Editor’s Note: The folloing are excerpts from GAO-15-368. All agency guidance documents disseminated to the public must comply with OMB’s Data Quality Act requirements.
From: US GAO
Given both the importance of guidance and the concerns about its use, in 2007 the Office of Management and Budget (OMB) recognized the need for good guidance practices. In particular, OMB established review processes for the documents with the most broad and substantial impact.
We found mixed compliance with requirements established by the Office of Management and Budget’s (OMB) Final Bulletin for Agency Good Guidance Practices (OMB Bulletin) for the subset of guidance documents considered “significant” under OMB’s definition. Education and USDA had written departmental procedures for the approval of significant guidance, as directed by the OMB bulletin. DOL officials had not made their procedures available to component staff to ensure consistent application of review processes for significant guidance, and those procedures required updating. HHS had no procedures for significant guidance approval. . . .