NASACT Member Input Needed on GREAT Act

NASACT was recently asked to comment on legislation established to create and require federal grant recipients to use data standards to report information to the federal government on grants they receive. The legislation, entitled the Grant Reporting Efficiency and Agreements Transparency Act of 2018 (GREAT Act) was introduced on January 29 and is a continuation of the vision enmeshed in the DATA Accountability and Transparency Act (DATA Act), which required the federal government to utilize data standards for spending information. NASACT is interested in gathering information on potential pitfalls and/or areas of concern that can be shared with Congressional staff.
 
The GREAT Act directs the executive branch to adopt a standardized data structure for the information grantees must report to agencies by:

• Requiring the creation of a comprehensive and standardized data structure, or “taxonomy,” covering all data elements reported by recipients of federal awards, including both grant and cooperative agreements.
• Tasking the director of the U.S. Office of Management and Budget to designate a standard setting agency with implementation.

1. Within one year: Establish government-wide data standards for information related to federal awards reported by recipients of federal awards.
2. Within two years: Issue guidance to grantmaking agencies on how to leverage new technologies and implement the new data standards into existing reporting practices with minimum disruption.

• Requiring the adoption of unique and non-proprietary identifiers for federal awards and entities receiving federal awards.
• Amending the Single Audit Act to provide for grantee audits to be reported in an electronic format consistent with the data standards.
• Requiring the data standards to:

1. Render grant reports fully searchable, machine-readable, and non-proprietary.
2. Align with standards maintained by voluntary consensus bodies.
3. Be consistent with applicable accounting principles.
4. Incorporate the data standards already established for federal spending information under the Digital Accountability and Transparency Act (P.L. 101-133).

• Publish grant reporting information, once transformed into open data, on a government-wide website, such as the existing grants.gov portal.
• Providing exceptions and restrictions:

1. No personally-identifiable or otherwise sensitive information will be published.
2. Information not subject to disclosure under the Freedom of Information Act (Title 5, Section 552) will not be publicly disclosed.
3. The OMB director to permit exceptions on a case-by-case basis.

• Requiring each grantmaking agency to begin collecting grant reports using the new data standards within three years.” 

​Although NASACT has received limited comments on the initial draft legislation from members of NSAA’s Single Audit Committee, we are now seeking feedback from the entire NASACT membership.  
 
Please provide any comments you may have, including areas that may be overly burdensome, or which may be difficult to comply, as soon as possible, but no later than COB on March 2 so that we may compile the information and discuss the comments with legislative staff. Comments may be sent to Cornelia Chebinou. Questions may be directed to Cornelia at (202) 624-5451.