AAMC Comments on HHS Information
Quality Guidelines
May 31, 2002
Director, Division of Data Policy
Office of the Assistant Secretary for Planning and Evaluation
U.S. Department of Health and Human Services
Room 440D, Hubert H. Humphrey Building
200 Independence Avenue S.W.
Washington, D.C. 20201
Attn: Information Quality Comments
Dear Sir/Madame:
The Association of American Medical Colleges (AAMC) has
reviewed the Department's proposed Draft Guidelines Ensuring
and Maximizing the Quality, Objectivity, Utility and Integrity
of Information Disseminated by HHS Agencies, released May
1, 2002 (67 FR 21685). The AAMC believes that the proposed
guidelines fully comply with the Office of Management and
Budget's final guidelines on information quality released
January 3rd and provide for the dissemination of timely, important,
and reliable medical and public health information.
The AAMC represents the nation's 125 allopathic medical
schools, nearly 400 teaching hospitals, more than 105,000
faculty in 98 academic and scientific societies, and the nation's
66,000 medical students and 97,000 residents. On behalf of
this constituency, the AAMC commented at length to OMB on
the development of federal information quality guidelines,
with particular respect to reporting on matters of public
health and to preserving the primacy of peer review in scientific
communications. We believe that the OMB conscientiously reviewed
and incorporated the health research community's concerns
within its standards for information quality, while addressing
the sweeping requirements of Section 515 (P.L. 106-554). Here,
we make two additional comments with respect to the HHS's
proposed guidelines.
First, the AAMC agrees with the mechanism proposed for processing
requests for corrections from affected persons (a major requirement
of the original statute). However, no one can tell at this
time the volume of requests that will be received, the nature
of the requests, or the level of effort that will be required.
The number of requests for "corrections" will be driven not
only by disseminated information that is actually or potentially
erroneous, but by individuals' perceptions of that information
compared to their own, often strongly held, beliefs about
health and disease. Differences in perception will often be
seen as differences in fact by some parties. The agency should
retain flexibility in reconsidering its implementation plan
after it has accumulated some experience with actual requests
and the level of effort needed to address them.
Secondly, in the case of the NIH, the proposed guidelines
appropriately assign to the Associate Director for Communications
in the Office of the NIH Director the responsibility to adjudicate
appeals from individuals who contest an institute's decision
on their request for correction. The guidelines should specify
that the Associate Director for Communications, when acting
in this capacity, reports directly to the NIH Director. The
AAMC believes that the Director of the NIH should have final
authority over all scientific or health information disseminated
by that agency.
Sincerely,
Jordan J. Cohen
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