Equity and Evaluation Policy: Making Good on the Biden Administration’s Commitment
March 31, 2021
The Biden Administration has taken clear steps to make racial equity a governmentwide priority. What should that look like for evaluation policy?
The January 20th Executive Order on Advancing Racial Equity and Support for Underserved Communities through the Federal Government (EO) cited the urgent need to address entrenched disparities in US law and public policy, acknowledging long-standing inequities that exacerbated the converging economic, health, and climate crises. One week later, the Memorandum on Restoring Trust in Government Through Scientific Integrity and Evidence-Based Policymaking (Memorandum) emphasized “the delivery of equitable programs, across every area of government,” including the role of evidence-based policymaking. The direct language of racial equity, accompanied by President Biden’s January 26th remarks explicitly naming racial injustice as a nation-wide equity agenda, promises a new level of unpacking how federal government operates and engages people and communities historically underserved, marginalized, and adversely affected by persistent poverty and inequality.
How Do These Presidential Actions Relate to Evaluation Policy?
The Advancing Racial Equity EO formally recognizes in policy the depth of racism and other forms of oppression that so many people in America have faced since the country’s inception, sometimes overt and explicit, sometimes subtle and hidden, both intentional and unintentional. It creates an opening to look at how a network of diverse policies, norms, and assumptions work together to maintain privilege for some while obscuring it for others—as the Order says, an “ambitious whole-of-government equity agenda that matches the scale of the opportunities and challenges that we face.” This breadth matters. While mandates to look at “policy” often direct attention to programmatic areas – justice, food and nutrition, education, workforce, and many others – non-programmatic areas like evaluation and evidence-building may go unexamined or seem less relevant. The “whole-of-government” approach means that evidence-building systems are not somehow separate or exempt from the deep examination and change called for in other policy areas.
The Memorandum reinforces the EO’s themes of equity and adds an explicit tie to evidence-based policymaking, including the federal investment in capacity to build and use evidence required by the Foundations for Evidence-Based Policymaking Act. If agencies fail to consider whether and how major frameworks like evaluation policies promote or hinder equity, they risk limiting their ability to deliver on the Administration’s charge and could further entrench existing inequities upheld by current policy and practice. The Memorandum makes clear that agencies cannot overlook the role of policies and practices related to evidence in “the equitable delivery of policies, programs, and agency operations” and charges the Office of Management and Budget with issuing related guidance.
What Should OMB Guidance on Do?
Together, the EO and the Memorandum create an opportunity to examine how evaluation policy reinforces racial and other inequities – and to take action. While no OMB guidance can simply “fix” inequity, OMB can create expectations, standards, and processes for the equity work that agencies need to do, including these four things related to evidence-building:
1. Explicitly acknowledge the role and value of equity in evaluation, evidence-based policy, and evidence-based decision-making by adding it as a new program evaluation standard alongside those laid out in OMB guidance M-20-12.
- Currently, M-2012 mentions equity only once under the ethics standard among a list of several qualities that an evaluation should have. This fleeting mention falls far short of “match[ing] the scale of the opportunities and challenges that we face.” Given its prominent role in our society – from intentional efforts to deny equity to entrenched inequities that may be inadvertently reinforced – equity requires the kind of concerted attention and consideration that it receives in the EO on an ongoing basis.
- Elevating equity to a standard for program evaluation can serve as a mandate for explicit attention not only to how evidence findings can be used to increase equity but also how the processes of building and using evidence can themselves be made more equitable.
2. Advise agencies on specific approaches they can take to promote greater equity and evidence in their evaluation and evidence-building work.
- Incentivize and invest in research-practice partnerships, participatory action research, and other participatory methods – which agencies like the Department of Education, the Administration for Children and Families, and the Corporation for National and Community Service are already using to some extent — wherever feasible and appropriate. Make such approaches clear and accessible options or even the default setting for appropriate programs or evaluation efforts.
- Prioritize engagement throughout the learning process, from setting priorities to sharing findings to making meaning of those findings. Engagement should prioritize grantees, communities affected, and participants in the research as well as practitioners and state, local, and tribal policymakers.
- Consider the completeness of existing bodies of evidence based on the extent to which they reflect the lived experience of individuals participating in policies or programs being evaluated and determine where understanding lived experience should be further incorporated into the agency’s learning agenda or agency’s evidence-building priorities.
- Create a government-wide evaluation priority for identifying and understanding disparate impacts of policy and programs, particularly across racial groups and other underserved populations.
3. Activate the Interagency Evaluation Officer Council to address issues of equity in agency evaluation policy and practices.
- Charge the Council with convening a work group focused on applying the EO to evaluation policy, agency programs that support evaluation, and other evaluation functions and activities within agencies and recommending changes to OMB, the Council, and agencies whose missions or functions may raise particular considerations.
- Work with the Office of Science and Technology Policy to formally connect the work of the Equitable Data Working Group called for under the Executive Order with the work of the Interagency Evaluation Officer Council.
4. Establish or reinvigorate a learning community for evaluation staff – not just Evaluation Officers – to support agencies in implementing existing both new and existing guidance in the context of equity.
- Cross-agency collaboration can build understanding across agencies about how traditional models and approaches reify inequities and provide opportunities to identify and test alternative approaches.
- Agencies can thoughtfully explore and build capacity to support effective engagement, more collaborative approaches to evaluation, and methods that best promote equity as well as cultural and contextual relevance. For example, this community could learn from existing agency work on research-practice partnerships and participatory action research initiatives. It could also bring in outside experts – from program participants to academics to grantees – to help challenge assumptions, shed new light, and generate new solutions to support racial equity and underserved communities.
We celebrate the potential that the Executive Order, together with the Memorandum, presents for making the diverse and promising work in historically underrepresented and underserved communities more visible and more valued. These Presidential actions provide both tools and technical heft for upholding a longstanding moral imperative that the opportunities of our nation be fully and fairly made available to all. Federal evaluation policy that is reflective of this racial equity mandate can help move institutions, both within and outside of Federal government, to robustly consider what works, for whom towards a vision of a more equitable America for all.