Information On Quality Guidelines
These guidelines describe National Labor Relations Board's
policy for ensuring the quality of information that it disseminates to the
public and sets forth the administrative procedure by which an affected person
may obtain correction of disseminated information.
Information Quality Correspondence
At this time, the NLRB has received no information quality
correction requests; however, NLRB will update this page if it receives any
requests.
Forthcoming Influential Scientific Disseminations
(Agenda)
NLRB does not produce or sponsor the distribution of influential
scientific information (including highly influential scientific assessments). As
a result, NLRB has no agenda of forthcoming influential scientific
disseminations to post on its website in accordance with OMB's Information
Quality Bulletin for Peer Review.
Information Quality Guidelines
1. Purpose. The National Labor Relations Board (NLRB or
the Board) issues these Information Quality Guidelines to describe the agency's
procedures for ensuring the quality of information that it disseminates to the
public and to set forth the administrative procedure by which an affected person
may obtain correction of disseminated information that does not comply with the
Guidelines. The purpose of the Guidelines is to ensure that information
disseminated by the NLRB is: (1) presented in an accurate, clear, complete, and
unbiased manner; (2) useful to the intended users; and (3) protected from
unauthorized access or revision.
2. Authority. Section 515 of the Treasury and General
Government Appropriations Act for FY 2001 (Public Law No. 106- 554) requires
each Federal agency to publish guidelines for ensuring and maximizing the
quality, objectivity, utility, and integrity of information that it disseminates
to the public. Each agency's guidelines must conform to government-wide
guidelines issued by the Office of Management and Budget (OMB). After seeking
comment on proposed government-wide guidelines, OMB published initial guidelines
(with certain provisions published on an interim final basis) in the Federal
Register on September 28, 2001 (66 FR 49718) and final guidelines on February
22, 2002 (67 FR 8452).
3. Effective Date. October 1, 2002.
4. Agency Background. The NLRB is an independent
administrative agency created by Congress in 1935 to administer the National
Labor Relations Act (NLRA), which is the primary Federal statute governing labor
relations in the private sector. The Act defines and protects the rights of
employees, unions and employers, and seeks to eliminate certain unfair labor
practices on the part of employers and unions so as to promote commerce and
strengthen the Nation's economy. Under the NLRA, the NLRB has two primary
functions: (1) to prevent and remedy statutorily defined unfair labor practices,
and (2) to conduct secret-ballot elections among employees to determine whether
the employees wish to be represented by a union. The NLRB consists of two major
components. A five- member Board appointed by the President acts primarily as a
quasi- judicial body in deciding cases on the basis of formal records in
administrative proceedings. The General Counsel, also appointed by the
President, has final authority to investigate unfair labor practice charges,
issue complaints, and prosecute such complaints before administrative law judges
and the Board. On behalf of the Board, the General Counsel also prosecutes
injunction proceedings, handles court of appeals proceedings to enforce or
review Board decisions and orders, and secures compliance with Board orders and
court judgments.
5. Definitions. For purposes of the NLRB's information
quality assurance guidelines, the following terms will have the meanings below.
These definitions follow or are derived from OMB's guidelines. Consistent with
OMB's guidelines, we have adapted OMB's definitions in ways appropriate to the
NLRB's particular practices and programs. Dissemination means an
NLRB-initiated or sponsored distribution of information to the public.
Dissemination does not include distributions intended to be limited to: (i)
government employees or agency contractors or grantees; (ii) intra- or inter-
agency use or sharing of government information; or (iii) responses to requests
for agency records under the Freedom of Information Act, the Privacy Act, the
Federal Advisory Committee Act or other similar laws. Dissemination further does
not include distributions limited to: correspondence with individuals or
persons, press releases, archival records, subpoenas or adjudicative processes.
In addition, dissemination does not include procedural, operational, policy, and
internal manuals prepared for the management and operations of the NLRB that are
not primarily intended for public dissemination.
Information means any communication or representation of
knowledge, such as facts or data, in any medium or form, including textual,
numerical, graphic, cartographic, narrative, or audiovisual forms. "Information"
includes data posted on the NLRB's Web site, but does not include the provision
of hyperlinks to information that others disseminate. "Information" also does
not include personal opinions, where the NLRB or the author makes clear that
what is being offered is the author's opinion rather than either fact or the
NLRB's views.
Influential is a specialized term that means certain
scientific, financial or statistical information that the agency can reasonably
determine will have or does have a clear and substantial impact on important
public policies or important private sector decisions. Consistent with the scope
of these guidelines, the term "influential" applies only to certain scientific,
financial or statistical information and does not apply to policy decisions that
the information may support. If a decision or action by the NLRB is itself very
important, a particular piece of information supporting that decision or action
may or may not be "influential." In rulemaking, influential information is
scientific, financial or statistical information that the NLRB considers
significant with respect to one or more critical issues in a "major rule," as
such term is defined in the Small Business Regulatory Enforcement Fairness Act
of 1996. In non-rulemaking contexts, the scope and significance of the effect of
the information on important public policies or important private sector
decisions will determine whether the information is influential.
Integrity refers to the security of the NLRB's
information, i.e., protection of the information from unauthorized access or
revision, to ensure that the information is not compromised through corruption
or falsification. Objectivity refers both to: (i) presenting information
in a proper context to set out that information in a clear, complete and
unbiased manner; and (ii) ensuring that the substance of the information is
accurate, reliable and unbiased.
Quality is an encompassing term comprising utility,
objectivity and integrity.
Reproducibility means that "influential" information is
capable of being substantially reproduced, subject to an acceptable degree of
imprecision. With respect to analytic results, "capable of being substantially
reproduced" means that independent analysis of the original or supporting data
using identical methods would generate similar analytic results, subject to an
acceptable degree of imprecision or error.
Utility refers to the relative usefulness of the
information to its intended users.
Information Quality Assurance Guidelines
In accordance with OMB's guidelines, the level of quality
assurance appropriate for information will vary according to the relative
importance of the information and the costs and benefits of requiring additional
assurances for the particular information. The NLRB has created the following
guidelines to describe its quality standards and formalize a correction
mechanism.
Quality. The NLRB takes pride in the quality of its
information and is committed to disseminating information that meets the NLRB's
already rigorous standards for objectivity, integrity and utility. Before the
NLRB disseminates any information to the public, it is thoroughly reviewed by
expert staff and appropriate levels of management. The NLRB's current internal
review and approval policies and procedures ensure, to the best of the NLRB's
ability, that the NLRB's disseminated information and data are accurate and
timely, appropriate for external consumption, uncompromised and useful to the
public. The NLRB will also apply the OMB and NLRB information quality guidelines
to the collection and use of information under any Paperwork Reduction Act (PRA)
clearance submissions to OMB.
Integrity. The NLRB's Information Technology Branch has
established policies for carrying out the NLRB's information security program
pursuant to the Computer Security Act of 1987, the Government Information
Security Reform Act of 2000 and the Security of Federal Automated Information
Resources, OMB Circular A-130 (February 8, 1996). The NLRB's information
security program encompasses those measures necessary to protect the NLRB's
information resources. These measures include providing, for each IT project:
(i) the appropriate technical, personnel, physical, administrative, environ-
mental and telecommunications safeguards; and (ii) continuity of operations
through contingency or disaster recovery plans. The protective measures cover
the following information resources: data, applications, software, hardware,
physical facilities and telecommunications. The NLRB's information security
program assures that each automated information system has a level of security
that is commensurate with the risk and magnitude of the harm that could result
from the loss, misuse, unauthorized disclosure or improper modification of the
information contained in the system.
Utility. The NLRB evaluates and determines the audience
for whom the information to be disseminated is intended and will benefit. The
NLRB is committed to maximizing the utility of the information it disseminates
to the public. To this end, information and the appropriate form and vehicle for
its dissemination are evaluated and reviewed by the relevant subject matter
experts on a given project, along with appropriate levels of management within
the NLRB, before the information is disseminated to ensure its usefulness to the
intended audience. This includes ensuring that the information is organized and
written in a manner that facilitates its understanding and use by the intended
audience. The information also is reviewed to ensure its timeliness and
continuing relevance for the intended audience.
Objectivity. The NLRB is committed to disseminating
information that is accurate, clear, complete and unbiased both in its content
and in its presentation. The relevant subject matter experts and appropriate
levels of management review information before it is disseminated, among other
things, to evaluate whether the information is accurate, reliable and unbiased,
including an assessment of collection, generation, and analysis of relevant
information and data. The review also considers the presentation of the
information to ensure that it is put in the proper context and presented in a
clear, complete and unbiased manner. Where appropriate, in the context of
certain rulemakings for example, the NLRB also identifies the sources of
supporting data so that the public can assess for itself the objectivity of
those sources.
Influential Information. Any information deemed to be
"influential" as defined in these guidelines will be reviewed by subject matter
experts within the NLRB and appropriate levels of management to ensure adequate
disclosure about underlying data and methods of analysis to facilitate
reproducibility of the information by qualified third parties.
General Categories of Information Subject to the
Guidelines
- Reports
on Board Activities. The Information Guidelines apply to general information
about the NLRB, whether it appears on the Agency's Web site, in written
materials, or other forms of communication. The Guidelines apply to the
following:
Annual Report of the NLRB that highlights
operations, decisions, and statistical data for each fiscal year.
Monthly
Election Report that lists the results of employees' secret- ballot voting in
NLRB-conducted representation cases. This compilation is arranged by union, with
employer name and location.
Weekly Summary of NLRB Cases that provides a
synopsis of NLRB cases and documents.
- Information
Disseminated through the Rulemaking Process -- With Notice and Comment.
The
NLRB rarely engages in rulemaking. Before the NLRB disseminates a proposed or
final rule, expert staff prepare drafts of the rule, that, when appropriate, are
circulated to other staff members having direct or complementary subject matter
expertise and finally are reviewed and approved by the General Counsel and/or
the Board or Executive Secretary of the Board. The Agency's infrequent proposed
rulemakings generally include a public comment process pursuant to the
Administrative Procedure Act ("APA"). These procedural safeguards should assure
a response to comments on the quality of information in the proposed rule and
provide affected parties an opportunity to contest the final decision. The NLRB
normally will review any correction request about a pending rulemaking through
the notice and comment process and not through the correction request procedures
described below. However, as described below in the "Requests for Correction"
section, if an individual or entity can show that an earlier response would not
unduly delay the NLRB and would avoid the potential for actual harm, the NLRB
will attempt to resolve the information quality complaint before the final
Agency action.
- Other
NLRB Publications. The Information Guidelines apply to publications such as
"The NLRB--What it is, What it does," "Basic Guide to the National Labor
Relations Act," "The NLRB and You-- Representation Cases," "The NLRB and
You--Unfair Labor Practices," and "Your Government Conducts an Election".
Information Outside the Scope of the Guidelines
Based on OMB's definitions of "dissemination" and "information,"
several types of information disseminated by the NLRB and members of the NLRB
staff do not fall under these guidelines. Excluded categories include:
- Distributions
intended to be limited to NLRB employees or contractors, such as internal
operating procedures, training manuals and requests for proposals.
- Disseminations
intended to be limited to intra- or inter-agency sharing of government
information, such as the NLRB's annual budget and the NLRB's plans and reports
pursuant to the Government Performance and Results Act of 1993.
- Opinions of
individual Board and staff members, where the author's presentation states that
the information is that person's opinion rather than fact or the NLRB's views.
These include articles, speeches, panel presentations, special studies and
academic papers authored by staff members that state that the views expressed in
their work are their own views and do not necessarily reflect the views of the
NLRB.
- Responses to
requests for agency records under the Freedom of Information Act, the Privacy
Act, the Federal Advisory Committee Act or other similar laws.
- Correspondence
with individual entities or persons.
- NLRB press
releases, where substantive facts have been disseminated elsewhere.
- Archival
records maintained by the NLRB.
- Information
from third parties, for which the NLRB is merely a conduit, and public comment
letters.
- Distributions
intended to be limited to subpoenas or adjudicative processes, including NLRB
orders, opinions, amicus and other briefs. Adjudicative processes also include
factual allegations by the staff during the investigative and trial phases of
cases. Due to well-established procedural safeguards and rights to address the
quality of factual allegations and adjudicatory decisions, as well as
opportunities to appeal decisions, these guidelines do not provide parties to
such adjudicative proceedings additional procedural rights of challenge or
appeal.
It should be noted that the intra- or inter-agency government
document distributions listed above are documents that would not normally be
disseminated to the general public, but would be provided to a requestor in
response to an individual request. Some are posted to the NLRB Web site as a
matter of convenience for potential requestors rather than for purposes of
dissemination to the public in general. The Agency, therefore, has determined
that such documents are not information dissemination products to which these
Guidelines apply, and the administrative procedure for requests for correction
of information set forth in below are not applicable to such documents. It
should be noted, however, that these documents are subject to quality control
procedures that are at least as stringent as those applied to the information
dissemination products that are covered by these Guidelines. In fact, most
documents of this kind are not only prepared by subject matter experts and
reviewed by NLRB office directors, but also must be approved by the General
Counsel, the Chairman or the full Board, as appropriate, prior to their
submission or publication. Documents of this kind also are subject to existing
procedures for review, generally by Congress and/or OMB, and any needed
corrections to information contained in such documents are made through those
existing procedures.
The correction process is designed to provide a mechanism for
affected persons to seek correction of information disseminated by the NLRB that
does not comply with the NLRB's or OMB's information quality guidelines. The
definition of "affected person" in the previous sentence is an individual or an
entity that may use, benefit, or be harmed by the disseminated information at
issue. These guidelines are applicable to information that the NLRB disseminates
on or after October 1, 2002, whether or not the information was previously
disseminated.
This process does not necessarily guarantee a correction in
every instance. Rather, the decision of whether a correction is appropriate, and
what degree of correction is appropriate, will be determined by the nature,
completeness and timeliness of the information involved and such factors as the
significance of the correction on the users of the information and the magnitude
of the correction. Responses may be in the form of personal contacts by letter
or telephone, form letters, press releases or mass mailings that correct widely
disseminated errors or address a frequently raised request. With respect to
proposed rules, the thorough consideration required by the APA process normally
should provide an adequate complaint and appeal process. Accordingly, the notice
and comment process is the presumptive means by which an affected person may
address the quality of data in a proposed rulemaking. If a final rule
incorporates new facts or data that were not available for public comment in
connection with the proposed rule, these new facts or data will be addressed
through this correction request process.
In cases where the Agency disseminates a study, analysis, or
other information prior to the final Agency action or information product
publication, requests for correction will be considered in those cases where the
Agency has determined that: 1) a response would not unduly delay issuance of the
Agency action or information product, and 2) the complainant has shown a
reasonable likelihood of suffering actual harm from the Agency's dissemination
if the Agency does not resolve the complaint prior to the final Agency action or
information product dissemination.
The NLRB's Director, Division of Information, is the initial
point of contact for correction requests, and that Office will refer matters to
be resolved to the appropriate division or office within the NLRB. If the matter
is resolved at the division/office level, the staff will use reasonable efforts
to send its response to the requestor within 60 days of the date the office or
division received the request. If the resolution of the matter is particularly
complicated or would benefit from consultation with other divisions or agencies,
the NLRB will inform the requestor that more time is required, and indicate the
reason why and an estimated decision date.
Request Format. To be treated as a data quality
correction request under these guidelines, any affected person seeking
correction of NLRB- disseminated data should submit a request in writing
(letter, fax or by e- mail) and include the following:
- A
description of the facts or data the requestor seeks to have corrected;
- An
explanation of how the requestor is an affected person with regard to those
facts or data;
- The factual
basis for believing the facts or data need to be corrected for failure to comply
with OMB or NLRB standards;
- A proposed
resolution, including the factual basis for believing the facts or data in the
requestor's proposed resolution are correct;
- The
consequences of not implementing the proposed resolution; and
- The
requestor's contact information, including name, address, daytime telephone and
fax numbers and e-mail address.
Requests should be marked "Data Quality Correction Request " on
the first line of the envelope directly above the mailing address and on the
correspondence itself, in the case of letters, or in the "Subject" line, in the
case of e-mail correspondence. E-mail correspondence should be sent to the
following address: dataquality@NLRB.gov. Letters should be addressed to:
NLRB
Director, Division of Information
Attn: Data
Quality
1099 14th Street, NW
Washington, DC 20570
Processing Data Quality Correction Requests. The
Director, Division of Information, will, if necessary, route the request to the
head of the appropriate division or office within the NLRB who will, in turn,
ensure that: (i) the request is reviewed; (ii) any appropriate corrective action
is taken; and (iii) a response to the request is made.
The NLRB will normally respond to requests for correction of
information within 60 calendar days of receipt. If the request requires more
than 60 calendar days to resolve, the NLRB will inform the requestor that more
time is required, and indicate the reason why and an estimated decision
date.
Requests for Reconsideration. If the requestor does not
agree with the response, the requestor may send a request for a reconsideration
of the response. The reconsideration request must be postmarked (or, in the case
of e-mail, date-stamped) within 30 calendar days of the date that the NLRB
transmitted its decision on the original request for correction. Requests for
reconsideration that are received by the NLRB after the 30-calendar day deadline
may be denied as untimely. The request for reconsideration should include a copy
of the original request, a copy of the original response (if in writing) or a
summary of the response (if oral), and the following:
- A statement
describing why the response to the original complaint did not comply with the
data quality guidelines or why the requestor disagrees with the original
response; and
- The
requestor's contact information, including name, address, daytime telephone
number and email address.
Reconsideration requests should be marked "Request for
Reconsideration of Data Quality Correction " on the first line of the envelope
directly above the mailing address and on the correspondence itself, in the case
of letters, or in the "Subject" line, in the case of e-mail correspondence.
E-mails should be sent to the following address: dataquality@NLRB.gov. Letters
should be addressed to:
NLRB
Director, Division of Information
Attn: Data
Quality
1099 14th Street, NW
Washington, DC 20570
Processing Reconsideration Requests. The Director,
Division of Information, will route the reconsideration request to the Deputy
General Counsel or the Executive Secretary, depending on whether the division or
office that processed the original request is under the Board or General
Counsel. The Deputy General Counsel or Executive Secretary may decide the matter
themselves, or designate another official to render a decision on the request.
The Deputy General Counsel, the Executive Secretary, or the designated official
will review the original response, determine if additional action is
appropriate, and use reasonable efforts to send a response to the
reconsideration request within 30 days of its receipt by the Director of the
Division of Information. If the reconsideration request requires more than 30
days to resolve, the NLRB will inform the requestor that more time is required,
and indicate the reason why and an estimated decision date.
The NLRB is required to provide an annual fiscal year report to
OMB, beginning January 1, 2004, providing information on the number, nature, and
resolution of complaints received by the Agency concerning compliance with OMB
or Agency Information Quality guidelines.
This is the Office of Inspector General's (OIG) submission for
the Agency's information quality guidelines for information disseminated to the
public. Pursuant to the Inspector General Act, 5 U.S.C. App.(as amended), the
OIG is a statutorily independent component of the Agency with responsibility to
investigate and report waste, fraud and abuse in the Agency's programs and
operations. Applying Agency-wide guidelines to the OIG would undermine the OIG's
independence by having another office in the Agency review the methodology and
preparation of the OIG's work. In addition, an Inspector General shall be under
the "general supervision" of the agency head or the officer next in rank below
the agency head, "but shall not report to, or be subject to supervision by, any
other officer of such establishment." Inspector General Act, § 3(a).
The conflict between the Agency-wide guidelines and the
Inspector General Act can be resolved by the development and issuance of OIG
information quality guidelines in accordance with Section 515 of PL 106-554 that
will provide comparable assurances and procedures to the public. The guidelines
set forth below will apply to OIG audit and inspection reports that are posted
on the OIG's Web site. The guidelines will not apply to reports of investigation
of employee misconduct or illegal activity that are submitted to Federal or
State prosecutors for purposes of criminal prosecution or to the Agency for
purposes of administrative discipline. These guidelines will also not apply to
memoranda of law, or other legal advice, prepared by the OIG Counsel to assist
OIG components in the performance of their responsibilities. The guidelines are
intended to ensure accuracy in OIG reports disseminated to the public. The steps
described below reflect the OIG normal practice and may vary to some degree from
one review to another. This description does not confer any rights upon a
subject or witness of an OIG investigation to a pre-issuance review, which is
reserved to the Inspector General's discretion and judgment. The remedies
provided in these guidelines are limited to that which is set forth below.
Oversight Management Responsibility
The Counsel to the Inspector General will be responsible for
overall implementation and oversight of information quality guidelines for the
OIG. The Counsel to the Inspector General will be responsible for receiving and
responding to requests for corrections and for producing the annual report to
OMB regarding complaints and how they were addressed. The Inspector General will
be responsible for considering and responding to requests for reconsideration of
requests for corrections.
Standards for Disseminated Information
The OIG has adopted standards of quality that assure utility,
objectivity, and integrity based on the OMB guidelines published in the Federal
Register on September 28, 2001 (66FR 49718) and on February 22, 2002 (67FR
8452). In addition, statistical information disseminated by the OIG is based on
sound statistical methods and the principle of transparency. Finally,
influential information is subject to an added level of scrutiny.
For purposes of these guidelines, the following definitions
apply:
Utility means that the information to be disseminated is
useful to its intended users including the public.
Objectivity means that disseminated information is
substantively accurate, reliable, and unbiased, and presented in a clear,
complete, and unbiased manner.
Integrity means that information is protected from
unauthorized access, corruption, or revision to ensure that disseminated
information is not compromised through corruption or falsification.
Sound statistical methods means that methods are used to
produce information that is accurate, reliable, and unbiased.
Transparency refers to a clear description of the methods,
data sources, assumptions, outcomes, and related information that will allow the
data user to understand how the information produced was designed or
produced.
Influential information means information that is expected to
have a clear and substantial impact at the national level on major public or
private policy decisions.
Application of Standards of Quality by the OIG
The OIG Audit staff is responsible for independent audits of
Agency programs as well as audits of entities doing business with the Agency.
Audits of Agency programs and operations are posted on the OIG part of the
Agency's Web site.
The OIG has standards and review procedures in place that assure
that information disseminated to the public is reviewed for objectivity,
utility, integrity, the use of sound statistical methods, and transparency of
methods, sources, assumptions, and outcomes.
The OIG adheres to the Government Auditing Standards,
issued by the Comptroller General of the United States (the Yellow Book), and
the Inspector General Manual (IG Manual). The Yellow Book prescribes
generally accepted government auditing standards and the IG Manual establishes
the policies and procedures to be followed by the Audit staff, including the
supervisory review of audit working papers and reports and the independent
referencing of significant audit reports prior to issuance. Further, the OIG
audit process undergoes both management and peer reviews on a recurring
basis.
In addition to these standards, each audit is subject to
extensive review within the OIG. Also, a copy of each audit report is provided
in draft to the Agency component that was the subject of the audit for review
and comment prior to final dissemination. The audited entity's comments are
published in the final report.
Prior to posting on the Agency's Web site, the report is
reviewed by the Counsel to assure compliance with the Privacy Act and any other
applicable statute or regulation.
The inspections provide an alternative mechanism to traditional
audits and investigations to review Agency programs and activities. Inspection
reports are posted on the Agency's Web site.
In accord with the intent of PL 106-554, the inspection process
follows guidelines ensuring that the information in inspection reports is
objective, useful, and based on sound evaluation principles, including the
proper use of statistical methods. Inspection reports also list sources,
assumptions, and outcomes.
The OIG follows the Quality Standards for Inspections promulgated by the President's Council on Integrity and Efficiency, issued in
March 1993. These guidelines, referred to as the "Blue Book," address 12 major
standards for ensuring quality work: Qualifications, Independence, Due
Professional Care, Quality Control, Planning, Data Collection and Analysis,
Evidence, Supporting Documentation, Timeliness, Fraud and Other Illegal Acts,
Reporting, and Follow-up.
In addition to these standards and procedures, each report
undergoes extensive review within the OIG. Also, a draft of the report is
provided to the component that is the subject of the review for comment prior to
final publication. The component's comments are incorporated into the final
report.
Prior to posting on the Agency's Web site, the report is
reviewed by the Counsel to assure compliance with the Privacy Act and any other
applicable statute or regulation.
Information Correction Request and Appeal Process
Submitting a Formal Request for Correction. All requests for
correction of OIG information must be submitted by letter, fax, or e- mail to
the OIG. Requests for correction should include the following information:
- A statement
that the request for correction of information is submitted under the OIG's
Information Quality Guidelines.
- An
explanation of how the requestor is an affected person with regard to those
facts or data.
- Requestor
contact information, including the name, mailing address, telephone number, fax
number (if any), e-mail address (if any), and organizational affiliation (if
any) of the person requesting the correction.
- Description
of information to be corrected, including the name of the OIG report or data
product, the date of issuance or other identifying information such as the URL
of the web pages, and a detailed description that clearly identifies the
specific information contained in that report or data product for which a
correction is being sought.
- Explanation
of noncompliance with OMB and/or OIG Information Quality Guidelines. This should
include an explanation that describes how information fails to meet either the
OMB or OIG Information Quality Guidelines.
- Explanation
of the effect of the alleged error. An explanation that describes how the
alleged error harms the requestor or how a correction would benefit the
requestor.
- Recommendation
and justification for how the information should be corrected. An explanation
that gives the requestor's specific recommendations for how the information
should be corrected and that describes the requestor's position as to why the
OIG should adopt those recommendations.
- Supporting
documentary evidence, such as comparable data or research results on the same
topic, which will help in evaluating the merits of the request.
Requestors 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. The OIG will base its decision on the merits of the
information provided by the requestor and will not attempt to contact the
requestor to obtain additional information when the submission by the requestor
is incomplete.
Requests should be marked "Data Quality Correction Request " on
the first line of the envelope directly above the mailing address and on the
correspondence itself, in the case of letters, or in the "Subject" line, in the
case of e-mail correspondence. E-mail correspondence should be sent to the
following address: OIGHotline@NLRB.gov. Letters should be addressed to:
NLRB
Office of Inspector General
Attn: Data
Quality
1099 14th Street, NW
Washington, DC 20570
OIG Review of the Request for Correction
The request for correction will be processed by the Counsel to
the Inspector General. These guidelines apply to all applicable information the
OIG disseminates on or after October 1, 2002, regardless of when the information
was first disseminated. Based on the explanation and evidence submitted with the
request for correction, the OIG audit staff will conduct a review of the
information being challenged, the processes that were used to create and
disseminate the information, and the conformity of the information and those
processes with both OMB's and OIG's Information Quality Guidelines. The audit
staff will submit its response to the request for correction to the Counsel.
After a review of the request for correction and the response, the Counsel will
determine whether a correction is warranted, and, if so, what corrective action
it will take.
Corrective action will be determined by the nature and
timeliness of the information involved and such factors as the significance of
the error on the use of the information and the magnitude of the error. The OIG
is not required to change, or in any way alter, the content or status of
information based only on the receipt of a request for correction.
The OIG need not respond substantively to frivolous or
repetitive requests for correction. Nor does the OIG have to respond
substantively to requests that concern information not covered by the guidelines
or from a person whom the information does not affect.
OIG Response to the Request for Correction
After the Counsel has made its final determination pertaining to
a request for correction of information, he will respond to the requestor by
letter, e-mail, or fax. The response will explain the findings and the actions
to be taken (if any) in response to the complaint.
The OIG will normally respond to requests for correction of
information within 60 calendar days of receipt. If the request requires more
than 60 calendar days to resolve, the OIG will inform the requestor that more
time is required, and indicate the reason why and an estimated decision
date.
Request for Reconsideration of OIG's Decision
If the requestor disagrees with the OIG's denial of the request
or with the corrective action the OIG intends to take, the requestor may file a
request for reconsideration with the Inspector General (Reconsideration
Official). Persons desiring to file a request for reconsideration should submit
the request by letter, fax, or e-mail. Persons requesting reconsideration should
also submit written material to support their case for reconsideration. They
should not resubmit the information originally submitted to support the request
for correction.
Requests for reconsideration must be filed with the OIG
(postmarked or shipped by an overnight delivery service) within 30 calendar days
of the date that the OIG transmitted its decision on the original request for
correction. Requests for reconsideration that are received by the OIG after the
30- calendar day deadline will be denied as untimely.
Requests should be marked "Data Quality Correction Request--
Reconsideration " on the first line of the envelope directly above the mailing
address and on the correspondence itself, in the case of letters, or in the
"Subject" line, in the case of e-mail correspondence. E-mail correspondence
should be sent to the following address: OIGHotline@NLRB.gov. Letters should be
addressed to:
NLRB
Office of Inspector General
Attn: Data
Quality
1099 14th Street, NW
Washington, DC 20570
OIG Review and Response to the Request for
Reconsideration
The Inspector General will review the information in question
and the material submitted in support of the request for reconsideration, the
material submitted with the original request for correction, and the OIG'
response to that request. The Inspector General will then arrive at a decision
regarding the request for reconsideration.
After the Inspector General has made a decision on the request
for reconsideration, the OIG will respond to the requestor by letter, e-mail, or
fax. The response will explain the Inspector General's decision and the action
the OIG will take (if any) in response to the request for reconsideration.
The OIG will respond to all requests for reconsideration within
30-calendar days of receipt.
- Beginning on
January 1, 2004, the OIG will submit a report to the Office of Management and
Budget on the number and nature of complaints received by the OIG regarding its
compliance with Sec. 515 of Public Law 106-554 and how those complaints were
resolved.
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