NHC Responds to OMB RFI on Methods and Leading Practices for Advancing Equity
By Maddie Mason, Senior Associate, Policy
On July 6, the National Health Council (NHC) submitted comments to the Office of Management and Budget (OMB) on their request for information (RFI) for “Methods and Leading Practices for Advancing Equity and Support for Underserved Communities through Government.” The NHC applauded OMB for undertaking such an ambitious effort to assure all Federal resources are being used to increase equity and remove barriers and burdens for all marginalized communities. Although this effort addresses all areas of equity, the NHC focused our comments specifically on health equity.
The NHC comments focus on the following three questions in the RFI:
- Question One: Equity Assessments and Strategies
- Question Two: Barrier and Burden Reduction
- Question Five: Stakeholder and Community Engagement
Equity Assessment and Strategies
The Federal government faces a lot of challenges to ensure that all its programs and initiatives weigh equity’s impact. The NHC recently developed a specific set of principles and policy considerations called Health Equity Domains and Values. We utilize this tool to assess health policies and ensure they help advance equity. They were developed with input from NHC members, internal staff, and external stakeholders, and approved by our Board of Directors. We shared these domains and values through our comments as a tool to evaluate federal health programs and policies with an equity lens.
Additionally, the NHC noted that data quality, comprehensiveness, and consistency are critical to addressing equity. Thus, we recommended that Federal standards be put in place for data collection and use. This will ensure that data is consistent across Federal agencies and programs. It is also important to continue to gather stakeholder input to ensure the appropriate data is collected and the right questions are being asked.
Barrier and Burden Reduction
Data quality is critical to identify barriers and burdens, and to accurately do this, we need to ensure we have comprehensive and consistent data to review. Barriers and burdens for marginalized populations in Federal programs need to be identified with a data-driven approach. It is very important that the development and collection of these data points to help us identify these barriers and burdens be created as quickly as possible. The Federal government should continue to engage stakeholders to provide input and build mechanisms to act on this development.
Stakeholder and Community Engagement
The NHC emphasized the importance of consistent stakeholder-engagement activities across agencies that meet minimum criteria. It is not enough to just ask stakeholders for feedback and comment on draft rules, but it is essential to consult them at the earliest stages of an initiative. Federal agencies should develop relationships with trusted community partners that represent marginalized communities to develop opportunities for engagement.
For more information, please read our full comment letter here.