Principles and Practices for a Federal Statistical Agency Third Edition (2005) / Chapter Skim
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Part II: Commentary
Part II: Commentary
Pages 13-48
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A statistical agency may be labeled a bureau, center, division, or office or similar title, so long as it is recognized as a distinct entity. Statistical agencies have been established for several reasons: (1)
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The work of federal statistical agencies is coordinated through the Interagency Council on Statistical Policy (ICSP) , created by the U.S.
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ESTABLISHMENT OF A FEDERAL STATISTICAL AGENCY One of the most important reasons for establishing a statistical agency is to provide information that will allow for an informed citizenry. A democracy depends on an informed electorate.
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The Census Bureau was established as a permanent agency in 1902 to conduct the decennial census and related statistical activities. Many federal statistical agencies that can trace their roots back to the 19th or early 20th century, such as the National Center for Education Statistics and the National Center for Health Statistics, were organized in their current form following World War II.
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There is no set rule or guideline for when it is appropriate to establish a separate federal statistical agency, carry on statistical activities within the operating units of departments and independent agencies, or contract for statistical services from existing federal statistical agencies or other organizations. Establishment of a federal statistical agency should be considered when one or more of the following conditions prevails:1 · There is a need for information on an ongoing basis beyond the capacity of existing operating units, possibly involving other departments and agencies.
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Federal statistical agencies are responsible for providing statistics on
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In order to provide information that is relevant to public issues, statistical agencies need to reach out to users of the data. Federal statistical agencies usually are in touch with the primary users in their own departments.
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Credibility is enhanced when an agency fully informs users of the strengths and weaknesses of the data, makes data available widely, and consults with users about priorities for data collection and analysis. Principle 3: A federal statistical agency must have a relationship of mutual respect and trust with respondents who provide data and all data subjects whose information it obtains.
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PRACTICES FOR A FEDERAL STATISTICAL AGENCY Practice 1: A Clearly Defined and Well-Accepted Mission A clear understanding of the mission of an agency, the scope of its statistical programs, and its authority and responsibilities is basic to planning and evaluating its programs and to maintaining credibility and independence from political control (National Research Council, 1986, 1997b)
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Among the agency heads with presidential appointments, such direct access currently is provided by legislation only for the Bureau of Labor Statistics. It is desirable for a statistical agency to have its own funding appropria
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Authority to decide the scope and specific content of the data collected or compiled is yet another important element of independence. Most 2Legislation and administrative actions have removed some of these organizational features for some statistical agencies.
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It also has the responsibility under the same act for reviewing all questionnaires and other instruments for the collection of data from 10 or more respondents. The budgetary constraints on statistical agencies and OMB review of data collections are ongoing; the other pressures depend, in part at least, on the relations between a statistical agency and those who have supervisory or oversight functions.
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When an agency modifies a customary release schedule for statistical purposes, it should announce and explain the change as far in advance as possible. Practice 3: Continual Development of More Useful Data Federal statistical agencies cannot be static.
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The Confidential Information Protection and Statistical Efficiency Act of 2002 (CIPSEA) , subtitle B, for the first time in the nation's history authorizes the sharing of business data among the three principal statistical agencies that produce the nation's key economic statistics -- the Bureau of Economic Analysis (BEA)
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. Historically, because statistical agencies are oriented toward the mission of their particular department, the longitudinal surveys they developed (and cross-sectional data activities as well)
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. Operational Methods Another area in which it is important for statistical agencies to be innovative concerns the methods used for data collection, processing, estimation, analysis, and dissemination.
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. Some statistical agencies have developed detailed quality profiles for some of their major series, such as those developed for the American Housing Survey (Chakrabarty, 1996)
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Using a framework developed collaboratively by the members of the Interagency Council on Statistical Policy, individual statistical agencies have developed guidelines for their own data collection programs, which are available on the Internet (see Appendix B)
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. Statistical agencies must be vigilant in their efforts to protect against the increased threats to disclosure from their summary data and microdata products while honoring their obligation to be proactive in seeking ways to provide data to users.
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Agencies that release preliminary estimates must educate the public about differences among preliminary, revised, and final estimates. Practice 6: Cooperation with Data Users Users of federal statistical data span a broad spectrum of interests and needs.
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If the data are to be used in court cases, administrative proceedings, or collective bargaining negotiations, it is wise to have a known policy ensuring that all sides may receive the special tabulations, regardless of which side requested them or paid the cost of the tabulation. Practice 7: Fair Treatment of Data Providers Clear policies and effective procedures for protecting data confidentiality, respecting the privacy of respondents, and, more broadly, protecting the rights of human research participants are critical to maintaining the quality and comprehensiveness of the data that federal statistical agencies provide to policy makers and the public.
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. To give additional weight and stature to policies that statistical agencies had pursued for decades, OMB issued a Federal Statistical Confidentiality Order on June 27, 1997.
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This dilemma is an important one to federal statistical agencies, and it has stimulated ongoing efforts to develop new statistical and administrative procedures to safeguard confidentiality while permitting more extensive access. An effective federal statistical agency will exercise judgment in determining which of these procedures are best suited to its requirements to serve data users while protecting confidentiality.
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The amount of effort or burden varies considerably from survey to survey, depending on such factors as the complexity of the information that is requested. Statistical agencies should attempt to minimize such effort, to the extent possible, by using concepts and definitions that fit respondents' common understanding; by simplifying questionnaires; by allowing alternative modes of response (e.g., via the Internet)
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Statistical agencies should respect this contribution by compiling the data and making them accessible to users in convenient forms. A statistical agency has an obligation to publish statistical information from the data it has collected unless it finds the results invalid.
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Data collections of federal statistical agencies are subject to IRB review within some departments. The Census Bureau, citing Title 13, has maintained an exemption from IRB review for its data collection programs under section 46.101(b.3)
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At a program or agency-wide level, mechanisms for outside review include standing advisory committees of technical experts and periodic assessments by 3See also data quality guidelines of statistical agencies in other countries, including Canada (Statistical Reference Centre, 2005) , and Great Britain (Office for National Statistics, 2005)
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(See Appendix B for a description of recent OMB guidelines for peer review of scientific information.) Practice 9: An Active Research Program Substantive Research and Analysis There are strong arguments for a statistical agency to have staff whose responsibility is to conduct objective substantive analyses of the data that the agency compiles, such as analyses that assess trends over time or compare population groups: · Agency analysts are in a position to understand the need for and purposes of the data and know how the statistics will be used.
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Several federal statistical agencies sponsor research using academic principles of cognitive psychology to improve the design of questionnaires, the clarity of data presentation, and the ease of use of electronic data collection and dissemination tools such as the Internet. The history of the statistical agencies has shown repeatedly that methodological and operations research can lead to large productivity gains in statistical activities at relatively low cost.
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. Practice 10: Professional Advancement of Staff An effective federal statistical agency has personnel policies that encourage the development and retention of a strong professional staff who are committed to the highest standards of quality work.
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Statistical agencies should also maintain and develop staff with the expertise necessary for effective management of contractor resources. 4Only the Bureau of Labor Statistics, the Census Bureau, and the National Agricultural Statistics Service maintain their own interviewing staff.
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Practice 11: Coordination and Cooperation with Other Statistical Agencies The U.S. federal statistical system consists of many agencies in different departments, each with its own mission.
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The 1995 reauthorization of the Paperwork Reduction Act created a statutory basis for the Interagency Council on Statistical Policy (ICSP) , formalizing an arrangement whereby statistical agency heads participate with OMB in activities to coordinate federal statistical activities.
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In other cases, federal statistical agencies engage in cooperative data collection with state counterparts to let one collection system satisfy the needs of both. A number of such joint systems have been developed, notably by the Bureau of Labor Statistics, the National Agricultural Statistics Service, the National Center for Education Statistics, and the National Center for Health Statistics.
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Such efforts should also extend to policies and professional practices so that agencies can respond effectively and with a coordinated voice to such governmentwide initiatives as data quality guidelines, privacy impact assessments, performance rating criteria, institutional review board requirements, and others. Finally, coordination efforts should encompass the development of data, especially for emerging policy issues (National Research Council, 1999a)
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No single agency, whether a statistical or program agency, could have produced the forum reports alone. Working together in this way, federal statistical agencies contribute to presenting data in a form that is more relevant to policy concerns and to a stronger statistical system overall.
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