Data is not a free good. It costs contractors money to collect, store, review, format and report data. It costs the government money to publish (as appropriate), store, review, and analyze data received from contractors. We all understand that data is a valuable asset and data collection is part of doing business with the Government. However, there should be a recognizable return on investment for data collection costs incurred by government and industry.

Over the last few years the procurement system has seen a series of “reforms” and/or additional data reporting tools and requirements intended to enhance transparency and accountability. These include:

• The Federal Funding Accountability and Transparency Act of 2006
• The Mandatory Disclosure Rule
• The Federal Awardee Performance and Integrity Information System
• USASpending.gov
• The American Recovery and Reinvestment Act o New Data reporting requirements via Recovery.gov
• The Recovery Act Accountability and Transparency (RAAT) Board
•  Reporting requirements on Executive Compensation and subcontractors

In addition, there has been a growth in “stealth” reporting requirements on a solicitation by solicitation basis. The term “stealth” refers to data collection requirements that have not been subject to the public review process mandated by the Paperwork Reduction Act. The Paperwork Reduction Act requires that the public have the opportunity to review and comment on proposed data collection requirements and the burden that may result.

Now comes H.R. 2146, the Digital Accountability and Transparency Act of 2011 (DATA Act). This bill would create the Federal Accountability and Spending Transparency (FAST) board modeled on the RAAT Board. The FAST board would be responsible for the collection, storage and public disclosure of information about Federal spending. The bill would require the creation of a new website for reporting data on spending. The bill also lists data elements to be reported and authorizes the FAST board to add additional reporting elements as appropriate—with no requirement for the public review process mandated by the Paperwork Reduction Act. Finally, as currently provided for in the bill, the FAST board will have audit and investigative powers, including the power of subpoena for documents and testimony.

Rather than create another new data reporting regime and a new, duplicative oversight agency in the form of the FAST board, we ought to be concentrating on improving the data reporting and collections systems we already have. Better yet, we should review current data collection requirements and eliminate those where the costs outweigh the benefits. Remember, data is not a free good.