Executive Order 13985 charged the Office of Management and Budget (OMB), in partnership with the heads of agencies, to identify, by July 2021, effective methods for assessing whether agency policies and actions (e.g., programs, services, processes, and operations) equitably serve all eligible individuals and communities, particularly those that are currently and historically underserved. As a part of this effort, OMB issued a Request for Information (RFI) to seek input, information, and recommendations from a broad array of stakeholders in the public, private, advocacy, not-for-profit, and philanthropic sectors, including State, local, Tribal, and territorial areas, on available methods, approaches, and tools that could assist in this effort.
OMB sought input in the following five areas:
- Equity Assessments and Strategies. Approaches and methods for holistic and program- or policy-specific assessments of equity for public sector entities, including but not limited to the development of public policy strategies that advance equity and the use of data to inform equitable public policy strategies.
- Barrier and Burden Reduction. Approaches and methods for assessing and remedying barriers, burden, and inequities in public service delivery and access.
- Procurement and Contracting. Approaches and methods for assessing equity in agency procurement and contracting processes.
- Financial Assistance. Approaches and methods for assessing equity in the administration of agency grant programs and other forms of financial assistance.
- Stakeholder and Community Engagement. Approaches and methods for accessible and meaningful agency engagement with underserved communities.
Pursuant to Executive Order 13985 and other Executive Orders that aim to further equity and inclusion across the Federal Government, RFIs were also issued by the Federal Emergency Management Agency (FEMA) , U.S. Department of Agriculture (USDA) , National Aeronautics and Space Administration (NASA) , U.S. Department of Transportation (DOT) , and U.S. Citizenship and Immigration Services (USCIS) . OMB has connected with these agencies to enhance our understanding of how we might coordinate our efforts and continue to share what we learn with each other.
Who responded to the RFI?
OMB received 499 unique responses to the RFI from across sectors, via regulations.gov.
Reflecting the nature of equity work, respondents spanned a wide range of policy areas (e.g., health equity, racial equity, housing, environmental justice, gender-based violence); services (e.g., advocacy, legal aid, health insurance, research); and community organizations (representing communities of color, LGBTQI+ communities, immigrants, rural communities, children and families, people with disabilities, and more).
Industry includes for-profit organizations and businesses. Non-profit includes local, state, national, and international non-profits. Joint Comment includes submissions representing collaboration across multiple organizations or multiple individuals in an unaffiliated capacity. Federal/State/Local/Tribal includes federal, state, local, and Tribal government entities. Labor & Membership Associations includes labor unions and professional membership associations (e.g., American Psychological Association).
What did the comments address?
The information included on this page is our summary of what was submitted to OMB via regulations.gov. If you're interested in learning more, you can view all responses and supporting documents shared with OMB on regulations.gov.
Nearly half of all comments discussed data collection, disaggregation, and reporting, and over one-third of comments touched on various dimensions of healthcare and health equity.
Recommendations were both specific and cross-cutting, in terms of policy and program areas (e.g., housing, Medicare, education) and relevance to various Federal agencies.
OMB’s RFI allowed commenters to address multiple RFI areas within their individually submitted comments, hence the total number here exceeds 499.
How we reviewed the responses
The OMB agency review team drew staff from across OMB’s Offices, including the Office of Performance and Personnel Management (including representatives from the Equity and Customer Experience teams); Office of Federal Procurement Policy; Office of federal financial management; and the Office of Information & Regulatory Affairs. Comments relating to specific policy areas were shared with relevant resource management offices.
To analyze the responses to the RFI, OMB staff first assigned each comment or portion of a comment within a submission to the corresponding RFI area (i.e., 1, 2, 3, 4, or 5). OMB then categorized each commenter within a sector (e.g., national non-profit, academia, industry) and the policy area that best represented the organizational/individual focus of the commenter. Next, OMB assigned keywords that captured the topic, policy, or program focus of the comment (e.g., data collection, contracting, housing, SSI) and summarized the key recommendations of the comment. Where applicable, staff noted references to equity assessment tools and frameworks, guiding principles, case studies, and other resources that could be readily useful to Federal agencies conducting equity assessment work. Lastly, depending on the content of a comment, staff also noted whether the content should be further reviewed by Subject Matter Experts or other Federal agencies for a deeper dive.
OMB then created an Excel document that aimed to provide a more user-friendly sorting mechanism for Agency Equity Teams to browse responses and resources that may be of use to their team.
What are we learning?
- Bringing together expertise and experience from across sectors can be a powerful catalyst for learning and solutions.
- Federal government can learn from and improve upon existing equity assessments, demographic data collection processes, and tools, particularly models that have supported state and local governments.
- Intersectionality matters; according to commenters, Federal policies, grants, and programs should always account for how people’s multiple identities interact with intersecting systems of oppression.
- Recommendations regarding data clustered around three general areas:
- Improving data collection and disaggregation to allow for detailed breakdowns by race/ethnicity, along with gender (including non-binary gender identification), income, and other demographics (such as sexual orientation) to assess disparities.
- Updating the Standards for the Classification of Federal Data on Race and Ethnicity to ensure accurate and actionable demographic data collection.
- Enabling data sharing and linking across Federal agencies to streamline data collection requirements, account for the intersectional needs of individuals, and examine the compounding effects of overlapping inequities. Data sharing efforts should, of course, appropriately maintain or enhance protections afforded under law and policy, including those related to civil rights, civil liberties, privacy, confidentiality, and information security.
- Many agencies underestimate the volume, variety, and significance of barriers that in-need individuals face when learning about and attempting to access public benefits and services. From assessing the usefulness of work requirements to strengthening outreach and improving coordination across agencies, stakeholders identified multiple opportunities to reduce burden and prioritize equitable access when looking at how programs are administered.
- There is a strong desire for a “no-wrong door” or one-stop shop approach to benefit program administration and streamlining/standardizing/modernizing application processes and offices to account for as many Federal programs as possible at once (thereby increasing both experience and efficiency).
- When it comes to Federal grants and financial assistance, commenters lifted up the importance of enhancing access to opportunities by:
- simplifying application processes and reporting requirements;
- reviewing and, as needed, revising grant scoring norms, rubrics, and processes to be more equitable;
- conducting targeted, culturally-responsive outreach to underserved communities and smaller organizations; and
- coupling flexible grant funding programs with capacity-building activities and technical assistance from trusted and experienced intermediaries.
- Responses highlighted that every community’s wellbeing should be supported through human-centered and trauma-informed approaches, and culturally-competent staff and outreach.
- Stakeholders endorse meaningful, long-term community engagement as a priority and recommend actions such as:
- engaging community members, especially those with lived experience, from the very early stages of program discussion and design, and in any decision-making processes;
- establishing advisory boards, task forces, and commissions that are inclusive of (and compensate) representatives from underserved communities; and
- including participatory budgeting processes where feasible to ensure communities can indicate collectively how resources should be spent and directed.
- Stakeholders also encourage Federal agencies to “meet people where they are at” through steps like:
- taking on the responsibility to initiate and maintain contact;
- making whatever accommodations (technological, physical, and otherwise) are needed to facilitate community participation, especially from underserved communities;
- offering multiple, accessible avenues (including virtual) to provide public comment; and
- reaching out via organizations and partner agencies that are trusted in the community.