Demand-Driven Open Data

More info:Contact

http://ddod.usDavid.Portnoy@HHS.gov | tw:@DPortnoy

DDOD for FOIA Organizations(Freedom of Information Act)

Originally presented in March 2015 to FOIA directors meeting for all agencies under HHS

Concepts explored here do not necessarily represent the views of HHS. 9/2015

Abstract

Industry and researchers can get valuable data through DDOD (Demand-Driven Open Data) and FOIA (Freedom of Information Act). Both paths have their advantages and limitations. A subset of FOIA requests can also be worked as DDOD "use cases". Such requests involve structured, machine-readable datasets that continue to be generated and are not for restricted data. This paper explains how combining the two methods by working this subset of requests in parallel significantly improves the effectiveness both DDOD and FOIA.

This paper was originally presented at the FOIA directors meeting for all HHS (U.S. Dept of Health and Human Services) agencies in March 2015.

Demand-Driven Open Data (DDOD) is a framework of tools and methods that…

Provide external data users✽ with a systematic, ongoing and transparent way to tell HHS what data they need

...To be managed, measured and executed in terms of use cases, enabling allocation of limited resources based on value

What is DDOD?

✽ Including industry, researchers, nonprofits, media and other government organizations

More effective open data initiativesMore engaged user communityMore economic value & discoveries delivered

Add

What does DDOD deliver to the user community?Implementation of a use case could fall into one of 3 categories

Time to execute

Cos

t / E

ffort Improve

Catalog

Facilitate deployment of ● New datasets● New APIs

For existing datasets● Add needed fields● Improve data quality● Add / improve metadata● Add / improve API

If datasets already exist in legacy systems, make them more available and discoverable

● Publicize availability● Index to HealthData.gov and Data.gov● Instructions for efficient FOIA handling

Current State

Processes for administration of use cases, such as • Encouraging responsiveness, transparency and documentation • Ensuring use cases and resulting datasets are indexed in HealthData.gov

Specialized tools for administering use cases • Workflow engine, communications method, knowledge base • Data processing, storage, hosting, versioning

Proactive outreach to industry and academia for a thriving community

What does DDOD provide to data owners?

1

2

3

“The Freedom of Information Act (FOIA) is a law that gives you the right to access information from the federal government. It is often described as the law that keeps citizens in the know about their government.”

What is FOIA?

Source: FOIA.gov

U.S. Department of Health & Human Services

What does FOIA look like within HHS?

Source: FOIA.gov

Agency Received Processed Pending

ACF 1,864 1,255 763

CMS 26,361 25,027 4,717

OIG 843 815 34

CDC 1,141 1,028 691

FDA 10,224 10,191 2,896

HRSA 355 352 92

IHS 152 160 20

NIH 1,169 1,156 84

SAMHSA 193 238 51

OS 1,531 1,605 314

OASH 437 455 120

ACL 13 11 2

Total 44,283 42,293 9,784

Some FOIA requests look quite similar to DDOD use cases

FOIA requests that have all of the following attributes could be potential DDOD use cases

1. The data is still being generated or refreshed on a regular basis. (Not a single pull of historical information.)

2. The data can be delivered in a machine readable, structured format, such as CSV, JSON, XML or Excel files. (Not freeform text-only, PDF, or scanned images.)

3. The data has widespread usefulness for multiple organizations. (Excluding complaints and investigations, which are often specific to an individual or organization, as is often the case in lawsuits.)

Although only a fraction of the 45,000 FOIA requests received so far by HHS have attributes that make them applicable to DDOD, there are still plenty that could become high value use cases.

But both FOIA and DDOD have their own challenges DDOD’s challenges:

● DDOD is a relatively new program that doesn’t enjoy the awareness, recognition and credibility that FOIA has developed over the years

● Proactive outreach to the user community is a big effort and expense for DDOD

● The toolset for managing use cases is early in its lifecycle and is still being developed

● While the DDOD workflow is documented and actively in use, it’s still being fine-tuned

FOIA’s challenges:

● Growing backlog, due to high demand, complexity of some requests and limited resources

● Process for spotting similar requests and posting the response to an electronic “reading room” is subjective and time consuming

● Difficult to maintain consistency in both format and actual data delivered. Requests may be subject to interpretation. Each request may be fulfilled by a different employee or contractor

● There’s no mechanism for automatically refreshing results for data that continues to be generated

Joining forces on applicable requests is mutually beneficial, because it can help address many of these challenges.

DDOD can benefit FOIA by...1. Reducing number of future requests

More data indexed and made publically available via HealthData.gov (See diagram)

Data that’s automatically being refreshed doesn’t need to be requested multiple times

Rework stemming from inconsistent format and data values between consecutive extracts on refreshed data

Better documentation of data provenance and usage via use case methodology

Data User runs search on HealthData.gov

Data User creates / updates use case

DDOD Admin engages Data Owner on use case

• keywords, subject • data dictionary

HealthData.gov

Data Dictionary

DatasetInventory

EDI*

Use Case

DDOD Admin ensures changes to EDI get propagated to HD.gov

* Enterprise Data Inventory (EDI), which is a catalog of HHS “Strategically Relevant Data Assets”

Data Dictionary

DatasetInventory

DDOD Admin enters use case on HD.gov with links to specifications

Data Owner adds entry to EDI, including metadata

DDOD Admin curates entry & ensures SLAs

DDOD Admin creates repository for use case

Process of adding a new DDOD use case

DDOD can benefit FOIA by… (cont)

2. Fulfilling the electronic “reading room” requirement for requests made multiple times by publishing the data using HealthData.gov infrastructure. Results end up benefiting more users.

3. Instituting best practices for open data projects in terms of machine readability, standards, documentation and access

4. Helping address the backlog, specifically for the subset of requests applicable to DDOD. These are also the requests that are beneficial to a wider audience.

Much of the current backlog is unrelated to machine readable datasets that serve the broader user community. FOIA is straining under the weight of one-time requests that benefit only the few. For example, a single lawsuit-related request to CDC required processing of 90,000 documents.

FOIA can benefit DDOD by...

1. Since FOIA is legislated and well-known, it can bring in more use cases into DDOD.

By identifying specific requests that are applicable to DDOD

By promoting DDOD on FOIA websites and materials

2. DDOD can leverage work being done anyway to fulfill FOIA requests

Data owner already needs to be involved and resources -- whether employees or contractors -- need to be allocated to do the extract

Once a data extract is performed, it might be trivial to configure periodic runs of the same code and perform automated pushes to HealthData.gov

3. Association with FOIA lends additional awareness, recognition, credibility to DDOD

Requester receives

documents

Requester can sue

Data owner produces

documents

Submit for fulfillment to data owner

Requester can appeal

We start with a simplified overview of the FOIA workflow to determine how DDOD requests could be initiated and executed in parallel

Agree to fulfill

Requests that are partially or incorrectly fulfilled can also go through the same appeals process

Agency decides whether and what

to release

Agency obtains clarification (if needed)

Request routed to ultimate

agency

Respond within 20 business days

(Can extend for unusual circumstances: Research, volume, consultation)

Route within 10 business days

Decline request Agree to

fulfill

Decline request

Requester submits request

to FOIA

In DDOD workflow, use case execution relies on three types of participants: Data User, DDOD Admin, and Data Owner. The Data User initiates the request

All implementation decisions ultimately are made by the Data Owner

The DDOD Admin only facilitates the process when needed

Although it’s a legislation-driven process, FOIA organizations may voluntarily notify DDOD on incoming requests. For such requests, the DDOD workflow works in parallel to the FOIA workflow.

Dat

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DO

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Adm

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Document ImplementEngage Discuss

Document Engage Clarify

Document Implement Discuss Clarify

FOIA

Org Workflow for FOIA - DDOD partnership

Typical FOIA request