Accountability deficit and globalization are two traditional explanatory devices which are used to examine the reasons behind the adoption of freedom of information law. However, these two devices are incapable of assisting in implementation of freedom of information law. Information flow analysis is such a device which has the capacity to help implementation. Although the Obama Administration has not mentioned information flow analysis, it has adopted a series of policies to implement freedom of information law, indicating that it lays stress on information flow. This is because the Obama Administration has begun to take an administrative approach to improve the performance of freedom of information from a perspective of information flow. This perspective focuses on a positive role of proactive disclosure, public participation and collaboration within government agencies in improving freedom of information performance.