OMB issued proposed guidelines for Data Quality in the June 28, 2001 Federal Register which would set quality thresholds for information disseminated by the federal government. These guidelines were mandated by Congress under section 515 of the Treasury and General Government Appropriations Act for FY 2001 (P.L. 106-554) and the Paperwork Reduction Act of 1995 (PRA).
This congressional mandate for Data Quality was in response to federal agencies’ growing use of the Internet and other communications mechanisms that permit dissemination of information that either expands existing regulations, is a precursor to new federal regulations, acts as an incentive for state and/or local authorities to regulate, or affects consumer perceptions.
The following points provide a summary of the most important features of the new Data Quality guidelines and associated requirements for federal agencies:
Key Components of the OMB Data Quality Guidelines
OMB has initiated a 45-day public comment period for the proposed Data Quality guidelines. Comments are due to the agency by August 13, 2001.
Comments may be submitted as follows:
In light of their importance, CRE strongly encourages all interested parties to review the Data Quality guidelines and submit their comments to OMB.
OMB has defined the scope of coverage of the Data Quality guidelines to include a range of agency information and means of disseminating such information to the public.
The proposed guidelines have been designed to "fit all media, be they in printed, electronic, or other form."
The agency has also defined key terms, such as "information," "government information," "information dissemination product," and "dissemination." (Discussed in further detail below.)
OMB has laid out parameters for key terms contained in the Data Quality statute, including the following:
"Quality," "Objectivity," "Utility," and "Integrity"
OMB sees the above four terms as closely interrelated concepts and defines them collectively such that information disseminated under the guidelines must take into consideration the following three elements:
(1) Information disseminated must be useful to all users, including the public.
– Usefulness must be determined not only from the standpoint of the agency but from that of the public.
– Relatedly, agencies must be mindful of the transparency of their information.
(2) Information disseminated must be clear, accurate, and complete.
– This requirement may entail agency provision of additional materials required to put the relevant agency information in context.
– In the statistical realm, agencies must demonstrate that their information was obtained using sound statistical methods and that error sources affecting data quality are identified and disclosed to users.
(3) Information disseminated must be protected from unauthorized access and revision to ensure that the information is not compromised through falsification or corruption.
Under the proposed guidelines, agencies are directed to develop information resources management procedures for reviewing and documenting for users the quality of information before it is disseminated to the public.
– A key component of these procedures is agency establishment of an administrative mechanism allowing affected persons to seek and obtain correction of information which does not comply with OMB’s guidelines.
In implementing the corrective mechanism, agencies may incorporate existing agency processes for evaluating information dissemination activities. For example, it may be possible to modify a corrective mechanism already established pursuant to OMB Circular A-130.
Agency Conforming Guidelines
As required under the Data Quality statute, agencies must issue their own conforming guidelines for information quality no later than one year after the date of issuance of final OMB guidelines. Such guidelines are to be included in a report to the Director of OMB and must include an administrative corrective mechanism, as discussed above.
– The draft report is reviewed by OMB for compliance with the OMB Data Quality guidelines.
– Once cleared by OMB, the agency must publish notice of the availability of this report in the Federal Register and post the report on the agency’s website.
By only laying out general parameters in its generic guidelines, OMB seeks to allow agencies to develop conforming guidelines which recognize their unique needs and circumstances of their individual programs.
– This will allow the Data Quality guidelines to be implemented in a common sense and workable manner.
– It will also ensure that agencies are not inhibited from continued utilization of the Internet or other emerging information dissemination technologies.
OMB lays out two primary reporting requirements for agencies, consistent with the requirements of the statute:
– As noted above, agencies must issue a report to the Director of OMB within one year after issuance of the OMB Data Quality guidelines, which includes a delineation of the agency’s conforming guidelines and corrective mechanism for information quality.
– Agencies must also issue an annual report to the Director of OMB (starting one year after issuance of the first report above) which details the number, nature, and resolution of complaints received by the agency regarding perceived or confirmed failure of the agency to comply with the OMB guidelines.
Responsibilities of the Chief Information Officer (CIO)
OMB Circular A-130 (Management of Federal Information Resources) and the Paperwork Reduction Act (PRA) assign important duties to agency CIOs to monitor and ensure the quality of agency information. (See Circular A-130, sec. 9(a)(4).) The Data Quality guidelines build upon these preexisting responsibilities:
– The CIO acts as an ombudsman to resolve complaints with the agency’s compliance with OMB Circular A-130 and the requirements of the Data Quality guidelines.
– The agency should respond in writing to allegations of noncompliance and the need for correction.