April 18, 2000

The Honorable Jo Ann Emerson
US House of Representatives
Washington, DC 20515

Dear Representative Emerson:

Thank you for your letter of March 20, in which you ask about the Office of Management and Budget (OMB) response to the language in the FY 1999 Omnibus Appropriations act conference report (House Report 105-592), which concerned the quality of information that Federal agencies disseminate to the public.

OMB is committed to helping the Federal government provide the public with high quality information. We work with the agencies in several ways to improve the quality of such information. Under the Paperwork Reduction Act, we review information collection proposals to ensure that they have maximum "practical utility." We coordinate and review the development and use of federal statistics. OMB Circular A-130 describes the best practice that agencies should follow to collect and use timely and appropriate information. It also establishes the criteria for agency budget requests to ensure that proposed information management investments are appropriate, efficient, and effective.

The FY 1999 House Report language urged OMB to establish government-wide rules for ensuring the quality of federally-disseminated information. We appreciate the need for ensuring such quality and are sensitive to the possibility that OMB Circular A-130 might need to be updated or supplemented to deal with concerns in this area. OMB Circular A-130 already establishes complaint resolution procedures for perceived violations of data quality and other requirements in the Circular. Section 9(a)10 of the Circular contains a requirement that each agency CIO must:

"Monitor agency compliance with the policies, procedures, and guidance in this Circular. Acting as an ombudsman, the [CIO] shall consider alleged instances of agency failure to comply with this Circular and recommend or take corrective action as appropriate."

The Circular also contains a specific requirement for agencies to report to OMB any alleged violations and their resolution:

"The [CIO] shall report annually, not later than February 1st of each year, to the Director those instances of alleged failure to comply with this Circular and their resolution." Last summer, OMB canvassed the agency Chief Information Officers (CIOs) about data quality. They indicated to us that they have not been hearing complaints about the quality of federally-disseminated information. None expressed a need for further guidance in this area. Based on our canvass of the CIOs and OMB's own experience, there does not currently appear to be a significant problem in this area. We are monitoring CIO activities and will be alert to any widespread complaints about publicly-disseminated information.

At the present time, OMB is not convinced that new "one-size-fits-all" rules will add much to the existing OMB guidance and oversight activity and the procedures followed by individual agencies. We are reluctant to issue more regulations without a clear sense that they would be useful in promoting data quality. We are also concerned that new regulations might prove counterproductive to the goal of increasing data quality. The Report suggests that agencies be required to establish a new "petition" process under which persons could file formal "complaints" over the quality of information. These administrative requirements could consume significant agency resources. An adversarial petition process also might discourage the type of free and open dialogue between the agency and the public that is crucial for identifying and addressing data quality issues.

We also note that the House Report suggests that any new regulations extend not only to Federal agencies, but also to non-Federal entities that disseminate information with Federal financial support, such as contractors, State and local governments, and no-profit grantees. This might leads to new unfunded Federal mandates and an intrusion into how non-Federal entities communicate with the public on public matters.

We are very much interested in exploring other ways to improve data quality. We believe it important to have interagency cooperation in this regard and to enlist the public in an ongoing dialogue aimed at improving such quality. Data quality is one of many considerations of agency information management activity. In that regard, we are launching this month an initiative to work with select agencies (HCFA, EPA, DOT, HHS, OSHA, IRS, and SBA) and the public on how we can collect information more effectively, with improved efficiency and data quality. We expect these discussions to identify agency best information management practices as well as recommendations for improving specific information collection and management activities.

We appreciate your strong interest in information quality and would welcome any further thoughts you might have on this subject.


John T. Spotila