The Executive Office of the President (EOP)

Office of Management and Budget (OMB)

Office of Information and Regulatory Affairs (OIRA)  The "information policy" function of OIRA includes improving the technical quality of information that agencies disseminate to the public  Other ‘information policy’ functions include privacy, data security, and e-government initiatives.

Selected OMB Information Quality Related Initiatives Executive Order 12866/13422 Circular A-4 Good Guidance Bulletin Paperwork Reduction Act Information Quality Act Information Quality Guidelines Peer Review Bulletin Updated Principles for Risk Assessment

Executive Order Regulatory Planning and Review (1993) Governs OIRA’s oversight of agency rulemaking, requiring OIRA review of “significant” agency regulatory actions. Regulatory Action: all substantive action by an agency that promulgates or is expected to lead to the promulgation of a final rule or regulation. Includes cross agency coordination; examination of legal authority; technical/scientific underpinnings; evaluation of regulatory impacts.

Good Guidance Bulletin and EO Update (2007) Goal is to increase the quality, transparency, accountability, and coordination with respect to significant guidance documents. Goal is to increase the quality, transparency, accountability, and coordination with respect to significant guidance documents. Two parts of a whole Two parts of a whole GGP Bulletin focuses on Agencies interaction with the public on guidance. GGP Bulletin focuses on Agencies interaction with the public on guidance. Establishes standards for guidance (e.g., non-binding). E.O. focuses on Agency interaction within the Executive Branch on guidance and all that it entails (including interagency review). E.O. focuses on Agency interaction within the Executive Branch on guidance and all that it entails (including interagency review). overarching policy concerns similar to those issues dealt with when reviewing regulations are of equal, if not more, importance.

OMB Circular A-4 for Regulatory Review (2003) Updated guidance on regulatory analysis, including as it relates to risk management decisions Updated guidance on regulatory analysis, including as it relates to risk management decisions Define the need for the proposed action Define the need for the proposed action Define the scope and identify the baseline Define the scope and identify the baseline Provide alternative regulatory options Provide alternative regulatory options Evaluate the benefits and costs of the proposed and alternative actions, including uncertainty analysis Evaluate the benefits and costs of the proposed and alternative actions, including uncertainty analysis

Paperwork Reduction Act (1995) Purpose: To improve the quality and practical utility of information required by the Federal Government, and to reduce the paperwork burden on the public. Relevant only to collections that involve people (as a general rule, if people are not being asked to fill out a survey, this Act does not apply). Surveys are reviewed to assure that the information collected is: Collected via the Least Burdensome approach Not Duplicative of other agency initiatives Has Practical Utility – study design; representativeness and power; privacy; data security.

Information Quality Act of 2000 Section 515 of the Treasury and General Government Appropriations Act for FY 2001 Section 515 of the Treasury and General Government Appropriations Act for FY 2001 Directed OMB to issue government-wide guidelines that provide policy and procedural guidance to Federal agencies for ensuring and maximizing the quality of information disseminated by Federal agencies. OMB issued its government-wide guidelines in interim- final form on September 28, 2001 and in final form on February 22, 2002 (67 FR8452). OMB issued its government-wide guidelines in interim- final form on September 28, 2001 and in final form on February 22, 2002 (67 FR8452).

Government-Wide Information Quality Guidelines (2002) Agencies must meet basic information quality standards, including pre-dissemination review. Applies to financial, statistical, and scientific information. Defines “quality.”

Definition of Information Quality Utility Usefulness of the information to the intended users. Objectivity Whether the disseminated information is presented in an accurate, clear, complete, and unbiased manner. Integrity Security and the protection of the information from unauthorized access or revision.

IQ Guidelines Embrace Good Government Transparency Results capable of being reproduced Flexibility The more important the information, the higher the quality standards should be.

OMB’S PEER REVIEW BULLETIN (2004) Extension of OMB efforts under Information Quality Act of 2000 Extension of OMB efforts under Information Quality Act of 2000 Pre-dissemination guidance for influential scientific information Pre-dissemination guidance for influential scientific information OMB issued Bulletin on Peer Review December 16, 2004 (FR notice published January 2005). OMB issued Bulletin on Peer Review December 16, 2004 (FR notice published January 2005). Agencies must peer review certain scientific information before it is disseminated to the public Agencies must peer review certain scientific information before it is disseminated to the public Minimum standards for those reviews Minimum standards for those reviews More rigorous review required of information that is likely to have the greatest impact on public policy or private sector decisions. More rigorous review required of information that is likely to have the greatest impact on public policy or private sector decisions. General good science/good government guidelines for peer review General good science/good government guidelines for peer review

Balancing the Investment Both the Guidelines and the Bulletin recognize that high quality comes at a cost and agencies should weigh the costs and benefits of higher information quality. The principle of balancing the investment in quality commensurate with the use to which it will be put is generally applicable to all data that the federal government generates. The principle of balancing the investment in quality commensurate with the use to which it will be put is generally applicable to all data that the federal government generates.

Dissemination “agency initiated or sponsored distribution of information to the public” Includes information which has the appearance of representing agency views (e.g., justification for a policy position). Does not include information that a federally employed scientist or Federal grantee or contractor publishes and communicates in the same manner as his/her academic colleagues. Researchers should use appropriate disclaimers such as “these views those of the author and do not necessarily reflect the view” of the agency. “Agency sponsored refers to situations where an agency has directed a third party to disseminate information or where the agency has the authority to review and approve the information before release. Agencies can provide funding to researchers without ‘sponsoring’ the dissemination.” Dissemination does not include distribution limited to correspondence with individuals or persons, press releases, archival records, public filings, subpoenas or adjudicative processes.

Data as a subset of ‘information’ The concept of dissemination covers both internal Agency databases and external information sources when they are used by the federal Government in support of a public policy decisions The concept of dissemination covers both internal Agency databases and external information sources when they are used by the federal Government in support of a public policy decisions Thus, the line between internal ADS and agency disseminated information is blurry, and somewhat artificial. Thus, the line between internal ADS and agency disseminated information is blurry, and somewhat artificial. Similarly, when non-government information is used to support public policy, the agency is endorsing its quality. Similarly, when non-government information is used to support public policy, the agency is endorsing its quality.

OMB Definition of Influential Influential Information: “Influential” 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.” Influential information needs to meet additional quality standards including reproducibility Agencies define criteria for influential within context of their mission.

Determining the Level of pre- dissemination review Is it subject to IQ Guidelines? Is it subject to IQ Guidelines? Is the agency disseminating it? Is the agency disseminating it? Is it also subject to Bulletin? Is it also subject to Bulletin? Is it influential scientific information? Is it influential scientific information? Is it also highly influential scientific assessment Is it also highly influential scientific assessment Is it also subject to the Principles of Risk Assessment? Is it also subject to the Principles of Risk Assessment? Is it also subject to Circular A-4? Is it also subject to Circular A-4?

Public aspects of the IQ Guidelines and the Bulletin Every agency has an IQ portal, which includes: Every agency has an IQ portal, which includes: Agency-level IQ Guidelines Agency-level IQ Guidelines Requests for correction Requests for correction Peer review ‘Agenda’ Peer review ‘Agenda’ Peer review plan – advance planning Peer review plan – advance planning Public comment – early input Public comment – early input Annual Report to OMB – required Annual Report to OMB – required Sent to Congress Sent to Congress Including corrections requested by the public, exemptions, waivers, deferrals, optional processes for peer review Including corrections requested by the public, exemptions, waivers, deferrals, optional processes for peer review

Peer Review Planning Website Website Update as needed, but at least every six months Update as needed, but at least every six months All planned information subject to the Bulletin All planned information subject to the Bulletin Link to relevant documents Link to relevant documents Mechanism to alter interested members of updates Mechanism to alter interested members of updates Mechanism for public comment Mechanism for public comment Plan Plan Description Description Level of influence Level of influence Mechanism (e.g., panel vs individual letter) Mechanism (e.g., panel vs individual letter) Number of reviewers Number of reviewers Expertise needed Expertise needed Opportunities for public comment and nomination of reviewers Opportunities for public comment and nomination of reviewers

Dove-tailing our Efforts For communicating the difference between the DQ Guidelines and the IQ Guidelines. For communicating the difference between the DQ Guidelines and the IQ Guidelines. Consider a change in name – e.g., Quality Guidelines for ADS Consider a change in name – e.g., Quality Guidelines for ADS For determining the level of quality assurance for ADS: For determining the level of quality assurance for ADS: What internal data systems (incl. ADS) are likely to be used to support government policy? What internal data systems (incl. ADS) are likely to be used to support government policy? Would any of these uses make the information influential? Would any of these uses make the information influential? For implementing the IQ guidelines: For implementing the IQ guidelines: Tweak current quality assurance practices to ensure that they dovetails with the IQ guideline. Tweak current quality assurance practices to ensure that they dovetails with the IQ guideline. Ensure that the peer review process (where applicable) is proactive (maintaining web accessible agenda). Ensure that the peer review process (where applicable) is proactive (maintaining web accessible agenda).