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Ensuring the Quality of Data Disseminated by the Federal Government: Workshop Report 1 Introduction Since the time of its founding, the federal government has disseminated important information to the public, primarily as paper copies of documents.1 With the advent of the Internet, the volume of this disseminated information has grown considerably. Congress has encouraged this process through statutes that describe particular dissemination activities, as have circulars of the White House Office of Management and Budget (OMB).2 As the volume of government information has increased, so have efforts by various groups to challenge the sources of that information, especially when it is used for regulatory or other rule-making activities. These challenges, in turn, have prompted more formal action to ensure the accuracy of information used by government agencies. 1 Thousands of statutes mandate agencies to disseminate information of various kinds. Such dissemination is of long standing and fundamental to how the operations of the U.S. government are made transparent to its citizens. It also reflects the belief that if the government spends money collecting information it generally should make that information available to the public. For this reason, agencies had already developed mechanisms and procedures to guide their dissemination practices and to ensure quality control. 2 See for example, OMB Circular A-130, “Management of Federal Information Resources,” and OMB Circular A-110, “Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations.” OMB Circulars are instructions or information issued by OMB to federal agencies. The Office of Management and Budget oversees federal regulation, the budget, information collection and dissemination, proposed legislation, testimony by agencies, and other related activities.
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Ensuring the Quality of Data Disseminated by the Federal Government: Workshop Report In the fall of 2000, Congress enacted the Data Quality Act, directing OMB to issue, by September 2001, government-wide guidelines to “provide policy and procedural guidance to federal agencies for ensuring and maximizing the quality, objectivity, utility, and integrity of information (including statistical information) disseminated by Federal agencies....”3 Accordingly, OMB issued proposed guidelines in June 2001, sought public comment, and issued revised guidelines in September 2001, seeking additional public comment. Final guidelines were issued in January 2002.4 The proposed OMB guidelines applied to information dissemination activities that vary in importance and scope, include all media (printed and electronic), and direct agencies to develop procedures that are consistent with their own missions, resources, and administrative practices. The proposed guidelines also: stated that “agencies shall have a basic standard of quality (including objectivity, utility, and integrity) as a performance goal”; recognized a range of importance for government information, and asserted that more important information, such as “influential scientific, financial, or statistical information,” should be held to a higher quality standard, with scientific or statistical results required to be “capable of being substantially reproduced”; required that agencies disseminating information regarding risks to human health, safety, and the environment either adopt or adapt the quality principles applied by Congress to risk information used and disseminated pursuant to the Safe Drinking Water Act Amendments of 1996; required agencies to establish administrative mechanisms that allow affected persons to seek correction of information disseminated by the agency, as well as to establish an appeals process; were designed to provide agencies flexibility in incorporating existing policies and procedures into the new guidelines; and were designed to assure maximal usefulness of the information to the intended users. OMB received approximately 100 comments from academic institutions and societies (including the National Academy of Sciences), federal agencies, industry groups, individuals, and others on their proposed guidelines. While several agencies noted that they would be able to com- 3 Section 515(a) of the Treasury and General Government Appropriations Act for Fiscal Year 2001 (Public Law 106-554). 4 “Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies,” January 3, 2002, 67 FR 369 and corrected version, February 5, 2002, 67 FR 5365, pp. 8452-8460.
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Ensuring the Quality of Data Disseminated by the Federal Government: Workshop Report ply with the guidelines by building on existing agency systems, the majority of comments focused on two aspects of the proposed guidelines: 1. the need to clarify definitions and terms, in particular the meaning of “influential scientific or statistical information” and “capable of being substantially reproduced”; and 2. the need to place limitations on the administrative correction mechanism. The research community, in particular, expressed concern that the new guidelines might add additional expense for compliance, jeopardize the security of intellectual property, be misused by those who oppose research for any reason, and otherwise weaken the performance of research. Researchers also expressed a desire for a more precise definition of “influential information” in the context of science, as a result of OMB’s interpretation of the statutory language, which went beyond what Congress had stated and included “scientific” in the category of influential information. Following expressions of concern from within the research community and a request made by OMB, The National Academies Science, Technology, and Law (STL) Program established an ad hoc committee to organize and host three workshops at which federal agencies that are subject to the guidelines could share their views and listen to ideas and concerns from other parties. The workshops were not intended to produce recommendations, but to assist agencies in developing their own agency-specific guidelines. This document provides a brief summary of the key issues raised during the presentations and discussion periods at all three workshops. It does not attempt to summarize the entire three days discussions. Chapter 2 summarizes the workshops held on March 21-22, 2002, which focused on the OMB guidelines prior to issuance of agency-specific guidelines. Chapter 3 summarizes the workshop held on May 30, 2002, which focused on the draft versions of the agencies’ guidelines. The order of presentations has been modified slightly to present a more logical sequence of topics. The transcripts from each workshop can be found at www.nationalacademies.org/stl.
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