The Executive Office of the PresidentThe Executive Office of the President(EOP)(EOP)

CEA CEQ OSTP OMB OVP ONDCP USTR OA PFIAB WHO

Office of Management and BudgetOffice of Management and Budget(OMB)(OMB)

Director

Support Resource Management Statutory Offices

General Counsel

Legislative Affairs

Communications

Administration

Economic Policy

Legislative Reference

Budget Review

Natural Resources

Human Resources

General Government

National Security

Financial Management

Procurement

E-Gov and IT

Information and Regulatory Affairs

Office of Information and Regulatory Affairs Office of Information and Regulatory Affairs (OIRA)(OIRA)

The "information policy" function of OIRA The "information policy" function of OIRA includes improving the technical quality of includes improving the technical quality of information that agencies disseminate to the information that agencies disseminate to the public public

Other ‘information policy’ functions include Other ‘information policy’ functions include privacy, data security, and e-government privacy, data security, and e-government initiatives.initiatives.

Selected OMB Information Quality Related Initiatives

Executive Order 12866/13422Circular A-4http://www.whitehouse.gov/omb/circulars/a004/a-4.pdf

Good Guidance Bulletinhttp://www.whitehouse.gov/omb/memoranda/fy2007/m07-07.pdfhttp://www.whitehouse.gov/omb/memoranda/fy2007/m07-13.pdf

Paperwork Reduction ActInformation Quality Act

Information Quality Guidelineshttp://www.whitehouse.gov/omb/fedreg/reproducible2.pdf

Peer Review Bulletinhttp://www.whitehouse.gov/omb/memoranda/fy2005/m05-03.pdf

Updated Principles for Risk Assessmenthttp://www.whitehouse.gov/omb/memoranda/fy2007/m07-24.pdf

Executive Order 12866Regulatory Planning and Review (1993)

Governs OIRA’s oversight of agency rulemaking, requiring OIRA review of “significant” agency regulatory actions.

Regulatory Action: all substantive action by an agency that promulgates or is expected to lead to the promulgation of a final rule or regulation.

Includes cross agency coordination; examination of legal authority; technical/scientific underpinnings; evaluation of regulatory impacts.

Good Guidance Bulletin andGood Guidance Bulletin and EO Update (2007) EO Update (2007)

Goal is to increase the quality, transparency, Goal is to increase the quality, transparency, accountability, and coordination with respect to accountability, and coordination with respect to significant guidance documents. significant guidance documents.

Two parts of a wholeTwo parts of a whole

GGP Bulletin focuses on Agencies interaction with the GGP Bulletin focuses on Agencies interaction with the public on guidance.public on guidance.

Establishes standards for guidance (e.g., non-binding). Establishes standards for guidance (e.g., non-binding).

E.O. focuses on Agency interaction within the Executive E.O. focuses on Agency interaction within the Executive Branch on guidance and all that it entails (including Branch on guidance and all that it entails (including interagency review).interagency review).

overarching policy concerns similar to those issues dealt with when overarching policy concerns similar to those issues dealt with when reviewing regulations are of equal, if not more, importance.reviewing regulations are of equal, if not more, importance.

OMB Circular A-4 for OMB Circular A-4 for Regulatory Review (2003)Regulatory Review (2003)

Updated guidance on regulatory analysis, Updated guidance on regulatory analysis, including as it relates to risk management including as it relates to risk management decisions decisions

Define the need for the proposed actionDefine the need for the proposed actionDefine the scope and identify the baselineDefine the scope and identify the baselineProvide alternative regulatory optionsProvide alternative regulatory optionsEvaluate the benefits and costs of the proposed Evaluate the benefits and costs of the proposed

and alternative actions, including uncertainty and alternative actions, including uncertainty analysisanalysis

Paperwork Reduction Act (1995)

Purpose: To improve the quality and practical utility of information required by the Federal Government, and to reduce the paperwork burden on the public. Relevant only to collections that involve people (as a general rule, if people are not being asked to fill out a survey, this Act does not apply).

Surveys are reviewed to assure that the information collected is:Collected via the Least Burdensome approach Not Duplicative of other agency initiativesHas Practical Utility – study design; representativeness and power;

privacy; data security.

Information Quality Act of 2000

Section 515 of the Treasury and General Government Section 515 of the Treasury and General Government Appropriations Act for FY 2001Appropriations Act for FY 2001

Directed OMB to issue government-wide guidelines that provide policy and procedural guidance to Federal agencies for ensuring and maximizing the quality of information disseminated by Federal agencies.

OMB issued its government-wide guidelines in interim-OMB issued its government-wide guidelines in interim-final form on September 28, 2001 and in final form on final form on September 28, 2001 and in final form on February 22, 2002 (67 FR8452).February 22, 2002 (67 FR8452).

Government-Wide Information Quality Guidelines (2002)

Agencies must meet basic information quality standards, including pre-dissemination review.

Applies to financial, statistical, and scientific information.

Defines “quality.”

Definition of Information Quality

UtilityUsefulness of the information to the intended users.

ObjectivityWhether the disseminated information is presented in an

accurate, clear, complete, and unbiased manner.

IntegritySecurity and the protection of the information from

unauthorized access or revision.

IQ Guidelines Embrace Good Government

TransparencyResults capable of being reproduced

FlexibilityThe more important the information, the

higher the quality standards should be.

OMB’S PEER REVIEW BULLETIN (2004)OMB’S PEER REVIEW BULLETIN (2004)

Extension of OMB efforts under Information Quality Act of 2000Extension of OMB efforts under Information Quality Act of 2000 Pre-dissemination guidance for influential scientific informationPre-dissemination guidance for influential scientific information

OMB issued Bulletin on Peer Review December 16, 2004 (FR notice published January 2005).OMB issued Bulletin on Peer Review December 16, 2004 (FR notice published January 2005).

Agencies must peer review certain scientific information before it is disseminated to the publicAgencies must peer review certain scientific information before it is disseminated to the public Minimum standards for those reviewsMinimum standards for those reviews

More rigorous review required of information that is likely to have the greatest impact on public policy or More rigorous review required of information that is likely to have the greatest impact on public policy or private sector decisions.private sector decisions.

General good science/good government guidelines for peer reviewGeneral good science/good government guidelines for peer review

Balancing the InvestmentBalancing the Investment

Both the Guidelines and the Bulletin recognize that high quality comes at a cost and agencies should weigh the costs and benefits of higher information quality.

The principle of balancing the investment The principle of balancing the investment in quality commensurate with the use to in quality commensurate with the use to which it will be put is generally applicable which it will be put is generally applicable to all data that the federal government to all data that the federal government generates. generates.

DisseminationDissemination

“agency initiated or sponsored distribution of information to the public” Includes information which has the appearance of representing agency

views (e.g., justification for a policy position). Does not include information that a federally employed scientist or

Federal grantee or contractor publishes and communicates in the same manner as his/her academic colleagues.

Researchers should use appropriate disclaimers such as “these views those of the author and do not necessarily reflect the view” of the agency.

“Agency sponsored refers to situations where an agency has directed a third party to disseminate information or where the agency has the authority to review and approve the information before release.

Agencies can provide funding to researchers without ‘sponsoring’ the dissemination.”

Dissemination does not include distribution limited to correspondence with individuals or persons, press releases, archival records, public filings, subpoenas or adjudicative processes.

Data as a subset of Data as a subset of ‘information’‘information’

The concept of dissemination covers both The concept of dissemination covers both internal Agency databases and external internal Agency databases and external information sources information sources whenwhen they are used they are used by the federal Government in support of a by the federal Government in support of a public policy decisionspublic policy decisions Thus, the line between internal ADS and Thus, the line between internal ADS and

agency disseminated information is blurry, and agency disseminated information is blurry, and somewhat artificial.somewhat artificial.

Similarly, when non-government information is Similarly, when non-government information is used to support public policy, the agency is used to support public policy, the agency is endorsing its quality.endorsing its quality.

OMB Definition of Influential

Influential Information: “Influential” means that the agency can reasonably

determine that dissemination of the information “will have or does have a clear and substantial impact on important public policies or important private sector decisions.”

Influential information needs to meet additional quality standards including reproducibility

Agencies define criteria for influential within context of their mission.

Determining the Level of pre-Determining the Level of pre-dissemination reviewdissemination review

Is it subject to IQ Guidelines? Is it subject to IQ Guidelines? Is the agency disseminating it?Is the agency disseminating it?

Is it also subject to Bulletin?Is it also subject to Bulletin? Is it influential scientific information?Is it influential scientific information?

Is it also highly influential scientific assessmentIs it also highly influential scientific assessment

Is it also subject to the Principles of Risk Is it also subject to the Principles of Risk Assessment?Assessment?

Is it also subject to Circular A-4?Is it also subject to Circular A-4?

Public aspects of the IQ Guidelines Public aspects of the IQ Guidelines and the Bulletinand the Bulletin

Every agency has an IQ portal, which Every agency has an IQ portal, which includes:includes: Agency-level IQ Guidelines Agency-level IQ Guidelines Requests for correctionRequests for correction Peer review ‘Agenda’Peer review ‘Agenda’

Peer review plan – advance planningPeer review plan – advance planningPublic comment – early inputPublic comment – early input

Annual Report to OMB – requiredAnnual Report to OMB – required Sent to CongressSent to Congress Including corrections requested by the public, Including corrections requested by the public,

exemptions, waivers, deferrals, optional exemptions, waivers, deferrals, optional processes for peer reviewprocesses for peer review

Peer Review PlanningPeer Review Planning

WebsiteWebsite Update as needed, but at least every six monthsUpdate as needed, but at least every six months All planned information subject to the BulletinAll planned information subject to the Bulletin Link to relevant documentsLink to relevant documents Mechanism to alter interested members of updatesMechanism to alter interested members of updates Mechanism for public commentMechanism for public comment

PlanPlan DescriptionDescription Level of influenceLevel of influence Mechanism (e.g., panel vs individual letter)Mechanism (e.g., panel vs individual letter) Number of reviewersNumber of reviewers Expertise neededExpertise needed Opportunities for public comment and nomination of reviewersOpportunities for public comment and nomination of reviewers

Dove-tailing our EffortsDove-tailing our Efforts

For communicating the difference between the DQ For communicating the difference between the DQ Guidelines and the IQ Guidelines.Guidelines and the IQ Guidelines.

Consider a change in name – e.g., Quality Guidelines for ADSConsider a change in name – e.g., Quality Guidelines for ADS For determining the level of quality assurance for For determining the level of quality assurance for

ADS: ADS: What internal data systems (incl. ADS) are likely to be used What internal data systems (incl. ADS) are likely to be used

to support government policy?to support government policy? Would any of these uses make the information Would any of these uses make the information influentialinfluential? ? 

For implementing the IQ guidelines:For implementing the IQ guidelines: Tweak current quality assurance practices to ensure that Tweak current quality assurance practices to ensure that

they dovetails with the IQ guideline.they dovetails with the IQ guideline. Ensure that the peer review process (where applicable) is Ensure that the peer review process (where applicable) is

proactive (maintaining web accessible agenda). proactive (maintaining web accessible agenda).