The Forum for Youth Investment submitted these comments on the Federal Data Strategy’s Year One Action Plan. The comments were delivered in person at a July 8th, 2019 event as well as online after the event.
The Forum is an action tank working to change the odds that all youth are ready by age 21 for college, work and life. Our efforts include improving policies, building partnerships, and strengthening practices. As part of our policy work, the Forum works to advance evidence-based policymaking and encourage better policy alignment within and across all levels of government.
We are pleased to see so many federal agencies involved in the effort to create the Federal Data Strategy as a whole and the Year-One Action Plan specifically. This is critical work, and we appreciate the extensive process, including opportunities for input, that the CAP goal team here today has made possible.
More specifically, we appreciate the action plan’s purpose, as it states, “to align activities and set a firm foundation of tools, processes, and capacity to leverage data as a strategic asset.”
Our comments on the initial draft of this action plan focus on the fact that, for many federal agencies and programs, part of a firm foundation includes thinking from the beginning about the role that states, tribes, and localities play in collecting, managing, and sharing data, whether for federal reporting and use or to effectively manage federal dollars toward their intended outcomes. We appreciate that the data strategy as a whole acknowledges this by explicitly encompassing federally sponsored data and through the strategy’s practice #26, “Share Data Between State, Local, and Tribal Governments and Federal Agencies,” which recognizes these vital partners in the effort to strengthen the federal government’s use of data.
However, other levels of government are almost invisible in the action plan. The strategy references other levels of government just once, specifically “partner[ing] with states to address improper payments in programs that they administer using federal funds” as part of the President’s Management Agenda. But, as the strategy acknowledges, this isn’t the only role for other levels of government, especially when it comes to the strategy’s broad goal of helping agencies deliver on mission.
Our concern is that, if other levels of government are not included in the foundation, it will be much easier to leave them out or undervalue them over time as the strategy is operationalized. While that’s clearly not the intent, visibility and hooks for accountability help make sure it happens effectively.
To be concrete, this concern applies directly to the data strategy team’s question #2 on how the action plan could align with or complement ongoing federal data initiatives. One specific initiative already referenced in the plan is the PMA’s CAP Goal #8, Resulted-Oriented Accountability for Grants. As you already know, the many grants that go to or flow through states, tribes, and localities cannot effectively shift to a results-oriented framework without better data and data infrastructure at other levels of government. However, even the reference to this CAP Goal is confined to step #10 “Improve Financial Management Standards,” which are essential but insufficient for results-oriented accountability while the goal itself reflects the importance of other data, like performance data.
To address the team’s question #4 regarding the action plan, we believe that small changes to three of the agency-specific action steps could go a long way to making sure that this foundational plan adequately accounts for the critical role of states, tribes, and localities over the long term:
- Action Step 13 asks agencies to conduct an initial maturity assessment focusing on data and data infrastructure needed to answer priority questions and set baselines. We recommend that the action step call for assessments to specifically identify and address where the maturity of data and infrastructure at state, tribe, and local levels will be relevant to the overall execution of the full data strategy. This information could help to inform later steps and mapping of investments that are relevant to state, local, and tribal actors—both by individual agencies and across agencies.
- The other two action steps—15 and 16—both raise the concern of calling for stakeholder engagement without naming states, tribes, localities as stakeholders that agencies may need to consult and without making agencies accountable for whom they consult.
- For example, where Action Step 15 asks agencies to engage stakeholders and key leaders in the process to identify data needed to answer agency-wide priority questions, the accountability measure for this explicitly mentions Chief Data Officers as an example of key leaders. We encourage 1) similarly explicit examples of stakeholder groups—including states, tribes, and localities—and 2) requiring agencies to identify the stakeholders consulted, including publicly to the extent possible.
- Similarly, the agency plans due under Action Step 16 on identifying priority data sets for open data plans, which should be developed with stakeholders, should also explicitly name states, tribes, and localities—among other stakeholders—as potentially relevant, and the agency plans should list the stakeholders consulted.
- For the portion of this concern that relates to naming stakeholders, the Year 1 Action Plan could also add a footnote listing categories of potential stakeholders to include other levels of government as well as other major stakeholder groups for general reference.
We hope that by including key references to and points of engagement with states, tribes, and localities, this first Action Plan will lay an appropriate, accountable, and comprehensive foundation for future plans, especially recognizing that future actions may require more investment and buy-in from intergovernmental partners.