The OMB Equity RFI: YES, you should submit comments!
On May 5, 2021, the Office of Management and Budget, the main administrative agency for the federal government, issued a “Request for Information” — an (RFI), asking the public to provide input on “Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government.”
This is an unprecedented opportunity for researchers, advocates, public servants, community leaders, citizens, and more to raise their ideas and work to the highest levels of government, and set the agenda for reshaping the federal government for equity for all.
On May 27, POPVOX Foundation joined Black Women’s Congressional Alliance and Representative Democracy to host a webinar about the RFI, with expert speakers offering background and tips on making a submission.
What is an RFI?
As lawyer-turned anthropologist, Chandra L. Middleton, PhD candidate in anthropology at the University of California Irvine, noted, a Request for Information comes at the beginning of an agency (in this case, OMB) setting its agenda on a particular topic. An RFI is an open-ended call for expertise, input, and suggestions from all interested. This means you!
What’s in this RFI?
This RFI seeks comments in five areas. Representative Democracy cofounder, Noralisa Leo, summarized them here, but we would recommend reading the actual RFI text to make sure that you are answering the specific question.
Area 1: Equity Assessments and Strategies. Government must assess future practices and policies to ensure they ADVANCE equity and that it is embedded in how they operate. That means having a framework and tools to assess equity, its impact (in a quantitative form) on underserved communities, and the ability to identify systemic inequities to be addressed by agency policy.
Area 2: Barrier and Burden Reduction. Assessing and remedying barriers, burden, and inequities in public service delivery and access. This includes external factors that disproportionately affect access to programs/information; and, internal barriers in the administration of programs.
Area 3: Procurement and Contracting. Approaches and methods for assessing equity in agency procurement and contracting processes that currently total over $650 billion per year.
Area 4: Financial Assistance. Approaches and methods for assessing equity, best practices, outreach and stakeholder engagement strategies, and the skill sets and training needed in-house to administer “equity-based grantmaking.” This includes grant opportunities and other activities that direct dollars into underserved communities.
Area 5: Stakeholder and Community Engagement. This area instructs agencies to expand their use of stakeholder and community engagement in carrying out the EO. OMBs’ questions in this section are likely to mirror the Outreach and Strategic Communications Strategy many of you use in your own advocacy campaigns to reach targeted communities. Elements may include the need for distinct, targeted and relevant messaging, the use of trusted messengers, native languages, accessible channels for feedback and further questions.
Preparing your response for success
Rachel Augustine Potter, former Office of Information and Regulatory Affairs employee and current Assistant Professor of Politics at UVA and author of “Bending the Rules: Procedural Politicking in the Bureaucracy,” offered these five tips for a successful submission:
Think about the person who will be reading your response: OMB is staffed mostly by career civil servants, who have served under multiple administrations. These folks are dedicated to making government work, and are curious and engaged with any new research and information. That said… They also have a lot on their plate! So it pays to make your document as readable as possible using headings, bullet points, and other organizing features.
Answer precisely the question, in the context of your mission and what you want to accomplish: an RFI is a carefully and precisely drafted document intended to be a tool for agency policy. This means that if a question is worded a certain way, it is giving you clues to what exactly OMB is looking for, and how to apply your expertise to help. Make sure your response carefully answers the specific question in the RFI!
Balance academic research with illustration and anecdote: OMB staff are generalists who are comfortable with academic writing, but may not know the specific jargon of your field. Think about balancing research and evidence with why this is important from your experience: anecdotes and personal stories can help bring the denser academic work to life.
Think about your response as part of a larger conversation: OMB staff will be reading and analyzing hundreds of comments at the same time, so being deliberate about showing how your expertise and ideas relates to a larger conversation can be helpful. Think about how you can connect your response to comments already submitted, or coordinate with other organizations submitting responses to tell a full story. If you’re leading a coalition, consider drafting a template that other organizations can add their own detail and expertise to.
Think about the future utility of what you’re submitting: this is an action-oriented process! Responses here will help inform a full-government agenda over the next few months, so giving OMB usable tools—for example, a slide deck that can be shared with agencies or citations that point policymakers in helpful directions or a ‘toolkit’ that can be adapted for trainings—will help make your response part of the ongoing conversation.
I’m ready to submit! What do I do now?
Make sure to go over the exact text of the RFI on the Federal Register to make sure you’re answering their questions
Review comments that have already been posted on Regulations.gov; you may want to reference those you agree with or directly counter points with which you disagree
Submit your comment through Regulations.gov
(Or you can submit an in-line comment on a piece of the RFI through POPVOX Madison)
What happens next?
Former Obama Director of the Office of Personnel Management, Katherine Archuleta explained the process:
Public comments are due at midnight on July 6, 2021
Federal agencies are working on “assessment of the state of equity for underserved communities and individuals,” which must be submitted to the Assistant to the President for Domestic Policy by August 8, 2021.
Agencies must then “develop a plan for addressing any barriers to full and equal participation in programs and procurement opportunities identified in its assessment” that is due January 19, 2022.
On the fence about preparing a submission?
Dr. Stephanie Rodriguez, Federal Partnership Director at Tech Talent explains why you should consider it:
This particular process is about shaping the agenda: the gvt doesn’t know what it wants to do yet, so your expertise sets the agenda. That also means there are no wrong answers!
Your submission will go to people who can act on it: OMB has a huge responsibility, and a huge amount of influence over policy for the whole federal government. This means that every comment can directly shape federal policy.
OMB recognizes that YOU are the expert: no one knows your stakeholders and communities like you do, and no one else will speak for them if you don’t.
