U.S. ELECTION ASSISTANCE COMMISSION

1201 New York Ave. NW – Suite 300 

Washington, DC 20005

EAC INFORMATION QUALITY GUIDELINES

I. OVERVIEW 

EAC is an independent, bipartisan agency created by the Help America Vote Act 

(HAVA). It assists state and local election administrators in improving the administration 

of elections for federal office by (1) disbursing federal funds to states to implement 

HAVA requirements; (2) auditing the use of HAVA funds; (3) adopting the Voluntary 

Voting System Guidelines (VVSG); and (4) serving as a national clearinghouse and 

resource of information regarding election administration. EAC also accredits voting 

system testing laboratories and certifies, decertifies and recertifies voting systems. 

This document contains the EAC’s policy directives and required procedures to 

implement the OMB Guidelines for Ensuring and Maximizing the Quality, Objectivity, 

Utility, and Integrity of Information Disseminated by Federal Agencies, 67 Fed. Reg. 

8452 (“OMB Guidelines”).The OMB Guidelines implement section 515 of the Treasury 

and General Government Appropriations Act for Fiscal Year 2001 (Pub. L. 106-554). 

The OMB Guidelines apply to the sharing of, and access to, information disseminated by 

Federal agencies. They also require that each Federal agency: (1) issue pre-dissemination 

review guidelines ensuring and maximizing the quality, objectivity, utility, and integrity 

of information (including statistical information) disseminated by the agency; (2) 

establish correction procedures allowing affected persons to seek and obtain correction of 

information maintained and disseminated by the agency that does not comply with the 

OMB Guidelines; and (3) report annually to OMB the number and nature of complaints 

received by the agency regarding the accuracy of information disseminated by the agency 

and how such complaints were handled by the agency. 

II. DEFINITIONS 

As used in this document: 

Affected person means anyone who may use, benefit from, or be harmed by the 

disseminated information. 

Capable of being substantially reproduced means that independent reanalysis of the 

original or supporting data using the same methods would generate similar analytical 

results, subject to an acceptable degree of imprecision. 

Commission means the U.S. Election Assistance Commission. 

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Dissemination means an agency initiated or sponsored distribution of information to the 

public. (See 5 CFR 1320.3(d), definition of “Conduct or Sponsor”). Dissemination does 

not include distribution limited to government employees or agency contractors or 

grantees; intra- or inter-agency use or sharing of government information; and responses 

to requests for agency records under the Freedom of Information Act, the Privacy Act, 

the Federal Advisory Committee Act, or other similar law. This definition also does not 

include distribution limited to correspondence with individuals or persons, archival 

records, public filings, subpoenas, adjudicative processes, or press releases, fact sheets, 

press conferences, or similar communications in any medium that announce or support 

the announcement or give public notice of information EAC has disseminated elsewhere. 

Government information means information created, collected, processed, 

disseminated, or disposed of by or for the Federal government. 

Influential information means information that the agency reasonably can determine 

will have or does have a clear and substantial impact on important public policies or 

important private sector decisions. 

Information means any communication or representation of knowledge such as facts or 

data, in any medium or form, including textual, numerical, graphic, cartographic, 

narrative, or audiovisual forms. This definition includes information that an agency 

disseminates from a web page, but does not include the provision of hyperlinks to 

information that others disseminate. This definition does not include opinions, where the 

agency's presentation makes it clear that what is being offered is someone's opinion rather 

than fact or the agency's views. 

Information dissemination product means any book, paper, map, machine-readable 

material, audiovisual production, or other documentary material, regardless of physical 

form or characteristic, an agency disseminates to the public. This definition includes, but 

is not limited to, any electronic document, CD-ROM, DVD, or web page. 

Integrity means protection of information from unauthorized access or revision, to 

ensure that the information is not compromised through corruption or falsification. 

Objectivity includes two distinct elements: 

1. "Objectivity" includes whether disseminated information is being presented in an 

accurate, clear, complete, and unbiased manner. This involves whether or not the 

information is presented within the proper context. Sometimes, in disseminating certain 

types of information to the public, other information must also be disseminated in order 

to ensure an accurate, clear, complete, and unbiased presentation. Also, the agency 

identifies the sources of the disseminated information (to the extent possible, consistent 

with confidentiality protections) and, in a scientific or statistical context, the supporting 

data and models, so that the public can assess for itself whether there may be some reason 

to question the objectivity of the sources. Where appropriate, supporting data should have 

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full, accurate, transparent documentation, and error sources affecting data quality should 

be identified and disclosed to users. 

2. In addition, "objectivity" involves a focus on ensuring accurate, reliable, and unbiased 

information. In a scientific or statistical context, the original or supporting data must be 

generated, and the analytical results must be developed, using sound statistical and 

research methods. 

a. If the results have been subject to formal, independent, external peer review, 

the information can generally be considered of acceptable objectivity. 

b. In those situations involving influential scientific or statistical information, the 

results must be capable of being substantially reproduced, if the original or 

supporting data are independently analyzed using the same models. 

Reproducibility does not mean that the original or supporting data have to be 

capable of being replicated through new experiments, samples, or tests. 

c. Making the data and models publicly available will assist in determining 

whether analytical results are capable of being substantially reproduced. 

However, these guidelines do not alter the otherwise applicable standards and 

procedures for determining when and how information is disclosed. Thus, the 

objectivity standard does not override other compelling interests, such as privacy, 

trade secret, and other confidentiality protections. 

Quality is an encompassing term comprising utility, objectivity, and integrity. Therefore, 

the OMB Guidelines sometimes refer to these four statutory terms, collectively, as 

"quality." 

Utility refers to the usefulness of the information to its intended users, including the 

public. In assessing the usefulness of information that the agency disseminates to the 

public, the agency needs to consider the uses of the information not only from the 

perspective of the agency but also from the perspective of the public. As a result, when 

reproducibility and transparency of information are relevant for assessing the 

information's usefulness from the public's perspective, the agency must take care to 

ensure that reproducibility and transparency have been addressed in its review of the 

information. 

III. POLICY 

The Commission maintains high standards of quality in the production of information 

disseminated outside the agency. It is the Commission's policy to ensure and maximize 

the quality, objectivity, utility, and integrity of the information that it disseminates to the 

public. The Commission will take appropriate steps to incorporate information quality 

criteria into its information dissemination practices, and will ensure the quality of 

information the agency disseminates in accordance with the standards set forth in these 

guidelines. The Commission is committed to integrating the principle of information 

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quality into every step of its development of information, including creation, collection, 

maintenance, and dissemination. The Commission will comply with all then-existing 

legal and policy rules, regulations, directives, and guidance at every step of the process. 

In accordance with OMB's guidelines, the level of quality assurance appropriate for 

information will vary according to the information's relative importance and the costs and 

benefits of requiring additional assurances for the particular information. The following 

guidelines describe the Commission's quality standards and formalize a correction 

mechanism. 

(A) Basic Principles

(1) Quality: The Commission takes pride in the quality of its information and is 

committed to disseminating information that meets the Commission's rigorous standards 

for objectivity, integrity and utility. Before the Commission disseminates any information 

to the public, all aspects are thoroughly reviewed by staff and appropriate levels of 

management. The Commission's current internal review and approval policies and 

procedures ensure, to the Commission's best ability, that the information and data 

disseminated by the Commission are accurate and timely, appropriate for external 

consumption, uncompromised and useful to the public. 

(2) Integrity: The Commission's information security program encompasses those 

measures necessary to protect the Commission's information resources. These measures 

include providing, for each project: (i) the appropriate technical, physical, administrative, 

environmental and telecommunications safeguards; and (ii) continuity of operations 

through contingency or disaster recovery plans. The Commission's protective measures 

cover the following information resources: data, applications, software, hardware, 

physical facilities and telecommunications. The Commission's information security 

program assures that each automated information system has a level of security that is 

commensurate with the risk and magnitude of the harm that could result from the loss, 

misuse, unauthorized disclosure or improper modification of the information contained in 

the system. 

(3) Utility: The Commission is committed to maximizing the utility of the information it 

disseminates to the public. To this end, information and the appropriate form and vehicle 

for its dissemination are evaluated and reviewed by the relevant subject matter experts on 

a given project, along with appropriate levels of management within the Commission, 

and in some cases, the EAC’s advisory committees before it is disseminated to ensure its 

usefulness to the intended audience. This includes ensuring that it is organized and 

written in a manner that facilitates its understanding and use by the intended audience. 

The information also is reviewed to ensure its timeliness and continuing relevance for the 

intended audience. 

(4) Objectivity: The Commission is committed to disseminating information that is 

accurate, reliable, and unbiased both in its content and in its presentation. The relevant 

subject matter experts and appropriate levels of management review information before it 

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is disseminated to, among other things, ensure that it is accurate, reliable and unbiased. 

As appropriate, this review includes an assessment of the collection, generation, and 

analysis of relevant information and data. The review also considers the information's 

presentation to ensure that it is put in the proper context and presented in a clear, 

complete and unbiased manner. Where appropriate, the Commission also identifies the 

sources of supporting data so that the public can assess for itself the objectivity of those 

sources. 

(5) Influential Information: Any information deemed to be "influential" as defined in 

these guidelines will be reviewed by subject matter experts within the Commission and 

appropriate levels of management to ensure adequate disclosure about underlying data 

and methods of analysis to facilitate reproducibility of the information by qualified third 

parties. 

B. Responsibilities 

(1) Chief Information Officer: The Chief Information Officer (CIO) is responsible for 

assuring that all disseminated information meets the basic quality standard. This 

responsibility may be delegated to the program directors. 

(2) Program Directors: The program directors are responsible for ensuring that the predissemination review process is performed and documented at a level appropriate for the 

type of information disseminated. 

(3) Originating Offices: Originating offices are responsible for initiating and/or utilizing 

peer reviews, working groups, or advisory committees to ensure that disseminated 

information is objective, unbiased, and accurate in both presentation and substance. 

C. Procedures 

(1) Pre-Dissemination Review 

(a) Election Administration and Voting Survey (including National Voter Registration 

Act and Uniformed and Overseas Citizens Absentee Voting Act studies) 

Routine statistical data such as those that appear in these reports do not undergo peer 

review. Since the information contained in these reports comes directly from the states 

and territories, EAC Research Division relies on a data verification process with the 

states wherein the EAC solicits information from the states and seeks confirmation from 

them that the data is accurate before it is reported. 

(b) Other EAC Research Department Studies 

EAC Research Department uses its Board of Advisors and/or Standards Board, where 

appropriate, for the review of information products. These Boards meet in person and via 

a virtual meeting room, which allows all Board members – whose membership is set by 

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statute and includes election officials and stakeholders from various other communities – 

an opportunity to offer comment on Research Division studies. Comments are collected 

and used to make changes where applicable. For studies that require the review of 

technical experts, EAC Research Division may choose to convene a peer review panel of 

experts to offer comment. 

(c) Election Management Guidelines and Quick Starts 

Each chapter to the Election Management Guidelines (EMG) is reviewed three times 

before being presented to the Commission for consideration of adoption. First, the draft 

chapter is reviewed by the participants in the working group used at the beginning of the 

process. The working group is composed of no more than nine individuals with expertise 

in election administration. Second, the draft chapter is reviewed by EAC staff. Generally, 

all employees in the Research Division provide comments on the chapter. Third, each 

chapter is reviewed by the EAC’s Board of Advisors (37 members) and the EAC’s 

Standards Board (110 members), usually via the EAC’s Virtual Meeting Room. All 

comments are incorporated, as appropriate, and the chapters are recommended to the 

Commission for consideration of adoption. 

The Quick Start Management Guides of approved EMGs are reviewed by EAC staff 

before dissemination. 

(d) Foreign Language Glossaries 

To date, the EAC has produced six (6) Glossaries of Key Election Terminology in 

Spanish, Chinese, Japanese, Korean, Vietnamese, and Tagalog. For all six (6) of these 

glossaries, the contractor was required to utilize stakeholder review groups composed of 

individuals with an expertise in the target languages and experience in the field of 

elections to ensure the translations were both culturally and linguistically accurate, as 

well as appropriate. 

 (e) Other Information Disseminated by EAC 

From time to time, the Commission prepares information that displays or relies on 

statistics and other data gathered by EAC staff. Sometimes the Commission staff gathers 

its own data and stores the data in databases that it controls and maintains. The staff may 

also rely on data gathered from independent third parties and vendors who supply data 

that the staff, and when appropriate, the Commission, reviews, analyzes and 

disseminates. Both internally generated and externally obtained data are subjected to 

internal review and are reviewed by the appropriate levels of management in the 

originating office responsible for preparing the reports. When appropriate, the data or the 

reports are also submitted to the Commission or peer review groups, working groups, or 

advisory committees for review or approval. 

(f) Information Outside the Guidelines’ Scope 

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Based on OMB's definitions of "dissemination" and "information," several types of 

information disseminated by the Commission and its staff do not formally fall under 

these guidelines. However, it should be emphasized that the Commission and its staff 

apply rigorous standards to all information disseminated, whether or not it formally falls 

under these guidelines. 

(g) Excluded categories include, but are not limited to: 

(i) Distributions intended to be limited to Commission employees or contractors, such as 

internal operating procedures, training manuals and requests for proposals. 

(ii) Government information intended to be limited distribution or sharing on an Intra- or 

inter-agency basis, such as the Commission's Annual Report and the Commission's 

annual budget. 

(iii) Opinions of individual Commissioners and staff members, where the author's 

presentation states that the information is that person's opinion rather than fact or the 

Commission's views. These include articles, speeches, panel presentations, special studies 

and academic papers authored by staff members that state that the views expressed in 

their work are their own views and do not necessarily reflect the Commission's views. 

(iv) Responses to requests for agency records under the Freedom of Information Act, the 

Government in the Sunshine Act, the Privacy Act, the Federal Advisory Committee Act 

or other similar statutes and regulations. 

(v) Correspondence with individual entities or persons, including staff letters and 

Advisory Opinions. 

(vi) Fact sheets, press conferences, or similar communications in any medium that 

announce or support the announcement or give public notice of information that EAC has 

disseminated elsewhere. 

(vii) Information from third parties, for which the Commission is merely a conduit, such 

as voting system test plans or other similar information. 

(viii) Dissemination of factual information or data where no analysis is performed. 

(ix) Any inadvertent or unauthorized disclosure of information intended only for interagency communications. 

(x) Testimony and other submissions to Congress containing information EAC has 

disseminated elsewhere. 

(xi) Procedural, operational, policy, and internal manuals and memoranda prepared for 

the management and operation of EAC not primarily intended for public dissemination. 

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(xii) Information disseminated by EAC employees, contractors, or grantees that is not put 

forth as an EAC information product (e.g., materials presented by an individual at a 

professional meeting). 

(xiii) Information disseminated by others that is accessible through hyperlinks on EAC’s 

website. 

For information not covered by this document, EAC is simply providing the public with 

access to the information. 

(2) Reproducibility of Results 

The OMB Guidelines distinguish between "original and supporting data" and "analytic 

results." Originating offices must ensure the reproducibility of original and supporting 

data according to commonly accepted scientific, financial, or statistical standards. 

Originating departments must ensure that analytical results receive especially rigorous 

reviews when reproducibility is not achievable through public access because of 

confidentiality protection or compelling interests. 

EAC’s commitment to quality and professional standards of practice includes: 

(a) Use of modern statistical theory and practice in all technical work 

(b) Development of strong staff expertise in the disciplines relevant to its mission 

(c) Implementation of ongoing quality assurance tasks to improve data validity and 

reliability and to improve the processes of compiling, editing, and analyzing data 

(d) Development of a strong and continuing relationship with appropriate professional 

organizations in relevant subject-matter areas. 

To carry out its mission, EAC assumes responsibility for: 

(a) Determining sources of data 

(b) Establishing measurement methods 

(c) Selecting methods of data collection and processing that provide useful information 

while minimizing respondent burden 

(d) Employing appropriate analytical methods 

(c) Ensuring the public availability of data and supporting documentation 

IV. REQUESTS FOR CORRECTION 

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The Commission has always stood ready to assist affected members of the public in 

obtaining appropriate correction of information disseminated by the Commission. 

Accordingly, the Commission Information Quality Guidelines announced by this notice 

formalize an administrative mechanism whereby affected members of the public may 

seek and obtain appropriate correction of information disseminated by the Commission if 

the information does not comply with OMB or EAC Guidelines. 

The correction process is designed to provide a mechanism for affected persons to seek 

correction of information disseminated by the Commission that does not comply with 

these guidelines. This process does not necessarily guarantee a correction in every 

instance. Rather, the decision of whether a correction is appropriate, and what degree of 

correction is appropriate, will be determined by the nature, completeness and timeliness 

of the information involved and such factors as the significance of the correction on the 

users of the information and the magnitude of the correction. Responses may be in the 

form of personal contacts by letter or telephone, form letters, press releases or mass 

mailings that correct widely disseminated errors or address a frequently raised request. 

With respect to proposed rules, the thorough consideration required by the Administrative 

Procedures Act process provides an adequate complaint and appeal process. In addition, 

by adopted policy, the EAC submits many of its proposed actions for public notice and 

comment. A separate complaint and appeal process for information that is already subject 

to such a public comment process would be duplicative, burdensome, disruptive to the 

orderly conduct of the action and unfair to other public commenters who submitted 

comments during the applicable comment period. Accordingly, the notice and comment 

process is the exclusive means by which an affected person may address the quality of 

information in a proposed rulemaking or other proposed action submitted for public 

notice and comment pursuant to EAC’s Notice and Comment Policy (available at 

www.eac.gov). 

In most instances, matters will be resolved at the appropriate office level within the 

Commission. Novel or highly complex matters may be sent to the Commission for 

review, at the staff's discretion. If the matter is resolved at the staff level, the staff will 

use reasonable efforts to send its response to the requestor within 30 days of filing. If the 

matter's resolution is particularly complicated or would benefit from consultation with 

other Commission offices or other agencies, the staff will use reasonable efforts to send a 

response to the requestor within 45 days of filing. The Executive Director or CIO will be 

notified of all such resolution. 

After it has completed its review of a request for correction, the Commission will 

determine whether a correction is warranted, and, if so, what corrective action it will take. 

Any corrective action will be determined by the nature and timeliness of the information 

involved and such factors as the significance of the error on the use of the information 

and the magnitude of the error. The Commission is not required to change, or in any way 

alter, the content or status of information simply based on the receipt of a request for 

correction. It is the EAC’s policy that the Commission need not respond substantively to 

requests for correction that it deems frivolous or repetitive. The Commission also does 

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not have to respond substantively to requests that concern information not covered by the 

Guidelines or from a person whom the information does not affect. 

(A) Information Correction Request 

(1) Format

To be treated as an information correction request under these guidelines, any affected 

person seeking correction of Commission-disseminated information should submit a 

request in writing (on paper or by email) including the following: 

(a) A description of the facts or data the requestor seeks to have corrected; 

(b) An explanation of how the requestor is an affected person with regard to those facts or 

data; 

(c) The factual basis for believing the facts or data to be corrected are inconsistent with 

Commission or OMB Guidelines; 

(d) A proposed resolution, including the factual basis for believing the facts or data in the 

requestor's proposed resolution are correct; 

(e) The consequences of not implementing the proposed resolution; and 

(f) The requestor's contact information, including name, address, daytime telephone 

number and email address. 

Requests should be marked "Information Correction Request" on the first line of the 

envelope directly above the mailing address and on the correspondence itself, in the case 

of letters, or in the "Subject" line, in the case of email correspondence. Emails should be 

sent to the following address: havainfo@eac.gov. Letters should be addressed to: 

U.S. Election Assistance Commission 

Chief Information Officer 

1201 New York Avenue, NW, Suite 300 

Washington, DC 20005 

(2) Processing Information Correction Requests 

The Chief Information Officer will route the request to the head of the appropriate 

department or office within the Commission who will ensure that: (a) the request is 

reviewed; (b) any appropriate corrective action is taken; and (c) a response to the request 

is made. The Commission will respond to the requestor in writing. If the request requires 

more than 30 calendar days to resolve, the Commission will inform the complainant that 

more time is required and indicate the reason for the delay and an estimated decision 

date. 

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(B) Requests for Staff Reconsideration 

(1) Format

If the requestor does not agree with the response, the requestor may request 

reconsideration of the staff's original response. Such a reconsideration request should be 

postmarked (or, in the case of email, date-stamped) within 30 days of the date of the 

initial response. The request for staff reconsideration should include a copy of the 

original request, a copy of the original response and the following: 

(a) A statement describing why the response to the original complaint did not comply 

with the information quality guidelines or why the requestor disagrees with the original 

response; and 

(b) The requestor's contact information, including name, address, daytime telephone 

number and email address. 

Requests for staff reconsideration should be marked "Request for Reconsideration of 

Information Correction" on the first line of the envelope directly above the mailing 

address and on the correspondence itself, in the case of letters, or in the "Subject" line, in 

the case of email correspondence. Emails should be sent to the following address: 

havainfo@eac.gov. Letters should be addressed to: 

United States Election Assistance Commission 

Chief Information Officer 

1201 New York Avenue, NW, Suite 300 

Washington, DC 20005 

(2) Processing Staff Reconsideration Requests

The Chief Information Officer will route the reconsideration request to the appropriate 

staff. The designated official may seek the advice and counsel of other appropriate staff 

in rendering the decision. The designated official will review the original response, 

determine if additional action is appropriate, and use reasonable efforts to send the staff's 

response to the reconsideration request within 30 days of receipt of the filing of the 

request for reconsideration. If the request requires more than 30 calendar days to resolve, 

the Commission will inform the complainant that more time is required, indicate the 

reason for the delay, and provide an estimated decision date. 

V. REPORTING PROCEDURES

The Commission will send an annual report to OMB describing the number and type of 

complaints received about compliance with OMB Guidelines, and how such complaints 

were resolved. 

VI. CONCLUSION

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These agency guidelines are not intended to create any right or benefit, substantive or 

procedural, enforceable in any court by a party against the Commission, the federal 

government, or any individual, beyond any that may be established by section 515 of 

Public Law 106-554 or by implementing OMB guidelines. In particular, these agency 

guidelines do not impose any additional requirements on the Commission during 

adjudicative, rulemaking or other proceedings initiated under the Commission's statutory 

authority, and do not provide parties to such proceedings any additional rights of 

challenge or appeal. 

VII. PRIVACY ACT STATEMENT

The Commission is authorized to collect the information provided by a requestor for 

information correction or for staff reconsideration. The information is needed to process 

each request and to allow the Commission to reply appropriately. The requestor is not 

required to furnish the information, but failure to do so may prevent the request from 

being processed. The principal use is to process and respond to the request, but the 

Commission may disclose information to a Congressional office in response to an inquiry 

made on the requestor's behalf, to the U.S. Department of Justice, a court or other tribunal 

when the information is relevant and necessary to litigation, or to a contractor or another 

federal agency to help accomplish a function related to these guidelines.