Feedback: Primary Place of Performance about fedspendingtransparency.github.io HOT 12 CLOSED

Ensure that "Primary" is clearly defined. I conducted a retrospective review of some awarded contracts on FedBizOpps where the "Primary Place of Performace displays the location of the contracting office. One recommendation might be that for actions that will be performed agency wide or in multiple locations to have a commonly understood term that can then be searched on.

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Wanted to mention the relationship to a new element I proposed #40

How would the award be reporting in my example (a school district in Florida receives a grant which is used to buy busses made in Michigan)? I think Florida would be reported even though the economic activity (jobs) are created in Michigan.

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The Primary Place of Performance Congressional District should not be a field transmitted but instead should be looked based on the address. During ARRA and FFATA reporting, we regularly have gotten errors indicating that the Congressional District did not match what is on file and the current district number was supplied to us (because district had changed since previous reporting). Since the information is obviously being looked as part of the edit checking process, it makes more sense to have it looked up by the system rather than having recipients supply the field.

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The first recommendation in the white paper refers to PPoP Country. I assume that should read county. If the county code is eliminated, then the county name can only be derived from other location data or entered by the submitter. I strongly recommend derivation. Text entry is too prone to errors. Before the county code is eliminated I recommend the original purpose of reporting it should be identified and confirmed that it no longer provides value.

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Yes. We want to see where the action is happening (jobs created as HerschelC says) rather than the headquarters of a contracting company or a local governmental body.
And too, I thought we could see when an award is for an entire county or state (pretty sure some stuff is across state-lines too) and decipher that hte congressional district may be unclear because the award crosses distrects. funds benefuit serveral congressional representatives.
If those instatnces are not in the data, how are you planning to identify a congressional district? like if a grant is given to a county govenrment to be used for easements across the county area, the congressional district is not as clear-cut. But if the report says the award is to the entire county it is obviously not going to have just one congressional district.
Or is that process just behind-the-scenes and some sort of coding thing would identify cross-district federal funding?

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AGA established a work group charged with responding to inquiries by the federal government, regarding implementation of the DATA Act. The following response is being submitted on behalf of AGA's work group, which is comprised of state, local, tribal and university practitioners from across the country. In commenting on this topic, group members had the following comments:
• When comparing a number of SF 425 reports and awards for various grants to a printout of FFATA reports, it appears that the SF 425 reports or grant awards contain none of the data elements that are being proposed for DATA Act reporting. For example, the FAIN number is only referenced on the FFATA report, otherwise grant #, award #, or federal grant or other identifying numbers are used. While FFATA reports call for an Award Type, the SF 425 asks for Assistance Type, Type of Award, or nothing at all. Some of the elements are imbedded into the narratives of the terms and conditions and can easily be missed. We recommended that DATA Act elements align with the 425 reports, grant award terms and condition contract templates.
• While “Performance” is discussed in the first paragraph of the white paper, it would be helpful to actually define the term and to discuss the types of activities that are included in “Performance.” The definition would be particularly helpful for pass-through entities, since “Performance” activities are performed off-site.
• How does the “Area of Benefit” differ from the “Place of Performance?”
• For consistency across all data elements, it is a good idea to spell out acronyms. For example, ISO, ACE and USPS are not spelled out.
• Under “Recommended Definitions for Transparency Reporting,” there appears to be two, conflicting recommendations for “Primary Place of Performance Country Code.”

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2. Is there any thought about having obligations reported at the grantee level – and not label that as place of performance, but instead label as place of payment while outlays would be reported separately at the place of performance? That is, we delink these two things so reporting is “ HUD/the Federal Government made obligations of $xxx to these grantees in FY 2015 in x county or x Congressional District” as one level of reporting and “HUD/the federal government made outlays of $xxx for xxx activities in x county or x congressional district in FY 2015” as a second level of reporting. At HUD, many of our grants are made to an administering entity located in one location while the actual end user (for example, a low-income tenant) is located in a different Congressional District or County. Simple example. New York City has multiple Congressional Districts, the New York City Housing Authority (the grantee) is located in just one of those Congressional Districts. However, the place of performance are the public housing units and the private units tenants use a housing voucher – those units are in all of the Congressional Districts of New York City. We can report the obligation as place of payment, but we don’t know the place of performance until expenditure occurs, which can be over the course of several years after obligation.

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I want to +1 on@Philmageddon's comment. Define Primary. Performance is where the greatest amount of the revenue is spent, where the greatest number of the employees work? What happens as this shifts over time? A contractor moves locations and the employees move along with it? How often is this information to be reported? Further, I think this should be the top 3 or 5 such locations where more than 10% of the dollars are spent for greater transparency.

Labor is a huge cost. Keep in mind that every employer must know where every worker lives and works in order to properly withhold state withholding tax and unemployment insurance premiums. This shouldn't be a hard thing to do for the top three segments related to an award. I think many people would like to know this detail to the location where people work and not the HQ of the company.

I also hope that it's accepted that this location may change and is not static from the moment when the contract is signed.

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I would suggest that the addresses go through some sort of address verification process like CASS certification from the USPS. This would aid in keeping the data clean and consistent and handle vanity names in addresses. Standard commercial practice - just like when we enter our address on a website for shipping and it conforms to postal specifications. The data entry system should have something similar for this government information.

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+1 @PentRector Dept. of Justice concurs with this comment about Congressional District unless it is re-awarded to a different location.

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+1 @PentRector - Dept of Interior agrees with the comment about Congressional District.

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Update 8/11/2015: Thank you for your feedback on Primary Place of Performance data elements. We will consider your feedback as we continually assess how we can improve data definitions.
You may still contribute the discussion for other data elements. Check http://fedspendingtransparency.github.io/dataelements/ to find data elements with open feedback pages.

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