We recommend that the SAO and EXIM’s DATA Act Working Group develop, test, and implement a DQP that covers significant milestones and major decisions pertaining to: • Organizational structure and key processes providing internal control activities for spending reporting; • Management’s responsibility to supply quality data to meet the reporting objectives for the DATA Act in accordance with OMB Circular No. A-123; • EXIM’s testing plan and identification of high-risk reported data, including: (1) specific data the agency determines to be high-risk that are explicitly referenced by the DATA Act; and (2) confirmation that these data are linked through the inclusion of the award identifier in the agency’s financial system, and reported with plain English award descriptions; and • Actions taken to manage identified risks.