Methods and Leading Practices for Advancing Equity and Support for Underserved Communities through Government
Summary of Stakeholder Responses to the OMB Request for Information (RFI)

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.

• 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:
  1. 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.
  2. Updating the Standards for the Classification of Federal Data on Race and Ethnicity to ensure accurate and actionable demographic data collection.
  3. 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.