Independent Auditors’ Report on EXIM’s Data Act Submission

Submitting OIG:

Export-Import Bank OIG

Date Issued:

Monday, November 8, 2021

Agency Reviewed / Investigated:

Export-Import Bank

Submitting OIG-Specific Report Number:

OIG-AR-22-01

Location(s):

Agency-Wide

Type of Report:

Audit

Questioned Costs:

Funds for Better Use:

Number of Recommendations:

View Document:

Attachment	Size
Final-Independent-Auditors-Report-EXIM-DATA-Act-Submission-OIG-AR-22-01-508.pdf	2.93 MB

Recommendation Number	Recommendation Status	Significant Recommendation
1	Open	No
We recommend that the SAO and EXIM’s DATA Act Working Group determine the root cause of the errors in EXIM-provided data identified during the testing of the second quarter FY 2021 Files D1 and D2, and take necessary corrective action to: (a) correct the errors for records shown in USASpending.gov; (b) identify the risk of reporting incorrect data for each data element containing the error; and (c) update the policies and procedures for recording data in Comprizon, FPDS, and FABS to address the risks and include adequate verification and validation review processes performed by the data owner and a supervisor or other independent party.
2	Open	No
We recommend that the SAO and EXIM’s DATA Act Working Group continue to improve the design of its review of the procurement award data in FPDS and financial assistance award data submissions to FABS by identifying the root cause for the exceptions in those data elements for which EXIM is responsible, and by developing more effective review procedures for those data elements, as well as the data elements that the SAO and DATA Act Working Group identify as having a high risk of not being accurate, complete, or reported timely.
3	Open	No
We recommend that the SAO and EXIM’s DATA Act Working Group review EXIM’s policies and procedures for submitting contract award data in FPDS, including procedures for reviewing and confirming the accuracy of the CAR, to ensure proper design and compliance with FAR guidelines for timeliness. Update the policies and procedures based on this review, as necessary, to ensure EXIM meets FAR timeliness guidelines.
4	Open	No
We recommend that the SAO and EXIM’s DATA Act Working Group review EXIM’s policies and procedures that address timelines for submitting complete and accurate FABS files containing financial assistance award data, to ensure proper design and compliance with DAIMS guidance. Update the policies and procedures based on this review, as necessary, to ensure EXIM meets DAIMs timeliness guidelines.
5	Open	No
We recommend that the SAO and EXIM’s DATA Act Working Group complete a data inventory for File D1 that defines each data element based on government-wide financial data standards, and that EXIM seeks clarification from OMB and Treasury, as necessary, in order to ensure appropriate interpretation of the DATA Act Standards.
6	Open	No
We recommend that the SAO and EXIM’s DATA Act Working Group establish policies and procedures to help ensure that all data reported in FABS and included in EXIM’s certified File D2 are reported as intended by the Data Act Standards, and that EXIM seek clarification from OMB and Treasury, if necessary, in order to ensure appropriate interpretation of the Data Act Standards.
7	Open	No
We recommend that the SAO and EXIM’s DATA Act Working Group complete a data inventory for each of Files A through D1 to govern EXIM’s DATA Act activities and help ensure compliance with government-wide financial data standards.
8	Open	No
We recommend that the SAO and EXIM’s DATA Act Working Group develop and document a review process of the data inventories for Files A through D2 that EXIM will perform at regular intervals and after each DAIMS update.
9	Open	No
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.
10	Open	No
We recommend that the SAO in coordination with the OCFO continue to implement its corrective action plan to ensure that object class codes are accurately and completely reported in all financial and award data submissions (Files B and C).

Recommendation Number

Recommendation Status

Significant Recommendation

Additional Details

Open

We recommend that the SAO and EXIM’s DATA Act Working Group determine the root cause of the errors in EXIM-provided data identified during the testing of the second quarter FY 2021 Files D1 and D2, and take necessary corrective action to: (a) correct the errors for records shown in USASpending.gov; (b) identify the risk of reporting incorrect data for each data element containing the error; and (c) update the policies and procedures for recording data in Comprizon, FPDS, and FABS to address the risks and include adequate verification and validation review processes performed by the data owner and a supervisor or other independent party.

Open

We recommend that the SAO and EXIM’s DATA Act Working Group continue to improve the design of its review of the procurement award data in FPDS and financial assistance award data submissions to FABS by identifying the root cause for the exceptions in those data elements for which EXIM is responsible, and by developing more effective review procedures for those data elements, as well as the data elements that the SAO and DATA Act Working Group identify as having a high risk of not being accurate, complete, or reported timely.

Open

We recommend that the SAO and EXIM’s DATA Act Working Group review EXIM’s policies and procedures for submitting contract award data in FPDS, including procedures for reviewing and confirming the accuracy of the CAR, to ensure proper design and compliance with FAR guidelines for timeliness. Update the policies and procedures based on this review, as necessary, to ensure EXIM meets FAR timeliness guidelines.

Open

We recommend that the SAO and EXIM’s DATA Act Working Group review EXIM’s policies and procedures that address timelines for submitting complete and accurate FABS files containing financial assistance award data, to ensure proper design and compliance with DAIMS guidance. Update the policies and procedures based on this review, as necessary, to ensure EXIM meets DAIMs timeliness guidelines.