Information Quality Act: Actions Needed to Improve Transparency and Reporting of Correction Requests
Published: 2015-12-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: IQA, passed in fiscal year 2001, required OMB to issue government-wide guidelines by the end of that fiscal year to ensure the quality of information disseminated by federal agencies. OMB issued guidance to agencies to clarify how agencies were to satisfy the law and otherwise implement IQA. The guidance required agencies to develop and post IQA guidelines and related information on their websites. GAO reported in 2006 that expanded oversight and clearer guidance by OMB could improve agencies' implementation of IQA. GAO was asked to conduct an updated study on IQA. This report (1) identifies the number, source, and final disposition of IQA correction requests received by the 24 Chief Financial Officers (CFO) Act and other agencies for fiscal years 2010 through 2014 and (2) assesses the extent to which the 24 CFO Act and other agencies that received correction requests made IQA information publicly available, among other objectives. GAO obtained data on IQA guidelines and other IQA-related information from the 24 CFO Act agencies and 6 additional agencies that reported receiving IQA correction requests for fiscal years 2010 through 2014. GAO also reviewed agency websites and interviewed OMB and agency officials.
section_title: What GAO Found
paragraphs: Of the 30 agencies in GAO's review, 16 reported on their respective websites receiving a total of 87 Information Quality Act (IQA) correction requests from fiscal years 2010 through 2014, while 14 agencies did not post any requests during this time. Three agencies—the Environmental Protection Agency, Department of Health and Human Services, and Department of Interior—reported receiving 61 of the 87 requests. Agencies are required to post all IQA correspondence, including a copy of each correction request and the agencies' formal response on their websites. However, 8 agencies who reported receiving IQA correction requests did not post on their website the same number of IQA correction requests that they reported to the Office of Management and Budget (OMB). In most cases, agencies indicated that the discrepancies were due to the time frames for posting information to their respective websites. OMB officials said they are communicating with agencies to address these discrepancies. GAO found that trade associations and advocacy organizations (50 of 87) submitted the most IQA correction requests, followed by private citizens (16), and businesses (13). GAO also found that IQA correction requests either (1) questioned agencies' use of or agencies' interpretation of data used or (2) cited administrative errors. For example, a trade association questioned the accuracy of data used in public service advertising on childhood lead poisoning prevention. Agencies did not make the requested corrections in 59 of the 87 IQA correction requests. IQA is one of several processes available to the public for requesting corrections of agency information. In one-fourth (15 of 59) of the requests where agencies determined that no change should be made, agencies addressed those requests through an administrative mechanism other than the dedicated IQA request for correction process.
OMB posts IQA information online, including links to agency-specific IQA guidelines; however, there is no central location on OMB's website where a user could access all IQA data, making specific IQA data more difficult to find and hindering transparency of the process. Twenty-eight of the 30 agencies in GAO's review posted the required IQA information online as of November 2015. The Department of Defense's (DOD) posted IQA information did not include the administrative mechanisms needed to submit a correction request to the agency as required. The Federal Housing Finance Agency's (FHFA) online information did not include its required IQA guidance. Without this information, the public may be unaware of the steps the agencies would take upon receiving a correction request, or even how to submit a correction request. OMB staff stated they would work with the agencies to improve the information on their websites, but as of December 2015, they had not completed that process. Ensuring that online content is accurate is one of the guidelines for federal digital services. These guidelines are aimed at helping federal agencies improve their communications and interactions with customers through websites. GAO found at least five agencies did not include any information regarding correction requests and other agencies' posts included outdated information or contained broken hyperlinks. The Department of Energy's web page includes a link to its IQA processes but as of November 2015 the page to submit correction requests online was under construction. OMB requires agencies to post information quality correspondence on agency websites to increase the transparency of the process but has not provided specific guidance to agencies for posting accessible, user-oriented information, including specific time frames for posting information, explanations of and links to other available correction processes, and other suggestions for improving website usability. Providing such guidance will help increase transparency and allow the public to view all IQA related information including correction requests, appeal requests, and agency responses to those requests.
section_title: What GAO Recommends
paragraphs: GAO recommends that OMB (1) consolidate and centralize on its website a summary of IQA correction requests, (2) work with DOD and FHFA to help ensure they post required IQA administrative mechanisms and guidance online, and (3) provide additional guidance to help improve the transparency and usability of IQA websites to ensure the public can easily find and access online information. OMB agreed with these recommendations.

section_title: Letter
paragraphs: Federal agencies publicly disseminate a wide range of information that is  critical to government, businesses, and individuals. The open and efficient  exchange of scientific and technical government information, subject to  applicable national security controls and the proprietary rights of others,  helps to foster excellence in scientific research and the effective use of  federal research and developmental 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 or the Act)—section 515 of the Treasury  and General Government Appropriations Act for Fiscal Year 2001— required the Office of Management and Budget (OMB) to issue  government-wide guidelines to ensure and maximize “the quality,  objectivity, utility, and integrity of information (including statistical  information) disseminated by Federal agencies.” On February 22, 2002,  OMB finalized the government-wide guidelines. In addition, IQA 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 on the  number of IQA correction requests and how the agencies addressed  them. In keeping with the goal of improving the quality of government  information, on December 16, 2004, OMB issued the Final Information  Quality Bulletin for Peer Review which required executive agencies to  ensure that all “influential scientific information” they disseminated after  June 16, 2005, was reviewed by independent subject matter experts.
We reported in 2006 that although OMB had taken steps to implement  IQA, IQA guidelines and information for many agencies were neither  available nor easily accessible. Thus, we concluded that users of  information from these agencies may not have known whether agencies  had guidelines or known how to request correction of agency information.
You requested that we conduct an updated study on IQA and agency  implementation of the Act. This report (1) identifies the number, source,  and final disposition of IQA correction requests received by the 24 Chief  Financial Officer (CFO) Act and other agencies for fiscal years 2010  through 2014; (2) assesses the extent to which the 24 CFO Act and other  agencies that received correction requests made IQA information publicly  available; and (3) identifies how selected agencies have implemented  IQA.
To address the first objective, we searched the websites of the 24 CFO  Act agencies and identified those that had posted correction requests and  responses online for fiscal years 2010 through 2014. We selected 2014  as an ending point for a 5-year analysis because 2014 was the most  recent fiscal year of data available. To identify other agencies that had  received correction requests during the same time frame, we reviewed  IQA data reported by agencies in OMB’s annual reports to Congress. We  reviewed relevant OMB and agency documents, including IQA guidelines  and agencies’ annual reports to OMB, examined requests and appeals to  correct agency information, and reviewed OMB’s and agencies’ websites.  To supplement the documentary evidence obtained, we interviewed  agency officials responsible for IQA in their respective agencies. We also  interviewed current and former OMB staff to provide additional context on  IQA. During the course of our review, we compared agency IQA data  posted on their websites with IQA data agencies reported to OMB and  identified discrepancies. We discussed the discrepancies with OMB staff  and agency officials and included their responses in the report. We  determined that OMB and agency data were sufficiently reliable to  provide a general indication of the numbers of correction requests  received. Although agencies have other processes to correct agency  disseminated information, we evaluated only information related to the  IQA correction process.
To address the second objective, we conducted an analysis of the  websites of the 24 CFO Act agencies, as well as the other 6 agencies  identified in objective one as having received IQA correction requests  during our selected time frame. We reviewed agency websites using  internal site search engines to determine whether they had posted  required IQA information online. We compared the information found on  the websites to IQA requirements in OMB guidance to agencies on  posting IQA documents. We also used OMB’s Open Government  Directive in assessing IQA documents. To identify IQA processes and  challenges agencies face in implementing IQA, we selected a non- generalizable sample of six agencies—the Departments of Agriculture,  Commerce, Health and Human Services, Interior, and Transportation,  and the Environmental Protection Agency—to obtain illustrative examples  of how they approached and implemented IQA. We selected these  agencies based in part on the number (both high and low to include a  range) of IQA correction requests the agencies had received from fiscal  years 2010 through 2014. We also included one agency (Department of  Transportation) based on the relatively high number of peer reviews  conducted during the same time frame. We interviewed OMB and agency  officials responsible for addressing IQA correction requests to gather their  perceptions on the overall IQA process. For a more detailed description of  our scope and methodology, see appendix I.
We conducted this performance audit from November 2014 to December  2015 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: IQA establishes a process that allows the public to help ensure the quality  of information disseminated by federal agencies. IQA consists of two  major elements. The first element of IQA required OMB to develop and  issue government-wide guidelines by the end of fiscal year 2001. These  guidelines were to provide policies and procedures 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 covered federal agencies to develop IQA  guidelines by the end of fiscal year 2002. These guidelines were to  establish administrative mechanisms allowing “affected persons to seek  and obtain correction of information maintained and disseminated” by the  agencies. The guidelines were to also require agencies to periodically  report to the Director of OMB on the number and nature of IQA  complaints and how such complaints were handled.
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. OMB Circular A-130 establishes a policy for the  management of federal information resources. 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.
OMB’s Office of Information and Regulatory Affairs (OIRA) develops and  oversees the implementation of government-wide policies in the areas of  information technology, privacy, and statistics. In this capacity, OIRA  developed the government-wide IQA guidelines and helped agencies to  meet the Act’s requirement that the agencies develop their own  guidelines. OMB issued guidance to agencies to clarify how agencies  were to satisfy the law and otherwise implement IQA. The guidance  required agencies to develop and post IQA guidelines and related  information on their websites. An October 2002 OMB memorandum  describing the implementation of IQA guidelines noted that it represented  the first time that the executive branch has developed a government-wide  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 persons” to request  correction of information that they did not consider correct.
We reported in August 2006 that expanded oversight and clearer  guidance by OMB could improve agencies’ implementation of the Act.  We found that OMB had issued government-wide guidelines that were the  basis for other agencies’ own IQA guidelines. We also reported that OMB  required agencies to post guidelines and other IQA information to their  websites and required agencies to provide information to OMB on the  number and nature of correction requests they received and how such  correction requests were resolved. We found that 14 of the 15 cabinet  agencies, the Environmental Protection Agency (EPA), and 4 other  independent agencies we reviewed had developed IQA guidelines and  posted them on their websites. Of these 19 cabinet and independent  agencies with guidelines, we found that 4 had information quality links on  their home pages while other agencies’ IQA information was difficult to  locate online. Moreover, 44 of 86 additional independent agencies that we  examined had not posted their guidelines and may not have had them in  place at the time. Consequently, users of information from those agencies  may not have known whether agencies had guidelines or how to request  correction of agency information. OMB also had not clarified guidance to  agencies about posting IQA-related information, including guidelines to  make that information more accessible.
We also found in our 2006 report that in fiscal year 2003, the Federal  Emergency Management Agency and two other agencies used IQA to  address flood insurance rate maps, website addresses, photo captions,  and other administrative matters. However, in fiscal year 2004, these  agencies changed their classification of these requests from being IQA  requests. Instead they processed them using other administrative  processes that were in place prior to IQA implementation. As a result, we  found that the total number of all IQA requests dropped from more than  24,000 in fiscal year 2003 to 62 in fiscal year 2004. We recommended  that OMB (1) identify agencies without IQA guidelines and work with them  to develop and implement IQA requirements and (2) clarify guidance to  agencies on improving the public’s access to online IQA information. In  response to our report, OMB stated it would work with agencies as they  develop and implement information quality measures and would also  continue to work with agencies to improve their dissemination of IQA  information. Further, in December 2009, OMB, in an executive  memorandum to heads of executive departments and agencies, issued  an Open Government Directive (1) establishing deadlines for action that,  among other things, encouraged agencies to advance their open  government initiatives (including IQA) ahead of those deadlines and (2)  calling for each agency to take prompt steps to expand access to  information by making it available online in open formats.
section_title: Most Agencies in Our Review Reported Receiving Relatively Few IQA Correction Requests; the Majority of Requests Questioned Data Use and Resulted in No Corrections Agencies’ Websites Show a Total of 87 IQA Correction Requests from Fiscal Years 2010 through 2014
paragraphs: According to IQA information posted on the 30 agency websites in our  review, 16 agencies reported receiving 87 IQA correction requests from  fiscal years 2010 through 2014 (see table 1). The other 14 agencies in  our review did not post any IQA correction requests during the period.  Agencies reported receiving the highest number of correction requests  (26) in fiscal year 2010, with the lowest number (13) coming in fiscal year  2014. Several agencies, including the Departments of Education, Housing  and Urban Development, and Labor, the Federal Reserve Board, and the  Office of Science and Technology Policy, reported receiving 1 correction  request during the 5-year period.
Three agencies— the Departments of Health and Human Services (HHS)  and Interior (Interior) and EPA—received 70 percent (61 of 87) of the  correction requests during fiscal years 2010 through 2014. These three  agencies were also the only ones that reported receiving IQA correction  requests during each of the 5 fiscal years. For the entire period, Interior  received the highest number of correction requests (26), followed by EPA  (21), and HHS (14).
IQA officials at several agencies told us that they receive relatively few  IQA requests and provided a number of reasons. For example, EPA  officials stated that the quality of data EPA disseminates is currently more  robust due to the consideration of the diversity of viewpoints provided by  the public and EPA’s opportunity to review pertinent information that may  not have been previously considered during the pre-dissemination  process. Department of Commerce (Commerce) officials attributed their  agency’s low number of IQA requests to the fact that the agency has few  highly influential scientific assessment projects and that most of its  research is relatively noncontroversial, with the exception of research  related to climate change. HHS officials said that it is not surprising that  IQA administrative corrective mechanisms are not resulting in a large  number of IQA correction requests because many correction requests are  for minor edits to agency information. A former OIRA administrator opined  that when several federal courts held that the IQA is not subject to judicial  review, most of the momentum behind IQA was lost, and that, as a result  of these rulings, outside parties do not submit very many IQA correction  requests.
In August 2004, the OIRA Administrator issued a memorandum to the  President’s Management Council directing that agencies post all  information quality correspondence, including a copy of each correction  request, the agency’s formal response(s), and any communications  regarding appeals on agency web pages to increase the transparency of  the process. The memorandum also directed agencies to provide a few  sentences describing the request and any subsequent responses. Finally,  the memorandum stated that agencies also needed to establish  processes for updating their information quality web pages regularly. In  addition to posting copies of the IQA correction requests on their  websites, agencies are required to report the number and nature of  correction requests the agency receives to the Director of OMB and how  such requests were resolved. OMB has provided a summary of this  agency-reported IQA data since its implementation in annual reports to  Congress since 2003.
We found discrepancies between the IQA data we found on agency  websites and the IQA data reported to OMB by agencies. Eight  agencies who reported receiving IQA correction requests did not post on  their website the same number of IQA correction requests that they  reported to OMB. In most instances where we identified discrepancies,  the number of IQA correction requests agencies posted on their websites  was lower than the number of IQA correction requests they reported to  OMB. Table 2 provides specific numbers of discrepancies in IQA  correction requests received for fiscal years 2010 through 2014.
One CFO Act agency, the Department of Transportation, reported to  OMB that it had received an IQA correction request, but did not post the  IQA correction request on its website as of November 2015. As stated  earlier, OMB guidance requires agencies to post correction requests and  agency responses on their websites. OMB staff told us that they issue an  annual data call to agencies requesting information on IQA correction  requests received. According to OMB, agencies are expected to  accurately report their IQA activities, including the number of requests  received. OMB staff stated that if there are discrepancies between what  OMB received from agencies and what the agencies post on their  websites, then there is a miscount or a disconnect on the agency side.  Although OMB’s guidance is not prescriptive on the time frames for  agencies to post this information, it states that agencies need to establish  “processes for updating their information quality web pages on a regular  basis.” OMB staff told us that some agencies posted correction requests  and responses online soon after sending out the agency responses. For  example, HHS officials told us that they post correction requests soon  after they are received and do not wait until a response is prepared.  According to OMB staff, other agencies waited until the end of the fiscal  year to post all relevant documents at the same time. In addition, they told  us that agencies often have changes in the staff assigned to report IQA  data to OMB that may contribute to late postings, and although the data  are eventually posted online, they are sometimes provided months after  the request was received and responded to.
Agency officials from the six agencies that we selected for further review  offered various explanations concerning their data discrepancies,  including the time frames for online postings of IQA data. For example,  officials from the Department of Agriculture (USDA) stated that the  agency does not specify time frames for posting correction requests.  However, USDA officials stated that, in response to our inquiries, moving  forward the agency will require its component agencies and staff offices  to post all correction requests and their responses to their component  agency’s website no later than 60 days after the correction requests are  received. USDA officials stated that each component agency maintains its  own website and updates it accordingly. Since we initially contacted  USDA concerning the data discrepancies, USDA officials have informed  us that the Food and Nutrition Service and Rural Development  component agencies have updated their websites to reflect the number of  correction requests received. In addition, the officials stated that the  Forest Service, the Office of the Inspector General, and the Animal and  Plant Health Inspection Service are in the process of making the  necessary updates to their websites.
Officials from EPA stated that their discrepancy we identified was a result  of a joint correction request sent to both OMB and EPA where OMB  served as the lead agency. Thus, OMB posted the correction request on  its website rather than EPA, but EPA included the correction request in its  total IQA request number for fiscal year 2013 to OMB. Interior officials  told us that they have not designated specific time frames for posting  correction requests online. They explained, however, that one of their  component agencies recently split into two separate agencies and as a  result, one of these agencies is in the process of developing its own  information quality program. According to agency officials, this component  agency received and responded to a 2014 IQA correction request, but as  of October 2015 had not posted the information on its website. Interior  officials stated they expected the data discrepancy issue we identified to  be resolved by the end of this fiscal year. OMB staff agreed that agencies  sometimes have challenges in accurately and timely reporting and  posting IQA corrections requests received and that they are  communicating with agencies to address any discrepancies.
A 2009 OMB memorandum on open government states that, the “timely  publication of information is an essential component of transparency.”  The memorandum adds that “delays should not be viewed as an  inevitable and insurmountable consequence of high demand.” However,  the memo does not provide guidance on what is considered timely  publication. We found that 3 of the 9 agencies that reported fiscal year  2014 correction requests to OMB had not posted IQA correction requests  and responses a year or more after the end of the fiscal year. Timely  reporting of IQA data would increase the transparency of the process and  allow the public to view all current correction requests, agency responses  to those requests, and any appeals. Doing so would also allow the public  to track the status of correction requests that may be of particular interest.
subsections: section_title: Sources of IQA Correction Requests Varied
paragraphs: In our review of the written correction requests received by the agencies,  we found that most requesters who submitted IQA correction requests  self-identified as part of the submission process. As shown in table 3, we  found that during fiscal years 2010 through 2014, 58 percent (50 of 87) of  the correction requests originated from trade associations and advocacy  organizations. Trade associations that submitted correction requests  represented several different types of industries including, for example,  the Western Energy Alliance which represents more than 450 companies  engaged in exploration and production of oil and natural gas in the West,  and the Pacific Coast Shellfish Growers Association whose membership  is composed of shellfish growers in California, Oregon, Washington,  Alaska and Hawaii. Advocacy organizations represented several different  interests, including the San Juan Citizens Alliance, which is concerned  with public land issues, and the Washington Area Bicyclist Association,  whose mission is to create a healthy, more livable region by, among other  things, promoting bicycling for fun, fitness, and affordable transportation.  Private citizens submitted the next largest number of correction requests  at 18 percent (16 of 87). We found that each of the 4 IQA correction  requests submitted to the Federal Communications Commission  originated from private citizens. Businesses, such as electricity producer  PacifiCorp, submitted 15 percent (13) of the IQA correction requests.  Local governments, such as California’s County of Siskiyou Board of  Supervisors submitted 7 percent (6) of the correction requests. Each of  the 6 IQA correction requests submitted by local governments was  directed to Interior.
There were 68 different requesters among the 87 IQA correction requests  received during fiscal years 2010 through 2014. Although the majority of  requesters submitted 1 request, several submitted more. Of those  requesters submitting multiple requests, 6 submitted requests to more  than one agency. For example, Public Employees for Environmental  Responsibility, an advocacy organization, submitted 6 correction requests  in total: 2 to EPA, 1 to Commerce, 1 to the Consumer Product Safety  Commission (CPSC), 1 to the General Services Administration, and 1 to  Interior during fiscal years 2010 through 2014.
section_title: The Majority of IQA Correction Requests Questioned Agencies’ Use of Data
paragraphs: We analyzed each of the 87 IQA correction requests posted on agencies’  websites and categorized the requests into two categories—data and  administrative. The majority of correction requests received by the 16  agencies during fiscal years 2010 through 2014 (66 of 87 requests, or  about 76 percent) questioned either agencies’ use of underlying data or  agencies’ interpretation of the data. The following IQA requests received  by agencies from fiscal years 2010 through 2014 illustrate the diversity of  IQA correction requests involving data.
On November 12, 2013, an advocacy organization stated that CPSC  disseminated a product recall announcement based on inaccurate  data; specifically claims of defects in design, warnings, and  instructions. Among other things, the requester asked that CPSC  disclose the statistical and scientific metrics used to determine that  the subject posed “a very serious hazard.” On March 13, 2014, CPSC  stated that the nature of the correction request was the subject of an  ongoing adjudicative proceeding. Thus, CPSC made no corrections.
On June 11, 2010, a trade association sent a correction request to  both EPA and the Department of Housing and Urban Development  (HUD) on, among other things the accuracy of data used in a public  service advertising on childhood lead poisoning prevention. It  requested that both agencies withdraw their participation in and  sponsorship of the advertisements. On December 30, 2011, EPA and  HUD issued a joint response letter stating that the quality of the  information included in the childhood lead prevention advertisements  was thoroughly reviewed. Thus, neither agency made corrections.
We found that some IQA correction requests (18 of 87 or 21 percent)  were administrative in nature. Examples of these correction requests  include, among other things, typographical changes or other text revisions  to update agency documents and websites.
On December 23, 2010, a private citizen submitted a correction  request identifying patent images that he believed to be incorrectly  labeled with another patent number in an online database. He  requested that the U.S. Patent and Trademark Office within the  Department of Commerce (Commerce) correct the images. On  January 6, 2011, that office stated the requested correction had been  made in full, and that the correct patent had been rescanned and  reloaded to the database.
On November 14, 2011, a business submitted a correction that  identified two errors—a typographical error and the omission of  information to a Final Rule published in the Federal Register—and  requested that EPA make corrections to both. On February 14, 2012  EPA agreed with the typographical error and stated that a data table  was inadvertently removed from the published information. EPA  stated that it was preparing a regulatory fix intended to reinstate the  portions of the table that were inadvertently removed from the final  rule.
section_title: Agencies Determined No Corrections Were Warranted for the Majority of IQA Correction Requests
paragraphs: Of the 87 IQA correction requests agencies received, agencies  determined in 59 cases (68 percent) that the request did not warrant any  change to the original document or data in question (see table 4).  Agencies made full corrections in 11 cases and made partial corrections  for 15 of the IQA correction requests received. Two correction requests  were still pending as of November 2015.
The IQA correction mechanism includes procedures for requesters to  appeal initial agency decisions. During fiscal years 2010 through 2014,  requesters appealed agency decisions in 19 IQA cases. IQA guidelines  allow requestors to file for reconsideration if they disagree with an  agency’s initial response. Of the 19 appealed cases, agencies made no  corrections to 15, rejected 1 because the appeal was not submitted within  the specified time frame, dismissed 1 as it was withdrawn by the  requester, and had not made final decisions in the last 2 cases as of  November 2015.
section_title: Processes Other than IQA are Available to the Public to Request Corrections of Agency Information
paragraphs: IQA is one of several processes available to the public for requesting  corrections of agency information. In addition to IQA, other administrative  mechanisms for correcting information available to the public include  notice-and-comment rulemaking and peer reviews. We previously  reported in 2006 that some agencies had the flexibility to respond to  correction requests through various processes, because those processes  were in place prior to IQA. For example, we reported that the Federal  Emergency Management Agency no longer classified requests to correct  flood insurance rate maps as IQA requests. Instead, the agency  addressed flood insurance rate map correction requests by using a  correction process it had implemented prior to the enactment of IQA.
In this review, we found that one-fourth (15 of 59) of the IQA correction  requests that resulted in no corrections were processed through an  administrative mechanism other than the dedicated IQA request for  correction process. According to OMB staff, agencies may respond to  correction requests through the applicable administrative process. For  example, agencies may process correction requests using notice-and- comment for rulemaking under the Administrative Procedure Act in  instances where the request concerns a proposed rule and the comment  process is still open. Processing such requests under IQA, as we  reported in 2006, could impact rulemaking outside of the rulemaking  process by affecting when or if an agency initiates a rulemaking. The  following is an example of an agency response to a correction request  submitted under IQA that the agency determined should be addressed  through the rulemaking process:
On July 1, 2010, a non-profit organization submitted a request to EPA  to “rescind and correct online and printed information regarding  alleged greenhouse gas emissions reductions resulting from  ‘beneficial use’ of coal combustion waste products.” On February 16,  2011, EPA responded that many of the specific documents in  question served as background technical support materials for EPA’s  proposed rulemaking to address the risks from the disposal of coal  combustion residuals generated by electric utilities and independent  power producers. As a result, the agency would address the issues of  the correction request through the rulemaking process for the rule.
The peer review process allows the public an opportunity to provide  comments and to question an agency’s use of data before it actually  disseminates the information. The following is an example of an agency  response to a correction request submitted under IQA that EPA  determined should be addressed through public comments during the  peer review process.
On August 20, 2010, EPA received a correction request from a private  citizen requesting EPA to, among other things, correct information  used to develop the Draft Benthic Total Maximum Daily Load  Development for Accotink Creek, Virginia. On November 15, 2010,  EPA responded that the public comment response process would be  used to address the concerns outlined in the correction request. EPA  stated that all public comments would be considered during the  revision of the draft document. EPA also stated that to “avoid  duplicate actions that would interfere with the ongoing Total Maximum  Daily Load Development process, we will not use the EPA Information  Quality Guidelines Request for Correction process to respond” to the  correction request.
The public may not be aware of the different administrative processes  agencies have available to address correction requests submitted under  IQA. As a result, agencies’ IQA staff may be tasked with responding to a  number of correction requests outside of the dedicated IQA request for  correction process. Including explanations and links on agencies’ IQA  websites to other available correction processes that might be more  appropriate to the public’s needs could help increase efficiencies for all  available information correction processes. Although OMB staff told us  that agencies should, in their response to public correction requests, state  whether those agencies plan to address the requests through other  administrative processes, current OMB IQA guidance does not address  this issue. However, we found that at least one agency has included in its  online IQA guidance information for submitting correction requests  outside of IQA. EPA included additional information on its IQA web page  that informs the public on how to report and correct EPA website data  errors as well as how to seek correction on information for which EPA has  sought public comment.
Agencies cited other reasons for not addressing a number of correction  requests submitted under IQA. These included requests related to cases  under litigation, requests too broad in nature (not specific), and requests  the agencies deemed to lack merit. In addition, agencies did not  recognize correction requests where the data in question were contained  in a document not subject to IQA (such as a press release or a document  not created by the agency). Specific examples follow.
In 2011, a private citizen requested the National Oceanic and  Atmospheric Administration (NOAA), which operates within  Commerce, to modify information about the location where Tropical  Storm Kirsten made landfall in 1966 in Mexico. NOAA responded that  the information in question was not subject to the requirements of IQA  as the data were considered to be archival (data disseminated by  NOAA before October 1, 2002, are considered to be archival  information).
On March 30, 2011, an advocacy organization submitted a request to  the National Park Service, which operates within Interior, to correct  information that the requestor deemed as “unfounded scientific  conclusions” in a report on allegations of scientific misconduct at Point  Reyes National Seashore. On June 6, 2011, Interior responded that  the document in question was a report of an investigation undertaken  by the Office of the Solicitor. The investigation looked to resolve  allegations of scientific misconduct on the part of employees. Also, the  “report was generated as part of the adjudicative process of this  personnel matter; it is not subject to review under the IQA.”
section_title: OMB and Agencies’ IQA Guidelines and Related Information Is Generally Available Online, but Usability Varied
subsections: section_title: OMB Makes IQA Information, Including Agency-Reported Data, Publicly Available; However Data Are Not Centrally Located
paragraphs: OMB staff told us they rely heavily on their own website to disseminate  IQA, OMB-specific, and government-wide guidance. OMB’s information  quality website includes guidelines from OMB that describe its policy for  ensuring the quality of information that it disseminates to the public. The  guidelines also establish the administrative procedure by which an  affected person may obtain correction of information disseminated by  OMB. In addition, OMB includes links the public and other interested  parties can use to locate individual agency information quality guidelines,  government-wide information quality guidelines, and OMB’s annual  reports to Congress. OMB’s reports to Congress, included on a separate  OMB web page from IQA guidelines, include brief updates on agency  reporting under the government-wide information quality guidelines.
As we previously stated, agencies are required by IQA to report to OMB  annually on the number and type of correction requests received, as well  as their respective responses. Although not required, since 2003 OMB  has published agency-reported IQA data from the previous fiscal year in  an annual report to Congress. OMB also makes this information available  on its website but the data are dispersed across multiple web pages  which could make the information hard to find and could contribute to  user confusion. For example, OMB provides links to the annual reports on  its website where the public and interested parties may access the  information (see figure 1). However, there is no central location on OMB’s  website where the IQA data are located, for example, in a table or some  other format by year or agency. Instead, interested parties would need to  go to each separate annual report link, search for IQA data, collect the  data, and create their own table to review IQA data government-wide  from year to year.
Enabling the public to better access information is one of the principles of  the President’s digital government strategy. According to the strategy, the  federal government must fundamentally shift how it thinks about digital  information. To drive this shift, agencies must, among other things, be  customer-centric to focus on customer needs. This means that quality  information should be accessible, current, and accurate at any time.  Federal digital services guidelines direct agencies to publish digital  information so that it is easy to find and access. These guidelines are  aimed at helping federal agencies improve their communications and  interactions with customers through websites. Although OMB has made  government-wide IQA data available in its reports to Congress, finding  and compiling such information may take several steps, potentially  making it more difficult to access and find, thus hindering transparency.  OMB officials acknowledged that consolidating and centralizing IQA  information on OMB’s website could improve transparency and access to  its IQA data.
section_title: Agencies Posted Required IQA Guidelines and Data Online as of November 2015 but the Usability Could Be Improved
paragraphs: In addition to posting correction requests and agency responses on  agency websites, agencies are required by IQA to post their IQA  guidelines and administrative mechanisms by which affected persons  could petition for correction of inaccurate agency information. Twenty- eight of 30 agencies posted the required IQA documents online as of  November 2015. However, the Department of Defense did not include  administrative mechanisms on its website. In addition, we were unable to  find the Federal Housing Finance Agency’s IQA guidelines anywhere on  its website. OMB concurred with our review of these agencies’ IQA  information and told us it would work with the agencies to improve the  information provided on their websites, but as of December 2015, they  had not completed that process. Until that step occurs, the public may be  unaware of the steps the agencies would take upon receiving a correction  request, or even how to submit a correction request.
In addition to the required IQA information, some agencies’ websites  included additional features that reflect customer-centric leading web  practices identified by the President’s digital government strategy such as  posting IQA information on a single website to ease accessibility and  identifying points of contact online. For example, the Department of  Labor’s website includes points of contact at its 21 component agencies.
Such information enables the interested public with questions regarding  IQA to more easily identify agency officials (see figure 2).
OMB’s guidance on posting IQA correction requests states that agencies  need to establish processes for updating their information quality web  pages on a regular basis but does not define regular basis. We identified  agency websites where information was outdated or web links were  broken. Specifically, 9 of 30 agencies posted either outdated information  or included broken hyperlinks (see figures 3 and 4). Consequently, the  public may be unable to access these agencies’ IQA guidelines and  correction requests. Ensuring that online content is accurate is one of the  guidelines for federal digital services. Easy access to current guidance  could also facilitate opportunities for affected parties and stakeholders to  provide feedback on those documents.
We identified five agencies that did not include on their websites any  information about IQA correction requests. As a result, it is not clear by  reviewing these agencies’ websites whether or not the agencies had  received such requests during fiscal years 2010 through 2014.  Specifically, we could not identify any language stating whether or not the  Departments of Energy, Homeland Security, Justice, and Transportation,  and the Office of Personnel Management had received correction  requests as of November 2015. In addition, we found that as of  November 2015:
The Consumer Product Safety Commission’s website included links to  the IQA correction requests the agency had received. However, there  was no text indicating whether or not the agency had received IQA  corrections requests for years where no correction requests were  posted or whether that information was simply missing.
The Department of Agriculture’s website included links to IQA data  reports for fiscal years 2010 through 2013, but had no information  regarding fiscal year 2014.
The Department of Housing and Urban Development’s website did not  include IQA data reports for fiscal years 2012 through 2014.
The Federal Housing Finance Agency’s website did not include IQA  information for fiscal year 2014.
As noted earlier, OMB’s guidance states that agencies also need to  establish processes for regularly updating their information quality  websites. However OMB staff told us that if an agency has not received  any IQA requests in a given fiscal year, they are not required to report  that information on their websites. Without that acknowledgement  however, it may be unclear to the public whether an agency has received  IQA correction requests but has not posted them or whether the agency  has in fact not received any requests. OMB staff agreed that clearly  stating whether or not agencies had received IQA correction requests  could improve the transparency of IQA. Even when agencies posted IQA  information on their website as OMB required, such information is  sometimes outdated making it difficult for users to know whether agencies  have received correction requests or how to request correction of agency  information. OMB staff acknowledged that additional OMB guidance that  specifies time frames for agencies to post information on IQA requests  received, requires explanations and links to other agency information  correction processes, and provides suggestions for improving the  usability of agency websites would be useful.
section_title: Selected Agencies Have Processes in Place to Implement IQA and Officials Reported Challenges and Benefits
paragraphs: Agency officials at six selected agencies—the Departments of Agriculture  (USDA), Commerce, Health and Human Services (HHS), Interior, and  Transportation, and the Environmental Protection Agency (EPA)—took a  range of actions as part of their efforts to implement the IQA correction  process and to better track and address correction requests received,  such as the following examples.
According to EPA officials, EPA’s centralized IQA process has  provided greater oversight on correction requests from receipt to final  response. EPA has developed internal process maps that outline the  steps needed to address correction requests. Once EPA receives a  correction request, EPA officials enter the request into a tracking  database. Then, an acknowledgement receipt is dispersed. EPA  officials then identify who within the agency is responsible for the  information in question, and forward the request to the appropriate  program office or region that schedules scoping meetings to review  the request and draft a response. In the meantime, EPA notifies OMB  of the correction request.
The Department of Health and Human Services (HHS) also has a  centralized IQA correction process. The agency’s Office of the  Assistant Secretary for Planning and Evaluation in the Office of the  Secretary manages and coordinates the IQA process and administers  the HHS information quality website and is the agency’s point of  contact with OMB. The HHS component or office within HHS that  originated the challenged information is responsible for developing  and sending the agency’s response.
Interior’s IQA correction process is decentralized. Within each of  Interior’s component agencies, Bureau Information Quality  Coordinators address IQA correction requests and coordinate with  Interior’s Information Quality Coordinator on the response.
Officials from 3 of the 6 selected agencies also reported challenges in  implementing IQA. Department of Transportation officials told us it has  been a challenge to retain IQA institutional knowledge amidst staff  turnover. EPA and Interior officials both stated that allocating the  necessary time to properly respond to IQA correction requests was  challenging. For example, EPA officials said that the amount of time it  takes to respond to a correction request can take an appreciable part of a  full-time employee’s efforts during busy periods. EPA officials said  additional review time and attention are required because responses to  corrections must be reviewed through EPA’s internal processes for  concurrence, as well as with OMB. Interior officials also told us they  spend a considerable amount of time addressing the often complex  and/or lengthy IQA requests as well as obtaining the necessary reviews  and concurrence of the agency response.
We found that agency responses to IQA requests and an appeal have  taken 2 years or longer to resolve. Although both EPA and Interior  officials cited time spent in addressing correction requests to be a  challenge, neither agency was able to provide estimates of agency or  employee hours spent in the process. Further, none of our selected  agencies had information about the actual workload or the number of staff  days for responding to IQA correction requests. As a result, the impact of  the IQA correction process on the selected agencies could not be  accurately measured because the agencies do not have mechanisms in  place to track the effects of implementing IQA. We previously reported  that agency IQA officials believe 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 on  specific issues or linking work exclusively to IQA requests would be  difficult.
According to OMB staff, there is not a specific amount of time that is  considered too long for agency responses to correction requests. They  explained that IQA correction requests may take a long time for some  agencies due to the extensive review that is required to make a final  agency decision. OMB staff stated that they did not want to be  prescriptive in IQA guidance by adding administrative time requirements  to an agency specific process. The officials added that taking a long time  to respond to an IQA correction request was not necessarily a bad thing.  It may indicate an extensive and comprehensive review by the agency  and discussion of the information in question.
Officials at our selected agencies told us they believe IQA has improved  the quality of data disseminated by their agencies. For example, EPA  officials told us that the quality of data disseminated by EPA is more  robust due to the consideration of the diversity of viewpoints provided by  the public, and the agency’s opportunity to review pertinent information  that may not have been obtained by EPA. Interior officials reported to us  that the IQA and peer review standards have greatly assisted in the  dissemination of quality information. They stated that their guidelines give  “teeth” to the objectives and requirements of quality information.  According to HHS officials, the IQA process has proved to be a useful  mechanism for the public to raise issues of concern to federal agencies  that publicly disseminate information. OMB staff told us that the IQA  process has improved agency information quality policies even though  the correction request metrics may not show it. They explained that while  it’s important for IQA correction numbers to be seen by the public, it is  also important that the public is aware that these numbers are only a  small piece of the benefits of IQA. IQA guidelines and peer reviews are all  about pre-dissemination review, transparency, and ensuring that only  information with good quality is released by agencies.
section_title: Conclusions
paragraphs: IQA allows businesses, trade associations, advocacy organizations, the  public, and others to submit requests to agencies to make corrections to  agency disseminated information. Some of the 30 agencies in our review  reported receiving relatively few IQA requests from fiscal years 2010  through 2014. Agencies determined that the majority of correction  requests received did not warrant any changes. Processes other than  IQA are available to request corrections of agency information and  agencies addressed a number of correction requests through  administrative mechanisms other than the dedicated IQA request for  correction process.
Agencies in our review have developed their own guidelines and  administrative mechanisms for implementing IQA. OMB and agencies rely  on their websites to disseminate guidance and also provide information  regarding results of correction requests. However, we found that OMB  had not consolidated all IQA data in one centralized location on its  website. We also found instances where IQA required information was  missing from agency websites or where information was outdated or  incomplete. To be effective, guidance documents should be accessible to  their intended audiences and corrective processes should be transparent.  This is consistent with guidelines for federal digital services. OMB has the  opportunity to build on its efforts to improve the transparency of the IQA  process. For example, by consolidating summaries of agency IQA  information, working with agencies to ensure all IQA requirements are  met, and providing additional guidance about posting accessible, user- oriented information on agency websites, OMB could help increase the  public’s access to and confidence in that information, thereby helping to  further the goal of disseminating quality information.
section_title: Recommendations for Executive Action
paragraphs: To better ensure agencies fulfill their requirements, including  implementing IQA guidelines and helping to promote easier public access  to IQA information on agency websites, we recommend that the Director  of OMB take the following actions:
Consolidate and centralize on OMB’s IQA guidance website a  government-wide summary of requests for correction submitted under  the IQA.
Work with the Department of Defense and the Federal Housing  Finance Agency to help ensure that they post their IQA administrative  mechanisms and IQA guidance online.
Provide additional guidance for agencies to help improve the  transparency and usability of their IQA websites to help ensure the  public can easily find and access online information about agency IQA  implementation. Such guidance should include specific time frames for agencies to post information on the IQA  correction requests they have received, including making it clear  when agencies have not received IQA requests; instructions for agencies to include a statement on their IQA  websites that the agencies may address correction requests  through other administrative processes;  instructions for agencies to include, when responding to correction  requests, whether those agencies plan to address the request  through another administrative processes, and if so, which  process they will use; and suggestions for improving usability of agencies’ websites including  fixing broken links.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Director of the Office of  Management and Budget. In oral comments received on December 1,  2015, OMB staff discussed our findings, conclusions, and draft  recommendations. They provided technical comments, which are  incorporated into the report where appropriate. In response to this  discussion, we made minor revisions to the draft and recommendation  language to more accurately reflect the role of agencies in responding to  correction requests along with OMB’s role in overseeing these activities.  The OMB staff stated they agreed with our modified recommendations.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the Director of OMB and  other interested parties. In addition, the report will be available at no  charge on the GAO website at www.gao.gov.
If you or your staff have any questions about this report, please contact  me at 202-512-2757 or GoldenkoffR@gao.gov. Contact points for our  Office of Congressional Relations and Public Affairs may be found on the  last page of this report. GAO staff who made key contributions to this  report are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: The objectives of this study were to (1) identify the number, source, and  final disposition of IQA correction requests received by the 24 Chief  Financial Officer (CFO) Act and other agencies for fiscal years 2010  through 2014; (2) assess the extent to which the 24 CFO Act and other  agencies that received correction requests made IQA information publicly  available; and (3) identify how selected agencies have implemented IQA.
To address the first objective, we searched the websites of the 24 Chief  Financial Officer (CFO) Act agencies and identified 10 of these that had  posted correction requests and responses online for fiscal years 2010  through 2014. We selected 2014 as an ending point for a 5-year analysis  because 2014 was the most recent, complete fiscal year of data  available. To identify other agencies that had received correction requests  during the same time frame, we reviewed the Office of Management and  Budget’s (OMB) annual reports to Congress for fiscal year 2010 through  fiscal year 2013 and identified those agencies outside of the 24 CFO Act  agencies that reported receiving Information Quality Act (IQA) correction  requests. OMB provided us with agency-reported data for fiscal year 2014  because the report to Congress had not yet been issued. From this, we  identified an additional 6 non-CFO Act agencies that posted IQA  correction requests and responses on their websites—the Consumer  Product Safety Commission, Federal Communications Commission,  Federal Housing Finance Agency, Federal Reserve Board, Office of  Management and Budget, and the Office of Science and Technology  Policy. We reviewed relevant OMB and agency documents, including  IQA guidelines and agencies’ annual reports to OMB, examined requests  and appeals to correct agency information, and reviewed OMB’s and  agencies’ websites. To supplement the documentary evidence obtained,  we interviewed agency officials responsible for IQA in their respective  agencies. We also interviewed current and former OMB staff to provide  additional context on IQA. During the course of our review, we compared  agency IQA data posted on their websites with IQA data agencies  reported to OMB and identified discrepancies. We discussed the  discrepancies with OMB staff and agency officials and included their  responses within the report. We determined that OMB and agency data  were sufficiently reliable to provide a general indication of the numbers of  correction requests received. Although agencies have other processes to  correct agency disseminated information, we evaluated only information  related to the IQA correction mechanism.
We assessed relevant agency IQA documents—including guidelines,  requests and appeals, agency decisions, and related documents—found  on the 16 agency websites that posted correction requests during our  identified time frame. To supplement and verify the accuracy and  completeness of this information, we interviewed OMB IQA staff.  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 all of the correction requests posted on agency  websites to the extent such information was available online. Two  analysts independently assessed each agency’s correction request and  final agency response to determine requester type, request category,  agency response and justification for response, and resolved all  discrepancies. To categorize the sources of the requests by type of entity,  such as business, trade association, or advocacy organization, we relied  on information and descriptions the requester provided in the correction  requests. Specifically, the majority of requesters self-identified as one of  the following types of requesters—trade association/advocacy  organization, business, private citizen, local government, or anonymous— in their correction requests to the agencies. However, when such  information was not available, we searched the requester’s name online  and used the descriptions found therein to make our determination as to  the type of entity. To determine the final disposition of IQA requests and  any appeals, we reviewed related agency documents, including interim  agency correspondence, to determine whether or not the agency  committed to make a correction(s) in response to the request. We  determined a correction was a partial correction if the agency made at  least one change based on the request, for example adding clarifying  language or additional references.
To address the second objective, we conducted an analysis of the 24  CFO Act agencies’ websites, as well as the six other agencies identified  in objective one as having received IQA correction requests during our  selected timeframe, using internal site search engines and search terms,  such as “information quality,” “correction request,” and “IQA guidelines,”  to determine whether they had IQA guidelines and other IQA information  online. We identified and used IQA search terms and steps to review and  find information on agency publicly available web pages consistent with  best practices guidance for search engine optimization from  digitalgov.gov’s website. We also used OMB’s Open Government  Directive in assessing IQA guidance documents. We compared the  information found on the websites to IQA requirements outlined in OMB  guidance to agencies on posting IQA documents. We also reviewed other  OMB and relevant government guidance on design features to make  government-wide information and data accessible. When we found  instances where agencies had not posted the required guidelines or  administrative mechanisms, we contacted OMB staff for verification.
To identify IQA processes and challenges agencies face in implementing  IQA, we selected a non-generalizable sample of six agencies -– the  Departments of Agriculture, Commerce, Health and Human Services,  Interior, and Transportation, and the Environmental Protection Agency -–  to obtain illustrative examples of how they approached and implemented  IQA. We selected these agencies based in part on the number (both high  and low to include a range) of IQA correction requests the agencies had  received from fiscal years 2010 through 2014. We also included one  agency (Department of Transportation) based on the relatively high  number of peer reviews conducted during the same time frame. We  interviewed OMB and agency officials responsible for addressing IQA  correction requests to gather their perceptions on the overall IQA  process.
We conducted this performance audit from November 2014 to December  2015 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objective.
section_title: Appendix II: Organizations That Filed Information Quality Act Correction Requests during Fiscal Years 2010 through 2014
paragraphs: Appendix II: Organizations That Filed  Information Quality Act Correction Requests  during Fiscal Years 2010 through 2014 Federal agency receiving request and filer  Consumer Product Safety Commission  Public Employees for Environmental Responsibility  Public Employees for Environmental Responsibility  The Association of Proprietary Colleges  Department of Health and Human Services  Capital Strategy Consultants, Inc.
Center for Regulatory Effectiveness (2)
International Premium Cigar and Pipe Retailers     Association  Styrene Information and Research Center (2)
Federal agency receiving request and filer  Pacific Coast Shellfish Growers Association  Pavement Coatings Technology Council (2)
United States Association of Reptile Keepers and Pet  Industry Joint Advisory Council  Western Energy Alliance (2)
Environmental Protection Agency  American Coatings Association  American Chemistry Council (2)
Artisan EHS Consulting, LLC  The Competitive Enterprise Institute and ActionAid  USA  Halogenated Solvents Industry Alliance, Inc.
International Platinum Group Metals Association  Organic Arsenical Products Task Force and Wood  Preservative Science Council  Public Employees for Environmental Responsibility  (2)
U.S. Chamber of Commerce (2)
Walter Coke, Inc.
W.R. Grace & Co. Conn.
section_title: Appendix III: Contacts and Staff Acknowledgments
subsections: section_title: GAO Contact
paragraphs: Robert Goldenkoff, (202) 512-2757 or goldenkoffr@gao.gov.
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Clifton G. Douglas, Jr. (Assistant  Director), Dewi Djunaidy (Analyst-in-Charge), Joseph Fread, Lisette  Baylor, Michele Fejfar, Ellen Grady, Farrah Graham, Andrea Levine, and  Stewart Small made key contributions to this report.