Information Quality Guidelines

Introduction

This document fulfills the statutory requirement for the Commission to issue information quality guidelines. The document implements section 515 of the Treasury and General Government Appropriations Act for FY 2001, Pub. L. No. 106-554, and government-wide guidelines issued by the Office of Management and Budget (OMB), 67 Fed. Reg. 8452 (February 22, 2002).

The Commission is an independent federal agency that, through a federal procurement program, provides employment opportunities for people who are blind or have significant disabilities.

Definitions

For a glossary of terms and their definitions used throughout this document, please consult Appendix A. The definitions are from OMB guidance to the Act.

Scope and Applicability

These guidelines are intended, within the context of laws administered and enforced by the Commission, to meet the data quality objectives set forth in OMB's guidelines. They are intended to improve the internal management of the Federal Government. They are not intended to impose any binding requirements or obligations on the Commission or the public or to create any right or benefit, substantive or procedural, enforceable at law by a party against the United States, its agencies, officers, or any person. They are not intended to provide any right to judicial review.

These guidelines reflect the Commission's commitment to information quality as an important management objective that takes its placed alongside other agency objectives, such as ensuring the success of the Commission's mission, observing budget resource priorities and restraints, and providing information to the public. The Commission will strive to assure that these goals reinforce each other as much as is practicable. Where the Commission believes that they conflict, the Commission will, consistent with its legal responsibilities, attempt to reconcile them in a manner which the agency believes will best serve the public interest and help the Commission meet its statutory or program obligations.

Information means any communication or representation of knowledge such as facts or data, in any medium or form, including textual, numerical, graphic, narrative or audiovisual forms. Information dissemination products include books, papers, CD-ROMs, electronic documents, or other documentary material disseminated to the public by the Commission. The guidelines apply to information disseminated by the Commission from a web page, but they do not apply to hyperlinks from the Commission website to information that others disseminate.

Dissemination includes Commission-initiated or sponsored distribution of information to the public. It does not include Commission citation to or discussion of information that was prepared by others and considered by the Commission in the performance of its responsibilities, unless the Commission disseminates it in a manner that reasonably suggests that the Commission agrees with the information. Commission sponsored distribution of information covers instances where the Commission has directed a third party to disseminate specific information on its behalf, or where the Commission has exercised its authority to review and approve the information before release.

These guidelines do not apply to the following:

• Government information intended to be limited to intra- or inter-agency use or sharing, such as strategic plans, performance plans, or budgets;
• Response to requests for Commission records under the Freedom of Information Act, the Privacy Act, the Federal Advisory Commission Act, or other similar laws;
• Correspondence or other communications with individuals, or organizations;
• Press releases (except where the press release itself is the primary source of information);
• Congressional testimony (except where the testimony itself is the primary source of the information);
• Archival records;
• Public filings;
• Dissemination of information through subpoenas or adjudicative processes, such as those recognized under the Administrative Procedure Act or established pursuant to regulation; provided, however, that information originally disseminated through such vehicles could subsequently become subject to these guidelines to the extent it is re-disseminated more broadly through other vehicles;
• Policy guidance, recommendations, or statements or summaries of agency policies, procedures, or programs;
• Statements of legal policy or interpretations, including briefs filed with courts or administrative bodies; and
• Final agency decisions, settlements in litigation and descriptions of these settlements, or determinations of legal force and effect.

Quality Management Principles

Quality includes the "utility," "objectivity," and "integrity" of the information. The level of quality will be "appropriate to the nature and timeliness of the information to be disseminated," and will be affected by the resources available and the nature of the underlying data. In considering utility, the Commission will evaluate the usefulness of particular information to those expected to use it. The information also will be objective-"accurate, reliable, and unbiased," and presented "in an accurate, clear, complete, and unbiased manner." The Commission will also protect the integrity of information from unauthorized access or revision. These objectives and guidelines are to be interpreted consistent with the Commission's statutory obligations.

Where the Commission is disseminating information of a scientific, financial or statistical nature, it will use sound statistical and research methods to develop and analyze the data. Depending on the type of information disseminated, and consistent with statutory and confidentiality restrictions, the Commission will identify the sources of the information, and where appropriate, the supporting data, models, and error sources.

Information Quality Responsibilities

Information quality will be an important goal in every phase of a product's development. The following responsibilities pertain to the implementation of these quality guidelines.

Director, Information Management

• Maintain a leadership role in overseeing the implementation of these guidelines and in providing guidance to the appropriate Commission employees on information quality matters.
• Develop and submit to OMB the annual report concerning the number, nature, and resolution of complaints regarding Commission compliance with OMB guidelines.
• Coordinate, as appropriate, with other federal organizations on cross-agency information quality issues.
• Apply, consistent with applicable statutes and regulations, these information quality guidelines to Commission-sponsored information products that the Commission has direct authority to control.
• Ensure that where Commission-sponsored information does not necessarily reflect the views of the Commission, an appropriate disclaimer will be included.
• Ensure that in its submissions to OMB under the Paperwork Reduction Act, the Commission demonstrates how it is attempting to provide that information will be collected, maintained, and used in a way consistent with OMB and Commission information quality standards.

Information Catagories

Per OMB's guidance, information means any communication or representation of knowledge such as facts or data, in any medium or form, including textual, numerical, graphic, cartographic, narrative, or audiovisual forms. This definition includes information that the Commission disseminates from a web page, but does not include the provision of hyperlinks to information that others disseminate. This definition does not include opinions where the Commission's presentation makes it clear that what is being offered is someone's opinion rather than fact or the agency's views on information of the kind that is subject to these Guidelines.

The Commission has identified two categories of information that are disseminated to the public, with the level of quality control and review being greater for influential information than for non-influential information. Whether information is influential is to be determined on an item-by-item basis rather than by aggregating multiple studies, documents, or other informational items that may influence a single policy or decision.

Influential

Definition: This category contains scientific, financial, or statistical information when the Commission can reasonably determine that dissemination will have or does have a clear and substantial impact on important public policies or important private sector decisions.

To be influential, information should have a clear and substantial impact. A clear impact is one that is determined by the Commission to have a high probability of occurring. A substantial impact is one that meets the levels of significance described below.

In rulemaking, influential information is scientific, financial or statistical information that the Commission believes will have a clear and substantial impact on the resolution of one or more key issues in an economically significant rulemaking, as that term is defined in section 3(f)(1) of Executive Order 12866.

It should be noted that the definition of "influential" applies to information itself and not to the decisions that the information may support. Even if a decision or action by the Commission is very important, a particular piece of information supporting it may not be influential, or example, because it is cumulative to other information or because it involves legal or policy issues.

Moreover, if it is merely arguable that an impact will occur, or if it is a close judgment call, then the impact is probably not clear and substantial. The "influential" designation is intended to be applied to information only when clearly appropriate. The Commission will not designate information products or types of information as influential on a regular or routine basis.

Non-Influential

Definition: All information disseminated to the public that does not meet the criteria set forth in the influential information definition.

Information Quality Assurance Process

The Commission will use the information quality assurance process described below to maximize the quality of information disseminated. The Commission will use information quality assurance processes that are appropriate to the complexity and importance of the product being developed. The Commission may use appropriate pre-existing information quality assurance processes that are at least as effective as those of OMB guidelines.

The quality assurance process will begin at the initiation of the product development process. The originating program office's Director is responsible for ensuring that the pre-dissemination review process is performed and documented at a level appropriate for the type of information disseminated. The costs and benefits of using a higher quality standard or a more extensive review process will be considered in deciding the appropriate level of quality for a given type of information, and the appropriate level of review and documentation. The originating office will utilize internal peer reviews and other review mechanisms to ensure that disseminated information is objective, unbiased, and accurate in both presentation and substance. The approval of information products prior to dissemination will be documented according to the internal procedures of the Commission. Routing slips, clearance forms, emails, or other approval mechanisms may be used to document the approval process.

The originating program office's Director is to review information presented to the public, including information on the Commission website, on an annual basis to ensure that the information is current, timely, and correct. The Commission will incorporate the selected quality assurance techniques into the project development schedule. Throughout the product's development, the Commission will ensure that quality assurance decisions are defensible and appropriate to the category of information involved.

The Commission will incorporate lessons learned into future product development activities so as to improve its overall quality management process. For draft information collections designed to gather information that the agency plans to disseminate, the Commission will demonstrate in its Paperwork Reduction Act clearance packages that each such draft information collection will result in information that will be collected, maintained, and used in a way consistent with OMB and Commission information quality standards.

Administrative Mechanisms For Information Correction

Affected persons may seek and obtain, where appropriate, timely correction of information maintained and disseminated by the Commission that does not comply with OMB or agency guidelines.

A. Complaint Procedure - Complaints regarding compliance of disseminated information with OMB or agency Guidelines must be addressed to the Executive Director, U.S. AbilityOne Commission, 1401 S. Clark Street, Suite 715, Arlington, VA 22202 or sent to the Executive Director through the "Contacts" feature on the agency's website at www.jwod.gov. Complainants should:

• Identify themselves and indicate where and how they can be reached;
• Identify, as specifically as possible, the information in question;
• Indicate how they are affected by the information about which they are complaining;
• Carefully describe the nature of the complaint, including an explanation of why they believe the information does not comply with OMB or Commission guidelines; and
• Describe the change requested and the reason why the Commission should make the change.

Failure to include this information may result in a complainant not receiving a response to the complaint or greatly reducing the usefulness or timeliness of any response. Complainants should be aware that they bear the burden of establishing that they are affected persons and showing the need and justification for the correction they are seeking, including why information being complained about does not comply with applicable guidelines.

B. Review Process - When disseminated information is the subject of a complaint, the Commission's Director, Information Management and other personnel responsible for the information will review the underlying data and the analytical process used to develop the disputed information to determine whether and how to correct the information, if appropriate. When the Commission determines that a correction of information is warranted, revisions to the information in question will begin as quickly as is practicable, subject to available resources and agency priorities.

The Commission is not required to change, or in any way alter, the content or status of information simply based on the receipt of a request for correction. Any corrective action will be determined by the nature and timeliness of the information involved and other factors such as the significance of the error on the use of the information, the magnitude of the error and the cost of undertaking a correction.

Any structured process would not apply to the Commission's archival information or to public filings. The Commission may choose not to respond to complaints about claimed defects that are frivolous or unlikely to have substantial future impact.

C. Timeframes - Within 60 calendar days from the date of receipt of the complaint, the Commission will make a determination regarding whether and how to correct the information. The Commission may extend the complaint resolution period for up to additional 60 calendar days based on the nature and extent of the complaint. The affected person(s) will be notified as to the reason for the additional time needed and an estimated decision date.

D. Agency Notification - The Commission will notify the affected person(s) of the corrections made to the subject information. Notification may include personal contacts via letter, telephone, electronic mail, form letters, press releases, mass mailings or website postings that correct a widely disseminated error or address a frequently raised complaint.

E. Appeal Process - If the person who requested a correction does not agree with the Commission's decision (including the corrective action, if any), the person may file for reconsideration with the agency. The Commission will respond to a request for reconsideration of the agency's initial decision within 60 calendar days of receiving the request. If the request cannot be resolved within 60 calendar days, the agency will inform the complainant that more time is required, indicate the reason and provide an estimated decision date.

F. Applicability - These administrative mechanisms apply to information that the agency disseminated on or after October 1, 2002, regardless of when the agency first disseminated the information. The fact that an information product that was disseminated by the Commission before this date is still maintained by the agency, does not make the information subject to these guidelines or to the request for correction process.

Certain dissemination of information, such as notices of proposed rulemaking, regulatory analyses, and requests for comment on information collections subject to the Paperwork Reduction Act, includes a comprehensive public comment process. The administrative complaint mechanism described in these Guidelines does not apply to such documents. Persons questioning information disseminated in such a document must submit comments as directed in that document.

Compliance Reporting

The Commission will submit compliance reports to the Director of OMB no later than January 1 following the end of each fiscal year, with the first report due no later than January 1, 2004. The report will include the number and nature of complaints received by the agency regarding agency compliance with the OMB and agency Guidelines and how such complaints were resolved.

APPENDIX A. DEFINITIONS

1. Affected Persons - Information users including: Businesses - nonprofit agencies, federal contractors, and trade associations; Citizens - households, individuals, employees, students, and retirees; government - state governments, local governments, universities, and schools; and Internal - federal agencies and federal employees.

2. Dissemination - Means Commission initiated or sponsored distribution of information to the public. Dissemination does not include distribution limited to government employees or agency contractors; intra- or inter-agency use or sharing of government information; and responses to requests for agency records under the Freedom of Information Act, the Privacy Act, the Federal Advisory Commission Act or other similar law. This definition also does not include distribution limited to correspondence with individuals or persons, press releases (unless they contain new substantive information not covered by a previous information dissemination subject to the Guidelines), archival records, public filings, subpoenas or adjudicative processes. The definition does not apply to procedural, operational, policy and internal manuals prepared for the management and operations of the Commission that are not primarily intended for public dissemination.

If a particular distribution of information is not covered by these Guidelines, the Guidelines still may apply to a subsequent distribution of the information in which the Commission adopts, endorses or uses the information to formulate or support a regulation, guidance or other agency decision or position.

3. Government information - Means information created, collected, processed, disseminated, or disposed of by or for the Federal Government.

4. Influential - When used in the phrase "influential financial or statistical information," means that the Commission has determined that dissemination of the information will have or does have a clear and substantial impact on important public policies or important private sector decisions.

5. Information - Means any communication or representation of knowledge such as facts or data, in any medium or form, including textual, numerical, graphic, narrative, or audiovisual forms. This definition includes information that the Commission disseminates from a web page, but does not include the provision of hyperlinks to information that others disseminate. This definition does not include opinions, where the agency's presentation makes it clear that what is being offered is someone's opinion rather than fact or the agency's views.

6. Information Dissemination Product - Means any book, paper, map, machine-readable material, audiovisual production, or other documentary material, regardless of physical form or a characteristic that the Commission disseminates to the public. This definition includes any electronic document, CD-ROM or web page.

7. Integrity - Refers to the security of information - protection of the information from unauthorized access or revision, to ensure that the information is not compromised through corruption or falsification.

8. Objectivity - Focuses on whether the disseminated information is being presented in an accurate, clear, complete and unbiased manner and, as a matter of substance, is accurate, reliable and unbiased.

9. Quality - An encompassing term comprising utility, objectivity and integrity. The Guidelines sometimes refer to these four statutory terms, collectively, as "quality."

10. Reproducibility - Means that the information is capable of being substantially reproduced, subject to an acceptable degree of imprecision.

11. Utility - Refers to the usefulness of the information to its intended users, including the public.