Performance Measurement and Data Verification and Validation Procedures

1.  Purpose.

The Federal Government must report high-quality data to maintain the trust placed in it by the American people and to support better data-driven decisions. Verification and validation of performance data should generate a sufficient level of confidence that performance information presented is credible as appropriate to its intended use.  This Order establishes the policy, procedures, and responsibilities for the improvement and continuity of GSA’s performance measurement system.

2.  Applicability.

This Order applies to Service and Staff Offices (SSOs) responsible for identifying, collecting, analyzing, and/or reporting data and/or performance measures for use internal or external to GSA.

3.  Background.

GSA’s Performance Improvement Officer (PIO) works with the Office of the Administrator and GSA’s Heads of Service and Staff Offices (HSSOs) to set agency goals, make results transparent, and review progress to inform decisions and course corrections.  GSA’s Chief Financial Officer (CFO) and the Office of the Chief Financial Officer (OCFO) provide budget, analytics, financial management, financial reporting, strategic planning, enterprise risk management, and performance management services to GSA’s customers; and develop and implement financial controls to ensure GSA properly manages public funds. Under the responsibilities of the CFO and PIO, GSA conducts actions to ensure data, performance measures, and methodologies are valid and reliable to support data-driven decisions, in compliance with Federal legislation, guidance, and financial standards, to include:

     a.  OMB Circular No. A-11, Preparation, Submission, and Execution of the Budget, (Executive Office of the President, updated 2023)

     b.  Program Management Improvement Accountability Act of 2016 (PMIAA) 

     c.  OMB Circular A-123, Management’s Responsibility for Enterprise Risk Management and Internal Control (2016)

     d.  Digital Accountability and Transparency Act of 2014 (DATA Act) 

     e.  Government Performance and Results (GPRA) Modernization Act of 2010 (GPRAMA) 

     f.  GAO Selected Approaches for Verification and Validation of Agency Performance Information 

    g.  Chief Financial Officers Act of 1990 (Public Law 101-576) 

4.  Cancellation.

Supersedes GSA Order CFO 2170.1A, Performance Measurement and Data Verification and Validation Procedures, issued on September 12, 2019.

5.  Revision.

This Order includes updates from associated policy and laws from oversight organizations resulting in the following changes: 

     a.  Paragraph 7A(1) was revised to include frequency of verification and validation.

     b.  Paragraph 8A(2) was added to include a requirement for OCFO to determine suitability of performance measures and targets externally reported via the Annual Performance Plan/Report (APP/R).

     c.  Paragraph 8A(4) was added to include a requirement for OCFO to work in collaboration with SSOs to develop and update Performance Measure Definition Forms (PMDFs).

     d.  Paragraph 8B(4) was added to include the requirement for SSOs to consult with the PIO on proposed changes to externally reported measures.