Sheila Conley: Enterprise risk management properly implemented could strengthen decision making

Sheila Conley, deputy assistant secretary and deputy chief financial officer at the Department of Health and Human Services, is one of 50 new fellows for the National Academy of Public Administration.

How will you use your NAPA fellowship to promote/influence good government?

NAPA provides a unique opportunity to engage with a wide range of fellows, who are knowledgeable and experienced in government management and policy matters.

I am looking forward to tapping into the collective expertise and wisdom of the fellows to help inform and advance the business portfolio at HHS while also participating in efforts to address pressing governmentwide issues, such as reducing improper payments and enhancing program integrity.  It is more important than ever to champion good government initiatives and best practices, many of which can be gleaned from NAPA reports and studies.

What do you think is the most important change the government needs to make in the next 5 years?

Enterprise risk management (ERM) is an emerging discipline in the federal government that, if properly implemented could strengthen agency decision-making, performance and ability to accomplish mission goals.  ERM challenges agencies to develop a risk aware culture, identify and prioritize enterprise risks and establish a risk appetite to help align agency resources with areas of greatest risk.  Successful ERM implementation requires changes in organizational culture, behaviors and attitudes about risk at every level of the agency. While it is critical for ERM to be endorsed by agency officials “setting the tone at the top,” it is also important to assess the “mood in the middle” and “buzz at the base” of the organization to develop a sustainable program that aligns with the agency’s culture.  Depending on an organization’s willingness and ability to enhance ERM, it could take five years or more to achieve the many benefits of a successful ERM program. 

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OMB’s latest DATA Act guidance highlights PII, financial assistance

Personally identifiable information and data “validity” are the focus of the Office of Management and Budget’s latest DATA Act guidance.

In a Nov. 6 memo to agencies, OMB delves into detail for reporting certain types of federal financial assistance and awards under the Digital Accountability and Transparency Act.

The guidance does not change or affect any existing policy, OMB clarifies, but does “further [specify] (1) responsibilities for reporting financial information for awards involving Intragovernmental Transfers (IGTs), (2) guidance for reporting financial assistance award records containing personally identifiable information (PII), and (3) guidance for agencies to provide the Senior Accountable Official (SAO) assurance over quarterly submissions to USASpending.gov,” the memo states.

According to the latest guidance, two types of intragovernmental transfers are included under DATA Act reporting: allocation transfers and buy/sell transactions.

OMB directs agencies that starting with their first DATA Act reporting on allocation transfers, the agency will “submit and assure the appropriations information, program activity and object class, and award financial information for allocation transfers for display on USASpending.gov.”

As for buy/sell transactions, both the awarding and funding agencies must submit information for spending reports.

Under the new guidance, if a Federal Award Identification Number (FAIN) is included in details for a single award, the agency should report that award to USASpending “as a single, discrete record.”

If single award-level reporting isn’t possible, agencies can report aggregated awards at a county or state level.

As of the Nov. 6 guidance, however, the DAIMS [DATA Act Information Model Schema] only offers guidance for aggregate county level.

OMB directs agencies to continue the county-level reporting practice until that schema is modified.

The guidance is the latest in a  series of OPM memos and updates for agencies, as they prepare for the May 2017 implementation of the DATA Act.

Officials with OMB and Treasury — the two agencies spearheading the DATA Act’s implementation — stand by the progress toward full adoption, while GAO auditors have repeatedly warned that the federal spending standardization could fall behind if agencies don’t get in line with the legislation’s requirements.

In early August, a GAO report warned that Treasury’s 4-month delay for releasing its schema version 1.0, triggered the delay of industry software patches while companies waited for a “stable version of the schema.”

That assessment came on the heels of another GAO report that said the full rollout of the DATA Act is at risk if OMB and Treasury don’t take steps to improve the review of agency plans and monitoring of progress updates.

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DATA Act Resources

Information regarding the requirements for implementation of the DATA Act can be found at the following websites:

–OMB Memo 15-12: https://www.whitehouse.gov/sites/default/files/omb/memoranda/2015/m-15-12.pdf.

–OMB MPM Memo 2016-03: https://www.whitehouse.gov/sites/default/files/omb/financial/memos/management-procedures-memorandum-no-2016-03-additional-guidance-for-data-act-implementation.pdf

–DATA Act Data Elements guidance: https://community.max.gov/pages/viewpage.action?spaceKey=Management&title=B%3A+DATA+Act+Elements+Guidance.

–DATA Act GitHub site: https://fedspendingtransparency.github.io/.

–DATA Act Policy FAQs: https://community.max.gov/display/Management/DATA+Act+Implementation+Other+Resources.

–RSS: https://community.max.gov/x/CIbyL

Shared Services Requirements: Kicking the Tires

Buying a car is a process that many of us have gone through at one point or another (more than once for a lot of us). Thinking back on that process raises the question of why some of the simple techniques we use in our personal lives aren’t being better applied in the workplace.

If we can apply four lessons from buying a car to the workplace, we can be as happy with our new systems as we are with our new cars.

1) Focus on what’s unique

2) Leave the engine to the engineers

3) Keep your priorities straight

4) Take it for a test drive

The process of buying a car can teach us a lot about how we should (and shouldn’t) approach requirements gathering for shared services migrations. Use the resources at your disposal to start with the baseline and focus on what’s unique, stay away from trying to design the system, make sure you stay realistic about your priorities, and of course take it for a test drive. This will help make sure that you don’t end up with a high-end sports car when all you can afford and all you really need is the economy model.

About the Authors

Teia Clarke, Deloitte Consulting Senior Manager in Federal Practice Shared Services

Karen Ganley, Deloitte Consulting Specialist Leader in Oracle and Technology Implementation

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