Information Quality Act

AuthorWilliam Funk - Jeffrey S. Lubbers
44 U.S.C. § 3516 note (2012); enacted December 21, 2000, by Pub. L.
No. 106-554 § 515, 114 Stat. 2763, 2763A-153.
Lead Agency:
Office of Management and Budget, Office of Information and Regula-
tory Affairs, 725 17th Street NW, Washington, D.C. 20503, (202) 395-4852;
The Information Quality Act (IQA), also frequently termed the Data
Quality Act, mandates the establishment of guidelines “ensuring and maxi-
mizing the quality, objectivity, utility, and integrity of information (includ-
ing statistical information) disseminated” by agencies. The IQA consists of a
two-sentence appropriations rider to the Treasury and General Government
Appropriations Act for Fiscal Year 2001 (Pub. L. No. 106-554) and amends
the 1995 Paperwork Reduction Act (PRA) 44 U.S.C. §§ 3501–3520. The
amendment directs the Office of Management and Budget (OMB) to issue
policy and procedural guidance to federal agencies that are subject to the
PRA. The IQA requires OMB to guide agencies (1) in issuing their own data
quality guidelines to regulate agency use and dissemination of information;
(2) in developing administrative mechanisms so that affected parties may
seek correction of information that does not comply with information quality
guidelines; and (3) in making periodic reports to OMB on the number, na-
ture, and resolution of any complaints the agencies receive concerning their
failure to comply with either OMB or agency-specific information quality
OMB published proposed guidelines pursuant to the IQA in the Federal
Register on June 28, 2001 (66 Fed. Reg. 34,489). Following public com-
ment, OMB published interim final guidelines on September 28, 2001 (66
Fed. Reg. 49,718), and then finalized guidelines, after additional public com-
ment, on February 22, 2002 (67 Fed. Reg. 8452). The guidelines are repro-
duced in Appendix 2 of this chapter and are available online at http://
reproducible2.pdf.On October 1, 2002, the OMB guidelines went into effect,
thus requiring agencies to issue, by the same date, their own guidelines de-
tailing their agency-specific information quality standards and outlining ad-
ministrative mechanisms for affected parties to challenge the quality of
agency-disseminated information. Any information disseminated by agencies
on or after October 1, 2002, is subject to the OMB and agency-specific infor-
mation quality guidelines. Agency-specific guidelines may be found on the
agency websites, in the Federal Register, or on the OMB website at http://
Information Quality Guidelines. The IQA aims to regulate “the sharing
by Federal agencies of, and access to, information disseminated by Federal
agencies.” The OMB guidelines define “information” as “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” (§ V.5). This definition includes information posted on an agency web
page, but excludes hyperlinks to information disseminated by sources outside
the agency. Similarly, if an agency presents information in a manner clearly
indicating that the information reflects an opinion, not a fact or an agency
view, the information is not subject to the same information quality standards.
The guidelines define “dissemination” as “agency initiated or sponsored distri-
bution of information to the public” (§ V.8). The guidelines exclude from the
definition of dissemination any distribution that is limited to “government
employees or agency contractors or grantees; intra- or inter-agency use or shar-
ing of government information; and responses to requests for agency records
under the Freedom of Information Act, the Privacy Act, the Federal Advisory
Committee Act or other similar law.” Further excluded are “correspondence
with individuals or persons, press releases, archival records, public filings,
[and] subpoenas or adjudicative processes” (§ V.8).
The IQA addresses the “quality, objectivity, utility, and integrity” of
agency information. The OMB guidelines provide definitions for these terms.
“Quality” encompasses utility, objectivity, and integrity. (§ V.1) “Utility”
contemplates the usefulness of information for both the agency and the pub-
lic such that “when transparency of information is relevant for assessing the
information’s usefulness from the public’s perspective, the agency must take
care to ensure that transparency has been addressed in its review of the infor-
mation.”(§ V.2) “Integrity” refers to the safeguarding of information fr om
unauthorized access or revision. (§ V.4) “Objectivity” focuses on whether
information is not only substantively accurate, clear and complete, but also
presented in an accurate, clear, complete, and unbiased manner (§§ V.3.a-b).
To satisfy the presentation prong of the objectivity requirement, agencies
must present information in context, which may—depending on the sort of
information—require providing additional information, sources, supporting
data, models, sources of errors and documentation. The substantive objectiv-
ity prong requires that scientific, financial, or statistical information be based
on original and supporting data and analytic results produced using “sound
statistical and research methods” (§ V.3.b).
The guidelines provide that information presumptively satisfies the sub-
stantive objectivity requirement if the relevant data and analytic results have
undergone formal, independent, external peer review (§ V.3.b.i). A presump-
tion of objectivity is rebuttable if a petitioner persuasively demonstrates a
lack of objectivity. If peer review is agency-sponsored, certain transparency
requirements are triggered to ensure the peer review is adequate. Agency-
sponsored peer reviews must be open and rigorous, and peer reviewers must
be selected primarily on the basis of necessary technical expertise, disclose to
agencies any prior positions they may have taken on pertinent issues, and
reveal sources of personal and institutional funding.
The objectivity standard—that information be “reproducible” to prove
transparency—is more particular for information that falls into the category
of not simply ordinary but “influential” information (§ V.3.b.ii.B). Informa-
tion is influential if “the agency can reasonably determine that dissemination
of the information will have or does have a clear and substantial impact on
important public policies or important private sector decisions” (§ V.9). Each
agency may separately define “influential” to accord with “the nature and
multiplicity of issues for which the agency is responsible” (§ V.9). Agencies
should consult with relevant scientific and technical communities on the fea-
sibility of making certain categories of data subject to the reproducibility
standard (§ V.3.b.ii.A). Reproducibility in the analytic analysis context de-
mands that “independent analysis of the original or supporting data using
identical methods would generate similar analytic results, subject to an ac-
ceptable degree of imprecision or error” (§ V.10). The acceptable degree of
imprecision changes to reflect the impacts the information may have. The
reproducibility standard for other categories of data is set forth by individual

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