should be very careful in deciding who is affected to make sure they don’t blur the distinction.”
Mr. Cohen also discussed relevancy. He indicated that “agencies should have the ability in their administrative mechanism process to be able to decide that correcting a particular item of information doesn’t make any difference. So, why…bother…” Mr. Cohen illustrated this with a complaint that might come in stating that the Weather Service had predicted that yesterday’s weather would be sunny and warm and instead it was raining and cold. Mr. Cohen asked, “… should the Weather Service even bother dealing with that as a request for correction?”
Ms. Elaine Stanley of the Environmental Protection Agency discussed the agency’s web-based integrated error correction system that the agency was considering using as part of the data quality correction process. Under this system, an error is defined as a “deviation from accuracy or correctness and described as the difference between observed and/or approximately determined value and the true value of a quantity.” Ms. Stanley noted that a key principle in managing any correction mechanism is knowing who owns the data. “Knowing who has the responsibility and the authority over the original data or more broadly the information is the No. 1 principle in terms of trying to get it corrected and resolved…”
In terms of the appeals process, Ms. Stanley stated that EPA was considering two options: (1) Affected persons would file the appeal with the assistant administrator or regional administration or (2) Affected persons would file the appeal with the chief information officer.
Mr. James Scanlon, Department of Health and Human Services, indicated that while honoring the existing processes and legal mechanisms for different agencies within the department, such as FDA and NIH, the department will try to establish a common template to be used by affected parties when making requests for correction. Scanlon indicated that DHHS is trying “to make it fairly flexible to request the correction,” but emphasize that the affected person must be quite clear in describing what exactly needs to be corrected. With respect to appeals, Scanlon said that the appeal would go to one level above the originating office and could conceivably be raised to a higher level within the department if needed.