December 21 will mark the beginning of the fifteenth year of the public using the Data Quality Act (DQA), aka the Information Quality Act, to ensure that federal agencies disseminate accurate information.
The most substantive recognition of the importance of the milestone in Executive agency accountability is the Office of Management and Budget issuing a binding Directive to agencies to improve the DQA’s implementation.
OMB has just issued data quality guidance applicable to federal statistical agencies that is equally applicable to the functioning of all agencies.
Federal statistical agencies have always played a dominant role in implementing the DQA. At the time of its passage, the DQA was controversial in that its opponents claimed the legislation would bring regulatory agencies to a halt as a result of never ending requests for correction filed by special interest groups.
Contrary to the position taken by the opponents of the DQA, federal statistical agencies said the requirements of the DQA simply placed into law what they were doing in the first place—disseminate accurate information to the public.
Much to its credit, OMB has now codified the views and expertise of the federal statistical agencies in a new binding “guidance” document. OMB’s Statistical Policy Directive No. 1: Fundamental Responsibilities of Federal Statistical Agencies and Recognized Statistical Units is noteworthy for explaining up front the dominant role that the Data Quality Act, and its parent the Paperwork Reduction Act, in ensuring that the public is provided with accurate information. The Directive states:
This Directive delineates the fundamental responsibilities of Federal statistical agencies and recognized statistical units. The responsibilities in this Directive are built upon and are consistent with the goals and principles of the Paperwork Reduction Act of 1995 (44 U.S.C. 3504 (e)), the Information Quality Act (Pub. L. 106- 554, Division C, title V, Sec. 515, Dec. 21, 2000; 114 Stat. 2763A-153 to 2763A-154).
Historically OMB has demonstrated very impressive leadership role in implementing the DQA beginning with its issuance, through notice-and-comment processes, of its government-wide DQA guidelines, reviewing agency specific guidelines and issuing specialized DQA implementing guidance such as the new Statistical Directive.
Since the fifteen years since the DQA’s passage, new data quality issues have emerged ranging from agency use of the social media to the applicability of the DQA to agency release of adverse publicity as a surrogate for formal enforcement actions (an issue presently being examined by the Administrative Conference of the US) to the use of the DQA has a means for initiating retrospective review of regulations to OMB becoming directly involved in Requests for a Correction.
Consequently, OMB should issue a Request for Information to address the aforementioned issues as well as others deemed to be important by members of the public.
Nota Bene, Administrator Shelanski’s transmittal Memorandum for Statistical Policy Directive No. 1 is available here.
