Information Quality Act
Expanded Oversight and Clearer Guidance by the Office of Management and Budget Could Improve Agencies' Implementation of the Act Gao ID: GAO-06-765 August 23, 2006The importance and widespread use of federal information makes its accuracy imperative. The Information Quality Act (IQA) required that the Office of Management and Budget (OMB) issue guidelines to ensure the quality of information disseminated by federal agencies by fiscal year 2003. GAO was asked to (1) assess OMB's role in helping agencies implement IQA; (2) identify the number, type, and source of IQA correction requests agencies received; and (3) examine if IQA has adversely affected agencies' overall operations and, in particular, rulemaking processes. In response, GAO interviewed OMB and agency officials and reviewed agency IQA guidelines, related documents, and Web sites.
OMB issued governmentwide guidelines that were the basis for other agencies' own IQA guidelines and required agencies to post guidelines and other IQA information to their Web sites. It also reviewed draft guidelines and undertook other efforts. OMB officials said that OMB primarily concentrated on cabinet-level and regulatory agencies, and 14 of the 15 cabinet-level agencies have guidelines. The Department of Homeland Security (DHS) does not have department-level guidelines covering its 22 component agencies. Also, although the Environmental Protection Agency and 4 other independent agencies posted IQA guidelines and other information to their Web sites, 44 of 86 additional independent agencies that GAO examined have not posted their guidelines and may not have them in place. As a result, users of information from these agencies may not know whether agencies have guidelines or know how to request correction of agency information. OMB also has not clarified guidance to agencies about posting IQA-related information, including guidelines, to make that information more accessible. Of the 19 cabinet and independent agencies with guidelines, 4 had "information quality" links on their home pages, but others' IQA information online was difficult to locate. From fiscal years 2003 to 2004, three agencies shifted to using IQA to address substantive requests--those dealing with the underlying scientific, environmental, or other complex information--which declined from 42 to 38. In fiscal year 2003, the Federal Emergency Management Agency and two other agencies used IQA to address flood insurance rate maps, Web site addresses, photo captions, and other simple or administrative matters. But, in fiscal year 2004, these agencies changed their classification of these requests from being IQA requests and instead processed them using other correction mechanisms. As a result, the total number of all IQA requests dropped from over 24,000 in fiscal year 2003 to 62 in fiscal year 2004. Also, of the 80 substantive requests that agencies received during the 2-year period--over 50 percent of which came from businesses, trade groups, or other profit-oriented organizations--almost half (39) of the initial agency decisions of these 80 were appealed, with 8 appeals resulting in changes. The impact of IQA on agencies' operations could not be determined because neither agencies nor OMB have mechanisms to determine the costs or impacts of IQA on agency operations. However, GAO analysis of requests shows that agencies can take from a month to more than 2 years to resolve IQA requests on substantive matters. According to agency IQA officials, IQA duties were added into existing staff responsibilities and administering IQA requests has not been overly burdensome nor has it adversely affected agencies' operations, although there are no supporting data. But evidence suggests that certain program staff or units addressing IQA requests have seen their workloads increase without a related increase in resources. As for rulemaking, agencies addressed 16 correction requests related to rulemaking under the Administrative Procedure Act, not IQA.
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Report to Congressional Requesters:
August 2006:
Information Quality Act:
Expanded Oversight and Clearer Guidance by the Office of Management and
Budget Could Improve Agencies' Implementation of the Act:
GAO-06-765:
GAO Highlights:
Highlights of GAO-06-765, a report to congressional requesters
Why GAO Did This Study:
The importance and widespread use of federal information makes its
accuracy imperative. The Information Quality Act (IQA) required that
the Office of Management and Budget (OMB) issue guidelines to ensure
the quality of information disseminated by federal agencies by fiscal
year 2003. GAO was asked to (1) assess OMB‘s role in helping agencies
implement IQA; (2) identify the number, type, and source of IQA
correction requests agencies received; and (3) examine if IQA has
adversely affected agencies‘ overall operations and, in particular,
rulemaking processes. In response, GAO interviewed OMB and agency
officials and reviewed agency IQA guidelines, related documents, and
Web sites.
What GAO Found:
OMB issued governmentwide guidelines that were the basis for other
agencies‘ own IQA guidelines and required agencies to post guidelines
and other IQA information to their Web sites. It also reviewed draft
guidelines and undertook other efforts. OMB officials said that OMB
primarily concentrated on cabinet-level and regulatory agencies, and 14
of the 15 cabinet-level agencies have guidelines. The Department of
Homeland Security (DHS) does not have department-level guidelines
covering its 22 component agencies. Also, although the Environmental
Protection Agency and 4 other independent agencies posted IQA
guidelines and other information to their Web sites, 44 of 86
additional independent agencies that GAO examined have not posted their
guidelines and may not have them in place. As a result, users of
information from these agencies may not know whether agencies have
guidelines or know how to request correction of agency information. OMB
also has not clarified guidance to agencies about posting IQA-related
information, including guidelines, to make that information more
accessible. Of the 19 cabinet and independent agencies with guidelines,
4 had ’information quality“ links on their home pages, but others‘ IQA
information online was difficult to locate.
From fiscal years 2003 to 2004, three agencies shifted to using IQA to
address substantive requests”those dealing with the underlying
scientific, environmental, or other complex information”which declined
from 42 to 38. In fiscal year 2003, the Federal Emergency Management
Agency and two other agencies used IQA to address flood insurance rate
maps, Web site addresses, photo captions, and other simple or
administrative matters. But, in fiscal year 2004, these agencies
changed their classification of these requests from being IQA requests
and instead processed them using other correction mechanisms. As a
result, the total number of all IQA requests dropped from over 24,000
in fiscal year 2003 to 62 in fiscal year 2004. Also, of the 80
substantive requests that agencies received during the 2-year
period”over 50 percent of which came from businesses, trade groups, or
other profit-oriented organizations”almost half (39) of the initial
agency decisions of these 80 were appealed, with 8 appeals resulting in
changes.
The impact of IQA on agencies‘ operations could not be determined
because neither agencies nor OMB have mechanisms to determine the costs
or impacts of IQA on agency operations. However, GAO analysis of
requests shows that agencies can take from a month to more than 2 years
to resolve IQA requests on substantive matters. According to agency IQA
officials, IQA duties were added into existing staff responsibilities
and administering IQA requests has not been overly burdensome nor has
it adversely affected agencies‘ operations, although there are no
supporting data. But evidence suggests that certain program staff or
units addressing IQA requests have seen their workloads increase
without a related increase in resources. As for rulemaking, agencies
addressed 16 correction requests related to rulemaking under the
Administrative Procedure Act, not IQA.
What GAO Recommends:
To help ensure that agencies covered by IQA meet requirements, GAO
recommends that OMB‘s Director take actions to (1) work with DHS to
help ensure it fulfills IQA requirements and set a deadline for doing
so; (2) identify other agencies without IQA guidelines and work with
them to develop and implement IQA requirements; and (3) clarify
guidance to agencies on improving the public‘s access to online IQA
information. OMB said it would continue working with DHS to develop
departmentwide guidelines and with other agencies to develop their
guidelines. OMB would also work with agencies to improve the online
dissemination of IQA information.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-765].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Brenda S. Farrell at
(202) 512-6806 or farrellb@gao.gov
[End of Section]
Contents:
Letter:
Results in Brief:
Background:
OMB Took Steps to Implement IQA, but IQA Guidelines and Information for
Many Agencies Are Not Available or Easily Accessible:
From Fiscal Years 2003 to 2004, Three Agencies Reclassified Correction
Requests to Concentrate on Substantive Matters:
Impact of IQA on Agencies Could Not Be Determined:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Scope and Methodology:
Appendix II: Independent Agencies Where Web Sites Were Checked for IQA
Guidelines:
Appendix III: Organizations That Filed IQA Correction Requests during
Fiscal Years 2003 and 2004:
Appendix IV: Comments from the Office of Management and Budget:
Tables:
Table 1: Cabinet-Level Agencies with IQA Guidelines:
Table 2: Distribution of Substantive IQA Requests by Category of
Petitioner, Fiscal Years 2003 and 2004:
Table 3: Substantive Fiscal Year 2003 and 2004 IQA Requests by Category
of Petitioner, Distribution by Agency, and Status as of May 2006:
Table 4: Status of 39 Appeals of Substantive Requests for Fiscal Years
2003 and 2004, as of March 31, 2006:
Table 5: Agencies Where We Interviewed IQA Officials:
Figure:
Figure 1: Time Line of Major IQA Milestones:
August 23, 2006:
The Honorable Henry A. Waxman:
Ranking Minority Member:
Committee on Government Reform:
House of Representatives:
The Honorable Bart Gordon:
Ranking Minority Member:
Committee on Science:
House of Representatives:
Federal agencies publicly disseminate a wide range of information that
is critical to government, business, and individuals. For example, the
open and efficient exchange of scientific and technical government
information, subject to applicable national security controls and the
proprietary rights of others, fosters excellence in scientific research
and effective use of federal research and development funds. Given the
widespread use of federal information by the public and private
sectors, it is important that this information be accurate.
The Information Quality Act (IQA)--section 515 of the Treasury and
General Government Appropriations Act for Fiscal Year 2001--required
the Office of Management and Budget (OMB) to issue governmentwide
guidelines to "ensure and maximize the quality, objectivity, utility,
and integrity of information, including statistical information,"
disseminated to the public.[Footnote 1] In addition, it required
agencies to issue their own guidelines, set up administrative
mechanisms to allow affected parties to seek the correction of
information they considered erroneous, and report periodically to OMB
information about IQA complaints (requests to correct agency
information) and how the agencies addressed them.
In light of questions you raised about IQA information that OMB
provided to Congress in its April 2004 report, you requested that we
examine the implementation of IQA.[Footnote 2] As agreed with your
offices, we (1) assessed OMB's role in helping agencies to implement
IQA; (2) identified the number, type, and source of correction requests
agencies received under IQA for fiscal years 2003 and 2004; and (3)
examined whether the implementation of IQA has adversely affected
agencies' overall operations in general and the rulemaking process in
particular.[Footnote 3]
To address the first objective, we reviewed documents, including IQA
guidelines; contacted and interviewed OMB staff and officials as well
as IQA and other knowledgeable officials from 12 cabinet-level agencies
and 5 independent agencies; and examined these agencies' Web
sites.[Footnote 4] In addition, we reviewed the Web sites of the other
cabinet agencies and 86 other independent agencies. To address the
second objective, we reviewed OMB and agency documents covering the 2-
year period, including annual reports submitted to OMB by agencies that
received correction requests, and interviewed OMB and agency officials
from those agencies. To address the third objective, we reviewed
relevant OMB and agency documents, including IQA guidelines and
agencies' annual reports to OMB, examined requests and appeals to
correct agency information, studied OMB's and agencies' Web sites, and
interviewed OMB and agency IQA and other knowledgeable officials. We
determined that OMB and agency IQA data were sufficiently reliable for
the purposes of this review and use in this report. Although agencies
have other mechanisms to correct information, we evaluated only
information related to the IQA correction mechanism. Appendix I
provides additional details on our scope and methodology. We conducted
our work in Washington, D.C., from March 2005 through July 2006 in
accordance with generally accepted government auditing standards.
Results in Brief:
As required by IQA, OMB issued guidelines for agencies, which agencies
used as the basis for developing their own IQA guidelines. OMB also
assisted agencies as they developed their IQA guidelines, reviewed
their draft guidelines, and established the mechanism agencies are to
use annually to report IQA information to OMB. OMB required agencies to
post IQA guidelines on their Web sites. In implementing IQA, according
to OMB officials, OMB primarily concentrated its efforts, including
outreach, on the cabinet-level and regulatory agencies. Fourteen of 15
cabinet agencies as well as the Environmental Protection Agency (EPA)
have IQA guidelines in place.
On the other hand, the Department of Homeland Security (DHS) does not
have departmentwide IQA guidelines, and four of its component agencies-
-including the Federal Emergency Management Agency (FEMA)--have IQA
guidelines corresponding to their previous departments or guidelines
that have not been updated by DHS. In addition, we did not find IQA
guidelines, references to IQA, or other IQA information on about half
(44) of the Web sites of 91 independent agencies we reviewed. Moreover,
even when IQA information was posted on agencies' Web sites, finding
that information on those Web sites was difficult. Of the 19 cabinet
and regulatory agencies with IQA guidelines that we examined, only the
Departments of Agriculture, Commerce, Energy, and the Interior provided
a direct IQA "information quality" link on their home pages that would
likely be easy for the public to find and use. Accessing IQA
information on the Web sites of the other 15 agencies we examined was
not easy because these agencies provided no discernable link to IQA
information; required multiple searches using various terms related to
IQA; or provided access to their guidelines and other information
through "contact us," "policies," or other less-than-obvious links,
such as "resources." OMB's guidance is not clear about how agencies
should provide access to online IQA information. Without clear and
easily accessible information about IQA, users of information from many
of these agencies may not know whether agencies have guidelines or how
to request correction of agency information.
From fiscal year 2003 to fiscal year 2004, three agencies shifted to
using IQA almost exclusively to address substantive requests--those
dealing with the underlying scientific, environmental, or other complex
information--which declined from 42 to 38. In fiscal year 2003, FEMA
and two agencies within the Departments of Labor and Transportation
used IQA to address flood insurance rate maps, Web site addresses,
photo captions, and other simple or administrative matters.[Footnote 5]
However, in fiscal year 2004, these agencies changed their
classification of these requests from IQA requests and instead
processed them using other correction mechanisms. As a result, the
total number of all IQA requests dropped from over 24,000 in fiscal
year 2003 to 62 in fiscal year 2004. Moreover, of the 80 substantive
requests that agencies received during the 2-year period, over 50
percent came from businesses, trade groups, or other profit-oriented
organizations. Almost half (39) of the initial agency decisions of
these 80 requests were appealed, and 8 appeals resulted in information
changes.
The impact of IQA on agencies' operations could not be determined
because agencies and OMB do not have mechanisms in place to track
implementing IQA. Agencies and OMB do not capture IQA workloads or cost
data, nor do they track the impact of IQA requests or resulting
information changes. Our analysis of requests found that agencies can
take from more than 1 month to more than 2 years and require the
involvement of a wide variety of staff to resolve IQA correction
requests, particularly if the requests center on substantive matters--
for example, endangered species or public health. Agency IQA officials
said that they incorporated IQA duties into existing staff
responsibilities, and administering IQA correction requests has not
been overly burdensome and has not adversely affected agencies'
operations, although they do not have data to support their views.
However, evidence suggests that certain program staff or units
addressing IQA requests have seen their workloads increase without a
related increase in resources. With respect to IQA requests related to
rulemaking, five agencies reported having received 16 such requests in
fiscal years 2003 and 2004; they addressed 10 of the 16 through the
notice and comment process of the Administrative Procedure Act rather
than IQA, rejected 2, and were developing or pending responses to the
remaining ones as of the end of March 2006. It should be recognized
that IQA correction requests could affect rulemaking outside of the
formal rulemaking process. For example, IQA correction requests that
are filed before an agency's formal rulemaking process begins could
affect when or if an agency initiates a rulemaking.
To help ensure that all agencies covered by the IQA fulfill their IQA
requirements, including implementing IQA guidelines and posting
information on how to file information correction requests, and promote
easier public access to IQA information on agency Web sites, we
recommend that the Director of OMB (1) work with DHS to help ensure it
fulfills IQA requirements and set a deadline for doing so, (2) identify
other agencies that do not have IQA guidelines and work with them to
develop and implement such guidelines, and (3) clarify guidance to
agencies on improving the public's access to online IQA information.
In written comments on a draft of this report, the Acting Administrator
of OMB's Office of Information and Regulatory Affairs (OIRA) stated
that OMB fully supports our recommendation that DHS develop IQA
guidelines and that OMB would continue to work with DHS to that end.
The Acting Administrator also stated that OMB would continue working
with other agencies as they develop and implement information quality
measures. He added that OMB shares GAO's interest in improving public
access to IQA information on agencies' Web sites and would continue to
work with agencies to improve their dissemination of IQA information in
a manner consistent with OMB policies. OIRA provided separate technical
corrections and suggestions to this draft, which we have incorporated
as appropriate. The written comments are reprinted in appendix IV.
Background:
IQA consists of two major elements. The first element of IQA required
OMB by the end of fiscal year 2001 to develop and issue guidelines that
provide policy and procedure guidance for federal agencies to use for
"ensuring and maximizing quality, objectivity, utility, and integrity
of information, including statistical information," that they
disseminate. The second element required federal agencies covered by
the Paperwork Reduction Act to develop IQA guidelines by the end of
fiscal year 2002, establish administrative mechanisms allowing
"affected persons" to seek and obtain correction of information
maintained and disseminated by the agencies, as well as periodically
report to the Director of OMB about the number and nature of IQA
complaints and how they handled such complaints.[Footnote 6]
IQA builds on previous federal efforts to improve the quality of
information, including OMB Circular A-130 and the Paperwork Reduction
Act of 1980, as amended. For example, two of the purposes of the
Paperwork Reduction Act were to "improve quality and use of federal
information — and provide for the dissemination of public information —
in a manner that promotes the utility of the information to the public
and makes effective use of information technology." IQA requires, among
other things, that executive branch agencies manage their information
resources to "improve the integrity, quality, and utility of
information to all users within and outside an agency."[Footnote
7],[Footnote 8]
OIRA, which develops and oversees the implementation of governmentwide
policies in the areas of information technology, privacy, and
statistics, had responsibility for developing the governmentwide IQA
guidelines and helping agencies to meet the act's requirement that they
develop their own guidelines. In an October 2002 memorandum describing
the implementation of IQA guidelines, OIRA's then administrator stated
he considered the IQA guidelines a continuation of the executive
branch's decades-long focus on improving the quality of information
federal agencies collect and disseminate. The memorandum added that
agencies' implementation "of the Information Quality Law represented
the first time that the executive branch has developed a governmentwide
set of information quality guidelines, including agency-specific
guidelines tailored to each agency's unique programs and information."
Agencies' guidelines, which were to follow OMB's model, were to include
administrative mechanisms that allow "affected parties"--as defined by
the agencies--to request correction of information that they did not
consider correct.
OMB Took Steps to Implement IQA, but IQA Guidelines and Information for
Many Agencies Are Not Available or Easily Accessible:
OMB set up a framework for federal agencies to follow in implementing
IQA, including providing assistance and direction to agencies in
developing agency IQA guidelines and requiring them to post IQA
information on their Web sites. However, we were not able to locate any
IQA information on about half of the independent agencies' Web sites
that we examined, nor could we find Federal Register notices about IQA
guidelines for them. According to OMB officials and OIRA's then
administrator, OIRA concentrated its communication and other outreach
efforts on cabinet-level and regulatory agencies. In written comments
on a draft of our report, OIRA noted that in working with agencies to
develop and implement information quality measures, it will consider
the needed resources for and the potential benefits of such measures.
Further, in a number of cases where IQA information was posted online,
locating the information was difficult. Agency IQA officials with whom
we met noted that their IQA correction mechanism is a formal process
and one of a number of correction mechanisms available to the public
for having information errors corrected.
OMB's OIRA Set Up Framework for IQA Implementation:
OMB set up a framework for agencies to follow in implementing IQA and
provided assistance and direction to agencies in developing their
guidelines. As required by IQA, OMB issued the basic set of
governmentwide IQA guidelines that agencies used as the basis for
developing their own guidelines. These guidelines explained what
agencies were to do to help ensure the development and public
dissemination of quality information. In developing these guidelines,
OIRA espoused three underlying principles that agencies were to reflect
in their guidelines:
* The guidelines are to apply to a wide variety of government
information dissemination activities that may vary in importance and
scope.
* Agencies are to meet basic information quality standards, noting that
the more important the information, "the higher the quality standards
to which it should be held," but that "agencies should weigh the costs
— and the benefits of higher information quality in the development of
information."
* Agencies are to apply the guidelines in "a common-sense and workable
manner," meaning that agency guidelines are not to "impose unnecessary
administrative burdens that would inhibit the agencies from continuing
to take advantage of the Internet and other technologies to disseminate
information that can be of great benefit and value to the public."
The guidelines, in elaborating on this last principle, explained that
"OMB encourages agencies to incorporate the standards and procedures
required by these guidelines into their existing — administrative
practices rather than create new and potentially duplicative or
contradictory processes." The guidelines also noted that they were
written to provide agencies with flexibility as they developed their
own guidelines.
Moreover, the guidelines defined four key concepts related to the
dissemination of information--quality, objectivity, utility, and
integrity--and described how quality was the outcome of the other three
components. These guidelines further explained that agencies were to
mirror these principles and actions in establishing their own
guidelines and to include an administrative mechanism that data users
who find mistakes in any agency's public data or information can use to
petition for correction. This mechanism was to include an appeals
process, which allows a petitioner to request that an agency reconsider
its initial decision about the correction request. The guidelines'
wording about the administrative correction mechanism allowed agencies
to avoid duplicating the public comment process required by the
rulemaking procedures under the Administrative Procedure Act, in which
interested persons are given the opportunity to comment on proposed
rules.
In addition to writing the governmentwide IQA guidelines, OIRA took
other steps to help agencies implement the principles and standards of
IQA. As part of helping agencies to develop their guidelines, OIRA
offered them assistance, including outreach to agencies such as
conducting workshops on drafting guidelines, and reviewed their
guidelines. IQA officials from a number of agencies, including the
Departments of Defense and Justice, told us they considered this
assistance beneficial. OIRA officials also issued memorandums to
clarify how agencies were to satisfy the law and otherwise implement
IQA, including requiring agencies to post IQA guidelines and related
information on their Web sites.[Footnote 9] Further, OIRA put in place
the mechanism for agencies to provide OMB with their annual IQA reports
on their implementation of IQA, the number of IQA requests and appeals,
and their status. According to OIRA staff and officials and agency
memorandums, OIRA monitored IQA correction requests received by
agencies and assisted them in developing their responses. Agency
officials told us that OMB's revisions consisted of comments that
ranged from editorial to significant and primarily involved IQA
requests pertaining to substantive issues. For example, agency
officials and OMB staff explained that OMB at times asked for more
detailed explanations, including references to other relevant
information, in agency responses to correction requests. According to
these officials, OMB's review did not cause changes that would have
substantially changed the agencies' ultimate decision. We found no
indication that OMB's involvement substantially changed agencies
responses when we examined nine specific IQA requests from four
agencies.
As described in figure 1, agencies covered by IQA were to have their
guidelines and the correction and appeals mechanism in place by the
start of fiscal year 2003 (October 1, 2002). The figure also shows that
in April 2004, OMB reported to Congress in response to a mandate that
OMB report on the first year--fiscal year 2003--of the implementation
of the act. That report included information about the characteristics
of the correction requests as well as the sources of the requests, and
commented on a number of common perceptions and concerns about the act.
OMB, of its own volition, in December 2005, updated this information
and included it in a chapter in its report to Congress on the costs and
benefits of federal regulations.[Footnote 10] In this report, OMB
provided information on the implementation of IQA in fiscal year 2004
and compared fiscal years 2003 and 2004 IQA information.
Figure 1: Time Line of Major IQA Milestones:
[See PDF for image]
Source: GAO analysis of OMB information.
Note: This time line excludes requirements and time frames related to
peer review, which OMB was developing and implementing at the time of
our review.
[A] The original deadline was July 1, 2002, but OMB extended it.
[End of figure]
OIRA Focused Its Efforts on Cabinet-Level and Regulatory Agencies:
According to OMB and OIRA staff and officials and OIRA's then
administrator, OIRA concentrated its efforts to implement IQA on
cabinet-level and regulatory agencies. In addition to working with the
cabinet agencies to create IQA guidelines, OIRA staff stated they also
focused their attention on regulatory agencies and commissions,
including EPA. OIRA did not clarify for many independent agencies--
especially smaller, nonregulatory ones--whether the law applied to them
or generally follow up with them to help them meet the act's
provisions. By the fiscal year 2002 deadline, 14 of the 15 cabinet-
level agencies had guidelines in place (see table 1).[Footnote 11]
Further, following the flurry of activities to help agencies develop
their IQA guidelines by October 1, 2002, OIRA shifted its emphasis away
from helping agencies develop their IQA guidelines to helping agencies
that already had guidelines to address IQA correction requests.
According to OIRA staff, since November 2002 OIRA has not promulgated
additional guidance regarding the development of IQA guidelines to
agencies.
Table 1: Cabinet-Level Agencies with IQA Guidelines:
Agencies:
Department of Agriculture;
Department of Commerce;
Department of Defense;
Department of Education;
Department of Energy;
Department of Health and Human Services;
Department of Housing and Urban Development;
Department of the Interior;
Department of Justice;
Department of Labor;
Department of State;
Department of Transportation;
Department of the Treasury;
Department of Veterans Affairs.
Source: GAO analysis of agency and OMB information.
[End of table]
Only one cabinet-level agency, DHS, the newest and one of the largest
federal agencies, has no department-level IQA guidelines covering its
22 agencies, which issue a wide array of information used by the
public. Because DHS was not created until January 2003--after IQA was
enacted and IQA deadlines had passed--OMB began working with DHS
officials to develop department-level guidelines after the other
cabinet-level and independent agencies had their guidelines in place,
according to OMB's April 2004 report to Congress.[Footnote 12] As of
March 2006, however, DHS did not have its IQA guidelines in place and
officials did not have a deadline for establishing them. Also, while 5
DHS component agencies had IQA guidelines before they became part of
DHS,[Footnote 13] the guidelines of 4 of the 5 component agencies--the
Coast Guard, Customs and Border Protection, FEMA, and Secret Service--
are still linked to their previous parent departments or otherwise have
not been updated by DHS. For example, the IQA guidelines for the Coast
Guard, which was previously part of the Department of Transportation
(DOT), instructed information users submitting IQA requests to file via
DOT's Docket Management System, the administrative mechanism that DOT
directs the public to use to file correction requests. Additionally,
FEMA has not updated its guidelines since becoming part of DHS. DHS
officials told us that the component agencies may update their
guidelines after DHS has its departmentwide guidelines in place. Until
that occurs, it is unclear what appeals process the public would follow
and how DHS agencies will make final decisions about IQA correction
requests.
Moreover, when we checked the Web sites of 91 independent agencies, we
did not find IQA guidelines posted on the Web sites of 44 of those
agencies. (See app. II for the list of independent agencies and the
status of their guidelines at the end of May 2006.) These 44
commissions, agencies, and other independent entities gave no
indication of any IQA guidelines or IQA reports, nor any mention of IQA
on their Web sites or on OMB's Web site of agencies' IQA guidelines. We
also could not find these agencies' Federal Register notices announcing
the establishment of their IQA guidelines, although OMB required these
notices. Also, OIRA staff did not have copies of the guidelines and
said that they had focused their attention on cabinet agencies and
regulatory agencies. These 44 agencies represented a broad spectrum of
entities--including fact-finding agencies, such as the U.S. Civil
Rights Commission; research organizations, such as the Smithsonian
Institution; and others, such as the U.S. Trade and Development Agency-
-that produce a wide range of publicly disseminated information. In
commenting on this report, the acting OIRA administrator noted that
OIRA will take into account the resources that would be needed and the
potential benefits that would be realized in working with agencies "to
develop and implement information quality measures."
Accessing Agencies' Web Site IQA Information Is Difficult:
Even when agencies posted IQA information on their Web sites as OMB
required, such information was hard to access, making it difficult for
information users to know whether agencies have IQA guidelines or how
to request correction of agency information. As part of the
governmentwide IQA guidelines, OIRA required agencies to post their
draft agency-specific IQA guidelines online by September 30, 2002, and
to inform the public about them and solicit comments. However, we found
it difficult to locate IQA information on agency Web sites. In addition
to the difficulties of trying to find whether the independent agencies'
Web sites contained IQA guidelines, we had problems finding IQA
guidelines on the Web sites of the 14 cabinet-level and 5 independent
agencies that we knew had those guidelines. Of these 19 cabinet-level
and independent agencies with IQA guidelines that we reviewed, only 4
agencies--the Departments of Agriculture, Commerce, Energy, and the
Interior--provided a direct IQA "information quality" link on their
home pages, which likely would be relatively easy for the public to use
to access IQA information. In the case of the 15 other agencies, we
found that accessing IQA information on their Web sites was difficult
because these agencies provided no discernable link to IQA information
on their home pages; provided access to their guidelines and other
information through "contact us," "policies," or other less-than-
obvious links, such as "resources"; or required multiple searches using
various terms related to IQA, as was the case with the Department of
Defense and the Department of State. Although OIRA directed agencies to
post IQA information online, OIRA's guidance is not specific about how
agencies should provide access to online IQA information. Moreover,
agency IQA officials told us that OMB did not provide guidance about
where to place IQA information on their Web sites or what kind of
access--or transparency--to provide. Agency IQA officials from a number
of agencies stated that access to their Web-based IQA information was
not "user-friendly" and said they were working to make IQA information
more transparent and easily accessible.
OMB is aware of the need to improve the public's access to IQA
information. In its April 2004 report to Congress, OIRA acknowledged
the need for agencies to improve the transparency of IQA information
and recommended that agencies include on their public Web sites IQA
correction requests, appeals, and agency responses to them, as well as
the agencies' annual IQA reports to OMB.[Footnote 14] OMB and OIRA
subsequently issued additional directives to facilitate the public's
ability to access government information and the process to request
correction of erroneous public information. For example, in August
2004, responding to "inconsistent practices regarding the public
availability of correspondence regarding information quality requests,"
OIRA's administrator issued a memorandum instructing each agency to
post its IQA documents online by December 1, 2004.
From Fiscal Years 2003 to 2004, Three Agencies Reclassified Correction
Requests to Concentrate on Substantive Matters:
From fiscal year 2003 to fiscal year 2004, three agencies shifted to
using IQA to address primarily substantive requests--those dealing with
the underlying scientific, environmental, or other complex information-
-which declined from 42 to 38. The total number of all IQA requests
dropped from over 24,000 in fiscal year 2003 to 62 in fiscal year 2004.
The overwhelming cause for this decline was that in fiscal year 2004
FEMA no longer classified requests to correct flood insurance rate maps
as IQA requests or addressed them through IQA. The decline in the
number of IQA requests does not indicate that there was a corresponding
decrease in agency workloads.
In fiscal year 2003, agencies reported having received over 24,600 IQA
correction requests, with FEMA's 24,433 requests accounting for over 99
percent of the year's total. FEMA's requests were all related to flood
insurance rate maps. Eighteen other agencies accounted for the balance
of the year's requests (183), 54 of which resulted in changes in
information, including clarifying language. In fiscal year 2004, FEMA,
with OMB's approval, no longer classified flood insurance rate map
correction as IQA requests. Instead, FEMA addressed flood insurance
rate map correction requests by using a correction process it had
implemented prior to the enactment of IQA. Largely as a result of this
change and a similar change by two other agencies--the Department of
Labor's Occupational Safety and Health Administration (OSHA) and DOT's
Federal Motor Carrier Safety Administration--in fiscal year 2004, 15
agencies reported a total of 62 IQA correction requests to OMB. Of
these, 26 requests resulted in changes.
As shown in table 2, from fiscal year 2003 to fiscal year 2004, the
number of substantive requests declined in terms of their total
numbers, decreasing from 42 in fiscal year 2003 to 38 in fiscal year
2004.
Table 2: Distribution of Substantive IQA Requests by Category of
Petitioner, Fiscal Years 2003 and 2004:
Source of Request: Business, trade group, or other profit-oriented
organization;
Requests in fiscal year 2003: Number: 22;
Requests in fiscal year 2003: Number: 52.4;
Requests in fiscal year 2004: Number: 22;
Requests in fiscal year 2004: Number: 57.9.
Source of Request: Nonprofit or other advocacy organization;
Requests in fiscal year 2003: Number: 12;
Requests in fiscal year 2003: Number: 28.6;
Requests in fiscal year 2004: Number: 10;
Requests in fiscal year 2004: Number: 26.3.
Source of Request: Private citizen;
Requests in fiscal year 2003: Number: 6;
Requests in fiscal year 2003: Number: 14.3;
Requests in fiscal year 2004: Number: 4;
Requests in fiscal year 2004: Number: 10.5.
Source of Request: Government;
Requests in fiscal year 2003: Number: 2;
Requests in fiscal year 2003: Number: 4.8;
Requests in fiscal year 2004: Number: 2;
Requests in fiscal year 2004: Number: 5.3.
Total;
Requests in fiscal year 2003: Number: 42;
Requests in fiscal year 2003: Number: 100;
Requests in fiscal year 2004: Number: 38;
Requests in fiscal year 2004: Number: 100.
Source: GAO analysis of agency and OMB data.
[End of table]
As shown in table 2, during fiscal years 2003 and 2004, over half of
the substantive IQA correction requests originated from businesses,
trade groups, or other profit-oriented organizations, and over one-
quarter were generated by nonprofit or other advocacy organizations.
(For a list of these requesters, see app. III.) Substantive requests
generated by individual citizens declined from about 1 in 7 of
substantive requests to about 1 in 10.
Substantive requests in fiscal year 2004 represented a greater
proportion of IQA correction requests than in fiscal year 2003,
excluding FEMA flood insurance rate map correction requests. Out of 183
non-FEMA requests in fiscal year 2003, 42--or almost one-fourth--were
substantive in nature. Addressing these substantive requests required
considerably more time and staff resources than simple or
administrative requests. OMB and agency officials considered the other
141 requests--over three-fourths--to be of a simple or administrative
nature--for example, requests to correct errors in photo captions,
personal information, or Internet addresses.[Footnote 15] Agencies were
able to quickly correct these simple or administrative requests--
correcting 17 requests took 7 or fewer days from the date the agencies
received them. In fiscal year 2004, of 62 total IQA requests, 38
requests--almost two-thirds--were considered to be substantive. Table 3
shows the 80 substantive requests for fiscal years 2003 and 2004 by
category of petitioner, agency, and status of requests, as of May 2006.
Table 3: Substantive Fiscal Year 2003 and 2004 IQA Requests by Category
of Petitioner, Distribution by Agency, and Status as of May 2006:
Agency: Department of agriculture[C];
Sources of Requests: Business/trade organization: 2;
Sources of requests: Nonprofit/advocacy organization: 2;
Sources of requests: Citizen: 1;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 5;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 1;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 1;
Sources of requests: 2-year Total[A]: 6;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 5;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 1.
Agency: Department of Commerce[C];
Sources of Requests: Business/trade organization: 1;
Sources of requests: Nonprofit/advocacy organization: 1;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 2;
Sources of Requests: Business/trade organization: 2;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 2;
Sources of requests: 2-year Total[A]: 4;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 4;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Department of Defense;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 1;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 1;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 1;
Sources of requests: Citizen: 1;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 2;
Sources of requests: 2-year Total[A]: 3;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 3.
Agency: Department of Education;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 1;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 1;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 0;
Sources of requests: 2-year Total[A]: 1;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 1;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Department of Energy;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 0;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 0;
Sources of requests: 2-year Total[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Department of Health and Human Services[C];
Sources of Requests: Business/trade organization: 8;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 2;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 10;
Sources of Requests: Business/trade organization: 6;
Sources of requests: Nonprofit/advocacy organization: 2;
Sources of requests: Citizen: 1;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 9;
Sources of requests: 2-year Total[A]: 19;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 9;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 6;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
2;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 2.
Agency: Department of Housing and Urban Development;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 0;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 0;
Sources of requests: 2-year Total[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Department of Homeland Security;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 0;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 0;
Sources of requests: 2-year Total[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Department of Interior[C];
Sources of Requests: Business/trade organization: 4;
Sources of requests: Nonprofit/advocacy organization: 1;
Sources of requests: Citizen: 0;
Sources of requests: Government: 1;
Sources of requests: Fiscal year 2003 Total: 6;
Sources of Requests: Business/trade organization: 3;
Sources of requests: Nonprofit/advocacy organization: 1;
Sources of requests: Citizen: 1;
Sources of requests: Government: 1;
Sources of requests: Fiscal year 2004 Total: 6;
Sources of requests: 2-year Total[A]: 12;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 9;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
1;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 2.
Agency: Department of Justice;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 1;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 1;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 1;
Sources of requests: Fiscal year 2004 Total: 1;
Sources of requests: 2-year Total[A]: 2;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 1;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 1;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Department of Labor;
Sources of Requests: Business/trade organization: 1;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 1;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 0;
Sources of requests: 2-year Total[A]: 1;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
1;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Department of State;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 0;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 1;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 1;
Sources of requests: 2-year Total[A]: 6;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 5;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 1.
Agency: Department of Transportation;
Sources of Requests: Business/trade organization: 1;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 1;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 2;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 1;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 1;
Sources of requests: 2-year Total[A]: 3;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 1;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
1;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 1.
Agency: Department of the Treasury;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 0;
Sources of Requests: Business/trade organization: 1;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 1;
Sources of requests: 2-year Total[A]: 1;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 1;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Department of Veterans Affairs;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 0;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 0;
Sources of requests: 2-year Total[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Access Board;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 0;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 0;
Sources of requests: 2-year Total[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Consumer Product Safety Commission;
Sources of Requests: Business/trade organization: 2;
Sources of requests: Nonprofit/advocacy organization: 1;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 3;
Sources of Requests: Business/trade organization: 1;
Sources of requests: Nonprofit/advocacy organization: 1;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 2;
Sources of requests: 2-year Total[A]: 5;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 3;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 1;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
1;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Commodities Futures Trading Commission;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 0;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 0;
Sources of requests: 2-year Total[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Environmental Protection Agency;
Sources of Requests: Business/trade organization: 3;
Sources of requests: Nonprofit/advocacy organization: 3;
Sources of requests: Citizen: 1;
Sources of requests: Government: 1;
Sources of requests: Fiscal year 2003 Total: 8;
Sources of Requests: Business/trade organization: 9;
Sources of requests: Nonprofit/advocacy organization: 3;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 12;
Sources of requests: 2-year Total[A]: 20;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 11;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 7;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
1;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 1.
Agency: Federal Communications Commission;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 0;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 1;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 1;
Sources of requests: 2-year Total[A]: 1;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 1;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Federal Deposit Insurance Commission;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 0;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 0;
Sources of requests: 2-year Total[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: National Archives and Records Administration;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 0;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 0;
Sources of requests: 2-year Total[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: National Aeronautics and Space Administration;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 1;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 1;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 0;
Sources of requests: 2-year Total[A]: 1;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 1;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Office of Science and Technology Policy[C]/Executive Office of
the President;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 1;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2003 Total: 1;
Sources of Requests: Business/trade organization: 0;
Sources of requests: Nonprofit/advocacy organization: 0;
Sources of requests: Citizen: 0;
Sources of requests: Government: 0;
Sources of requests: Fiscal year 2004 Total: 0;
Sources of requests: 2-year Total[A]: 1;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 1;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 0;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
0;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 0.
Agency: Total;
Sources of Requests: Business/trade organization: 22;
Sources of requests: Nonprofit/advocacy organization: 12;
Sources of requests: Citizen: 6;
Sources of requests: Government: 2;
Sources of requests: Fiscal year 2003 Total: 42;
Sources of Requests: Business/trade organization: 22;
Sources of requests: Nonprofit/advocacy organization: 10;
Sources of requests: Citizen: 4;
Sources of requests: Government: 2;
Sources of requests: Fiscal year 2004 Total: 38;
Sources of requests: 2-year Total[A]: 80;
Outcome of fiscal year 2003 and 2004 requests: No change made[A]: 48;
Outcome of fiscal year 2003 and 2004 requests: Change from initial
request[B]: 15;
Outcome of fiscal year 2003 and 2004 requests: Change from appeal[B]:
7;
Outcome of fiscal year 2003 and 2004 requests: Outcome pending: 10.
Source: GAO analysis of agency information.
[A] Includes three requests, each of which was filed with two agencies
and are therefore counted twice.
[B] "Change" means either full or partial correction of information.
[C] Includes requests filed with another agency. App. III identifies
these requests.
[End of Table]
One reason that substantive requests in fiscal year 2004 represented an
increased percentage of total IQA correction requests compared with
fiscal year 2003 is that in fiscal year 2004 some agencies decided to
exclude simple or administrative errors from IQA correction mechanisms.
Specifically, according to agency IQA documents and OMB's December 2005
report, in fiscal 2004, FEMA, the Department of Justice, the Federal
Motor Carrier Safety Administration, and OSHA no longer classified and
addressed most simple or administrative types of errors as IQA
correction requests. As a result, the majority of the correction
requests that remained to be processed through IQA were substantive
requests.[Footnote 16] For example, in fiscal year 2004, the Department
of Health and Human Services' (HHS) National Institutes of Health
received a request related to information about smokeless tobacco; EPA
received a request challenging information related to the water
conservation benefits of water utility billing systems of multifamily
housing; and the Department of the Interior's Fish and Wildlife Service
received a request that challenged information used to protect the
Florida panther.
We also found that no one agency dominated or accounted for the
majority of fiscal year 2004 requests. In fact, in fiscal year 2004 the
distribution of requests was more broadly spread across agencies than
in fiscal year 2003, with EPA and the National Archives and Records
Administration (NARA) each reporting 12 correction requests, and HHS
reporting 9 requests to OMB.
A few agencies did not experience a decrease in the total number of IQA
requests because they did not shift simple requests away from IQA or
otherwise change how they processed such requests during the 2-year
period. For example, according to OMB and NARA IQA documents, NARA's
IQA requests--8 in fiscal 2003 and 12 in fiscal 2004--continued to be
simple in nature and came primarily from individuals in both years. For
the same 2 years, EPA's 25 requests and HHS's 19 requests were nearly
all substantive and mainly came from businesses or profit-oriented
organizations as well as nonprofits or advocacy groups.
Agencies Changed Simple Requests More Often Than Substantive Requests
or Appeals during 2 Years:
In fiscal years 2003 and 2004, the simpler and more administrative the
initial request, the more likely an agency was to correct the
information without appeal. For example, during the 2-year period, NARA
corrected or clarified information for 16 of the 20 IQA correction
requests it received, which were all considered to be simple in nature.
Conversely, the more significant the correction request, the lower the
likelihood of a change. HHS, for example, addressed 19 IQA requests
that were substantive but changed information for only 5 based on the
initial request or an appeal. Regardless of the complexity of the
request, agency IQA documents showed that agencies addressed all
requests filed during the 2-year period.
Substantial requests were less likely to result in an initial
information change but more likely to be appealed than simple or
administrative requests. Few petitioners appealed agency decisions
regarding simple or administrative requests. None of 131 "simple or
administrative" fiscal year 2003 IQA requests from the Departments of
Transportation, Labor, and the Treasury and NARA was appealed. By
comparison, of the 80 substantive requests over the 2-year period,
petitioners appealed 39 (almost half) of the agencies' decisions. Of
the 39 requests that were appealed, 25 were denied and 8 appeals
resulted in information changes.
Table 4 shows the outcome or status of the appeals filed during fiscal
years 2003 and 2004, as of the end of March 2006.[Footnote 17] Two of
the 39 appeals still have outcomes pending after more than 2 years,
demonstrating that although the number of appeals may be considered
small, the impact on agency operations may be significant, depending on
the complexity of the specific issue. For example, in table 4, the EPA
appeal pending--filed by the U.S. Chamber of Commerce in April 2005--
affects 16 EPA databases that deal with such issues as wastewater
treatment and the bioaccumulation of organic chemicals. This case has
been ongoing for over 2 years, and could have effects on assessments
regarding human health risks, other environmental impacts, and cleanup
decisions. Also listed in table 3 is another IQA appeal filed in
October 2003 by a private individual. The initial request for
correction was filed in January 2003 before the DOT's Federal Aviation
Administration (FAA) challenging the analytical basis for its "age 60
rule" that forces air carrier pilots out of service at age 60. FAA
upheld its "age 60 rule" in September 2003, but the complainant filed
an appeal in October 2003 and filed additional amendments thereafter.
The request was still pending at the time we completed our study, more
than 3-½ years after the initial IQA request was made and almost 3
years after the appeal.
Table 4: Status of 39 Appeals of Substantive Requests for Fiscal Years
2003 and 2004, as of March 31, 2006:
Agency: Department of Agriculture;
Total appeals: 3;
No changes from appeals: 3;
Changes from appeals[A]: 0;
Appeal withdrawn: 0;
Outcome pending: 0.
Agency: Department of Commerce;
Total appeals: 3;
No changes from appeals: 2;
Changes from appeals[A]: 0;
Appeal withdrawn: 1;
Outcome pending: 0.
Agency: Department of Education;
Total appeals: 1;
No changes from appeals: 1;
Changes from appeals[A]: 0;
Appeal withdrawn: 0;
Outcome pending: 0.
Agency: Department of Health and Human Services;
Total appeals: 12;
No changes from appeals: 9;
Changes from appeals[A]: 2;
Appeal withdrawn: 1;
Outcome pending: 0.
Agency: Department of the Interior;
Total appeals: 4;
No changes from appeals: 3;
Changes from appeals[A]: 1;
Appeal withdrawn: 0;
Outcome pending: 0.
Agency: Department of Justice;
Total appeals: 1;
No changes from appeals: 0;
Changes from appeals[A]: 0;
Appeal withdrawn: 1;
Outcome pending: 0.
Agency: Department of Labor;
Total appeals: 1;
No changes from appeals: 0;
Changes from appeals[A]: 1;
Appeal withdrawn: 0;
Outcome pending: 0.
Agency: Department of Transportation;
Total appeals: 2;
No changes from appeals: 0;
Changes from appeals[A]: 1;
Appeal withdrawn: 0;
Outcome pending: 1.
Agency: Department of Veterans Affairs;
Total appeals: 1;
No changes from appeals: 0;
Changes from appeals[A]: 1;
Appeal withdrawn: 0;
Outcome pending: 0.
Agency: Consumer Product Safety Commission;
Total appeals: 1;
No changes from appeals: 0;
Changes from appeals[A]: 1;
Appeal withdrawn: 0;
Outcome pending: 0.
Agency: Environmental Protection Agency;
Total appeals: 9;
No changes from appeals: 6;
Changes from appeals[A]: 1;
Appeal withdrawn: 1;
Outcome pending: 1.
Agency: Office of Science and Technology Policy/Executive Office of the
President;
Total appeals: 1;
No changes from appeals: 1;
Changes from appeals[A]: 0;
Appeal withdrawn: 0;
Outcome pending: 0.
Agency: Total;
Total appeals: 39;
No changes from appeals: 25;
Changes from appeals[A]: 8;
Appeal withdrawn: 4;
Outcome pending: 2.
Source: GAO analysis of agency and OMB information.
[A] "Changes" means either full or partial correction of information.
[End of table]
As for the source of appeals, businesses, trade groups, and other
profit-oriented organizations filed more appeals than other types of
organizations or individuals. Businesses and profit-oriented
organizations accounted for 25 of the 39 appeals of IQA requests filed
during fiscal years 2003 and 2004. Of these 25 appeals, 4 resulted in
changes. Appeals from advocacy/nonprofit groups resulted in 1 change
from 5 appeals. Appeals from private citizens resulted in 3 changes
from 7 appeals. The most appeals--25, or almost two-thirds of them--
were filed with EPA, HHS, and the Department of the Interior. Those
agencies also received nearly two-thirds of the requests that were
classified as substantive.
Impact of IQA on Agencies Could Not Be Determined:
The impact of IQA on agencies could not be determined because agencies
and OMB do not have mechanisms in place to track the effects of
implementing IQA. Agencies and OMB do not capture IQA workloads or cost
data, nor do they track the impact of IQA requests or resulting
information changes. However, evidence indicates that in at least some
cases, addressing IQA requests and appeals can take agencies 2 years or
longer to resolve and requires a wide range of staff, particularly if
IQA correction requests center on substantive matters.
More specifically, none of the agencies we visited had information
about the actual workload, the number of staff days, or other costs,
with one exception.[Footnote 18] Agency IQA officials told us they do
not collect such data. They explained that their agencies did not
capture specific workload or cost data related to establishing IQA
guidelines, nor do they track workload or cost data involved in
responding to IQA requests or have mechanisms to measure any impact IQA
information changes have on operations or the quality of information.
Officials at two agencies--the National Aeronautics and Space
Administration and the Department of the Interior's Fish and Wildlife
Service--considered developing systems to track IQA costs but did not.
Fish and Wildlife Service officials told us they decided against
implementing an IQA cost tracking system because of the declining
number of requests they have received since fiscal years 2003 and 2004
and the high cost and administrative complexities of setting up such a
system. Additionally, IQA officials told us that addressing IQA
requests is considered to be part of their agencies' day-to-day
business, and because of the multifaceted nature of some requests,
allocating time and resources to one specific issue or linking work
exclusively to IQA requests would be difficult. For example, Fish and
Wildlife Service officials stated that when agency biologists work on
IQA requests, they are also frequently working on broad biological,
environmental, and related issues that go beyond a given request and
relate to other agency work, so it would be difficult to allocate the
biologists' time among various codes. In their view, selecting a
specific code would be somewhat arbitrary, and time or other codes
would not necessarily accurately reflect the cross-cutting nature of
the biologists' work. Moreover, according to agency officials and OMB
staff, neither the agencies nor OMB have mechanisms in place to track
the effects of implementing the law.
Agency IQA officials and OIRA staff and officials told us that
administering IQA has not been overly burdensome and that it has not
adversely affected agencies' overall operations to date. Agencies IQA
officials told us they gave IQA responsibilities to various staff
within their agencies--generally in offices already responsible for
information-related issues--and that no staff are dedicated exclusively
to administering IQA. For example, most agencies have folded
responsibilities for IQA, including setting up guidelines, into the
office of the chief information officer or their public affairs unit.
In addition, although they track the status of IQA correction requests,
they do not track changes resulting from IQA requests or appeals.
Although there is a lack of comprehensive IQA-related cost or resource
data, evidence suggests that certain program staff or units involved in
creating IQA guidelines, including the correction mechanism, and
addressing IQA correction requests have seen their workloads increase
without any corresponding increase in resources. For example, officials
at the Fish and Wildlife Service, HHS's National Institutes of Health,
the Department of Commerce's National Oceanic and Atmospheric
Administration, and the Department of Defense's Army Corps of Engineers
estimate the costs of addressing IQA requests are "many thousands of
dollars" because of the number of high salary professional staff, such
as biologists, toxicologists, engineers, and managers, who review and
respond to substantive requests and appeals and the extensive time
involved. According to agency IQA officials and OMB staff, agencies did
not receive funds for IQA, and the act did not specify any funds for
implementing IQA. Moreover, our analysis of IQA requests shows that
agencies have taken from 1 month to more than 1 year to produce a final
decision on substantive IQA requests and appeals, while 2 appeals made
during fiscal years 2003 and 2004 are still ongoing after 2 years or
longer. However, evidence does not exist showing the resources allotted
to those appeals over the 2-year period in question. The following IQA
requests illustrate the length of time it can take to address an IQA
correction, regardless of the final outcome.
* On March 10, 2004, a group of trade associations and organizations
primarily representing the residential and commercial properties sector
submitted an IQA request to EPA challenging the accuracy of an EPA
statement that water allocation (submetering) billing systems in
apartment buildings and other multifamily housing did not encourage
water conservation. This statement was in a Federal Register notice
regarding the applicability of the Safe Drinking Water Act to
submetered properties.[Footnote 19] The group did not consider the
statement to be correct regarding one type of allocation system in
particular--Ratio Utility Billing Systems. According to EPA documents
and officials, EPA's response to the request and subsequent appeal
involved a number of EPA staff, including senior executives,
scientists, and others in the Office of Water and other headquarters
units. The appeal itself was reviewed by a three-member panel of senior
executives. EPA took a total of almost 5 months (146 days) to respond
to the initial correction request, well over the 90-day goal stated in
EPA's IQA guidelines, and almost 11 months (323 days) more to decide on
the appeal, over three times longer than the 90-day appeals goal in
EPA's guidelines, according to our analysis of EPA IQA requests. The
nearly 15-month total response time was not unusual compared to other
EPA processing times for IQA requests. The lengthy response time was in
part due to EPA waiting for the completion of a related study--under
way at the time of the correction request--before making a final
decision about revising its submetering policy. On September 28, 2005,
EPA ultimately denied the appeal and did not change its statement,
citing the results of the study as not showing that Ratio Utility
Billing Systems encouraged water conservation.
* On May 4, 2004, a nonprofit organization representing public sector
employees involved in the environment and an individual federal
employee submitted an IQA request to the Fish and Wildlife Service
about alleged errors in agency documents, including the Multi-Species
Recovery Plan and the draft Landscape Conservation Strategy, which are
intended to protect the endangered Florida panther. The request and
subsequent appeal involved previously identified errors in peer-
reviewed research associated with the definition of panther habitat, as
well as estimates of panther population and models used to determine
strategies to help the panther species survive and recover in Florida.
Fish and Wildlife Service staff who evaluated and responded to the
initial request and to the appeal included senior executives,
attorneys, field biologists, and other professional staff from a number
of offices within headquarters, including the program offices, the
Solicitor's Office, the External Affairs Office, and the Director's
Office, as well as field offices in Vero Beach and Jacksonville,
Florida, and the regional office in Atlanta. The administrative appeals
panel for the correction request consisted of executives from Fish and
Wildlife Service headquarters and its Northwest Regional Office and
Interior's U.S. Geological Survey. Although the service responded to
the initial request 2 months after its receipt, it took more than 7-½
months (over 230 calendar days) to respond to the appeal. While the
initial response was consistent with the Service's 45-business day
response time stated in the guidelines, the appeal took over 6 months
more than the guideline's 15-business day appeal time frame, according
to our analysis. The nearly 300-day total response time was not unusual
compared to other Fish and Wildlife Service processing times for IQA
requests. On March 16, 2005, the Fish and Wildlife Service suspended
the draft conservation strategy for the panther, corrected other key
documents, posted notices on the regional and Vero Beach agency field
office Web sites about these actions, and revised and published for
public comment the panther section of the agency's recovery plan.
Agencies Treated Most IQA Rulemaking-Related Requests as Comments to
Proposed Rules:
According to OMB staff and agency IQA officials, IQA correction
requests have not adversely affected agency rulemaking procedures to
date, partly because agencies handled most IQA requests related to
rulemaking as public comments to proposed rules under the
Administrative Procedure Act rather than as IQA requests. This
approach, described in a number of agencies' IQA guidelines, including
EPA's and the Department of Agriculture's, was followed to avoid
duplicating the rulemaking comment process and diverting resources away
from the rulemaking process. It should be recognized that IQA
correction requests could affect rulemaking outside of the formal
rulemaking process. For example, IQA correction requests that are filed
before an agency's formal rulemaking process begins could affect when
or if an agency initiates a rulemaking.
We found 16 requests for corrections submitted during fiscal years 2003
and 2004 to be related to agency rulemaking. According to our analysis
of IQA requests, annual IQA reports sent to OMB, and OMB's own reports,
and as later confirmed by OMB, five agencies reported having received
16 IQA requests related to rulemaking for the 2-year period. These five
agencies were EPA, the Fish & Wildlife Service, the Department of
Agriculture's Forest Service, the Department of the Treasury's Alcohol
and Tobacco Tax and Trade Bureau, and DOT. These 16 requests--touching
on a diverse range of issues, such as air safety, alcohol, chemicals,
and the environment--accounted for almost 1 in 5 substantive requests
for the 2 years.
* The Fish and Wildlife Service received the largest number of
rulemaking-related IQA requests out of the 16 requests related to
regulations or rules during fiscal years 2003 and 2004. Seven of the
Service's 11 requests were related to proposed rulemaking. These 7
requests represented 44 percent of all rulemaking-related IQA requests
received by all agencies during the 2 years.
* The agencies treated 10 of the 16 requests that they received during
the 2-year period as comments to proposed rules rather than processing
them as IQA requests, and the agencies so informed the IQA petitioner.
For example, the Alcohol and Tobacco Tax and Trade Bureau considered an
IQA request regarding flavored malt beverages and related proposals as
comments to a proposed rule. The bureau informed the IQA petitioner
that it was handling the request as a public comment under the
procedures of the Administrative Procedure Act, rather than as an IQA
correction request. Agencies similarly processed the other nine
requests related to regulations or rulemaking.
* As for the other six IQA requests related to rulemaking or
regulations, agencies rejected two, are developing responses to two,
and were--as of the end of March 2006--awaiting additional information
or court decisions before responding to the remaining two.
Conclusions:
OMB's governmentwide IQA guidelines provide agencies with flexibility
to develop their own guidelines to suit their missions. Having
executive branch agencies use the Internet to inform the public about
the existence of their IQA guidelines, including the IQA correction
mechanism, is a step toward improving the transparency of how agencies
develop and disseminate information and address information errors, as
well as how information users can seek correction of information.
Given the current status of IQA at agencies, OMB has before it
additional opportunities to build on its efforts in implementing IQA so
far, a mission on which it embarked a few years ago. For example, it
could draw from its experience of working with cabinet and many
independent agencies to put additional agency-specific guidelines in
place. Likewise, OMB could apply the knowledge from the lessons it and
agencies have learned about posting accessible, user-oriented
information on agency Web sites. By working with agencies and tapping
into public input, OMB could enhance agencies' and the public's
involvement in promoting high-quality agency information as well as
increasing the public's access to and confidence in that information,
thereby helping to further the goal of disseminating quality
information.
Recommendations for Executive Action:
To help ensure that all agencies covered by IQA fulfill their
requirements, including implementing IQA guidelines and helping to
promote easier public access to IQA information on agency Web sites, we
recommend that the Director of OMB take the following three actions:
* work with DHS to help ensure it fulfills IQA requirements and set a
deadline for doing so;
* identify other agencies that do not have IQA guidelines and work with
them to develop and implement IQA requirements; and:
* clarify guidance to agencies on improving the public's access to
online IQA information, including suggestions about clearer linkages to
that information, where appropriate.
Agency Comments and Our Evaluation:
In written comments on a draft of this report, the Acting Administrator
of OMB's OIRA responded to our recommendations. Regarding our draft
report's recommendation to OMB to work with DHS and other agencies not
meeting IQA requirements, the Acting Administrator stated that OMB
fully supports our recommendation that DHS develop IQA guidelines and
that OMB would continue to work with DHS to that end. In our draft
report, we had one recommendation for OMB to work with DHS and other
agencies to develop IQA guidelines. Based on OIRA's comments, in our
final report we made two separate recommendations regarding DHS and the
other agencies developing IQA guidelines. Further, we believe that as
OIRA continues to work with DHS--which has 22 component agencies--
setting a deadline for DHS to implement IQA guidelines is important. As
for the other agencies (many of which are small) without IQA
guidelines, OIRA stated it would work with them as they develop and
implement information quality measures. OIRA stated that in those
efforts, it would consider the resources that would be needed and the
potential benefits that would be achieved by having IQA guidelines in
place. Regarding our recommendation about public access to online IQA
information, OIRA noted it shares GAO's interest in improving public
access and will continue to work with agencies to improve dissemination
of IQA information. OIRA also provided separate technical corrections
and suggestions to the draft of our report, which we have incorporated
as appropriate. The written comments are reprinted in appendix IV.
As agreed with your offices, unless you release its contents earlier,
we plan no further distribution of this report until 30 days from its
date. At that time we will send copies to other interested
congressional committees and the Acting Administrator of OIRA. This
report will also be available at no charge on GAO's Web site at
[Hyperlink, http://www.gao.gov]v.
If you or your staff have any questions concerning this report, please
contact me on (202) 512-6806 or by e-mail at farrellb@gao.gov. Contact
points for our Offices of Congressional Relations and Public Affairs
may be found on the last page of this report. Key contributors to this
report were Robert Goldenkoff, Assistant Director; Ernie Hazera,
Assistant Director; Andrea Levine; Keith Steck; and Margit Willems
Whitaker.
Signed by:
Brenda S. Farrell:
Acting Director Strategic Issues:
[End of section]
Appendix I: Scope and Methodology:
To assess the Office of Management and Budget's (OMB) role in
implementing the Information Quality Act (IQA), we reviewed OMB's IQA
documents, including memorandums sent to agencies, and interviewed
Office of Information and Regulatory Affairs (OIRA) staff involved with
IQA.[Footnote 20] In addition, we reviewed IQA documents--including
guidelines, requests and appeals, agency decisions, and related
documents--and interviewed IQA and other knowledgeable officials at the
17 federal agencies identified in table 5. While we reviewed IQA
guidelines at all cabinet-level agencies, we conducted interviews at 5
independent agencies and 12 of the 15 federal cabinet agencies and at
least one component of each, as shown in table 5.
Table 5: Agencies Where We Interviewed IQA Officials:
Cabinet agencies and component: Department of Agriculture;
* Forest Service;
Cabinet agencies and component: Department of Housing and Urban
Development.
Cabinet agencies and component: Department of Commerce;
* National Oceanic and Atmospheric Administration;
Cabinet agencies and component: Department of the Interior;
* Fish and Wildlife Service.
Cabinet agencies and component: Department of Defense;
* Army Corps of Engineers;
Cabinet agencies and component: Department of Justice;
* Bureau of Justice Statistics.
Cabinet agencies and component: Department of Energy;
* Energy Information Administration;
Cabinet agencies and component: Department of Labor;
* Occupational Safety and Health Administration.
Cabinet agencies and component: Department of Health and Human
Services;
* National Institutes of Health;
Cabinet agencies and component: Department of Transportation;
* Federal Motor Carrier Safety Administration.
Cabinet agencies and component: Department of Homeland Security;
* Transportation Safety Administration;
* Federal Emergency Management Agency;
Cabinet agencies and component: Department of the Treasury;
* Internal Revenue Service.
Cabinet agencies and component: Independent agencies.
Consumer Product Safety Commission;
National Aeronautics and Space Administration.
Environmental Protection Agency;
Nuclear Regulatory Commission.
Federal Deposit Insurance Corporation.
Source: GAO analysis of agency information.
[End of table]
We selected these agencies to obtain a cross section of agencies that
reflect the diverse range of government activities. We made our
selection to cover a wide range of criteria, including the
organization's size (number of employees in fiscal year 2004); its
mission (regulatory versus statistical, for example); and the nature of
issues covered by the agency--such as the environment, health, and
safety.[Footnote 21] We discussed with agency officials the development
of their IQA guidelines, whether they had received requests for
correction of information and how they addressed them, and what role
OMB played in all of this.
To further evaluate OMB's role in the implementation of IQA, we
reviewed OMB and agency IQA documents for all 15 cabinet agencies and
the 5 independent agencies we contacted. These documents included
online information, such as OMB memorandums and agency IQA guidelines,
related IQA information, and OMB and agency IQA Web sites.
Additionally, we reviewed the Web sites of 86 other independent
agencies, including commissions, boards, and other entities, covered by
the Paperwork Reduction Act to determine whether they had IQA
guidelines online, but we did not survey them. Further, we reviewed the
Federal Register for notices about these agencies' IQA guidelines, as
OMB required. We did not contact these 86 individual agencies or survey
users of their Web sites, as this was beyond the scope of our review.
Regarding the second objective of determining the number, type, and
source of IQA requests, including who submitted them, for fiscal years
2003 and 2004, we contacted agency IQA officials and OMB staff and
obtained relevant information from them. We also reviewed OIRA's two
reports to Congress to validate data collected through other
sources.[Footnote 22] To the extent the information was available
online, we reviewed IQA requests on agency Web sites. To supplement and
verify the accuracy and completeness of this information, we
interviewed agency and OMB IQA staff and officials. In addition, to
categorize the sources of the requests by type of entity, such as
business, trade group, or nonprofit advocacy organization, we relied on
information from the sources and agency descriptions. We made our
determination when information was contradictory or not available.
Moreover, to determine the final status of IQA requests and any
appeals, we reviewed related agency documents, including agency
notification letters, and spoke with agency IQA officials about their
status. We determined that OMB and agency data were sufficiently
reliable for the purposes of this review. The results of our analysis
differ from information in OMB's two reports to Congress discussing IQA
because of (1) differences between report information about IQA
requests and information on agency Web sites and (2) minor report
errors, including errors reported by agencies to OMB--such as IQA
requests reported for calendar year 2003 instead of fiscal year 2003--
that OMB repeated. In addition, we tracked the status of appeals to the
end of March 2006 to provide current information, going beyond the end
of fiscal year 2004, which is the date OMB used as the cutoff for
appeal information in its December 2005 report.
Regarding the third objective of examining whether the implementation
of IQA has adversely affected agencies' or overall operations in
general and the rulemaking process in particular, we contacted agency
IQA and other knowledgeable officials and OMB staff. We also attempted
to determine the resources that OMB and agencies committed to
implementing IQA by obtaining IQA cost and staff allocation data, but
agency officials told us they do not track such information, although
the Department of Labor had cost information on setting up a system on
the status of IQA requests. In addition, we reviewed the annual IQA
reports submitted to OMB by the cabinet-level agencies and the 5
independent agencies with guidelines where we conducted interviews.
Moreover, to better understand specific aspects of IQA requests and how
agencies addressed them, as well as to illustrate specific points, we
reviewed in detail selected IQA requests at four agencies--the
Environmental Protection Agency, the Department of Health and Human
Services' National Institutes of Health, the Department of
Agriculture's Forest Service, and the Department of the Interior's Fish
and Wildlife Service.[Footnote 23]
Because OMB was still developing its IQA peer review policies at the
time of our review, we did not discuss with agency officials their
plans for carrying out these future requirements. In addition, although
agencies have other mechanisms to correct information, we evaluated
only the IQA information correction mechanism.
We conducted our work in Washington, D.C., from March 2005 through July
2006 in accordance with generally accepted government auditing
standards.
[End of section]
Appendix II; Independent Agencies Where Web Sites Were Checked for IQA
Guidelines:
1; Agency: Advisory Council on Historic Preservation;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
2; Agency: African Development Foundation;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
3; Agency: Agency for International Development;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
4; Agency: American Battle Monuments Commission;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
5; Agency: AMTRAK (National Railroad Passenger Corporation);
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
6; Agency: Antitrust Modernization Commission;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
7; Agency: Appalachian Regional Commission;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
8; Agency: Access Board;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
9; Agency: Arctic Research Commission;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
10; Agency: Armed Forces Retirement Home;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
11; Agency: Broadcasting Board of Governors;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
12; Agency: Central Intelligence Agency;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
13; Agency: Chemical Safety and Hazard Investigation Board;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
14; Agency: Christopher Columbus Fellowship Foundation;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
15; Agency: Commission Regarding Weapons of Mass Destruction;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
16; Agency: Commission on International Religious Freedom;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
17; Agency: Commission on Ocean Policy;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
18; Agency: Commodities Futures Trading Commission;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
19; Agency: Consumer Product Safety Commission;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
20; Agency: Corporation for National and Community Service; IQA
guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
21; Agency: Court Services and Offender Supervision Agency;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
22; Agency: Defense Nuclear Facilities Safety Board;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
23; Agency: Denali Commission;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
24; Agency: Environmental Protection Agency;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
25; Agency: Equal Employment Opportunity Commission;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
26; Agency: Export-Import Bank of the United States;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
27; Agency: Farm Credit Administration;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
28; Agency: Farm Credit System Insurance Corporation;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
29; Agency: Federal Mediation and Conciliation Service;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
30; Agency: Federal Mine Safety and Health Review Commission;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
31; Agency: Federal Retirement Thrift Investment Board;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
32; Agency: Federal Communications Commission;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
33; Agency: Federal Deposit Insurance Corporation;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
34; Agency: Federal Energy Regulatory Commission;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
35; Agency: Federal Housing Finance Board;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
36; Agency: Federal Labor Relations Authority;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
37; Agency: Federal Maritime Commission;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
38; Agency: Federal Reserve System;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
39; Agency: Federal Trade Commission;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
40; Agency: General Services Administration;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
41; Agency: Institute of Museum and Library Services;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
42; Agency: Inter-American Foundation;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
43; Agency: Legal Services Corporation;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
44; Agency: Marine Mammal Commission;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
45; Agency: Merit Systems Protection Board;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
46; Agency: Migratory Bird Conservation Commission;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
47; Agency: Millennium Challenge Corporation;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
48; Agency: Mississippi River Commission;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
49; Agency: National Aeronautics and Space Administration;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
50; Agency: National Archives and Records Administration;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
51; Agency: National Commission on Libraries and Information Science;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
52; Agency: National Capital Planning Commission;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
53; Agency: National Council on Disability;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
54; Agency: National Credit Union Administration;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
55; Agency: National Endowment for the Arts;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
56; Agency: National Endowment for the Humanities;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
57; Agency: National Indian Gaming Commission;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
58; Agency: National Labor Relations Board;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
59; Agency: National Park Foundation;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
60; Agency: National Science Foundation;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
61; Agency: National Transportation Safety Board;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
62; Agency: Northwest Power Planning Council;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
63; Agency: Nuclear Regulatory Commission;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
64; Agency: Nuclear Waste Technical Review Board;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
65; Agency: Occupational Safety and Health Review Commission;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
66; Agency: Office of Navajo and Hopi Indian Relocation;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
67; Agency: Office of Federal Housing Enterprise Oversight;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
68; Agency: Office of Government Ethics;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
69; Agency: Office of Personnel Management;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
70; Agency: Office of Special Counsel;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
71; Agency: Overseas Private Investment Corporation;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
72; Agency: Peace Corps;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
73; Agency: Pension Benefit Guaranty Corporation;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
74; Agency: Presidio Trust;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
75; Agency: Railroad Retirement Board;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
76; Agency: Securities and Exchange Commission;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
77; Agency: Selective Service System;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
78; Agency: Small Business Administration;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
79; Agency: Smithsonian Institution;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
80; Agency: Social Security Administration;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
81; Agency: Social Security Advisory Board;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
82; Agency: State Justice Institute;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
83; Agency: Surface Transportation Board;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
84; Agency: Susquehanna River Basin Commission;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
85; Agency: Tennessee Valley Authority;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
86; Agency: Trade and Development Agency;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
87; Agency: U.S. Commission on Civil Rights;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check[A].
88; Agency: U.S. Holocaust Memorial Museum;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
89; Agency: U.S. International Trade Commission;
IQA guidelines in place and on Web site?: Yes: check;
IQA guidelines in place and on Web site?: No: [Empty].
90; Agency: Utah Reclamation Mitigation and Conservation Commission;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
91; Agency: Valles Caldera Trust;
IQA guidelines in place and on Web site?: Yes: [Empty];
IQA guidelines in place and on Web site?: No: check.
Source: GAO analysis of agency information.
[A] The commission has drafted but not finalized guidelines as of late
July 2006.
[End of table]
[End of section]
Appendix III: Organizations That Filed IQA Correction Requests during
Fiscal Years 2003 and 2004:
Federal department/agency receiving request and filer: Department of
Agriculture: W.K. Olsen and Associates, LLC;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Agriculture: Earth Island Institute, etc. (2);
Business, trade group, or profit-oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Department of
Agriculture: Sierra Club, etc;
Business, trade group, or profit-oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Department of
Agriculture: Center for Regulatory Effectiveness--same as; Department
of Health and Human Services; filing;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Agriculture: Alliance for the Wild Rockies;
Business, trade group, or profit-oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Department of
Commerce: Competitive Enterprise Institute--same as Office; of Science
and Technology Policy filing;
Business, trade group, or profit-oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Department of
Commerce: Atlantic Salmon of Maine--same as Department; of the Interior
filing;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Commerce: Associated Fisheries of Maine, Inc., etc;
Business, trade group, or profit- oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Commerce: Center for Regulatory Effectiveness, et al;
Business, trade group, or profit- oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Defense: Public Employees for Environmental; Responsibility;
Business, trade group, or profit- oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Department of
Defense: Public Interest Group (identity not provided);
Business, trade group, or profit- oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Department of
Education: National Wrestling Coaches Association, etc;
Business, trade group, or profit- oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Department of
Health and Human Services: Center for Regulatory Effectiveness, etc.
(3)--; one same as Department of Agriculture filing;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Health and Human Services: Animal Health Institute (2);
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Health and Human Services: SafeBlood Technologies, etc;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Health and Human Services: Chemical Products Corporation (2);
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Health and Human Services: Nickel Development Institute;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Health and Human Services: Styrene Information and Research Center,
Inc;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Health and Human Services: Salt Institute, etc;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Health and Human Services: Environmental Working Group;
Business, trade group, or profit-oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Department of
Health and Human Services: McNeil Consumer and Specialty Products;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Health and Human Services: National Legal and Policy Center;
Business, trade group, or profit-oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Department of
Health and Human Services: American Chemistry Council (2);
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
the Interior: Atlantic Salmon of Maine--same as Department; of Commerce
filing;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
the Interior: Chilton Ranch and Cattle Company;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
the Interior: Public Employees for Environmental; Responsibility (2);
Business, trade group, or profit-oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Department of
the Interior: Florida Marine Contractors Association;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
the Interior: National Association of Home Builders;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
the Interior: Union Electric Company;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
the Interior: Partnership for the West;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
the Interior: Center for Regulatory Effectiveness;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Justice: National Coalition for Asian Pacific American; Community
Development;
Business, trade group, or profit-oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Department of
Labor: Liquid Container/Plaxicon;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
Transportation: Marine industry consultant;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Department of
the Treasury: Diageo North America, Inc;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Consumer Product
Safety Commission: American Chemistry Council;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Consumer Product
Safety Commission: Competitive Enterprise Institute (2);
Business, trade group, or profit-oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Consumer Product
Safety Commission: Association of Home Appliance Manufacturers;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Consumer Product
Safety Commission: McDowell Owings Engineering, Inc;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Office of
Science and Technology Policy (Executive Office of the President):
Competitive Enterprise Institute--same as; Department of Commerce
filing;
Business, trade group, or profit-oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Environmental
Protection Agency: Chemical Products Corporation;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Environmental
Protection Agency: Center for Regulatory Effectiveness, etc. (2);
Business, trade group, or profit- oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Environmental
Protection Agency: Competitive Enterprise Institute;
Business, trade group, or profit-oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Environmental
Protection Agency: Friends of Massachusetts Military Reservation;
Business, trade group, or profit- oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Environmental
Protection Agency: Morgan, Lewis & Bockius, LLP;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Environmental
Protection Agency: Geronimo Creek Observatory (4);
Business, trade group, or profit-oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Federal department/agency receiving request and filer: Environmental
Protection Agency: Perchlorate Study Group;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Environmental
Protection Agency: National Multi- Housing Council, etc;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Environmental
Protection Agency: U.S. Chamber of Commerce;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Environmental
Protection Agency: National Paint and Coatings Association, etc;
Business, trade group, or profit- oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Environmental
Protection Agency: Dow Chemical Company;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Environmental
Protection Agency: National Association of Home Builders;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Environmental
Protection Agency: NPC Services, Inc;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Environmental
Protection Agency: American Chemistry Council;
Business, trade group, or profit-oriented organization: Department of
Agriculture: check;
Nonprofit or other advocacy organization: Department of Agriculture:
[Empty].
Federal department/agency receiving request and filer: Federal
Communications Commission: TeleTruth;
Business, trade group, or profit-oriented organization: Department of
Agriculture: [Empty];
Nonprofit or other advocacy organization: Department of Agriculture:
check.
Source: GAO analysis of agency and OMB information.
Note: The numbers in parentheses following an entity's name indicate
the number of substantive IQA requests submitted to the agency.
[End of table]
[End of section]
Appendix IV: Comments from the Office of Management and Budget:
Executive Office Of The President:
Office Of Management And Budget:
Washington, D.C. 20503:
Jul - 5 2006:
Ms. Brenda S. Farrell:
Acting Director:
Strategic Issues:
Government Accountability Office:
441 G Street, SW:
Washington, DC 20548:
Dear Ms. Farrell:
Thank you for the opportunity to comment on the Government
Accountability Office's (GAO) draft report titled, "Information Quality
Act: Expanded Oversight and Clearer Guidance by the Office of
Management and Budget Could Improve Agencies' Implementation of the
Act" (GAO-06-765).
We greatly appreciate GAO's efforts to evaluate the Office of
Management and Budget's (OMB) oversight role. The Information Quality
Act (IQA) is very important to us and we are grateful for the time and
energy GAO devoted to this evaluation. In the draft report, GAO made
two recommendations to OMB.
First, your draft report recommends that we "work with DHS and other
agencies lacking IQA guidelines to help ensure they fulfill IQA
requirements, and set a deadline for doing so." We fully support your
recommendation that DHS develop IQA guidelines. While the Coast Guard,
Bureau of Customs and Border Protection, Federal Emergency Management
Agency, and the Secret Service do have guidelines in place, we agree
that DHS department-wide guidelines are important. We will continue to
work with DHS to assist the department in completing its guidelines as
soon as is practicable. We will also continue to work with the other
agencies (many of which are small agencies) as they develop and
implement information quality measures. As we work with these agencies,
especially the very small ones, we will take into account the resources
that would be needed and the potential benefits that would be achieved
by having IQA guidelines in place.
Your draft report also recommends that we "clarify guidance to agencies
about how to improve the public's access to IQA information on agency
web sites, including suggestions about clearer linkages to that
information." We share your interest in improving public access to IQA
information and will continue to work with agencies to improve their
dissemination of IQA information in a manner consistent with OMB
policies.[Footnote 24] As you know, agencies consider the needs and
demands of their specific user groups and the general public when
determining how to disseminate information, including IQA information,
on their websites. While some agencies may determine a link on their
homepage is an effective means for disseminating IQA information,
others may find alternative methods more appropriate. OMB's policies on
agency dissemination and websites preserve for agencies this
operational flexibility, while emphasizing the bottom-line importance
of each agency ensuring that the public can readily and easily obtain
public information about that agency's programs and activities.
Thank you again for the opportunity to review and comment on your draft
report.
Signed by:
Steven D. Aitken:
Acting Administrator:
Office of Information and Regulatory Affairs:
(450397):
FOOTNOTES
[1] Consolidated Appropriations - Fiscal Year 2001, Pub. L. No. 106-
554, § 515, 114 Stat. 2763A-153 to 2763A-154 (2000) (44 U.S.C. § 3516
note). The law is also referred to as the Data Quality Act.
[2] Office of Management and Budget, Office of Information and
Regulatory Affairs, Information Quality: A Report to Congress, Fiscal
Year 2003 (Washington D.C.: Apr. 30, 2004).
[3] We use the term agencies to refer to executive branch cabinet
departments and independent agencies covered by the Paperwork Reduction
Act--the agencies also covered by IQA.
[4] The cabinet-level agencies we examined are the Departments of
Agriculture, Commerce, Defense, Energy, Health and Human Services,
Homeland Security, Housing and Urban Development, the Interior,
Justice, Labor, Transportation, and the Treasury. In addition, we
interviewed officials at the following independent agencies: the
Environmental Protection Agency, the Consumer Product Safety
Commission, Federal Deposit Insurance Corporation, National Aeronautics
and Space Administration, and Nuclear Regulatory Commission.
[5] The agencies or OMB designates IQA requests to be "simple or
administrative."
[6] Agencies subject to the Paperwork Reduction Act are executive
departments; military departments; independent regulatory agencies;
government corporations; government-controlled corporations; or other
establishments in the executive branch, including the Executive Office
of the President. It specifically excludes the Federal Election
Commission; GAO; and federal government-owned contractor-operated
facilities, including laboratories engaged in national defense research
and production activities, as well as District of Columbia and
territorial governments. 44 U.S.C. § 3502(1).
[7] 44 U.S.C. § 3506(b)(1)(C).
[8] No hearings or debates were held or committee reports filed before
IQA was enacted as part of the Treasury and General Government
Appropriations Act for Fiscal Year 2001.
[9] These memorandums are accessible by selecting the Information
Policy, E-gov & IT option under Information and Regulatory Affairs on
OMB's Web site at [Hyperlink, http://www.whitehouse.gov/omb/].
[10] Office of Management and Budget, Office of Information and
Regulatory Affairs, Validating Regulatory Analysis: 2005 Report to
Congress on the Costs and Benefits of Federal Regulations and Unfunded
Mandates on State, Local, and Tribal Entities (Washington, D.C.:
December 2005).
[11] OMB granted an extension to the Department of Defense (DOD) for
implementing its guidelines because of the war in Iraq. DOD implemented
its guidelines in February 2003.
[12] Office of Management and Budget, Information Quality: A Report to
Congress, Fiscal Year 2003.
[13] These are the Coast Guard, Customs and Border Protection
(previously Customs Service), FEMA, Federal Law Enforcement Training
Center, and Secret Service.
[14] Office of Management and Budget, Information Quality: A Report to
Congress, Fiscal Year 2003.
[15] OMB and agency officials sometimes differed in whether they
considered requests to be minor or significant; therefore, our analysis
of the number of requests by type of request differed from OMB's.
[16] According to the report, the Departments of Labor, Justice, and
Transportation as well FEMA decided "to not treat simple correction
requests not generated by the Act as correction requests in their FY04
annual report to OMB." Despite this statement, the Department of
Justice's annual report describes five requests, including four that
could be considered simple in nature.
[17] Our analysis differed from OMB's analysis in its December 2005
report because OMB provided a status of appeals at the end of fiscal
year 2004, whereas our analysis was based on the final outcome, which
in some cases occurred after fiscal year 2004.
[18] The Department of Labor had information for one IQA-related cost-
-a contract for $170,000 to set up a system to track the status of IQA
requests.
[19] See 42 U.S.C. § 300g and 68 Fed. Reg. 74233 (Dec. 23, 2003).
[20] We use the term agencies to refer to both federal executive branch
cabinet departments and independent agencies covered by the Paperwork
Reduction Act.
[21] While we took measures to ensure the selected agencies reflect
meaningful criteria for our work, our selection was not intended to be
representative. Thus, the findings from our interviews cannot be used
to make inferences about all agencies.
[22] Office of Management and Budget, Office of Information and
Regulatory Affairs, Information Quality: A Report to Congress, Fiscal
Year 2003 and Validating Regulatory Analysis: 2005 Report to Congress
on the Costs and Benefits of Federal Regulations and Unfunded Mandates
on State, Local, and Tribal Entities. In both reports OIRA identified
the agencies that had guidelines in place and the number of IQA
correction requests they received for fiscal years 2003 and 2004.
[23] Our case illustrations cannot be used to make inferences about all
IQA requests (at the agencies from which the examples were taken or all
federal agencies) during the 2-year period we studied.
[24] Policies include OMB Circular A-130 "Management of Federal
Information resources," and OMB Memorandum M-06-02 "Improving Public
Access to and Dissemination of Government Information and Using the
Federal Enterprise Architecture Data Reference Model."
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