XBRL US submitted a letter responding to a U.S. Commerce Department request for comments on the Cross Agency Priority Goal: Leveraging Data as a Strategic Asset. The Commerce Department notice seeks comment on best strategies and processes for achieving this CAP goal. The Request for Comments seeks input on a 4 part strategy to:
- Manage government data as a strategic asset;
- Enable the American public, businesses, and researchers to effectively and efficiently access and use data;
- Improve the use of data for federal decision-making and accountability, including for policy-making, innovation, oversight, and learning; and,
- Facilitate the use of federal data by interested parties to enhance the accessibility and usefulness of that data through commercial ventures, or innovation, or for additional public uses.
Recommendations made by XBRL US include the following:
- Adopt an open source, nonproprietary, widely used, financial data standard, that can be continuously improved, and that can adapt to changes in industry trends and reporting needs.
- Require a single data standard for all financial data reporting, from all entities, reporting to all government agencies. This will allow the government to establish a single data collection process, and will significantly ease the use of, and reduce the cost, of data for downstream users.
- Require the use of the Legal Entity Identifier for entities reporting to the Federal government.
- Designate a single government agency to build and manage the data standard; and ensure collaboration from all stakeholders. This approach has been employed in other countries and has been proven to reduce the cost to the federal government of creating the data collection process, and of managing it on an ongoing basis.
- Ensure quality of data by requiring reporting entities to be the source of the data, and by leveraging validation rules to resolve data errors.
- Conduct periodic reviews of the data reported to ensure that quality is good and to continuously improve the validation rules employed.