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Guidelines for Information Dissemination

Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the Institute of Museum and Library Services

The following guidelines describe IMLS'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.

These Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the Institute of Museum and Library Services are prepared under the Treasury and General Government Appropriations Act for Fiscal Year 2001, Section 515(b), and are designed to ensure and maximize the quality, objectivity, utility and integrity of information disseminated by IMLS.

SCOPE

IMLS' pre-dissemination review applies to information that IMLS first disseminates on or after October 1, 2002. IMLS' administrative mechanisms apply to information that IMLS disseminates on or after October 1, 2002, regardless of when IMLS first disseminated the information.

IMLS incorporates by reference the definitions set out in OMB's Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies, 67 Fed. Reg. 8451-8460 (Feb. 22, 2002).

ENSURING AND MAXIMIZING INFORMATION QUALITY

IMLS is authorized by statute to support and conduct, as appropriate, policy research, data collection, analysis and modeling, evaluation, and dissemination of information to extend and improve the Nation’s museum, library, and information services.

The agency has adopted a basic standard of quality (including objectivity, utility, and integrity) as a performance goal for all information that it disseminates. IMLS has taken appropriate steps to incorporate information quality criteria into IMLS information dissemination practices.

As a matter of good and effective agency information resources management, IMLS reviews the quality (including the objectivity, utility, and integrity) of information before it is disseminated. Information quality is integral to every step of IMLS' development of information, including creation, collection, maintenance, and dissemination. IMLS substantiates the quality of the information it has disseminated through documentation or other means appropriate to the information.

Generally, the office disseminating the information, such as the Office of Communications, the Office of the Chief Information Officer, or the Offices of Museum and Library Services, will be responsible for reviewing the quality of information before dissemination, with appropriate oversight by IMLS' Director or the Director's designees. The originating offices will use internal peer reviews and other review mechanisms to ensure that disseminated information meets quality standards including objectivity, utility, and integrity in both presentation and substance. Each office is responsible for ensuring that the pre-dissemination review is performed and documented at a level appropriate for the type of information disseminated.

The Chief Information Officer of the Institute of Museum and Library Services is responsible for IMLS compliance with pre-dissemination review under these guidelines.

INFORMATION CORRECTION MECHANISM

To facilitate citizen review, affected persons may seek and obtain, where appropriate, timely correction of information maintained and disseminated by IMLS that does not comply with OMB (67 Fed. Reg. 8451-8460, Feb. 22, 2002) or IMLS guidelines.

Requests for correction should be sent in writing, by mail, fax, or email to:

Information Change Request
Office of General Counsel
Institute of Museum and Library Services
955 L'Enfant Plaza North SW, Suite 4000
Washington, DC 20024

(202) 653-4787
(202) 653-4625
ogc@imls.gov

The request should clearly identify the information asserted to be incorrect, including the name of the publication or other source of information, the date of issuance, and a detailed description of the information to be corrected. The request should state specifically why the information should be corrected for failure to comply with OMB or IMLS guidelines and should suggest specific changes.

The request should include the requester's name, mailing address, fax number, email address, and telephone number. IMLS needs this information to respond to the request and to contact the requester as necessary.

If a request does not reasonably describe the information asserted to be incorrect, IMLS may request additional information.

IMLS will investigate and respond to requests for correction in a flexible manner, taking into consideration the nature and extent of the complaint, the nature and timeliness of the information involved, the significance of the correction to the use of the information, and the magnitude of the correction needed. Should IMLS determine that a correction is necessary, appropriate responses might include personal contacts by letter or telephone, press releases, website postings, errata sheets in publications, or mass mailings to correct a widely disseminated error or address a frequently raised complaint.

IMLS will generally notify the requester in writing of the agency decision on whether and how any corrections will be made within 60 calendar days of receipt of the request. If the request requires more than 60 calendar days to resolve, IMLS will inform the requestor that more time is required, will specify the reasons for the delay, and will provide an estimated decision date. If the requester does not agree with the agency's decision regarding corrective action, the requester may file for reconsideration by the Director within 30 calendar days of IMLS' decision. Such reconsideration requests will generally be resolved within 60 calendar days.

On an annual fiscal-year basis, IMLS will submit a report to the Director of OMB providing information (both quantitative and qualitative, where appropriate) on the number and nature of complaints received by IMLS regarding agency compliance with these guidelines and how such complaints were resolved. IMLS will submit these reports no later than January 1 of each following year, with the first report due January 1, 2004.

The General Counsel of the Institute of Museum and Library Services is responsible for resolution of requests for correction.

INFORMATION QUALITY CORRESPONDENCE

At this time, IMLS has received no information quality correction requests. IMLS will update this page if it receives any.

PEER REVIEW

Based on the review it has conducted, the Institute of Museum and Library Services believes that it does not currently produce or sponsor the distribution of influential scientific information (including highly influential scientific assessments) within the definitions promulgated by OMB. As a result, the Institute of Museum and Library Services has no agenda of forthcoming influential scientific disseminations to post on its website in accordance with OMB's Information Quality Bulletin for Peer Review (PDF, 265 KB).

COMPLIANCE WITH OMB MEMORANDUM M-19-15

On April 24, 2019, OMB issued a Memorandum to the Heads of Executive Departments and Agencies (M-19-15) to reinforce, clarify, and interpret agency responsibilities under the Information Quality Act.  The Institute of Museum and Library Services is in the process of revising these guidelines in accordance with M-19-15 and is committed to complying with each of the memorandum’s implementation updated, listed below.

Implementation Update 1.1: Drawing on experience implementing the Guidelines, agencies should revisit the parameters for identifying “influential information.” Agencies should provide specific guidance to program managers for determining the amount and type of pre-dissemination review necessary. Agencies should identify specific types of information the agency produces that are “influential” and should provide a rigorous process for determining whether types of information not specifically listed by the guidelines qualify as “influential.”

Implementation Update 1.2: When using scientific information, including third-party data or models, to support their policies, agencies must ensure compliance with the requirements of OMB's Information Quality Bulletin for Peer Review,

Implementation Update 1.3: When conducting peer review, agencies should ensure reviewers are asked to evaluate the objectivity of the underlying 4ata and the sensitivity of the agency's conclusions to analytic assumptions.

Implementation Update 1.4: When influential information that has been peer reviewed changes significantly (e.g., as a result of the peer reviewer comments, additional agency analysis, or further consideration), the agency should conduct a second peer review.

Implementation Update 2.1: When an agency makes information originally collected or developed by other Federal agencies available to the public in a cross-agency dissemination, each agency is responsible for the quality of the information they contribute, and that responsibility should be clearly communicated to the public.

Implementation Update 2.2: Agencies should provide the public with sufficient documentation about each dataset released to allow data users to determine the fitness of the data for the purpose for which third parties may consider using it. Robust practices may include developing a standard template or framework that provides data users with the relevant information. Safeguarding privacy and confidentiality is vital in the context of open data.

Implementation Update 2.3: Agencies should consider the potential for using existing data sources from both inside and outside the agency for statistical and research purposes, while protecting privacy and confidentiality.

Implementation Update 2.4: When designing or improving data collection systems, Departments should actively solicit comment from their statistical, research, and evaluation agencies about potential downstream uses. Agencies should describe such uses in the Information Collection Request submitted to OMB for review under the PRA.

Implementation Update 2.5: If agencies are considering secondary analysis of data that includes personally identifiable information, the agencies should coordinate with their Senior Agency Official for Privacy to meet all privacy requirements and manage privacy risks.

Implementation Update 2. 6: Agencies should develop procedures for clearly documenting and communicating the quality of administrative data that have the potential to be used for statistical purposes.

Implementation Update 3.1: Consistent with the Office of Science and Technology Policy's 2010 Memorandum for the Heads of Executive Departments and Agencies: Scientific Integrity, agencies should ensure that influential information is communicated transparently by including a clear explication of underlying assumptions, accurate contextualization of uncertainties, and a description of the probabilities associated with both optimistic and pessimistic projections, including best-case and worst-case scenarios.

Implementation Update 3.2: When an agency has performed analysis using a specialized set of computer code, the computer code used to process it should be made available to the public for further analysis, if consistent with applicable law and policy.

Implementation Update 3.3: Agencies should ensure that when using non-government sources to create influential information they communicate to the public sufficient information on the characteristics of the data and analysis, including its scope (e.g., temporal or demographic), generation protocols, and any other information necessary to allow-the public to reproduce the agencies' conclusions.

Implementation Update 3.4: Agencies should prioritize increased access to the data and analytic frameworks (e.g., models) used to generate influential information. All data disclosures must be consistent with statutory, regulatory, and policy requirements for protections of privacy and confidentiality, proprietary data, and confidential business information.

Implementation Update 3.5: Agencies should explore methods that provide wider access to datasets while reducing the risk of disclosure of personally identifiable information. In particular, tiered access offers promising ways to make data widely available while protecting privacy. Implementation of such approaches must be consistent with principles for ethical governance, which include employing sound data security practices, protecting individual privacy, maintaining promised confidentiality, and ensuring appropriate access and use.

Implementation Update 4.1: Agencies should revise their procedures to reflect more realistic timelines for RFCs. Revised procedures should, at minimum, provide that agencies will not take more than 120 days to respond to an RFC without the concurrence of the party that requested the request for correction.

Implementation Update 4.2: In its response to an RFC, agencies should not opine on the requestor 's or the agency's policy position.

Implementation Update 4.3: The agency response should contain a point-by-point response to any data quality arg11ments contained in the RFC and should refer to a peer review that directly considered the issue being raised, if available.

Implementation Update 4.4: Agencies should share draft responses to RFCs and appeals with OMB prior to release to the requestor for assessment of compliance with the above norms.

Implementation Update 4.5: To ensure the integrity of the appeals process, agencies should ensure that those individuals reviewing and responding to the appeals request were not involved in the review and initial response to the RFC.