OFFICE OF INSPECTOR GENERAL INFORMATION QUALITY GUIDELINES
The following comprises the Office of Inspector General (OIG) Information Quality Guidelines. They are intended to be supplemental to U.S. Department of Agriculture’s Quality of Information Guidelines.
These guidelines are intended to ensure accuracy in OIG reports disseminated to the public and have been adopted pursuant to Section 515 of Public Law 106-554 (codified at 44 U.S.C. § 3516 note and commonly referred to as the Data Quality Act). They will apply to OIG audit reports, reports of investigation that are disseminated to the public, and inspection reports. They will not apply to reports of investigation of employee misconduct or illegal activity that are only submitted to Federal or State prosecutors for purposes of criminal prosecution or to U.S. Department of Agriculture (USDA) components for purposes of administrative discipline. Additionally, they will not apply to memoranda of law, or other legal advice, prepared by the OIG Office of Counsel to assist OIG components in the performance of their responsibilities.
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 what is set forth below.
Oversight Management Responsibility
The Deputy Inspector General will be responsible for overall implementation and oversight of information quality guidelines for the OIG.
The Deputy Inspector General will be responsible for receiving and responding to requests for correction and for producing the annual report to the Office of Management and Budget (OMB) regarding complaints and how they are addressed.
The Inspector General will be responsible for considering and responding to requests for reconsideration of requests for correction.
Standards for Disseminated Information
The OIG has adopted standards of quality that assure utility, objectivity, and integrity. 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, clear, complete, and presented in an 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 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 Office of Audit is responsible for independent audits of USDA programs, computer systems, and financial statements, as well as audits of entities doing business with or receiving benefits from USDA. Audits of USDA programs and operations and of outside entities are normally posted on the OIG web site.
The Office of Audit 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. The IG Manual establishes the policies and procedures to be followed by the Office of Audit, including the supervisory review of audit working papers and reports and the independent referencing of significant audit reports prior to issuance. Further, the Office of Audit undergoes both management and peer reviews on a recurring basis.
In addition to these standards, each audit is subject to extensive review within the Office of Audit. Audits are also reviewed by OIG senior management. A copy of each audit report is provided in draft to the USDA agency 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 OIG website, the audit reports are reviewed by the OIG Office of Counsel to assure compliance with the Freedom of Information Act and the Privacy Act.
The OIG Office of Investigations is the law enforcement arm of USDA, with USDA-wide investigative jurisdiction. The Office of Investigations conducts investigations of significant criminal activities involving USDA programs, operations, and personnel. Generally, reports of investigation are not disseminated to the public by OIG and must be requested through the Freedom of Information Act (FOIA). However, on occasion, OIG may disseminate a report of investigation to the public.
The Office of Investigations adheres to the Quality Standards for Investigations, issued by the President’s Council on Integrity and Efficiency and the Executive Council on Integrity and Efficiency and the Inspector General Manual (IG Manual). The Quality Standards for Investigations prescribes general and qualitative investigative standards. The IG Manual establishes the policies and procedures to be followed by the Office of Investigations. In addition, the Office of Investigations undergoes peer review on a recurring basis.
The Office of Inspections and Research (OIR) conducts inspections of USDA programs and activities. Inspections include evaluations, inquiries, and similar types of reviews that do not constitute an audit or a criminal investigation. Final inspection reports will normally be posted on the OIG web site. In conducting its work, the OIR adheres to the Quality Standards for Inspections issued by the President’s Council on Integrity and Efficiency and the Executive Council on Integrity and Efficiency.
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 Deputy Inspector General. 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.
- 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, 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 or OIG Information Quality Guidelines, including an explanation that describes how information fails to meet the OMB or OIG Information Quality Guidelines.
- Explanation of the effect of the alleged error, including 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, including 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.
- Documentary evidence that will help in evaluating the merits of the request, such as comparable data or research results on the same topic.
Requestors 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.
OIG Review of the Request for Correction
The request for correction will be processed by the Deputy Inspector General. Based on the explanation and evidence submitted with the request for correction, the OIG office that produced the report 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 OMB’s and OIG’s Information Quality Guidelines. The preparing office will submit its response to the request for correction to the Deputy Inspector General. After the Deputy Inspector General has completed review of the request for correction and the response and consulted with OIG Management, the Deputy Inspector General will determine whether a correction is warranted, and, if so, what corrective action to 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, the magnitude of the error, and the cost of undertaking a correction. 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 making a final determination pertaining to a request for correction of information, the Deputy Inspector General will respond to the requestor by letter, e-mail, or fax. The response will explain the finding 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 submit 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 45 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 45-calendar day deadline will be denied as untimely.
OIG Review and Response to the Request for Reconsideration
In making a determination regarding 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’s response to that request.
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 OIG’s decision and the action the OIG will take (if any) in response to the request for reconsideration.
The OIG will normally respond to all requests for reconsideration 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.
Beginning on January 1, 2007, the OIG will submit an annual report to OMB on the number and nature of complaints received by the OIG regarding its compliance with Sec. 515 of Public Law 106-554, codified at 44 U.S.C. § 3516 note, and how those complaints were resolved.