Information Quality Act: History and Guidelines
The Information Quality Act emerged in 2000 as a rider contained in Section 515 of the Treasury and General Government Appropriations Act for Fiscal Year 2000 (Public Law 106-554). There were no hearings and no recorded debate on the law, which was added to the bill by Representative Jo Ann Emerson (R-MO), a member of the House Appropriations Committee. The law was in large part the brainchild of the Center for Regulatory Effectiveness (CRE), an industry-sponsored ‘regulatory watch-dog’ group.
The law required the Office of Management and Budget (OMB) to issue data quality guidelines to federal agencies by September 30, 2001. Under the OMB’s IQA guidelines, all agencies subject to the Paperwork Reduction Act—a law that requires OMB to develop and oversee the implementation of policies, principles, standards, and guidelines applicable to the dissemination of public information by federal agencies—were required to establish and follow data quality guidelines that:
- Ensure and maximize the quality, objectivity, utility and integrity of information including statistical information prior to dissemination;
- Allow affected individuals and or organizations to seek and obtain correction of information maintained and disseminated by the agency that does not comply with OMB or agency guidelines; and
- Report to OMB regarding the number and nature of complaints received by the agency regarding agency compliance with OMB guidelines.
OMB issued proposed data quality guidelines on September 28, 2001 and after incorporating public comments, published final OMB IQA Guidelines in the Federal Register on February 22, 2002. Agencies began implementing their own agency-specific IQA guidelines on October 1, 2002.
For proponents of the IQA such as the US Chamber of Commerce and CRE, IQA was a mechanism for “regulating the regulators.” Critics of the law - including public interest groups such as the Center for Progressive Regulation, OMB Watch and Public Citizen - were concerned that a high volume of petitions would sap resources.
Definitions of key terms in the OMB guidelines have affected how agencies have implemented and interested parties have used the Information Quality Act. These include:
Information: OMB broadly defined information governed by the IQA as, “any communication or representation of knowledge such as facts or data, in any medium or form, including textual, numeric, graphic, cartographic, narrative or audiovisual forms.” (paragraph V.5)
Quality: In defining quality, OMB uses the terms, “objectivity,” “utility,” and “integrity,” and provides a definition for each. “Utility” refers to the usefulness of the information to its intended users. “Integrity” refers to the protection of information from unauthorized access or revision. “Objectivity” is a function of both presentation (whether the information is presented in an accurate, clear, complete, and unbiased manner) and substance (whether the information is accurate, reliable, and unbiased and uses sound statistical and research methods). If the information had been peer reviewed, OMB stated that agencies could presume that the information was “objective” unless a persuasive showing by the petitioner is made to the contrary (paragraph V3bi).
Influential: OMB imposes higher standards on information deemed influential, defined as “the dissemination of information that the agency can reasonably determine will have or does have a clear and substantial impact on important public policies or important private sector decisions." (paragraph V.10) OMB leaves it to the agencies to decide how best to define influential for their own purposes, but indicates that data and analytic results considered influential should meet certain “reproducibility” and “transparency” standards.