Information Quality Act: Expanded Oversight and Clearer Guidance
by the Office of Management and Budget Could Improve Agencies'
Implementation of the Act (23-AUG-06, GAO-06-765).
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.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-06-765
ACCNO: A59184
TITLE: Information Quality Act: Expanded Oversight and Clearer
Guidance by the Office of Management and Budget Could Improve
Agencies' Implementation of the Act
DATE: 08/23/2006
SUBJECT: Federal regulations
Government information
Government information dissemination
Information access
Information management
Interagency relations
Policies and procedures
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GAO-06-765
* 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
* Contents
* Results in Brief
* Background
* OMB Took Steps to Implement IQA, but IQA Guidelines and
Information for Many Agencies Are Not Available or Easily
Accessible
* OMB's OIRA Set Up Framework for IQA Implementation
* OIRA Focused Its Efforts on Cabinet-Level and Regulatory
Agencies
* Accessing Agencies' Web Site IQA Information Is Difficult
* From Fiscal Years 2003 to 2004, Three Agencies Reclassified
Correction Requests to Concentrate on Substantive Matters
* Agencies Changed Simple Requests More Often Than Substantive
Requests or Appeals during 2 Years
* Impact of IQA on Agencies Could Not Be Determined
* Agencies Treated Most IQA Rulemaking-Related Requests as
Comments to Proposed Rules
* Conclusions
* Recommendations for Executive Action
* Agency Comments and Our Evaluation
* Scope and Methodology
* Independent Agencies Where Web Sites Were Checked for IQA Guidelines
* Organizations That Filed IQA Correction Requests during Fiscal Years
2003 and 2004
* Comments from the Office of Management and Budget
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
Contents
Tables
Figure
August 23, 2006 Letter
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.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.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.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.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.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.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."8 7,
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:
o The guidelines are to apply to a wide variety of government information
dissemination activities that may vary in importance and scope.
o 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."
o 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.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.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
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.
aThe original deadline was July 1, 2002, but OMB extended it.
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).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 the Interior
Department of Commerce Department of Justice
Department of Defense Department of Labor
Department of Education Department of State
Department of Energy Department of Transportation
Department of Health and Human Department of the Treasury
Services Department of Veterans Affairs
Department of Housing and Urban
Development
Source: GAO analysis of agency and OMB information.
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.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,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.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
Requests in Requests in
fiscal year fiscal year
2003 2004
Source of request Number Percentage Number Percentage
Business, trade 22 52.4 22 57.9
group, or other
profit-oriented
organization
Nonprofit or other 12 28.6 10 26.3
advocacy organization
Private citizen 6 14.3 4 10.5
Government 2 4.8 2 5.3
Total 42 100 38 100
Source: GAO analysis of agency and OMB data.
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.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
Source: GAO analysis of agency information.
aIncludes 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.
cIncludes requests filed with another agency. App. III identifies these
requests.
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.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 2006.17 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-
1/2 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 Total No Changes Appeal Outcome
appeals changes from withdrawn pending
from appealsa
appeals
Department of Agriculture 3 3 0 0 0
Department of Commerce 3 2 0 1 0
Department of Education 1 1 0 0 0
Department of Health and Human 12 9 2 1 0
Services
Department of the Interior 4 3 1 0 0
Department of Justice 1 0 0 1 0
Department of Labor 1 0 1 0 0
Department of Transportation 2 0 1 0 1
Department of Veterans Affairs 1 0 1 0 0
Consumer Product Safety 1 0 1 0 0
Commission
Environmental Protection Agency 9 6 1 1 1
Office of Science and 1 1 0 0 0
Technology Policy/Executive
Office of the President
Total 39 25 8 4 2
Source: GAO analysis of agency and OMB information.
a"Changes" means either full or partial correction of information.
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.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.
o 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.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.
o 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- 1/2 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.
o 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.
o 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.
o 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:
o work with DHS to help ensure it fulfills IQA requirements and set a
deadline for doing so;
o identify other agencies that do not have IQA guidelines and work with
them to develop and implement IQA requirements; and
o 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 http://www.gao.gov .
If you or your staff have any questions concerning this report, please
contact me on (202) 512-6806 or by e-mail at [email protected] . 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.
Brenda S. Farrell Acting Director Strategic Issues
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.1 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 Department of Housing and Urban
Development
o Forest Service
Department of Commerce Department of the Interior
o National Oceanic and Atmospheric o Fish and Wildlife Service
Administration
Department of Defense Department of Justice
o Army Corps of Engineers o Bureau of Justice Statistics
Department of Energy Department of Labor
o Energy Information Administration o Occupational Safety and Health
Administration
Department of Health and Human Services Department of Transportation
o National Institutes of Health o Federal Motor Carrier Safety
Administration
Department of Homeland Security Department of the Treasury
o Transportation Safety Administration o Internal Revenue Service
o Federal Emergency Management Agency
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.
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.2 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.3 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.4
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.
Appendix II
Independent Agencies Where Web Sites Were Checked for IQA
Guidelines
Source: GAO analysis of agency information.
aThe commission has drafted but not finalized guidelines as of late July
2006.
Appendix III
Organizations That Filed IQA Correction Requests during Fiscal Years 2003
and 2004
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.
Appendix IV
Comments from the Office of Management and Budget
(450397)
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
[email protected].
Highlights of GAO-06-765 , a 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
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 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.
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.
*** End of document. ***