GAO-24-106237: Federal Spending Transparency: Opportunities Exist to Improve COVID-19 and Other Grant Subaward Data on USAspending.gov
Summary
GAO-24-106237, Federal Spending Transparency: Opportunities Exist to Improve COVID-19 and Other Grant Subaward Data on USAspending.gov, a November 2023 Government Accountability Office report to congressional committees. GAO ran tests on roughly 6 million grant subaward records and reports missing information, impossibly large amounts and likely duplicative records. It found that 26 percent of non-COVID-19 grant subawards and 11 percent of COVID-19 grant subawards reported by prime recipients are likely duplicate records. GAO makes two recommendations to GSA, which administers FSRS, one to Treasury on subaward data quality disclosures and one to OMB to clarify agency roles. GSA and Treasury concurred, and OMB did not have any comments.
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“GAO-24-106237: Federal Spending Transparency: Opportunities Exist to Improve COVID-19 and Other Grant Subaward Data on USAspending.gov.”
Original at www.gao.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gao-24-106237-federal-spending-transparency-opportunities-exist-to-imp-d19cc1a1cf/
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United States Government Accountability Office
Report to Congressional Committees
FEDERAL
November 2023
SPENDING
TRANSPARENCY
Opportunities Exist to
Improve COVID-19
and Other Grant
Subaward Data on
USAspending.gov
GAO-24-106237
November 2023
FEDERAL SPENDING TRANSPARENCY
Opportunities Exist to Improve COVID-19 and Other
Grant Subaward Data on USAspending.gov
Highlights of GAO-24-106237, a report to
congressional committees
Why GAO Did This Study What GAO Found
Congress has long recognized the Federal grant award recipients, such as nonprofit organizations, can pass on a
importance of providing quality data to portion of their awards to another entity as a subaward to carry out a portion of
the public to ensure the transparency the work. Office of Management and Budget (OMB) guidance directs recipients
of federal spending, including of federal grants (prime recipients) to report grant subawards they make to the
subawards. This is critical during Federal Funding Accountability and Transparency Act of 2006 Subaward
national emergencies when federal Reporting System (FSRS) for display on USAspending.gov, with exceptions.
emergency relief funds, such as those Prime recipients are legally responsible for the quality of the reported data. OMB
appropriated in response to the guidance directs federal agencies to support overall subaward data quality.
COVID-19 pandemic, must be
distributed to the public quickly. GAO’s analysis of grant subaward data available from USAspending.gov
identified data quality issues, including grant subawards with missing information,
The CARES Act includes a provision
for GAO to monitor and oversee funds impossibly large amounts, and likely duplicative records. GAO found that 26
used to prepare for, respond to, and percent of non-COVID-19 grant subawards and 11 percent of COVID-19 grant
recover from the pandemic. This report subawards reported by prime recipients are likely duplicate records (see figure).
(1) assesses the quality of grant
Percent of Likely Duplicate Grant Subaward Records on USAspending.gov
subaward data available on
USAspending.gov, including COVID-
19-related awards; and (2) examines
the extent to which guidance governing
subaward reporting supports the
quality of the subaward data.
GAO conducted a series of tests on
roughly 6 million grant subaward
records available on
USAspending.gov; reviewed the legal
framework that governs subaward
reporting; and interviewed officials from
selected agencies to understand how
they support subaward data quality.
Note: A “subaward” is an award provided by a recipient to a subrecipient to carry out part of a federal
What GAO Recommends award. Grant subawards cover subawards that are made under federal grant awards. The term does
not include subawards made under other forms of federal financial assistance awards (i.e., loans) or
GAO is making two recommendations subawards made under federal contracts (subcontracts). COVID-19 grant subawards refer to
to GSA, including that it incorporate subawards reported to USAspending.gov that were made after April 1, 2020, and are associated with
data validation controls into its plan for a prime award with a disaster emergency fund code indicating it received COVID-19 funding.
modernizing the reporting system; one FSRS includes some built-in data entry tools, such as mandatory data fields, but
recommendation to Treasury to there are few validation tests to alert prime recipients about potential data entry
improve grant subaward data quality
errors during the reporting process. The General Services Administration (GSA),
disclosures on USAspending.gov; and
which administers FSRS, plans to address some known reporting challenges as
one recommendation to OMB to clarify
part of its plan to modernize FSRS. In the interim, the Department of the
agency roles for supporting grant
subaward data quality. GSA and Treasury, which administers USAspending.gov, could more clearly disclose
Treasury concurred with the subaward data limitations by putting them where users are likely to see them.
recommendations, and OMB did not OMB guidance delineates agency responsibilities for communicating prime
have any comments on the report. award recipients’ subaward data reporting requirements. However, OMB
guidance is unclear on what processes agencies are expected to implement to
View GAO-24-106237. For more information,
contact Jeff Arkin at (202) 512-6806 or support subaward data quality. Without clear expectations from OMB, agencies
ArkinJ@gao.gov. may not consistently or adequately support subaward data quality, which could
affect the usability of subaward data.
United States Government Accountability Office
Contents
Letter 1
Background 4
Opportunities Exist to Improve the Quality and Transparency of
Grant Subaward Data Available on USAspending.gov 9
Guidance for Agencies on Supporting Subaward Data Quality Is
Unclear 20
Conclusions 25
Recommendations for Executive Action 25
Agency Comments 26
Appendix I Objectives, Scope, and Methodology 29
Appendix II Subaward Data Elements on USAspending.gov 32
Appendix III Comments from the General Services Administration 34
Appendix IV Comments from the Department of the Treasury 36
Appendix V GAO Contact and Staff Acknowledgments 37
Tables
Table 1: Selected Federal Laws and Guidance for Reporting
Subawards 5
Table 2: Selected Exemptions from Requirements to Report
Subawards 5
Table 3: Selected Office of Management and Budget (OMB)
Guidance Delineating Agency Responsibility for
Subaward Reporting 21
Table 4: Selected Office of Management and Budget (OMB)
Guidance to Agencies Related to Subaward Data Quality 22
Table 5: Subaward Data Elements on USAspending.gov 32
Page i GAO-24-106237 Federal Spending Transparency
Figures
Figure 1: Process Overview of Federal Grant Subaward Data
Displayed on USAspending.gov 7
Figure 2: Percentage of Duplicate Grant Subaward Records on
USAspending.gov 10
Figure 3: Impossibly Large Grant Subaward Amounts on
USAspending.gov 11
Figure 4: Inconsistent Subaward Descriptions on Select Grant
Subaward Records from USAspending.gov 13
Figure 5: Percent of Grant Subaward Records Submitted to the
Federal Funding Accountability and Transparency Act
(FFATA) Subaward Reporting System (FSRS) Later than
Required 15
Abbreviations
DATA Act Digital Accountability and Transparency Act of 2014
DEFC disaster emergency fund code
DUNS Data Universal Numbering System
FFATA Federal Funding Accountability and Transparency Act of
2006
FISCAM Federal Information System Controls Audit Manual
FSRS Federal Funding Accountability and Transparency Act of
2006 Subaward Reporting System
GSA General Services Administration
IAE Integrated Award Environment
IIJA Infrastructure Investment and Jobs Act
OIG Office of Inspector General
OMB Office of Management and Budget
PRAC Pandemic Response Accountability Committee
SAM System for Award Management
UEI unique entity identifier
USDA Department of Agriculture
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Page ii GAO-24-106237 Federal Spending Transparency
Letter
441 G St. N.W.
Washington, DC 20548
November 16, 2023
Congressional Committees
Congress has long highlighted the importance of making federal spending
information available to the public by passing laws that seek to increase
the transparency of federal spending. For example, the Federal Funding
Accountability and Transparency Act of 2006 (FFATA) required
information on federal awards to be made available to the public on
USAspending.gov. 1 The purpose of the Digital Accountability and
Transparency Act of 2014 (DATA Act) is to improve the quality of that
information by holding agencies accountable for the completeness and
accuracy of the data submitted, and enabling taxpayers and policy
makers to track where and how federal funds are spent. 2 The DATA Act
required the establishment of government-wide standards for financial
data, including for subawards—an award provided by a recipient to a
subrecipient to carry out part of a federal award. 3
Our prior work has identified a lack of reliable subaward data available on
USAspending.gov, including for grant subawards. 4 Ensuring the quality of
subaward data is important for enabling the public and policymakers to
track where and how federal funds are being spent. It is also important for
detecting and preventing fraud, waste, and abuse in federal spending, as
well as improper payments. This is critical during national emergencies,
such as the COVID-19 pandemic, when federal agencies must get relief
1Pub. L. No. 109-282, 120 Stat. 1186 (2006), codified at 31 U.S.C. § 6101 note.
2The DATA Act amended the Federal Funding Accountability and Transparency Act of
2006 (FFATA). Pub. L. No. 113-101, 128 Stat. 1146 (2014).
3A subaward is an award provided by a pass-through entity to a subrecipient to carry out
part of a federal award received by the pass-through entity. It does not include payments
to contractors or payments to an individual who is a beneficiary of a federal program. A
subaward may be provided through any form of legal agreement, including an agreement
that the pass-through entity considers a contract. 2 C.F.R. § 200.1. For the purposes of
this report, we use the term “grant subaward” to only cover subawards that are made
under federal grant awards. The term does not include subawards made under other
forms of federal financial assistance awards (i.e., loans) or subawards made under federal
contracts (subcontracts).
4In April 2023, we reported that the lack of reliable federal government subaward data
prohibited us from definitively identifying awards that went to certain entities in China. See
GAO, Federal Spending: Information on U.S. Funding to Entities Located in China,
GAO-23-105238 (Washington, D.C.: Apr. 12, 2023).
Page 1 GAO-24-106237 Federal Spending Transparency
funds out quickly while ensuring appropriate financial and other
safeguards are in place.
The CARES Act includes a provision for us to monitor and oversee funds
used to prepare for, respond to, and recover from the pandemic. 5 Since
its enactment in March 2020, we have made 386 recommendations to
federal agencies, including recommendations intended to increase the
transparency and accountability of federal COVID-19 response. This
report (1) assesses the quality of grant subaward data available on
USAspending.gov, including COVID-19-related awards; and (2) examines
the extent to which guidance governing subaward reporting supports the
quality of the subaward data available on USAspending.gov.
To assess the quality of grant subaward data available on
USAspending.gov, we conducted a series of tests on roughly 6 million
grant subaward records from October 1, 2010, through August 1, 2023.
We also reviewed documents that describe the process, timing, and
source systems of the subaward data displayed on USAspending.gov. In
addition, we met with officials from the General Services Administration
(GSA) and the Department of the Treasury—the agencies that administer
these systems—to confirm our understanding of the process flow and
data sources for subaward data. We also reviewed published reports from
the Pandemic Response Accountability Committee (PRAC) and federal
offices of inspectors general to identify challenges that could limit the
quality of subaward data available on USAspending.gov.
We also interviewed officials from agency grant-making offices from three
selected agencies—the Departments of Agriculture (USDA), Education,
and Interior—about their specific subaward experiences to identify system
and reporting challenges that could limit the quality of subaward data
available on USAspending.gov. We selected these agencies based on (1)
the amount of COVID-19 funding obligated between April 2020 and
September 2022 for awards that were tagged with a disaster emergency
fund code (DEFC) relative to the agency’s overall obligations; (2) the
agencies’ overall USAspending.gov data quality scores as assigned by
their respective inspectors general; (3) the number of subawards
associated with prime awards made by the agency in fiscal year 2022;
5Pub. L. No. 116-136, § 19010, 134 Stat. 281, 580 (2020). All of GAO’s reports related to
the COVID-19 pandemic are available on GAO’s website at
http://www.gao.gov/coronavirus.
Page 2 GAO-24-106237 Federal Spending Transparency
and (4) the number of awards made to Tribal, state, local, and territorial
governments in fiscal year 2022. 6
To assess the extent to which relevant guidance associated with
subaward reporting supports the quality of subaward data displayed on
USAspending.gov, we reviewed the legal framework that governs
subaward reporting and confirmed our understanding through interviews
with the Office of Management and Budget (OMB), GSA, and Treasury. 7
We compared relevant OMB guidance against federal internal control
standards. We also interviewed officials from USDA, Education, and
Interior to understand their roles in supporting subaward data quality, and
reviewed grant award documents from these selected agencies. See
appendix I for additional details about our objectives, scope, and
methodology.
We conducted this performance audit from September 2022 to November
2023 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
6COVID-19 obligations displayed on USAspending.gov include all covered funds as
defined in the CARES Act that have been tagged with a disaster emergency fund code
(DEFC), including DEFC “L” -PL 116-123, designated as emergency, DEFC “M” -PL 116-
127, designated as emergency, DEFC “N” -PL 116-136 (CARES Act), designated as
emergency, DEFC “O” -PL 116-136 (CARES Act), not designated as emergency. CARES
Act, Pub. L. No. 116-136, § 15011, 134 Stat. 281, 541 (2020). Inspectors General for 51
agencies reviewed and graded the overall quality of their agencies’ data submissions to
USAspending.gov (see GAO, OIGs Reported That Quality of Agency-Submitted Data
Varied, and Most Recommended Improvements, GAO-20-540 (Washington, D.C.: July 9,
2020)).
7Among others, we reviewed OMB guidance published in the Code of Federal Regulations
including parts 25, 170, and 200 of Title 2, Code of Federal Regulations. These parts are
contained in subtitle 2 and are considered OMB guidance. Federal agency regulations
implementing this OMB guidance may give regulatory effect to the guidance, to the extent
that the agency regulations require compliance with all or portions of the guidance. 2
C.F.R. § 1.105. For the purposes of this report, when we refer to “OMB guidance” we
include the guidance included in 2 C.F.R. parts 25, 170, and 200.
Page 3 GAO-24-106237 Federal Spending Transparency
Background
Overview of Subaward Federal agencies provide funding to non-federal entities, such as
Reporting nonprofit organizations, for public purposes through federal awards. 8
Assistance awards, also known as federal financial assistance awards,
allow entities to receive or administer assistance in the form of grants,
cooperative agreements, direct appropriations, or loans, among other
assistance. An entity can receive an assistance award from a federal
agency in the form of a prime grant award, or from a prime award
recipient through a subaward to carry out part of the work associated with
the original award. In the latter case, this entity is referred to as a first-tier
subaward recipient. First-tier subaward recipients, in turn, can pass on a
portion of the funds they receive to other subrecipients.
Prime recipients of grants are responsible for determining whether the
funds they pass through to other entities classify the recipient as a
contractor or grant subrecipient, in which case the funds are subject to
grant subaward reporting requirements. 9 The prime recipient’s
determination is based on the form of the agreement between the prime
recipient and the subrecipient.
Applicable Laws and Subaward reporting requirements for prime recipients of financial
Guidance Governing assistance awards are established in laws and further explained in OMB
guidance (see table 1).
Subaward Reporting
8A federal award means the federal financial assistance that a recipient receives directly
from a federal awarding agency or indirectly from a pass-through entity, or the cost-
reimbursement contract under the Federal Acquisition Regulations that a nonfederal entity
receives directly from a federal awarding agency or indirectly from a pass-through entity. A
federal award may also mean the instrument setting forth the terms and conditions, such
as the grant agreement, cooperative agreement, or other agreement for assistance.
9For the purpose of federal financial assistance, a contract means the legal instrument by
which a recipient or subrecipient purchases property or services needed to carry out the
project or program under a federal award. For the purpose of determining whether a
recipient is a contractor or subrecipient, a contract is for the purpose of obtaining goods
and services for the nonfederal entity’s own use and creates a procurement relationship
with the contractor. 2 C.F.R. § 200.1, 200.331(b).
Page 4 GAO-24-106237 Federal Spending Transparency
Table 1: Selected Federal Laws and Guidance for Reporting Subawards
Selected Laws Reporting Requirement(s)
Federal Funding Accountability and Establishes USAspending.gov and the requirement to publish data on grants, subgrants,
Transparency Act of 2006 (FFATA) – Pub. loans, awards, cooperative agreements, and other forms of financial assistance greater
L. No. 109-282, § 2(b) than $30,000.
Digital Accountability and Transparency Act Establishes standards for reporting government spending information, including
of 2014 (DATA Act) - Pub. L. No. 113-101 information on subawards.
Selected Guidance Reporting Requirement(s)
2 C.F.R. § 170.105 Applies certain subaward reporting requirements to grants, cooperative agreements,
loans, and other forms of federal financial assistance.
2 C.F.R. pt. 170 app. A(I)(a) Requires prime recipients to report each action that equals or exceeds $30,000 in
federal funds for a subaward to the FFATA Subaward Reporting System (FSRS), unless
otherwise exempt.a
2 C.F.R. pt. 170 app. A(I)(a) Requires prime award recipients to report subawards to FSRS by no later than the end
of the month after the month in which the subaward obligation was made.
2 C.F.R. § 200.331 Requires prime recipients to make a case-by-case determination whether each
agreement it makes for the disbursement of federal program funds casts the receiving
party in the role of a subrecipient or a contractor.
Source: GAO analysis of laws and guidance. | GAO-24-106237
Note: We reviewed OMB guidance published in the Code of Federal Regulations including parts 25,
170, and 200 of Title 2, Code of Federal Regulations. These parts are contained in subtitle 2 and are
considered OMB guidance. Federal agency regulations implementing the OMB guidance may give
regulatory effect to the OMB guidance to the extent that the agency regulations require compliance
with all or portions of the guidance. 2 C.F.R. § 1.105. For the purposes of this report, when we refer to
“OMB guidance,” we include the guidance included in 2 C.F.R. parts 25, 170, 200.
a
Effective November 12, 2020, the Office of Management and Budget (OMB) raised the first-tier
subaward reporting threshold for grants and cooperative agreements from $25,000 to $30,000 as part
of a revision to its guidance. See Guidance for Grants and Agreements, 85 Fed. Reg. 49506, 49526
(Aug. 13, 2020), codified at 2 C.F.R. pt. 170 App. A.
As shown in table 2, the current legal framework exempts some
subawards from being reported. For example, FFATA exempts any entity
that demonstrates its gross income from all sources did not exceed
$300,000 in the previous tax year from reporting subawards.
Table 2: Selected Exemptions from Requirements to Report Subawards
Laws and Guidance Reporting Exemption(s)
Federal Funding Prime recipients with less than $300,000 in gross income
Accountability and the previous year do not have to report subawards they
Transparency Act of 2006, make.
Pub. L. No. 109-282, § (2)(e)
2 C.F.R. § 170.220 Federal awards less than $30,000 do not have to be
reported.
2 C.F.R. § 170.110(b) Individuals who receive federal awards do not have to
report.
Page 5 GAO-24-106237 Federal Spending Transparency
Laws and Guidance Reporting Exemption(s)
2 C.F.R. § 170.110(c) The Office of Management and Budget (OMB) is
authorized to allow exceptions for classes of federal
awards or recipients subject to reporting requirements,
except when exceptions are prohibited by statute.
Source: GAO analysis of laws and guidance. | GAO-24-106237
Note: We reviewed OMB guidance published in the Code of Federal Regulations including parts 25,
170, and 200 of Title 2, Code of Federal Regulations. These parts are contained in subtitle 2 and are
considered OMB guidance. Federal agency regulations implementing the OMB guidance may give
regulatory effect to the OMB guidance to the extent that the agency regulations require compliance
with all or portions of the guidance. 2 C.F.R. § 1.105. For the purposes of this report, when we refer to
“OMB guidance,” we include the guidance included in 2 C.F.R. parts 25, 170, 200.
Sources of Grant Prime grant recipients report data elements including the subrecipient
Subaward Data Displayed unique entity identifier (UEI), subaward amount, subaward date, and a
description of the subaward’s purpose to FSRS. FSRS prepopulates
on USAspending.gov
information, such as the names and addresses of prime and
subrecipients, from the System for Award Management (SAM), which is
where prime and subrecipients originally register to do business with the
federal government. 10
As illustrated in figure 1, new and newly modified grant subaward data
are extracted from FSRS daily and made available to the public on
USAspending.gov. Prior to publication on the website, there are several
steps involving other government-wide award reporting systems that take
place before prime recipients can report subaward data to FSRS.
10See appendix II for a full list of subaward data elements reported on USAspending.gov.
Page 6 GAO-24-106237 Federal Spending Transparency
Figure 1: Process Overview of Federal Grant Subaward Data Displayed on USAspending.gov
a
UEIs replaced Data Universal Numbering System (DUNS) identification numbers as the entity
identifier required to do business with the federal government in 2022. Subrecipients are required to
have a UEI to receive pass-through funding.
b
The Data Broker is Treasury’s application for compiling information from agencies and from external
federal reporting systems, including from FSRS and SAM, for display on USAspending.gov.
While these different systems have different updating requirements,
Treasury’s Data Broker transfers updated subaward data to
USAspending.gov.
Prime grant recipients must have registered for a UEI in SAM before
receiving any federal funds. They must disclose their intent to pass on
part of the award to a subrecipient in their application for a federal grant
Page 7 GAO-24-106237 Federal Spending Transparency
or request prior written approval from the awarding federal agency. After
the prime grant recipient makes a subaward, it is required to report the
subaward to FSRS if the subaward meets the reporting thresholds
described above and no reporting exemptions apply. After logging into
FSRS, the prime recipient will find its prime grant award in the system,
which the system has prepopulated with existing USAspending.gov data.
The prime recipient will then create a subaward report under its prime
grant award. According to OMB guidance, subaward recipients have an
obligation to provide the prime recipient all information required for
reporting. 11 Once the prime recipient submits the grant subaward report,
Treasury’s Data Broker extracts the new or newly modified record from
FSRS to USAspending.gov daily, where it is available for public use.
Reporting Requirements Subawards funded under COVID-19 supplemental appropriations are
for Subawards Funded subject to the same subaward reporting requirements, exceptions, and
data entry processes as subawards from annual appropriations. The
under COVID-19
CARES Act also required prime recipients to submit quarterly reports to
Supplemental awarding agencies and the PRAC that includes information on
Appropriations subawards. 12 However, OMB guidance directed prime recipients to use
the existing subaward reporting process to meet the CARES Act reporting
requirements. The intent of this guidance was to reduce the
administrative burden of requiring recipients to report the same
information multiple times. 13
This same OMB guidance directed agencies to assign a disaster
emergency funding code to awards they make from COVID-19
supplemental appropriations to track pandemic spending. Subawards are
not assigned their own disaster emergency funding codes, but can be
identified as potential COVID-19 subawards if they are both successfully
linked to their associated prime award on USAspending.gov and that
prime award has been appropriately tagged with a disaster emergency
11OMB, Open Government Directive – Federal Spending Transparency and Subaward
and Compensation Data Reporting (Washington, D.C.: Aug. 27, 2010).
12Pub. L. No. 116-136, § 15011, 134 Stat. at 541.
13OMB, Implementation Guidance for Supplemental Funding Provided in Response to the
Coronavirus Disease 2019 (COVID-19), M-20-21 (Washington, D.C.: Apr. 10, 2020).
Page 8 GAO-24-106237 Federal Spending Transparency
funding code. 14 When a subaward is identified as a COVID-19 subaward
on USAspending.gov this way, it indicates that the subaward relates to a
prime grant that is funded, at least partially, from COVID-19
appropriations. It does not necessarily mean that the subaward was
funded from COVID-19 appropriations. 15
Our analysis of grant subaward records available on USAspending.gov
Opportunities Exist to identified several data quality challenges that affect the usefulness and
Improve the Quality transparency of the data. Some of these quality challenges could be
addressed through more robust data validations and updated guidance.
and Transparency of In addition, more information about the quality of grant subaward data
Grant Subaward Data displayed on USAspending.gov in proximity to where users are most
likely to interact with the data would also improve its usefulness and
Available on transparency.
USAspending.gov
Improved Data Entry We identified several anomalies and other data quality limitations with the
Validations and User roughly 6 million grant subaward records available on USAspending.gov
from October 1, 2010, to August 1, 2023. Specifically, we found:
Guidance Could Help
Address Grant Subaward • Duplicative grant subawards. Approximately 25 percent of grant
Data Quality Limitations subawards have characteristics that suggest they are duplicative of
other existing subaward records on USAspending.gov (see fig. 2). 16
We found that many of the likely duplicate grant subaward records on
USAspending.gov originate from a small portion of subaward records.
Specifically, we found that 279,798 individual grant subaward
14We recently found more than 10 million award records on USAspending.gov totaling
more than $1.2 trillion in obligations that were unlinked. As a result, these records did not
include DEFCs. Thus, we were unable to quantify how much of these award records were
funded from COVID-19 appropriations. We made one recommendation and raised two
matters for congressional consideration aimed to help improve data reporting. See GAO,
Federal Spending Transparency: Opportunities to Improve USAspending.gov Data,
GAO-24-106214 (Washington, D.C.: Nov. 7, 2023).
15In this product, we use the term “COVID-19 grant subawards” to refer to subawards
reported to USAspending.gov through FSRS that were made on or after April 1, 2020, and
are associated with a prime award that was given a DEFC to indicate that it received
pandemic funding.
16For this analysis, “duplicative grant subawards” are defined as grant subawards with the
exact same information in the following fields: Prime Award Identification, Subaward
Identification, Subawardee Unique Entity Identifier, Subawardee DUNS Number,
Subaward Amount, and Subaward Date. We did not review source records to confirm that
their records were definitively duplicative, but validated this approximation method with
GSA and Treasury officials.
Page 9 GAO-24-106237 Federal Spending Transparency
records—roughly 6.2 percent of all grant subaward records displayed
on USAspending.gov—were likely duplicated one or more times to
create the 1.5 million grant subaward records we identified as likely
duplicative. On average, these likely duplicated subaward records
were each duplicated five times. Additionally, we found 40 individual
grant subawards records on USAspending.gov that were likely
duplicated 100 or more times. A greater share of non-COVID-19 grant
subawards (26 percent) were likely duplicative compared to COVID-
19 grant subawards (11 percent).
Figure 2: Percentage of Duplicate Grant Subaward Records on USAspending.gov
Note: A “subaward” is an award provided by a pass-through entity to a subrecipient to carry out part
of a federal award. Grant subawards cover subawards that are made under federal grant awards. The
term does not include subawards made under other forms of federal financial assistance awards (i.e.,
loans) or subawards made under federal contracts (subcontracts). COVID-19 grant subawards refer
to subawards reported to USAspending.gov through the Federal Funding Accountability and
Transparency Act (FFATA) Subaward Reporting System (FSRS) that were made after April 1, 2020,
Page 10 GAO-24-106237 Federal Spending Transparency
and are associated with a prime award that was given a Disaster Emergency Funding Code to
indicate that it received pandemic funding.
• Impossibly high subaward amounts. Some grant subaward records
had impossibly high subaward amounts (see fig. 3). For example, we
found one subaward record on USAspending.gov with a subaward
amount of $1 quintillion, and five other grant subaward records with
amounts that exceeded the United States’ gross domestic product for
the year in which they were made. 17 Data from impossibly large
subaward records skew data graphics displayed on USAspending.gov
that show agency spending totals and spending over time, which can
affect its usefulness for the public and policy makers.
Figure 3: Impossibly Large Grant Subaward Amounts on USAspending.gov
• Transcribed data fields. We found some grant subawards records
(1,853) in which the reported subaward amount matched the numeric
17The Bureau of Economic Analysis estimates that the United States’ gross domestic
product in the second quarter of fiscal year 2023 was around $26.8 trillion.
Page 11 GAO-24-106237 Federal Spending Transparency
characters of another field in the record—such as the subaward
identification number—as demonstrated in some of the subawards in
figure 3. 18 These records with identical numeric values for their
subaward amount and identification numbers are not necessarily
errors because prime recipients could have assigned the records a
subaward identification number based on the award amount. 19
However, given the impossibly high dollar amounts for some of the
subaward records we observed—some totaling in the trillions of
dollars for a single subaward—it is likely that some of these records
are prime recipient reporting errors.
• Subaward amounts greater than prime awards amounts. We
found some grant subaward amounts that were larger than their
associated prime grant award amounts. Specifically, we found 25,260
of the roughly 6 million grant subaward records displayed on
USAspending.gov had subaward amount values that exceeded the
amount of the associated prime grant award. Moreover, we found
34,009 prime grant award records—about 14 percent of all the prime
grant awards with any associated grant subawards—where the
combined totals of all grant subawards associated with a prime grant
award exceeded the prime grant award amount. This finding suggests
that some of those subaward amounts were likely inaccurate. OMB
staff told us that, generally, an individual subaward amount should not
exceed the amount of its associated prime award, so it is likely, based
on our review, that these records contain reporting errors. For
example, GSA officials told us that a grant subaward could be funded
through multiple federal and nonfederal sources, and a prime recipient
may incorrectly report the total amount of funding rather than the
federal funding amount as required. However, GSA officials stated
there are some legitimate reasons why a prime recipient may report a
higher subaward amount than a prime award amount, such as when a
grant subaward is designed to be greater than the prime award
amount because of how the grant program’s funding is structured.
• Subaward descriptions not consistent with established
standards. We found some grant subaward data fields that were
inconsistent with the data standards established under OMB
guidance. Specifically, OMB guidance directs agencies to have
controls to assure that award description briefly describes the purpose
18For example, row three displays 4806294890002914 as the subaward ID, and
$4,806,294,890,002,914 as the subaward amount.
19Subawards do not have a system-generated identifier that is unique to a single
transaction to differentiate subawards from each other.
Page 12 GAO-24-106237 Federal Spending Transparency
of the award. 20 OMB guidance also specifies that the description
should be in plain language. 21 Based on our analysis of grant
subaward data on USAspending.gov, we found 148,271 of the roughly
6 million grant subaward records where the subaward award
descriptions had either five or fewer characters, no letters, no spaces,
or ended exactly at the 18,000-character maximum. These grant
subaward descriptions are not consistent with the standards because
they do not describe the purpose of the subaward in brief, plain
language. 22 See figure 4 for some examples of grant subaward
descriptions on USAspending.gov that were not consistent with data
standards.
Figure 4: Inconsistent Subaward Descriptions on Select Grant Subaward Records from USAspending.gov
20OMB, Appendix A to OMB Circular No. A-123, Management of Reporting and Data
Integrity Risk, OMB Memorandum M-18-16 (Washington, D.C.: June 6, 2018). See also
Federal Spending Transparency Data Standards (last updated October 25, 2021).
Available at: https://portal.max.gov/portal/assets/public/offm/DataStandardsFinal.htm.
21OMB M-20-21.
22The subaward description’s max field length is 18,000 characters. We have previous
work recommending that Treasury ensure that its documented DATA Act and
USAspending.gov guidance related to the maximum number of characters for
procurement and financial assistance award descriptions is consistent with established
policy. Treasury subsequently addressed this recommendation by updating guidance to
make it consistent with established policy for reporting award descriptions on
USAspending.gov. See GAO, Federal Spending Transparency: Opportunities Exist to
Further Improve the Information Available on USAspending.gov, GAO-22-104702
(Washington, D.C.: Nov. 8, 2021).
Page 13 GAO-24-106237 Federal Spending Transparency
• Subawards with incomplete data fields. Of the records we
reviewed that were available through USAspending.gov, we found
some that had some blank data fields. For example, we found that
1,705 of the nearly 6 million grant subaward records we reviewed
from USAspending.gov had blank fields for both the UEI and the
DUNS identification number. These fields help identify the entity that
received a subaward. 23
• Late subaward submissions. We found that more than 2.4 million of
the nearly 6 million grant subaward records had an FSRS submission
date that was later than the required deadline. 24 We found that prime
recipients reported non-COVID-19 grant subawards to FSRS late
more often than they did COVID-19 grant subawards (see fig. 5).
23See appendix II for full list of subaward data fields available on USAspending.gov.
24Subawards greater than or equal to $30,000 are required to be reported to FSRS by the
end of the month after the month in which the obligation was made. For example, if a
subaward is made in November, the subaward must be reported no later than the end of
the following December. 2 C.F.R. pt. 170, App. A.
Page 14 GAO-24-106237 Federal Spending Transparency
Figure 5: Percent of Grant Subaward Records Submitted to the Federal Funding
Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS)
Later than Required
Note: A “subaward” is an award provided by a pass-through entity to a subrecipient to carry out part
of a federal award. Grant subawards cover subawards that are made under federal grant awards. The
term does not include subawards made under other forms of federal financial assistance awards (i.e.,
loans) or subawards made under federal contracts (subcontracts). COVID-19 grant subawards refer
to subawards reported to USAspending.gov through Federal Funding Accountability and
Transparency Act Subaward Reporting System (FSRS) that were made after April 1, 2020, and are
associated with a prime award that was given a Disaster Emergency Funding Code to indicate that it
received pandemic funding.
GSA officials told us that they plan to address known reporting challenges
with FSRS, the website where prime recipients report subaward data to
USAspending.gov, as part of their plan to modernize several legacy
systems associated with the Integrated Award Environment (IAE) and the
SAM website. 25 While the time frame and project plan for modernizing
FSRS have not yet been developed, GSA officials told us that FSRS is
the next system they will modernize. However, they added that
modernizing FSRS or building a successor system could take several
25IAE is a government-wide initiative administered by GSA’s Federal Acquisition Service
within the Technology Transformation Services. This multiyear modernization effort plans
to integrate the capabilities, which existed in GSA’s portfolio of legacy systems, including
FSRS, into SAM.
Page 15 GAO-24-106237 Federal Spending Transparency
years once started. In addition to addressing known reporting challenges,
GSA officials stated that any successor site to FSRS would be developed
using an agile software development framework that should improve
navigation, make reporting requirements clearer, and reduce reporting
burden for prime recipients. 26 However, GSA officials were unable to
specify exactly how their modernization efforts would address the data-
quality challenges we observed, such as preventing prime recipients from
reporting impossibly high subaward amounts, or when these efforts would
begin.
While the current version of FSRS includes some built-in data entry tools,
such as mandatory data fields and data formatting checks, there are few
validation tests or warnings to alert prime recipients about potential data-
entry errors during the submission process. According to GSA officials,
FSRS has mandatory fields—which ensure that certain fields are
completed before prime recipients submit subaward records—and
automatic formatting checks. These mandatory fields ensure that the data
submitted in specific fields are in the appropriate type, such as numeric,
non-numeric, or date formats. GSA officials also stated that they have
controls to prevent prime recipients from editing the prepopulated data,
which FSRS sources from other government-wide reporting system, such
as SAM.
However, GSA officials stated that FSRS does not currently conduct
robust data validations—or automatic checks to detect likely errors or
omissions in the submitted data—that prime recipients report to FSRS.
GSA officials told us that the lack of robust validations is because they
initially developed FSRS to support the collection of subaward data for
federal spending transparency purposes and, by policy, all subaward data
reported in FSRS is displayed in USAspending.gov. These officials also
stated that GSA’s role, as FSRS’s administrator, is to ensure that
subaward data are captured, stored, and available for their intended use,
so they do not have the authority to edit the subaward data entered into
FSRS by prime recipients.
While prime recipients are primarily responsible for the quality of the
subaward data they submit, additional data validation tests could better
26Agile software development is characterized by iterative product development and
delivery; that is, development of software in iterations that are being continuously
evaluated on their functionality, quality, and customer satisfaction. For more information
on agile software development, see GAO, Agile Assessment Guide: Best Practices for
Agile Adoption and Implementation, GAO-20-590G (Washington, D.C.: Sept. 28, 2020).
Page 16 GAO-24-106237 Federal Spending Transparency
support data quality by flagging more potential errors prime award
recipients can correct before the subaward data are displayed on
USAspending.gov. For example, if a prime recipient entered a subaward
amount that exceeded the amount of the associated prime award, the
system could alert the prime recipient and ask the recipient to confirm
whether the amount they entered is correct.
GAO’s Federal Information System Controls Audit Manual (FISCAM)
highlights the importance of constructing robust controls within data
systems to ensure the quality of data collected. 27 Specifically, FISCAM
emphasizes the importance of designing and implementing user and
application controls to assure that data input into an information system
are complete, accurate, and valid. Generally, system owners should build
automatic checks directly into the application to limit the number of errors
that users input into an application. One of the purposes of the DATA Act
is to enable taxpayers and policy makers to effectively track federal
spending. Prime recipients could use these checks to help identify and
correct mistakes as they are reporting, such as impossibly large
subaward amounts or incorrect data. Without specific documented plans
in place for GSA to address known subaward data quality challenges,
these data quality limitations may persist, which would limit the
transparency and usefulness of subaward data to Congress, the public,
and federal agencies.
Likewise, prime recipients rely on the currently available guidance that
GSA provides to help them report data to the FSRS system. GSA
provides several online resources to prime recipients that use FSRS,
such as a Frequently Asked Questions page, a demonstration video, and
a downloadable user guide. GSA officials stated that they update the
downloadable user guides any time there are significant changes. For
example, GSA updated the user guide in March 2022 and April 2023 to
account for changes associated with the government-wide transition from
the DUNS identification number to UEI.
However, we found that the current directions for users do not address
many grant subaward data quality challenges on USAspending.gov, such
as duplicative grant subawards. Specifically, GSA and Treasury officials
stated that the duplication of subaward records on USAspending.gov is
most likely the result of prime recipient user error during the FSRS
27GAO, Federal Information System Controls Audit Manual, GAO-09-232G (Washington,
D.C.: Feb. 2, 2009).
Page 17 GAO-24-106237 Federal Spending Transparency
reporting process. For example, Treasury officials told us that prime
recipients could incorrectly believe that they have to maintain a running
total on FSRS for the same subaward rather than just reporting each
subaward action. This would result in the same record being submitted
multiple times, despite no changes being made to the award.
Additionally, GSA officials told us there is a feature in the FSRS system
intended to reduce prime recipient reporting burden by allowing prime
recipients to copy a previous subaward report when creating a new
subaward report. These officials stated that this function can be useful, for
example, if a prime recipient periodically awards subawards to a recipient
it works with regularly. However, if done incorrectly, officials told us that
this process could lead to the prime recipient copying the old report and
adding a new record to it without deleting the original report or changing
copied data in the new record before submitting it, which would result in
sending both the new and old subaward report to USAspending.gov as
new submissions.
GSA officials told us that in their role as the FSRS administrator, they are
not responsible for ensuring the quality of the subaward data or for
providing exhaustive reporting guidance for prime recipients. However,
GSA’s Data Quality Guidelines states that information published by an
agency must convey a sense of utility and objectivity, which means that it
is useful to its intended users, and is presented in an accurate, clear, and
complete manner. 28 In the absence of clear direction from GSA that
addresses known reporting errors, prime recipients may continue to
submit subaward data that are duplicative, inaccurate, and incomplete.
This, in turn, could lead users of the data to draw inaccurate conclusions
about where and how grant subawards are spent.
Additional Treasury Treasury discloses some subaward data quality challenges on
Disclosures on Subaward USAspending.gov, but opportunities exist to disclose additional
challenges, which would increase the usefulness of subaward data
Data Could Improve
available on USAspending.gov. Treasury, which administers
Transparency of Data USAspending.gov, publishes several online disclosures on the “About the
Available on Data” web page on USAspending.gov. Treasury describes two known
USAspending.gov issues with the quality of the published subaward data, including the
prevalence of duplicative subaward records and inconsistent reporting of
required subawards information. However, given the subaward data
28GSA’s Data Quality Guidelines can be found at
https://www.gsa.gov/reference/reports/information-quality-guidelines/data-quality-guideline
s. Accessed September 11, 2023.
Page 18 GAO-24-106237 Federal Spending Transparency
quality challenges we identified—such as impossibly large subaward
amounts, subaward records that were submitted after the required
reporting deadlines, and subawards with missing values for data fields—
additional disclosures to users would improve the transparency and
usefulness of subaward data available on the website.
Moreover, we also found that the disclosures on subaward data quality
currently available on USAspending.gov are not presented in close
proximity to where users are likely to interact with the data, so users may
be unaware of these data quality challenges. While Treasury provides
some information on subaward data quality on its “About the Data” page
and on the “Data Sources” page, the disclosures are not located or visible
for users on web pages where they are likely to search or view subaward
data, such as the “Advanced Search” or the “Data Download” web pages.
We previously reported that users of USAspending.gov reported
difficulties locating disclosures about data limitations on the website
because this information is typically unavailable on or near the pages
where users are searching for, or viewing, the data. 29 If users cannot
easily locate data limitation disclosures, they could inadvertently draw
inaccurate conclusions from the data. Adding the disclosures
themselves—or links to the disclosure web page—to the web pages
where users access subaward data could help users of the data better
understand potential quality issues with particular data elements, and how
to appropriately interpret the data. Treasury officials acknowledged that
they could make the disclosures for users more prominent and accessible
on web pages that include subaward data.
OMB guidance states that federal agencies are responsible for the
content they disseminate and should take affirmative steps to maximize
its quality, such as identifying, where appropriate, error sources affecting
the data quality. 30 OMB guidance also states that agencies should
optimize and organize online content to help the public find what they are
29GAO, Federal Spending Transparency: Opportunities Exist for Treasury to Further
Improve USAspending.gov’s Use and Usefulness, GAO-22-104127 (Washington, D.C.;
Dec. 16, 2021). We previously recommended that Treasury develop and implement
approaches to make known data limitation disclosures more prominent and easily
accessible to USAspending.gov users. In response, Treasury implemented several
website updates that significantly improved the prominence and accessibility of
information about known data limitations on USAspending.gov.
30See OMB, Delivering a Digital-First Public Experience, M-23-22 (Washington, D.C.:
Sept. 22, 2023), and Guidelines for Ensuring and Maximizing the Quality, Objectivity,
Utility, and Integrity of Information Disseminated by Federal Agencies, 67 Fed. Reg. 8452,
8459 (Feb. 22, 2002).
Page 19 GAO-24-106237 Federal Spending Transparency
looking for as efficiently as possible, with the fewest number of steps or
clicks. 31 Additionally, Treasury’s Information Quality Guidelines states that
when disseminating information to the public, information should be
presented within the proper context so that it is disseminated in an
accurate, clear, complete, and unbiased manner. 32 Until Treasury fully
and transparently discloses information about data quality limitations with
subaward data where users of the data will be aware of it, users of
USAspending.gov may draw inaccurate conclusions based on these data.
OMB guidance delineates agency responsibilities for communicating and
Guidance for monitoring prime award recipients’ subaward data reporting requirements.
Agencies on However, OMB guidance on agencies’ role in supporting the quality of the
subaward data prime award recipients report is unclear.
Supporting Subaward
Data Quality Is OMB guidance describes specific responsibilities for awarding agencies
to help ensure that prime recipients are aware of, and comply with,
Unclear certain subaward reporting requirements (see table 3). 33
31OMB M-23-22.
32Treasury’s Information Quality Guidelines can be found at
https://home.treasury.gov/department-of-the-treasury-information-quality-guidelines.
Accessed September 11, 2023. Treasury based these guidelines on OMB guidelines
published in the Federal Register on September 28, 2001, January 3, 2002, and February
22, 2002. Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and
Integrity of Information Disseminated by Federal Agencies, 66 Fed. Reg. 49718 (Sept. 28,
2001); Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and
Integrity of Information Disseminated by Federal Agencies, 67 Fed. Reg. 369 (Jan. 3,
2002); and Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and
Integrity of Information Disseminated by Federal Agencies; Republication, 67 Fed. Reg.
8452 (Feb. 22, 2002).
33For the purposes of this report, we did not assess whether selected agencies discussed
in this objective and their grant-making offices comply with applicable laws or follow the
relevant guidance for subaward reporting. Instead, we provide illustrative examples of how
selected agencies oversee and monitor prime recipients to ensure they report subaward
data.
Page 20 GAO-24-106237 Federal Spending Transparency
Table 3: Selected Office of Management and Budget (OMB) Guidance Delineating
Agency Responsibility for Subaward Reporting
Source Awarding Agency Oversight Responsibility
2 C.F.R. § 170.220 Include subaward reporting requirements in the award
terms for each grant award anticipated to equal or exceed
$30,000.
2 C.F.R. § 200.513(c) Follow up on findings from audits of award recipients to
ensure they take appropriate and timely corrective
action.a
2 C.F.R. § 200.339 Consider imposing additional conditions or taking
additional actions as appropriate if award recipients fail to
comply with the U.S. Constitution, federal statutes,
regulations, or the terms and conditions of a federal
grant.
Source: GAO analysis of guidance. | GAO-24-106237
Note: We reviewed OMB guidance published in the Code of Federal Regulations including parts 25,
170, and 200 of Title 2, Code of Federal Regulations. These parts are contained in subtitle 2 and are
considered OMB guidance. Federal agency regulations implementing the OMB guidance may give
regulatory effect to the OMB guidance, to the extent that the agency regulations require compliance
with all or portions of the guidance. 2 C.F.R. § 1.105. For the purposes of this report, when we refer to
“OMB guidance” we include the guidance included in 2 C.F.R. parts 25, 170, 200.
a
Nonfederal entities that expend $750,000 or more in federal awards in a fiscal year are subject to a
single audit or a program-specific audit for the fiscal year. 2 C.F.R. pt. 200, subpt. F.
Officials from each of the three agencies selected for our review provided
us with examples of steps they take to communicate and help ensure
prime recipients comply with their subaward reporting requirements. They
told us they include the requirement for prime grant award recipients to
report subaward data to FSRS in the terms and conditions of the prime
grant awards, and shared with us examples of the language they use in
grant agreements. They also said that if audit findings from their Offices
of Inspector General (OIG) or independent audit reports indicated that a
prime recipient was not in compliance with the subaward reporting
requirements, their agencies would work with the prime recipient to
develop plans on how to address these compliance issues. 34 Officials
from selected grant-making offices within our selected agencies shared
examples of audits that had identified issues with subaward reporting or
34Officials from our selected agencies told us they rely on these audits (which include
single audits) to identify noncompliance with requirements. The Single Audit Act is
codified, as amended, at 31 U.S.C. §§ 7501-06, and implementing OMB guidance is
reprinted in 2 C.F.R. part 200. Federal award recipients that expend $750,000 or more in
federal awards in a fiscal year are required to undergo a single audit, which is an audit of
an entity’s financial statements and federal awards, or a program-specific audit, for the
fiscal year. 31 U.S.C. § 7502; 31 C.F.R. § 200.501.
Page 21 GAO-24-106237 Federal Spending Transparency
issues with the prime recipient’s monitoring of the subrecipient, as well as
examples of them working to address subaward issues.
OMB has also issued guidance to agencies to support subaward data
quality, including that FSRS is the authoritative source of subaward data,
that prime recipients are responsible for the quality of these data, and that
agencies have responsibilities to implement processes to support
subaward data quality (see table 4).
Table 4: Selected Office of Management and Budget (OMB) Guidance to Agencies Related to Subaward Data Quality
OMB Memo M-15-12 Directs agencies to require that all recipients report subaward information by Federal
Award Identification Number into the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS).
OMB MPM-16-03 Stipulates that FSRS is the authoritative source for subaward information, and that
subaward data that prime award recipients report to FSRS will flow directly to
USAspending.gov with no additional actions required of agencies.
OMB Memo M-18-16 Specifies that prime recipients of federal awards are required to submit accurate data to
FSRS, and that the quality of these data are the legal responsibility of the recipients.
Establishes that agencies are not responsible for certifying the quality of subaward data
reported by prime award recipients to the General Services Administration and made
available on USAspending.gov.
OMB Memo M-21-20 Reminds agencies of their responsibilities to implement processes that support the
overall quality of subaward data, including actions agencies are expected to take when
recipients are noncompliant with reporting requirements.
OMB Memo M-22-12 Directs agencies to include an annual review of the quality of the financial assistance
subaward data quality for all programs in their DATA Act Data Quality plans.a
Directs agencies to implement processes that support the overall quality of subaward
data, including monitoring financial assistance recipient noncompliance with reporting
requirements and, when required, taking appropriate action.
Source: GAO analysis of OMB guidance. | GAO-24-106237
Note: A prime recipient is the entity that received a federal award from an awarding agency.
a
OMB Memorandum M-18-16 published on June 6, 2018, entitled “Appendix A to OMB Circular A-
123, Management of Reporting and Data Integrity Risk,” calls for a Digital Accountability and
Transparency Act of 2014 (DATA Act) data quality plan, among other requirements. The Data Quality
Plan should cover milestones and decisions related to organizational structure, management’s
responsibility to supply quality data and testing plan and identification of high-risk reported data, and
actions taken to manage identified risks. Agencies were directed to review the plans annually for 3
years or until the agency determines that sufficient controls are in place to achieve the reporting
objective.
Officials from our three selected agencies provided us with illustrative
examples of some actions they have taken to support subaward data
quality. These varied within and across agencies. For example, officials
from USDA told us they check USAspending.gov data monthly for
subaward amounts that exceed the associated prime award amount,
which may indicate a reporting error, and pass those findings on to the
Page 22 GAO-24-106237 Federal Spending Transparency
associated grant-making offices within the agency. Officials from
Education told us they provide technical assistance and training to help
prime recipients better understand reporting requirements and address
subaward reporting issues. Officials from USDA and Education told us
that these interventions could have led to a decrease in incidences of
likely duplicate reports. 35
Officials we spoke to from our selected agencies stated that OMB
guidance does not hold agencies responsible for the quality of subaward
data. Specifically, they cited guidance that states the quality of subaward
data is the legal responsibility of the prime recipient, and that agencies
are not responsible for certifying the quality of data reported by awardees
to GSA and made available on USAspending.gov. 36 Treasury officials we
spoke to also pointed to guidance that states FSRS is the authoritative
source for subaward information, and that data will continue to flow
directly from FSRS to USAspending.gov with no additional actions
required of agencies. 37 Treasury officials told us this guidance is one of
the reasons they typically do not contact agencies when they identify an
issue in subaward data, as they do not want to give agencies the
impression they are responsible for addressing the issue.
OMB staff told us that this guidance was written to assure agencies that
they are not legally responsible for the quality of subaward data that
prime recipients report, and that no additional actions were needed from
agencies for reporting subaward data to USAspending.gov as a result of
new provisions in the DATA Act. OMB staff also told us the intent of this
guidance was not to absolve agencies of their responsibilities to ensure
that prime recipients comply with their reporting requirements, nor was
the directive that agencies are not required to certify subaward data
quality meant to establish that agencies should take no actions to support
subaward reporting or data quality.
However, current OMB guidance is unclear on what processes agencies
are expected to implement to support subaward data quality. Specifically,
OMB M-21-20 reminds agencies of their responsibilities to implement
processes that support the overall quality of subaward data, including
actions agencies are expected to take when recipients are not compliant
35The rate of grant subawards we identified as likely duplicates decreased from 48
percent in fiscal year 2011 to 12 percent in fiscal 2022.
36OMB M-18-16.
37OMB M-16-03.
Page 23 GAO-24-106237 Federal Spending Transparency
with reporting requirements. 38 OMB M-22-12 also directs agencies to
implement processes that support the overall quality of subaward data,
including monitoring financial assistance recipient non-compliance with
reporting requirements and, when required, taking appropriate action. 39
However, this guidance does not provide specific detail on what additional
processes, beyond taking appropriate action when noncompliance is
identified, OMB expects agencies to implement to support subaward data
quality.
Likewise, OMB staff told us that while there is no requirement for
awarding agencies to proactively monitor whether each prime grant
award recipient is reporting subaward data, agencies should monitor
prime recipient noncompliance with reporting requirements for financial
assistance awards. OMB staff told us that this responsibility to monitor
noncompliance with reporting requirements is based on provisions in the
Uniform Guidance that agencies consider taking action when
noncompliance is identified. 40 OMB staff told us that the implication of
being directed to appropriately address noncompliance when it is found is
that agencies should be checking for noncompliance.
However, OMB’s guidance does not make it clear whether OMB intends
for agencies’ role in supporting subaward data quality to be limited to
addressing noncompliance whenever it is found, such as through
independent audits, or if OMB intends for federal agencies to support
38This memorandum also emphasizes the importance of subaward reporting. It notes that
OMB included this topic in its 2020 Compliance Supplement Addendum as one of the
areas auditors are required to review in COVID-19 grants and cooperative agreement
programs, and that OMB plans to include this topic in future compliance supplements.
OMB’s Compliance Supplements are guidance for auditors, such as those conducting
Single Audits, and contain information on what information should be reviewed as a part of
those audits.
39OMB issued this memorandum to provide guidance to agencies with responsibilities for
implementing the Infrastructure Investment and Jobs Act (IIJA) programs. OMB staff told
us that the direction to agencies to implement processes that support the overall quality of
subaward data was applicable broadly to include agencies with no responsibilities
implementing IIJA programs. Moreover, OMB staff stated that they included this language
in the IIJA implementing guidance because they believed agencies needed a reminder
about their role to implement processes to support subaward data quality. OMB,
Advancing Effective Stewardship of Taxpayer Resources and Outcomes in the
Implementation of the Infrastructure Investment and Jobs Act, M-22-12 (Washington,
D.C.: Apr. 29, 2022).
40If a nonfederal entity fails to comply with the U.S. Constitution, federal statutes,
regulations, or the terms and conditions of a federal award, the federal awarding agency
or pass-through entity may impose additional conditions, as described in 2 C.F.R. §
200.208. 2 C.F.R. § 200.339.
Page 24 GAO-24-106237 Federal Spending Transparency
subaward data quality through more proactive interventions and
processes, such as monitoring compliance, reviewing reporting data, and
conducting trainings.
Federal internal control standards highlight the importance of
communicating quality information to achieve objectives. We have
previously reported on the importance of clear guidance. 41 Without clear
expectations from OMB on agencies’ role in supporting subaward data
quality, agencies may not consistently or adequately support prime
recipients’ submission of quality subaward data. This, in turn, could result
in missed opportunities to improve the transparency and usability of
federal subaward spending data available to public.
Improving the quality of subaward data on USAspending.gov is an
Conclusions important step toward fulfilling the DATA Act’s purpose to increase the
quality and transparency of federal spending data available to the public.
Addressing known reporting challenges that limit data quality by
improving data entry validations, providing more user guidance, clearly
disclosing known data challenges, and clarifying federal agency
responsibility for supporting the quality of subaward data submitted by
prime recipients would further contribute to greater federal spending
transparency. Addressing these challenges will help advance the DATA
Act’s purpose of making quality federal spending data available to enable
taxpayers and policy makers to track federal spending more effectively.
Quality subaward data will also help detect and prevent fraud, waste and
abuse in federal spending, and improper payments, which is particularly
important during national emergencies such as the COVID-19 pandemic.
We are making a total of four recommendations, including two to GSA,
Recommendations for one to Treasury, and one to OMB. Specifically:
Executive Action
The Administrator of GSA should incorporate automated data validations
or other controls that will address known FSRS data quality limitations,
such as incorrect award amount entries, into the design and development
plan for modernizing FSRS or for a successor system (Recommendation
1).
41GAO, VA Disability Exams: Actions Needed to Clarify Program Requirements Regarding
Examiners, GAO-23-105787 (Washington, D.C.: June 15, 2023), and Standards for
Internal Control in the Federal Government, GAO-14-704G (Washington, D.C.: Sept. 10,
2014).
Page 25 GAO-24-106237 Federal Spending Transparency
The Administrator of GSA should provide additional guidance to help
prime recipients improve the quality of their subaward data submissions,
such as actions to prevent duplicative reporting (Recommendation 2).
The Secretary of the Treasury should disclose additional subaward data
quality limitations on the USAspending.gov pages where users search for
or view subaward data (Recommendation 3).
The Director of OMB should clarify its expectations for agencies to
support the quality of subaward data reported by prime recipients
(Recommendation 4).
We provided a draft of this report to USDA, Education, GSA, Interior,
Agency Comments OMB, and Treasury for review and comment. GSA and Treasury
concurred with our recommendations. Education and Treasury also
provided technical comments, which we incorporated as appropriate.
GSA and Treasury also provided written comments, which are
reproduced in appendix III and IV, respectively. USDA, Interior, and OMB
did not have any comments on this report.
We are sending copies of this report to relevant congressional
committees; the Secretary of the Treasury; the Director of the Office of
Management and Budget; the Administrator of the General Services
Administration; the Secretary of Agriculture; the Secretary of the Interior;
and the Secretary of Education. In addition, the report is available at no
charge on the GAO website at http://www.gao.gov.
If you or your staff have questions about this report, please contact me at
(202) 512-6806 or ArkinJ@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. GAO staff who made key contributions to this report are
listed in appendix V.
Jeff Arkin
Director, Strategic Issues
Page 26 GAO-24-106237 Federal Spending Transparency
List of Committees
The Honorable Patty Murray
Chair
The Honorable Susan Collins
Vice Chair
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Bernard Sanders
Chair
The Honorable Bill Cassidy, M.D.
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rand Paul, M.D.
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Kay Granger
Chairwoman
The Honorable Rosa L. DeLauro
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Cathy McMorris Rodgers
Chair
The Honorable Frank Pallone, Jr.
Ranking Member
Committee on Energy and Commerce
House of Representatives
Page 27 GAO-24-106237 Federal Spending Transparency
The Honorable Mark E. Green, M.D.
Chairman
The Honorable Bennie G. Thompson
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable James Comer
Chairman
The Honorable Jamie Raskin
Ranking Member
Committee on Oversight and Accountability
House of Representatives
The Honorable Jason Smith
Chairman
The Honorable Richard Neal
Ranking Member
Committee on Ways and Means
House of Representatives
Page 28 GAO-24-106237 Federal Spending Transparency
Appendix I: Objectives, Scope, and
Appendix I: Objectives, Scope, and
Methodology
Methodology
This report (1) assesses the quality of grant subaward data available on
USAspending.gov, including COVID-19-related awards; and (2) examines
the extent to which guidance governing subaward reporting support the
quality of the subaward data available on USAspending.gov.
To assess the quality of grant subaward data available on
USAspending.gov, including COVID-19-related awards, we conducted a
series of tests on grant subaward data that were available to be
downloaded from USAspending.gov. We downloaded all of the nearly 6
million reported grant subaward records available in March 2023 for a
preliminary analysis to guide our investigation, and later re-ran similar
tests (adding and excluding some analyses based on our preliminary
findings) with more recent data in August 2023. This second analysis was
limited to grant subaward records reported in fiscal year 2011 and later,
as the requirement to report subaward data to USAspending.gov via the
Federal Funding Accountability and Transparency Act of 2006 (FFATA)
Subaward Reporting System (FSRS) took effect on October 1, 2010.
In our analysis, we compared the subaward action date (the date the
award was made) to the subaward report date (the date the award was
reported in FSRS). Subawards are required to be reported to FSRS by
the end of the month following the month in which the award was made.
Thus, we could assess how frequently the records on USAspending.gov
met, or did not meet, that requirement. We also tested how many
subawards records had blank cells for several required fields. In addition,
we designed a test for the subaward award description field to identify
records in which the field was not blank, but likely did not meet the
standard of being a brief description of the award (such as having fewer
than five characters or containing no letters). We reviewed the data to
identify some instances of obvious errors in the data available. We did not
have the underlying source records to compare to the USAspending.gov
data, so we could not compare reported values to authoritative sources.
Instead, we identified illustrative examples of instances in which the
subaward data were likely inaccurate. This included subawards with
amounts larger than their associated prime grant awards, subawards that
had the exact same award identification number and award amount, and
subawards with reported award amounts too large to be possible.
We also reviewed documents that describe the process, timing, and
source systems of the subaward data displayed on USAspending.gov and
met with officials from the General Services Administration (GSA) and the
Department of the Treasury—the agencies that administer these
Page 29 GAO-24-106237 Federal Spending Transparency
Appendix I: Objectives, Scope, and
Methodology
systems—to confirm our understanding of the process flow and data
sources for subaward data.
In addition, we reviewed published reports from the Pandemic Response
Accountability Committee and federal agency Offices of Inspector
General (OIG) in order to describe and provide additional insight into the
challenges that could affect the quality of subaward data made available
to the public through USAspending.gov.
To examine the extent to which guidance governing subaward reporting
support the quality of the subaward data available on USAspending.gov,
we reviewed the legal framework that governs subaward reporting. We
also reviewed guidance that directs awarding agencies and recipients
about their subaward reporting responsibilities. We met with GSA and
Treasury officials to discuss their roles in subaward data administration
and met with Office of Management and Budget (OMB) staff to discuss
relevant subaward reporting guidance OMB has issued. We compared
relevant OMB guidance against federal internal control standards. We
determined that the information and communication component of
Standards for Internal Control in the Federal Government—specifically
the underlying principles that management should externally
communicate the necessary quality information to achieve their
objectives—were significant to this objective. 1
We also selected three federal grant-making agencies to provide us with
their experiences with subaward reporting and data based on (1) the
amount of COVID-19 funding obligated between April 2020 and
September 2022 for awards that were tagged with a disaster emergency
fund code (DEFC), relative to the agency’s overall obligations; (2)
agencies overall USAspending.gov data quality score as assigned by
their respective OIG; (3) the number of subawards associated with prime
awards made by the agency in fiscal year 2022; and (4) the number of
awards made to Tribal, state, local, and territorial governments in fiscal
1GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: Sept. 10, 2014).
Page 30 GAO-24-106237 Federal Spending Transparency
Appendix I: Objectives, Scope, and
Methodology
year 2022. 2 The three grant-making agencies—the Departments of
Agriculture, Education, and the Interior—were selected to provide a range
of experiences within each of these selection criteria.
We interviewed grant-making officials from the three selected agencies
about their specific subaward experiences to identify system and
reporting challenges that could limit the quality of subaward data. We
reviewed subaward data, grant award documents, and audit findings
specific to these agencies. We also chose three programs that each
selected agency administers that received pandemic funding based on
the low number of subawards reported to USAspending.gov for prime
grant awards that received pandemic funding under those programs. We
requested that the grant-making offices that administer those programs
provide us additional data and context on the subawards made under
those programs. For the purposes of this report, we did not assess
whether selected agencies and their grant-making offices complied with
applicable laws or followed the relevant guidance for subaward reporting.
Instead, we provided illustrative examples of how selected agencies
oversee and monitor prime recipients to ensure they report subaward
data. We did review whether some USAspending.gov data submissions
broadly complied with certain reporting guidance.
We conducted this performance audit from September 2022 to November
2023 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
2COVID-19 obligations displayed on USAspending.gov include all covered funds as
defined in the CARES Act that have been tagged with a disaster emergency fund code
(DEFC) including DEFC “L” -PL 116-123, designated as emergency, DEFC “M” -PL 116-
127, designated as emergency, DEFC “N” -PL 116-136 (CARES Act), designated as
emergency, DEFC “O” -PL 116-136 (CARES Act), not designated as emergency. CARES
Act, Pub. L. No. 116-136, § 15011, 134 Stat. 281, 541 (2020). Inspectors General for 51
agencies reviewed and graded the overall quality of their agencies’ data submissions to
USAspending.gov (see GAO, OIGs Reported That Quality of Agency-Submitted Data
Varied, and Most Recommended Improvements, GAO-20-540 (Washington, D.C.: July 9,
2020)).
Page 31 GAO-24-106237 Federal Spending Transparency
Appendix II: Subaward Data Elements on Appendix II: Subaward Data Elements on
USAspending.gov
USAspending.gov
Table 5: Subaward Data Elements on USAspending.gov
Data element Description Source
Subaward Identification Information
Subaward type The type of subaward (either contract subaward or grant subaward) Entered into the Federal
Funding Accountability and
Transparency Act (FFATA)
Subaward Reporting System
(FSRS) by Prime Recipient
Subaward number A non-unique identifying number assigned by the prime awardee Entered into FSRS by Prime
organization to facilitate the tracking of its subawards Recipient
Subaward FSRS report The year in which a given report in FSRS was published by the prime FSRS System Generated
year awardee
Subaward FSRS report The month in which a given report in FSRS was published by the prime FSRS System Generated
month awardee
Subaward FSRS report Unique 32-character identifier for a report in FSRS that can be used to FSRS System Generated
Identification easily navigate to the report within that system
Subaward Obligation Dollar Value
Subaward amount The total amount being awarded to the subaward recipient Entered into FSRS by Prime
Recipient
Subaward Dates
Subaward action date The date the action being reported was issued and signed by the Entered into FSRS by Prime
government, or a binding agreement was reached Recipient
Subaward Recipient Information
Subawardee Unique Entity The UEI for the subaward recipient Entered into FSRS by Prime
Identifier (UEI) Recipient
Subawardee name The name of the subaward recipient that relates to the subaward Derived from subawardee UEI
recipient unique identifier (pulled from the System for
Award Management (SAM))a
Subawardee doing The doing business as name of the contractor address Derived from subawardee UEI
business as name (pulled from SAM)a
Subawardee parent UEI The UEI for the ultimate parent entity of a subaward recipient Derived from subawardee UEI
(pulled from SAM)a
Subawardee parent name The name of the ultimate parent entity of the subaward recipient Derived from parent UEI
(pulled from SAM)a
Subawardee country name The name corresponding to the country code Derived from subawardee UEI
(pulled from SAM)a
Subawardee country code Code for the country in which the awardee or recipient is located, using Derived from subawardee
the International Standard for country codes country name
Subawardee address line First line of the awardee or recipient’s legal business address where the Derived from subawardee UEI
office represented by the UEI is located (pulled from SAM)a
Subawardee city name Name of the city in which the awardee or recipient’s legal business Derived from subawardee UEI
address is located (pulled from SAM)a
Subawardee state name State where the awardee or recipient is located Derived from subawardee UEI
(pulled from SAM)a
Page 32 GAO-24-106237 Federal Spending Transparency
Appendix II: Subaward Data Elements on
USAspending.gov
Data element Description Source
Subawardee state code United States Postal Service (USPS) two-letter abbreviation for the Derived from subawardee UEI
state or territory in which the awardee or recipient’s legal business (pulled from SAM)a
address is located
Subawardee zip code USPS zoning code Derived from subawardee UEI
(pulled from SAM)a
Subawardee congressional The congressional district in which the awardee or recipient is located Derived from subawardee UEI
district (pulled from SAM)a
Subawardee foreign postal For foreign recipients only: foreign postal code in which the awardee or Derived from subawardee UEI
code recipient’s legal business address is located (pulled from SAM)a
Subawardee business Comma separated list representing subrecipient business types Derived from subawardee UEI
types (pulled from SAM)a
Subaward Place of Performance
Subaward primary place of The name of the city where the predominant performance of the Entered into FSRS by Prime
performance city name subaward will be accomplished Recipient
Subaward primary place of The name of the state or territory where the predominant performance Entered into FSRS by Prime
performance state name of the subaward will be accomplished Recipient
Subaward primary place of USPS two-letter abbreviation for the state or territory indicating where Derived from primary place of
performance state code the predominant performance of the subaward will be accomplished performance state name
Subaward primary place of United States ZIP code (five digits) linked with the additional +4 digits, Entered into FSRS by Prime
performance address zip identifying where the predominant performance of the subaward will be Recipient
code accomplished
Subaward primary place of United States congressional district where the predominant Derived from primary place of
performance congressional performance of the subaward will be accomplished performance zip code
district
Subaward primary place of Name of the country represented by the country code where the Entered into FSRS by Prime
performance country name predominant performance of the subaward will be accomplished Recipient
Subaward primary place of Country code where the predominant performance of the subaward will Derived from primary place of
performance country code be accomplished performance country name
Key Subaward Information
Subaward description A brief description of the purpose of the award Entered into FSRS by Prime
Recipient
Subawardee Executive Compensation Information
Subawardee highly The name of an individual identified as one of the five most highly Derived from subawardee UEI
compensated officer name compensated “Executives” (pulled from SAM)a
Subawardee highly The cash and noncash dollar value earned by the one of the five most Derived from subawardee UEI
compensated officer highly compensated “Executives” during the subawardee’s preceding (pulled from SAM)a
amount fiscal year
Transaction Information
Subaward FSRS report last The last modified date captures the change date FSRS System Generated
modified date
Source: GAO Analysis of Department of the Treasury and FSRS documentation. | GAO-24-106237
a
According to GSA officials, subrecipients do not have to complete the SAM registration process
beyond getting a UEI number. In these cases, FSRS cannot prepopulate data from other government
systems, such as SAM, and the prime recipient must complete those sections of the report manually
to complete the report for submission.
Page 33 GAO-24-106237 Federal Spending Transparency
Appendix III: Comments from the General
Appendix III: Comments from the General
Services Administration
Services Administration
Page 34 GAO-24-106237 Federal Spending Transparency
Appendix III: Comments from the General
Services Administration
Page 35 GAO-24-106237 Federal Spending Transparency
Appendix IV: Comments from the
Appendix IV: Comments from the Department
of the Treasury
Department of the Treasury
Page 36 GAO-24-106237 Federal Spending Transparency
Appendix V: GAO Contact and Staff
Appendix V: GAO Contact and Staff
Acknowledgments
Acknowledgments
Jeff Arkin, (202) 512-6806 or arkinj@gao.gov
GAO Contact
In addition to the contact named above, Kathleen M. Drennan (Assistant
Staff Director), Samuel A. Gaffigan (Analyst-in-Charge), Elise K. Beisecker,
Acknowledgments Virginia A. Chanley, Ann Czapiewski, Samantha Lalisan, Amalia Konstas,
Jennifer M. Stavros-Turner, and Christopher Woika made key
contributions to this report.
Page 37 GAO-24-106237 Federal Spending Transparency
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