It may seem that the simplest way to gather accurate information about deaths in police custody is for the police departments themselves to collect the data.

But that’s not the how the U.S. Department of Justice (DOJ) proposes to implement the Deaths in Custody Reporting Act (DICRA), signed into law in 2014, and that’s a real problem, according to scores of organizations.

In a letter sent Monday to the DOJ, 96 groups including the ACLU, Amnesty International USA, Government Accountability Project, and the Leadership Conference on Civil and Human Rights outline what they see as major flaws in the proposal.

Among them: it wrongly shifts the reporting requirement from state to federal authorities. That authority, the Bureau of Justice Statistics, will rely on an “inadequate method”—the Arrest-Related Deaths Program, which uses publicly available information. That means that investigative projects undertaken by the Guardian and the Washington Post are the “best national sources” for the data, but that puts the key data on lives lost at the risk of potentially dwindling national interest and media resources.

Further problematic, the groups write, is that the proposal fails to fully clarify what is meant by “custody,” and the fact that data is also needed in confrontations with the police in community encounters such as traffic stops.

The proposal also fails to mention “penalties for noncompliance,” but that is “critical for successful implementation of DICRA as voluntary reporting programs on police-community encounters have failed,” the letter states. Citing reporting by the Guardian and Washington Post, it continues: “Reportedly, only 224 of the more than 18,000 law enforcement agencies reported approximately 444 fatal police shootings to the Federal Bureau of Investigation (FBI) in 2014, though we have reason to believe that annual numbers of peopled killed by police exceed 1,000.”