All AoA documents must be prepared in accordance with professional and ethical standards, as well as generally accepted standards of good taste. They must be appropriate for dissemination by this agency, and must undergo appropriate review and approval prior to release. At AoA, the quality assurance process begins at the inception of the information development process. AoA efforts to ensure and maximize information quality begin at the preparation stage, and continue through the review and approval stages. Existing AoA policies developed in concert with Federal computer security laws provide appropriate security safeguards to ensure integrity of AoA documents, i.e., ensure that the information is protected from unauthorized access, revision, corruption, or falsification.
AoA has quality control measures embedded in its grant application review process to ensure that the information ultimately disseminated is of high quality. AoA grant applications undergo extensive professional review.
B. AoA Information Review and Approval Policies and Procedures
Publications are expected to meet high standards of quality, make a substantial contribution to the field, and contain sufficient information for the informed audience to assess its validity. The review, approval, and dissemination of substantive information by AoA require adherence to appropriate clearance procedures for this type of material and are consistent with HHS guidelines. The originating office is responsible for obtaining the necessary clearances for reproduction and distribution of printed materials and should ensure that written material distributed is appropriate and consistent with HHS policy. A document that has obtained publication clearance for paper printing is often posted on the AoA web site for greater accessibility. AoA Web documents with no print counterpart require content clearance by the appropriate AoA office or contact person to ensure that the information observes all applicable requirements governing information for release to the public.
As noted above, AoA issues four types of information:
- Programmatic Analyses and Evaluations
- Reports, Monographs, and Technical Assistance Materials
- Consumer Information
- Oral Information
AoA reviews the quality (including the objectivity, utility, and integrity) of information before it is disseminated and treats information quality as integral to every step of the development of information, including its creation, collection, maintenance and dissemination. The information review and approval process is essentially the same for each of these types of information. Such information must meet the following guidelines which AoA employs to assure the quality of its information products, including their utility, objectivity, and validity:
Utility involves the usefulness of the information to its intended users. Utility is achieved by staying informed of information needs and developing and information products which are appropriate to these needs. This is achieved by: internal analyses of information requirements, continuous informal discussions and consultation with members of the aging services network, project grantees and other experts in the field, consultation with consumer groups, convening and attending conferences, working with professional groups, and sponsoring outreach activities. Where appropriate, contact information is available on each publication to allow feedback and questions by users.
Objectivity involves a focus on ensuring that information is accurate, reliable and unbiased and that information products are presented in an accurate, clear, complete and unbiased manner. Objectivity is achieved by using reliable data sources and sound analytical techniques, and preparing information products that use proven methods by qualified people that are carefully reviewed.
Integrity -- Information contained in analytical reports and technical assistance materials is based on valid and reliable data sources which are identified. All reports and materials are reviewed by technically qualified staff to ensure that analysis is valid, complete, unbiased, objective and relevant. Materials that are considered to be more technically complex are also reviewed by subject matter experts and other AoA program experts outside of the originating component to provide additional perspective and expertise.
C. Administrative Requirements
AoA printed publications must be cleared through the Assistant Secretary for Aging and the Office of the Assistant Secretary for Public Affairs (OASPA), HHS. Similarly, all AoA Audio/Visual projects and exhibits must be cleared through OASPA. Further, AoA will demonstrate in its PRA clearance packages that each draft information collection will result in information that will be collected, maintained, and used in a way that is consistent with OMB, HHS and AoA information quality guidelines.
In general, any writing by an AoA employee on a work-related subject, whether intended for electronic or print publication, or for oral delivery, must be prepared according to accepted AoA standards of quality, reviewed for substantive content, and administratively approved. The purpose of the AoA clearance process is to improve the quality of information, and to ensure the accuracy, objectivity, utility, and validity of information. Directors of AoA component units (or their delegates) are responsible for establishing and maintaining controls to ensure competent and timely clearance of professional writing and presentations by developing procedures appropriate to the type of information.
Oral information, including speeches, interviews, expert opinions, only if representing AoA views, official positions, or policies, including any statements, comments, or discussion of Federal policies or practices that are relevant to the employee's position or duties, draw conclusions, advocate or oppose professional practices or positions on subjects related to AoA duties, or might otherwise be construed as reflecting an official position by AoA, HHS, or the Federal Government, are covered by the OMB Guidelines, and must be approved in the Office of the Assistant Secretary for Aging or the Director of CCCS, AoA.
No review or approval is required for nonofficial and private writing, speaking, and publishing by an employee unless his/her AoA employment is likely to be regarded as influencing the content.
D. Special Considerations for Agency Dissemination
Disclaimers -- Normally, the need for a disclaimer is eliminated through the clearance process. However, a disclaimer may still be needed even after official clearance to clarify that the presentation should not be construed as necessarily representing AoA views, and/or to distinguish the status of information (e.g., preliminary, based on partial data set). The Department's regulations (Standards of Conduct) to which the AoA subscribes, require that disclaimers be used in all unofficial writing and editing related to the employee's official duties and/or affiliation with programs of the Federal Government in which the employee's identification with AoA is to be shown, can be inferred, or is well-known.
E. AoA Center for Communications and Consumer Services (CCCS)
The Center for Communications and Consumer Services (CCCS), a unit of AoA, is a central source for a wide variety of consumer as well as program- and policy-related materials and demographic and other statistical data on the health, economic, and social status of older Americans. CCCS services include the following: inquiry response, repository of AoA-funded research products, a bibliographic database of AoA-funded r&d products and other aging-related products, a reading room and reference collection, and statistical information.
At AoA, there are essentially three types of materials being disseminated through information services to the public: (1) Materials produced by AoA staff or contractors that undergo usual AoA review and approval processes; (2) materials produced by AoA grantees that are subject to policies and procedures in the AoA Grants Administration Manual; and (3) other materials not produced by AoA but available from a variety of professional sources (e.g., brochures handbooks, statistical tables, articles) whether in print or in electronic format, with appropriate disclaimers attached. Non-Federal materials typically undergo careful professional review before they are disseminated by AoA information staff. Such materials are accompanied by appropriate disclaimers.
F. Web Site Information
AoA has designated content area experts to develop or recommend material for inclusion on the AoA web site. These content area specialists periodically review material on the Web page to determine whether it is accurate and up to date. Information, particularly time-sensitive information, should be posted as soon as possible. Web page creators are expected to promptly update or remove out-of-date information.
Unless noted otherwise, information posted on pages within the "AoA.Gov" domain is considered to be "in the public domain." As such, others are free to establish links to AoA online resources. In establishing such links, AoA requests that others avoid creating the impression that AoA is endorsing or promoting any particular product or service. In the same vein, any outside link to an external resource from an AoA Web site is examined on a case-by-case basis. In general, the content manager for each page determines when links to outside entities are justified.
AoA web pages containing links to external web pages not located on AoA servers should include a link to a statement that releases AoA from responsibility for the material included in the external Web page. Again, it is important to avoid giving a user the impression that AoA is endorsing information or a service or product described in an external site.