Correspondence

Dear Secretary Duncan: 

Congress passed the Data Quality Act to ensure the federal government utilizes reliable and accurate data as it develops guidelines and regulations. Under the Act, the Office of Management and Budget (OMB) requires federal agencies to publish guidelines for the purpose of “ensuring and maximizing the quality, objectivity, utility, and integrity of information (including statistical information) disseminated by the agency…” To comply with the OMB directive, the Department of Education issued ‘Information Quality Guidelines,’ a document that outlines the Department’s basic standard of data quality and process for reviewing the quality of information before it is publicly released. We are interested in learning more about how the Department complied with the Data Quality Act as it developed the proposed regulation defining ‘gainful employment’ and published the data supporting the proposed regulation. 

According to the Department’s ‘Information Quality Guidelines,’ information or data put forward by the Department will be judged on three factors: utility, objectivity, and integrity. Beyond the minimum standards outlined in each of these categories, the guidelines have a higher standard for information that is deemed ‘influential,’ which is defined as information that is “reasonably likely to have a clear and substantial impact on public policies or private sector decisions if disseminated.” The ‘Information Quality Guidelines’ further state that influential information must be presented with accompanying information that allows an outside entity to be able to reproduce the information.