technical problems with the information collected, used and published and released by the federal agencies.” Dr. Graham cited recent studies by the National Institutes of Health and the Environmental Protection Agency in which results had been fabricated, misread, or poorly analyzed.

Dr. Graham stated that the Bush Administration is “committed to vigorous implementation of the new information quality law” and that the Administration believes it “provides an excellent opportunity to enhance both the competence and accountability of government.” To fulfill this opportunity, the guidelines “imposed three co-responsibilities upon all federal agencies”:

  1. Agencies must commit to a basic standard of quality for the information they disseminate.

  2. Agencies must develop information management procedures to prevent dissemination of poor-quality data, with peer review playing an important role.

  3. Agencies must have an administrative mechanism that allows “affected parties” to request corrections of information. The burden of proof, Dr. Graham noted, is on the requester to demonstrate that the information fails to meet OMB or agency guidelines. If the request is denied, there must be an appeals process.2

Dr. Graham acknowledged that a number of concerns had been raised about the guidelines:

  1. The guidelines subject government information to a higher standard than information generated by industry, academics, and public interest groups. Dr. Graham noted that a closer reading of the guidelines would suggest a more “nuanced” conclusion. “If a government agency wishes to rely upon and cite information from industry to support a decision, that information, because it becomes a dissemination, must meet the same quality standard that information generated by the agency must meet.”

  2. The guidelines are unfunded mandates on agencies. It is true that agencies will need to spend time responding to requests, Dr. Graham said, but the guidelines allow them to reject complaints that are groundless. He also estimated that agencies would probably save money in the long run.

  3. Original data may not be available. Dr. Graham said the OMB was “reluctant” to require that all original data be reproducible, instead they require that analytical results (i.e., those derived from original data) be


Graham cited this responsibility as “perhaps the key provision.”

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