Latest OMB Memo Details Actions for Federal Evidence-Based Decisions

To further its emphasis of a data-driven decision-making federal government, the Biden Administration’s OMB issued a memorandum on June 30 providing detail on Evidence Act provisions. This latest memo compliments three other OMB issuances on the legislation, including OMB M-19-23, OMB M-20-12 and OMB Circular A-11.

Title I of the Evidence Act places a statutory requirement on CFO Act agencies for several deliverables, including a Learning Agenda, Annual Evaluation Plans, and Capacity Assessments for Statistics. The latest memorandum expands on previous guidance and pushes agencies away from doing the bare minimum to meet these legislative requirements, and towards producing evidence-driven results. “Agencies should not simply produce the required documents and then turn their attention elsewhere; success requires that agencies develop processes and practices that establish habitual and routine reliance on evidence across agency functions and demand new or better evidence when it is needed,” according to the memo’s introduction.

Furthermore, the latest document references earlier Biden executive orders, and encourages small agencies, non-CFO Act agencies and subcomponents to undertake in the activities prescribed as well.

Evidence, the memo outlines, must be present in government contexts such as agency operations, grant making, program and service delivery, human capital management and development, and program administration. Federal learning agendas and evaluations should reflect equality, scientific integrity, administration priorities, and adapt to unconventional events such as COVID-19.

While the memo acknowledges Learning Agenda and Annual Evaluation activities thus far, the document outlines even further actions for both to drive effective decision-making.

Learning Agendas and Annual Evaluation Plans

The process of Learning Agendas (i.e. question development, disseminating and using results, refining questions) is just as important as the document itself, the memo states. Moreover, Learning Agendas must be flexible, iterative, and revised annually. Evaluation Plans, on the other hand, should only include activities that meet statutory requirements and respective agencies’ definition of “significant.”

The memo states that both deliverables must contain the following:

• Establishment of processes for developing, executing and updating the final products
• Engagement with an array of stakeholders, ensuring equity with a full range of perspectives and voices
• Future iterations must build on and refer to evidence generated from prior deliverables
• Government-wide efforts to address current and future challenges (i.e. climate change and public health emergencies)
• Activities must be transparent in the planning, implementation and completion phases, with public-facing documents posted on agency websites in a machine-readable format

The results of these deliverables, the memo describes, are two-fold; past progress and activities must support current and future evidence-building plans, and agencies must report on the evidence built from these activities such as lessons learned and influenced decisions in improved programs and operations.

The memo provides an outline for deliverables, requiring full draft Learning Agendas and Agency Evaluation Policies by September 2021, concurrent with FY 2023 budget submissions. Final Learning Agendas, Annual Evaluation Plans and Final Capacity Assessments will be due February 2022, and publicly available on a central evaluation.gov website.

Contractor Implications

With this push to not only meet Evidence Act compliance standards, but also produce actionable, evidence-based results, contractors have an opportunity here to aid agencies in fulfilling the demands of the OMB memo. The guidance directs agencies to strengthen the workforce by ensuring skill and expertise in evaluation, statistics, research and other analysis. The memo states that OMB expects agency investment in evaluations to extend to hiring, retaining and developing such qualified employees to oversee activities. Agencies may turn to outsourcing to fulfill gaps in expertise, as well as lean on recruitment, training and other services to help build the federal workforce.

Moreover, the memo outlines four broad types of evidence agencies should use to fulfill its directives: foundational fact-finding, policy analysis, program evaluation, and performance measurement. The memo places emphasis on methodologies to obtain evidence, requiring additional support by agencies to measure and track data. Contractors may be able to help agencies in these methodologies in areas such as data dashboard implementation, value stream mapping, root cause analysis and statistical analysis.

The transparency of evaluations and agendas will also help glean agency priority areas, needs and roadmaps to evidence-based policy and decision-making. As such, contractors must continue to track the progress and publication of Evidence Act deliverables.