a

GAO

United States Government Accountability Office

Report to Congressional Requesters

August 2006 INFORMATION 

QUALITY ACT

Expanded Oversight 

and Clearer Guidance 

by the Office of 

Management and 

Budget Could Improve 

Agencies’ 

Implementation of the 

Act

GAO-06-765
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

August 2006

INFORMATION QUALITY ACT 

Expanded Oversight and Clearer 

Guidance by the Office of Management 

and Budget Could Improve Agencies’ 

Implementation of the Act 

Highlights of GAO-06-765, a report to 

congressional requesters 

www.gao.gov/cgi-bin/getrpt?GAO-06-765.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Brenda S. 

Farrell at (202) 512-6806 or farrellb@gao.gov. 

The importance and widespread

use of federal information makes 

its accuracy imperative. The

Information Quality Act (IQA) 

required that the Office of

Management and Budget (OMB) 

issue guidelines to ensure the 

quality of information disseminated

by federal agencies by fiscal year

2003. GAO was asked to (1) assess 

OMB’s role in helping agencies

implement IQA; (2) identify the 

number, type, and source of IQA 

correction requests agencies 

received; and (3) examine if IQA 

has adversely affected agencies’ 

overall operations and, in 

particular, rulemaking processes.

In response, GAO interviewed OMB 

and agency officials and reviewed

agency IQA guidelines, related 

documents, and Web sites.

What GAO Recommends

To help ensure that agencies

covered by IQA meet requirements, 

GAO recommends that OMB’s 

Director take actions to (1) work

with DHS to help ensure it fulfills 

IQA requirements and set a

deadline for doing so; (2) identify 

other agencies without IQA

guidelines and work with them to

develop and implement IQA 

requirements; and (3) clarify

guidance to agencies on improving

the public’s access to online IQA 

information. OMB said it would 

continue working with DHS to 

develop departmentwide guidelines

and with other agencies to develop

their guidelines. OMB would also

work with agencies to improve the 

online dissemination of IQA 

information. 

OMB issued governmentwide guidelines that were the basis for other 

agencies’ own IQA guidelines and required agencies to post guidelines and 

other IQA information to their Web sites. It also reviewed draft guidelines

and undertook other efforts. OMB officials said that OMB primarily 

concentrated on cabinet-level and regulatory agencies, and 14 of the 15 

cabinet-level agencies have guidelines. The Department of Homeland 

Security (DHS) does not have department-level guidelines covering its 22

component agencies. Also, although the Environmental Protection Agency 

and 4 other independent agencies posted IQA guidelines and other 

information to their Web sites, 44 of 86 additional independent agencies that 

GAO examined have not posted their guidelines and may not have them in 

place. As a result, users of information from these agencies may not know 

whether agencies have guidelines or know how to request correction of 

agency information. OMB also has not clarified guidance to agencies about 

posting IQA-related information, including guidelines, to make that 

information more accessible. Of the 19 cabinet and independent agencies 

with guidelines, 4 had “information quality” links on their home pages, but 

others’ IQA information online was difficult to locate. 

From fiscal years 2003 to 2004, three agencies shifted to using IQA to 

address substantive requests—those dealing with the underlying scientific, 

environmental, or other complex information—which declined from 42 to 

38. In fiscal year 2003, the Federal Emergency Management Agency and two 

other agencies used IQA to address flood insurance rate maps, Web site 

addresses, photo captions, and other simple or administrative matters. But, 

in fiscal year 2004, these agencies changed their classification of these 

requests from being IQA requests and instead processed them using other 

correction mechanisms. As a result, the total number of all IQA requests 

dropped from over 24,000 in fiscal year 2003 to 62 in fiscal year 2004. Also, 

of the 80 substantive requests that agencies received during the 2-year

period—over 50 percent of which came from businesses, trade groups, or 

other profit-oriented organizations—almost half (39) of the initial agency

decisions of these 80 were appealed, with 8 appeals resulting in changes. 

The impact of IQA on agencies’ operations could not be determined because

neither agencies nor OMB have mechanisms to determine the costs or 

impacts of IQA on agency operations. However, GAO analysis of requests 

shows that agencies can take from a month to more than 2 years to resolve

IQA requests on substantive matters. According to agency IQA officials, IQA

duties were added into existing staff responsibilities and administering IQA 

requests has not been overly burdensome nor has it adversely affected 

agencies’ operations, although there are no supporting data. But evidence 

suggests that certain program staff or units addressing IQA requests have

seen their workloads increase without a related increase in resources. As 

for rulemaking, agencies addressed 16 correction requests related to 

rulemaking under the Administrative Procedure Act, not IQA. 
Page i GAO-06-765 Information Quality Act

Contents

Letter 1

Results in Brief 3

Background 5

OMB Took Steps to Implement IQA, but IQA Guidelines and 

Information for Many Agencies Are Not Available or Easily 

Accessible 7

From Fiscal Years 2003 to 2004, Three Agencies Reclassified 

Correction Requests to Concentrate on Substantive Matters 14

Impact of IQA on Agencies Could Not Be Determined 21

Conclusions 25

Recommendations for Executive Action 26

Agency Comments and Our Evaluation 26

Appendixes

Appendix I: Scope and Methodology 28

Appendix II: Independent Agencies Where Web Sites Were Checked for 

IQA Guidelines 32

Appendix III: Organizations That Filed IQA Correction Requests during 

Fiscal Years 2003 and 2004 35

Appendix IV: Comments from the Office of Management and Budget 38

Tables Table 1: Cabinet-Level Agencies with IQA Guidelines 11

Table 2: Distribution of Substantive IQA Requests by Category of 

Petitioner, Fiscal Years 2003 and 2004 15

Table 3: Substantive Fiscal Year 2003 and 2004 IQA Requests by 

Category of Petitioner, Distribution by Agency, and Status 

as of May 2006 16

Table 4: Status of 39 Appeals of Substantive Requests for Fiscal 

Years 2003 and 2004, as of March 31, 2006 20

Table 5: Agencies Where We Interviewed IQA Officials 28

Figure Figure 1: Time Line of Major IQA Milestones 10
Contents

Page ii GAO-06-765 Information Quality Act

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately.

Abbreviations

DHS Department of Homeland Security

DOT Department of Transportation

EPA Environmental Protection Agency

FEMA Federal Emergency Management Agency

HHS Department of Health and Human Services

IQA Information Quality Act

NARA National Archives and Records Administration

OIRA Office of Information and Regulatory Affairs

OMB Office of Management and Budget

OSHA Occupational Safety and Health Administration
Page 1 GAO-06-765 Information Quality Act

United States Government Accountability Office

Washington, D.C. 20548

A

August 23, 2006 Letr

The Honorable Henry A. Waxman

Ranking Minority Member

Committee on Government Reform

House of Representatives 

The Honorable Bart Gordon

Ranking Minority Member

Committee on Science

House of Representatives

Federal agencies publicly disseminate a wide range of information that is 

critical to government, business, and individuals. For example, the open 

and efficient exchange of scientific and technical government information, 

subject to applicable national security controls and the proprietary rights 

of others, fosters excellence in scientific research and effective use of 

federal research and development funds. Given the widespread use of 

federal information by the public and private sectors, it is important that 

this information be accurate. 

The Information Quality Act (IQA)—section 515 of the Treasury and 

General Government Appropriations Act for Fiscal Year 2001—required the 

Office of Management and Budget (OMB) to issue governmentwide 

guidelines to “ensure and maximize the quality, objectivity, utility, and 

integrity of information, including statistical information,” disseminated to 

the public.1

 In addition, it required agencies to issue their own guidelines, 

set up administrative mechanisms to allow affected parties to seek the 

correction of information they considered erroneous, and report 

periodically to OMB information about IQA complaints (requests to correct 

agency information) and how the agencies addressed them. 

In light of questions you raised about IQA information that OMB provided 

to Congress in its April 2004 report, you requested that we examine the 

1

 Consolidated Appropriations – Fiscal Year 2001, Pub. L. No. 106-554, § 515, 114 Stat. 2763A153 to 2763A-154 (2000) (44 U.S.C. § 3516 note). The law is also referred to as the Data 

Quality Act.
Page 2 GAO-06-765 Information Quality Act

implementation of IQA.2 As agreed with your offices, we (1) assessed 

OMB’s role in helping agencies to implement IQA; (2) identified the 

number, type, and source of correction requests agencies received under 

IQA for fiscal years 2003 and 2004; and (3) examined whether the 

implementation of IQA has adversely affected agencies’ overall operations 

in general and the rulemaking process in particular.3

 

To address the first objective, we reviewed documents, including IQA 

guidelines; contacted and interviewed OMB staff and officials as well as 

IQA and other knowledgeable officials from 12 cabinet-level agencies and 5 

independent agencies; and examined these agencies’ Web sites.4

 In 

addition, we reviewed the Web sites of the other cabinet agencies and 86 

other independent agencies. To address the second objective, we reviewed 

OMB and agency documents covering the 2-year period, including annual 

reports submitted to OMB by agencies that received correction requests, 

and interviewed OMB and agency officials from those agencies. To address 

the third objective, we reviewed relevant OMB and agency documents, 

including IQA guidelines and agencies’ annual reports to OMB, examined 

requests and appeals to correct agency information, studied OMB’s and 

agencies’ Web sites, and interviewed OMB and agency IQA and other 

knowledgeable officials. We determined that OMB and agency IQA data 

were sufficiently reliable for the purposes of this review and use in this 

report. Although agencies have other mechanisms to correct information, 

we evaluated only information related to the IQA correction mechanism. 

Appendix I provides additional details on our scope and methodology. We 

conducted our work in Washington, D.C., from March 2005 through July 

2006 in accordance with generally accepted government auditing 

standards.

2

 Office of Management and Budget, Office of Information and Regulatory Affairs, 

Information Quality: A Report to Congress, Fiscal Year 2003 (Washington D.C.: Apr. 30, 

2004). 

3 We use the term agencies to refer to executive branch cabinet departments and 

independent agencies covered by the Paperwork Reduction Act—the agencies also covered 

by IQA. 

4

 The cabinet-level agencies we examined are the Departments of Agriculture, Commerce, 

Defense, Energy, Health and Human Services, Homeland Security, Housing and Urban 

Development, the Interior, Justice, Labor, Transportation, and the Treasury. In addition, we 

interviewed officials at the following independent agencies: the Environmental Protection 

Agency, the Consumer Product Safety Commission, Federal Deposit Insurance Corporation, 

National Aeronautics and Space Administration, and Nuclear Regulatory Commission.
Page 3 GAO-06-765 Information Quality Act

Results in Brief As required by IQA, OMB issued guidelines for agencies, which agencies 

used as the basis for developing their own IQA guidelines. OMB also 

assisted agencies as they developed their IQA guidelines, reviewed their 

draft guidelines, and established the mechanism agencies are to use 

annually to report IQA information to OMB. OMB required agencies to post 

IQA guidelines on their Web sites. In implementing IQA, according to OMB 

officials, OMB primarily concentrated its efforts, including outreach, on the 

cabinet-level and regulatory agencies. Fourteen of 15 cabinet agencies as 

well as the Environmental Protection Agency (EPA) have IQA guidelines in 

place. 

On the other hand, the Department of Homeland Security (DHS) does not 

have departmentwide IQA guidelines, and four of its component 

agencies—including the Federal Emergency Management Agency 

(FEMA)—have IQA guidelines corresponding to their previous 

departments or guidelines that have not been updated by DHS. In addition, 

we did not find IQA guidelines, references to IQA, or other IQA information 

on about half (44) of the Web sites of 91 independent agencies we 

reviewed. Moreover, even when IQA information was posted on agencies’ 

Web sites, finding that information on those Web sites was difficult. Of the 

19 cabinet and regulatory agencies with IQA guidelines that we examined, 

only the Departments of Agriculture, Commerce, Energy, and the Interior 

provided a direct IQA “information quality” link on their home pages that 

would likely be easy for the public to find and use. Accessing IQA 

information on the Web sites of the other 15 agencies we examined was not 

easy because these agencies provided no discernable link to IQA 

information; required multiple searches using various terms related to IQA; 

or provided access to their guidelines and other information through 

“contact us,” “policies,” or other less-than-obvious links, such as 

“resources.” OMB’s guidance is not clear about how agencies should 

provide access to online IQA information. Without clear and easily 

accessible information about IQA, users of information from many of these 

agencies may not know whether agencies have guidelines or how to 

request correction of agency information.

From fiscal year 2003 to fiscal year 2004, three agencies shifted to using 

IQA almost exclusively to address substantive requests—those dealing 

with the underlying scientific, environmental, or other complex 

information—which declined from 42 to 38. In fiscal year 2003, FEMA and 

two agencies within the Departments of Labor and Transportation used 

IQA to address flood insurance rate maps, Web site addresses, photo 
Page 4 GAO-06-765 Information Quality Act

captions, and other simple or administrative matters.5 However, in fiscal 

year 2004, these agencies changed their classification of these requests 

from IQA requests and instead processed them using other correction 

mechanisms. As a result, the total number of all IQA requests dropped 

from over 24,000 in fiscal year 2003 to 62 in fiscal year 2004. Moreover, of 

the 80 substantive requests that agencies received during the 2-year period, 

over 50 percent came from businesses, trade groups, or other profitoriented organizations. Almost half (39) of the initial agency decisions of 

these 80 requests were appealed, and 8 appeals resulted in information 

changes. 

The impact of IQA on agencies’ operations could not be determined 

because agencies and OMB do not have mechanisms in place to track 

implementing IQA. Agencies and OMB do not capture IQA workloads or 

cost data, nor do they track the impact of IQA requests or resulting 

information changes. Our analysis of requests found that agencies can take 

from more than 1 month to more than 2 years and require the involvement 

of a wide variety of staff to resolve IQA correction requests, particularly if 

the requests center on substantive matters—for example, endangered 

species or public health. Agency IQA officials said that they incorporated 

IQA duties into existing staff responsibilities, and administering IQA 

correction requests has not been overly burdensome and has not adversely 

affected agencies’ operations, although they do not have data to support 

their views. However, evidence suggests that certain program staff or units 

addressing IQA requests have seen their workloads increase without a 

related increase in resources. With respect to IQA requests related to 

rulemaking, five agencies reported having received 16 such requests in 

fiscal years 2003 and 2004; they addressed 10 of the 16 through the notice 

and comment process of the Administrative Procedure Act rather than IQA, 

rejected 2, and were developing or pending responses to the remaining 

ones as of the end of March 2006. It should be recognized that IQA 

correction requests could affect rulemaking outside of the formal 

rulemaking process. For example, IQA correction requests that are filed 

before an agency’s formal rulemaking process begins could affect when or 

if an agency initiates a rulemaking. 

To help ensure that all agencies covered by the IQA fulfill their IQA 

requirements, including implementing IQA guidelines and posting 

information on how to file information correction requests, and promote 

5 The agencies or OMB designates IQA requests to be “simple or administrative.” 
Page 5 GAO-06-765 Information Quality Act

easier public access to IQA information on agency Web sites, we 

recommend that the Director of OMB (1) work with DHS to help ensure it 

fulfills IQA requirements and set a deadline for doing so, (2) identify other 

agencies that do not have IQA guidelines and work with them to develop 

and implement such guidelines, and (3) clarify guidance to agencies on 

improving the public’s access to online IQA information. 

In written comments on a draft of this report, the Acting Administrator of 

OMB's Office of Information and Regulatory Affairs (OIRA) stated that 

OMB fully supports our recommendation that DHS develop IQA guidelines 

and that OMB would continue to work with DHS to that end. The Acting 

Administrator also stated that OMB would continue working with other 

agencies as they develop and implement information quality measures. He 

added that OMB shares GAO's interest in improving public access to IQA 

information on agencies' Web sites and would continue to work with 

agencies to improve their dissemination of IQA information in a manner 

consistent with OMB policies. OIRA provided separate technical 

corrections and suggestions to this draft, which we have incorporated as 

appropriate. The written comments are reprinted in appendix IV. 

Background IQA consists of two major elements. The first element of IQA required 

OMB by the end of fiscal year 2001 to develop and issue guidelines that 

provide policy and procedure guidance for federal agencies to use for 

“ensuring and maximizing quality, objectivity, utility, and integrity of 

information, including statistical information,” that they disseminate. The 

second element required federal agencies covered by the Paperwork 

Reduction Act to develop IQA guidelines by the end of fiscal year 2002, 

establish administrative mechanisms allowing “affected persons” to seek 

and obtain correction of information maintained and disseminated by the 

agencies, as well as periodically report to the Director of OMB about the 

number and nature of IQA complaints and how they handled such 

complaints.6

 

6

 Agencies subject to the Paperwork Reduction Act are executive departments; military 

departments; independent regulatory agencies; government corporations; governmentcontrolled corporations; or other establishments in the executive branch, including the 

Executive Office of the President. It specifically excludes the Federal Election Commission; 

GAO; and federal government-owned contractor-operated facilities, including laboratories 

engaged in national defense research and production activities, as well as District of 

Columbia and territorial governments. 44 U.S.C. § 3502(1).
Page 6 GAO-06-765 Information Quality Act

IQA builds on previous federal efforts to improve the quality of 

information, including OMB Circular A-130 and the Paperwork Reduction 

Act of 1980, as amended. For example, two of the purposes of the 

Paperwork Reduction Act were to “improve quality and use of federal 

information ... and provide for the dissemination of public information ... 

in a manner that promotes the utility of the information to the public and 

makes effective use of information technology.” IQA requires, among other 

things, that executive branch agencies manage their information resources 

to “improve the integrity, quality, and utility of information to all users 

within and outside an agency.”7, 8

 

OIRA, which develops and oversees the implementation of 

governmentwide policies in the areas of information technology, privacy, 

and statistics, had responsibility for developing the governmentwide IQA 

guidelines and helping agencies to meet the act’s requirement that they 

develop their own guidelines. In an October 2002 memorandum describing 

the implementation of IQA guidelines, OIRA’s then administrator stated he 

considered the IQA guidelines a continuation of the executive branch’s 

decades-long focus on improving the quality of information federal 

agencies collect and disseminate. The memorandum added that agencies’ 

implementation “of the Information Quality Law represented the first time 

that the executive branch has developed a governmentwide set of 

information quality guidelines, including agency-specific guidelines 

tailored to each agency’s unique programs and information.” Agencies’ 

guidelines, which were to follow OMB’s model, were to include 

administrative mechanisms that allow “affected parties”—as defined by the 

agencies—to request correction of information that they did not consider 

correct. 

7

 44 U.S.C. § 3506(b)(1)(C).

8

 No hearings or debates were held or committee reports filed before IQA was enacted as 

part of the Treasury and General Government Appropriations Act for Fiscal Year 2001. 
Page 7 GAO-06-765 Information Quality Act

OMB Took Steps to 

Implement IQA, but 

IQA Guidelines and 

Information for Many 

Agencies Are Not 

Available or Easily 

Accessible 

OMB set up a framework for federal agencies to follow in implementing 

IQA, including providing assistance and direction to agencies in developing 

agency IQA guidelines and requiring them to post IQA information on their 

Web sites. However, we were not able to locate any IQA information on 

about half of the independent agencies’ Web sites that we examined, nor 

could we find Federal Register notices about IQA guidelines for them. 

According to OMB officials and OIRA’s then administrator, OIRA 

concentrated its communication and other outreach efforts on cabinetlevel and regulatory agencies. In written comments on a draft of our 

report, OIRA noted that in working with agencies to develop and 

implement information quality measures, it will consider the needed 

resources for and the potential benefits of such measures. Further, in a 

number of cases where IQA information was posted online, locating the 

information was difficult. Agency IQA officials with whom we met noted 

that their IQA correction mechanism is a formal process and one of a 

number of correction mechanisms available to the public for having 

information errors corrected. 

OMB’s OIRA Set Up 

Framework for IQA 

Implementation 

OMB set up a framework for agencies to follow in implementing IQA and 

provided assistance and direction to agencies in developing their 

guidelines. As required by IQA, OMB issued the basic set of 

governmentwide IQA guidelines that agencies used as the basis for 

developing their own guidelines. These guidelines explained what agencies 

were to do to help ensure the development and public dissemination of 

quality information. In developing these guidelines, OIRA espoused three 

underlying principles that agencies were to reflect in their guidelines:

• The guidelines are to apply to a wide variety of government information 

dissemination activities that may vary in importance and scope. 

• Agencies are to meet basic information quality standards, noting that the 

more important the information, “the higher the quality standards to 

which it should be held,” but that “agencies should weigh the costs ... 

and the benefits of higher information quality in the development of 

information.”

• Agencies are to apply the guidelines in “a common-sense and workable 

manner,” meaning that agency guidelines are not to “impose 

unnecessary administrative burdens that would inhibit the agencies 

from continuing to take advantage of the Internet and other 
Page 8 GAO-06-765 Information Quality Act

technologies to disseminate information that can be of great benefit and 

value to the public.” 

The guidelines, in elaborating on this last principle, explained that “OMB 

encourages agencies to incorporate the standards and procedures required 

by these guidelines into their existing ... administrative practices rather 

than create new and potentially duplicative or contradictory processes.” 

The guidelines also noted that they were written to provide agencies with 

flexibility as they developed their own guidelines. 

Moreover, the guidelines defined four key concepts related to the 

dissemination of information—quality, objectivity, utility, and integrity—

and described how quality was the outcome of the other three components. 

These guidelines further explained that agencies were to mirror these 

principles and actions in establishing their own guidelines and to include 

an administrative mechanism that data users who find mistakes in any 

agency’s public data or information can use to petition for correction. This 

mechanism was to include an appeals process, which allows a petitioner to 

request that an agency reconsider its initial decision about the correction 

request. The guidelines’ wording about the administrative correction 

mechanism allowed agencies to avoid duplicating the public comment 

process required by the rulemaking procedures under the Administrative 

Procedure Act, in which interested persons are given the opportunity to 

comment on proposed rules. 

In addition to writing the governmentwide IQA guidelines, OIRA took other 

steps to help agencies implement the principles and standards of IQA. As 

part of helping agencies to develop their guidelines, OIRA offered them 

assistance, including outreach to agencies such as conducting workshops 

on drafting guidelines, and reviewed their guidelines. IQA officials from a 

number of agencies, including the Departments of Defense and Justice, told 

us they considered this assistance beneficial. OIRA officials also issued 

memorandums to clarify how agencies were to satisfy the law and 

otherwise implement IQA, including requiring agencies to post IQA 

guidelines and related information on their Web sites.9

 Further, OIRA put 

in place the mechanism for agencies to provide OMB with their annual IQA 

reports on their implementation of IQA, the number of IQA requests and 

9 These memorandums are accessible by selecting the Information Policy, E-gov & IT option 

under Information and Regulatory Affairs on OMB’s Web site at 

http://www.whitehouse.gov/omb/. 
Page 9 GAO-06-765 Information Quality Act

appeals, and their status. According to OIRA staff and officials and agency 

memorandums, OIRA monitored IQA correction requests received by 

agencies and assisted them in developing their responses. Agency officials 

told us that OMB’s revisions consisted of comments that ranged from 

editorial to significant and primarily involved IQA requests pertaining to 

substantive issues. For example, agency officials and OMB staff explained 

that OMB at times asked for more detailed explanations, including 

references to other relevant information, in agency responses to correction 

requests. According to these officials, OMB’s review did not cause changes 

that would have substantially changed the agencies’ ultimate decision. We 

found no indication that OMB’s involvement substantially changed 

agencies responses when we examined nine specific IQA requests from 

four agencies.

As described in figure 1, agencies covered by IQA were to have their 

guidelines and the correction and appeals mechanism in place by the start 

of fiscal year 2003 (October 1, 2002). The figure also shows that in April 

2004, OMB reported to Congress in response to a mandate that OMB report 

on the first year—fiscal year 2003—of the implementation of the act. That 

report included information about the characteristics of the correction 

requests as well as the sources of the requests, and commented on a 

number of common perceptions and concerns about the act. OMB, of its 

own volition, in December 2005, updated this information and included it in 

a chapter in its report to Congress on the costs and benefits of federal 

regulations.10 In this report, OMB provided information on the 

implementation of IQA in fiscal year 2004 and compared fiscal years 2003 

and 2004 IQA information. 

10 Office of Management and Budget, Office of Information and Regulatory Affairs,

Validating Regulatory Analysis: 2005 Report to Congress on the Costs and Benefits of 

Federal Regulations and Unfunded Mandates on State, Local, and Tribal Entities

(Washington, D.C.: December 2005).
Page 10 GAO-06-765 Information Quality Act

Figure 1: Time Line of Major IQA Milestones

Note: This time line excludes requirements and time frames related to peer review, which OMB was 

developing and implementing at the time of our review.

a

The original deadline was July 1, 2002, but OMB extended it.

OIRA Focused Its Efforts on 

Cabinet-Level and 

Regulatory Agencies

According to OMB and OIRA staff and officials and OIRA’s then 

administrator, OIRA concentrated its efforts to implement IQA on cabinetlevel and regulatory agencies. In addition to working with the cabinet 

agencies to create IQA guidelines, OIRA staff stated they also focused their 

attention on regulatory agencies and commissions, including EPA. OIRA 

did not clarify for many independent agencies—especially smaller, 

nonregulatory ones—whether the law applied to them or generally follow 

up with them to help them meet the act’s provisions. By the fiscal year 2002 

deadline, 14 of the 15 cabinet-level agencies had guidelines in place (see 

Dec. 21, 2000: 

IQA enacted as

Section 515 of 

Treasury and 

General Appropriations Act for Fiscal 

Year 2001

Sept. 28, 2001: 

OMB issued for 

public comment 

governmentwide 

IQA guidelines for 

federal agencies

May 1, 2002: 

Federal agencies

were to put notice 

in Federal Register

seeking public 

comment on draft 

IQA guidelines

Feb. 22, 2002: OMB 

issued final revised 

governmentwide 

IQA guidelines for 

federal agencies

Aug. 1, 2002a: 

Federal agencies

were to provide draft 

IQA guidelines to 

OMB, including 

public comments

Oct. 1, 2002: Federal 

agencies were to 

publish notice in 

Federal Register that 

their IQA guidelines, 

including administrative correction 

mechanism, are 

available on Internet

Apr. 30, 2004: OMB 

provided Congress

report on fiscal year 

2003 IQA 

implementation 

Dec. 2005: 

OMB included 

evaluation of 

implementation of IQA 

in fiscal years 2003 

and 2004 in report to 

Congress on costs and 

benefits of regulations

Jan. 1, 2004: 

Federal agencies

were to provide first 

annual IQA report to 

OMB

Source: GAO analysis of OMB information.

2000 2001 2002 2003 2004 2005
Page 11 GAO-06-765 Information Quality Act

table 1).11 Further, following the flurry of activities to help agencies 

develop their IQA guidelines by October 1, 2002, OIRA shifted its emphasis 

away from helping agencies develop their IQA guidelines to helping 

agencies that already had guidelines to address IQA correction requests. 

According to OIRA staff, since November 2002 OIRA has not promulgated 

additional guidance regarding the development of IQA guidelines to 

agencies. 

Table 1: Cabinet-Level Agencies with IQA Guidelines

Source: GAO analysis of agency and OMB information.

Only one cabinet-level agency, DHS, the newest and one of the largest 

federal agencies, has no department-level IQA guidelines covering its 22 

agencies, which issue a wide array of information used by the public. 

Because DHS was not created until January 2003—after IQA was enacted 

and IQA deadlines had passed—OMB began working with DHS officials to 

develop department-level guidelines after the other cabinet-level and 

independent agencies had their guidelines in place, according to OMB’s 

April 2004 report to Congress.12 As of March 2006, however, DHS did not 

have its IQA guidelines in place and officials did not have a deadline for 

establishing them. Also, while 5 DHS component agencies had IQA 

guidelines before they became part of DHS,13 the guidelines of 4 of the 5 

11 OMB granted an extension to the Department of Defense (DOD) for implementing its 

guidelines because of the war in Iraq. DOD implemented its guidelines in February 2003.

Agencies 

Department of Agriculture

Department of Commerce

Department of Defense

Department of Education

Department of Energy

Department of Health and Human 

Services

Department of Housing and Urban

Development

Department of the Interior

Department of Justice

Department of Labor

Department of State

Department of Transportation

Department of the Treasury

Department of Veterans Affairs

12 Office of Management and Budget, Information Quality: A Report to Congress, Fiscal 

Year 2003.

13 These are the Coast Guard, Customs and Border Protection (previously Customs Service), 

FEMA, Federal Law Enforcement Training Center, and Secret Service. 
Page 12 GAO-06-765 Information Quality Act

component agencies—the Coast Guard, Customs and Border Protection, 

FEMA, and Secret Service—are still linked to their previous parent 

departments or otherwise have not been updated by DHS. For example, 

the IQA guidelines for the Coast Guard, which was previously part of the 

Department of Transportation (DOT), instructed information users 

submitting IQA requests to file via DOT’s Docket Management System, the 

administrative mechanism that DOT directs the public to use to file 

correction requests. Additionally, FEMA has not updated its guidelines 

since becoming part of DHS. DHS officials told us that the component 

agencies may update their guidelines after DHS has its departmentwide 

guidelines in place. Until that occurs, it is unclear what appeals process the 

public would follow and how DHS agencies will make final decisions about 

IQA correction requests. 

Moreover, when we checked the Web sites of 91 independent agencies, we 

did not find IQA guidelines posted on the Web sites of 44 of those agencies. 

(See app. II for the list of independent agencies and the status of their 

guidelines at the end of May 2006.) These 44 commissions, agencies, and 

other independent entities gave no indication of any IQA guidelines or IQA 

reports, nor any mention of IQA on their Web sites or on OMB’s Web site of 

agencies’ IQA guidelines. We also could not find these agencies’ Federal 

Register notices announcing the establishment of their IQA guidelines, 

although OMB required these notices. Also, OIRA staff did not have copies 

of the guidelines and said that they had focused their attention on cabinet 

agencies and regulatory agencies. These 44 agencies represented a broad 

spectrum of entities—including fact-finding agencies, such as the U.S. Civil 

Rights Commission; research organizations, such as the Smithsonian 

Institution; and others, such as the U.S. Trade and Development Agency—

that produce a wide range of publicly disseminated information. In 

commenting on this report, the acting OIRA administrator noted that OIRA 

will take into account the resources that would be needed and the potential 

benefits that would be realized in working with agencies “to develop and 

implement information quality measures.” 

Accessing Agencies’ Web 

Site IQA Information Is 

Difficult

Even when agencies posted IQA information on their Web sites as OMB 

required, such information was hard to access, making it difficult for 

information users to know whether agencies have IQA guidelines or how to 

request correction of agency information. As part of the governmentwide 

IQA guidelines, OIRA required agencies to post their draft agency-specific 

IQA guidelines online by September 30, 2002, and to inform the public 

about them and solicit comments. However, we found it difficult to locate 
Page 13 GAO-06-765 Information Quality Act

IQA information on agency Web sites. In addition to the difficulties of 

trying to find whether the independent agencies’ Web sites contained IQA 

guidelines, we had problems finding IQA guidelines on the Web sites of the 

14 cabinet-level and 5 independent agencies that we knew had those 

guidelines. Of these 19 cabinet-level and independent agencies with IQA 

guidelines that we reviewed, only 4 agencies—the Departments of 

Agriculture, Commerce, Energy, and the Interior—provided a direct IQA 

“information quality” link on their home pages, which likely would be 

relatively easy for the public to use to access IQA information. In the case 

of the 15 other agencies, we found that accessing IQA information on their 

Web sites was difficult because these agencies provided no discernable link 

to IQA information on their home pages; provided access to their 

guidelines and other information through “contact us,” “policies,” or other 

less-than-obvious links, such as “resources”; or required multiple searches 

using various terms related to IQA, as was the case with the Department of 

Defense and the Department of State. Although OIRA directed agencies to 

post IQA information online, OIRA’s guidance is not specific about how 

agencies should provide access to online IQA information. Moreover, 

agency IQA officials told us that OMB did not provide guidance about 

where to place IQA information on their Web sites or what kind of access—

or transparency—to provide. Agency IQA officials from a number of 

agencies stated that access to their Web-based IQA information was not 

“user-friendly” and said they were working to make IQA information more 

transparent and easily accessible.

OMB is aware of the need to improve the public’s access to IQA 

information. In its April 2004 report to Congress, OIRA acknowledged the 

need for agencies to improve the transparency of IQA information and 

recommended that agencies include on their public Web sites IQA 

correction requests, appeals, and agency responses to them, as well as the 

agencies’ annual IQA reports to OMB.14 OMB and OIRA subsequently 

issued additional directives to facilitate the public’s ability to access 

government information and the process to request correction of 

erroneous public information. For example, in August 2004, responding to 

“inconsistent practices regarding the public availability of correspondence 

regarding information quality requests,” OIRA’s administrator issued a 

memorandum instructing each agency to post its IQA documents online by 

December 1, 2004. 

14 Office of Management and Budget, Information Quality: A Report to Congress, Fiscal 

Year 2003.
Page 14 GAO-06-765 Information Quality Act

From Fiscal Years 2003 

to 2004, Three 

Agencies Reclassified 

Correction Requests to 

Concentrate on 

Substantive Matters 

From fiscal year 2003 to fiscal year 2004, three agencies shifted to using 

IQA to address primarily substantive requests—those dealing with the 

underlying scientific, environmental, or other complex information—which 

declined from 42 to 38. The total number of all IQA requests dropped from 

over 24,000 in fiscal year 2003 to 62 in fiscal year 2004. The overwhelming 

cause for this decline was that in fiscal year 2004 FEMA no longer classified 

requests to correct flood insurance rate maps as IQA requests or addressed 

them through IQA. The decline in the number of IQA requests does not 

indicate that there was a corresponding decrease in agency workloads. 

In fiscal year 2003, agencies reported having received over 24,600 IQA 

correction requests, with FEMA’s 24,433 requests accounting for over 99 

percent of the year’s total. FEMA’s requests were all related to flood 

insurance rate maps. Eighteen other agencies accounted for the balance of 

the year’s requests (183), 54 of which resulted in changes in information, 

including clarifying language. In fiscal year 2004, FEMA, with OMB’s 

approval, no longer classified flood insurance rate map correction as IQA 

requests. Instead, FEMA addressed flood insurance rate map correction 

requests by using a correction process it had implemented prior to the 

enactment of IQA. Largely as a result of this change and a similar change 

by two other agencies—the Department of Labor’s Occupational Safety and 

Health Administration (OSHA) and DOT’s Federal Motor Carrier Safety 

Administration—in fiscal year 2004, 15 agencies reported a total of 62 IQA 

correction requests to OMB. Of these, 26 requests resulted in changes.

As shown in table 2, from fiscal year 2003 to fiscal year 2004, the number of 

substantive requests declined in terms of their total numbers, decreasing 

from 42 in fiscal year 2003 to 38 in fiscal year 2004. 
Page 15 GAO-06-765 Information Quality Act

Table 2: Distribution of Substantive IQA Requests by Category of Petitioner, Fiscal 

Years 2003 and 2004

Source: GAO analysis of agency and OMB data.

As shown in table 2, during fiscal years 2003 and 2004, over half of the 

substantive IQA correction requests originated from businesses, trade 

groups, or other profit-oriented organizations, and over one-quarter were 

generated by nonprofit or other advocacy organizations. (For a list of these 

requesters, see app. III.) Substantive requests generated by individual 

citizens declined from about 1 in 7 of substantive requests to about 1 in 10. 

Substantive requests in fiscal year 2004 represented a greater proportion of 

IQA correction requests than in fiscal year 2003, excluding FEMA flood 

insurance rate map correction requests. Out of 183 non-FEMA requests in 

fiscal year 2003, 42—or almost one-fourth—were substantive in nature. 

Addressing these substantive requests required considerably more time 

and staff resources than simple or administrative requests. OMB and 

agency officials considered the other 141 requests—over three-fourths—to 

be of a simple or administrative nature—for example, requests to correct 

errors in photo captions, personal information, or Internet addresses.15

Agencies were able to quickly correct these simple or administrative 

requests—correcting 17 requests took 7 or fewer days from the date the 

agencies received them. In fiscal year 2004, of 62 total IQA requests, 38 

requests—almost two-thirds—were considered to be substantive. Table 3 

shows the 80 substantive requests for fiscal years 2003 and 2004 by 

category of petitioner, agency, and status of requests, as of May 2006.

Requests in fiscal 

year 2003

Requests in fiscal 

year 2004

Source of request Number Percentage Number Percentage

Business, trade group, or other profitoriented organization 22 52.4 22 57.9

Nonprofit or other advocacy organization 12 28.6 10 26.3

Private citizen 6 14.3 4 10.5

Government 2 4.8 2 5.3

Total 42 100 38 100

15 OMB and agency officials sometimes differed in whether they considered requests to be 

minor or significant; therefore, our analysis of the number of requests by type of request 

differed from OMB’s.
Page 16 GAO-06-765 Information Quality Act

Table 3: Substantive Fiscal Year 2003 and 2004 IQA Requests by Category of Petitioner, Distribution by Agency, and Status as of 

May 2006 

Sources of requests

Agency

Business/trade

organization

Nonprofit/

advocacy

organization Citizen Government

Fiscal year

2003 Total

Department of Agriculturec

 2 21 0 5

Department of Commercec 1 10 0 2

Department of Defense 0 1 0 0 1

Department of Education 0 1 0 0 1

Department of Energy 0 0 0 0 0

Department of Health and Human Servicesc 8 02 0 10

Department of Housing and Urban Development 0 0 0 0 0

Department of Homeland Security 0 0 0 0 0

Department of the Interiorc 4 10 1 6

Department of Justice 0 1 0 0 1

Department of Labor 1 0 0 0 1

Department of State 0 0 0 0 0

Department of Transportation 1 0 1 0 2

Department of the Treasury 0 0 0 0 0

Department of Veterans Affairs 0 0 0 0 0

Access Board 0 0 0 0 0

Consumer Product Safety Commission 2 1 0 0 3

Commodities Futures Trading Commission 0 0 0 0 0

Environmental Protection Agency 3 3 1 1 8

Federal Communications Commission 0 0 0 0 0

Federal Deposit Insurance Corporation 0 0 0 0 0

National Archives and Records Administration 0 0 0 0 0

National Aeronautics and Space Administration 0 0 1 0 1

Office of Science and Technology Policyc

/

Executive Office of the President 

0 10 0 1

Total 22 12 6 2 42
Page 17 GAO-06-765 Information Quality Act

Source: GAO analysis of agency information.

a

Includes three requests, each of which was filed with two agencies and are therefore counted twice.

b

“Change” means either full or partial correction of information.

c

Includes requests filed with another agency. App. III identifies these requests.

Sources of requests Outcome of fiscal year 2003 and 2004 requests

Business/trade

organization

Nonprofit/

advocacy

organization Citizen Government

Fiscal year

2004 Total

2-year

Totala

No

change

madea

Change

from initial

requestb

Change

from

appealb

Outcome

pending

0 10 0 1 6 5 00 1

2 00 0 2 4 4 00 0

0 11 0 2 3 0 00 3

0 00 0 0 1 1 00 0

0 00 0 0 0 0 00 0

6 21 0 9 19 9 62 2

0 00 0 0 0 0 00 0

0 00 0 0 0 0 00 0

3 11 1 6 12 9 01 2

0 00 1 1 2 1 10 0

0 00 0 0 1 0 01 0

0 00 0 0 0 0 00 0

0 01 0 1 3 1 01 1

1 00 0 1 1 1 00 0

0 00 0 0 0 0 00 0

0 00 0 0 0 0 00 0

1 10 0 2 5 3 11 0

0 00 0 0 0 0 00 0

9 3 0 0 12 20 11 7 1 1

0 10 0 1 1 1 00 0

0 00 0 0 0 0 00 0

0 00 0 0 0 0 00 0

0 00 0 0 1 1 00 0

0 00 0 0 1 1 00 0

22 10 4 2 38 80 48 15 7 10
Page 18 GAO-06-765 Information Quality Act

One reason that substantive requests in fiscal year 2004 represented an 

increased percentage of total IQA correction requests compared with fiscal 

year 2003 is that in fiscal year 2004 some agencies decided to exclude 

simple or administrative errors from IQA correction mechanisms. 

Specifically, according to agency IQA documents and OMB’s December 

2005 report, in fiscal 2004, FEMA, the Department of Justice, the Federal 

Motor Carrier Safety Administration, and OSHA no longer classified and 

addressed most simple or administrative types of errors as IQA correction 

requests. As a result, the majority of the correction requests that remained 

to be processed through IQA were substantive requests.16 For example, in 

fiscal year 2004, the Department of Health and Human Services’ (HHS) 

National Institutes of Health received a request related to information 

about smokeless tobacco; EPA received a request challenging information 

related to the water conservation benefits of water utility billing systems of 

multifamily housing; and the Department of the Interior’s Fish and Wildlife 

Service received a request that challenged information used to protect the 

Florida panther. 

We also found that no one agency dominated or accounted for the majority 

of fiscal year 2004 requests. In fact, in fiscal year 2004 the distribution of 

requests was more broadly spread across agencies than in fiscal year 2003, 

with EPA and the National Archives and Records Administration (NARA) 

each reporting 12 correction requests, and HHS reporting 9 requests to 

OMB. 

A few agencies did not experience a decrease in the total number of IQA 

requests because they did not shift simple requests away from IQA or 

otherwise change how they processed such requests during the 2-year 

period. For example, according to OMB and NARA IQA documents, 

NARA’s IQA requests—8 in fiscal 2003 and 12 in fiscal 2004—continued to 

be simple in nature and came primarily from individuals in both years. For 

the same 2 years, EPA’s 25 requests and HHS’s 19 requests were nearly all 

substantive and mainly came from businesses or profit-oriented 

organizations as well as nonprofits or advocacy groups.

16 According to the report, the Departments of Labor, Justice, and Transportation as well 

FEMA decided “to not treat simple correction requests not generated by the Act as 

correction requests in their FY04 annual report to OMB.” Despite this statement, the 

Department of Justice’s annual report describes five requests, including four that could be 

considered simple in nature. 
Page 19 GAO-06-765 Information Quality Act

Agencies Changed Simple 

Requests More Often Than 

Substantive Requests or 

Appeals during 2 Years

In fiscal years 2003 and 2004, the simpler and more administrative the 

initial request, the more likely an agency was to correct the information 

without appeal. For example, during the 2-year period, NARA corrected or 

clarified information for 16 of the 20 IQA correction requests it received, 

which were all considered to be simple in nature. Conversely, the more 

significant the correction request, the lower the likelihood of a change. 

HHS, for example, addressed 19 IQA requests that were substantive but 

changed information for only 5 based on the initial request or an appeal. 

Regardless of the complexity of the request, agency IQA documents 

showed that agencies addressed all requests filed during the 2-year period.

Substantial requests were less likely to result in an initial information 

change but more likely to be appealed than simple or administrative 

requests. Few petitioners appealed agency decisions regarding simple or 

administrative requests. None of 131 “simple or administrative” fiscal year 

2003 IQA requests from the Departments of Transportation, Labor, and the 

Treasury and NARA was appealed. By comparison, of the 80 substantive 

requests over the 2-year period, petitioners appealed 39 (almost half) of the 

agencies’ decisions. Of the 39 requests that were appealed, 25 were denied 

and 8 appeals resulted in information changes. 

Table 4 shows the outcome or status of the appeals filed during fiscal years 

2003 and 2004, as of the end of March 2006.17 Two of the 39 appeals still 

have outcomes pending after more than 2 years, demonstrating that 

although the number of appeals may be considered small, the impact on 

agency operations may be significant, depending on the complexity of the 

specific issue. For example, in table 4, the EPA appeal pending—filed by 

the U.S. Chamber of Commerce in April 2005—affects 16 EPA databases 

that deal with such issues as wastewater treatment and the 

bioaccumulation of organic chemicals. This case has been ongoing for 

over 2 years, and could have effects on assessments regarding human 

health risks, other environmental impacts, and cleanup decisions. Also 

listed in table 3 is another IQA appeal filed in October 2003 by a private 

individual. The initial request for correction was filed in January 2003 

before the DOT’s Federal Aviation Administration (FAA) challenging the 

analytical basis for its “age 60 rule” that forces air carrier pilots out of 

service at age 60. FAA upheld its “age 60 rule” in September 2003, but the 

17 Our analysis differed from OMB’s analysis in its December 2005 report because OMB 

provided a status of appeals at the end of fiscal year 2004, whereas our analysis was based 

on the final outcome, which in some cases occurred after fiscal year 2004. 
Page 20 GAO-06-765 Information Quality Act

complainant filed an appeal in October 2003 and filed additional 

amendments thereafter. The request was still pending at the time we 

completed our study, more than 3-1⁄2 years after the initial IQA request was 

made and almost 3 years after the appeal. 

Table 4: Status of 39 Appeals of Substantive Requests for Fiscal Years 2003 and 

2004, as of March 31, 2006

Source: GAO analysis of agency and OMB information.

a

“Changes” means either full or partial correction of information. 

Agency

Total 

appeals

No changes 

from 

appeals

Changes 

from 

appealsa

Appeal 

withdrawn

Outcome 

pending

Department of 

Agriculture 3 3 0 0 0

Department of 

Commerce 3 2 0 1 0

Department of 

Education 1 1 0 0 0

Department of 

Health and Human 

Services 12 9 2 1 0

Department of the 

Interior 4 3 1 0 0

Department of 

Justice 1 0 0 1 0

Department of 

Labor 1 0 1 0 0

Department of 

Transportation 2 0 1 0 1

Department of 

Veterans Affairs 1 0 1 0 0

Consumer Product 

Safety Commission 1 0 1 0 0

Environmental 

Protection Agency 9 6 1 1 1

Office of Science 

and Technology 

Policy/Executive 

Office of the 

President 1 1 0 0 0

Total 39 25 8 4 2
Page 21 GAO-06-765 Information Quality Act

As for the source of appeals, businesses, trade groups, and other profitoriented organizations filed more appeals than other types of organizations 

or individuals. Businesses and profit-oriented organizations accounted for 

25 of the 39 appeals of IQA requests filed during fiscal years 2003 and 2004. 

Of these 25 appeals, 4 resulted in changes. Appeals from 

advocacy/nonprofit groups resulted in 1 change from 5 appeals. Appeals 

from private citizens resulted in 3 changes from 7 appeals. The most 

appeals—25, or almost two-thirds of them—were filed with EPA, HHS, and 

the Department of the Interior. Those agencies also received nearly twothirds of the requests that were classified as substantive. 

Impact of IQA on 

Agencies Could Not Be 

Determined

The impact of IQA on agencies could not be determined because agencies 

and OMB do not have mechanisms in place to track the effects of 

implementing IQA. Agencies and OMB do not capture IQA workloads or 

cost data, nor do they track the impact of IQA requests or resulting 

information changes. However, evidence indicates that in at least some 

cases, addressing IQA requests and appeals can take agencies 2 years or 

longer to resolve and requires a wide range of staff, particularly if IQA 

correction requests center on substantive matters. 

More specifically, none of the agencies we visited had information about 

the actual workload, the number of staff days, or other costs, with one 

exception.18 Agency IQA officials told us they do not collect such data. 

They explained that their agencies did not capture specific workload or 

cost data related to establishing IQA guidelines, nor do they track workload 

or cost data involved in responding to IQA requests or have mechanisms to 

measure any impact IQA information changes have on operations or the 

quality of information. Officials at two agencies—the National Aeronautics 

and Space Administration and the Department of the Interior’s Fish and 

Wildlife Service—considered developing systems to track IQA costs but did 

not. Fish and Wildlife Service officials told us they decided against 

implementing an IQA cost tracking system because of the declining number 

of requests they have received since fiscal years 2003 and 2004 and the high 

cost and administrative complexities of setting up such a system. 

Additionally, IQA officials told us that addressing IQA requests is 

considered to be part of their agencies’ day-to-day business, and because of 

the multifaceted nature of some requests, allocating time and resources to 

18 The Department of Labor had information for one IQA-related cost—a contract for 

$170,000 to set up a system to track the status of IQA requests.
Page 22 GAO-06-765 Information Quality Act

one specific issue or linking work exclusively to IQA requests would be 

difficult. For example, Fish and Wildlife Service officials stated that when 

agency biologists work on IQA requests, they are also frequently working 

on broad biological, environmental, and related issues that go beyond a 

given request and relate to other agency work, so it would be difficult to 

allocate the biologists’ time among various codes. In their view, selecting a 

specific code would be somewhat arbitrary, and time or other codes would 

not necessarily accurately reflect the cross-cutting nature of the biologists’ 

work. Moreover, according to agency officials and OMB staff, neither the 

agencies nor OMB have mechanisms in place to track the effects of 

implementing the law. 

Agency IQA officials and OIRA staff and officials told us that administering 

IQA has not been overly burdensome and that it has not adversely affected 

agencies’ overall operations to date. Agencies IQA officials told us they 

gave IQA responsibilities to various staff within their agencies—generally 

in offices already responsible for information-related issues—and that no 

staff are dedicated exclusively to administering IQA. For example, most 

agencies have folded responsibilities for IQA, including setting up 

guidelines, into the office of the chief information officer or their public 

affairs unit. In addition, although they track the status of IQA correction 

requests, they do not track changes resulting from IQA requests or appeals. 

Although there is a lack of comprehensive IQA-related cost or resource 

data, evidence suggests that certain program staff or units involved in 

creating IQA guidelines, including the correction mechanism, and 

addressing IQA correction requests have seen their workloads increase 

without any corresponding increase in resources. For example, officials at 

the Fish and Wildlife Service, HHS’s National Institutes of Health, the 

Department of Commerce’s National Oceanic and Atmospheric 

Administration, and the Department of Defense’s Army Corps of Engineers 

estimate the costs of addressing IQA requests are “many thousands of 

dollars” because of the number of high salary professional staff, such as 

biologists, toxicologists, engineers, and managers, who review and respond 

to substantive requests and appeals and the extensive time involved. 

According to agency IQA officials and OMB staff, agencies did not receive 

funds for IQA, and the act did not specify any funds for implementing IQA. 

Moreover, our analysis of IQA requests shows that agencies have taken 

from 1 month to more than 1 year to produce a final decision on 

substantive IQA requests and appeals, while 2 appeals made during fiscal 

years 2003 and 2004 are still ongoing after 2 years or longer. However, 

evidence does not exist showing the resources allotted to those appeals 
Page 23 GAO-06-765 Information Quality Act

over the 2-year period in question. The following IQA requests illustrate 

the length of time it can take to address an IQA correction, regardless of 

the final outcome. 

• On March 10, 2004, a group of trade associations and organizations 

primarily representing the residential and commercial properties sector 

submitted an IQA request to EPA challenging the accuracy of an EPA 

statement that water allocation (submetering) billing systems in 

apartment buildings and other multifamily housing did not encourage 

water conservation. This statement was in a Federal Register notice 

regarding the applicability of the Safe Drinking Water Act to submetered 

properties.19 The group did not consider the statement to be correct 

regarding one type of allocation system in particular—Ratio Utility 

Billing Systems. According to EPA documents and officials, EPA’s 

response to the request and subsequent appeal involved a number of 

EPA staff, including senior executives, scientists, and others in the 

Office of Water and other headquarters units. The appeal itself was 

reviewed by a three-member panel of senior executives. EPA took a 

total of almost 5 months (146 days) to respond to the initial correction 

request, well over the 90-day goal stated in EPA’s IQA guidelines, and 

almost 11 months (323 days) more to decide on the appeal, over three 

times longer than the 90-day appeals goal in EPA’s guidelines, according 

to our analysis of EPA IQA requests. The nearly 15-month total response 

time was not unusual compared to other EPA processing times for IQA 

requests. The lengthy response time was in part due to EPA waiting for 

the completion of a related study—under way at the time of the 

correction request—before making a final decision about revising its 

submetering policy. On September 28, 2005, EPA ultimately denied the 

appeal and did not change its statement, citing the results of the study as 

not showing that Ratio Utility Billing Systems encouraged water 

conservation. 

• On May 4, 2004, a nonprofit organization representing public sector 

employees involved in the environment and an individual federal 

employee submitted an IQA request to the Fish and Wildlife Service 

about alleged errors in agency documents, including the Multi-Species 

Recovery Plan and the draft Landscape Conservation Strategy, which 

are intended to protect the endangered Florida panther. The request 

and subsequent appeal involved previously identified errors in peer19 See 42 U.S.C. § 300g and 68 Fed. Reg. 74233 (Dec. 23, 2003).
Page 24 GAO-06-765 Information Quality Act

reviewed research associated with the definition of panther habitat, as 

well as estimates of panther population and models used to determine 

strategies to help the panther species survive and recover in Florida. 

Fish and Wildlife Service staff who evaluated and responded to the 

initial request and to the appeal included senior executives, attorneys, 

field biologists, and other professional staff from a number of offices 

within headquarters, including the program offices, the Solicitor’s 

Office, the External Affairs Office, and the Director’s Office, as well as 

field offices in Vero Beach and Jacksonville, Florida, and the regional 

office in Atlanta. The administrative appeals panel for the correction 

request consisted of executives from Fish and Wildlife Service 

headquarters and its Northwest Regional Office and Interior’s U.S. 

Geological Survey. Although the service responded to the initial request 

2 months after its receipt, it took more than 7-1⁄2 months (over 230 

calendar days) to respond to the appeal. While the initial response was 

consistent with the Service’s 45-business day response time stated in the 

guidelines, the appeal took over 6 months more than the guideline’s 15-

business day appeal time frame, according to our analysis. The nearly 

300-day total response time was not unusual compared to other Fish and 

Wildlife Service processing times for IQA requests. On March 16, 2005, 

the Fish and Wildlife Service suspended the draft conservation strategy 

for the panther, corrected other key documents, posted notices on the 

regional and Vero Beach agency field office Web sites about these 

actions, and revised and published for public comment the panther 

section of the agency’s recovery plan. 

Agencies Treated Most IQA 

Rulemaking-Related 

Requests as Comments to 

Proposed Rules

According to OMB staff and agency IQA officials, IQA correction requests 

have not adversely affected agency rulemaking procedures to date, partly 

because agencies handled most IQA requests related to rulemaking as 

public comments to proposed rules under the Administrative Procedure 

Act rather than as IQA requests. This approach, described in a number of 

agencies’ IQA guidelines, including EPA’s and the Department of 

Agriculture’s, was followed to avoid duplicating the rulemaking comment 

process and diverting resources away from the rulemaking process. It 

should be recognized that IQA correction requests could affect rulemaking 

outside of the formal rulemaking process. For example, IQA correction 

requests that are filed before an agency’s formal rulemaking process begins 

could affect when or if an agency initiates a rulemaking.

We found 16 requests for corrections submitted during fiscal years 2003 

and 2004 to be related to agency rulemaking. According to our analysis of 
Page 25 GAO-06-765 Information Quality Act

IQA requests, annual IQA reports sent to OMB, and OMB’s own reports, and 

as later confirmed by OMB, five agencies reported having received 16 IQA 

requests related to rulemaking for the 2-year period. These five agencies 

were EPA, the Fish & Wildlife Service, the Department of Agriculture’s 

Forest Service, the Department of the Treasury’s Alcohol and Tobacco Tax 

and Trade Bureau, and DOT. These 16 requests—touching on a diverse 

range of issues, such as air safety, alcohol, chemicals, and the 

environment—accounted for almost 1 in 5 substantive requests for the 2 

years. 

• The Fish and Wildlife Service received the largest number of 

rulemaking-related IQA requests out of the 16 requests related to 

regulations or rules during fiscal years 2003 and 2004. Seven of the 

Service’s 11 requests were related to proposed rulemaking. These 7 

requests represented 44 percent of all rulemaking-related IQA requests 

received by all agencies during the 2 years. 

• The agencies treated 10 of the 16 requests that they received during the 

2-year period as comments to proposed rules rather than processing 

them as IQA requests, and the agencies so informed the IQA petitioner. 

For example, the Alcohol and Tobacco Tax and Trade Bureau 

considered an IQA request regarding flavored malt beverages and 

related proposals as comments to a proposed rule. The bureau 

informed the IQA petitioner that it was handling the request as a public 

comment under the procedures of the Administrative Procedure Act, 

rather than as an IQA correction request. Agencies similarly processed 

the other nine requests related to regulations or rulemaking. 

• As for the other six IQA requests related to rulemaking or regulations, 

agencies rejected two, are developing responses to two, and were—as 

of the end of March 2006—awaiting additional information or court 

decisions before responding to the remaining two. 

Conclusions OMB’s governmentwide IQA guidelines provide agencies with flexibility to 

develop their own guidelines to suit their missions. Having executive 

branch agencies use the Internet to inform the public about the existence 

of their IQA guidelines, including the IQA correction mechanism, is a step 

toward improving the transparency of how agencies develop and 

disseminate information and address information errors, as well as how 

information users can seek correction of information. 
Page 26 GAO-06-765 Information Quality Act

Given the current status of IQA at agencies, OMB has before it additional 

opportunities to build on its efforts in implementing IQA so far, a mission 

on which it embarked a few years ago. For example, it could draw from its 

experience of working with cabinet and many independent agencies to put 

additional agency-specific guidelines in place. Likewise, OMB could apply 

the knowledge from the lessons it and agencies have learned about posting 

accessible, user-oriented information on agency Web sites. By working 

with agencies and tapping into public input, OMB could enhance agencies’ 

and the public’s involvement in promoting high-quality agency information 

as well as increasing the public’s access to and confidence in that 

information, thereby helping to further the goal of disseminating quality 

information. 

Recommendations for 

Executive Action 

To help ensure that all agencies covered by IQA fulfill their requirements, 

including implementing IQA guidelines and helping to promote easier 

public access to IQA information on agency Web sites, we recommend that 

the Director of OMB take the following three actions: 

• work with DHS to help ensure it fulfills IQA requirements and set a 

deadline for doing so; 

• identify other agencies that do not have IQA guidelines and work with 

them to develop and implement IQA requirements; and

• clarify guidance to agencies on improving the public’s access to online 

IQA information, including suggestions about clearer linkages to that 

information, where appropriate. 

Agency Comments and 

Our Evaluation

In written comments on a draft of this report, the Acting Administrator of 

OMB's OIRA responded to our recommendations. Regarding our draft 

report's recommendation to OMB to work with DHS and other agencies not 

meeting IQA requirements, the Acting Administrator stated that OMB fully 

supports our recommendation that DHS develop IQA guidelines and that 

OMB would continue to work with DHS to that end. In our draft report, we 

had one recommendation for OMB to work with DHS and other agencies to 

develop IQA guidelines. Based on OIRA's comments, in our final report we 

made two separate recommendations regarding DHS and the other 

agencies developing IQA guidelines. Further, we believe that as OIRA 

continues to work with DHS—which has 22 component agencies—setting a 
Page 27 GAO-06-765 Information Quality Act

deadline for DHS to implement IQA guidelines is important. As for the 

other agencies (many of which are small) without IQA guidelines, OIRA 

stated it would work with them as they develop and implement information 

quality measures. OIRA stated that in those efforts, it would consider the 

resources that would be needed and the potential benefits that would be 

achieved by having IQA guidelines in place. Regarding our 

recommendation about public access to online IQA information, OIRA 

noted it shares GAO's interest in improving public access and will continue 

to work with agencies to improve dissemination of IQA information. OIRA 

also provided separate technical corrections and suggestions to the draft of 

our report, which we have incorporated as appropriate. The written 

comments are reprinted in appendix IV. 

As agreed with your offices, unless you release its contents earlier, we plan 

no further distribution of this report until 30 days from its date. At that 

time we will send copies to other interested congressional committees and 

the Acting Administrator of OIRA. This report will also be available at no 

charge on GAO’s Web site at http://www.gao.gov. 

If you or your staff have any questions concerning this report, please 

contact me on (202) 512-6806 or by e-mail at farrellb@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs may be 

found on the last page of this report. Key contributors to this report were 

Robert Goldenkoff, Assistant Director; Ernie Hazera, Assistant Director; 

Andrea Levine; Keith Steck; and Margit Willems Whitaker. 

Brenda S. Farrell

Acting Director

Strategic Issues
Page 28 GAO-06-765 Information Quality Act

Appendix I

Scope and Methodology AAppenednxidexiIs

To assess the Office of Management and Budget’s (OMB) role in 

implementing the Information Quality Act (IQA), we reviewed OMB’s IQA 

documents, including memorandums sent to agencies, and interviewed 

Office of Information and Regulatory Affairs (OIRA) staff involved with 

IQA.1

 In addition, we reviewed IQA documents—including guidelines, 

requests and appeals, agency decisions, and related documents—and 

interviewed IQA and other knowledgeable officials at the 17 federal 

agencies identified in table 5. While we reviewed IQA guidelines at all 

cabinet-level agencies, we conducted interviews at 5 independent agencies 

and 12 of the 15 federal cabinet agencies and at least one component of 

each, as shown in table 5. 

Table 5: Agencies Where We Interviewed IQA Officials 

Source: GAO analysis of agency information.

1 We use the term agencies to refer to both federal executive branch cabinet departments 

and independent agencies covered by the Paperwork Reduction Act. 

Cabinet agencies and component

Department of Agriculture

• Forest Service

Department of Housing and Urban 

Development

Department of Commerce

• National Oceanic and Atmospheric 

Administration

Department of the Interior

• Fish and Wildlife Service

Department of Defense

• Army Corps of Engineers

Department of Justice

• Bureau of Justice Statistics

Department of Energy

• Energy Information Administration

Department of Labor

• Occupational Safety and Health 

Administration

Department of Health and Human Services

• National Institutes of Health

Department of Transportation

• Federal Motor Carrier Safety 

Administration

Department of Homeland Security 

• Transportation Safety Administration

• Federal Emergency Management Agency

Department of the Treasury

• Internal Revenue Service

Independent agencies

Consumer Product Safety Commission National Aeronautics and Space 

Administration

Environmental Protection Agency Nuclear Regulatory Commission

Federal Deposit Insurance Corporation
Appendix I

Scope and Methodology

Page 29 GAO-06-765 Information Quality Act

We selected these agencies to obtain a cross section of agencies that reflect 

the diverse range of government activities. We made our selection to cover 

a wide range of criteria, including the organization’s size (number of 

employees in fiscal year 2004); its mission (regulatory versus statistical, for 

example); and the nature of issues covered by the agency—such as the 

environment, health, and safety.2

 We discussed with agency officials the 

development of their IQA guidelines, whether they had received requests 

for correction of information and how they addressed them, and what role 

OMB played in all of this. 

To further evaluate OMB’s role in the implementation of IQA, we reviewed 

OMB and agency IQA documents for all 15 cabinet agencies and the 5 

independent agencies we contacted. These documents included online 

information, such as OMB memorandums and agency IQA guidelines, 

related IQA information, and OMB and agency IQA Web sites. Additionally, 

we reviewed the Web sites of 86 other independent agencies, including 

commissions, boards, and other entities, covered by the Paperwork 

Reduction Act to determine whether they had IQA guidelines online, but 

we did not survey them. Further, we reviewed the Federal Register for 

notices about these agencies’ IQA guidelines, as OMB required. We did not 

contact these 86 individual agencies or survey users of their Web sites, as 

this was beyond the scope of our review.

Regarding the second objective of determining the number, type, and 

source of IQA requests, including who submitted them, for fiscal years 2003 

and 2004, we contacted agency IQA officials and OMB staff and obtained 

relevant information from them. We also reviewed OIRA’s two reports to 

Congress to validate data collected through other sources.3

 To the extent 

the information was available online, we reviewed IQA requests on agency 

Web sites. To supplement and verify the accuracy and completeness of this 

information, we interviewed agency and OMB IQA staff and officials. In 

addition, to categorize the sources of the requests by type of entity, such as 

2

 While we took measures to ensure the selected agencies reflect meaningful criteria for our 

work, our selection was not intended to be representative. Thus, the findings from our 

interviews cannot be used to make inferences about all agencies.

3

 Office of Management and Budget, Office of Information and Regulatory Affairs, 

Information Quality: A Report to Congress, Fiscal Year 2003 and Validating Regulatory 

Analysis: 2005 Report to Congress on the Costs and Benefits of Federal Regulations and 

Unfunded Mandates on State, Local, and Tribal Entities. In both reports OIRA identified 

the agencies that had guidelines in place and the number of IQA correction requests they 

received for fiscal years 2003 and 2004.
Appendix I

Scope and Methodology

Page 30 GAO-06-765 Information Quality Act

business, trade group, or nonprofit advocacy organization, we relied on 

information from the sources and agency descriptions. We made our 

determination when information was contradictory or not available. 

Moreover, to determine the final status of IQA requests and any appeals, we 

reviewed related agency documents, including agency notification letters, 

and spoke with agency IQA officials about their status. We determined that 

OMB and agency data were sufficiently reliable for the purposes of this 

review. The results of our analysis differ from information in OMB’s two 

reports to Congress discussing IQA because of (1) differences between 

report information about IQA requests and information on agency Web 

sites and (2) minor report errors, including errors reported by agencies to 

OMB—such as IQA requests reported for calendar year 2003 instead of 

fiscal year 2003—that OMB repeated. In addition, we tracked the status of 

appeals to the end of March 2006 to provide current information, going 

beyond the end of fiscal year 2004, which is the date OMB used as the 

cutoff for appeal information in its December 2005 report. 

Regarding the third objective of examining whether the implementation of 

IQA has adversely affected agencies’ or overall operations in general and 

the rulemaking process in particular, we contacted agency IQA and other 

knowledgeable officials and OMB staff. We also attempted to determine 

the resources that OMB and agencies committed to implementing IQA by 

obtaining IQA cost and staff allocation data, but agency officials told us 

they do not track such information, although the Department of Labor had 

cost information on setting up a system on the status of IQA requests. In 

addition, we reviewed the annual IQA reports submitted to OMB by the 

cabinet-level agencies and the 5 independent agencies with guidelines 

where we conducted interviews. 

Moreover, to better understand specific aspects of IQA requests and how 

agencies addressed them, as well as to illustrate specific points, we 

reviewed in detail selected IQA requests at four agencies—the 

Environmental Protection Agency, the Department of Health and Human 

Services’ National Institutes of Health, the Department of Agriculture’s 

Forest Service, and the Department of the Interior’s Fish and Wildlife 

Service.4

 

4

 Our case illustrations cannot be used to make inferences about all IQA requests (at the 

agencies from which the examples were taken or all federal agencies) during the 2-year 

period we studied.
Appendix I

Scope and Methodology

Page 31 GAO-06-765 Information Quality Act

Because OMB was still developing its IQA peer review policies at the time 

of our review, we did not discuss with agency officials their plans for 

carrying out these future requirements. In addition, although agencies have 

other mechanisms to correct information, we evaluated only the IQA 

information correction mechanism. 

We conducted our work in Washington, D.C., from March 2005 through July 

2006 in accordance with generally accepted government auditing 

standards.
Page 32 GAO-06-765 Information Quality Act

Appendix II

Independent Agencies Where Web Sites Were 

Checked for IQA Guidelines ApendxiI

IQA guidelines in place 

and on Web site?

Agency Yes No

1 Advisory Council on Historic Preservation 9

2 African Development Foundation 9

3 Agency for International Development 9

4 American Battle Monuments Commission 9

5 AMTRAK (National Railroad Passenger Corporation) 9

6 Antitrust Modernization Commission 9

7 Appalachian Regional Commission 9

8 Access Board 9

9 Arctic Research Commission 9

10 Armed Forces Retirement Home 9

11 Broadcasting Board of Governors 9

12 Central Intelligence Agency 9

13 Chemical Safety and Hazard Investigation Board 9

14 Christopher Columbus Fellowship Foundation 9

15 Commission Regarding Weapons of Mass Destruction 9

16 Commission on International Religious Freedom 9

17 Commission on Ocean Policy 9

18 Commodities Futures Trading Commission 9

19 Consumer Product Safety Commission 9

20 Corporation for National and Community Service 9

21 Court Services and Offender Supervision Agency 9

22 Defense Nuclear Facilities Safety Board 9

23 Denali Commission 9

24 Environmental Protection Agency 9

25 Equal Employment Opportunity Commission 9

26 Export-Import Bank of the United States 9

27 Farm Credit Administration 9

28 Farm Credit System Insurance Corporation 9

29 Federal Mediation and Conciliation Service 9

30 Federal Mine Safety and Health Review Commission 9

31 Federal Retirement Thrift Investment Board 9

32 Federal Communications Commission 9

33 Federal Deposit Insurance Corporation 9

34 Federal Energy Regulatory Commission 9
Appendix II

Independent Agencies Where Web Sites Were 

Checked for IQA Guidelines

Page 33 GAO-06-765 Information Quality Act

35 Federal Housing Finance Board 9

36 Federal Labor Relations Authority 9

37 Federal Maritime Commission 9

38 Federal Reserve System 9

39 Federal Trade Commission 9

40 General Services Administration 9

41 Institute of Museum and Library Services 9

42 Inter-American Foundation 9

43 Legal Services Corporation 9

44 Marine Mammal Commission 9

45 Merit Systems Protection Board 9

46 Migratory Bird Conservation Commission 9

47 Millennium Challenge Corporation 9

48 Mississippi River Commission 9

49 National Aeronautics and Space Administration 9

50 National Archives and Records Administration 9

51 National Commission on Libraries and Information 

Science

9

52 National Capital Planning Commission 9

53 National Council on Disability 9

54 National Credit Union Administration 9

55 National Endowment for the Arts 9

56 National Endowment for the Humanities 9

57 National Indian Gaming Commission 9

58 National Labor Relations Board 9

59 National Park Foundation 9

60 National Science Foundation 9

61 National Transportation Safety Board 9

62 Northwest Power Planning Council 9

63 Nuclear Regulatory Commission 9

64 Nuclear Waste Technical Review Board 9

65 Occupational Safety and Health Review Commission 9

66 Office of Navajo and Hopi Indian Relocation 9

67 Office of Federal Housing Enterprise Oversight 9

68 Office of Government Ethics 9

69 Office of Personnel Management 9

(Continued From Previous Page)

IQA guidelines in place 

and on Web site?

Agency Yes No
Appendix II

Independent Agencies Where Web Sites Were 

Checked for IQA Guidelines

Page 34 GAO-06-765 Information Quality Act

Source: GAO analysis of agency information.

a

The commission has drafted but not finalized guidelines as of late July 2006.

70 Office of Special Counsel 9

71 Overseas Private Investment Corporation 9

72 Peace Corps 9

73 Pension Benefit Guaranty Corporation 9

74 Presidio Trust 9

75 Railroad Retirement Board 9

76 Securities and Exchange Commission 9

77 Selective Service System 9

78 Small Business Administration 9

79 Smithsonian Institution 9

80 Social Security Administration 9

81 Social Security Advisory Board 9

82 State Justice Institute 9

83 Surface Transportation Board 9

84 Susquehanna River Basin Commission 9

85 Tennessee Valley Authority 9

86 Trade and Development Agency 9

87 U.S. Commission on Civil Rights 9a

88 U.S. Holocaust Memorial Museum 9

89 U.S. International Trade Commission 9

90 Utah Reclamation Mitigation and Conservation 

Commission

9

91 Valles Caldera Trust 9

(Continued From Previous Page)

IQA guidelines in place 

and on Web site?

Agency Yes No
Page 35 GAO-06-765 Information Quality Act

Appendix III

Organizations That Filed IQA Correction 

Requests during Fiscal Years 2003 and 2004 ApendxiI

Federal department/agency receiving request 

and filer

Business, 

trade group, or 

profit-oriented 

organization

Nonprofit 

or other 

advocacy 

organization

Department of Agriculture

 W.K. Olsen and Associates, LLC 9

 Earth Island Institute, etc. (2) 9

 Sierra Club, etc. 9

 Center for Regulatory Effectiveness—same as 

 Department of Health and Human Services

 filing

9

 Alliance for the Wild Rockies 9

Department of Commerce

 Competitive Enterprise Institute—same as Office

 of Science and Technology Policy filing

9

 Atlantic Salmon of Maine—same as Department

 of the Interior filing

9

 Associated Fisheries of Maine, Inc., etc. 9

 Center for Regulatory Effectiveness, et al. 9

Department of Defense

 Public Employees for Environmental

 Responsibility

9

 Public Interest Group (identity not provided) 9

Department of Education

 National Wrestling Coaches Association, etc. 9

Department of Health and Human Services

 Center for Regulatory Effectiveness, etc. (3)—

 one same as Department of Agriculture filing

9

 Animal Health Institute (2) 9

 SafeBlood Technologies, etc. 9

 Chemical Products Corporation (2) 9

 Nickel Development Institute 9

 Styrene Information and Research Center, Inc. 9

 Salt Institute, etc. 9

 Environmental Working Group 9

 McNeil Consumer and Specialty Products 9

 National Legal and Policy Center 9

 American Chemistry Council (2) 9
Appendix III

Organizations That Filed IQA Correction 

Requests during Fiscal Years 2003 and 2004

Page 36 GAO-06-765 Information Quality Act

Department of the Interior

 Atlantic Salmon of Maine—same as Department

 of Commerce filing

9

 Chilton Ranch and Cattle Company 9

 Public Employees for Environmental 

 Responsibility (2)

9

 Florida Marine Contractors Association 9

 National Association of Home Builders 9

 Union Electric Company 9

 Partnership for the West 9

 Center for Regulatory Effectiveness 9

Department of Justice

 National Coalition for Asian Pacific American 

 Community Development

9

Department of Labor

 Liquid Container/Plaxicon 9

Department of Transportation

 Marine industry consultant 9

Department of the Treasury

 Diageo North America, Inc. 9

Consumer Product Safety Commission

 American Chemistry Council 9

 Competitive Enterprise Institute (2) 9

 Association of Home Appliance Manufacturers 9

 McDowell Owings Engineering, Inc. 9

Office of Science and Technology Policy (Executive Office of the President)

 Competitive Enterprise Institute—same as

 Department of Commerce filing

9

Environmental Protection Agency

 Chemical Products Corporation 9

 Center for Regulatory Effectiveness, etc. (2) 9

 Competitive Enterprise Institute 9

 Friends of Massachusetts Military Reservation 9

 Morgan, Lewis & Bockius, LLP 9

 Geronimo Creek Observatory (4) 9

 Perchlorate Study Group 9

(Continued From Previous Page)

Federal department/agency receiving request 

and filer

Business, 

trade group, or 

profit-oriented 

organization

Nonprofit 

or other 

advocacy 

organization
Appendix III

Organizations That Filed IQA Correction 

Requests during Fiscal Years 2003 and 2004

Page 37 GAO-06-765 Information Quality Act

Source: GAO analysis of agency and OMB information.

Note: The numbers in parentheses following an entity’s name indicate the number of substantive IQA 

requests submitted to the agency. 

 National Multi-Housing Council, etc. 9

 U.S. Chamber of Commerce 9

 National Paint and Coatings Association, etc. 9

 Dow Chemical Company 9

 National Association of Home Builders 9

 NPC Services, Inc. 9

 American Chemistry Council 9

Federal Communications Commission

 TeleTruth 9

(Continued From Previous Page)

Federal department/agency receiving request 

and filer

Business, 

trade group, or 

profit-oriented 

organization

Nonprofit 

or other 

advocacy 

organization
Page 38 GAO-06-765 Information Quality Act

Appendix IV

Comments from the Office of Management 

and Budget ApendxiIV
Appendix IV

Comments from the Office of Management 

and Budget

(450397) Page 39 GAO-06-765 Information Quality Act
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