Ensuring the Quality of Data Disseminated by the Federal Government Workshop Report (2003) / Chapter Skim
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3. Draft Agency-Specific Guidelines
3. Draft Agency-Specific Guidelines
Pages 23-36
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From page 23... ...
The CIO was to file an annual agency report on data quality to the OMB, while the operating units were to publish their own reports. The agency also designed agency-wide standards for data quality and asked individual units to "adopt or adapt" these standards "where it makes sense," including statements on disclaimers, utility, integrity, and administrative mechanisms for corrections.
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From page 24... ...
To create these guidelines, the HHS assembled a data quality working group under its Data Policy Council. This Council is responsible for overseeing the dissemination of substantive information by the agency, including: · results of scientific research studies · statistical and analytic studies and products · programmatic and regulatory information, including program evaluations · public health surveillance, epidemiological and risk assessment studies and information; and · authoritative health, medical, and safety information initiated or sponsored by HHS.
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From page 25... ...
When the Bureau of Economic Analysis published income and productivity information, such data were considered disseminated. If a BEA economist, however, publishes a paper under his/her own name, it does not necessarily represent the view of the agency and is not considered disseminated.
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From page 26... ...
One agency offered more detail: "someone who has suffered injury to a legally protected interest, who can show a causal connection between agency action and injury, and who can show that correction will correct the injury." An agency might rule that one person was not affected by a ruling, and would not receive a response, while it might rule that another person was affected by the same ruling and would receive a response. · The issue of 'filters': The following conditions might filter out a response: the request does not pertain to disseminated information or "information" at all; the request is frivolous, trivial, or made in bad faith; the request is duplicative (e.g., one of many form letters, to which only one response is needed)
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From page 27... ...
end up operationalizing it, and work with program offices to process it." Environmental Protection Agency Ms. Barbara Pace noted that the guidelines were intended to provide guidance, not rules, and that the corrections process had been built on an existing process.
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From page 28... ...
That is, corrections deemed reasonable would be made, while those requiring significant resources might have to be reviewed individually. A representative of the Natural Resources Defense Council asked about the EPA's intention to weave an appeal into their notice and comment process, and whether that would comply with the intentions of the Act.
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From page 29... ...
Giving the results of his informal survey, Mr. Ashby said that the EPA had addressed this issue directly, listing categories of the most important agency actions, including those whose economic impact could be $100 million or more, or constituted the basis for new or revised policy.
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From page 30... ...
Ashby said, and some people will always disagree with those calls. As an aside, he noted that as stated in their comment letters, the position of the Chamber of Commerce was that all information pertaining to rule making should be considered influential; in another example, the American Bar Association did not agree with the use of an arbitrary line of $100 million in economic impact to determine influential information.
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From page 31... ...
The agency uses the following criteria for risk assessment that can be quantitative: · The three criteria listed above; · State appropriate upper-bound and/or lower-bound risk estimates; · Identify data gaps, other significant uncertainties; · Identify studies that would assist in reducing data gaps and uncertainties; and · Identify additional studies that support or fail to support the findings of the assessment and explain why they were not used.
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From page 32... ...
Mr. Ashby said that the OMB guidelines were "really an embellishment on the original statute." On the low end, a properly framed appeal for information might function as a due diligence check that is, did the agency in fact follow proper procedures in producing the information.
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From page 33... ...
In conclusion, said Dr. Garrison, both agencies had developed comprehensive policies to demonstrate the quality of the data they disseminated, as well as mechanisms for addressing challenges and providing reasonable avenues for affected parties to request corrections.
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From page 34... ...
Existing procedures already provide 2Several speakers noted the possibility that serial suits could be used as a harassment tactic to encumber research and ultimately delay agency action.
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From page 35... ...
Carney concluded by saying that EPA needs to be more specific about its time limits for correction requests, and how a petitioner has to demonstrate being harmed by the information. These guidelines need to be clear, she said, or the agency will be "overburdened." Next Steps in the Data Quality Process Over the course of the Spring and Summer 2002, agencies will receive comments from the public and will work with OMB on revising and finalizing their agency-specific guidelines.
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