July 12, 2019 

VIA ELECTRONIC MAIL 

Director, Information Collection Clearance Division 

Office of the Chief Privacy Officer 

Office of Management 

U.S. Department of Education 

400 Maryland Avenue S.W. 

LBJ, Mailstop L-OM-2-2E319 

Washington, D.C. 20202 

OMInformationQuality@ed.gov 

Principal Deputy Assistant Secretary Office of Management 

U.S. Department of Education 

400 Maryland Avenue S.W. 

LBJ, Room 2W311 

Washington, D.C. 20202 

OMInformationQualityRequests@ed.gov 

ATTN: Information Quality Request 

Re: NPRM – Student Assistance General Provisions, the Secretary’s Recognition of Accrediting 

Agencies, the Secretary’s Recognition Procedures for State Agencies 

Docket ID ED-2018-OPE-0076 

To whom it may concern: 

This is a Petition for Correction and Disclosure (“Petition”) in accordance with the Information 

Quality Act (“IQA”), the information and quality guidelines issued by the Office of Management 

and Budget (“OMB”), and the IQA Guidelines1 issued by the U.S. Department of Education (the 

“Department”).2 

This Petition focuses on the Department’s recent publication of a Notice of Proposed Rulemaking 

(“NPRM”) that proposes to revise the Department’s accreditation, state authorization, institutional 

eligibility, and student assistance general provisions.3 The NPRM includes an abundance of factual 

1 See Ex. A (U.S. Dep’t of Educ., “Information Quality Guidelines” (2002), available at: 

https://www2.ed.gov/policy/gen/guid/iq/infoqualguide.pdf) (hereinafter the “ED Guidelines”)). 2 The ED Guidelines do not provide clear instructions on how to submit this sort of petition. In the PDF 

version of the ED Guidelines (https://www2.ed.gov/policy/gen/guid/iq/infoqualguide.pdf), the Department instructs 

the public to submit IQA correction requests to the Principal Deputy Assistant for Management. In the non-PDF 

version (https://www2.ed.gov/policy/gen/guid/iq/iqg_5a.html), the Department instructs the public to submit IQA 

correction requests to the Director, Information Collection Clearance Division. Out of an abundance of caution, we are 

providing it to both recipients. 

3 84 Fed. Reg. 27,404 (Jun. 12, 2019). 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Principal Deputy Assistant Secretary Office of Management & 

Director, Information Collection Clearance Division 

U.S. Department of Education 

Page 2 of 12 

July 12, 2019 

claims without disclosing the underlying sources or methodologies, a clear failure to comply with the 

IQA. These failures render meaningless the entire purpose of the public comment period. As a 

result, commenters, including NSLDN,4 have been unable to provide effective feedback on the 

Department’s proposals. 

Because NSLDN stands to suffer harm from the continued dissemination of this information, it is 

an “affected person” under the IQA and may, therefore, submit this Petition. Although the ED 

Guidelines do not define “affected,”5 NSLDN has been—and will continue to be—harmed by the 

disseminated information. Not only has NSLDN submitted written comments in response to the 

NPRM, which was made more difficult and at times impossible due to the IQA failures identified 

herein, but also NSLDN actively studies, researches, and proposes student-focused policies at the 

state and local level. By disseminating information that fails to meet the basic standards of the IQA, 

the Department is infringing upon NSLDN’s significant interest in ensuring that the Department 

relies upon and publishes only accurate and reliable data in its communications with the public. 

Given the current abundance of unsupported claims in the Department’s NPRM on accreditation, 

state authorization, institutional eligibility, and student assistance general provisions, NSLDN 

requests that the Department rescind this NPRM immediately and, if the Department desires, 

correct and reissue it with information that complies with the IQA. 

1. Background 

As we have discussed in our separately submitted comments, the Department’s NPRM proposes 

one of the most comprehensive regulatory reform packages covering a dizzying array of topics. For 

example, as part of the proposal, the Department suggests gutting accountability criteria for 

recognizing accrediting agencies, a move that favors poor-performing institutions and creates 

enormous space for bad actors to exploit the neediest students. Simultaneously, the Department 

proposes to make sweeping changes to the 2016 State Authorization Rule and other mandatory 

disclosure requirements, which provide students with critical information to make informed 

enrollment decisions, as well as the institutional eligibility and standards for participation in Title IV 

program requirements, which hold institutions accountable for any misconduct. By watering down 

these regulations, the Department’s NPRM serves as one more glaring example of this 

Administration’s anti-student agenda. 

As many have stated while commenting on the proposed changes, this NPRM is also the result of a 

fundamentally flawed negotiated rulemaking process. The result of that process is not only a 

proposal that will harm students, but also one with consequences that the Department clearly does 

not comprehend. By the Department’s own admission, the NPRM’s proposed changes are being 

made with only “limited data on which to base estimates of accrediting agency, institutional, and 

4 NSLDN is a non-profit, nonpartisan organization that works, through litigation and advocacy, to advance 

students’ rights to educational opportunity and to ensure that higher education provides a launching point for economic 

mobility. 

5 See generally Ex. A. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Principal Deputy Assistant Secretary Office of Management & 

Director, Information Collection Clearance Division 

U.S. Department of Education 

Page 3 of 12 

July 12, 2019 

student responses to the regulatory changes.”6 To make matters worse, and as explained in further 

detail below, the NPRM also relies upon unsourced information in violation of the IQA. Given 

these deficiencies, NSLDN urges the Department to go back to the drawing board. 

2. Grounds for Disclosure and Correction under the IQA 

The IQA and its implementing guidelines require that information disseminated to the public by 

federal agencies be accurate, reliable, and unbiased. Indeed, the IQA—passed by Congress in 

2001—directed the OMB to require that each applicable federal agency “issue guidelines ensuring 

and maximizing the quality, objectivity, utility, and integrity of information (including statistical 

information)” that the agency disseminated.7 In response to the statute, OMB issued final guidelines 

implementing the IQA and requiring agencies to publish their own guidelines no later than October 

1, 2002.8 

Similar to OMB’s Guidelines, the ED Guidelines apply to “information,” i.e., “any communication 

or representation of knowledge, such as facts or data, in any medium or form” that is 

“disseminat[ed]” to the public.9 Ex. A at 1 (emphasis added). The ED Guidelines affirm that, “[t]o 

make sound decisions, the Department intends to accept and use only information that is accurate 

and reliable.” Ex. A at 2. Furthermore, the ED Guidelines make clear that it is similarly “important 

that the information the Department [itself] disseminates be accurate and reliable.” Id. at 1. 

The Department uses three factors to assess the quality of information it disseminates: “utility, 

objectivity, and integrity.” Ex. A at 4. As relevant here, the ED Guidelines define objectivity as 

follows: 

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. 

Id. at 5 (emphasis removed). The ED Guidelines then go on to list what each dissemination of 

general information should include in order to be considered “objective,” such as: 

• “[D]raw[ing] upon peer-reviewed, scientific evidence-based research that is appropriately 

documented;” 

6 84 Fed. Reg. at 27,450. 7 Consolidated Appropriations Act, Pub. L. No. 106-554, § 515(a), 114 Stat. 2763 (2001). 8 67 Fed. Reg. 8,452 (Feb. 22, 2002). 9 See also 67 Fed. Reg. at 8,453 (establishing that “information” means “any communication or representation of 

knowledge such as facts or data”). 
 

 

 

 

 

 

 

 

 

 

 

Principal Deputy Assistant Secretary Office of Management & 

Director, Information Collection Clearance Division 

U.S. Department of Education 

Page 4 of 12 

July 12, 2019 

• “Clearly identify[ing] data sources;” [and] 

• “Confirm[ing] and document[ing] the reliability of the data, and acknowledg[ing] any 

shortcoming or explicit errors in any data that is included.” 

Id. at 5. Additionally, the ED Guidelines state that, to be considered “objective,” each dissemination 

of research and evaluation information should: 

• “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;” 

• Present conclusions that are strongly supported by the data;” [and] 

• “Undergo peer review.” 

Id. at 6. 

Beyond objectivity, the Department has also imposed heightened requirements for information 

quality when that information is deemed “particularly influential.” See Ex. A at 9 (“Government 

information that is particularly influential needs to meet higher quality standards, and in particular 

must be reproducible.”). Per the ED Guidelines, information is “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.” Id. In the instant case, the Department has 

already determined that the NPRM constitutes an “economically significant regulatory action” under 

Executive Order 12,866.10 Thus, the information contained in the NPRM is “influential.” Pursuant 

to the ED Guidelines, then, that 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.” Ex. A at 10. 

Despite the clear standards set forth in both the ED Guidelines and the IQA, the Department’s 

NPRM is filled with examples of information that are not supported by sources, fail to explain the 

methodology used, or otherwise are not “accompanied by information that allows an external user 

to understand clearly the information and be able to reproduce it, or understand the steps involved 

in producing it.” 

3. Specific IQA Violations 

The chart below provides a specific description of information disseminated in the NPRM that 

violates the IQA, as well as the basis for each IQA violation. 

NPRM STATEMENT IQA VIOLATION 

“The Department is adding a definition. . .to 

implement its current policy with respect to 

those terms and to avoid confusion caused by 

1. Fails to clearly identify and describe 

data sources 

See 84 Fed. Reg. at 27,444. 10 
 

 

 

 

 

 

 

 

Principal Deputy Assistant Secretary Office of Management & 

Director, Information Collection Clearance Division 

U.S. Department of Education 

Page 5 of 12 

July 12, 2019 

occasional inconsistent usage among the 

Department, States, and various accrediting 

agencies.”11 

(boldface added to highlight point at issue) 

“[M]any States have adopted requirements for 

distance education and correspondence courses 

that refer to a student’s location, which may be 

more temporary than permanent residence.”12 

1. Fails to clearly identify and describe 

data sources 

2. Fails to “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” 

“Historically, postsecondary institutions have 

not sought institutional accreditation from 

multiple agencies for a number of reasons, 

including the limitations of geographic scope 

adopted by regional accrediting agencies, the 

expense and effort associated with the 

accreditation process, a dearth of institutional 

accrediting agency options that provide unique 

approaches to mission-based educational 

objectives institutions are seeking to achieve, 

and concern about how the statutory and 

regulatory restrictions in title IV on changes in 

accreditation and multiple accreditation will be 

applied.”13 

1. Fails to rely upon peer-reviewed, 

scientific evidence-based research 

2. Fails to clearly identify and describe 

data sources 

3. Fails to confirm and document the 

reliability of the data 

4. Fails to “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” 

“[I]nstitutions that close with unpaid refunds or 

outstanding liabilities for title IV, HEA funds 

are often unable to repay those liabilities, and 

the Department is subsequently unable to 

collect amounts owed.”14 

1. Fails to clearly identify and describe 

data sources 

2. Fails to confirm and document the 

reliability of the data 

3. Fails to “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” 

“Competition could allow for greater 

specialization among agencies to ensure a closer 

1. Fails to rely upon peer-reviewed, 

scientific evidence-based research 

11 84 Fed. Reg. at 27,411. 12 84 Fed. Reg. at 27,413. 13 84 Fed. Reg. at 27,414. 14 84 Fed. Reg. at 27,416. 
 

 

 

 

 

 

 

 

 

 

 

 

 

Principal Deputy Assistant Secretary Office of Management & 

Director, Information Collection Clearance Division 

U.S. Department of Education 

Page 6 of 12 

July 12, 2019 

match with the mission of the institutions or 

programs they accredit. In addition, greater 

competition (or the allowance for competition 

where there is none today) can mean more 

accountability when incumbents are being 

insufficiently responsive to the needs of 

institutions or programs and their key 

stakeholders such as students, faculty, alumni, 

or employers.”15 

2. Fails to clearly identify and describe 

data sources 

3. Fails to confirm and document the 

reliability of the data 

4. Fails to “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” 

“In some instances, the unjustified 

differentiation of agencies based on the 

geographic area in which they operate has 

created barriers to entry for certain occupations 

and has made it difficult for those who 

complete programs to continue their education 

and earn a higher-level credential.”16 

1. Fails to rely upon peer-reviewed, 

scientific evidence-based research 

2. Fails to clearly identify and describe 

data sources 

3. Fails to confirm and document the 

reliability of the data 

4. Fails to “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” 

“Disparate treatment of students based on 

which agency accredits an institution or 

program is unwarranted given that all agencies 

adhere to the same Department requirements, 

and this practice harms students and adds cost 

for students and taxpayers.”17 

1. Fails to rely upon peer-reviewed, 

scientific evidence-based research 

2. Fails to clearly identify and describe 

data sources 

3. Fails to confirm and document the 

reliability of the data 

4. Fails to “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” 

“The Department is also concerned that the 

current regulations impose a ‘widely-accepted’ 

standard that . . . has been enforced 

inconsistently in the past.”18 

1. Fails to clearly identify and describe 

data sources 

2. Fails to confirm and document the 

reliability of the data 

3. Fails to “be accompanied by supporting 

documentation that allows an external 

15 84 Fed. Reg. at 27,415. 16 Id. 17 84 Fed. Reg. at 27,418. 18 84 Fed. Reg. at 27,419. 
 

 

 

 

 

 

 

 

 

 

 

Principal Deputy Assistant Secretary Office of Management & 

Director, Information Collection Clearance Division 

U.S. Department of Education 

Page 7 of 12 

July 12, 2019 

user to understand clearly the 

information and be able to reproduce it, 

or understand the steps involved in 

producing it” 

“In certain occupations, especially vocational 

occupations, education or experience may 

qualify an individual for their role with an 

accrediting agency to carry out its functions.”19 

1. Fails to rely upon peer-reviewed, 

scientific evidence-based research 

2. Fails to clearly identify and describe 

data sources 

3. Fails to confirm and document the 

reliability of the data 

4. Fails to “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” 

“The Department does not believe an agency 

should have to choose between setting rigorous 

standards for faculty that may be appropriate, 

for example, at comprehensive or research 

institutions, and allowing other kinds of 

institutions to hire the faculty that will provide 

students with the best opportunities possible, 

including in rural locations where faculty 

with specific kinds of degrees are not 

plentiful.”20 

(boldface added to highlight point at issue) 

1. Fails to rely upon peer-reviewed, 

scientific evidence-based research 

2. Fails to clearly identify and describe 

data sources 

3. Fails to confirm and document the 

reliability of the data 

4. Fails to “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” 

“Assessment models that employ the use of 

complicated rubrics and expensive tracking and 

reporting software further add to the cost of 

accreditation.”21 

1. Fails to rely upon peer-reviewed, 

scientific evidence-based research 

2. Fails to clearly identify and describe 

data sources 

3. Fails to confirm and document the 

reliability of the data 

4. Fails to “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” 

19 84 Fed. Reg. at 27,420. 20 84 Fed. Reg. at 27,421. 21 84 Fed. Reg. at 27,422. 
 

 

 

 

 

 

 

Principal Deputy Assistant Secretary Office of Management & 

Director, Information Collection Clearance Division 

U.S. Department of Education 

Page 8 of 12 

July 12, 2019 

“[I]n many instances, dual enrollment programs 

are provided at the high school location due to 

unreasonable travel distances to a local college. 

In those instances, the high school teacher may 

have a different kind of academic credential but 

may have years of experience teaching collegelevel courses that are relevant to the dual 

enrollment opportunity.”22 

1. Fails to rely upon peer-reviewed,

scientific evidence-based research

2. Fails to clearly identify and describe

data sources

3. Fails to confirm and document the

reliability of the data

4. Fails to “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”

“Many accrediting agencies already have 

standards that include the retroactive 

application of an effective date of 

accreditation.”23 

1. Fails to clearly identify and describe

data sources

“There are also instances in which the finding 

of noncompliance is due to economic 

conditions outside of the institution’s control, 

in which case the institution may require 

additional time to adjust to the underlying 

challenge or for the economic condition to 

change.”24 

“Costs for agency review of substantive 

changes can be as high as $66,000 plus the 

expenses associated with any required site visit. 

In addition, agency boards generally meet 

infrequently, meaning that an institutions 

application may be held for several months 

before it can be reviewed and approved.”25 

1. Fails to clearly identify and describe

data sources

2. Fails to confirm and document the

reliability of the data

3. Fails to “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 undue delay, educational innovations, 

especially those that require large investments 

in state-of-the-art tools and technologies, can 

be beyond the reach of some institutions due to 

high start-up costs or the inability to commit 

reliability of the data

2. Fails to confirm and document the

1. Fails to clearly identify and describe

data sources

3. Fails to “be accompanied by supporting

documentation that allows an external

22 Id. 23 84 Fed. Reg. at 27,423. 24 84 Fed. Reg. at 27,425. 25 84 Fed. Reg. at 27,427. 

1. Fails to clearly identify and describe

data sources
 

Principal Deputy Assistant Secretary Office of Management & 

Director, Information Collection Clearance Division 

U.S. Department of Education 

Page 9 of 12 

July 12, 2019 

multiyear funds to seeing such a project 

through to full implementation.”26 

user to understand clearly the 

information and be able to reproduce it, 

or understand the steps involved in 

producing it” 

1. Fails to clearly identify and describe 

data source 

2. Fails to confirm and document the 

reliability of the data 

“As discussed during the negotiated 

rulemaking, the Department learned that some 

agencies use the terms ‘additional location’ and 

‘branch campus’ differently than the 

Department, which leads to confusion. By 

standardizing the use of these terms, there will 

be fewer instances of misunderstanding or 

conflict.”27 

“In some instances, agencies provide multiple 

letters of support and are deemed to meet the 

requirement, and in other instances, agencies 

provide multiple letters substantiating wide 

acceptance, and they have been deemed 

insufficient. The Department also fears that 

the widely accepted standard could block 

competition and prevent innovative practices 

28 since the standard favors the status quo.”

1. Fails to clearly identify and describe 

data source 

2. Fails to confirm and document the 

reliability of the data 

3. Fails to describe and document the data 

collection technique used 

“We believe the qualifications a student needs 1. Fails to clearly identify and describe 

for licensure or certification examinations may data sources 

increase as a result of demands of multiple 2. Fails to confirm and document the 

stakeholders. This would lead to more reliability of the data 

coursework required by the student and 3. Fails to “be accompanied by supporting 

possibly a higher cost of education and other documentation that allows an external 

opportunity costs.”29 user to understand clearly the 

information and be able to reproduce it, 

or understand the steps involved in 

producing it” 

“By allowing a monitoring report . . . the 1. Fails to clearly identify and describe 

Department can ensure resolution of minor data sources 

problems without requiring a full compliance 2. Fails to confirm and document the 

review, which burdens both staff and reliability of the data 

agencies.”30 3. Fails to “be accompanied by supporting 

documentation that allows an external 

(boldface added to highlight point at issue) user to understand clearly the 

information and be able to reproduce it, 

26 Id. 27 84 Fed. Reg. at 27,431. 28 84 Fed. Reg. at 27,436. 29 Id. 30 84 Fed. Reg. at 27,437. 
 

 

 

 

 

 

 

 

 

Principal Deputy Assistant Secretary Office of Management & 

Director, Information Collection Clearance Division 

U.S. Department of Education 

Page 10 of 12 

July 12, 2019 

or understand the steps involved in 

producing it” 

“The Department believes that the existing 

requirement that an institution disclose any 

placement rate that it calculates, even those 

rates that it calculates for internal purposes, is 

overly burdensome, unhelpful to students, and 

limits an institution’s ability to evaluate its own 

programs if the methods used for internal 

analysis do not meet the standard of rigor 

required for published placement rates.”31 

1. Fails to clearly identify and describe 

data sources 

2. Fails to confirm and document the 

reliability of the data 

3. Fails to “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” 

“One possible outcome of the proposed 

regulation would be to make it easier for 

students to transfer credits to continue or attain 

an additional degree at a new institution.”32 

1. Fails to clearly identify and describe 

data sources 

2. Fails to confirm and document the 

reliability of the data 

“The Department does not believe many 

students rely on the distinction between 

regional and national accrediting agencies when 

deciding between programs or institutions but 

instead base their choice on other factors such 

as location, cost, programs offerings, campus, 

and career opportunities.”33 

1. Fails to rely upon peer-reviewed, 

scientific evidence-based research 

2. Fails to clearly identify and describe 

data sources 

3. Fails to confirm and document the 

reliability of the data 

4. Fails to “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” 

“The additional flexibility under the proposed 

regulations for accrediting agencies to sanction 

programs instead of entire institutions 

potentially creates a trade-off as the students in 

programs that close are not eligible for closed 

school discharges. However, by focusing on 

problematic programs, fewer institutions may 

close precipitously, and fewer students would 

have their programs disrupted.”34 

1. Fails to rely upon peer-reviewed, 

scientific evidence-based research 

2. Fails to clearly identify and describe 

data sources 

3. Fails to confirm and document the 

reliability of the data 

4. Fails to “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” 

31 84 Fed. Reg. at 27,441. 32 84 Fed. Reg. at 27,449. 33 Id. 34 84 Fed. Reg. at 27,450. 
 

 

 

 

 

 

 

 

 

 

 

Principal Deputy Assistant Secretary Office of Management & 

Director, Information Collection Clearance Division 

U.S. Department of Education 

Page 11 of 12 

July 12, 2019 

“The Federal government would benefit from 

savings due to a reduced number of closedschool loan discharges as a result of an 

expected increase in students completing teachouts, but it could also incur annual costs to 

fund more Pell Grants and some title IV loans 

for students participating in teach-outs and 

increased volume from new programs or 

extension of existing programs, as discussed in 

the Net Budget Impacts section.”35 

1. Fails to clearly identify and describe 

data sources 

2. Fails to confirm and document the 

reliability of the data 

3. Fails to “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” 

“[A]ccrediting agency actions have rarely been 

the sole cause of institutional closure.”36 

1. Fails to rely upon peer-reviewed, 

scientific evidence-based research 

2. Fails to clearly identify and describe 

data sources 

3. Fails to confirm and document the 

reliability of the data 

4. Fails to “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” 

“5 institutions may utilize this opportunity 

[using Title IV funds for up to 120 days to 

teach-out their students after the institutions’ 

eligibility to participate in Title IV programs 

ends] annually.”37 

1. Fails to describe and document the data 

collection technique used 

2. Fails to clearly identify and describe 

data sources 

3. Fails to confirm and document the 

reliability of the data, and acknowledge 

any shortcomings or explicit errors in 

any data that is included 

4. Fails to undergo peer review 

* * * 

Given the importance and immediacy of the public comment period for an NPRM that proposes to 

make such sweeping regulatory changes, as well as the lack of quality information that the 

Department is disseminating as a part of that process, NSLDN requests that the Department 

rescind this NPRM immediately and, if the Department desires, correct and reissue it with 

information that complies with the IQA. If you would like to speak with us, or have any questions 

35 Id. 36 84 Fed. Reg. at 27,458. 37 84. Fed. Reg. at 27,464. 
 

 

Principal Deputy Assistant Secretary Office of Management & 

Director, Information Collection Clearance Division 

U.S. Department of Education 

Page 12 of 12 

July 12, 2019 

regarding this submission, please contact NSLDN’s Advocacy Manager, Senya Merchant, at 

senya@nsldn.org. 

Sincerely, 

National Student Legal Defense Network 
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 highquality research – whether or not it is funded by the Department – is synthesized, publicized, and 

disseminated widely.” 

 

 

 

1 
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 redisseminated 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/. Other individual offices 

within the Department of Education also may develop guidelines tailored to their specific needs; 

 

 

 

 

 

 

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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 –

o Represents, uses, or relies upon the information as the official position of the

Department, or in support of the official position of the Department;

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

o Directs that the information be disseminated;

• 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;

3 
 

 

 

 

• 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.

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• 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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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;

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

3. Provide an unbiased test of the question;

4. 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;

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

6. Clearly identify data sources, if applicable;

7. Confirm and document the reliability of the data, and acknowledge any shortcomings or

explicit errors in any data that is included; and

8. 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;

2. 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;

3. 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;

4. In designing the work, every effort should be made to minimize the amount of time required

for responding institutions;

6 
 

 

5. The source of research information or data should be reliable. Data should be collected with 

survey instruments that have been properly developed and tested; 

6. Response rates should be monitored during data collection. When necessary, appropriate 

steps should be taken to ensure the respondents are representative of the population; 

7. 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; 

8. 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; 

9. 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); 

10. 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; 

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

12. Reports using these data should identify the source(s) of the information, including a citation. 

Reports should also include: 

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 

13. 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; 

2. 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; 

3. 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; 

4. In designing the work, every effort should be made to minimize the amount of time required 

for study participants; 

7 
5. 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; 

6. Response rates should be monitored during data collection. When necessary, appropriate 

steps should be taken to ensure that the respondents are a representative sample; 

7. 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; 

8. 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; 

9. 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); 

10. Data should be capable of being reproduced or replicated based on information included in 

the documentation, such as: 

a) The source(s) of the information; 

b) The date the information was current; 

c) Any known limitations on the information; 

d) The reason that the information is provided; 

e) Descriptions of any statistical techniques or mathematical operations applied to 

source data; and 

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

11. 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); 

12. 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; 

13. 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; 

14. 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; 

15. 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; 

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

 

 

 

 

8 
17. 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. 

 

 

 

 

 

9 
 

 

 

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 

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• 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 Principal Deputy Assistant Secretary for the Office of 

Management at the following address: 

Principal Deputy Assistant Secretary 

Office of Management 

U.S. Department of Education 

RE: Information Quality Request 

Room 2W311, LBJ 

400 Maryland Avenue, SW 

Washington, DC 20202 

Alternatively, requesters may submit e-mail requests to the following address: 

“OMInformationQualityRequests@ed.gov.” Requesters should indicate that they are submitting 

an Information Quality Request in the subject line of the e-mail. 

Review 

The Principal Deputy Assistant Secretary (PDAS) 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 PDAS 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. 

11 
Response 

The Department will respond to all requests for correction within 60 calendar days of the PDAS’ 

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 PDAS 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 PDAS. 

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 Principal Deputy Assistant 

Secretary 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 Principal Deputy Assistant 

Secretary at the following address: 

Principal Deputy Assistant Secretary 

Office of Management 

U.S. Department of Education 

RE: Information Quality Request 

Room 2W311, LBJ 

400 Maryland Avenue, SW 

Washington, DC 20202 

Alternatively, requesters may submit an appeal by e-mail to the following address: 

“OMInformationQualityRequests@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. 

 

 

 

 

 

 

 

 

12 
 

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 Principal Deputy’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. 

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