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Part II

Commentary

This part of the report comments on most of the topics in the principles and practices; the comments are offered to explain, illustrate, or further define the statement of principle in Part I.

DEFINITION OF A FEDERAL STATISTICAL AGENCY

A federal statistical agency is a unit of the federal government whose principal function is the compilation and analysis of data and the dissemination of information for statistical purposes.

A statistical agency may be labeled a bureau, center, division, or office or similar title, so long as it is recognized as a distinct entity. Statistical agencies have been established for several reasons: (1) to develop new information for an area of public concern (e.g., the Bureau of Labor Statistics, the National Center for Health Statistics); (2) to conduct large statistical collection and dissemination operations (e.g., the Bureau of the Census); (3) to compile and analyze statistics from sets of administrative records for policy purposes and public use (e.g., units in the Internal Revenue Service and the Social Security Administration); and (4) to develop broad and consistent estimates from a variety of statistical and administrative sources in accordance with a prespecified conceptual framework (e.g., the Bureau of Economic Analysis in the Department of Commerce and the Economic



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Page 13 Part II Commentary This part of the report comments on most of the topics in the principles and practices; the comments are offered to explain, illustrate, or further define the statement of principle in Part I. DEFINITION OF A FEDERAL STATISTICAL AGENCY A federal statistical agency is a unit of the federal government whose principal function is the compilation and analysis of data and the dissemination of information for statistical purposes. A statistical agency may be labeled a bureau, center, division, or office or similar title, so long as it is recognized as a distinct entity. Statistical agencies have been established for several reasons: (1) to develop new information for an area of public concern (e.g., the Bureau of Labor Statistics, the National Center for Health Statistics); (2) to conduct large statistical collection and dissemination operations (e.g., the Bureau of the Census); (3) to compile and analyze statistics from sets of administrative records for policy purposes and public use (e.g., units in the Internal Revenue Service and the Social Security Administration); and (4) to develop broad and consistent estimates from a variety of statistical and administrative sources in accordance with a prespecified conceptual framework (e.g., the Bureau of Economic Analysis in the Department of Commerce and the Economic

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Page 14 Research Service in the Department of Agriculture). Once established, many statistical agencies engage in all these functions to varying degrees. This definition of a federal statistical agency does not include many statistical activities of the federal government because they are not performed by distinct units, or because they do not result in the dissemination of statistics to others—for example, statistics compiled by the Postal Service to set rates or by the Department of Defense to test weapons (see, e.g., National Research Council, 1998b, on statistics and testing for defense acquisition). Nor does it include agencies whose primary functions are the conduct or support of problem-oriented research, although much of the research may be based on information gathered by statistical means, for example, by the Department of Energy's national laboratories and by the National Institutes of Health. Finally, this definition of a statistical agency does not usually include agencies whose primary function is policy analysis and planning (e.g., the Office of Tax Analysis in the Department of the Treasury, the Office of the Assistant Secretary for Planning and Evaluation in the Department of Health and Human Services). Such agencies may collect and analyze statistical information, and statistical agencies, in turn, may perform some policy-related analysis functions for their department. However, to maintain credibility as an objective source of accurate, useful information, statistical agencies must be separate from units that are involved in developing policy and assessing policy alternatives. The work of federal statistical agencies is coordinated through the Interagency Council on Statistical Policy (ICSP), created by the 1995 reauthorization of the Paperwork Reduction Act. The ICSP currently includes representation from 10 principal statistical agencies and from the statistical units in the Environmental Protection Agency, the Internal Revenue Service, the National Science Foundation, and the Social Security Administration (see Box II-1). Throughout the federal government, the Office of Management and Budget recognizes more than 70 units and agencies that are not statistical agencies but that have annual budgets of $500,000 or more for statistical activities (U.S. Office of Management and Budget, 2000). Many of the considerations in the principles and practices presented here may be pertinent to these agencies. Similarly, the principles and practices may be relevant to statistical units in state and local government agencies, and international audiences may find them useful as well.

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Page 15 BOX II-1 Federal Agencies Represented on the Interagency Council on Statistical Policy as of 2000 Office of Management and Budget (OMB), Chair Bureau of the Census, Department of Commerce Bureau of Economic Analysis (BEA), Department of Commerce Bureau of Justice Statistics (BJS), Department of Justice Bureau of Labor Statistics (BLS), Department of Labor Bureau of Transportation Statistics (BTS), Department of Transportation Economic Research Service (ERS), Department of Agriculture Energy Information Administration (EIA), Department of Energy National Agricultural Statistics Service (NASS), Department of Agriculture National Center for Education Statistics (NCES), Department of Education National Center for Health Statistics (NCHS), Department of Health and Human Services Office of Environmental Information, Environmental Protection Agency (EPA) Office of Research, Evaluation, and Statistics, Social Security Administration (SSA) Science Resources Studies Division, National Science Foundation (NSF) Statistics of Income Division (SOI), Internal Revenue Service ESTABLISHMENT OF A FEDERAL STATISTICAL AGENCY One of the most important reasons for establishing a statistical agency is to provide information that will allow for an informed citizenry. A democracy depends on an informed electorate. A citizen has a right to information that is relevant, accurate, and timely. Timely information of high quality is also critical to policy analysts and decision makers in both the public and private sectors. (For more information on the purposes of official statistics, see the Fundamental Principles of Official Statistics of the United Nations Statistical Commission in Appendix A.) Federal statistical agencies serve the key functions of providing a broad array of information to the public and policy makers and of ensuring the necessary quality and credibility of the data.

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Page 16 Private-sector organizations also provide useful statistical information, including data they compile and data collected by government agencies and others to which they add value. However, because the benefits of statistical information are shared widely throughout society and because it is difficult to collect payments for these benefits, private markets are not likely to provide all of the data that are needed for public and private decision making or to make data as widely available as needed for important public purposes. Government statistical agencies are established to ensure that a broad range of information is publicly available. (See National Research Council, 1999b, for a discussion of the governmental role in providing public goods, or near-public goods, such as research and data.) The United States collected and published statistics long before any distinct federal statistical agency was formed (see Duncan and Shelton, 1978; Norwood, 1995). The U.S. Constitution mandated the conduct of a decennial census of population beginning in 1790, and the census enumeration was originally conducted by U.S. marshals as just one of their many duties. Legislation providing for the compilation of statistics on agriculture, education, and income was enacted by Congress in the 1860s. The Bureau of Labor (forerunner of the Bureau of Labor Statistics) was established by law in 1884 as a separate agency with a general mandate to respond to widespread public demand for information on the conditions of industrial workers. The Bureau of the Census was established as a permanent agency in 1902 to conduct the decennial census and related statistical activities. Many federal statistical agencies that can trace their roots back to the 19th or early 20th century, such as the National Center for Education Statistics and the National Center for Health Statistics, were organized in their current form following World War II. Several new agencies were also established, such as the Energy Information Administration and the Bureau of Justice Statistics. In every case, the agency itself, in consultation with users of its information, has major responsibility for determining its specific statistical programs and for setting priorities. Initially, many of these agencies also had responsibilities for certain policy analysis functions for their department heads. More recently, policy analysis has generally been located in separate units that are not themselves considered to be statistical agencies. A statistical agency has at least two roles: (1) provider of the statistical information and analysis needed for policy and program administration by its own department and (2) source of national statistics for the public in its

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Page 17 area of concern. It is sometimes difficult to keep these two roles distinct on policy-relevant statistics. An effective statistical agency, nevertheless, will frequently play a creative, not just reactive, role in the development of data needed for policy analysis. Sometimes federal statistical agencies play additional roles, such as monitor and consultant on statistical matters to other units within the same department (see, e.g., National Research Council, 1985a) and collector of data on a reimbursable basis for other agencies. There is no set rule or guideline for when it is appropriate to establish a separate federal statistical agency, carry on statistical activities within the operating units of departments and independent agencies, or contract for statistical services from existing federal statistical agencies or other organizations. Establishment of a federal statistical agency may be considered when one or more of the following conditions prevail: There is a need for information extending beyond one-time uses and the scope of individual operating units, possibly involving other departments and agencies. Such needs may require coordinating data from various sources, initiating new data collection programs to fill gaps, or developing regularly updated time series of estimates. There is a need, in fact or as a matter of credibility, to ensure that major data series are independent of policy makers' control. There is a need to establish confidentiality of data by law or regulation covering a distinct organizational unit. When a separate statistical unit is established, the data it collects that could identify individual reporting units can be more easily protected by law or regulation from disclosure. Statistical agencies disseminate statistical data for statistical purposes; they do not disseminate identifiable data for administrative, regulatory, or enforcement uses. The functional separation of statistical data, recommended by the Privacy Protection Study Commission (1977), is easier to maintain when the data are compiled in a unit separate from operating units. At the same time, functional separation makes the promise of confidentiality more credible. There is a need to emphasize the principles and practices of an effective statistical agency, for example, professional practice, openness about the data provided, and wide dissemination of data. There is a need to encourage research and development of a broad range of statistics in a particular area of public interest or of government activity or responsibility. There is a need to consolidate compilation, analysis, and dissemina-

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Page 18 tion of statistics in one unit to encourage high-quality performance, eliminate duplication, and streamline operations. PRINCIPLES FOR A FEDERAL STATISTICAL AGENCY A federal statistical agency must be in a position to provide information relevant to issues of public policy. A statistical agency supplies information not only for the use of immediate managers and policy makers in the executive branch and for legislative designers and overseers in Congress, but also to all those who require statistical information on public issues, whether the information is needed for purposes of production, trade, consumption, or participation in civic affairs. Just as a free enterprise economic system depends on the availability of economic information to all participants, a democratic political system depends on wide access to information on education, health, transportation, the economy, the environment, criminal justice, and other social concerns. Federal statistical agencies are responsible for providing statistics on conditions in a variety of areas. The resulting information is used both inside and outside the government not only to delineate problems and sometimes to suggest courses of action, but also to evaluate the results of government activity or lack of activity. The statistics provide much of the basis on which the government itself is judged. This role places a heavy responsibility on federal statistical agencies for impartiality and objectivity. In order to provide information that is relevant for public policy, statistical agencies need to reach out to users of the data. Federal statistical agencies usually are in touch with the primary users in their own departments. Considerable energy and initiative are required to open avenues of communication more broadly to other current and potential users, including analysts and policy makers in other federal departments, state and local government agencies, academic researchers, private-sector organizations, organized constituent groups, the media, and Congress. Advisory committees representing major users are frequently employed and are recommended as a means to obtain users' views (see, e.g., National Research Council, 1993a). One frequently recommended method for alerting statistical agencies to emerging statistical information needs is for the agency's own staff to engage in analysis of its data (Norwood, 1975; Martin, 1981; Triplett,

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Page 19 1991). For example, relevant analysis may use the agency's data to examine correlates of key social or economic phenomena or to study the statistical error properties of the data. Such in-house analysis can lead to improvements in the statistics, to identification of new needs, to a reordering of priorities, and to closer cooperation and mutual understanding with policy analysis units. In its work for a policy analysis unit, a statistical agency describes conditions and possibly measures progress toward some previously identified goal, but it refrains from making policy recommendations. The distinction between statistical analysis and policy analysis is not always clear, and a statistical agency will need to consider carefully the extent of policy-related activities that are appropriate for it to undertake. A federal statistical agency must have a relationship of mutual respect and trust with those who use its data and information. Users of a statistical agency's data must be able to trust that the data were collected and analyzed in an objective, impartial manner and that they are as reliable as the agency can make them. An agency should make every effort to provide accurate and credible statistics that will permit policy debates to be concerned about policy, not about the credibility of the data. Credibility is enhanced when an agency fully informs users of the strengths and weaknesses of the data, makes data available widely, and consults with users about priorities for data collection and analysis. A federal statistical agency must have a relationship of mutual respect and trust with respondents who provide data and all data subjects whose information it obtains. The statistics program of the federal government relies in large part on information supplied by individuals and by organizations outside the federal government, such as state and local governments, businesses, and other organizations. Some of this information is required by law or regulation (such as employers' wage reports), some of it is related to administration of government programs (such as information provided by benefit recipients), but much of it is obtained through the voluntary cooperation of respondents in statistical surveys. Even when response is mandatory, the cooperation of respondents reduces costs and is likely to promote accuracy (see National Research Council, 1995). Important elements in encouraging such cooperation are that respondents believe that the data requested are

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Page 20 important, that they are being collected in an impartial, competent manner, and that the confidentiality of their responses will be protected. In brief, trust in a statistical agency must be maintained. The agency must not be perceived as being swayed by political considerations. It must be perceived as working in the national interest, not the interest of a particular administration, and as taking a long view, balancing new data needs against the need for consistency with past data (Ryten, 1990). Respondent trust also depends on providing respondents with realistic promises of confidentiality that the agency can reasonably expect to honor and then scrupulously honoring those promises. PRACTICES FOR A FEDERAL STATISTICAL AGENCY A Clearly Defined and Well-Accepted Mission A clear understanding of the mission of an agency, the scope of its statistical programs, and its authority and responsibilities is basic to planning and evaluating its programs and to maintaining credibility and independence from political control (National Research Council, 1986). Some agency missions are clearly spelled out in legislation; other agencies have only very general legislative authority. On occasion, very specific requirements may be set by legislation or regulation. Agencies should communicate their mission clearly to others. The use of the Internet is one means to publicize an agency's mission to a broad audience and to provide related information, including enabling legislation, the scope of the agency's statistical program, confidentiality provisions, and operating procedures. An agency's mission should focus on the compilation, evaluation, analysis, and dissemination of statistical information. In addition, considerable and formal attention must be paid to setting statistical priorities (National Research Council, 1976). Advice from outside groups should be sought on the agency's statistical program, on setting statistical priorities, on the statistical methods used, and on data products. Such advice may be sought in a variety of formal and informal ways, and it should be obtained from data users and providers as well as professional or technical experts in the subject-matter area and in statistical methods and procedures. A strong research program in the agency's subject-matter field can assist in setting priorities and identifying ways to improve an agency's statistical programs (Triplett, 1991).

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Page 21 A Strong Position of Independence A statistical agency must be able to provide credible information that may be used to evaluate the program and policies of its own department or the government as a whole. More broadly, a statistical agency must be a trustworthy source of objective, reliable information for decision makers, analysts, and others inside and outside the government who want to use statistics to understand current conditions, draw comparisons with the past, and help guide plans for the future. For these purposes, a strong position of independence for a statistical agency is essential. (See the Fundamental Principles of Official Statistics of the United Nations Statistical Commission in Appendix A.) Statistical agency independence must be exercised in a broader framework. Legislative authority usually gives ultimate responsibility to the department rather than the statistical agency head. In addition, an agency is subject to the normal budgetary processes and to various coordinating and review functions of the Office of Management and Budget (OMB), as well as the legislative mandates, oversight, and informal guidance of Congress. Within this broader framework, a statistical agency must work to maintain its credibility as an impartial purveyor of information. In the long run, the effectiveness of an agency depends on its maintaining a reputation for impartiality; thus, an agency must be continually alert to possible infringements on its credibility and be prepared to argue strenuously against such infringements. Independence of an agency head is usually encouraged when the head is appointed by the President with approval by the Senate. Examples of agencies with such an arrangement are the Bureau of the Census, the Bureau of Justice Statistics, the Bureau of Labor Statistics, the Bureau of Transportation Statistics, the Energy Information Administration, and the National Center for Education Statistics. A further safeguard is provided when such a head is appointed for a fixed term, as is currently the case with the Bureau of Labor Statistics, the Bureau of Transportation Statistics, and the National Center for Education Statistics. It is desirable that the term not coincide with the presidential term, so that incumbents need not end their leadership with changes of administration and professional considerations may more easily predominate over political aims in the appointment process. It is also desirable that a statistical agency head have direct access to the secretary of the department or the head of the independent agency in which

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Page 22 it is located. Such access allows the head to inform new secretaries about the appropriate role of a statistical agency and present the case for new statistical initiatives to the secretary directly. Among the agency heads with presidential appointments, such direct access currently is provided by legislation only for the Bureau of Labor Statistics and the Bureau of Transportation Statistics. These organizational aspects—appointment by the President with approval by the Senate, a fixed term not coincident with that of the administration, and direct access to the secretary of the agency's department— facilitate a strong position of independence for a statistical agency. However, they are neither necessary nor sufficient. Control over personnel actions, especially the selection and appointment of qualified professional staff, including senior executive career staff, is another aspect of independence. Agency staff reporting directly to the agency head should have formal education and deep experience in the substantive, methodological, operational, or management issues facing the agency as appropriate for their positions. In addition, professional qualifications are of the utmost importance for statistical agency heads, whether the profession is that of statistician or the subject-matter field of the statistical agency (National Research Council, 1997b). The American Statistical Association has, when requested, assisted in the development of a list of suitable candidates for heads of statistical agencies. Authority to decide the scope and content of the data collected or compiled is an important element of independence. Most statistical agencies have broad authority, limited by budgetary constraints, departmental interests, OMB review, and congressional mandates. In addition, the courts sometimes become involved in interpreting laws and regulations that affect statistical agencies, as in a number of issues concerning confidentiality and freedom of information, as well as in the issue of adjusting the census population counts. Congress frequently specifies particular data that it wishes to be collected (e.g., by the National Agricultural Statistics Service in the Department of Agriculture, the National Center for Health Statistics in the Department of Health and Human Services) and, in the case of the decennial census, requires an opportunity to review the proposed questions before the forms are printed. The OMB Office of Information and Regulatory Affairs, under the Paperwork Reduction Act (and under the preceding Federal Reports Act), has the responsibility for designating a single data collection instrument for information wanted by two or more agencies. It also

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Page 23 has the responsibility under the same act for reviewing all questionnaires and other instruments for the collection of data from 10 or more respondents. The budgetary constraints on statistical agencies and OMB review of data collections are ongoing; the other pressures depend, in part at least, on the relations between a statistical agency and those who have supervisory or oversight functions. Agencies need to develop skills in communicating to oversight groups the need for statistical series and credibility in assessing the costs of statistical work. In turn, although it is standard practice for the secretary of a department or the head of an independent agency to have ultimate responsibility for all matters within the department or agency, for credibility, the head of a statistical agency should be allowed full authority in professional and technical matters. Other aspects of independence that underscore a statistical agency's credibility are also important. These aspects include authority to release statistical information without prior clearance and authority for the statistical agency head and qualified staff to speak about the agency's statistics before Congress, with congressional staff, and before public bodies. It is important, when a statistical agency releases information publicly, that a clear distinction be made between the statistical information and any policy interpretations of such information by the secretary of the department, the President, or others. Not even the appearance of manipulation for political purposes should be allowed. This is one reason why statistical agencies adhere to predetermined schedules for the public release of important economic indicators and take steps to ensure that no person outside the agency can gain access to such indicators before the official release time (see U.S. Office of Management and Budget, 1985). Continual Development of More Useful Data Federal statistical agencies cannot be static. To provide information of continued relevance for public and policy use, they must continually anticipate data needs for future policy considerations and look for ways to develop data systems that can serve broad purposes. To improve the quality and timeliness of their information, they must keep abreast of methodological and technical advances and be prepared to implement new procedures in a timely manner. They must also continually seek ways to make their operations more efficient. Preparing for the future requires that agencies reevaluate existing data series, plan new data series as required, and be

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Page 28 from the point of view of the users as well as the issuers of the data. Agencies that release preliminary estimates must educate the public about differences among preliminary, revised, and final estimates. Cooperation with Data Users Users of federal statistical data span a broad spectrum of interests and needs. They include policy makers, planners, administrators, and researchers in federal agencies, state and local governments, the business sector, and academia. They also include activists, citizens, students, and media representatives. An effective statistical agency endeavors to learn about its data users and to obtain input from them on the agency's statistical programs. The needs of users can be explored by forming advisory committees, holding focus groups, analyzing requests and Internet activity, or by undertaking formal surveys of users. The task requires continual alertness to the changing composition and needs of users and the existence of potential users. An agency should cooperate with professional associations, institutes, universities, and scholars in the relevant fields to determine the needs of the research community and obtain their insight on potential uses. An agency should also work with relevant associations and other organizations to determine the needs of business and industry for its data. Within the limitations of its confidentiality procedures as noted above, an agency should seek to provide maximum access to its data, including making the data available to external researchers for secondary analysis (National Research Council, 1985b). Having data accessible for a wide range of analyses increases the return on the investment in data collection and provides support for an agency's program. Once statistical data are made public, they may be used in numerous ways not originally envisaged. An agency should attempt to monitor the major uses of its data as part of its efforts to keep abreast of user needs. Researchers and other users of data frequently request data from statistical agencies for specific purposes. The agency should have procedures in place for referring users to professionals within the agency who can comprehend the user's purposes and needs and who have a thorough knowledge of the agency's data. Statistical agencies should view these services as a part of their dissemination activities. Ensuring equal access requires avoiding release of data to selected individuals, organizations, or news media in advance of other users. Agencies that prepare special tabulations of their data on request for external groups

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Page 29 must be alert to the proposed uses. If the data are to be used in court cases, administrative proceedings, or collective bargaining negotiations, it is wise to have a known policy ensuring that all sides receive the special tabulations, regardless of which side requested them or paid the cost of the tabulation. Fair Treatment of Data Providers Protecting Confidentiality Data providers must believe that the data they give to an agency cannot be used to harm them. For statistical data collection programs, protecting the confidentiality of individual responses is considered essential to encourage high response rates and accuracy of response. Some agencies have legislative mandates supporting promises of confidentiality; others rely on strong statements of policy, legal precedents in court cases, or custom. The latter agencies risk having their policies overturned by judicial interpretations of legislation or executive decisions that may require the agency to disclose identifiable data collected under a pledge of confidentiality. Agencies that lack strong legal protection for confidentiality should be especially careful not to give data providers stronger promises of confidentiality than they can reasonably expect to honor. To give additional weight and stature to policies that statistical agencies have pursued for decades, OMB issued a Federal Statistical Confidentiality Order on June 27, 1997. This order assures respondents who provide statistical information to specified agencies that their responses will be held in confidence and will not be used against them in any government action, “unless otherwise compelled by law” (U.S. Office of Management and Budget, 1997). The heads of statistical agencies must be prepared to deal with requests from other units in their own department, from other agencies and organizations, and from the courts wanting to use individually identifiable data. When such uses would be contrary to confidentiality pledges to data providers, agency heads should do everything in their power under the law to deny access to the data. In all such circumstances, agencies must be prepared to stand firm and to justify the importance of a strong commitment to confidentiality for maintaining credibility and trust with the public, in particular with data providers, and therefore in maintaining the future quality and credibility of their statistics.

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Page 30 Statistical agencies devote much time and effort to avoid inadvertent disclosure of confidential information in disseminating data. Recently, the widespread dissemination of statistical data via the Internet has heightened attention by agencies to effective safeguards for confidential information. Risks are increased when data for small groups are tabulated, when the same data are tabulated in a variety of ways, or when public-use microdata files (samples of records for unidentified individuals or units) are released with highly detailed geographic or other characteristics. Because of the disclosure risks associated with detailed tabulations and public-use microdata files, there is always a tension between the desire to safeguard confidentiality and the desire to provide broader public access to data. This dilemma is an important one to federal statistical agencies, and it has stimulated ongoing efforts to develop new statistical and administrative procedures to safeguard confidentiality while permitting more extensive access. An effective federal statistical agency will exercise judgment in determining which of these procedures are best suited to its requirements to serve data users while protecting confidentiality. (For discussion of these issues and alternative procedures, see the report of the Panel on Confidentiality and Data Access [National Research Council, 1993b] and the report of the Workshop on Improving Access to and Confidentiality of Research Data [National Research Council, 2000].) Respecting Privacy To promote trust and encourage accurate response, it is important that statistical agencies respect the privacy of respondents to the extent possible. When data providers are asked to participate in a survey, they should be told whether the survey is mandatory or voluntary, how the data will be used, and who will have access to the data. In the case of voluntary surveys, information on these matters is necessary in order for data providers to give their informed consent to participate. Respondents invest time and effort in replying to surveys. The amount of effort varies considerably from survey to survey, depending on such factors as the complexity of the information that is requested. Statistical agencies should attempt to minimize such effort, to the extent possible, by using concepts and definitions that fit respondents' common understanding; by simplifying questionnaires; by allowing alternative modes of response (e.g., via the Internet) when appropriate; and by using administrative records or other data sources, if they are sufficiently complete and accurate

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Page 31 to provide some or all of the needed information. In surveys of businesses or other institutions, agencies should seek innovative ways to obtain information from the institution's records and minimize the need for respondents to reprocess and reclassify information. It is also the responsibility of agencies to use qualified, well-trained interviewers. As provided in OMB directives, respondents should be informed of the likely duration of a survey interview and, if the survey involves more than one interview, how many times they will be contacted over the life of the survey. This information is particularly important when respondents are asked to cooperate in extensive interviews, search for records, or participate in longitudinal surveys. Ways in which participation in surveys can be made easier for respondents and result in more accurate data can be explored by such means as focus group discussions or surveys. Many agencies apply the principles of cognitive psychology to questionnaire design, not only to make the resulting data more accurate, but also to make the time and effort of respondents more efficient (National Research Council, 1984). Some agencies thank respondents for their cooperation by providing them with brief summaries of the information after the survey is compiled. A reason that respondents reply to statistical surveys is because they have been persuaded that their answers will be useful to the government or to society generally. Statistical agencies should respect this contribution by compiling the data and making them accessible to users in convenient forms. A statistical agency has an obligation to publish statistical information from the data it has collected unless it finds the results invalid. Commitment to Quality and Professional Standards of Practice The best guarantee of high-quality results is a strong professional staff that includes experts in the subject-matter fields covered by the agency's program, experts in statistical methods and techniques, and experts in data collection, processing, and other operations. A major function of an agency's managers is to strike a balance among these groups and promote working relationships that make the agency's program as productive as possible, with each group of experts contributing to the work of the others. An effective statistical agency keeps up to date on developments in theory and practice that might be relevant to its program. An effective agency is also alert to changes in the economy or in society that may call for changes in the concepts or methods used in particular data sets. Often the

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Page 32 need for change conflicts with the need for comparability with past data series, and this issue can easily dominate consideration of proposals for change. Agencies have the responsibility to manage this conflict by initiating more relevant data series while producing statistical bridges between old and new series. An Active Research Program Substantive Research and Analysis There are strong arguments for a statistical agency to have staff whose responsibility is to conduct objective substantive analyses of the data that the agency compiles, such as analyses that assess trends over time or compare population groups: Agency analysts are in a position to understand the need for and purposes of the data and know how the statistics will be used. Such information must be available to the agency and understood thoroughly if the survey design is to produce the data required. Those involved in analysis can best articulate the concepts that should form the basic framework of a statistical series. Agency analysts are well situated to understand and transmit the views of external users and researchers; at the same time, close working relationships between analysts and data producers are needed for the translation of the conceptual framework into the design and operation of the survey. Agency analysts have access to the microdata and so are in a better position than analysts outside the agency to understand and describe the limitations of the data for analysis purposes. Substantive research by analysts on an agency's staff will have credibility because of the agency's commitment to openness about the data provided and maintaining independence from political control. Substantive research by analysts on an agency's staff can assist in formulating the agency's data program, suggesting changes in priorities, concepts, and needs for new data or discontinuance of outmoded or little-used series. As with descriptive analyses provided by the agency, substantive analyses must be designed to be relevant to policy but not take positions on policy options or be designed with any particular policy agenda in mind.

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Page 33 These issues are discussed in Norwood (1975), Martin (1981), and Triplett (1991). Methodological Research For statistical agencies to be innovative in methods for data collection, analysis, and dissemination, methodological research must be ongoing. Such research may be directed toward improving survey design; measuring and, when possible, reducing error from such sources as nonresponse and reporting errors; making data collection, processing, and dissemination operations more efficient; reducing the time and effort asked of respondents; or developing new and improved summary measures and estimation techniques. Much of what is current practice in statistical agencies was developed through research they conducted or obtained from other agencies. Federal statistical agencies, frequently in partnership with academic researchers, pioneered the applications of statistical probability sampling, the national economic accounts, input-output models, and other analytic methods. The U.S. Census Bureau pioneered the use of computers for processing the census, and research on data collection, processing, and dissemination operations continues to lead to creative uses of automated procedures and equipment in these areas. Several federal statistical agencies sponsor research using principles of cognitive psychology to improve the design of questionnaires, the clarity of data presentation, and the ease of use of electronic, data collection and dissemination tools such as the Internet. Such research has been furthered by interactions between statistical agencies and the academic community. The history of the statistical agencies has shown repeatedly that methodological research can lead to large productivity gains in statistical activities at relatively low cost. Research on Policy Uses Much more needs to be known on how statistics are actually used in the policy-making process, both inside and outside the government. Research on how the information produced by a statistical agency is used in practice should contribute to future improvements in the design, concepts, and format of data products. For example, public-use files of statistical microdata were developed in response to the growing analytic needs of government and academic researchers.

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Page 34 Gaining an understanding of the variety of uses and users of an agency's data is only a first step. More in-depth research on the policy uses of an agency's information might, for example, explore the use of data in microsimulation or other economic models, or go further to examine how the information from such models and other sources is used in decision making (see National Research Council, 1991a, 1991b). The focus of such research should be on ways to improve the relevance and accuracy of an agency's data for use in policy analysis and decision making, independent of any particular policy agenda. Professional Advancement of Staff An effective federal statistical agency has personnel policies that encourage the development and retention of a strong professional staff who are committed to the highest standards of quality work. There are several key elements of such a policy: The required levels of technical and professional qualifications for positions in the agency are identified, and the agency adheres to these requirements in recruitment and professional development of staff. Position requirements take account of the different kinds of technical and other skills, such as supervisory skills, that are necessary for an agency to have a full range of qualified staff, including not only statisticians, but also experts in relevant subject-matter areas, data collection, processing, and dissemination processes, and management of complex, technical operations. Continuing technical education and training of staff, appropriate to the needs of their positions, are provided by sponsoring in-house training programs and providing opportunities for external education and training. Professional activities, such as publication in refereed journals and presentations at conferences, are encouraged and recognized. Participation in relevant statistical and other scientific associations is encouraged to promote interactions with academic researchers and other data users. Such participation is also a mechanism for openness about the data provided. Interaction with other professionals is increased through technical advisory committees, supervision of contract research and research consultants, fellowship programs of visiting researchers, exchange of staff with relevant statistical, policy, or research organizations, and opportunities for new assignments within the agency. Accomplishment is rewarded by appropriate recognition and by af-

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Page 35 fording opportunity for further professional development. The prestige and credibility of a statistical agency is enhanced by the professional visibility of its staff, which may include establishing high-level nonmanagement positions for highly qualified technical experts. An effective statistical agency also has policies and practices to instill the highest possible commitment to professional ethics among its staff. When an agency comes under pressure to act against its principles—for example, if it is asked to disclose confidential information for an enforcement purpose or to support an inaccurate interpretation of its data—it must be able to rely on its staff to resist such actions as contrary to the ethical principles of their profession. An effective agency will refer its staff to such statements of professional practice as the guidelines published by the American Statistical Association and the International Statistical Institute on their Internet web sites ( www.amstat.org/profession; www.cbs.nl/isi/ethics.htm), as well as to the agency's own statements about protection of confidentiality and similar matters. It will endeavor in other ways to ensure that its staff are fully cognizant of the ethics that must guide their actions in order for the agency to maintain its credibility as a source of objective, reliable information for use by all. Coordination and Cooperation with Other Statistical Agencies The U.S. federal statistical system consists of many agencies in different departments, each with its own mission. Nonetheless, statistical agencies do not and should not conduct their activities in isolation. An effective statistical agency will actively explore ways to work with other agencies to meet current information needs, for example, by seeking ways to integrate the designs of existing data systems to provide new or more useful data than a single system can provide. An effective agency will also be alert for occasions when it can provide technical assistance to other agencies—including not only other statistical agencies, but also program agencies in its department—as well as occasions on which it can receive such assistance in turn. Efforts to standardize definitions further contribute to effective coordination of statistical agency endeavors, as does the development of broad macro models, such as the system of national accounts. Initiatives for sharing data among statistical agencies (possibly including individual data and address lists when permitted by law and when sharing does not violate confidentiality promises) can also be helpful for such purposes as achieving greater

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Page 36 efficiency in drawing samples or reducing duplication among statistical programs. The responsibility for coordinating statistical work in the federal government is specifically assigned to the Office of Information and Regulatory Affairs (OIRA) in the Office of Management and Budget by the Paperwork Reduction Act (previously, the Federal Reports Act and the Budget and Accounting Procedures Act). Some functions are undertaken by OIRA desk officers; others, by the OMB Statistical Policy Office. Under the Paperwork Reduction Act, OIRA desk officers review proposed data collection instruments. The Statistical Policy Office, generally working with the assistance of interagency committees, reviews concepts of interest to more than one agency; issues standard classification systems (of industries, metropolitan areas, etc.) and oversees their periodic revision; consults with other parts of OMB on statistical budgets; and, by reviewing the statistical program of the government as a whole, identifies gaps in statistical data, programs that may be duplicative, and areas in which interagency cooperation might lead to greater efficiency and added utility of data. The Statistical Policy Office also is responsible for coordinating U.S. participation in international statistical activities. The Statistical Policy Office encourages the use of administrative data for statistical purposes, when feasible, and works to establish common goals and norms on major statistical issues, such as confidentiality. It sponsors and heads the interagency Federal Committee on Statistical Methodology, which issues guidelines and recommendations on statistical issues common to a number of agencies (see Federal Committee on Statistical Methodology, 1978a-2000; see also www.fcsm.gov). It has encouraged the Committee on National Statistics at the National Academies to serve as an independent adviser and reviewer of federal statistical activities. The 1995 reauthorization of the Paperwork Reduction Act created the Interagency Council on Statistical Policy (ICSP), formalizing an arrangement whereby statistical agency heads participate with OMB to coordinate federal statistical activities. (See Box II-1 for a list of agencies represented on the ICSP.) There are many forms of interagency cooperation and coordination. Some efforts are multilateral, some bilateral. Many result from common interests in specific subject areas, such as economic statistics, statistics on people with disabilities, or statistics on children or the elderly. (See U.S. Office of Management and Budget, 2000, for a description of several current interagency collaborative efforts.) A common type of bilateral arrangement is the agreement of a pro-

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Page 37 gram agency to provide administrative data to a statistical agency to be used as a sampling frame, a source of classification information, or a summary compilation to check (and possibly revise) preliminary sample results. The Bureau of Labor Statistics, for example, benchmarks its monthly establishment employment reports to data supplied by state employment security agencies. Such practices improve statistical estimates, reduce costs, and eliminate duplicate requests for information from the same respondents. In other cases, federal statistical agencies engage in cooperative data collection with state counterparts to let one collection system satisfy the needs of both. A number of such joint systems have been developed, notably by the Bureau of Labor Statistics, the National Agricultural Statistics Service, the National Center for Education Statistics, and the National Center for Health Statistics. Another example of a joint arrangement is the case in which one statistical agency contracts with another to conduct a survey, compile special tabulations, or develop models. Such arrangements make use of the special skills of the supplying agency and facilitate use of common concepts and methods. The Bureau of the Census conducts many surveys for other agencies, as do the Bureau of Labor Statistics, the National Center for Health Statistics, and the National Agricultural Statistics Service. (See U.S. Office of Management and Budget, 2000, for a discussion of these and other reimbursable arrangements.) The major federal statistical agencies are also concerned with international comparability of statistics. Under the overall guidance of OMB's Statistical Policy Office, they contribute to the deliberations of the United Nations Statistical Commission and other international organizations, participate in the development of international standard classifications and systems, and support educational activities that promote improved statistics in developing countries. Several statistical agencies run educational programs for government statisticians in developing countries. Some statistical agencies have had long-term cooperative relationships with international groups, for example, the Bureau of Labor Statistics with the International Labor Organization, the National Agricultural Statistics Service with the Food and Agriculture Organization, and the National Center for Health Statistics with the World Health Organization. To be of most value, the efforts of statistical agencies to cooperate as partners with one another should involve the full range of their activities, including definitions, concepts, measurement methods, analytical tools, professional practice, dissemination modes, and disclosure limitation tech-

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Page 38 niques. Such efforts should also extend to the development of data, especially for emerging policy issues (National Research Council, 1999a). In some cases, it may be not only more efficient, but also productive of needed new data for agencies to fully integrate the designs of existing data systems, such as when one survey provides the sampling frame for a related survey. In other instances, cooperative efforts may identify ways for agencies to improve their individual data systems so that they are more useful for a wide range of purposes. Two of the more effective continuing cooperative efforts in this regard have been the Federal Interagency Forum on Aging-Related Statistics and the Federal Interagency Forum on Child and Family Statistics. The former was established in the mid-1980s by the National Institute on Aging, in cooperation with the National Center for Health Statistics and the Census Bureau. The forum's goals include coordinating the development and use of statistical data bases among federal agencies, identifying information gaps and data inconsistencies, and encouraging cross-national research and data collection for the aging population. The forum was reorganized in 1998 to include six new member agencies, and the reconfigured forum decided at its first meeting in March 1999 to focus on developing an indicators chart book, which was published the following year (Federal Interagency Forum on Aging-Related Statistics, 2000). The Federal Interagency Forum on Child and Family Statistics was formalized in a 1994 executive order to foster coordination and collaboration in the collection and reporting of federal data on children and families. It includes many relevant statistical and program agencies. Its annual reports (e.g., Federal Interagency Forum on Child and Family Statistics, 2000) describe the condition of America's children, including changing population, family characteristics, and the context in which children are living and indicators of well-being in the areas of economic security, health, behavior, social environment, and education. No single agency, whether a statistical or program agency, could have produced the forum reports alone. Working together in this way, federal statistical agencies contribute to data more relevant to policy concerns and to a stronger statistical system overall.