Can Protected Data Be Shared to Improve Services?
“Start with what you have,” is the advice consultants recommend to organizations that are just launching performance measurement initiatives. Now the Office of Management and Budget has issued guidance encouraging agencies to use existing program data in new ways.
The Obama administration has championed open data by encouraging agencies to make a wider range of statistical information available to the public. The philosophy is “information is a valuable national resource and strategic asset.” To that end, OMB has issued directives and created Data.gov, a centralized website for public data.
But what about administrative data that cannot be publicly shared because of privacy or security reasons? Agencies collect and use administrative data for the basic operations of government programs. For good reason, government records of individuals’ tax, Social Security earnings, health insurance and other benefit information cannot and should not be shared publicly. In fact, there are strict laws in place to safeguard these kinds of data.
Sharing Non-Public Data
Can protected data at least be shared between federal agencies -- if stripped of individual identifiers -- so they can be used to improve services? So far, this has been difficult. Each agency has been left to interpret whether it can share its data, and under what circumstances.
Laws allow certain kinds of sharing, but in many cases, constraints -- real or perceived -- have meant that one agency has to survey individuals or businesses for information that has already been collected by another agency. This has resulted in costly and duplicative efforts for government, businesses and citizens.
During the past five years, OMB has advocated sharing statistical information among agencies for evidence-based analyses that support better program decisions -- without new and costly data collection efforts. The Housing and Urban Development, for example, has worked with the Veterans Affairs Department to share data about homeless veterans to better target services. This joint effort has reduced veteran homelessness by 25 percent since 2010.
OMB’s New Guidance
Last week, OMB quietly released a significant piece of guidance that provides agencies the following practical advice on how to share non-public administrative data in responsible ways that protect confidentiality:
- Foster collaboration across program and statistical agencies. An earlier OMB memo required agencies to develop an inventory of data sets they collect and maintain. Agency leaders should “communicate the importance of identifying those administrative data sets with great potential for statistical use” and highlight their existence to relevant statistical agencies.
- Adhere to data stewardship practices that safeguard data. OMB outlines a set of principles that allow agencies “to maintain public trust in their ability to appropriately handle identifiable information.” Examples include certifying procedural safeguards and eliminating identifiable information when the data are no longer needed.
- Documenting quality control measures for statistical agencies. The directive says “program agencies should provide the technical documentation or other assistance that statistical agencies or components require to adequately assess the quality of a particular data set.” Sometimes, OMB notes, program agencies might be able to make their data more useful by making changes to how they collect or report it.
- Foster clearly written interagency agreements for data sharing. Agencies should employ interagency agreements to the document terms and conditions for when and how non-public data should be shared. OMB’s guidance includes a helpful checklist of what should be included in such an agreement, but also encourages agencies to “seek the advice of their counsel before signing.”
No OMB memo would be complete without a requirement for agencies to report on their progress. Agencies must report to OMB no later than June 30 on what processes they have put in place to implement the guidance. The directive provides a helpful outline of what that report should contain:
- A copy of whatever communication the department head sent out to staff to tell them this is important stuff.
- List at least three data sets identified as having the “highest potential statistical value” -- including data sets at other agencies -- and the status of any requests to use the data.
- Identify any barriers to sharing data with other agencies for statistical purposes.
So, if another agency has data that would be useful to your meeting your mission, you now have the permission slip to ask for it -- for statistical purposes, that is.