recipients
(BusinessTypes includes 'P', regardless of the RecordType
value).
Fatal Error
17
DUNS
AwardeeOrRecipientUniqueId
entifier
FABS
FABS31.2 AwardeeOrRecipientUniqueIdentifier is required
for AssistanceType of 02, 03, 04, or 05 where ActionDate is
after October 1, 2010, unless the record is an aggregate or
PII-redacted non-aggregate record (RecordType = 1 or 3) or
individual recipient (BusinessTypes includes 'P').
Fatal Error
18
DUNS
AwardeeOrRecipientUniqueId
entifier
FABS
FABS31.3 When AwardeeOrRecipientUniqueIdentifier is
provided, it must be nine digits.
Fatal Error
19
DUNS
AwardeeOrRecipientUniqueId
entifier
FABS
FABS31.4 For AssistanceType of 02, 03, 04, or 05 whose
ActionDate is after October 1, 2010,
AwardeeOrRecipientUniqueIdentifier must be registered (not
necessarily active) in SAM, unless the record is an aggregate
or PII-redacted non-aggregate record (RecordType = 1 or 3)
or awarded to an individual recipient (BusinessTypes
includes 'P').
Fatal Error
20
DUNS
AwardeeOrRecipientUniqueId
entifier
FABS
FABS31.5 For AssistanceType of 02, 03, 04, or 05 whose
ActionDate is after October 1, 2010 and ActionType = A,
AwardeeOrRecipientUniqueIdentifier must be active as of
the ActionDate, unless the record is an aggregate or PII-
redacted non-aggregate record (RecordType = 1 or 3) or
awarded to an individual recipient (BusinessTypes includes
'P'). This is an error because CorrectionDeleteIndicator is not
C or the action date is after January 1, 2017.
Fatal Error

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
A-4
ID
Business Data Element
or Concept
Schema Data Label
Applicable
File(s)
Extracted Validation Rules
Severity
21
DUNS
AwardeeOrRecipientUniqueId
entifier
FABS
FABS31.6 For AssistanceType of 02, 03, 04, or 05 whose
ActionDate is after October 1, 2010 and ActionType = A,
AwardeeOrRecipientUniqueIdentifier should be active as of
the ActionDate, unless the record is an aggregate or PII-
redacted non-aggregate record (RecordType = 1 or 3) or
awarded to an individual recipient (BusinessTypes includes
'P'). This is a warning because CorrectionDeleteIndicator is C
and the action date is before January 1, 2017.
Warning
22
DUNS
AwardeeOrRecipientUniqueId
entifier
FABS
FABS31.7 For AssistanceType of 02, 03, 04, or 05 whose
ActionDate is after October 1, 2010 and ActionType = B, C,
or D, AwardeeOrRecipientUniqueIdentifier should be active
on the ActionDate, unless the record is an aggregate or PII-
redacted non-aggregate record (RecordType = 1 or 3) or
awarded to an individual recipient (BusinessTypes includes
'P').
Warning
23
Compensated employee Name
HighCompOfficer1FullName
N/A
None found
N/A
24
Compensated employee Amount
HighCompOfficer2Amount
N/A
None found
N/A
25
Disaster Emergency Fund Code
(DEFC)
DisasterEmergencyFundCode
B
B19 The combination of TAS/object class/program activity
code/reimbursable flag/DEFC in File B (object class program
activity) should be unique
Fatal Error
26
DEFC
DisasterEmergencyFundCode
B
B21 For monthly submissions, all TAS and COVID-19
Disaster Emergency Fund Code combinations required to be
reported to GTAS are reported in File B, with the exception
of Financing Accounts (or when all obligation and outlay
monetary amounts are zero for the TAS). As noted in A33,
allocation accounts should be reported by the Child Agency,
not by the Parent agency.
Warning
27
DEFC
DisasterEmergencyFundCode
B, C
B24 DEFC values must be A, B, C, D, E, F, G, H, I, J, K, L,
M, N, O, P, Q, R, S, T or 9 (plus future codes as determined
by OMB). DEFC cannot be blank.
Fatal Error

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
A-5
ID
Business Data Element
or Concept
Schema Data Label
Applicable
File(s)
Extracted Validation Rules
Severity
28
Catalog of Domestic Financial
Assistance (CFDA)
CFDA_Number
FABS
FABS2.1 The combination of FAIN,
AwardModificationAmendmentNumber, URI,
CFDA_Number, and AwardingSubTierAgencyCode must be
unique within the submission file.
Fatal Error
29
CFDA
CFDA_Number
FABS
FABS2.2 The combination of FAIN,
AwardModificationAmendmentNumber, URI,
CFDA_Number, and AwardingSubTierAgencyCode must be
unique when compared to currently published data--unless
the record is a correction or deletion (i.e., if
CorrectionDeleteIndicator = C or D). In this particular case,
the combination of these five fields in this transaction has
already been published in USAspending.gov, making this
second attempt a duplicate.
Fatal Error
30
CFDA
CFDA_Number
FABS
FABS36 CFDA_Number must be in ##.### format, where #
represents a number from 0 to 9.
Fatal Error
31
CFDA
CFDA_Number
FABS
FABS37.1 For new (ActionType = A) or mixed aggregate
(ActionType = E) assistance awards specifically, the
CFDA_Number must be active as of the ActionDate. This
does not apply to correction records (those with
CorrectionDeleteIndicator = C).
Fatal Error
32
CFDA
CFDA_Number
FABS
FABS37.2 For non-new assistance awards (ActionType = B,
C, or D), the CFDA_Number need not be active as of the
ActionDate, but a warning will trigger in this case. This
warning will not trigger for correction records (those with
CorrectionDeleteIndicator = C).
Warning
33
CFDA
CFDA_Number
FABS
FABS37.3 CFDA_Number must have been registered with
CFDA.gov or registered as an Assistance Listing on
beta.SAM.gov (post-May 2018) at some point in time.
Fatal Error
34
CFDA
CFDA_Number
FABS
FABSREQ10 This field is required for all submissions but
was not provided in this row (CFDA_Number).
Fatal Error
35
NIA Code
National Interest Action
N/A
Not found
N/A

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
A-6
ID
Business Data Element
or Concept
Schema Data Label
Applicable
File(s)
Extracted Validation Rules
Severity
36
Award Type
AssistanceType
FABS
FABS5 AssistanceType field must contain one of the
following values: "02", "03", "04", "05", "06", "07", "08",
"09", "10", or "11".
Fatal Error
37
Award Type
AssistanceType
FABS
FABSREQ7 AssistanceType is required for all submissions
but was not provided in this row.
Fatal Error
38
PSC
Product or Service Code
N/A
Not found
N/A
39
Award Description
AwardDescription;
SubAwardDescription
FABS
FABSREQ1 AwardDescription is required for all
submissions but was not provided in this row. (Note: No
specific references to “SubAwardDescription” were found.)
Fatal Error
40
Award ID
PrimeAwardID
C, D1
C11 Each unique PIID (or combination of
PIID/ParentAwardId) from file C should exist in file D1.
Note that this only compares award identifiers when the
TotalObligationAmount is not null.
Warning
41
Award ID
PrimeAwardID
C, D1
C12 Each unique PIID (or combination of
PIID/ParentAwardId) from file D1 should exist in file C with
a TransactionObligatedAmount that is not null during the
same reporting period, except D1 records where
FederalActionObligation = 0.
Warning
42
Awarding Agency
AwardingAgencyCode
FABS
FABS23.2 If both are submitted,
AwardingSubTierAgencyCode and AwardingOfficeCode
must belong to the same AwardingAgencyCode (per the
Federal Hierarchy).
Fatal Error
43
SubAward/subcontract
SubAwardNumber
N/A
Not found
N/A
44
SubAward/subcontract
AwardingSubTierAgencyCode
FABS
FABS2.1 The combination of FAIN,
AwardModificationAmendmentNumber, URI,
CFDA_Number, and AwardingSubTierAgencyCode must be
unique within the submission file.
Fatal Error

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
A-7
ID
Business Data Element
or Concept
Schema Data Label
Applicable
File(s)
Extracted Validation Rules
Severity
45
SubAward/subcontract
AwardingSubTierAgencyCode
FABS
FABS2.2 The combination of FAIN,
AwardModificationAmendmentNumber, URI,
CFDA_Number, and AwardingSubTierAgencyCode must be
unique when compared to currently published data--unless
the record is a correction or deletion (i.e., if
CorrectionDeleteIndicator = C or D). In this particular case,
the combination of these five fields in this transaction has
already been published in USAspending.gov, making this
second attempt a duplicate.
Fatal Error
46
SubAward/subcontract
AwardingSubTierAgencyCode
FABS
FABS23.1 When provided, AwardingSubTierAgencyCode
must be a valid 4-character sub-tier agency code from the
Federal Hierarchy.
Fatal Error
47
SubAward/subcontract
AwardingSubTierAgencyCode
FABS
FABS23.2 If both are submitted,
AwardingSubTierAgencyCode and AwardingOfficeCode
must belong to the same AwardingAgencyCode (per the
Federal Hierarchy).
Fatal Error
48
SubAward/subcontract
AwardingSubTierAgencyCode
FABS
FABS23.3 AwardingSubTierAgencyCode must be provided
when AwardingOfficeCode is not provided.
Fatal Error
49
n-tier subaward/subcontract
N/A
N/A
No specific references found
N/A
50
Obligated Amount
TransactionObligatedAmount;
FederalActionObligation

C, D2
C9 Unique FAIN or URI from file D2 should exist in file C
with a TransactionObligatedAmount that is not null, except
for:
1)    Loans (AssistanceType = 07 or 08) with
OriginalLoanSubsidyCost <= 0 in D2; or
2)    Non-Loans with FederalActionObligation = 0 in D2.
For non-aggregate and PII-redacted non-aggregate records,
only the FAIN in D2 will be compared to C. For aggregate
records, only the URI in D2 will be compared to C. Note that
for File C, FAIN and URI cannot be provided on the same
row.
Warning

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
A-8
ID
Business Data Element
or Concept
Schema Data Label
Applicable
File(s)
Extracted Validation Rules
Severity
51
Obligated Amount
ObligatedAmountFundedByC
OVID19Supplementals;
PotentialTotalValueOfAward
(for procurements)
PrimeAwardAmount
N/A
No specific references found
N/A
52
Obligated Amount
ObligatedAmountFundedByC
OVID19Supplementals;
TransactionObligatedAmount;
FederalActionObligation
PotentialTotalValueOfAward
(for procurements)
PrimeAwardAmount
C, D1
C12 Each unique PIID (or combination of
PIID/ParentAwardId) from file D1 should exist in file C with
a TransactionObligatedAmount that is not null during the
same reporting period, except D1 records where
FederalActionObligation = 0.
Warning
53
Obligated Amount
ObligatedAmountFundedByC
OVID19Supplementals;
TransactionObligatedAmount;
FederalActionObligation
PotentialTotalValueOfAward
(for procurements)
PrimeAwardAmount
C
C17 TransactionObligatedAmount and USSGL related
balances and subtotals cannot be provided on the same row.
Please note that this rule will apply for any non-null (non-
blank) value provided, including zero (0).
Fatal Error
54
Obligated Amount
ObligatedAmountFundedByC
OVID19Supplementals;
TransactionObligatedAmount;
FederalActionObligation
PotentialTotalValueOfAward
(for procurements)
PrimeAwardAmount
C, D1, D2
C23 For each unique award ID (PIID or combination of
PIID/ParentAwardId for procurement; FAIN or URI for
financial assistance) in File C, the sum of each
TransactionObligatedAmount should match (but with
opposite signs) the sum of the FederalActionObligation (in
either D1 or D2) or OriginalLoanSubsidyCost (only in D2)
amounts reported in D1 or D2. For example, if the
TransactionObligatedAmounts for a FAIN add to -100 in File
C, the sum of the FederalActionObligation for that FAIN in
D2 should be 100. This rule does not apply if the
AllocationTransferAgency (ATA) field is populated and is
different from the Agency ID. Note that this only compares
award identifiers when the TotalObligationAmount is not
null.
Warning

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
A-9
ID
Business Data Element
or Concept
Schema Data Label
Applicable
File(s)
Extracted Validation Rules
Severity
55
Obligated Amount
ObligatedAmountFundedByC
OVID19Supplementals;
TransactionObligatedAmount;
FederalActionObligation
PotentialTotalValueOfAward
(for procurements)
PrimeAwardAmount
FABS
FABS26.1 FederalActionObligation must be blank or 0 for
loans (AssistanceType = 07 or 08).
Fatal Error
56
Obligated Amount
ObligatedAmountFundedByC
OVID19Supplementals;
TransactionObligatedAmount;
FederalActionObligation
PotentialTotalValueOfAward
(for procurements)
PrimeAwardAmount
FABS
FABS26.2 FederalActionObligation is required for non-loans
(i.e., when AssistanceType is not 07 or 08).
Fatal Error
57
Obligated Amount
ObligatedAmountFundedByC
OVID19Supplementals;
TransactionObligatedAmount;
FederalActionObligation
PotentialTotalValueOfAward
(for procurements)
PrimeAwardAmount
FABS
FABSTYPE1 The value provided was of the wrong type.
Note that all type errors in a line must be fixed before the rest
of the validation logic is applied to that line.
(FederalActionObligation).
Fatal Error

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
A-10
ID
Business Data Element
or Concept
Schema Data Label
Applicable
File(s)
Extracted Validation Rules
Severity
58
Expended Amount
OutlayedAmountFundedByCO
VID19Supplementals
C
C5 GrossOutlayAmountByAward_FYB (File C) =
GrossOutlaysUndeliveredOrdersPrepaidTotal_FYB (File C)
+ GrossOutlaysDeliveredOrdersPaidTotal_FYB (File C).
GrossOutlayAmountByAward_CPE (File C) should reflect
year-to-date activity as of the end of the reporting period for
the same TAS/DEFC combination:
GrossOutlayAmountByAward_CPE =
(GrossOutlaysUndeliveredOrdersPrepaidTotal_CPE less
GrossOutlaysUndeliveredOrdersPrepaidTotal_FYB) +
(GrossOutlaysDeliveredOrdersPaidTotal_CPE less
GrossOutlaysDeliveredOrdersPaidTotal_FYB).

Note: This rule only applies if
GrossOutlayAmountByAward_CPE is the only non-zero
value provided on a non-TOA line on File C.
Warning
59
Expended Amount
OutlayedAmountFundedByCO
VID19Supplementals
C
C6 GrossOutlaysUndeliveredOrdersPrepaidTotal in File C =
USSGL 4802 + 4832+ 4882 in File C for the same date
context (FYB or CPE) and TAS/DEFC combination. This
applies to the award level. Note for FYB values, only 4802 is
expected to have a balance other than zero.
Warning
60
Expended Amount
OutlayedAmountFundedByCO
VID19Supplementals
C
C7 GrossOutlaysDeliveredOrdersPaidTotal in File C =
USSGL 4902 + 4908 + 4982 in File C for the same date
context (FYB or CPE) and TAS/DEFC combination. This
applies to the award level. Note for FYB values, only 4908 is
expected to have a balance other than zero.
Warning
61
Expended Amount
OutlayedAmountFundedByCO
VID19Supplementals
C
C25 If the DisasterEmergencyFundCode element has a valid
COVID-19-related code and TOA is blank, then
GrossOutlayByAward_CPE cannot be blank.
Fatal Error

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
A-11
ID
Business Data Element
or Concept
Schema Data Label
Applicable
File(s)
Extracted Validation Rules
Severity
62
Expended Amount
OutlayedAmountFundedByCO
VID19Supplementals
C
C27 The File C GrossOutlayByAward_CPE balance for a
TAS/DEFC/Award combination should continue to be
reported in subsequent periods during the FY, once it has
been submitted to DATA Act, unless the most recently
reported outlay balance for this award breakdown was zero.
This only applies to File C outlays, not TOA.
Warning
63
Expended Amount
OutlayedAmountFundedByCO
VID19Supplementals
A
A14 GrossOutlayAmountByTAS_CPE= value for GTAS SF
133 line #3020 for the same reporting period.
Fatal Error
64
Expended Amount
OutlayedAmountFundedByCO
VID19Supplementals
A, B
A18 The GrossOutlayAmountByTAS_CPE amount in the
appropriation file (A) does not equal the sum of the
corresponding
GrossOutlayAmountByProgramObjectClass_CPE values in
the award financial file (B). {This value is the sum of all
Gross Outlay Amounts reported in file B, to indicate year-to-
date activity by TAS/Subaccount.}
Warning
65
Expended Amount
OutlayedAmountFundedByCO
VID19Supplementals
B
B5 GrossOutlayAmountByProgramObjectClass_FYB (File
B) = GrossOutlaysUndeliveredOrdersPrepaidTotal_FYB
(File B) + GrossOutlaysDeliveredOrdersPaidTotal_FYB
(File B). GrossOutlayAmountByProgramObjectClass_CPE
(File B) should reflect year-to-date activity as of the end of
the reporting period for the TAS/DEFC combination:
GrossOutlayAmountByProgramObjectClass_CPE =
(GrossOutlaysUndeliveredOrdersPrepaidTotal_CPE less
GrossOutlaysUndeliveredOrdersPrepaidTotal_FYB) +
(GrossOutlaysDeliveredOrdersPaidTotal_CPE less
GrossOutlaysDeliveredOrdersPaidTotal_FYB)
Warning
66
Expended Amount
OutlayedAmountFundedByCO
VID19Supplementals
B
B6 GrossOutlaysUndeliveredOrdersPrepaidTotal in File B =
USSGL 4802 + 4832+ 4882 in File B for the same date
context (FYB or CPE) and TAS/DEFC combination. This
applies to the program activity and object class level. Note
for FYB values, only 4802 is expected to have a balance
other than zero.
Warning

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
A-12
ID
Business Data Element
or Concept
Schema Data Label
Applicable
File(s)
Extracted Validation Rules
Severity
67
Expended Amount
OutlayedAmountFundedByCO
VID19Supplementals
B
B7 GrossOutlaysDeliveredOrdersPaidTotal in File B =
USSGL 4902 + 4908 + 4982 in File B for the same date
context (FYB or CPE) and TAS/DEFC combination. This
applies to the program activity and object class level. Note
for FYB values, only 4908 is expected to have a balance
other than zero.
Warning
68
Expended Amount
OutlayedAmountFundedByCO
VID19Supplementals
B
B22 GrossOutlayAmountByProgramObjectClass_CPE =
value for GTAS SF 133 line #3020 for the same reporting
period for the TAS and DEFC combination (except for when
'9' is provided as DEFC).
Warning
69
Progress reports
N/A
N/A
Not found
N/A

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
B-1

Data Quality Analysis Detail
MITRE conducted a detailed sample assessment of data elements informed by various analyses to evaluate for transparency and across the
three data dimensions: completeness, accuracy, and timeliness.
The detailed analysis is provided in this appendix by data source.
The data sources sampled for analysis are:
• USASpending.gov
o Assistance_PrimeAwardSummaries (35,435 records)
o Assistance_PrimeTransactions (46,131 records)
o Assistance_Subawards (15,472 records)
o Assistance_Subawards_Summaries (15,492 records)
o Contracts_PrimeAwardSummaries (2,348 records)
o Contracts_PrimeTransactions (5,469 records)
o Contracts_Subawards (1,267 records)
o Contracts_Subawards_summaries (2,167)
• U.S. Department of Health and Human Services (HHS) Tracking Accountability in Government Grants System (TAGGS) COVID-
19 Data (8,722 records)
The data sources that were utilized without sampling:
• SBA.gov PPP loans >= $150k (662,515 records)
• SBA.gov PPP loans < $150k (4,549613 records)
The source files to assess data quality are listed in the table below:

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
B-2
Table B-1. Data Quality Analysis Source Files
ID
Description
Data Source
Constraints
Applied When
Extracting
Extract File Name(s)
1
USA spending reported –
Coronavirus Aid, Relief,
and Economic Security Act
of 2020 (CARES Act)
USAspending.gov
DEFC = N & O
No direct
payments
Assistance_PrimeAwardSummaries_2020-09-24_H01M56S51_1.csv
Assistance_PrimeTransactions_2020-09-24_H00M39S22_1.csv
Assistance_Subawards_2020-09-24_H00M40S29_1.csv
Assistance_Subawards_Summaries_2020-09-24_H02M09S52_1.csv
Contracts_PrimeAwardSummaries_2020-09-24_H01M53S20_1.csv
Contracts_PrimeTransactions_2020-09-24_H00M38S34_1.csv
Contracts_Subawards_2020-09-24_H00M40S08_1.csv
Contracts_Subawards_summaries_2020-09-24_H02M01S25_1.csv
2
USA spending reported –
CARES Act  - HHS Data
USAspending.gov
DEFC = N & O
HHS agency;
HHSCARESActAssistance_PrimeAwardSummaries_20201004_H17M07S
41_1.csv
3
TAGGS COVID-19 Data https://taggs.hhs.gov/Coronavirus Appropriation code
= CV
TAGGSExportCovid19_10012020.csv
4 Zip Code Reference Table
zipbronze.csv
 N/A
https://www.zipcodestogo.com/
5
Small Business
Administration
(SBA) Grants Data
USAspending.gov
SBA grants data
SBA; DEFC L, M,
N, O, P; grants
SBAPrimeAssstanceAwardSummaries_20201005.csv
6
USA Spending Loan Data  USAspending.gov SBA loan data  SBA; loans, DEFC
=P
SBALoanTransactionsUSAspending_20201005.zip
7
SBA Paycheck Protection
Program (PPP) Data
SBA published PPP loan data
N/A
PPP Data 150k plus 080820.csv
PPP Data up to 150k 080820 nn.csv where “nn” is the state code for each
state
8
Coronavirus Relief Fund
(CRF)
FinancialProgressReportValidation
Rules_09292020.xlsx
N/A
N/A
9
CRF
Treasury OIG & PRAC Financial
Reporting OLDC Form: Prime
Recipient User Guide
N/A
GrantSolutions.gov; August 20, 2020

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
B-3
Table B-2. USAspending.gov Analysis
ID
CARES Act
Source Section
Business Data
Element or Concept
Schema Data Label
Completeness
Accuracy
Comment
1
Supporting
NAIC
NAICS
Collected and
Reported
Standard reference applied; at least
one NAIC code that appears incorrect
N/A
2
15010
Recipient Location –
State
LegalEntityStateCode
Highly collected and
reported (contract
transactions <1%
blank; assistance
transaction < 4%
blank- based on city)
Standard reference list applied; Need
more information for correctness
N/A
3
Supporting
Place of Performance
Location - State
PrimaryPlaceOfPerformanceStateCod
e
contracts
transactions: < 10%
blank
assistance
transactions: < 0.25%
blank
Standard reference list applied; Need
more information for correctness
N/A
4
15010
Recipient
Congressional District
LegalEntityCongressionalDistrict
contracts
transactions: <5%
blank
assistance
transactions: < 0.03
% blank
Standard reference list applied; Need
more information for correctness
N/A
5
15010
Place of Performance
Congressional District
PrimaryPlaceOfPerformanceCongres
sionalDistrict
contracts
transactions: <10%
blank
assistance
transactions: < 0.25%
blank
Standard reference list applied; Need
more information for correctness
N/A
6
15011
Entity Name
AwardeeOrRecipientLegalEntityNam
e
Collected and
Reported
Can contain some derivations in name
spellings. USAspending.gov shows
other name combinations.
N/A
7
Supporting
Number of Employees
N/A
Not Collected
Not Collected
Possibly derived
from other sources.

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
B-4
ID
CARES Act
Source Section
Business Data
Element or Concept
Schema Data Label
Completeness
Accuracy
Comment
8
Supporting
DUNS
AwardeeOrRecipientUniqueIdentifier
Collected and
Reported
Standard reference list applied; Need
more information for correctness
N/A
9
Supporting
Compensated
employee Name
HighCompOfficer1FullName
<15% reported by
USAspending.gov in
transaction query at
prime level
Open Text field with minimal
standardization
N/A
10
Supporting
Compensated
employee Amount
HighCompOfficer2Amount
<15% reported by
USAspending.gov in
transaction query at
prime level
numeric field
N/A
11
Supporting
DEFC
DisasterEmergencyFundCode
by definition of
extract it is 100%
populated
Codes are not mutually exclusive
Reported by Agency
per OMB M-20-21
12
Supporting
CFDA
CFDA_Number
Collected and
Reported
Standard reference list applied; Need
more information for correctness by
comparing against other sources and
fields
Assistance only
13
Supporting
NIA Code
National Interest Action
Approx. 44%
populated in prime
transactions; 55% in
prime summary
codes listed were either P20C “r
"n”ne" indicating that when used
codes are correct
"P”0“" "COVID-19
2”20" Procurements
only;
Per 4/6/2020
guidance all COVID-
19- related
procurements
14
Supporting
Award Type
AssistanceType
Collected and
Reported
Standard reference list applied; Need
more information for correctness by
comparing against other sources and
fields
Grant, Loan,
Contract, Direct
Payment
15
Supporting
PSC
Product or Service Code
Collected and
Reported
Standard reference list applied; Need
more information for correctness by
comparing against other sources and
fields
N/A

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
B-5
ID
CARES Act
Source Section
Business Data
Element or Concept
Schema Data Label
Completeness
Accuracy
Comment
16
15011
Award Description
AwardDescription;
SubAwardDescription
Collected and
Reported
Open Text field with minimal
standardization
N/A
17
15010/15011
Award ID
PrimeAwardID
Collected and
Reported for Prime
and First Tier
No standard format; Need more
information for correctness by
comparing against other sources and
fields
FAIN, PIID
18
15011
Awarding Agency
AwardingAgencyCode
Collected and
Reported for Prime
Standard reference list applied; Need
more information for correctness by
comparing against other sources and
fields
N/A
19
15011
SubAward/subcontract
SubAwardNumber
Collected and
Reported
No standard format, both numeric and
alphanumeric represented; Some
inaccurate value“: ”na"
1st tier only
20
15011
n-tier
subaward/subcontract
N/A
Not Collected
Not Collected
N/A
21
15011
Obligated Amount
ObligatedAmountFundedByCOVID1
9Supplementals;
TransactionObligatedAmount;
FederalActionObligation
PotentialTotalValueOfAward (for
procurements)
PrimeAwardAmount
Collected and
Reported
More analysis could show
inconsistencies pointing to Fraud,
Waste, and Abuse (FWA).
N/A
22
15011
Expended Amount
OutlayedAmountFundedByCOVID1
9Supplementals
Collected and
Reported
More analysis could show
inconsistencies pointing to FWA.
N/A
23
Supporting
Progress reports
N/A
Not Collected
Not Collected
N/A

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
B-6
Table B-3. Zip Code Metrics Analysis for USAspending.gov
ID
Metric
Element
Value
Comment [Query]
1
Valid zip codes
recipient_zip_code
870 potentially
invalid zip codes
found in a total of
5,024 records
Prime Award Transactions (DEFC = N & O
No direct payments)
2
Valid zip codes
primary_place_of_performance_zip_4
153 potentially
invalid zip codes
found in a total of
19,674 records
Prime Award Transactions (DEFC = N & O
No direct payments)
The element does not appear to apply standardization for entries.
There are blanks, 5-digit zips, zip+4, and text entries.

Table B-4. HHS TAGGS to USAspending.gov Comparison Analysis
ID
Metric
Data Element(s)
Value
Comment [Query]
1
Unique count of award numbers (FAIN) –
TAGGS
Award Number
8,722

Count of award numbers pulled from TAGGS on
October 1, 2020 where the appropriation code = C3
2
Unique count of award numbers (FAIN) –
USAspending.gov
award_id_fain
8,430

Count of award numbers pulled from USAspending.gov
on September 24, 2020 where the DEFC = N & O, no
direct payments and agency is HHS
3
Count of awards that have matching award ids
between TAGGS and USAspending.gov
award_id_fain
Award Number
8,387

Count of records where award numbers match between
the two sets of records extracted from TAGGS and
USAspending.gov

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
B-7
ID
Metric
Data Element(s)
Value
Comment [Query]
4
Number of award numbers (FAIN) in TAGGS
extract that are not in USASpending.gov extract
award_id_fain
Award Number
335

This represents a 3.8% unmatch rate.

The expectation is that this should be 0. A sampling of
the unmatched award numbers show that they were
either not coded with a DEFC or not coded with the
DEFC “N” or “O”.
In one of the sampled records the Federal Award
Identification Number (FAIN) did not exist at all in
USAspending.gov.
Match is made where award_id_fain = Award Number.
5
Number of award numbers (FAIN) in
USAspending.gov that are not in TAGGS
award_id_fain
Award Number
0

This is the expected result.
Match is made where award_id_fain = Award Number.

6
Number of total amounts in TAGGS that does not
equal total amount in USAspending.gov
obligated_amount_funded_by_
COVID-19_supplementals
2,527 out of
8,387

This represents a 30.1% mismatch rate.
 Match is made where award_id_fain = Award Number.

Table B-5. Effect of OMB Clarification of Award Description in USAspending.gov Analysis
ID
Metric
Timeframe:
Modified Date > 9/1/2020
Timeframe:
Modified Date < 9/1/2020
1
Total Number of Assistance Prime Transactions
before and after first reporting post OMB
additional guidance on Award Descriptions
4,653
4,653
2
Number of records for timeframe that have a
length of award description < 10
1,762
151
3
Total COVID-obligated fund for length of award
description < 10
$7,268,161,723.54
$126,926,967.55

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
B-8
Table B-6. SBA PPP Loans >= $150K Completeness Checks Results
ID
Metric
Element
Value
Comment [Query]
1
Number of records
 Count of records
662,515
Query to count the records from SBA PPP Loans >= $150k
2
Completeness Populated
LoanRange
100% complete
0% empty
3
Completeness Populated
BusinessName
5 not available
< 1% empty
4
Completeness Populated
Address
17 not available
< 1% empty
5
Completeness Populated
City
15 not available
< 1% empty
6
Completeness Populated
State
16 blank
< 1% empty
7
Completeness Populated
Zip
16 blank
< 1% empty
8
Completeness Populated
NAICSCode
6,715 blank
1% empty
9
Completeness Populated
BusinessType
1,405 blank
< 1% empty
10
Completeness Populated
RaceEthnicity
568,103 unanswered
85% blank/unanswered
11
Completeness Populated
Gender
471,770 unanswered
71% blank/unanswered
12
Completeness Populated
Veteran
522,970 unanswered
79% blank/unanswered
13
Completeness Populated
NonProfit
622,520 blank
94% blank/unanswered
14
Completeness Populated
JobsReported
39,880 blank
6% blank/unanswered
15
Completeness Populated
DateApproved
100% complete
 0% empty
16
Completeness Populated
Lender
100% complete
 0% empty
17
Completeness Populated
CD
223 blank
< 1% empty
18
Granular standardization
LoanRange
SBA PPP > $150k : Loan
Range
The extract from SBA PPP > $150k only contains loan ranges, not
actual loan values.

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
B-9
Table B-7. SBA PPP Loans < $150k Completeness Checks Results
ID
Metric
Element
Value
Comment
1
Number of records
 Count of records
4,549,613
Query to count the records from SBA
PPP Loans <150k
2
Completeness
NonProfit
4,409,022 empty
97% empty
3
Completeness
JobsReported
297,998 empty
553,245 qty 0 reported
7% empty
12% with 0 reported
4
Completeness
NAICSCode
126,429 empty
3% empty
5
Completeness
BusinessType
3,165 empty
<1% empty
6
Completeness
CD
794 empty
<1% empty
7
Completeness
Zip
 100% complete
0% empty
8
Completeness
State
 100% complete
0% empty
9
Completeness
LoanAmount
 100% complete
0% empty
10
Completeness
City
 100% complete
0% empty
11
Completeness
RaceEthnicity
4,107,224 unanswered
90% listed as unanswered
12
Completeness
Gender
3,624,603 unanswered
80% listed as unanswered
13
Completeness
Veteran
3,927,345 unanswered
86% listed as unanswered
14
Completeness
DateApproved
 100% complete
0% empty
15
Completeness
Lender
 100% complete
0% empty

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
B-10
Table B-8. SBA PPP Loans >= $150K Accuracy Checks Results
ID
Metric
Element
Value
Comment [Query]
1
Granular
standardization
LoanRange
SBA PPP > $150k: Loan Range
The extract from SBA PPP > $150k only contains loan
ranges, not actual loan values.
2
Congressional District
match
CD
349 mismatch

Of those, 132 have both a state and a CD value entered
where the CD does not match the state. The other
mismatches have a missing CD value.
3
Valid zip codes
Zip
29 potentially invalid zip codes found
in a total of 29 records
Identify zip codes in PPP > 150k  that are not listed in zip
code file. Select associated records from PPP > 150k   file
that utilize identified zip codes.
4
Valid zip code to state
match
Zip
State
111 potentially mismatched zip code
to state code found in a total of 500
records
Identify zip code + state combination in PPP > 150k that
are not listed in zip code file. Select associated records
from PPP > 150k file that utilize identified zip code + state
combination.

Table B-9. SBA PPP Loans < $150k Accuracy Checks Results
ID
Metric
Element
Value
Comment
1
Congressional District
Match
CD
590 mismatch
Match was made on the state code and the first 2 characters
of the CD;
In some cases, the city appears aligned with the state in the
CD not the State code.
2
Valid zip codes
 Zip
309 potentially invalid zip codes
found in a total of 4,840 records
Identify zip codes in PPP < 150k that are not listed in zip
code file. Select associated records from PPP < 150k file
that utilize identified zip codes.
3
Valid zip code to state
match
Zip
State
740 potentially mismatched zip code
to state code found in a total of 5,364
records
Identify zip code + state combination in PPP < 150k that are
not listed in zip code file. Select associated records from
PPP < 150k that utilize identified zip code + state
combination.

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
C-1

Risk Areas
MITRE reviewed each of the four COVID-19-related statutes enacted as of May 11, 2020 that
provide funding to help individuals and businesses counter the human and economic impacts of
the pandemic. These statutes contain hundreds of provisions that present payment integrity
risks—whether from applicant errors (e.g., thousands of individuals who have never filed for
government benefit payments now completing and submitting claim forms), from agency errors
(e.g., agencies expected to rapidly process a massive increase in benefit claims in a very short
period of time), or from outright fraud.
MITRE then catalogued these provisions into a table, an excerpt of which is shown in Error! R
eference source not found.. The table presents, for each statute, key payment integrity issues,
the agency associated with each one, and the dollars identified in the statute for that issue. These
issues can be viewed individually as risk areas or they can be grouped in higher-level domains—
such as funding related to healthcare, infrastructure, benefits, or workforce/job issues—for data
gathering, assessment, and analysis.
Table C-1. Excerpt of Payment Integrity High Risk Areas
Agency
Issues
Statute / Section
$M
HHS – National Institutes of
Health (NIH)
Prevention, preparation, response;
includes worker-based training
Coronavirus
Preparedness and
Response Supplemental
Appropriations Act
(CPRSA) – Title III
Part of $836
HHS
Authority to temporarily waive or
modify application of certain
Medicare requirements with respect
to telehealth services furnished
during certain emergency periods
CPRSA – sec. 102
Unspecified
HHS
Numerous healthcare provisions –
from eliminating some telehealth
restrictions to increasing Medicare
payments to hospitals by 20% for
treating patients admitted with
COVID-19 to preventing scheduled
reductions in Medicare payments for
durable medical equipment
CARES Act – A -Title
III
Unspecified
HHS
Outreach and assistance for low-
income programs – state health
insurance programs (Medicare),
aging programs
CARES Act – A -Title
III – Sec. 3803
$38
HHS
Extension – Money follows the
person rebalancing demonstration
program (Medicaid)
CARES Act – A -Title
III – Sec. 3811
$38
HHS
Extension – Community health
centers, National Health Service
Corps, teaching health centers that
CARES Act – A -Title
III – Sec. 3831
$5,050

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
C-2
Agency
Issues
Statute / Section
$M
operate Graduate Medical Education
programs
HHS
Diabetes programs
CARES Act – A -Title
III – Sec. 3832
$50
HHS – Food and Drug
Administration
Development of medical
countermeasures and vaccines,
advanced manufacturing for medical
products, monitoring of medical
product supply chains
CARES Act – B – Title I
$80
Commerce – National
Institute of Standards and
Technology
Assist manufacturers, support
development and manufacturing of
medical counter measures and
biomedical equipment and supplies
CARES Act – B – Title
II
$60
National Science Foundation
Research and related activities for
response, including grants
CARES Act – B – Title
II
$75
HHS
Fund COVID-19 testing – Indian
Health Service (for COVID-19
testing)
Families First
Coronavirus Response
Act (FFCRA) – Title IV
$64
HHS
Fund COVID-19 testing – Public
Health and Social Services
Emergency Fund (direct payment for
COVID-19 testing of the uninsured)
FFCRA – Title V
$1,000
HHS
Additional funding for the Public
Health and Social Services
Emergency Fund to research,
develop, validate, manufacture,
purchase, administer, and expand
capacity for COVID-19 tests
Paycheck Protection
Program and Health
Care Enhancement Act
(PPPHCEA) – B – Title
I
$25,000
HHS
Domestic and international –
Development/purchase of vaccines,
construction of non-federal facilities
to produce them
CPRSA – Title III
$3,100
HHS – Indian Health Service
(IHS)
Public health support, electronic
health record modernization,
telehealth, and other IT upgrades
CARES Act – B – Title
VII
$1,032
HHS – NIH
Acquire medical supplies, construct
facilities – Various components,
including National Institute of
Allergy and Infectious Diseases for
equipment and facilities
CARES Act – B – Title
VIII
$945
HHS – Secretary
Acquire medical supplies, construct
facilities – Purchase vaccines;
development, translation, and
demonstration at scale of innovations
in manufacturing platforms (these
funds can be used for construction or
CARES Act – B – Title
VIII
Part of $27,275

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
C-3
Agency
Issues
Statute / Section
$M
renovation of non-governmental
U.S.-based next-generation
manufacturing); telehealth and other
rural health services
HHS – Secretary
Funding for Public Health and Social
Services Emergency Fund to
reimburse eligible healthcare
providers for healthcare-related
expenses or lost revenues attributable
to COVID-19
CARES Act – B – Title
VIII
$100,000
HHS
Additional funding for the Public
Health and Social Services
Emergency Fund to reimburse
eligible healthcare providers for
healthcare-related expenses or lost
revenues attributable to COVID-19
PPPHCEA – B – Title I
$75,000
Veterans Affairs
Acquire medical supplies, construct
facilities – Address increased
demand for healthcare facilities,
including the purchase of medical
equipment and supplies, testing kits,
and protective equipment; IT support
to increase telework, telehealth, and
call center capabilities (includes
purchase of devices and enhanced
systems bandwidth and support)
CARES Act – B – Title
X
Part of $19,600
Department of Defense (DoD)
Acquire medical supplies – Procure
medical supplies, Personal Protective
Equipment (PPE), non-medical PPE
and supplies, pharmaceuticals,
biohazard mitigation
CARES Act – B – Title
III
Part of $1,614
DoD
Acquire medical supplies – Defense
Production Act purchases
CARES Act – B – Title
III
$1,000
DoD – Defense Health
Program
Acquire medical supplies – Procure
medical equipment, PPE; expand
military treatment facilities; develop
vaccines, anti-virals, 24/7 lab
operations, diagnostic tests
CARES Act – B – Title
III
$3,806
Department of Homeland
Security – Transportation
Security Administration,
Management Directorate
Acquire medical supplies – Purchase
of PPE; cleaning and sanitizing
checkpoints and other airport
common areas
CARES Act – B – Title
V
$278
Interior – IHS, Bureau of
Indian Affairs, et al.
Acquire medical supplies – Medical
equipment and supplies, triage units,
medicines, increased telehealth
CARES A–t -–B - Title
VII
Part of $735
Environmental Protection
Agency (EPA)
Research on methods to reduce risks
from environmental transmission of
COVID-19; expediting registration
CARES A–t -–B - Title
VII
$7

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
C-4
Agency
Issues
Statute / Section
$M
related to pesticides to address
COVID-19; cleaning/disinfecting
EPA equipment or facilities
U.S. Department of
Agriculture – Forest Service
Cleaning/disinfecting public
recreation amenities, PPE, and
baseline health testing for first
responders, reestablishing
abandoned/failed experiments
associated with employee restrictions
due to COVID-19
CARES A–t -–B - Title
VII
$71
HHS – Agency for Toxic
Substances and Disease
Registry
Support spatial analysis and mapping
of infectious-disease hot spots,
including cruise ships; for guidance
and outreach on safe practices for
disinfecting home, school, daycare
facilities
CARES A–t -–B - Title
VII
$13

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
D-1

Acronyms and Abbreviations

Acronym
Definition
CARES
Coronavirus Aid, Relief, and Economic Security Act of 2020
CD
Congressional District
CFDA
Catalog of Domestic Financial Assistance
CIGIE
Council of the Inspectors General on Integrity and Efficiency
CPRSA

CRF
Coronavirus Relief Fund
DAIMS
Data Act Information Model Schema
DATA
Digital Accountability and Transparency Act 0f 2014
DEFC
Disaster Emergency Fund Code
DHS
Department of Homeland Security
DoD
Department of Defense
DUNS
Data Universal Numbering System (Dun and Bradstreet)
EPA
Environmental Protection Agency
FAIN
Federal Award Identification Number
FFATA
Federal Funding Accountability and Transparency Act of 2006
FFCR
Families First Coronavirus Response Act
FPDS
Federal Procurement Data System
FSRS
Federal Subaward Reporting System
FWA
Fraud, Waste, and Abuse
GAO
Government Accountability Office
GSA
General Services Administration
GTAS
Government-wide Treasury Account Symbol Adjusted Trial Balance System
HHS
Department of Health and Human Services
IG
Inspector General
IHS
Indian Health Service
NIA
National Interest Action
NAICS
North American Industry Classification System
NIH
National Institutes of Health
OFFM
Office of Federal Financial Management
OFPP
Office of Federal Procurement Policy
OIG
Office of Inspector General

Transparency in Pandemic-Related Federal Spending
Report of Alignment and Gaps

UNCLASSIFIED
D-2
Acronym
Definition
OLDC
On-line Data Collection
OMB
Office of Management and Budget
PPP
Paycheck Protection Program
PPPHCEA
Paycheck Protection Program and Health Care Enhancement Act
PRAC
Pandemic Response Accountability Committee
PSC
Product Service Code
SBA
Small Business Administration
TAGGS
Tracking Accountability in Government Grants System
Treasury
U.S. Department of the Treasury
USPS
U.S. Postal Service
U.S.C.
United States Code

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