Listening Session on EB-5: Pre-dissemination Requirements under the Data Quality Act (DQA)
OMB guidelines implementing the DQA state:
As a matter of good and effective agency information resources management, agencies shall develop a process for reviewing the quality (including the objectivity, utility, and integrity) of information before it is disseminated.
An agency spokesman replied that it would comply with all applicable statutes and regulations, including the Data Quality Act. The agency is to be complimented for its commitment to the quality of the information it disseminates.
We look forward to the agency making its pre-dissemination reviews available to the public.
N. B. Compliance audits are subject to the DQA. If input-output models are to be used as a part of the application process the models should be subject to notice and comment because of the wide range of variation in such models.
Appreciate the post and your comment today. Can you elaborate on this so all of us “non-OMBers” can understand? Are you saying that any information obtained today on the call IF used in a revision of the ANPRM would need to be made public for comment prior to a releases of an ANPRM?
Sorry for the late response.
First, I added some links to my earlier post in order to give you a better understanding of the DQA.
Second, any information mentioned in the listening session need not be submitted for public comment prior to its inclusion in a subsequent rulemaking but any outside party could challenge the said data if it is used in a rulemaking by filing a Request for Correction under the DQA claiming if it does not meet some of the criteria set forth in OMB’s guidelines.
Jim Tozzi
Center for Regulatory Effectiveness