Guidelines for Ensuring the Quality of Information Disseminated to the Public
H. � Indian Health Service
I. � Agency Mission
The Indian Health Service (IHS) is responsible for providing federal health services to American Indians and Alaska Natives. The IHS provides a comprehensive health services delivery system for American Indians and Alaska Natives with opportunity for maximum tribal involvement in developing and managing programs to meet their health needs. The goal of the IHS is to raise the health status of American Indian and Alaska Native people to the highest possible level. IHS services are provided directly and also through tribally contracted and operated health programs.
II. � Scope and Applicability of Guidelines for IHS
IHS will ensure that disseminated information meets the standards of quality set forth in the OMB, HHS and IHS guidelines. It is IHS’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 guidelines apply only to the dissemination of substantive information that the IHS initiates or sponsors. The IHS information to which these guidelines would apply are programmatic statistics and IHS program and policy information.
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.
III. � Types of Information Disseminated by the IHS to the Public
IHS disseminates statistical reports and IHS policy and programmatic information to the public via the IHS web site and through IHS publications. The IHS website also contains links to other useful sites relating to health information and IHS related activities. The Indian Health Service (IHS) provides information to the public about the current IHS programs, clinical epidemiological data on American Indian and Alaska Natives(AI/AN), the projected scope and impact of IHS programs of AI/AN people in the future, and the effect of proposed changes to the IHS and tribal health care systems. Information products describe the impact of IHS programs on American Indian and Alaska Natives communities and upon its beneficiary populations. IHS provides detailed demographic and economic information on health benefits for AI/AN people. The IHS also provides information on research among AI/AN communities. IHS information products are used by government planners and policymakers as well as many actuaries, economists and other social scientists, the media and the public to analyze IHS programs and their impact on the health of the Indian Nation.
IV. � Types of Dissemination Methods
IHS disseminates information in print and electronic form.
V. � Agency Quality Assurance Policies, Standards and Processes for Ensuring the Quality of Information Disseminated to the Public
The quality assurance process begins at the inception of the information development process. �Further, IHS 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. �In addition, IHS demonstrates in its Paperwork Reduction Act clearance submission that information will be collected, maintained, and used in a way that is consistent with 0MB, HHS and IHS information quality guidelines.
Information released by IHS is developed from reliable data sources utilizing accepted methods for data collection. The information is based on thoroughly reviewed analyses and models. The guidelines below describe procedures that IHS employs to assure the quality of its information products, including their utility, objectivity, integrity, transparency, and reproducibility.
IHS's ongoing publication series and other information products are reviewed to ensure that they remain relevant and address current information needs. Based on internal product reviews, consultation with users, and in response to changing needs and emphases, content of ongoing information products is changed, new products are introduced and others discontinued. IHS prepares special Clinical Trends reports and topical studies that address emerging information needs stemming from data coming from the agency clinical services. It also addresses proposed changes in the law and related policy debates. IHS also identifies requirements for simulation models to support the preparation of analytic reports and policy studies and modifies its current models or develops new models accordingly. Where appropriate, contact information is available on each publication (and in some cases on each table of a publication) to allow feedback and questions by users. In addition, IHS's Office of Program Support has recently begun a periodic customer satisfaction survey to obtain input and guidance by users.
Much of the information disseminated by IHS is based on patient data files. These files contain information used to manage IHS programs, including data to determine benefits, and plan for improving the health of the American Indian and Alaska Native people IHS's Office of Public Health conducts ongoing reviews of data and information in IHS data systems to ensure its accuracy. In support of these activities, IHS employs an outside contractor to review IHS's quality control methodology and processes to confirm the validity of its data management processes. IHS administrative data are also covered under IHS Financial Management System and conform to the high standards of financial accountability demanded by these Systems. These financial management systems are mandated by the Office of Management and Budget and are designed to provide complete, reliable, consistent, timely and useful management information to enable agencies to carry out their fiduciary responsibilities.
IHS-sponsored surveys are conducted using methodologies that are consistent with generally accepted professional standards for all aspects of survey development, including sample frame development, statistical design of the survey sample, questionnaire design and testing, data collection, sampling and coverage errors, non-response analysis, imputation of missing data, weights and variance estimates. IHS surveys follow guidelines and policies set forth in the Paperwork Reduction Act and other regulations related to the conduct of government surveys. IHS also prepares information products using data produced or maintained by other federal agencies and established survey organizations. All such external survey and administrative data used by IHS are produced using generally accepted methodologies.
Where samples from administrative data files are employed for analysis, sound statistical methods are employed to develop samples. Staff producing statistical publications are knowledgeable about the content, structure and limitations of the administrative data files and maintain working relations with staff who create, update and maintain these files.
IHS utilizes several simulation models to make estimates of the effects of demographic and economic trends and legislative and policy options on Indian Health programs and beneficiary populations now and in the future. Some simulation models have been or are being developed within IHS. Others are being developed under contracts. All contracts to develop simulation models provide for detailed documentation that describes the goals and objectives of the model, the data sources being used and the methodologies and assumptions employed. Contract reports are being made available on the Internet. Documentation is available for some simulation models that have been developed within IHS and will be prepared for others.
All simulation models are extensively tested and reviewed within IHS to verify that the computer programs that were developed to implement the model conform to the stated objectives. Where appropriate, historical simulations are developed to evaluate the success of a model in producing reasonable projections.� Simulation models are based on IHS's and its contractor's best judgments of current and future behavioral relationships and methods of projecting key program outcomes. These models are periodically updated to reflect input from internal and external reviews and research findings on behavioral relationships. These updates are also documented.
If an error is detected before an initial mailing, IHS includes an errata notice with the mailing. If the mailing has been sent out, IHS issues an errata sheet with all subsequent publications, and as appropriate, sends the errata sheet to all those who received the initial notice. Errata notices are put on the first page of the Web version to inform both new and repeat site visitors about the mistake, and the corrected version of the document is posted on the Web.
IHS is subject to statutory requirements to protect the sensitive information it gathers and maintains on individuals. These requirements are contained in the following documents:
VI. � Agency Administrative Complaint Procedures
The complaint should contain
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.
Complaints by mail should be directed to:
Data Quality Management
801 Thompson Avenue
Rockville, MD 20852
Alternatively, complaints may be e-mailed to Tony.Knedrick@mail.ihs.gov
The agency program 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.
VI. � Influential Scientific, Financial and Statistical Information
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 much of IHS's actuarial, statistical and analytical information products potentially have an impact on important public policies, IHS's information that is subject to section 515 should be highly transparent and capable of being reproduced by qualified persons.
IHS's guidelines call for identification and documentation of data sets used in producing estimates and projections and clear descriptions of methods used to produce estimates and to develop model projections to make its results as transparent as possible. Many estimates and projections included in IHS information products are not directly reproducible by the public because the underlying data sets used to produce them are confidential. However, some statistical publications that are based on publicly available data and whose programs are made available on request are fully reproducible by the public. And IHS is in the process of developing public-use versions of several data files, which will increase the reproducibility of estimates and projections to the extent possible while still protecting confidentiality. Some estimates and projections may not be easily reproduced by third parties due to the complexity and detail of the methods and data. In these cases greater emphasis is placed on periodic review by outside panels of technical experts.
IHS also achieves transparency through wide dissemination of its information. Most reports and other data products are available both as printed and electronic documents. They are announced on the IHS web site and most electronic versions can be accessed and downloaded directly from the IHS web site. All documents posted on our Web site since year 2000 are section 508 compliant making information available to an audience that includes persons who have a visual impairment and read online using assistive technology.
Last revised: November 12, 2003