Page 38 - Financial Report 2020

PRIVACY AND CIVIL LIBERTIES OVERSIGHT BOARD

Anti-Deficiency Act

The Anti-Deficiency Act (31 U.S.C. §§ 1341 and 1517) prohibits federal agencies from
obligating and expending federal funds in excess of its appropriation. The agency’s financial
system was designed to prevent Anti-Deficiency Act violations through the implementation
of a zero-tolerance funds control check at the fund and office level. This systematic control
ensures that obligations are not recorded until monies are authorized and allotted by the
OCFO. Funds control is a critical tool in ensuring funds are managed effectively across all
levels of the agency.

Prompt Payment Act

In 1982, Congress enacted the Prompt Payment Act (31 U.S.C. Chapter 39) to require
federal agencies to pay their bills on a timely basis, to pay interest penalties when
payments are made late, and to take discounts only when payments are made by the
discount date. In FY 2020, PCLOB paid 23 of its 24 invoices (or 96%) subject to the Prompt
Payment Act on time, with one invoice totaling $114 paid late due to an administrative
error.

Digital Accountability and Transparency Act

Digital Accountability and Transparency Act of 2014 (“Public Law. 113-101”), or DATA Act,
was signed into law in May 2014 to establish governmentwide, financial data standards
and increase the availability, accuracy, and usefulness of federal spending information.
DATA Act implementation, which is being led by Treasury and the OMB, mandates federal
agencies to report on procurement data to bring awareness on federal spending. Pursuant
to the statutory reporting requirements, PCLOB submits award-level information for
posting on usaspending.gov using the required standard data exchange called the DATA Act
Information Model Schema. Federal spending that is reported on usaspending.gov is
derived from financial and contract award information. The agency’s financial system is
updated with the most recent version of DATA Act Information Model Schema to ensure
that the submission of all required financial data elements is complete and accurate. As for
contract award data, the agency uses Procurement Information System for Management
(“PRISM”) for domestic contracts, which automatically updates to Federal Procurement
Data System-Next Generation, the central repository of information for federal contracting.
Validation issues between financial and award information are reconciled to ensure that
spending data is accurate.

PCLOB does not have an Inspector General and therefore is not required to conduct an
annual audit to validate the accuracy of the agency’s DATA Act submission. However,
PCLOB’s financial service provider, ARC, does have a Statement of Standards for Attestation
Engagements (“SSAE”) Number 18 internal controls audit each year, which inherently
provides assurance over internal controls related to the submission of DATA Act data.

FY 2020 AGENCY FINANCIAL REPORT 29