The OIG’s information quality policy establishes a means for ensuring that the OIG’s reports and work products contain accurate information.  In addition, this policy establishes a means by which persons who believe that an OIG report contains erroneous information can request a change.  This policy is an extension of the EAC’s information quality standards.

U.S. Election Assistance Commission
Inspector General Manual

Volume: 1                                                  Administration Chapter: 3
General Policies: 1.3.6                                  Subject: 6       

Information Quality

I. Purpose

This chapter establishes the policy of the Office of Inspector General with regard to ensuring information disseminated by the OIG is reviewed for accuracy and that there is a mechanism in place to correct information.

II. Authorities

The Paperwork Reduction Act, 44 U.S.C. §3501 et seq., as modified by the Data Quality Act and implemented by the Office of Management and Budget (OMB), requires most Federal agencies to issue guidelines to ensure the quality of information disseminated to the general public.  These agencies must establish mechanisms by which persons may seek corrections of such information, and must also report the number and nature of information quality complaints to the OMB.  

III. Responsibilities

The Inspector General is responsible for ensuring that information disseminated by the OIG satisfies applicable information quality requirements, and that corrections are made promptly when warranted.  All OIG employees support the Inspector General in fulfilling this responsibility.

IV. Quality Guidance

A. EAC’s Information Quality Guideline

OIG information quality guidelines are adopted in conformity with the applicable EAC information quality guidelines.  OIG information quality guidelines are to be read in harmony with EAC guidelines.  Any potential conflicts between the OIG and EAC information quality guidelines should be addressed to the Inspector General for resolution.

B. Definitions

1. Information. 

Any communication or representation of knowledge, conveyed in any form or medium, however disseminated.  Such knowledge may include facts or data, but does not include opinion unless that opinion is the OIG’s official position.  Information subject to these guidelines includes information that the OIG generates, as well as information provided to the OIG by other parties.  However, while the guidelines apply to information disseminated by the OIG to the public on a web page, they do not apply to hyperlinks from the OIG website to information that others disseminate.

2. Influential Information.

Information that has or will have a clear and substantial impact on important public policies or important private sector decisions.  A clear and substantial impact is one that has a high probability of occurring; possible or arguable impacts do not suffice.  Even if information will have a clear and substantial impact, that impact is not influential if the impact is on a trivial policy or decision only.

This inquiry must consider whether the information has or would have a significant economic impact.  Generally speaking, the greater economic impact of information at issue, the more likely that it will qualify as "influential."  In evaluating the actual or potential economic impact of information, the OIG will use criteria set forth in Executive Order 12866, Section 2(f)(1), which requires "an annual effect on the economy of $100 million or more or [a material adverse] affect [on] the economy, a sector of the economy, productivity, competition, jobs, the environment, public health or safety, or State, local, or tribal governments or communities [.]"  It is expected that few pieces of information may reach this threshold.  In its discretion, the OIG may find sufficiently significant economic impact for amounts below $100 million, but such findings should be documented thoroughly.

Notwithstanding the previous paragraph, the Inspector General may designate classes of information as "influential."

3. Dissemination.

Affirmative, intentional distribution to the public by the OIG.  The following acts do not constitute dissemination:

• Accidental or inadvertent disclosures;

• Releasing information in response to a request from the public, such as a FOIA request;

• Releasing information to government employees, contractors, or grantees, if the information is to be restricted or limited to those entities;

• Inter- or intra-agency disclosure;

• Press releases and other disclosures of a temporary, ephemeral nature, regardless of medium, advising the public of a fact, even or activity or a finite duration;

• Disclosures required or compelled by law;

• Correspondence with individuals, regardless of medium;

• Information provided to Congress as part of  legislative or oversight processes, not simultaneously disseminated to the public;

• Archival records disseminated by Federal Agency libraries or similar Federal Data repositories;

• Library holdings;

• Public filings;

• Release of third party information, views or opinions that are clearly identified as not having been generated, produced, adopted or sponsored by the OIG; and

• Procedural, operational, policy and internal manuals not primarily intended for public dissemination.

4. Quality.

The extent to which information reflects the following aspects:

a. Utility

Usefulness to the information’s intended users, including the public if applicable.  Utility is to be measured by reference to established criteria, such as accessibility or timeliness.

b. Objectivity

Accuracy, completeness, reliability, clarity, and lack of bias in information collection, substance, manipulation and presentation.

c. Integrity

The degree to which information has been protected from unauthorized access or revision to ensure that the information has not been compromised through corruption or falsification.

C. Guidelines for Disseminated Audit Information

The OIG Audit Manual establishes policies and procedures for quality control relating to audit reports.  These quality control procedures will be used for all audit reports to ensure that the information therein is accurate.

D. Guidelines for Rulemaking

The Counsel to the Inspector General shall conduct pre-dissemination information quality reviews for all proposed rules.

V. Information Correction

A. Submitting Requests for Correction

The OIG adopts and implements the EAC procedures regarding receipt of request to correct information.

B. Processing Requests for Correction

Upon receiving a request for correction, the Inspector General will forward the request to the OIG employee who was responsible for the report or other information that was disseminated. 

The OIG employee will review the request for correction to determine if the complaint provides sufficient information to permit consideration of the request.  If not, the OIG employee will notify the requester and identify the additional information needed to consider the request.  Communications with the requester may occur by telephone, email, mail or fax.  However, a written record of the communication is preferred.

If the request contains sufficient information, the OIG employee will review the request to determine if it requires action to correct the information.  The OIG employee may also determine that the request does not require action because of one or more of the following reasons:

• The request is frivolous on its face;

• The request is not germane to the substance of the information at issue;

• The request is the same or substantively similar to a request to which the OIG has responded previously;

• The OIG did not actually disseminate the information that it is being asked to correct;

• The information at issue was distributed solely in correspondence with individuals, press releases, archival records, public filings, subpoenas, or adjudicative processes;

• The OIG disseminated the information at issue one year or more prior to receiving the request;

• The requester is not affected by the information in question;

• The information at issue has no continuing impact on OIG projects or policy decisions, on important private sector decisions, or on affected individuals;

• The request pertains to information in a final rule or other final document for which there was an opportunity for public comment or participation, when the requester could have sought correction of the information at issue, and the requester failed to do so; and/or

• The information at issue is exempt from disclosure under the FOIA or Privacy Act.

Upon review, if the information at issue satisfies the applicable information quality standards, the responsible OIG employee shall reject the request and document the reason(s) therefore.  If the information at issue does not satisfy the applicable information quality standards, the responsible OIG employee shall grant the request for correction and document the reasons therefore.  The OIG shall develop a correction plan to guide the OIG in its efforts to correct the information at issue.  The plan will consider the substantive corrections required to correct the information at issue, and the forum(s) in which the corrected information should be disseminated. 

C. Notifying the Requester

The OIG employee shall notify the requester of the OIG’s decision on the request within 60 days following receipt of the request.  Notifications shall be in writing.  The notification shall set forth the OIG’s reasons for rejecting or granting the request.  If a request for correction is accepted, the notification shall not include a copy of the correction plan.

If the request requires more than 60 calendar days to respond, the OIG employee will inform the requester that more time is required, indicate the reason why and provide an estimated decision date.  The notification shall advise the requester that appeals of the OIG’s decision, if any, must be filed within 10 days after receipt of the decision.  Appeals shall be filed in accordance with the EAC’s information quality guidelines.

D. Appealing Decisions

The Inspector General shall decide whether to grant an appeal.  The Inspector General shall notify the requester of the appeal decision within 60 days of the date of receipt of the appeal.  The notification shall be in writing and set forth the Inspector General’s decision and what corrective action, if any, will be taken.  Decisions on appeals are final.

If the appeal requires more than 60 days for response, the Inspector General shall notify the requester that more time is required, indicate the reason(s) why and provide an estimated decision date.

VI. Reporting

The OIG will provide all necessary information to the EAC for inclusion in the EAC’s report to OMB.