1) Use of websites to keep public informed about data quality. OMB recommends that agencies make use of websites to inform the public about Data Quality Guidelines, what they are, how to submit a request, major decisions, etc. Many in the public interest community suggested during the public comment period that agencies establish an online docket providing information on who has submitted a complaint, the substance of the complaint, and the disposition of the complaint.

2) Rulemaking and other procedures. OMB agreed with various agencies that made the point that a separate data quality process would be unnecessary and duplicative when rulemaking, adjudications, and other administrative procedures already allow for comments and complaints. OMB recommended that any data quality complaints be considered during these processes. OMB also makes an important point in its recommended language noting that the data quality requests cannot unduly delay rulemaking. This was a major concern among many public interest groups.

3) Deadlines on decisions for requests and appeals. OMB recommends that agencies provide a written response within 60 calendar days of receiving a data quality request. The recommended language allows agencies more time should they need it, so long as they send the request or written explanation and an estimated completion date.

The memo from OIRA administrator John Graham reads as if it may be the last piece of written guidance from OMB to the agencies on Data Quality Guidelines. It restates that the agency "guidelines must be issued by October 1, 2002." But the memo notes that OMB still intends to weigh in on agency guidelines. "My staff also will be working with your staff in the next few days concerning other innovative highlights from agency guidelines that may deserve your consideration."