Data Access
CRE Analysis
1. Scope -- What government activity should trigger Data Access?
Background:
The February 4, 1999 OMB proposed revision stated that the new data access provision would apply to research findings that the government used in developing "policy or rules." The proposal did not define the terms "rules" or "policy," and many commenters noted this omission.
Limiting the scope of the A-110 revision to federal rules or policies is one arguably reasonable interpretation of the statute, however, as many have pointed out, the language of the underlying statute appears to be broader. Arguments both for expanding and for further restricting the scope of the law were submitted to OMB.
OMB's August 11, 1999 reproposal would restrict the data access provision to studies that the government uses in developing "regulations", a narrower scope that the original proposal.
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