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September 5, 2002 Memo - Agency Final Information Quality Guidelines

The U.S. Equal Employment Opportunity Commission

September 5, 2002


FROM: John D. Graham

SUBJECT: Agency Final Information Quality Guidelines

As you know, Congress directed OMB and the agencies to issue guidelines to maximize the quality, objectivity, utility and integrity of information disseminated to the public. OMB previously issued its government-wide guidelines, and the agenices' must be issued by October 1, 2002.

My staff and I are now completing our review of agency draft final information quality guidelines. We want to thank you and your staff for the significant progress and effort reflected in theses drafts. The drafts reflect the serious effort that agencies have made to prepare agency-specific guidelines that implement OMB's guidelines as well as the more recent guidance that I sent you on June 10 of this year.During the developement of these guidelines, some agencies advanced particularly thoughtful approaches for approving information quality.

In our final review of the draft agency quality guidelines, we have identified a small number of process issues for which increased cross-agency uniformity would improve the Executive Branch's implementation of these information quality guidelines. The attachment to this memorandum describes uniform procedures that OMB requests agencies to incorporate in their upcoming guidelines, either verbatim or adapted to the style and format of the agency's draft. We recognize that this final round of OMB guidance is coming near the end of the process, and we appreciate the agencies' immediate attention to this issue.

I request that you send this attachment to the appropriate officials who are responsible for developing your agency's information quality guidelines. Agencies that believe that the principles or uniform language in this attachment are not appropriate in this case, particularly smaller agencies, should call my Senior Advisor, Jeff Hill, at 395-7340 for further discussion. My staff also will be working with your staff in the next few days concerning other innovative highlights from agency guidelines that may deserve your consideration.


Information Quality Guidelines - Principles and Model Language
September 5, 2002

(1) Use of Websites: Agencies should use their websites to keep the public informed about information quality on a timely basis. Specifically, each agency or office should establish an information quality site on its website. The purpose of the information quality site would be to meaningfully inform the public about the agency's information quality practices and procedures. The information quality site should include, at a minimum, access to the agency's data quality guidelines and an easy-to-understand explanation of the agency's procedures regarding requests for correction (which shall include an explanation of how a person may file a request and, subsequently, an administrative appeal of the agency's response to the request). The information quality site also could contain other types of information, such as a description of significant corrections that the agency has made as a result of the correction procedures. Each agency should determine the content of this information page based on its mission, activities subject to the guidelines, and the expected level of interest by members of the public.

(2) Rulemakings and Other Public Comment Procedures: This is a follow-up to the discussion of this topic in my June 10 memorandum to the PMC. Where existing public comment procedures -- for rulemakings, adjudications, other agency actions or information products -- provide well established prcedural safeguards that allow affected persons to contest information quality on a timely basis, agencys may use those procedures to respond to information quality complaints. However, agencies should respond sooner where needed to avoid the potential for actual harm or undue delay.

Recommended Language: "In cases where the agency disseminates a stud, analysis, or other information prior to the final agency action or information product, requests for correction will be considered prior to the final agency action or information product in those cases where the agency has determined that an earlier response would not unduly delay issuance of the agency action or infomration product and the complainant has shown a reasonable likelihood of suffering actual harm from the agency's dissemination if the agency does not resolve the complaint prior to the final agency action or information product."

(3) Deadlines for Decision on Initial Request and Appeal: Under OMB's Guidelines, agencies are to establish administrative mechanisms allowing affected persons to seek and obtain "timely correction" of informatio dissemminated by the agency that does not comply with the agency or OMB information quality guidelines. OMB's Guidelines state that "[a]gencies shall specify appropriate time periods for agency decisions on whether and how to correct information." As OMB in its Guidelines did not establish any particular timetable, but left that to the agencies to determine, the agencies in their draft guidelines have included a variety of time periods.

However, having reviewed the agencies' draft guidelines, OMB now believes that a uniform response period is preferable if practical. Unless there are important reasons for a different time period, agency procedures should provide for a written response by the agency to complaints and appeals within 60 calendar days. If the complaint or appeal requires more time to resolve, the agency should so notify the complainant within that period that more time is required, the reasons for the delay, and an estimated decision date.

Recommended Language: "The agency will respond to the requestor in writing....If the request requires more than___calendar days to resolve, the agency will inform the complainant that more time is required and indicate the reason why and an estimated decision date... The agency will respond to all requests for appeals within___ calendar days of receipt. If the request requires more than ___ calendar days to resolve, the agency will inform the complainant that more time is required and indicate the reason why and an estimated decision date."

This page was last modified on October 1, 2002.