Editor’s Note: OMB’s update today to its Data (Information) Quality Act implementing guidance–including its new instance that an agency which has “performed analysis using a specialized set of computer code, the computer code used to process it should be made available to the public for further analysis…”is consistent with international research standards for data transparency and quality set by the United Kingdom in its Joint Code of Practice for Research (JCoPR), National Environmental Council (NERC) Data Policy and NERC Data Policy Guidance Notes, and NERC’s Guidance on Preservation of NERC Model Code and Model Output.

The following is a brief excerpt from OMB Memorandum M-19-15 Improving Implementation of the Information Quality Act (April 24, 2019).

4.      Requests for Correction


Sharing Draft Responses with OMB Prior to Release

Implementation Update 4.2: In its response to an RFC, agencies should not opine on the requestor ‘s or the agency’s policy position.

Implementation Update 4.3: The agency response should contain a point-by-point response to any data quality arguments contained in the RFC and should refer to a peer review that directly considered the issue being raised, if available.

Implementation Update 4.4: Agencies should share draft responses to RFCs and appeals with OMB prior to release to the requestor for assessment of compliance with the above norms.

          The process described here is designed to challenge technical information that drives policy, not to debate the policy itself. At times, agencies have failed to respond fully to the. technical challenges posed by requestors. Under the IQA and Guidelines, an agency should respond thoroughly to substantive RFCs, including by making clear, as fully as practicable, the data underlying the challenged information, the methodologies the agency used to analyze the data, the reasons for use of such methodologies, and any peer reviews addressing the agency’s analysis.

Read Complete OMB Memorandum M-19-15