EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
WASHINGTON, D.C. 20502
ADMINISTRATOR
OFFICE OF INFORMATION AND REGULATORY AFFAIRS
April 18, 2000
The Honorable Jo Ann
Emerson
US House of Representatives
Washington, DC 20515
Dear Representative
Emerson:
Thank you for your letter
of March 20, in which you ask about the Office of Management and Budget (OMB)
response to the language in the FY 1999 Omnibus Appropriations act conference
report (House Report 105-592), which concerned the quality of information that
Federal agencies disseminate to the public.
OMB is committed to helping
the Federal government provide the public with high quality information. We
work with the agencies in several ways to improve the quality of such
information. Under the Paperwork Reduction Act, we review information
collection proposals to ensure that they have maximum "practical
utility." We coordinate and review the development and use of federal
statistics. OMB Circular A-130 describes the best practice that agencies should
follow to collect and use timely and appropriate information. It also
establishes the criteria for agency budget requests to ensure that proposed
information management investments are appropriate, efficient, and effective.
The FY 1999 House Report
language urged OMB to establish government-wide rules for ensuring the quality
of federally-disseminated information. We appreciate the need for ensuring such
quality and are sensitive to the possibility that OMB Circular A-130 might need
to be updated or supplemented to deal with concerns in this area. OMB Circular
A-130 already establishes complaint resolution procedures for perceived
violations of data quality and other requirements in the Circular. Section
9(a)10 of the Circular contains a requirement that each agency CIO must:
"Monitor agency compliance with the policies,
procedures, and guidance in this Circular. Acting as an ombudsman, the [CIO]
shall consider alleged instances of agency failure to comply with this Circular
and recommend or take corrective action as appropriate."
The Circular also contains
a specific requirement for agencies to report to OMB any alleged violations and
their resolution:
"The [CIO] shall
report annually, not later than February 1st of each year, to the
Director those instances of alleged failure to comply with this Circular and
their resolution." Last summer, OMB canvassed the agency Chief Information
Officers (CIOs) about data quality. They indicated to us that they have not
been hearing complaints about the quality of federally-disseminated
information. None expressed a need for further guidance in this area. Based on
our canvass of the CIOs and OMB's own experience, there does not currently
appear to be a significant problem in this area. We are monitoring CIO activities
and will be alert to any widespread complaints about publicly-disseminated
information.
At the present time, OMB is
not convinced that new "one-size-fits-all" rules will add much to the
existing OMB guidance and oversight activity and the procedures followed by
individual agencies. We are reluctant to issue more regulations without a clear
sense that they would be useful in promoting data quality. We are also
concerned that new regulations might prove counterproductive to the goal of
increasing data quality. The Report suggests that agencies be required to
establish a new "petition" process under which persons could file
formal "complaints" over the quality of information. These
administrative requirements could consume significant agency resources. An
adversarial petition process also might discourage the type of free and open
dialogue between the agency and the public that is crucial for identifying and
addressing data quality issues.
We also note that the House
Report suggests that any new regulations extend not only to Federal agencies,
but also to non-Federal entities that disseminate information with Federal
financial support, such as contractors, State and local governments, and
no-profit grantees. This might leads to new unfunded Federal mandates and an
intrusion into how non-Federal entities communicate with the public on public
matters.
We are very much interested
in exploring other ways to improve data quality. We believe it important to
have interagency cooperation in this regard and to enlist the public in an
ongoing dialogue aimed at improving such quality. Data quality is one of many
considerations of agency information management activity. In that regard, we
are launching this month an initiative to work with select agencies (HCFA, EPA,
DOT, HHS, OSHA, IRS, and SBA) and the public on how we can collect information
more effectively, with improved efficiency and data quality. We expect these
discussions to identify agency best information management practices as well as
recommendations for improving specific information collection and management
activities.
We appreciate your strong
interest in information quality and would welcome any further thoughts you
might have on this subject.
Sincerely,
John T. Spotila
Administrator