Independence and the Federal Statistical System Robert M. Groves Georgetown University

Outline What does “independence” mean? Personal comments on how we’re doing Concerns not well covered under “independence” Summary

Independence in Principles and Practices Principle 4: A federal statistical agency must have a strong position of independence within the government. National Research Council. (2009). Principles and Practices for a Federal Statistical Agency, Fourth Edition. Committee on National Statistics. Constance F. Citro, Margaret E. Martin, and Miron L. Straf, Editors. Division of Behavioral and Social Sciences and Education. Washington, DC: The National Academies Press.

“... a statistical agency must be a trustworthy source of objective, accurate information for decision makers, analysts, and others inside and outside the government who want to use statistics to understand present conditions, draw comparisons with the past, and help guide plans for the future.” National Research Council. (2009). Principles and Practices for a Federal Statistical Agency, Fourth Edition. Committee on National Statistics. Constance F. Citro, Margaret E. Martin, and Miron L. Straf, Editors. Division of Behavioral and Social Sciences and Education. Washington, DC: The National Academies Press.

However, “Statistical agency independence must be exercised in a broad framework. Legislative authority usually gives ultimate responsibility to the secretary of the department rather than the statistical agency head. In addition, an agency is subject to the normal budgetary processes and to various coordinating and review functions of OMB, as well as the legislative mandates, oversight, and informal guidance of Congress.” National Research Council. (2009). Principles and Practices for a Federal Statistical Agency, Fourth Edition. Committee on National Statistics. Constance F. Citro, Margaret E. Martin, and Miron L. Straf, Editors. Division of Behavioral and Social Sciences and Education. Washington, DC: The National Academies Press.

Ingredients Promoting Independence Fixed term appointment by President, with approval of Senate, not linked to presidential term Direct access to secretary or head of independent agency Separate funding appropriation Authority over scope, content, and frequency of statistical products Authority for selection of professional, technical, operation staff Authority to release statistical products without prior clearance Authority to control IT systems Authority to speak directly to Congress about agency’s statistics Adherence to fixed schedules of release Clear distinction between statistical information and policy interpretations Direct dissemination of major statistical products National Research Council. (2009). Principles and Practices for a Federal Statistical Agency, Fourth Edition. Committee on National Statistics. Constance F. Citro, Margaret E. Martin, and Miron L. Straf, Editors. Division of Behavioral and Social Sciences and Education. Washington, DC: The National Academies Press.

Fundamental Principles of Official Statistics Principle 1....official statistics...are to be compiled and made available on an impartial basis Principle statistical agencies need to decide according to strictly professional considerations... the methods and procedures for the collection, processing, storage and presentation of statistical data.

American Association for Public Opinion Research We shall attempt, as practicable, to correct factual misrepresentations or distortions of our data or analysis including those made by our research partners, co-investigators, sponsors, or clients. …We shall issue corrective statements to all parties who were presented with the factual misrepresentations or distortions...

How Are We Doing? Fixed term appointment by President, with approval of Senate, not linked to presidential term –Several agencies lose status on “Senate approval” –One agency gains fixed term

How Are We Doing? Direct access to secretary or head of independent agency –Hierarchical layering of statistical agencies –Embedding statistical agencies inside program agencies

How Are We Doing? Separate funding appropriation –All agencies linked to higher-level budget unit

How Are We Doing? Authority over scope, content, and frequency of statistical products –Line-item budgeting of programs reduces use of funds for needed purposes

How Are We Doing? Authority for selection of professional, technical, operation staff –Use of Senior Executive Service for leadership positions

How Are We Doing? Authority to release statistical products without prior clearance –OMB directives 3 and 4 –Explicit time schedules of statistical releases

How Are We Doing? Authority to control IT systems –Centralization of cabinet departments IT network support –Naïve use of the cloud –Cybersecurity legislation

How Are We Doing? Authority to speak directly to Congress about agency’s statistics –Few congressional presentations to defend budget –Few substantive hearings –Diverse committees’ oversight

How Are We Doing? Adherence to fixed schedule of releases –Directive 4 incompletely implemented by agencies

How Are We Doing? Clear distinction between statistical information and policy interpretations –OMB directive 4 draws explicit boundaries –Inherent fuzziness of differences between analysis and policy interpretations –Increased acceptance that quality of data depends on agency analysis of the data

How Are We Doing? Direct dissemination of major statistical products –Degree of outreach on statistical “stories” open to manipulation for political purposes –Web dissemination has greatly assisted directness

Concerns Not Covered Disagreements with higher executive branch authorities on importance of new statistical products –What does independent judgment on scope of statistics mean without funding? Budget cuts that decimate basic functions –What actions should directors take when core functions are threatened?

Concerns Not Covered Disagreements on temporal, geographical, subpopulation levels of reporting –What should agencies do when budget cuts create unhelpful periodicity of statistics? Transfer of responsibility to private sector providers –What should agencies do to convey quality impacts of such transfers?

Summary Principles and Practices and other codes are hortatory, not regulatory Much depends on the leadership of directors Even more depends on the culture of the agencies to be vigilant regarding independence The strongest enforcement of such principles comes through the fear of “outing” political interference by career staff