Information Quality

Process

14.5.1 Information Review Process

As a matter of good and effective information resources management, Bureaus and the Departmental Offices should develop processes for reviewing the quality (including the objectivity, utility, and integrity) of information before it is disseminated.

• Treat information quality as integral to every step of the development of information, including creation, collection, maintenance, and dissemination.
• Substantiate the quality of the information disseminated through documentation or other means appropriate to the information.

14.5.2 Information Collection Process

It is important that Treasury bureaus make use of OMB's Paperwork Reduction Act (PRA) clearance process to help improve the quality of information that the Department collects and disseminates to the public. Treasury bureaus are already required to demonstrate in their PRA submissions to OMB the "practical utility" of a proposed collection of information the bureau plans to disseminate. Additionally, for all proposed collections of information that will be disseminated to the public, Treasury bureaus should demonstrate in their PRA clearance submission to OMB that the proposed collection of information will result in information that will be collected, maintained, and used in a way consistent with the OMB and Treasury information quality guidelines.

14.5.3 Administrative Complaint Mechanism

Section 515 requires each agency to develop an administrative mechanism for receiving complaints and appeals regarding information quality. Using the administrative mechanism, affected persons can seek, and obtain where appropriate, timely correction of information that does not comply with OMB, Treasury or Bureau guidelines. These administrative mechanisms shall be flexible, appropriate to the nature and timeliness of the disseminated information, and incorporated into agency information resources management and administrative practices. Conduct both elements (complaint and appeal) of the administrative mechanism within the Bureau (or the Departmental Office), which disseminated the information.

Overall, OMB and Treasury do not envision administrative mechanisms that would burden agencies with frivolous claims. Instead, the correction process should serve to address the genuine and valid needs of Treasury and its constituents without disrupting agency processes. In making determinations of whether or not to correct information, bureaus may reject claims made in bad faith or without justification. They are required to undertake only the degree of correction that they conclude is appropriate for the nature and timeliness of the information involved and explain such practices in their annual fiscal year reports to Treasury.

A. Complaint Process

Treasury Bureaus and the Departmental Offices should respond to complaints and/or requests for correction in writing within 60 calendar days of receipt. If the complaint requires an extended period of time for processing, the agency must notify the petitioner. The agency must develop or identify the initial administrative complaint process for affected persons to seek and obtain correction of information that does not comply with OMB or Treasury Guidelines. The process should specify the name and address of the organization responsible for evaluating and responding to requests for correction of information disseminated. The process should meet designated timeframes for requests, evaluations, and agency response and should identify what is required from a petitioner, such as:

• Description of the information deemed to need correction.
• Manner disseminated and date of dissemination.
• Specific error(s) cited for correction and proposed correction or remedy.
• Specific manner in which the information does not comply with OMB or Treasury Guidelines.
• How the person was affected and how correction would benefit them.
• Petitioner's contact information for the agency reply on whether and how correction will be made.

B. Administrative Appeal Process

Treasury Bureaus and the Departmental Offices should develop an administrative appeal process in the event a petitioner is not satisfied with the reply. This right to an appeal should be included in the notice of denial issued during the complaint process.

After the petitioner receives a response or decision from the agency on a complaint, the incumbent must send their appeal of the ruling within 45 workdays in accordance with the instructions in the initial agency reply. The agency must respond to appeals and/or requests for correction in writing within 60 calendar days of receipt. If the response requires an extended period for processing, the agency must notify the petitioner. The bureau (or the Departmental Office) appeal process must include a final judgment by an official independent from the initial response.

C. Information on which the Agency Requested Public Comments

In some cases, a bureau may disseminate a study, analysis, or other information in connection with the issuance of a notice of proposed rulemaking or other action that involves well-established procedures for obtaining, considering, and responding to comments from the public. In most cases, comments concerning the quality of the disseminated information can be addressed through these procedures, such as by responding to a request for correction of the information in the preamble to a final rule. However, in unusual circumstances, it would be appropriate for a bureau to address such comments at an earlier time pursuant to these guidelines. For example, the procedures of these guidelines should be used if the commenter has shown a reasonable likelihood of suffering actual harm if the comment is not resolved before issuance of the final action and the bureau determines that resolving the matter pursuant to these guidelines will not unduly delay the final action.