Advancing Equity Requires Leadership and Coordination Across Agencies

Census and Data Equity Resources 05.1,23

A major theme of The Leadership Conference Education Fund’s recent report “Data for Equity: A Review of Federal Agency Equity Action Plans” is that many federal agencies have similar challenges, shortcomings, and unanswered questions about equity-related issues. As the report highlights, rather than having dozens of agencies each try to navigate these common issues on their own, a few federal entities should play a leadership and coordination role. These coordinating bodies should share knowledge and best practices across agencies, connect agencies with experts in other parts of the government, and push agencies to address problems they have not yet identified or made plans to solve.

Specifically, Data for Equity recommends that the following bodies should play this coordinating role:

  • The Office of Management and Budget (OMB), a White House office that oversees implementation of the president’s agenda throughout the executive branch and coordinates the U.S. federal statistical system
  • The 13 federal statistical agencies whose mission is to produce official federal statistics
  • The National Science and Technology Counsel (NSTC)’s Subcommittee on Equitable Data, which took over implementation of the recommendations of the now-sunsetted Equitable Data Working Group
  • The White House Steering Committee on Equity, a new body whose formation the White House announced in February 2023

This recommendation echoes announcements in President Biden’s February 2023 executive order on advancing equity. OMB, the executive order said, will support implementation of agencies’ annual equity action plans, and the new White House Steering Committee on Equity will coordinate government-wide efforts to advance equity. Data for Equity’s proposals also recall several key recommendations of the Equitable Data Working Group.

Tasks for Coordinating Bodies

Data for Equity makes a number of specific recommendations about ways these coordinating entities can help agencies advance equity.

  • Encourage agencies to expand collection of data necessary to assess equity

Many of the dozens of Agency Equity Action Plans agencies released in April 2022 reveal that agencies lack the data necessary to assess equity in society and in their own programs. OMB should assist agencies in correcting these deficiencies.

Procurement. Multiple Action Plans identify the need for more complete data on federal procurement and contracting. For instance, both the Department of Homeland Security and the State Department noted that existing laws and regulations do not provide for tracking of contracting or procurement with businesses owned by people from certain underserved communities, including religious minorities and LGBTQ+ people. OMB should assist in this effort by providing guidance on how agencies can track these contracts, and by coordinating across agencies on data relating to equity in contracting.

Identifying and addressing data gaps. OMB and the NSTC Subcommittee on Equitable Data should lead in encouraging agencies to recognize when they have data gaps, develop plans to address those deficiencies, and follow through to implement those plans. They should also provide guidance to agencies on when they can and cannot collect data directly, coordinate the sharing of data and statistical tools across agencies, and assist agencies that need to modernize their data systems.

For instance, the Department of the Interior already plans to work with OMB to improve data on recreation and tribal discretionary grants. But the Department of Justice’s Action Plan does not discuss any plan to obtain data on hate crimes, even though countering hate crimes is among the agency’s top equity priorities.

  • Lead on increasing data disaggregation

Update OMB standards on race/ethnicity. The most important change required to meaningfully disaggregate data about race and ethnicity is for OMB itself to change its outdated Statistical Policy Directive No. 15: Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity (“Standards”). The current Standards fail to reflect the identities of many people, including those of Middle Eastern and North African heritage. OMB announced a formal review of its Standards in 2022. It should strive to complete it by the stated goal of summer 2024.

Increase disaggregation even without changes to the Standards. Even without a change to the Standards, OMB and the NSTC Subcommittee on Equitable Data should follow up with agencies to ensure they create and implement plans to increase data disaggregation. For instance, the Equal Employment Opportunity Commission plans to increase disaggregation of race/ethnicity and gender data. The Social Security Administration does not have, and should develop, a plan to expand beyond binary M/F gender designations.

  • Provide guidance on language and disability access and improving response rates

OMB and other coordinating bodies should centralize and share guidance and best practices about improving response rates and about language and disability access plans, to ensure that data collection instruments are accessible to people who are limited English proficient or who have disabilities.

  • Give agencies resources to conduct equity assessments and focus on the big picture

Many agencies, including the Department of Health and Human Services (HHS) and the United States Department of Agriculture (USDA), identified in their Action Plans a need for more capacity to perform equity assessments. Additionally, several agencies’ Action Plans reveal an ill-advised focus on measuring equity just within their own operations, rather than in the aspects of society that their programs touch on. For instance, the Privacy & Civil Liberties Oversight Board’s Action Plan discussed internal measures like increasing public access to agency events, but not assessing whether the anti-terrorism activities on which it advises have a disparate impact on the privacy and civil liberties of historically marginalized groups. OMB and the other coordinating bodies should provide resources to enable agencies to conduct high-quality equity assessments, and steer them to examine the big picture.

  • Lead on reforming cost-benefit analysis

A few Action Plans discuss the need to reform cost-benefit analysis methods to account for equity concerns. For instance, the Environmental Protection Agency will begin considering the cumulative impacts of its decisions, such as whether multiple sources of pollution in communities of color or low-income neighborhoods may have heightened health impacts. OMB and the other coordinating bodies should provide education and best practices to agencies about how to reform cost-benefit analyses so that they do not ignore or exacerbate inequities.

  • Ensure big data and algorithms do not entrench inequity

The Action Plans of the Department of Defense and the Consumer Financial Protection Bureau highlighted the concern that “big tech” and algorithms could entrench inequity. This issue is surely relevant to other agencies as well, so OMB and the other coordinating bodies should share insights on this issue across agencies.

  • Help agencies increase data accessibility

Agencies including the Commerce Department, the Department of Education, and NASA discussed plans to make data and tools more accessible to researchers and the public by building more user-friendly tools. OMB and the other coordinating bodies should coordinate disseminate knowledge and best practices on this widely-relevant topic.