might be encountered in implementing the DAA, suggesting that this approach might not be an ideal way to ensure public access to data underlying federal policies and regulations.50 At the same time, the DAA does not appear to have led to any contentious cases during the decade since it went into effect. For example, a 2003 General Accounting Office report found that two agencies had received a total of 42 requests under the DAA up to that time, and that none of the requests had actually met the Circular A-110 criteria.51

The IQA was passed as a two-sentence rider to the 2001 Consolidated Appropriations Act. The IQA called on OMB to issue regulations for “ensuring and maximizing the quality, objectivity, utility, and integrity of information (including statistical information) disseminated by Federal agencies.” In response, OMB issued guidelines that all agencies “must embrace a basic standard of quality as a performance goal, and agencies must incorporate quality into their information dissemination practices.”52

The guidelines state that “if an agency is responsible for disseminating influential scientific, financial, or statistical information, agency guidelines shall include a high degree of transparency about data and methods to facilitate the reproducibility of such information by qualified third parties.”53 For “original and supporting data,” agencies are to consult with “relevant scientific and technical communities” and determine which data are subject to the reproducibility requirement.54 “Reproducibility” here means a high level of transparency about research design and methods, which is meant to negate any need to replicate work before dissemination. For “analytic results” there must be “sufficient transparency about data and methods that an independent reanalysis could be undertaken.”55 This means that “independent analysis of the original or supporting data using identical methods would generate similar analytic results, subject to an acceptable degree of imprecision or error.”56 In cases where the public does not have access to data and methods (privacy, security, trade

50

See National Research Council, Access to Research Data in the 21st Century. In particular, Chapter 6, which reports on workshop chair Richard Merrill’s summary remarks, is a concise statement of the longer-term shortcomings of DAA.

51

General Accounting Office. 2003. University Research: Most Federal Agencies Need to Better Protect against Financial Conflicts of Interest. GAO-04-31. November. Washington, DC: General Accounting Office.

52

Office of Management and Budget. 2002. “Guidelines for ensuring and maximizing the quality, objectivity, utility, and integrity of information disseminated by federal agencies; Notice; Republication.” Federal Register 67(36):8451–8460. Available at http://www.noaanews.noaa.gov/stories/feb22.pdf. This Federal Register entry includes the final guidelines as well as a discussion of the comments received.

53

Ibid., p. 8455.

54

Ibid.

55

Ibid., p. 8456.

56

Ibid.



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