Volume I - Financial Management
Chapter 03 – Quality Financial Information
Questions concerning this policy chapter should be directed to:
- Veterans Health Administration
- Veterans Benefits Administration
- National Cemetery Administration
- Debt Management Center
- Financial Services Center
- Construction and Facilities Management
- All others
0301 Overview
This chapter establishes the Department of Veterans Affairs’ (VA) financial policies on the quality of financial information.
Key points covered in this chapter:
- VA will follow the core principles of transparency, participation, and collaboration as directed in the President’s Memorandum of January 21, 2009, titled Transparency and Open Government. Adhering to such principles is fundamental to VA achieving its mission and vision.
- VA must be accountable to the Veteran and taxpayer while improving its infrastructure to promote openness and ensure quality financial information; and
- VA will ensure compliance with OMB-issued guidance while continuous progress is made to improve the timeliness, completeness, and accuracy of financial information.
0302 Revisions
| Section | Revision | Office | Reason for Change | Effective Date |
|---|---|---|---|---|
| Various | Completed full review | OFP | Updated guidance | July 2026 |
| Various | Eliminated CFOC | OFP | To align with organizational structure | July 2026 |
| 030502 | Updated authorities | OFP | Align with existing authorities | July 2026 |
| 0306 | Updated Authorities and References to current guidance | OFP | Full review | July 2026 |
For a complete list of previous policy revisions, see Appendix A: Previous Policy Revisions.
0303 Definitions
Data – Information, especially facts or numbers, collected to be examined and considered and used to help decision-making, or information in an electronic form that can be stored and used by a computer.
Data Accuracy – A quantitative metric that represents the degree to which information correctly reflects the real-world event being described.
Data Completeness – A quantitative metric that includes the extent to which the expected attributes of data are provided in their entirety.
Data Consistency – A qualitative characteristic where information is used similarly unless there is a good reason to change the valuation method or basis of accounting. If there are changes, the nature and reason will be disclosed.
Data Reliability – A qualitative characteristic that is verifiable, unbiased, and represents comprehensive information that is not misleading. This does not imply accuracy and includes narratives about the degree of estimation and underlying uncertainties.
Federal Subaward Reporting System – The system for prime awardees to report sub-award data as required under the Federal Funding Accountability and Transparency Act (FFATA) and the DATA Act.
Objectivity – A measure of whether disseminated information is accurate, reliable, and unbiased and whether that information is presented in an accurate, clear, complete, and unbiased manner.
Quality – A measure of the condition of data based on factors such as accuracy, completeness, consistency, reliability, and whether it is up to date.
Quantitative – A metric that includes numbers, may be measured, and is subject to ‘yes’ and ‘no’ decisions.
Unprocessed Documents – Original source record (form) that captures details about an Integrated Financial and Acquisition Management System (iFAMS) transaction or event that remains unresolved or incomplete. These open items primarily pertain to financial transactions like invoices, payments, and receipts, requiring further action before they can be considered fully closed or settled.
Utility – The usefulness of the information for the intended audience’s anticipated purposes.
0304 Roles and Responsibilities
Secretary of Veterans Affairs (SECVA) has delegated ASM/CFO to serve as the Senior Accountable Official (SAO) responsible for coordinating and collaborating VA’s efforts pursuant to the development and implementation of a data quality framework.
Under Secretaries, Assistant Secretaries, Other Key Officials, Chief Financial Officers, and Fiscal Officers are responsible for ensuring compliance with the policies and procedures outlined in this chapter.
Assistant Secretary for Management and Chief Financial Officer (ASM/CFO) has designated SAO responsibilities for the development and implementation of a data quality framework to the Executive Director, Office of Business Oversight (OBO). Further, ASM/CFO has designated SAO responsibilities for the review and certification of the Digital Accountability and Transparency Act (DATA Act) reporting to the Office of Finance.
Senior Accountable Official (SAO) is responsible for coordinating and collaborating VA’s efforts pursuant to the development and implementation of a data quality framework for VA.
Office of Business Oversight (OBO) is responsible for managing the implementation and execution of the Department’s OMB Circular A-123, Appendix A, internal control over reporting assessment activities across VA. OBO maintains an internal control monitoring program consistent with the requirements of OMB Circular A-123, Appendix A.
Office of Acquisition, Logistics, and Construction (OALC) is responsible for reporting on acquisition, contract, and spending related data.
Office of Finance (OF) is responsible for the preparation and submission of VA’s DATA Act reporting, ensuring that financial and award data derived from VA’s financial systems are complete, reasonable, and accurate.
Office of Finance, Strategic Management Analytics Reporting Team (OF/SMART)is responsible for
- Reviewing and interpreting new and existing OMB guidance on DATA Act data quality for VA federal spending;
- Serving as the central operational authority for DATA Act data quality reporting per OMB guidelines;
- Collecting, analyzing, disseminating, and reporting financial data on federal expenditures, contracts, grants, loans, and other assistance to the DATA Act and USAspending.gov;
- Performing a final quality review of the timeliness, completeness, and accuracy before reporting financial spending data to USAspending.gov; and
- Certifying the timeliness, completeness, and accuracy of VA financial spending data monthly via Treasury’s Data Broker on behalf of the reporting program offices.
0305 Policies
030501 Data Quality
- VA will ensure and maximize the quality, objectivity, utility, and integrity of its information (including statistics).
- The key governing principles for providing quality data are:
- Presentation and Disclosure: Present information in a logical and coherent format; place the information in a proper context and cross-reference the information to the same data in other datasets.
- Existence and Occurrence: Report information from activities or events, make supporting information available, and ensure the supporting documentation complies with Government-wide guidance.
- Rights and Obligations: Own and be responsible for the information and ensure adequate internal controls.
- Completeness: Present all required information and implement a process to ensure data completeness.
- Valuation: Assign the correct value to information and verify the information for reliability and consistency within and outside of VA.
- VA will take proactive measures to ensure the accurate and timely recording of transactions through the entire life cycle of a transaction or event: from its initiation and authorization until it is fully processed within VA’s accounting and subsidiary systems. Unprocessed documents will be reviewed/corrected in a timely manner (e.g., at a minimum every 30 days). If unprocessed documents are unable to be resolved within 30 days, documentation of the corrective action plan or justification for the delay should be readily available.
- ASM/CFO has designated the Executive Director, Office of Business Oversight (OBO) as the SAO responsible for the development and implementation of a data quality framework for the Department. The SAO will seek input from across the Department in developing said plan.
- VA Administration and Staff Office CFOs will ensure internal controls are in place to mitigate risks of misstating, misrepresenting, or losing information. Basic control activities may include: segregation of duties, physical controls, security protocols, system access rights, transaction monitoring, and maintenance of appropriate documentation. Refer to VA Office of Financial Policy (OFP) Vol. I Chapter 5, Management’s Responsibility for Internal Controls.
- Data will be presented in a manner that allows for the:
- Calculation of mission related costs;
- Evaluation of performance;
- Display of financial condition and results of operations;
- Department to conduct financial planning;
- Safeguarding of public funds and other resources; and
- Determination of compliance with applicable laws.
- VA Administration and Staff Office CFOs will ensure appropriate financial policies and procedures are developed, documented, and implemented for all financial processes identified by new or changing requirements to improve the quality of Government financial information. Financial and accounting data have a direct effect on financial information quality since it is through the accounting functions of classifying, recording, controlling, reporting, and analyzing that reliable financial information is developed.
- Strategic Management Analytics Reporting Team (SMART) will review and interpret new and existing OMB guidance on DATA Act data quality for VA federal spending and communicate interpretations and changes with Administrations and Staff Office CFOs.
- SMART will serve as the central operational authority for DATA Act data quality reporting per OMB guidelines and will:
- Collect, analyze, disseminate, and report financial data on federal expenditures, contracts, grants, loans, and other assistance to the DATA Act and USAspending.gov;
- Perform a final quality review of the timeliness, completeness, and accuracy before reporting financial spending data to USAspending.gov; and
- Certify the timeliness, completeness, and accuracy of VA financial spending data monthly via Treasury’s Data Broker on behalf of the reporting program offices.
030502 OMB USA Spending Requirements
- VA CFO, Administration CFOs, or Other Key Officials may designate a Program Office (PO). The PO may be an existing business line or may be created in response to a specific law or legislation. For example, POs by business lines may be Grants, Education, Pharmaceuticals, and Insurance. An example relating to a specific law is the PO for the American Recovery and Reinvestment Act of 2009.
- In compliance with the Federal Funding Accountability and Transparency Act of 2006, as amended by the DATA Act of 2014 and the Congressional Budget Justification Transparency Act of 2021,VA is responsible for providing all spending data to USAspending.gov at regular intervals (e.g., weekly, bi-weekly, monthly) with sub-award information reported through the Federal Subaward Reporting System (FSRS) and displayed in SAM.gov and USAspending.gov.
- VA is required to aggregate outlays to Veterans and their beneficiaries per USASpending.gov guidelines. This will avoid reporting information that uniquely identifies anyone receiving VA benefits and violates privacy laws and regulations.
- VA is responsible for ensuring the key data reported on USAspending.gov will not disclose any individual’s personally identifiable information.
- VA Program Offices (POs) are responsible for monitoring the qualitative and quantitative data characteristics of understandability, reliability, relevance, timeliness, consistency, and comparability with other spending reporting websites to reconcile data and correct rejection processes. In addition, POs are responsible for:
- Submitting the required information to the Program Office Representative (POR), who will conduct a quality review before passing on the information to SMART;
- Ensuring all corrections for the prior months are reviewed and submitted to SMART;
- Understanding the data quality, reporting requirements, the data to report, and how data quality will be monitored;
- Adopting a basic standard of quality at all program levels;
- Performing data quality processes and key control activities as part of their normal daily operations;
- Executing initial quality reviews of program data before regular submission requirements (e.g., twice-monthly, monthly);
- Documenting data quality processes and maintaining all associated documentation;
- Working with OI&T to develop and implement efficient and effective data quality processes, policies, and procedures;
- Providing operational support and involvement in reviews of internal control data quality;
- Assuring remediation efforts are completed as required;
- Remediating deficiencies as appropriate; and
- Identifying the Program Office Representative.
- The POR is identified when the PO is defined, and an individual is made responsible for:
- Serving as the key point of contact for SMART and facilitating access to the
- program office’s facilities, systems, documentation, and necessary personnel to document, evaluate, and test internal controls;
- Managing the respective program office’s processes and outputs by reviewing each output against VA standards before the required (e.g., twice-monthly, monthly) submission to SMART;
- Submitting the program office’s outputs to SMART promptly;
- Assisting the program area in identifying key control data and data quality processes;
- Managing remediation efforts and providing regular status reports to OF on remediation activity and corrective action plans; and
- The Office of Acquisition, Logistics, and Construction (OALC) is responsible for:
- Submitting automated contract information and populating spending data (e.g., eCMS, IFCAP, direct entry) in the General Services Administration’s Federal Procurement Data System (FPDS) Web site that provides daily feeds into USAspending.gov; and
- Documenting procedures to capture and report sub-award information.
030503 Reporting Requirements
- VA will submit timely and quality information in the monthly, quarterly, and Consolidated Financial Statements, and in response to requests from OMB and other Federal entities.
- SMART will submit VA’s information, related to USA Spending and the DATA Act, via Treasury’s Data Broker in accordance with the Digital Accountability and Transparency Act (DATA) Act of 2014 (P.L. 113-101).
- Quantitative metrics for the data including timeliness, completeness, and accuracy will be reported by OMB.
0306 Authorities and References
- Public Law
- 38 U.S.C. Chapter 5, Authority and Duties of the Secretary, January 5, 2009
- Federal Accounting Standards Advisory Board Statement of Federal Financial Concepts Number 1; Objectives of Federal Financial Reporting, Chapter 6: Qualitative Characteristics of Information in Financial Reports
- President’s Memorandum (FR Doc. E9–1777) for the Heads of Executive Departments and Agencies on Transparency and an Open Government,
- January 21, 2009
- GAO Green Book: Standards for Internal Control in the Federal Government; Principle 13 – Use Quality Information
- OMB Circular A-123 Management’s Responsibility for Enterprise Risk Management and Internal Control (revised July 15, 2016); Appendix A, Management of Reporting and Data Integrity Risk, (revised June 6, 2018)
- OMB Memoranda
- OMB Memorandum M-09-19, Guidance on Data Submission under the Federal Funding Accountability and Transparency Act (FFATA), June 1, 2009
- OMB Memorandum M-10-06, Open Government Directive – Framework for the Quality of Federal Spending Information, February 8, 2010 & April 6, 2010
- OMB Memorandum M-20-21, Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19)
- OMB Memorandum M-21-20, Promoting Public Trust in the Federal Government through Effective Implementation of the American Rescue Plan Act and Stewardship of the Taxpayer Resources
- OMB Memorandum M-22-02, New Financial Assistance Transparency Reporting Requirements
- VA Financial Policy Publications, Volume I, Chapter V – Management’s Responsibility for Internal Controls
- VA Open Government Plan, June 2010
0307 Rescissions
Volume I, Chapter 3 – Quality Financial Information, January 2026.
Appendix A: Previous Policy Revisions
| Section | Revision | Office | Reason for Change | Effective Date |
|---|---|---|---|---|
| 0304 | Replaced OBO with OF for DATA Act responsibilities | OFP | Targeted Change | December 2025 |
| 030502 | Replaced OBO with OF for DATA Act responsibilities | OFP | Targeted Change | December 2025 |
| 0304 | Updated R&R section to address SECVA delegation to ASM/CFO for Senior Accountable Officials. | OFP | Targeted Change | May 2025 |
| 0304 | Updated R&R section to include ASM/CFO delegation to Executive Director, OBO as Senior Accountable Official for development and implementation of VAs data quality framework. | OFP | Targeted Change | May 2025 |
| 0305 | Updated policy section to address ASM/CFO delegation to Executive Director, OBO for handling data quality framework for VA. | OFP | Targeted Change | May 2025 |
| 010501 | Clarified VA requirements for transactional processing validation and clearing | OFP | Leadership request | April 2025 |
| Roles & Responsibilities | OBO assumed reporting requirements | OFP (047G) | Leadership request | February 2023 |
| 010503 | Replaced FMBT with OBO | OFP (047G) | Leadership request | February 2023 |
| Various | Clarified SMART office requirements in the policy section based on description in roles and responsibilities | OFP (047G) | Leadership request | February 2023 |
| Various | Completed a full review and updated to new formatting style. | OFP (047G) | Full review | April 2022 |
| Various | Updated office names throughout. | OFP (047G) | Full review | April 2022 |
| Various | Updated authorities and links throughout. | OFP (047G) | Full review | April 2022 |
| Appendix | Incorporated the Appendix into Policy | OFP (047G) | Full review | April 2022 |
| Various | Changed the title of Data Quality Service to Strategic Management Analytics Reporting Team. | FBO (047E) | Organizational Name Change | February 2018 |
| 0104 Roles and Responsibilities, Appendix B | Changed the title of the Office of Business Oversight to the Office of Internal Controls. | OFP (047G) | Organizational Name Change | February 2018 |
| 0109 Revisions | Insert Revision Table | OFP (047G) | Revision table needed for reference. | February 2018 |
