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INFORMATION QUALITY GUIDELINE

Introduction

The Office of the Special Inspector General for the Troubled Asset Relief Program (SIGTARP) disseminates a variety of information to the public. Section 515 of the Treasury and General Government Appropriations Act for Fiscal Year 2001 [Public Law 106-554] requires Federal agencies to issue guidelines ensuring and maximizing the quality, utility, objectivity, and integrity of disseminated information.

1.1 Background

The focus of Section 515 is on the Federal Government's information dissemination activities. Federal agencies have disseminated information to the public for decades. Until recently, agencies have disseminated information principally by making paper copies of documents available to the public. In recent years, Federal dissemination has grown.

Section 515 builds upon the existing Government-wide responsibility to ensure information quality. According to the Paperwork Reduction Act (PRA), the agency Chief Information Officers (CIO) must manage information resources to "improve the integrity, quality, and utility of information to all users within and outside the agency, including capabilities for ensuring dissemination of public information, public access to government information, and protections for privacy and security."

1.2 Purpose

This guidance should be used to ensure and maximize the quality of disseminated information. The Department's guidelines are based on the Office of Management and Budget (OMB) guidelines published in the Federal Register on September 28, 2001, January 3, 2002, and February 22, 2002. The guidelines are not intended to be legally binding regulations or mandates. They are not legally enforceable and do not create any legal rights or impose any legally binding requirements or obligations on the agency or the public. Nothing in these guidelines affects any otherwise available judicial review of agency action.

1.3 Scope

In accordance with OMB guidance, the Treasury guidelines will become effective on October 1, 2002. These guidelines will cover information disseminated on or after October 1, 2002, regardless of when the information was first disseminated.

Treasury bureaus and the Departmental Offices (DO) should use these guidelines to develop processes for disseminating quality information. The Internal Revenue Service (IRS) will develop Service-wide guidelines and processes.

The guidelines apply to information disseminated to the public in any medium including textual, graphic, narrative, numerical, or audiovisual forms. The guidelines apply to information that agencies post on the Internet. The guidelines also apply to Bureau or Departmental Offices sponsored distribution of information - where the agency directs a third party to distribute information or the agency has the authority to review and approve the information before release. If the Department is to rely on information submitted by a third party, for example, a commenter to a proposed rule, that information would need to meet appropriate standards of objectivity and utility.

The guidelines do not override other compelling interests such as privacy, trade secrets, intellectual property, and other confidentiality protections. The guidelines do not apply to Hyperlinks to information that others disseminate. The guidelines do not apply to opinions where the agency's presentation makes it clear that the material is an opinion or the agency's views rather than fact. In addition, the guidelines do not apply to information disseminated in the following contexts:

Dissemination of information limited to government employees or agency contractors or grantees.
Dissemination of information intended to be limited to intra- or inter-agency use or sharing of government information.
Correspondence with individual persons, archival records, public filings, subpoenas or adjudicative processes.
Response to requests for agency records under the Freedom of Information Act, the Privacy Act, the Federal Advisory Committee Act, or other similar laws.

1.4 Guidelines

It is Treasury's policy to ensure and maximize the quality, objectivity, utility, and integrity of the information that it disseminates to the public. Treasury will take appropriate steps to incorporate information quality criteria into Treasury's information dissemination practices, and will ensure the quality of information the agency disseminates in accordance with the standards set forth in these Guidelines. Treasury is committed to integrating the principle of information quality into every step of Treasury's development of information, including creation, collection, maintenance, and dissemination. Treasury will comply with all legal and policy rules, regulations, directives, and guidance at every step of the process. High quality information must be a performance goal for all Treasury information that is disseminated.

Treasury Bureaus and the Departmental Offices should:

develop standards of information quality;
adopt the standards as a performance goal;
incorporate the standards in information dissemination practices; and
ensure quality and establish levels of quality appropriate to the nature and timeliness of the information disseminated.

To ensure and maximize quality information, the standards should focus on the three underlying requirements for quality: utility, objectivity, and integrity of information.

1.4.1 Utility

In assessing the usefulness of information disseminated to the public, consider the uses of the information from the perspective of the public. When transparency of information is relevant for assessing information's usefulness from the public's perspective, address transparency when developing and reviewing the information. (Transparent refers to the clear, obvious and precise nature of the information.)

1.4.2 Objectivity

Objectivity involves two distinct elements, presentation and substance:

A. Presentation:

Disseminate information in an accurate, clear, complete, and unbiased manner. This involves presenting information within a proper context.
Where appropriate, data should have full, accurate, and transparent documentation, and should identify and disclose error sources affecting data quality.
Sometimes, in disseminating certain types of information to the public, other information must also be disseminated in order to ensure an accurate, clear, complete, and unbiased presentation.
1. Identify the sources of the disseminated information (to the extent possible, consistent with confidentiality protections).
2. In a scientific, financial, or statistical context, identify the supporting data and models so that the public can assess for itself whether there may be some reason to question the objectivity of the sources.

B. Substance:

Focus on ensuring accurate, reliable, and unbiased information.
In a scientific, financial, or statistical context, generate the original and supporting data, and develop the analytic results, using sound statistical and research methods.
1. If data and analytic results have been subjected to formal, independent, external peer review, the information may generally be presumed to be of acceptable objectivity.
2. If agency-sponsored peer review is employed to help satisfy objectivity, the review process shall meet the general criteria for competent and credible peer review, namely:
  1. peer reviewers must be selected primarily on the basis of necessary technical expertise;
  2. peer reviewers must be expected to disclose to agencies prior technical/policy positions they may have taken on the issues at hand;
  3. peer reviewers must be expected to disclose to agencies their sources of personal and institutional funding (private or public sector); and
  4. peer reviews must be conducted in an open and rigorous manner.
When disseminating influential scientific, financial, or statistical information, include a high degree of transparency about data and methods to facilitate the reproducibility of such information by qualified third parties.
1. Bureaus and the Departmental Offices may identify, in consultation with the relevant scientific and technical communities, those types of data that can practicably be subjected to a reproducibility requirement, given ethical, feasibility, or confidentiality constraints. Reproducibility of data is an indication of transparency about research design and methods and thus a replication exercise (i.e., a new experiment, test, or sample) is not required prior to each dissemination.
2. Concerning analytic results, provide sufficient transparency about data and methods so that a qualified member of the public could undertake an independent reanalysis. These transparency standards apply to agency analysis of data from a single study as well as to analyses that combine information from multiple studies.
3. The guidelines do not override other compelling interests such as privacy, trade secrets, intellectual property, and other confidentiality protections.
  1. In situations where public access to data and methods will not occur due to other compelling interests, apply especially rigorous robustness checks to analytic results and document what checks were undertaken.
  2. Disclose the specific data sources that have been used and the specific quantitative methods and assumptions that have been employed.
  3. Define the type of robustness checks, and the level of detail for documentation, appropriate for the nature and multiplicity of issues for which the agency is responsible.

1.4.3 Influential

At the Department of the Treasury, influential data/information is that which has a genuinely clear and substantial impact at the national level and on major public and private policy decisions as they relate to Federal financial issues. The accuracy of this information is significant due to the critical nature of these decisions. An example of influential data within Treasury would be the Treasury Bulletin. It contains data on the cash and debt operation of the Treasury and is used when deliberating over policy relating to government financing, such as debt limit issues.

For the purposes of this guidance, each bureau will develop function/program appropriate definitions for "influential" as they develop processes for disseminating quality information.

1.4.4 Integrity

Protect information from unauthorized access or revision, to prevent corruption or falsification of information. Comply with Government-wide, Treasury-wide and bureau security requirements and OMB Circulars A-123, A-127, and A-130 when disseminating information. In addition, comply with other regulation, depending on the nature of the information.

1.5 Process

1.5.1 Information Review Process

As a matter of good and effective information resources management, Bureaus and the Departmental Offices should develop processes for reviewing the quality (including the objectivity, utility, and integrity) of information before it is disseminated.

Treat information quality as integral to every step of the development of information, including creation, collection, maintenance, and dissemination.
Substantiate the quality of the information disseminated through documentation or other means appropriate to the information.

1.5.2 Information Collection Process

It is important that Treasury bureaus make use of OMB's Paperwork Reduction Act (PRA) clearance process to help improve the quality of information that the Department collects and disseminates to the public. Treasury bureaus are already required to demonstrate in their PRA submissions to OMB the "practical utility" of a proposed collection of information the bureau plans to disseminate. Additionally, for all proposed collections of information that will be disseminated to the public, Treasury bureaus should demonstrate in their PRA clearance submission to OMB that the proposed collection of information will result in information that will be collected, maintained, and used in a way consistent with the OMB and Treasury information quality guidelines.

1.5.3 Administrative Complaint Mechanism

Section 515 requires each agency to develop an administrative mechanism for receiving complaints and appeals regarding information quality. Using the administrative mechanism, affected persons can seek, and obtain where appropriate, timely correction of information that does not comply with OMB, Treasury or Bureau guidelines. These administrative mechanisms shall be flexible, appropriate to the nature and timeliness of the disseminated information, and incorporated into agency information resources management and administrative practices. Conduct both elements (complaint and appeal) of the administrative mechanism within the Bureau (or the Departmental Office), which disseminated the information.

Overall, OMB and Treasury do not envision administrative mechanisms that would burden agencies with frivolous claims. Instead, the correction process should serve to address the genuine and valid needs of Treasury and its constituents without disrupting agency processes. In making determinations of whether or not to correct information, bureaus may reject claims made in bad faith or without justification. They are required to undertake only the degree of correction that they conclude is appropriate for the nature and timeliness of the information involved and explain such practices in their annual fiscal year reports to Treasury.

A. Complaint Process

Treasury Bureaus and the Departmental Offices should respond to complaints and/or requests for correction in writing within 60 calendar days of receipt. If the complaint requires an extended period of time for processing, the agency must notify the petitioner. The agency must develop or identify the initial administrative complaint process for affected persons to seek and obtain correction of information that does not comply with OMB or Treasury Guidelines. The process should specify the name and address of the organization responsible for evaluating and responding to requests for correction of information disseminated. The process should meet designated timeframes for requests, evaluations, and agency response and should identify what is required from a petitioner, such as:

Description of the information deemed to need correction.
Manner disseminated and date of dissemination.
Specific error(s) cited for correction and proposed correction or remedy.
Specific manner in which the information does not comply with OMB or Treasury Guidelines.
How the person was affected and how correction would benefit them.
Petitioner's contact information for the agency reply on whether and how correction will be made.

Mail:
Office of the Special Inspector General
For The Troubled Asset Relief Program
1500 Pennsylvania Ave., NW, Suite 1064
Washington, D.C. 20220
Online Contact Form: SIGTARP Contact form
Facsimile: (202) 622-4559

Privacy Act Statement: We are authorized to collect the information you provide under section 515 of the Treasury and General Government Appropriations Act for Fiscal Year 2001 (Public Law No. 106-554 codified at 44 U.S.C. § 3516). It is needed to process your request and allow us to reply accordingly. You do not have to furnish the information, but failure to do so may prevent your request from being processed. The information you furnish is rarely used for any purpose other than to process and respond to your request. However, we may disclose information you give us (e.g., to Congressional Office, or Department of Justice) if authorized or required by Federal law, such as the Privacy Act.

B. Administrative Appeal Process

Treasury Bureaus and the Departmental Offices should develop an administrative appeal process in the event a petitioner is not satisfied with the reply. This right to an appeal should be included in the notice of denial issued during the complaint process.

After the petitioner receives a response or decision from the agency on a complaint, the incumbent must send their appeal of the ruling within 45 workdays in accordance with the instructions in the initial agency reply. The agency must respond to appeals and/or requests for correction in writing within 60 calendar days of receipt. If the response requires an extended period for processing, the agency must notify the petitioner. The bureau (or the Departmental Office) appeal process must include a final judgement by an official independent from the initial response.

C. Information on which the Agency Requested Public Comments

In some cases, a bureau may disseminate a study, analysis, or other information in connection with the issuance of a notice of proposed rulemaking or other action that involves well-established procedures for obtaining, considering, and responding to comments from the public. In most cases, comments concerning the quality of the disseminated information can be addressed through these procedures, such as by responding to a request for correction of the information in the preamble to a final rule. However, in unusual circumstances, it would be appropriate for a bureau to address such comments at an earlier time pursuant to these guidelines. For example, the procedures of these guidelines should be used if the commenter has shown a reasonable likelihood of suffering actual harm if the comment is not resolved before issuance of the final action and the bureau determines that resolving the matter pursuant to these guidelines will not unduly delay the final action.

1.6 Reporting Requirements

1.6.1 Bureau and Departmental Offices Reporting Requirements to the Department

The bureaus and the Departmental Offices will post their information quality standards on the Internet by October 1, 2002. These documents will be elements of the Treasury Department input to OMB. Periodically, there will be internal review and update of the standards to maintain quality and accuracy of the Information Review Process and the Administrative Complaint Mechanism.

On a fiscal-year basis, the bureaus and Departmental Offices shall submit a report to the Deputy Assistant Secretary for Information Systems and Chief Information Officer (DASIS/CIO). The reports shall identify the number and nature of complaints received regarding compliance with the guidelines and explain how the complaints were resolved. Bureaus and DO shall submit the reports by November 1, of each following year with the first report due November 1, 2003. Periodically, there will be internal review and update of the guidelines to ensure and maximize the quality of disseminated information.

1.6.2 Department Reporting Requirements to OMB

On a fiscal year basis, the DASIS/CIO will submit a report to the Director of OMB providing information on the number and nature of complaints and how such complaints were resolved. DASIS/CIO will submit the reports no later than January 1, of each following year with the first report due January 1, 2004.

1.7 Responsibilities

1.7.1 The DASIS/CIO shall:

provide management and oversight to the Treasury-wide implementation of the law;
develop and issue final information quality guidelines and post them on the Internet, by October 1, 2002;
coordinate standards formulation and posting by the bureaus and the Departmental Offices; and
report to the Director of OMB the number of and nature of complaints regarding compliance with the guidelines for the quality of disseminated information and how such complaints were resolved.

1.7.2 Treasury Bureaus and the Departmental Offices shall:

develop and issue final implementation plan for ensuring and maximizing the quality, objectivity, utility, and integrity of information, including statistical information, and post them to the Internet, by October 1, 2002;
develop an administrative mechanism for receiving and responding to information quality complaints;
designate a neutral organization responsible to serve as final arbiter regarding an appeal of the Bureau/Department Office decision on an information quality complaint; and
designate officials(s) to be responsible for compliance with the information quality processes within their organization and who shall:
1. maintain quality information procedures and educate officials on their use;
2. develop and manage an administrative mechanism for receiving and responding to information quality complaints and appeals;
3. provide multiple media sources for the filing of complaints (via mail, Internet, etc.);
4. post the information quality procedures and the administrative mechanism on the official Internet Web pages by October 1, 2002;
5. keep official records on complaints beginning October 1, 2002, and retain statistics necessary for annual reports to DASIS/CIO; and
6. prepare annual reports to DASIS/CIO beginning November 1, 2003.

Appendix A - Definitions

Affected Persons are people who may benefit or be harmed by the disseminated information. This includes persons who are seeking to address information about themselves as well as persons who use information.

Quality is an encompassing term comprising utility, objectivity, and integrity. Therefore, the guidelines sometimes refer to these four statutory terms, collectively, as "quality."

Utility refers to the usefulness of the information to its intended users, including the public. In assessing the usefulness of information that the agency disseminates to the public, the agency needs to consider the uses of the information not only from the perspective of the agency but also from the perspective of the public. As a result, when transparency of information is relevant for assessing the information's usefulness from the public's perspective, the agency must take care to ensure that transparency has been addressed in its review of the information.

Objectivity involves two distinct elements: presentation and substance.

"Objectivity" includes whether disseminated information is being presented in an accurate, clear, complete, and unbiased manner. This involves whether the information is presented within a proper context. Sometimes, in disseminating certain types of information to the public, other information must also be disseminated in order to ensure an accurate, clear, complete, and unbiased presentation. Also, the agency needs to identify the sources of the disseminated information (to the extent possible, consistent with confidentiality protections) and, in a scientific, financial, or statistical context, the supporting data and models, so that the public can assess for itself whether there may be some reason to question the objectivity of the sources. Where appropriate, data should have full, accurate, transparent documentation, and error sources affecting data quality should be identified and disclosed to users.
In addition, "objectivity" involves a focus on ensuring accurate, reliable, and unbiased information. In a scientific, financial, or statistical context, the original and supporting data shall be generated, and the analytic results shall be developed, using sound statistical and research methods.
1. If data and analytic results have been subjected to formal, independent, external peer review, the information may generally be presumed to be of acceptable objectivity. However, this presumption is rebuttable based on a persuasive showing by the petitioner in a particular instance. If agency-sponsored peer review is employed to help satisfy the objectivity standard, the review process employed shall meet the general criteria for competent and credible peer review recommended by OMB-OIRA to the President's Management Council (9/20/01) (http://www.whitehouse.gov/omb/inforeg/oira_review-process.html), namely, "that (a) peer reviewers be selected primarily on the basis of necessary technical expertise, (b) peer reviewers be expected to disclose to agencies prior technical/policy positions they may have taken on the issues at hand, (c) peer reviewers be expected to disclose to agencies their sources of personal and institutional funding (private or public sector), and (d) peer reviews be conducted in an open and rigorous manner."
2. If an agency is responsible for disseminating influential scientific, financial, or statistical information, agency guidelines shall include a high degree of transparency about data and methods to facilitate the reproducibility of such information by qualified third parties.
With regard to analysis of risks to human health, safety and the environment maintained or disseminated by the agencies, agencies shall either adopt or adapt the quality principles applied by Congress to risk information used and disseminated pursuant to the Safe Drinking Water Act Amendments of 1996 (42 U.S.C. 300g-1(b)(3)(A) & (B)). Agencies responsible for dissemination of vital health and medical information shall interpret the reproducibility and peer-review standards in a manner appropriate to assuring the timely flow of vital information from agencies to medical providers, patients, health agencies, and the public. Information quality standards may be waived temporarily by agencies under urgent situations (e.g., imminent threats to public health or homeland security) in accordance with the latitude specified in agency-specific guidelines.
If, at the end of the public comment period, an agency is not prepared to identify what kinds of original and supporting data will be subject to the reproducibility standard, then the agency must include in its guidelines a statement to the effect that the agency shall assure reproducibility for those kinds of original and supporting data according to - commonly accepted scientific, financial, or statistical standards

Integrity refers to the security of information -- protection of the information from unauthorized access or revision, to ensure that the information is not compromised through corruption or falsification.

Information for purposes of the data quality law, Section 515, means any communication or representation of knowledge such as facts or data, in any medium or form, including textual, numerical, graphic, cartographic, narrative, or audiovisual forms. This definition includes information that an agency disseminates from a web page, but does not include the provision of hyperlinks to information that others disseminate. Unlike the OMB Circular 130 definition, this definition does not include opinions, where the agency's presentation makes it clear that what is being offered is someone's opinion rather than fact or the agency's views.

Government information means information created, collected, processed, disseminated, or disposed of by or for the Federal Government.

Information dissemination product means any book, paper, map, machine-readable material, audiovisual production, or other documentary material, regardless of physical form or characteristic, an agency disseminates to the public. This definition includes any electronic document, CD-ROM, or web page.

Dissemination means agency initiated or sponsored distribution of information to the public (see 5 C.F.R. 1320.3(d) (definition of "Conduct or Sponsor"). Dissemination does not include distribution intended to be limited to: government employees or agency contractors or grantees; intra- or inter-agency use or sharing of government information; and responses to requests for agency records under the Freedom of Information Act, the Privacy Act, the Federal Advisory Committee Act or other similar law. This definition also does not include distribution intended to be limited to: correspondence with individuals or persons, press releases, archival records, public filings, subpoenas or adjudicative processes.

Influential, when used in the phrase "influential scientific, financial, or statistical information", means that the agency can reasonably determine that dissemination of the information will have or does have a clear and substantial impact on important public policies or important private sector decisions. Each agency is authorized to define "influential" in ways appropriate for it given the nature and multiplicity of issues for which the agency is responsible.

Reproducibility means that the information is capable of being substantially reproduced, subject to an acceptable degree of imprecision. For information judged to have more (less) important impacts, the degree of imprecision that is tolerated is reduced (increased). If agencies apply the reproducibility test to specific types of original or supporting data, the associated guidelines shall provide relevant definitions of reproducibility (e.g., standards for replication of laboratory data). With respect to analytic results, "capable of being substantially reproduced" means that independent analysis of the original or supporting data using identical methods would generate similar analytic results, subject to an acceptable degree of imprecision or error.

Appendix B - Laws, Regulations, and References

Public Law 106-554; H.R. 5658, "Treasury and General Government Appropriations Act for Fiscal Year 2001, Section 515."

Public Law 104-13, "Paperwork Reduction Act of 1995."

Public Law 104-182, Sec. 103, Subsec. 1(b)(3), "Safe Drinking Water Act Amendments of 1996." (Risk assessment, management, and communication.)

Public Law 100-235, "Computer Security Act of 1987."

(Site for all public laws http://www.gpoaccess.gov/plaws/index.html)

OMB Circular A-130, "Management of Federal Resources." (Appendix III, Security of Federal Automated Information Resources)

OMB Circular A-110, "Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations."

(OMB circulars can be found at http://www.whitehouse.gov/omb/circulars/.)

Federal Register Vol. 66, September 28, 2001, "Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies."

Federal Register Vol. 67, No. 2, page 369, January 3, 2002, "Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies; Final Guidelines."

Federal Register Vol. 67, No. 36, page 8452, February 22, 2002, "Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies; Republication."

(OMB site for Federal Register announcements can be found at http://www.whitehouse.gov/omb/inforeg/infopoltech.html)

Last updated: June 17, 2011

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