Guidelines for Ensuring the Quality of Information Disseminated to the Public
K. Office of the Secretary
Office of the Assistant Secretary
for Planning and Evaluation
I. � Office Mission
The Assistant Secretary for Planning and Evaluation
(ASPE) advises the Secretary of the Department of Health and Human Services
on policy development in health, disability, human services, and science,
and provides advice and analysis on economic policy. ASPE leads special initiatives,
coordinates the Department's evaluation, research and demonstration activities,
and manages cross-Department activities such as strategic planning, legislative
planning and review of regulations. Integral to this role, ASPE conducts
research and evaluation studies, develops policy analyses and estimates the
cost and benefits of policy alternatives under consideration by the Department
or Congress.
II. � Scope and Applicability of Guidelines ASPE will ensure that
disseminated information meets the standards of quality set forth in the
OMB, HHS and ASPE guidelines. It is ASPE's goal to ensure and maximize the
quality, objectivity, utility, and integrity of information that it disseminates
to the public. We strive to provide information that is accurate, reliable,
clear, complete, unbiased, and useful. We are committed to integrating the
principle of information quality into every phase of information development,
including creation, collection, maintenance, and dissemination. The pre-dissemination review described in the guidelines only applies
to information disseminated on or after October 1, 2002. The administrative
mechanism for correction applies to information that the agency disseminates
on or after October 1, 2002, regardless of when the agency first disseminated
the information. The guidelines apply to the following kinds of information that
the Office of the Assistant Secretary for Planning and Evaluation (ASPE)
disseminates:
- the reports of research and evaluation projects that ASPE sponsors. These
reports are usually the results of research that has been conducted for ASPE
by contractors under our direction.
- The final reports of projects supported by grants from ASPE may also be disseminated by ASPE.
- ASPE staff occasionally write papers for publication and distribution.
These reports are formal documents which have gone through several reviews
within both within the author's organization and within ASPE.
The Office also produces materials that are not distributed externally.
These materials are intended to inform the policy-making process. These materials
consist of briefing papers and technical analyses concerning proposed legislative
changes, the requirements of new legislation or descriptions of programs
or initiatives. While these papers may eventually be distributed externally
after the policy-making process is concluded, as required by the Freedom
of Information Act, they are not intended to be disseminated widely and consequently
are not covered under these guidelines. Further, the guidelines do not apply
to press releases that support the announcement or give public notice of
information that ASPE has disseminated elsewhere
III. � Types of Information Disseminated
- Research and evaluation reports
- Annual plans
- Lists of projects in progress or completed
- Project summaries
- Annotated bibliographies
- Lists of sources of data
- Reports to Congress
- Data files for public use
- Tabulations and charts of data relevant to particular topics, such as welfare dependence and child well-being
IV. � Types of Dissemination Methods The Office of the Assistant
Secretary for Planning and Evaluation provides both printed copies and electronic
copies of the reports it selects for dissemination. The individual components
of ASPE have responsibility for the dissemination of the products of their
research and evaluation efforts. Each component maintains mailing lists
and conducts direct mailings that are limited to the intended audience of
the publication. In addition, some components have developed extensive electronic
mailing lists that notify subscribers of the availability of new reports
on the ASPE website. In some circumstances, a plan for the dissemination
of a specific product may be developed to ensure widespread dissemination
to a particular audience. Such a plan might include notices to appropriate
media outlets, interviews, and presentations at conferences and other meetings.
V. � Agency Quality Assurance Policies, Standards and Processes for Ensuring
the Quality of Information Disseminated to the Public From their inception,
research and evaluation projects and any other information developmental
efforts that are undertaken by ASPE are subjected to a quality assurance
process. Further, ASPE reviews the quality (including the objectivity, utility,
and integrity) of information before it's disseminated and treats information
quality as integral to every step of the development of information, including
its creation, collection, maintenance and dissemination. Each project is
developed with the knowledge that the purpose, proposed methodology and work
plan will have to be defended before a peer review panel. The members of
the panel are appointed for at least a year at a time and are technically
qualified by their professional training and experience. The process for
conducting this peer review has been established for many years and refined
as circumstances have changed. Requests for changes in the design of proposed
projects are not infrequent. Projects are not approved for funding until
the peer review panel is satisfied that the project design and work plan
have a reasonable expectation of providing a useful product. All projects
involving original large scale data collected from the public undergo an
exacting, rigorous multi-level review process in connection with the Paperwork
Reduction Act (PRA). Further, ASPE is committed to demonstrating in its PRA
clearance packages that each draft information collection will result in
information that will be collected, maintained, and used in a way that is
consistent with OMB, HHS and ASPE information quality guidelines. Reports that are selected for dissemination to the public undergo the
following processes: Every report that is received as the result of a grant
or contract is reviewed by the project officer and that person's supervisor.
If necessary, a technical expert may be asked to review the report and offer
an opinion. A decision is made whether the report may be distributed or not.
A further decision is made whether to seek support for a more extensive dissemination
effort. If a more extensive dissemination effort is recommended, a more
thorough review process involving other organizations is initiated. This
will usually follow formal clearance procedures controlled by the Executive
Secretariat in the Office of the Secretary. Offices outside of ASPE, including
the Office of the Assistant Secretary for Public Affairs and one or more
operating divisions with an interest in the report’s contents are asked to
concur in the release of the report and provide comments. Editorial changes
may be made as a result of this review.
VI. � Agency Administrative Complaint Procedures
ASPE has developed
administrative mechanisms to allow affected persons to seek and obtain correction
of disseminated information that does not comply with OMB, HHS and ASPE guidelines.Complaints
about the quality or accuracy of the information being disseminated in a
report or other document should be addressed in writing by mail to:
Coordinator of Information Dissemination
Office of the Assistant Secretary for Planning and Evaluation
200 Independence Ave., S.W.
Washington, D.C. 20201
Or e-mail your complaint to: Infoquality.aspe@hhs.gov
- Responsibility of the Complainant
To seek correction of information disseminated by the agency, individuals should follow the procedures described below.
- A complaint or request for review and correction of information shall be in written hard copy or electronic form;
- it shall be sent to the agency by mail or electronic-mail(e-mail); and
- it shall state that an information quality request for correction is being submitted.
- a detailed description of the specific material that needs to
be corrected including where the material is located, i.e. the publication
title, date, and publication number, if any, or the Web site and Web page
address (url), or the speech title, presenter, date and place of delivery;
and
- the specific reasons for believing the information does not
comply with OMB, HHS or ASPE guidelines and is in error and supporting documentation,
if any;
- the specific recommendations for correcting the information;
- a description of how the person submitting the complaint is affected by the information error; and
- the name, mailing address, telephone number, e-mail address,
and organizational affiliation, if any, of the individual making the complaint.
- Complainants should be aware that they bear the "burden of proof"
with respect to the necessity for correction as well as with respect to the
type of correction they seek.
- Responsibility of the Agency
Based on a review of the information provided, the agency will determine
whether a correction is warranted and, if so, what action to take. The agency
will respond to the requestor by letter or e-mail. The agency's response
will explain the findings of the review and the actions that the agency will
take, if any. The response will consider the nature and timeliness of the
information involved and such factors as the significance of the correction
on the use of the information and the magnitude of the correction. The response
will describe how the complainant may request reconsideration. The agency
will respond to all requests for correction within 60 calendar days of receipt.
If the request requires more than 60 calendar days to resolve, the agency
will inform the complainant that more time is required and indicate the reason
why and an estimated decision date
- Appeals
If the individual submitting the complaint does not agree with the
agency's decision (including the corrective action, if any), the complainant
may send a written hard copy or electronic request for reconsideration within
30 days of receipt of the agency's decision. The appeal shall state the reasons
why the agency response is insufficient or inadequate. Complainants shall
attach a copy of their original request and the agency response to it, clearly
mark the appeal with the words, Information Quality Appeal and send the appeal
to the specific agency appeals address. The agency official who resolved
the original complaint will not have responsibility for the appeal. The agency
will respond to all requests for appeals within 60 calendar days of receipt.
If the request requires more than 60 calendar days to resolve, the agency
will inform the complainant that more time is required and indicate the reason
why and an estimated decision date.
VII. � Influential Scientific, Financial and Statistical Information
ASPE prepares revisions to the poverty guidelines that are published each
year by the Department of Health and Human Services (HHS). The guidelines
are a simplification of the poverty thresholds (published by the Census Bureau)
and are used for a variety of administrative purposes for instance, determining
financial eligibility for certain federal programs. The methodology for calculating
these amounts is well-established and documented. The accuracy can be independently
verified. At times individual reports of the kind described above may contribute
to decisions having major national impacts. In all such instances, the methods,
measures, procedures, data sources, limitations and assumptions are described
in the report itself to assure that the findings are substantially reproducible.
In some instances, the data itself is available to researchers as public
use data file. In addition, these reports contain the name of an ASPE contact
person.
HHS Office of Inspector General
I. � Office Mission
The mission of the Office of Inspector General,
as mandated by Public Law 95-452 (as amended), is to protect the integrity
of Department of Health and Human Services programs, as well as the health
and welfare of the beneficiaries of those programs. The OIG has a responsibility
to report both to the Secretary and to the Congress program and management
problems and recommendations to correct them. The OIG's duties are carried
out through a nationwide network of audits, investigations, inspections and
other mission-related functions performed by the OIG components.
II. � Scope and Applicability of Guidelines for Office OIG will
ensure that disseminated information meets the standards of quality set forth
in the OMB, HHS and OIG guidelines. It is OIG's policy to ensure and maximize
the quality, objectivity, utility, and integrity of information that it disseminates
to the public. We strive to provide information that is accurate, reliable,
clear, complete, unbiased, and useful. We are committed to integrating the
principle of information quality into every phase of information development,
including creation, collection, maintenance, and dissemination. The OMB Information Quality Guidelines require OIG to evaluate and identify
the types of OIG information that will be subject to the Guidelines. The
pre-dissemination review described in the guidelines only applies to information
disseminated on or after October 1, 2002. The administrative mechanism for
correction applies to information that the agency disseminates on or after
October 1, 2002, regardless of when the agency first disseminated the information.
This section identifies the types of information covered, and also lists
the types of information that are exempt.
- Covered Information
OIG reports prepared for use by Department officials formulating broad
program policies which are not subject to review by the affected individual(s)
or entity prior to public dissemination.
Editorials or Open Letters to the public representing position or view of the agency.
- Information Not Covered
Documents that are summary in nature and where the source documents
are already covered under the Guidelines, this would include the Semiannual
Report, the Orange Book and the Red Book.
Planning documents that represent future work which has not been completed. This includes the annual OIG Work Plan.
Findings and determinations or agreements made in the course of adjudication.
This includes the List of Excluded Individuals and Entities and Corporate
Integrity Agreements. Affected parties are subject to and/or can contest
exclusion decisions through an adjudicatory process.
Proprietary information owned by another agency, which the Department
does not have authority to release to outside sources, such as the Annual
Report of the State Medicaid Fraud Control Units.
Documents where the subject individual or entity is already afforded
an opportunity to comment on the accuracy of the information to ensure a
fair, objective and complete report, this includes most Audit reports.
Advisory Opinions, which are requested of the OIG and are binding only on the requestor.
The guidelines do not apply to press releases that support the announcement
or give public notice of information that OIG has disseminated elsewhere.
Documents which comply with the Federal Register standards
for public notices. This includes Fraud Alerts, Special Advisory Bulletins
and Safe Harbor Regulations, which are published in the Federal Register.
As such, the public is accorded the administrative procedures for public
notices and afforded the opportunity to comment. The safe harbors also are
excluded because they serve as OIG policy.
Guidance issued by the OIG where compliance is voluntary such as
those issued under the Compliance Guidance Program. The compliance guidance
is based on the Centers for Medicare and Medicaid Services (CMS) regulations
and guidelines, any requirements imposed in corporate integrity agreements
negotiated by the OIG and input from the affected industry, thus there is
an established quality control process through input from the affected entities.
Information or documents explicitly excluded by the Quality Control
Guidelines such as press releases, public filings, subpoenas, or adjudicative
processes.
Procedural and policy manuals that are produced primarily for internal use.
III. � Types of Information Disseminated
The types of information published by the OIG is described in Section II.
IV. � Types of Dissemination Methods
Hard copy reports and electronic
media such as the Internet. Interested persons can subscribe to receive information
electronically on recently issued reports, press releases and other documents.
V. � Agency Quality Assurance Policies, Standards and Procedures for
Ensuring the Quality of Information Dissemination to the Public
The quality assurance process begins at the inception of the information development process.
Information released by OIG is developed from reliable data sources utilizing
accepted methods for data collection and is based on thoroughly reviewed
analyses and models. The guidelines below describe procedures that OIG employs
to assure the quality of its information products. Quality is an encompassing
term comprising utility, objectivity, integrity, and reproducibility.
- Utility
Utility involves the usefulness of the information to its intended audience.
The purpose of OIG documents and information is to identify fraud, waste
and abuse and to protect the integrity of HHS programs. The OIG issues findings
and recommendations on the efficiency, effectiveness, and vulnerabilities
of departmental programs.
- Objectivity
Objectivity involves a focus on ensuring that information is accurate,
reliable and unbiased and that information products are presented in an accurate,
clear, complete and unbiased manner. Objectivity is achieved by using reliable
data sources and sound analytical techniques, and preparing information products
that use proven methods by qualified individuals that are carefully reviewed.
Below is a description of the quality assurance guidelines that are used
to ensure objectivity and accuracy of information.
OIG reviews the quality (including the objectivity, utility, and
integrity) of information before its is disseminated and treats information
quality as integral to every step of the development of information, including
its creation, collection, maintenance and dissemination.
Quality Assurance Process
The quality assurance procedures is a collaborative, team effort by staff
who conduct program inspections and staff who assist, guide, and review written
and oral inspection plans and products. Any individual involved with a particular
inspection is responsible for helping assure quality of work done and products
released. Further, OIG is committed to demonstrating its Paper Reduction
Act (PRA) clearance packages that each draft information collection will
result in information that will be collected, maintained, and used in a way
that is consistent with OMB, HHS, and OIG information quality guidelines.
Specific responsibility for conducting and ensuring quality program
inspections rests with Regional Inspectors Generals (RIGs). RIGs assign a
Team Leader and other team members to each inspection. This team is responsible
for doing quality inspection field work -- including design, data collection,
data analysis, and written and oral reports. RIGs must certify for final
reports that the inspection was done in accordance with OIG procedures and
PCIE quality standards.
If an audit methodology is used to develop the product, the Government Auditing Standards are employed as described below:
- Government Auditing Standards State that "Each audit organization conducting
audits in accordance with these standards should have an appropriate internal
quality control system in place and undergo an external quality control review."
- This control system is to provide reasonable assurance that
the audit organization (1) has adopted, and is following, applicable auditing
standards (which includes reporting "the views of responsible officials")
and (2) has established, and is following, adequate policies and procedures.
- To determine whether in fact the audit organization's quality
control system is operating effectively, the organization is required by
standards to have "n external quality control review at least once every
3 years by an organization not affiliated with the organization being reviewed."
OIG's quality control program ensures that audit work performed meets
government auditing standards. It consists of two elements:
- The OIG System of Quality Control consists of independent report referencing,
Headquarter Desk Reviews and Internal Quality Control Reviews. The latter
includes review of working papers related to selected reports.
- External Reviews -- These reviews, also known as peer reviews,
are performed by Federal auditors outside the OAS. The external review is
required by the Comptroller General's standard on quality control and should
be conducted at least once every three years.
Report Validation
Report Validation is a process that is used to help ensure that the
facts, findings, conclusions, and recommendations contained in OIG reports
are accurate, reliable, and supportable by inspection work papers and analysis.
Report validation is conducted prior to submitting the draft report
for IG signature. For objectivity, validation is performed by regional staff
that are not a part of the inspection team. To facilitate this process, the
draft report is cross indexed to applicable work papers. Work papers must
include documentation that inspection teams verified data presented in draft
reports by checking it against supporting evidence in the work papers.
Agency Reviews
To help assure quality and impact of its inspection results, OIG
obtains comments and other input from applicable agency staffs on inspection
plans, results, and selected products. Inspection teams obtain such input
in a variety of ways, including entrance, exit, and other conferences; and
comments on inspection designs, data collection instruments, and draft and
final reports. Inspection teams use such meetings and reviews to help identify
client needs, identify relevant data for accomplishing inspection purposes,
verify accuracy and reliability of data collected, and verify soundness of
findings, conclusions, and recommendations developed.
Reliability of Data Sources
To maintain credibility, OIG must take reasonable steps to assess
the reliability of pre-existing computerized data used as the basis for inspection
findings and recommendations. Many inspections either begin with a computerized
sample selection or are based entirely on analyzing data extracted from computerized
records not under OIG's direct control. Project staff do not assume that
such computer extracts or sample selections are complete or that they accurately
reflect the universe of people or transactions being studied.
Data reliability means the degree to which data extracted from computer
records for a program inspection completely and accurately reflect the individuals
or transactions being studied. This is a relative concept, one that recognizes
that data with errors may still be usable, if the errors are not of a magnitude
that would cause a reasonable person to doubt findings or conclusions that
are based on the data.
To provide reasonable assurance of computerized data reliability we:
- Identify prior reviews by OIG, GAO or by system managers attesting to the computer system and data reliability,
- Review the data dictionary, if it exists, for the database to assure
a full understanding of the relevant data elements' structure, content, how
the elements are derived, and their interrelationships before requesting
data extractions,
- Obtain frequency counts of critical data elements to determine
if the data selection criteria are providing the information anticipated,
- Conduct data accuracy tests to ensure that required data elements have been provided and are in the expected format,
- Obtain detailed printouts for a sub-sample of records included in
the data extract to confirm that the extraction produced the types of records
sought and the required information from those records,
- Obtain source documents (e.g., claim folders) for a sample of extracted
records to determine the validity of the data contained in the automated
records, if the data reliability is questionable, and include a statement
in the Methodology section of draft and final reports describing the extent
of reliability testing performed and our confidence in the data used.
Integrity
Integrity refers to the security of information from unauthorized
access or revision to ensure that the information is not compromised through
corruption or falsification. To ensure the integrity of information, OIG
has in place rigorous controls that have been identified as representing
sound security practices.
OIG is highly protective of the confidentiality of information it
holds through its policies and practices. OIG has in place programs and policies
for securing OIG resources as required by the Government Information Security
Reform Act (P.L. 106-398, Title X, Subtitle G). OIG is subject to statutory
requirements to protect the sensitive information it gathers and maintains
on individuals.
Reproducibility
If an agency is responsible for disseminating "influential" information,
guidelines for dissemination should include a high degree of transparency
about data and methods to facilitate its reproducibility by qualified third
parties. Information is considered influential if it will have a substantial
impact on important public policies or important private sector decisions.
Since many of the OIG's Inspection reports have an impact on important public
policies, OIG's information that is subject to section 515 should be highly
transparent and capable of being reproduced by qualified persons.
OIG's guidelines call for identification and documentation of data
sets used in producing estimates and projections and clear description of
the methodology used to produce the analytical results. Some results included
in OIG reports are not directly reproducible by the public because the underlying
data sets used to produce them are confidential. However, those inspections
that are based on publically available data and are made available on request
are fully reproducible by the public.
VI. � Agency Administrative Complaint Procedure OIG has developed
administrative mechanisms to allow affected persons to seek and obtain correction
of disseminated information that does not comply with OMB, HHS and OIG guidelines.
Requests for review should to be submitted in writing to the OIG at the following address:
Public Affairs Officer
Office of Inspector General
Office of Management and Policy
Room 5541 Cohen Building
Washington D.C. 20201
Alternatively, they can be e-mailed to: DataQuality@hhs.gov
- Responsibility of the Complainant
To seek a correction of information disseminated by the agency, individuals should follow the procedures described below.
- A complaint or request for review and correction of information shall be in written hard copy or electronic form;
- it shall be sent to the agency by mail or electronic-mail (e-mail); and
- it shall state that an information quality request for correction is being submitted.
The complaint shall contain
- a detailed description of the specific material that needs to be corrected
including where the material is located, i.e. the publication title, date,
and publication number, if any, or the website and web page address (url),
or the speech title, presenter, date and place of delivery; and
- the specific reasons for believing the information does not
comply with OMB, HHS or OIG guidelines and is in error and supporting documentation,
if any;
- the specific recommendations for correcting the information;
- a description of how the person submitting the complaint is affected by the information error; and
- the name, mailing address, telephone number, e-mail address,
and organizational affiliation, if any, of the individual making the complaint.
- Complainants should be aware that they bear the "burden of proof"
with respect to the necessity for correction as well as with respect to the
type of correction they seek.
- Responsibility of the Agency
Based on a review of the information provided, the agency will determine
whether a correction is warranted and if, so what action to take. The agency
will respond to the requestor by letter or e-mail. The agency's response
will explain the findings of the review and the actions that the agency will
take, if any. The response will consider the nature and timeliness of the
information involved and such factors as the significance of the correction
on the use of the information and the magnitude of the correction. The response
will describe how the complainant may request reconsideration. The agency
will respond to all requests for correction within 60 calendar days of receipt.
If the request requires more than 60 calendar days to resolve, the agency
will inform the complainant that more time is required and indicate the reason
why and an estimated decision date.
- Appeals
If the individual submitting the complaint does not agree with the
agency's decision (including the corrective action, if any), the complainant
may send a written hard copy or electronic request for reconsideration within
30 days of receipt of the agency's decision. The appeal shall state the reasons
why the agency response is insufficient or inadequate. Complainants shall
attach a copy of their original request and the agency response to it, clearly
mark the appeal and the envelope with the words, "Information Quality Appeal,"
and send the appeal to:
Public Affairs Officer
Office of Inspector General
Office of Management and Policy
Room 5541 Cohen Building
Washington D.C. 20201
The agency official who resolved the original complaint will not have
responsibility for the appeal. The agency will respond to all requests for
appeals within 60 calendar days of receipt. If the request requires more
than 60 calendar days to resolve, the agency will inform the complainant
that more time is required and indicate the reason why and an estimated decision
date.
VII. � Influential scientific, financial and statistical information
Addressed in Section V.
VIII. � Special Considerations for Dissemination
All OIG inspections are conducted in accordance with the Quality Standards for Inspections issued by the President's Council on Integrity and Efficiency. The following is an outline of these standards.
Qualifications: Individuals assigned to perform inspection
work must collectively possess adequate professional proficiency for the
task required.
Independence: Individuals performing inspection work must be
free from impairments that hinder objectivity. Inspectors must consistently
maintain an independent, objective attitude and appearance, and shall be
subject to supervisory guidance and review to preclude actual or perceived
impairments or bias in conducting inspection work and presenting results.
Due Professional Care: Due professional care will be used in conducting inspection work and in preparing reports of other products.
Quality Control: To ensure quality and to expedite the progress
of an inspection, proper supervision will be exercised from the start of
an inspection to completion of the final inspection report.
Planning: To ensure adequate planning, inspection work will
be coordinated, researched, and designed to achieve the objectives of the
inspection.
Data Collection: Information and data obtained about the organization,
program analysis activity, or function being inspected should be consistent
with inspection objectives and sufficient enough to provide a reasonable
basis for reaching conclusions.
Evidence: Evidence supporting inspection conclusions should
be competent and relevant and lead a prudent person to the same conclusion
as that of the inspectors.
Supporting: All relevant information generated, obtained, and
used in Documentation supporting inspections findings, conclusions, and recommendations
should be retained.
Timeliness: inspectors should seek to deliver significant information to appropriate management officials in a timely manner.
Fraud and Other: If during or in connection with an inspection,
inspectors become Illegal Acts aware of illegal acts, or indications of such
acts, they should promptly present such information to their supervisors
for review and possible referral to the appropriate investigative office.
Reporting: All inspection reports shall present factual data
accurately, fairly, and objectively, and present findings and conclusions
in a persuasive manner.
Follow-up: Appropriate follow-up will be performed to assure
that any recommendations made to agency officials are adequately considered
and appropriately addressed.
All OIG audits are conducted in accordance with Government Auditing
Standards and OAS policy. Both (1) afford affected entities the opportunity
for corrections and (2) require a stringent quality control program.
- Auditee Response
- Government Auditing Standards
Government Auditing Standards state that "Auditors should report the
views of responsible officials of the audited program concerning auditor's
findings, conclusions, and recommendations, as well as corrections planned."
- Obtaining comments is one of the most effective ways to ensure that a report is fair, complete, and objective.
- Advance comments should be objectively evaluated and recognized, as appropriate in the report.
- OIG Audit Policy
OIG Audit policy requires that reports give recognition to the views of the auditee.
- The auditee's formal response to each finding should be included in the final audit report.
- The official position of the auditee should be in writing and should be signed by the responsible official.
- The auditee may present new information in formal written comments
to the draft report. In these instances, the information should be evaluated
prior to incorporating the comments and issuing the final report.
- The auditee comments would appear in the final report in three
places, report summary, individual finding and appendix to report.
- The OIG regards the absence of a response to audit findings and
recommendations as a departure from generally accepted government auditing
standards. If the auditee does not provide comments after receiving the draft
report, this is stated in the final audit report.
- OIG Audit policy requires that respond to each relevant auditee comment.
- Quality Control Program
- Government Auditing Standards
Government Auditing Standards State that "Each audit organization conducting
audits in accordance with these standards should have an appropriate internal
quality control system in place and undergo an external quality control review."
This control system is to provide reasonable assurance that the
audit organization (1) has adopted, and is following, applicable auditing
standards (which includes reporting "the views of responsible officials")
and (2) has established, and is following, adequate policies and procedures.
To determine whether in fact the audit organization's quality control
system is operating effectively, the organization is required by standards
to have "an external quality control review at least once every 3 years by
an organization not affiliated with the organization being reviewed."
- OIG Audit Policy
OIG's Audit quality control program ensures that work performed meets
government auditing standards. It consists of two elements:
- A System of Quality Control which consists of independent report referencing,
Headquarter Desk Reviews and Internal Quality Control Reviews. The latter
includes review of working papers related to selected reports.
- External Reviews -- These reviews, also known as peer reviews,
are performed by Federal auditors outside the OIG. The external review is
required by the Comptroller General's standard on quality control and should
be conducted at least once every three years.
IX. � Other Agency Specific Policies and Procedures
Office of Evaluation Procedures Manual, Data Analysis -- oig.hhs.gov/organization/OEI/ (currently under revision)
Quality Standards for Federal Offices of Inspector General -- www.ignet.gov/pande/standards/igstds.pdf
Quality Standards for Inspections -- oig.hhs.gov/organization/OEI/other/qsidoc.pdf
Government Auditing Standards
Quality Standards for Federal Offices of Inspector General
OMB Circular A-123 (Revised June 21, 1995)
Office of Public Health and Science
I. � Office Mission The Office of Public Health and Science (OPHS)
provides leadership to the nation on public health and science, and communicates
on these subjects to the American people. OPHS is led by the Assistant Secretary
for Health (ASH), whose chief interest is promoting, protecting, and improving
the nation's health. This role encompasses responsibilities as senior advisor
to the Secretary for public health and science and director of program offices
housing a variety of essential public health activities. The offices in OPHS
are: the Immediate Office of the ASH; the Office of the Surgeon General;
the Office of HIV/AIDS Policy; the Office of Population Affairs (OPA); the
Office of Disease Prevention and Health Promotion (ODPHP); the President's
Council on Physical Fitness and Sports; the Office of Minority Health (OMH);
the Office on Women's Health (OWH); the Office for Human Research Protections;
the Office of Global Health Affairs (OGHA); the Office of Research Integrity;
and the Office of Military Liaison and Veterans Affairs. In addition, the
Director of the National Vaccine Program Office and the Regional Health Administrators
report to the ASH.
II. � Scope and Applicability of Guidelines for Agency/Office The
pre-dissemination review described in the guidelines only applies to information
disseminated on or after October 1, 2002. The administrative mechanism for
correction applies to information that the agency disseminates on or after
October 1, 2002, regardless of when the agency first disseminated the information.
The purpose of these Guidelines is to provide guidance to OPHS offices
about administrative procedures to ensure the quality of the information
they disseminate to the public. The Guidelines also provide guidance to the
public about how to file a complaint about the quality of the substantive
information disseminated by OPHS offices and how OPHS offices should respond
to public complaints. The Guidelines apply to substantive information disseminated
by OPHS offices and representing OPHS/HHS views. Substantive information
includes consumer and professional education materials, scientific and technical
reports, policy and program recommendations, research findings from sponsored
grants that include a dissemination component, and public speeches representing
official HHS policy. The Guidelines do not apply to information that is labeled
with a disclaimer as not representing agency views, intra- or inter-agency
information, regulations, compliance oversight reports, grants and program
announcements, or information describing basic agency operations.
III. � Types of Information Disseminated by the Agency to the Public
OPHS offices disseminate a variety of public health and science information
to the public. The primary types of information disseminated are consumer
and professional education and scientific and technical reports. Information
disseminated by OPHS is based on science, derived from state of the art knowledge,
and peer-reviewed by experts inside and outside government, depending on
the nature of the information. For example, the Office of Disease Prevention and Health Promotion disseminates
information about national disease prevention and health promotion goals
and objectives such as the Healthy People 2010 document published in November
2000. The Office on Women's Health disseminates consumer education about
women's health issues in the form of pocket planners, annual daybooks, and
fact sheets such as the 2002 Women's Health Daybook Living Long, Living Well.
The Office of Minority Health disseminates information on minority health
issues through two nationally distributed newsletters. The Office of the
Surgeon General disseminates information on high priority national public
health issues in the form of Surgeon General Reports, Calls to Action and
National Strategies such as the Surgeon General's Call to Action to Prevent
and Decrease Overweight and Obesity 2001.
IV. � Types of Dissemination Methods OPHS offices use both
print and electronic methods to disseminate information. Offices use Web
sites, clearinghouses (telephone information services), print reports, print
brochures and newsletters, fact sheets, and a variety of consumer and professional
educational materials, such as bookmarks, wallet cards, day planners, and
pocket guides. OPHS staff also makes public speeches representing OPHS/HHS
public health policy matters. These speeches are presentations of substantive
content, not public affairs events.
V. � Agency Quality Assurance Policies, Standards, and Processes for
Ensuring the Quality of Information Disseminated to the Public It is
OPHS policy to ensure and maximize the quality, objectivity, utility, and
integrity of information that it disseminates to the public according to
the standards set forth in the OMB, HHS and OPHS guidelines. OPHS offices
strive to provide information that is accurate, reliable, clear, complete,
unbiased, and useful. OPHS offices are committed to integrating the principle
of information quality into every phase of information development, including
creation, collection, maintenance, and dissemination. The general standard for information disseminated by OPHS offices is
the best available public health and science information. Best available
is determined by information published in the highest quality peer-reviewed
journals, comparison with best practices as established by the relevant discipline,
and reviews by expert panels, individual subject experts, external Advisory
Committees, Coordinating Committees with subject experts from HHS agencies,
Steering Committees, and staff review. OPHS reviews the quality (including
the objectivity, utility, and integrity) of information before it is disseminated
and treats information quality as integral to every step of the development
of information, including its creation, collection, maintenance and dissemination.
For consumer and professional educational materials, appropriateness of the
materials for the intended users is a special focus. Appropriateness is determined
through staff review, focus groups, user surveys, audience testing, and dissemination
of information and materials for public comment. Depending on the subject
matter, disseminated information may also be subject to review by legal staff.
Further, staff strives to collect updated, timely information and
remain aware of emerging and newly developed data. In addition, staff is
committed to demonstrating in the Paper Reduction Act (PRA) clearance packages
that each draft information collection will result in information that will
be collected, maintained, and used in a way that is consistent with OMB,
HHS and OPHS information quality guidelines.
VI. � Agency Administrative Complaint Procedures OPHS has developed
administrative mechanisms to allow affected persons to seek and obtain correction
of disseminated information that does not comply with OMB, HHS and OPHS guidelines.
- Responsibility of the Complainant
To seek a correction of information disseminated by the agency, individuals
should follow the procedures described below. Complainants should be aware
that they bear the "burden of proof" with respect to the necessity for correction
as well as with respect to the type of correction they seek.
A complaint or request for review and correction of information
must be in written hard copy or electronic form; sent to the agency by mail
or electronic-mail (e-mail); and state that an information request for correction
is being submitted.
The complaint shall contain
- a detailed description of the specific material that needs to be corrected
including where the material is located, i.e. the publication title, date,
and publication number, if any, or the Web site and Web page address (url),
or the speech title, presenter, date and place of delivery; and
- the specific reasons for believing the information does not
comply with OMB, HHS or OPHS guidelines and is in error and supporting documentation,
if any;
- the specific recommendations for correcting the information;
- a description of how the person submitting the complaint is affected by the information error; and
- the name, mailing address, telephone number, e-mail address,
and organizational affiliation, if any, of the individual making the complaint.
Complaints should be addressed and submitted to:
Executive Officer
Office of Public Health and Science
U.S. Department of Health and Human Services
200 Independence Ave, S.W.
Washington, D.C. 20201
Alternatively, complaints may be e-mailed to: hthompson@osophs.dhhs.gov.
- Responsibility of the Agency
Based on a review of the information provided, the relevant OPHS
office will determine whether a correction is warranted and, if so, what
action to take. The office will respond to the requestor by letter or e-mail.
The office's response will explain the findings of the review and the actions
that the office will take, if any. The response will consider the nature
and timeliness of the information involved and such factors as the significance
of the correction on the use of the information, the magnitude of the correction,
and the resource requirements for the correction. The response will describe
how the complainant may request reconsideration. The office will respond
to all requests for correction within 60 calendar days of receipt. If the
request requires more than 60 calendar days to resolve, the office will inform
the complainant that more time is required and indicate the reason why and
an estimated decision date.
- Appeals
If the individual submitting the complaint does not agree with the
office's decision (including the corrective action, if any), the complainant
may send a written hard copy or electronic request for reconsideration within
30 days of receipt of the office's decision. The appeal shall state the reasons
why the office response is insufficient or inadequate. Complainants shall
attach a copy of their original request and the office response to it, clearly
mark the appeal with the words, "Information Quality Appeal" and send the
appeal to the OPHS appeals address.
The office official who resolved the original complaint will not
have responsibility for the appeal. OPHS will respond to all requests for
appeals within 60 calendar days of receipt. If the request requires more
than 60 calendar days to resolve, OPHS will inform the complainant that more
time is required and indicate the reason why and an estimated decision date.
Appeals should be addressed and submitted to:
Executive Officer
Office of Public Health and Science
U.S. Department of Health and Human Services
200 Independence Ave, S.W.
Washington, D.C. 20201
jjarman@osophs.dhhs.gov
VII. � Influential Scientific, Financial and Statistical Information
Given the OPHS mission, from time to time, OPHS offices disseminate information
that is regarded as influential. In these instances, OPHS adheres to the
highest standards of transparency about information sources, methods and
analytical techniques. This influential information is in the form of scientific
and technical reports. These reports compile, synthesize, and analyze state-of-the-art
knowledge about high priority public health issues that have not previously
received sufficient attention. The reports include data from published sources
and the public domain, as well as expert opinion, consensus, and recommendations.
The sources of underlying data are referenced in reports. Typically, the
sponsoring or disseminating office does not conduct original research for
these reports, although the office may convene Advisory Groups, Steering
Committees, Coordinating Committees or similar bodies as well as take public
comment. This input may become part of the report.
Last revised: July 28, 2004
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