U.S. Department of Education

Information Quality Guidelines

# 

# Introduction

Section 515 of the Treasury and General Government Appropriations Act
for Fiscal Year 2001 (Public Law 106-554) directed the U.S. Office of
Management and Budget (OMB) to issue government-wide guidelines that
"provide policy and procedural guidance to Federal agencies for ensuring
and maximizing the quality, objectivity, utility, and integrity of
information (including statistical information) disseminated by Federal
agencies." *Information*, as defined by OMB, includes 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. *Dissemination* refers to any distribution of
information to the public that is initiated or sponsored by a federal
agency. (OMB, *Guidelines for Ensuring and Maximizing the Quality,
Objectivity, Utility, and Integrity of Information Disseminated by
Federal Agencies,* February 22, 2002, 67 FR 8452-8460).

In summary, OMB's guidelines, issued on February 22, 2002, direct
agencies to:

-   Develop and implement their own agency-specific information quality
    guidelines by October 1, 2002;

-   Adopt a basic standard of quality (including objectivity, utility,
    and integrity) as a performance goal and incorporate the standard
    into the agency's operations;

-   Develop a process for reviewing the quality of information to ensure
    quality before information is disseminated;

-   Establish a process for affected persons to request correction of
    information that may not comply with OMB's or the agency's
    guidelines; and

-   Report annually to the Director of OMB, beginning January 1, 2004,
    the number and nature of complaints received by the agency regarding
    the agency's compliance with its guidelines concerning the quality,
    objectivity, utility, and integrity of information, and how such
    complaints were resolved.

# Background

# 

Information quality is important to the Department of Education because
educators, researchers, policymakers, and the public use information
that the Department disseminates for a variety of purposes**.** Thus, it
is important that the information the Department disseminates be
accurate and reliable.

The Department's Strategic Plan emphasizes the importance of information
quality. For example, goal four of the six strategic goals is to
"Transform Education into an Evidence-based Field." Under this goal, the
Department seeks "to ensure that research funded or published by the
Department is of the highest quality." The Department places priority on
ensuring "... that high-quality research -- whether or not it is funded
by the Department -- is synthesized, publicized, and disseminated
widely."

The Department also relies on high quality information in the
administration of its grant programs. For example, Objective 1.1 under
the Strategic Plan requires the Department to "...link federal education
funding to accountability for results." Consequently, programs that
cannot demonstrate evidence of effectiveness will be candidates for
reform or elimination. High quality information is required to
demonstrate evidence of effective programs. To make sound decisions, the
Department intends to accept and use only information that is accurate
and reliable**.**

To serve the public, the Department of Education prepares and
disseminates information products that describe the condition of
American education and the Department's policies, programs, and
services. The Department also disseminates profiles of the learner
populations served by Department programs, evaluations of Department
programs, and research products describing what works in American
education. In addition, the Department reports statistical data
describing the educational achievement, attainment, and the demographic
and socioeconomic characteristics of America's students; the
characteristics of the education labor force in the United States; the
financing of education in the United States; and international
comparisons of education systems and their students. The Department
disseminates most of its information products in both printed and
electronic formats, as well as in oral presentations. Many information
products are announced on the Department's Web site (www.ed.gov), where
they can be accessed and downloaded.

# 

# Purpose and Scope

# 

Consistent with the guidance from OMB**,** the Department of Education's
Information Quality Guidelines (Guidelines) described below reflect the
Department's policy and procedures for reviewing and substantiating the
quality of information it disseminates, (*e.g*., reports, studies, and
summaries), as well as provide an administrative mechanism allowing
affected persons to seek and obtain, where appropriate, correction of
information not complying with the Guidelines. These Guidelines, along
with those issued by OMB, represent a performance goal for the
Department and are intended only to improve the internal management of
the Department. They do not create any private right of action to be
used by any party against the government in a court of law or in an
administrative hearing.

The Guidelines are applicable to information that the Department of
Education disseminates on or after October 1, 2002, including the review
of information to ensure quality before it is disseminated to the
public. Some previously released information products continue to be
used for decision-making or are relied upon by the Department and the
public as official, authoritative, government information; this
information is, in effect, constantly being re-disseminated and are thus
subject to these Guidelines. Previously released information products
that do not meet these criteria are considered archived information and
thus are not subject to these Guidelines.

In addition, individual offices within the Department of Education may
have more detailed guidelines that are tailored to specific information
needs. An example of program-specific guidelines are the National Center
for Education Statistics (NCES) Statistical Standards, which may be
accessed at the following url:
[**http://nces.ed.gov/statprog/**](http://nces.ed.gov/statprog/). Other
individual offices within the Department of Education also may develop
guidelines tailored to their specific needs; however, individual office
guidelines would be consistent with the Department of Education
Guidelines described below.

Under these Guidelines, information disseminated by the Department of
Education is divided into four categories:

-   ***General Information about Education Programs***, such as fact
    sheets, descriptions of programs and services and guidance on who is
    eligible and how and where to apply for services or assistance.
    General information might also include public service reports on
    evaluations of specific programs and services, and descriptions of
    findings.

-   ***Research Studies and Program Evaluation Information***, such as
    detailed reports of research findings and methodologies and
    technical reports describing the procedures employed and the results
    of program evaluations.

-   ***Administrative and Program Data***, such as aggregates of records
    from schools, school districts, and states.

-   ***Statistical Data***, such as data collections of
    nonadministrative data and special purpose surveys that are designed
    to fill data gaps or information needs.

These Guidelines, however, do not govern all information of the
Department, nor do they cover all information disseminated by the
Department. For example, the Guidelines generally **do not cover**:

# 

-   Internal information such as employee records;

-   Internal procedural, operational, or policy manuals prepared for the
    management and operations of the Department of Education that are
    not primarily intended for public dissemination;

-   Information collected or developed by the Department that is not
    disseminated to the public, including documents intended only for
    inter-agency or intra-agency communications;

-   Research findings and other information published by grantees,
    unless the Department --

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-   Represents, uses, or relies upon the information as the official
    position of the Department, or in support of the official position
    of the Department;

-   Has authority to review and approve the information before release;
    or

-   Directs that the information be disseminated;

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-   Opinions that are clearly identified as such, and that do not
    represent facts or the agency's views;

-   Electronic links to information on other Web sites;

-   Correspondence with individuals;

-   Responses to requests for information under the Freedom of
    Information Act, the Federal Advisory Committee Act, and the Privacy
    Act;

-   Press releases, unless they contain new substantive information that
    was not previously released;

-   Congressional testimony that includes data that has previously been
    disseminated;

-   Comments received from the public in response to *Federal Register*
    notices;

-   Distributions intended to be limited to subpoenas or adjudicative
    processes, *i.e.,* the findings and determinations made in the
    course of adjudications;

-   Information collected during the course of a Departmental
    investigation that is not intended to be disseminated to the public,
    *e.g*.*,* data collected through resolution of an OCR or OIG
    investigation; and

-   Archival records, including previously released information products
    that are not being relied upon, used for decision-making, or held
    out as authoritative data.

# Information Quality

These Guidelines assess information quality using three factors:
utility, objectivity, and integrity. These elements are intended to
ensure that information the Department disseminates is useful, accurate,
reliable, unbiased, and secure. Department staff will treat information
quality as integral to the creation, collection, maintenance, and
dissemination of information, and will review products before they are
disseminated to ensure that they are consistent with these Guidelines.
In particular, information products from the Department will follow the
*Guide to Publishing at the U.S. Department of Education*, and all
clearance submissions under the Paperwork Reduction Act will explain how
the proposed collection of information will yield high quality,
objective, and useful data, consistent with OMB's guidelines.
Furthermore, the Guidelines provide that the level of quality assurance
for information must be tied to its level of importance. *Influential
Information,* that is information that will or does have a clear and
substantial impact on public policies or private sector decisions, must
meet a higher level of quality as described on page 9 of these
Guidelines.

# 

## Utility

*Utility refers to the usefulness of the information to its intended
users. Utility is achieved by staying informed of information needs and
developing new products and services where appropriate. To maximize the
utility of influential information, care must be taken in the review
stage to ensure that the information can be clearly understood and,
where appropriate and to the extent practical, an external user of the
information can reproduce the steps involved in producing the
information.*

Ultimately, the Department intends to ensure that the information it
disseminates meets the needs of intended users. All information products
should be grammatically correct and clearly written in plain English.
The target audience should be clearly identified, and the product should
be understandable to that audience.

To ensure the usefulness of Department products, all information
products should provide information that will help the Department
fulfill its mission "to ensure equal access to education and to promote
educational excellence throughout the nation." When appropriate,
Department products should include contact information for users who
seek clarification or further information, or who want to provide
feedback.

In particular---

-   ***General Information*** should provide clear and readable
    descriptions of the Department's programs and services and, where
    applicable, guidance and assistance, including who is eligible and
    how and where to apply for services or assistance. It also may
    include information pertaining to evaluations of specific programs
    and services, and descriptions of findings.

-   ***Research Studies and Program Evaluations*** should be designed
    and reviewed to fill the information needs that are identified
    through internal review, legislative mandates, or input from data
    users outside the Department.

-   ***Administrative and Program Data,*** *e.g.,* aggregate data (or
    information) derived from records at the school, school district,
    and state levels, should be carefully described and documented in
    all reports and products released by the Department.

-   ***Statistical Data,** e.g*., data collections of non-administrative
    data and special purpose surveys should be designed to fill data
    gaps or information needs that are identified through internal
    review, legislative mandates, or input from data users outside the
    Department, and should be reviewed for how well they fulfill that
    purpose.

The usefulness of information the Department disseminates will be
evaluated from the perspective of the Department, educators, education
researchers, policymakers, and the public. The Department relies upon
internal reviews and analyses, along with feedback from advisory
committees, educators, education researchers, policymakers, and the
public to achieve this. Consistent with OMB's guidance, the Department's
goal is to maximize the usefulness of the information and minimize the
cost to the government and the public. When disseminating its
information products, the Department will utilize varied dissemination
channels so that the public, education researchers, and policymakers can
locate Department information in an equitable and timely fashion.

## Objectivity

*Objectivity refers to the accuracy, reliability, and unbiased nature of
information. It is achieved by using reliable information sources and
appropriate techniques to prepare information products. Objectivity
involves both the content and the presentation of the information.
Content should be complete, include documentation of the source of any
information used, as well as, when appropriate, a description of the
sources of any errors in the data that may affect the quality of the
information product**.** The presentation of the information should be
clear and in a proper context so that users can easily understand its
meaning.*

The Department strives to present information to the public in an
accurate, clear, complete, and unbiased manner. In keeping with the OMB
Information Quality Guidelines, all information products should undergo
editorial and technical peer review to assist the Department in meeting
this performance goal.

### General Information

Department of Education information products should be appropriate for
the target audience. Each product should:

1.  Clearly state the goals or purpose of the information product;

2.  Include an unbiased presentation of the topic in question;

3.  If applicable, draw upon peer**-**reviewed, scientific
    evidence-based research that is appropriately documented;

4.  Clearly identify data sources, if applicable; and

5.  Confirm and document the reliability of the data, and acknowledge
    any shortcomings or explicit errors in any data that is included.

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1.  

### Research and Evaluation Information

Department of Education research and evaluation information products
should, at a minimum:

1.  Clearly state the goals or purpose of the topic in question;

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6.  Pose the research or evaluation question in a balanced and unbiased
    manner;

7.  Provide an unbiased test of the question;

8.  Have a research study approach or data collection technique that is
    well thought out, designed to use state of the art methodologies in
    the data collection, and be clearly described in the study
    documentation;

9.  Present conclusions that are strongly supported by the data;

10. Clearly identify data sources, if applicable;

11. Confirm and document the reliability of the data, and acknowledge
    any shortcomings or explicit errors in any data that is included;
    and

12. Undergo peer review.

Department of Education research and evaluation information products
documenting cause and effect relationships or evidence of effectiveness
should meet the quality standards that will be developed as part of the
*What Works Clearinghouse.*

### Administrative and Program Data

The Department of Education reports data that rely upon information
provided by third parties. These data draw upon aggregates from student
record systems or other administrative data (*e.g*., universe studies,
including censuses, and other reports based on aggregate administrative
data). These data rely upon information provided by third parties.
Because of this, the Department does not have full control over the
quality of the reported data; the Department intends to, however,
identify the source of the information and any shortcomings or
limitations of the data if we rely upon it for decision-making purposes.
This will facilitate the public's understanding of the strengths and
potential weaknesses of these data. Furthermore, as an additional
assurance of quality, these data should meet the criteria that are being
developed as part of an ongoing Department-wide data standardization and
coordination initiative. At a minimum, these standards will require the
following:

1.  In formulating a data collection plan the goals of the study should
    be clearly described;

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13. The subjects to be studied and the data to be collected should be
    clearly defined, using broadly understood concepts and definitions
    that are consistent with Department data definition handbooks;

14. The research study approach or data collection techniques should be
    well thought out and designed to use state-of-the-art methodologies
    in the data collection, and should be clearly described in the study
    documentation;

15. In designing the work, every effort should be made to minimize the
    amount of time required for responding institutions;

16. The source of research information or data should be reliable. Data
    should be collected with survey instruments that have been properly
    developed and tested;

17. Response rates should be monitored during data collection. When
    necessary, appropriate steps should be taken to ensure the
    respondents are representative of the population;

18. When applicable, care should be taken to ensure the confidentiality
    of personally identifiable data, as required by law, during the
    collection, processing, and analysis of the data;

19. Upon completion of the work, the findings and data should be
    processed in a manner sufficient to ensure that the data are edited
    to help ensure that the data are accurate and reliable;

20. The findings and data collection should be properly documented and
    stored, and the documentation should include an evaluation of the
    quality of the data with a description of any limitations of the
    data. In particular, any known limitations of the information should
    be documented (*e.g*., missing values, amount of nonresponse);

21. The analysis should be selected and implemented to ensure that the
    data are correctly analyzed using modern statistical techniques
    suitable for hypothesis testing. Techniques may vary from simple
    tabulations and descriptive analysis to multivariate analysis of
    complex interrelationships. Care should be taken to ensure that the
    techniques are appropriate for the data and the questions under
    inquiry;

22. All work should be conducted and released in a timely manner;

23. Reports using these data should identify the source(s) of the
    information, including a citation. Reports should also include:

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a)  The reason the information is provided, its potential uses, and
    cautions as to inappropriate extractions or conclusions.

b)  Descriptions of any statistical techniques or mathematical
    operations applied to the data.

c)  The identification of other possible sources of potentially
    corroborating or conflicting information; and

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24. Prior to dissemination, all reports, data, and documentation should
    undergo editorial and technical review to ensure accuracy and
    clarity.

### Statistical Data

Department of Education reports and data collections that draw upon
sample survey data should be clearly written, and should follow these
Guidelines:

1.  In formulating a data collection plan, the goals of the study should
    be clearly described;

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25. The subjects to be studied and the data to be collected should be
    clearly defined, using broadly understood concepts and definitions
    that are consistent with Department data definition handbooks;

26. The research study approach or data collection techniques should be
    well thought out and designed to use state-of-the-art methodologies
    in the data collection and should also be clearly described in the
    study documentation;

27. In designing the work, every effort should be made to minimize the
    amount of time required for study participants;

28. The source of data should be reliable. The sample should be drawn
    from a complete list of items to be tested or evaluated, and the
    appropriate respondents should be identified, correctly sampled, and
    queried with survey instruments that have been properly developed
    and tested;

29. Response rates should be monitored during data collection. When
    necessary, appropriate steps should be taken to ensure that the
    respondents are a representative sample;

30. Care should be taken to ensure the confidentiality of personally
    identifiable data, as required by law, during research/data
    collection, processing, and analysis of the resulting data;

31. Upon completion of the work, the data should be processed in a
    manner sufficient to ensure that the data are cleaned and edited to
    help ensure that the data are accurate and reliable;

32. The findings and data collection should be properly documented and
    stored, and the documentation should include an evaluation of the
    quality of the data with a description of any limitations of the
    data. In particular, any known limitations of the information should
    be documented (*e.g*., missing values, amount of nonresponse);

33. Data should be capable of being reproduced or replicated based on
    information included in the documentation, such as:

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a)  The source(s) of the information;

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d)  The date the information was current;

e)  Any known limitations on the information;

f)  The reason that the information is provided;

g)  Descriptions of any statistical techniques or mathematical
    operations applied to source data; and

h)  Identification of other sources of potentially corroborating or
    conflicting information.

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34. If secondary analysis of data is employed, the source should be
    acknowledged, the reliability of the data should be confirmed and
    documented, and any shortcomings or explicit errors should be
    acknowledged (*e.g.,* the representativeness of the data,
    measurement error, data preparation error, processing error,
    sampling errors, and nonresponse errors);

35. The analysis should be selected and implemented to ensure that the
    data are correctly analyzed using modern statistical techniques
    suitable for hypothesis testing. Techniques may vary from simple
    tabulations and descriptive analysis to multivariate analysis of
    complex interrelationships. Care should be taken to ensure that the
    techniques are appropriate for the data and the questions under
    inquiry;

36. Reports should include the reason the information is provided, its
    potential uses, and cautions as to inappropriate extractions or
    conclusions, and the identification of other sources of potentially
    corroborating or conflicting information;

37. Descriptions of the data and all analytical work should be reported
    in sufficient detail to ensure that the findings could be reproduced
    using the same data and methods of analysis; this includes the
    preservation of the data set used to produce the work;

38. Prior to dissemination all reports, data, and documentation should
    undergo editorial and technical review to ensure accuracy and
    clarity. Qualified technical staff and peers both inside and outside
    the Department should do the technical review;

39. All work should be conducted and released in a timely manner; and

40. There should be established procedures to correct any identified
    errors. These procedures may include the publication of errata
    sheets, revised publications, or Web postings.

## Integrity

Integrity refers to the security or protection of information from
unauthorized access or revision. Integrity ensures that the information
is not compromised through corruption or falsification.

The Department strives to protect the information it collects, uses, and
disseminates to the public from unauthorized disclosure, alteration,
loss, or destruction. Statutory and administrative guidelines to protect
the integrity of Department information include the following:

-   Privacy Act;

-   Freedom of Information Act;

-   OMB Circulars A-123, A-127, and A-130;

-   Federal Policy for the Protection of Human Subjects;

-   Family Educational Rights and Privacy Act;

-   Computer Security Act of 1987;

-   Government Information Security Reform Act; and

-   National Education Statistics Act, as amended by the USA Patriot
    Act.

Under the Privacy Act, the Department safeguards personally identifiable
information that it gathers and maintains about individuals in a system
of records. The Department is also highly protective of administrative
records and sample survey data that include personally identifiable
information, especially survey data that are collected under pledges of
confidentiality.

Under the Computer Security Act of 1987, the Department of Education has
identified all federal computer systems that contain sensitive
information and has implemented security plans to protect these systems,
so as to protect sensitive information against loss, misuse, disclosure
or modification. In this context, sensitive information includes data
covered under the Privacy Act and information that could affect the
conduct of federal programs.

## Influential Information

Government information that is particularly influential needs to meet
higher quality standards, and in particular must be reproducible. Per
the OMB guidelines, information is designated as influential if the
Department determines that the information is reasonably likely to have
a clear and substantial impact on public policies or private sector
decisions if disseminated. Scientific, financial, and statistical
information all may be considered influential. Individual programs
within the Department of Education may designate certain classes of
scientific, financial, and statistical information as influential.

For example, institutional data on the total number of student borrowers
who enter repayment on Stafford loans during a specific fiscal year, and
related data on the subset of students who default before the end of the
next fiscal year are used in the calculation of cohort loan default
rates of Stafford loan borrowers at each postsecondary institution.
These default rates are compared to established thresholds for high and
low default rates, resulting in sanctions for institutions with high
default rates and reduced administrative burden for institutions with
low default rates. Given this use, these data and the calculations used
in computing the rates and in setting the thresholds are influential.
Similarly, the data and formulas used in determining program allocation
of funds in areas such as special education, adult education, and Title
I are influential.

As specified in the OMB guidelines, influential information must be
accompanied by supporting documentation that allows an external user to
understand clearly the information and be able to reproduce it, or
understand the steps involved in producing it. With respect to original
and supporting data related thereto, the Department will assure
reproducibility for such data according to commonly accepted scientific,
financial, or statistical standards for that type of data, taking into
account any ethical and confidentiality constraints. In the case of
influential analytic results, the mathematical and statistical processes
used to produce the report must be described in sufficient detail to
allow an independent analyst to substantially reproduce the findings
using the original data and identical methods. In situations where the
public cannot access the data and methods due to other compelling
interests such as privacy, intellectual property or other
confidentiality protections, the Department will apply especially
rigorous robustness checks to analytic results and document what checks
were undertaken.

# Information Correction Requests and Appeals 

Effective October 1, 2002**,** the Department of Education will allow
any affected person to request the correction of information the
Department disseminates that does not comply with applicable OMB and
Department of Education information quality guidelines. An affected
person is an individual or an entity that may use, benefit or be harmed
by the disseminated information at issue.

Most Department information products include the names of knowledgeable
staff that can assist users in understanding the information presented,
and in determining whether there is an error that warrants action using
the correction process described in this section. Users of the
Department's information should consult with the contact person listed
in the product before filing a formal request for correction.

## Information Correction Requests

In the Department of Education's correction request process, the burden
of proof rests with the requester. An affected person who believes that
information the Department disseminates does not adhere to the
information quality guidelines of OMB or the Department, or an office of
the Department that has issued program-specific guidelines, and who
would like to request correction of specific information, needs to
provide the following information:

-   Identification of the requester (*i.e.,* name, mailing address,
    telephone number, and organizational affiliation, if any);

-   A detailed description of the information that the requester
    believes does not comply with the Department's or OMB's guidelines,
    including the exact name of the data collection or report, the
    disseminating office and author, if known, and a description of the
    specific item in question;

-   Potential impacts on the requester from the information identified
    for correction (*i.e*., describe the requestor's interest in the
    information and how the requestor is affected by the information in
    question); and

-   An explanation of the reason(s) that the information should be
    corrected (*i.e*., describe clearly and specifically the elements of
    the information quality guidelines that were not followed).

This information should be provided to the Deputy Chief Information
Officer for Information Management at the following address:

> Director, Information Management
>
> Office of the Chief Information Officer
>
> U.S. Department of Education
>
> RE: Information Quality Request
>
> Room 4060, ROB-3
>
> 400 Maryland Avenue, SW
>
> Washington, DC 20202

Alternatively, requesters may submit e-mail requests to the following
address: "<ocio.infoqualityrequest@ed.gov>." Requesters should indicate
that they are submitting an Information Quality Request in the subject
line of the e-mail.

## Review

The Director, Information Management, CIO (DIM/CIO) will review the
request and determine whether it contains all the information required
for a complaint. If the request is unclear or incomplete, the Department
will seek clarification from the requester.

If the request is clear and complete, the DIM/CIO will forward it to the
appropriate program office(s) for a response to the requester. The
responsible office(s) will determine whether a correction is warranted,
and if so, what corrective action it will take. Any corrective action
will be determined based on the nature and timeliness of the information
involved, as well as the significance of the error on the use of the
information, the magnitude of the error, and the cost of undertaking a
correction.

Comments about information on which the Department has sought public
comment, such as rulemaking or studies cited in a rulemaking**,** will
be responded to through the public comment process, or through an
individual response if there was no published process for responding to
all comments. The Department may choose to provide an earlier response,
if doing so is appropriate, and will not delay issuance of the final
action in the matter.

The Department is not required to change the content or status of
information simply based on the receipt of a request for correction. The
Department may reject a request that appears to be made in bad faith or
without justification, and is only required to undertake the degree of
correction that is appropriate for the nature and timeliness of the
information involved. In addition, the Department need not respond
substantively to requests that concern information not covered by the
information quality guidelines.

## Response

The Department will respond to all requests for correction within 60
calendar days of the DIM/CIO's receipt of the request, including
requests that the Department elects not to process further. For requests
that merit review **--**

-   If the request is clear and complete, the Department's response will
    explain the findings of the review, or will inform the requester if
    more time is needed to complete the review, the reason(s) for the
    additional time, and an estimate of the time it will take to
    respond. The appropriate program office will be responsible for
    determining what action is necessary and, if an error was made, it
    will determine the appropriate level of correction.

-   If the request is incomplete or unclear, the DIM/CIO, will seek
    clarification from the requester. In the case of an unclear or
    incomplete request, the requester may submit additional clarifying
    information if he or she so chooses. However, the deadline for the
    Department's review and response will be based upon the date the
    clarifying information is received.

Once a decision is made, the response will explain to the requester that
he or she has a right to appeal the decision. Copies of all Department
correspondence related to Information Quality Requests will be
maintained by the DIM/CIO.

## Appeals

If a requester is not satisfied with the Department's decision on the
request (including the corrective action, if any), he or she may appeal
to the Department's Chief Information Officer within thirty (30)
calendar days of receipt of the Department's decision. This
administrative appeal must include a copy of the initial request, a copy
of the Department's decision, and a letter explaining why he or she
believes the Department's decision was inadequate, incomplete, or in
error.

This appeal information should be provided to the Department's Chief
Information Officer (OCIO) at the following address:

> The Chief Information Officer
>
> U.S. Department of Education
>
> RE: Information Quality Appeal
>
> Room 4082, ROB-3
>
> 400 Maryland Avenue, SW
>
> Washington, DC 20202

Alternatively, requesters may submit an appeal by e-mail to the
following address: "<ocio.infoqualityappeal@ed.gov>."

Requesters should indicate that they are submitting an Information
Quality Appeal in the subject line of the e-mail. Such e-mail requests
must include all of the information specified for an appeal submitted by
regular mail.

The Department will ensure that all appeals are subjected to an
impartial review that is conducted by parties other than those who
prepared the Department's decision. The Department will respond to all
appeals within 60 calendar days of the CIO's receipt of the appeal, or
will inform the requester if more time is needed to complete the review
of the appeal, and the reason(s) for the additional time.