The Grammar and Use of Initialisms by the U.S. Federal Government

This research on the use of initialisms by the United States federal government was produced during our publication of a paper in the Springer journal, Science and Engineering Ethics. The editor of that journal thought it would be worth publishing this information separately, for the benefit of others. We agreed; the following summarizes what we learned:
1. The definite article, “the”, should generally precede initialisms – but that is often not the case for the initialisms of U.S. government agency names
As previously noted by John McIntyre, an editor at the Baltimore Sun newspaper:
“An initialism uses the first letters of the words being abbreviated and is pronounced letter by letter rather than as a word*: FBI, mph. An acronym combines first letters or compounds of the constituent words into an abbreviation that is pronounced as a word: NASA, scuba. If it’s not pronounced as a word, it’s not an acronym.” (http://www.baltimoresun.com/bs-mtblog-2008-12-abbreviations_initialisms_and_acronyms-story.html)
*[In this basic meaning, a “word” is a spoken sound or its written representation.]
Then, getting to the point at hand, McIntyre continues:
“The definite article is used before abbreviations of agencies — the FBI, the CIA — and nations — the U.S., the U.K. — but not before the abbreviations of universities’ names. Devoutly as some might wish, Ohio State University is not called the OSU. Some bureaucrats indulge in omitting the article before the names of their agencies, because they are very important people, pressed for time on the nation’s business and too urgently focused on the public weal to trifle with the definite article. For them, it’s OMB says and EPA reports. But if you were interested in mimicking pomposity, you wouldn’t be reading this.” [With bold emphasis added.]
However, as we noted in our article, both the federal Office of Research Integrity, ORI, and the laws referring to it, often do not use “the” preceding ORI.
For example, although its formal webpage header and caption do state “The ORI”, much of the rest of the ORI’s website does not continue the use of the definite article before the agency name:
About ORI
The Office of Research Integrity (ORI) oversees and directs Public Health Service (PHS) research integrity activities on behalf of the Secretary of Health and Human Services with the exception of the regulatory research integrity activities of the Food and Drug Administration.
Organizationally, ORI is located within the Office of the Assistant Secretary for Health (OASH) within Office of the Secretary of Health and Human Services (OS) in the Department of Health and Human Services (HHS).”
Also, we reproduce here one of our many quotes of HHS regulations which also does not employ the definite article before ORI:
“(c) Any authorized HHS component may impose, administer, or enforce HHS administrative actions separately or in coordination with other HHS components, including, but not limited to ORI, the Office of Inspector General, the PHS funding component, and the debarring official.” (42 CFR § 93.407(c). 
2. HHS style
The U.S. Department of Health and Human Services, HHS, is the home for many agencies involved with biomedical research and commerce, including the ORI, the National Institutes of Health (NIH), and the Food and Drug Administration (FDA). HHS has its own style guide (http://www.hhs.gov/web/policies-and-standards/web-style-guide/), as do other government agencies. HHS’s style guide seems to cite “prominence” of an agency, (perhaps a variant of “pomposity”), as a basis for the use of the definite article before initialisms is dropped. Specifically:
“the [HHS] Department’s style, which is based on the AP Stylebook. Please consult this resource if you have questions. …
HHS Exceptions from AP style
Agency Names and Use of the Word “The” –Use “the” before the agency name (the Office of the Inspector General) if the agency commonly is known by that usage.
As for the abbreviations, it would be up to the agency to decide if the public would refer to the agency commonly by its initials and know what that means, and the name is being used as a noun (the FDA announced.) AP copy commonly uses “the” before FDA. That’s not the case for agencies less well-known, such as AHRQ.” [AHRQ is the Agency for Healthcare Research and Quality.]
http://www.hhs.gov/web/policies-and-standards/web-style-guide/index.html
AHRQ does exactly that on its website:
“With the support of contracting staff, AHRQ maintains several additional subsites to fulfill our mission. A list of these sites and a link to the description of their focus is provided here.”
However, even the FDA, which a U.S. layperson might consider a more well-known agency, uses their initialism without a preceding definite article:
“The scope of FDA’s regulatory authority is very broad. FDA’s responsibilities are closely related to those of several other government agencies. Often frustrating and confusing for consumers is determining the appropriate regulatory agency to contact. The following is a list of traditionally-recognized product categories that fall under FDA’s regulatory jurisdiction; however, this is not an exhaustive list.”
In keeping with the HHS style guide(s), a former director of the ORI whom we quote, does not consistently use the definite article:
“[Former ORI Director] Wright asked in his letter “whether OASH is the proper home for a regulatory office such as ORI, noting that [Assistant Secretary of Health/ASH] Koh himself has described his office as an intensely political environment.’ (The contents of the letter were published in Kaiser 2014).
Even the Director of the NIH, in speaking to Congress, appears to use a mix of references to NIH with and without the definite article:
“It is an honor to appear before you today to present the Administration’s fiscal year (FY) 2017 budget request for the NIH” … “As the nation’s premier biomedical research agency, NIH’s mission is to seek fundamental knowledge about the nature and behavior of living systems” … “NIH will pursue these and many other forward-looking measures”. (https://www.nih.gov/about-nih/who-we-are/nih-director/testimony-fiscal-year-2017-budget-request-before-senate-committee)
NIH certainly would be considered a “prominent” agency, even outside the U.S. Consequently, we believe that the HHS Style Guide as stated in its Consumer Materials, has now become the predominant rule throughout HHS.
The HHS style guide rule quoted above can also be read as allowing each agency to decide its own usage. In order to learn more about what HHS policy on this point is, we contacted the HHS Media Information Office. They responded in writing as follows:
“[E]ach agency does determine its own usage. In the case of ORI, we’d encourage refraining from using “the”.”
So we are now fairly confident that HHS, its agency directors, its regulations, and its websites and publications, are all acting knowingly in not wishing to promote general use of the definite article before agency initialisms.
3. Our recommendation about the initialisms
Therefore, the question which arose with our editor was whether we should follow the HHS style guide (as we did in our initial submission), or should we attempt, by example, to “correct” the arguably “erroneous” grammatical usage being promoted by HHS and other U.S. agencies.
We believed that it might be less jarring to the readers to use HHS style throughout. This is because a significant part of the readership of our article, or any article discussing U.S. federal agencies and laws, would be expected to be those who are already used to this style, or who are members of the U.S. government, who are not only used to it, but even expecting it.
Therefore, we recommend keeping the HHS style for its initialisms.
For what it is worth, even the Chicago Manual of Style Online, which we consider in some ways superior to the AP Style Guide which HHS modifies, does not mandate use of the definite article before initialisms:
“10.9“A,” “an,” or “the” preceding an abbreviation
When an abbreviation follows an indefinite article, the choice of a or an is determined by the way the abbreviation would be read aloud. Acronyms are read as words and are rarely preceded by a, an, or the (“member nations of NATO”), except when used adjectivally (“a NATO initiative”). Initialisms are read as a series of letters and are often preceded by an article (“member nations of the EU”). See 10.2; see also 7.44.”
4. Use of contiguous initialisms in the article
When we considered the treatment of compound initialisms like HHS OIG and NSF OIG, a question arose as to whether to indicate the possessive, or treat the contiguous intialisms as a single name: HHS OIG versus HHS’ OIG, and NSF OIG rather than NSF’s OIG. Generally, avoiding the apostrophe indicating possession appears to be the practice for both agencies. (OIG is the initialism for Office of the Inspector General.)
From the NSF OIG website:
“Recent news articles have raised some concern about the security of the online complaint process used to report fraud, waste, and abuse to more than two dozen OIG hotlines, including NSF OIG. NSF OIG has swiftly addressed the issue …”
From the HHS OIG website:
“HHS OIG is the largest inspector general’s office in the Federal Government, with approximately 1,600 dedicated to combating fraud, waste and abuse and to improving the efficiency of HHS programs.”
Note that even the NIH at times does away with the possessive:
NIH leadership plays an active role in shaping the agency’s research planning, activities, and outlook.” (https://www.nih.gov/about-nih/who-we-are/organization).
Therefore, as noted above for the use of the definite article before single agency initialisms like ORI, we recommend generally following the agency’s use, except, for example, in cases in which distinction from other OIGs is desired.

 

 

Robert Bauchwitz

Robert Bauchwitz is a biomedical research scientist and certified fraud examiner. His research expertise is in behavioral neuroscience and molecular genetics. He was the relator (plaintiff acting on behalf of the government) in a U.S. federal False Claims Act qui tam case involving scientific research fraud. He has obtained additional fraud investigation training from the John Jay College of Criminal Justice and operational audit training from the Institute of Internal Auditors. He also has certifications in litigation support from the Widener University Law School's Legal Education Institute and in network security from CompTIA.

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One Comment

  1. Why do they choose to drop the article? I don’t understand why they are adamant about essentially personifying the given entity through what is essentially incorrect use of articles.

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