Keeping promises while keeping score: Gauging the impacts of policy proposals on racial equity

Side profiles of 5 diverse individuals' on pink background
Editor's note:

This research brief is part of a joint research project by Brookings Metro and the Institute on Race, Power and Political Economy at The New School.


On May 25, 2020, four Minneapolis police officers fatally injured George Floyd, a Black man, while he was under their custody—a searing, caught-on-camera killing that sparked the largest mass protests in American history. While the protests ostensibly focused on police killings of Black people, they also called out the systemic racism that fuels many other manifestations of racial inequality. In Minnesota state court, a jury found former Minneapolis police officer Derek Chauvin guilty of murder, and in a federal trial, the other three officers were found guilty of violating Floyd’s civil rights. But beyond justice for George Floyd, how much progress have we made in addressing racial inequality in the U.S.? 

Two years after Floyd’s murder, the question of how to gauge that progress lingers without resolution. There are encouraging long-run shifts in white Americans’ recognition, after generations of denial, that racism is real and pervasive. But a clear lesson from our history is that such shifts in public attitudes do not automatically lead to institutional reforms. The mass protests of 2020 were, after all, a call for accountability—not only in criminal justice, but across the functions of government and other institutions. As a former chief equity officer in local government told us, “That means a call for a different way to govern.” 

A central plank in accountability—in that different way to govern—is gauging the equity impacts of public policy. This has been done in ad hoc ways for laws, regulations, spending plans, and other instruments of policy for decades. What’s new, and what we and others are advocating, is formally and routinely embedding equity assessment, including racial equity impact assessment, into government consideration of policy proposals in addition to assessment of actual policy impacts over time. 

There are four main findings in our research so far, and the first is a very hopeful one: In a range of communities across the country and across multiple functions and levels of government, applying an equity lens in the form of impact assessments has gone from the margins to the mainstream of thinking about how government can serve everyone more effectively and address a history of exclusion in the process. For now, local governments are in the lead, the federal government is making notable progress (at least in the executive branch), and state decisionmaking shows great room for improvement, especially in basic transparency and accountability. 

Our second finding is that such progress has put a spotlight on key gaps and chronic challenges, some of which undermine all types of government innovation—not just changes to advance equity. We need better and more disaggregated data that makes meaningful equity impact analysis possible on the full range of issues government touches. We also need innovative and collaborative forms of public engagement and expanded operating capacity to help public agencies respond when communities and elected leaders press for equity analyses. Finally, to deliver the work of government more fairly and effectively, we need concrete plans that measure impact.  

Third, to advance the work and make it endure, we must change our political culture and grow a broader, more resilient base of political support for racial equity beyond the brave leadership of racial justice advocates. Building political support against the tide of racially divisive politics and fear-mongering tribalism that has driven so much of our public life will take creative and bold leadershipand, we realize, a broader moral awakening. Racial equity, like other forms of equity, must be understood on moral, not just pragmatic, grounds. That, too, was part of the call when hundreds of thousands of everyday people from all walks of life took to the streets in 2020 to demand better. Equity impact assessment can and should be embraced by a bigger tent of allies, because it makes better, more innovative government possible. 

Our fourth finding is that to address the gaps that act as barriers and build that bigger tent, advocates for change inside and outside of government also need well-defined, generative projects—such as plans for public investment in infrastructure or innovative public safety strategies—as well as new practices for making public budgets at all levels of government. These will show how equity impact assessment changes the conversation, generates new insights about problems and persistent disparities, and drives better solutions, with resources attached. We give several examples of such generative projects in this brief, and will expand on them in a longer report later this year. 

In sum, community advocates and pathbreaking governments have gone from conceptual framework to concrete and innovative practice in just a few years and in a remarkable range of ways. But for the work to become broadly transformative and supported, governing for equity—and, specifically, embedding equity impact analyses—now needs more public sector capacity, more allies, and more generative projects that show the idea in action and deliver visible, valued results in communities. 

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The current landscape of racial equity assessments and the origin of this project

Bolstered by the movement for racial justice, Joe Biden’s 2020 presidential victory spurred action for achieving greater equity in government programs and identifying biases, discrimination, and other drivers of inequity in government practices. When Biden and a new Congress took office last January, the president issued the first-ever executive order on “advancing racial equity and supporting underserved communities” through policies and practices used across the executive branch. This effort drew energy and lessons from years of work by advocates and local governments at the forefront of change across the country, as we detail below. 

At the same time, our colleagues Andre Perry of Brookings Metro and Darrick Hamilton of the New School’s Institute on Race, Power and Political Economy argued that “just as we score policies’ budget impact, we should score for racial equity as well.” They called on elected leaders, especially in Congress, to build in mechanisms to evaluate policy for impacts on racial equity beyond traditional cost scoring. Perry and Hamilton called for “a scoring system to hold government accountable” for fairness and racial equity, and invoking the nation’s history of racial injustice and struggles for equality, they emphasized, “We must take on an anti-racist orientation to policymaking and implementation—a proactive weeding-out of racism.” 

Scoring legislative proposals for their racial impact could serve as a key proactive mechanism, complementing the guard-rail function of analyzing policy and practices by disparate treatment and disparate impact standards. Those approaches have a long and important history in civil rights law and anti-discrimination work. Much of that work is vital for assessing equity impacts after new laws, regulations, or administrative policies are adopted. 

Since early last year, some federal policymakers have taken the initiative to promote racial equity assessment and generate new government practices and approaches to decisionmaking. Last year, Democrats in the House and Senate introduced bills (S. 2723 and H.R. 5018) to require racial equity assessments for certain types of bills. In July of last year, in response to the president’s executive order, the White House Office of Management and Budget issued a wide-ranging review of methods for assessing equity (with respect to race, ethnicity, religion, income, geography, gender identity, sexual orientation, and disability) in federal agency “policies and actions” and, crucially, for building the requisite data and capacity to effectively use the best methods to change outcomes. And in April of this year, the administration released the first “equity action plans” for federal agencies, based on the previously mentioned executive order and a year of internal review. 

The administration has also launched a number of special initiatives. For example, driven by President Biden’s Justice40 pledge (to deliver at least 40% of the benefits of federal climate action to disadvantaged communities), the White House Council on Environmental Quality published a Climate and Economic Justice Screening Tool. And the Property Appraisal and Valuation Equity (PAVE) action plan, developed by a multi-agency task force led by the U.S. Department of Housing and Urban Development, was inspired by research showing systemic and costly racial biases in the home appraisal industry. Both initiatives illustrate how careful and creative equity impact assessment can lead to promising shifts in policy and practice. But it will take time to gauge impacts on the ground, whether in the targeting of infrastructure funding to promote more equitable and effective climate resilience or by making it possible for homeowners to build wealth regardless of their race or neighborhood of residence. 

Our work with a larger team, led by Hamilton and Perry, is a joint effort by Brookings and the New School to concretize their proposal, with support from the Robin Hood Foundation, New York’s largest povertyfighting philanthropy.  Learning from the efforts of advocates and experts nationwide, our project is analyzing and addressing barriers to adopting racial equity impact assessment effectively in government. In a parallel effort, PolicyLink, a nonprofit research and advocacy organization dedicated to advancing equity, and the Urban Institute launched the Equity Scoring Initiative, which is initially focused on equity scoring of proposed federal legislation. 

All of this work builds on pioneering efforts by leaders, advocates, and institutions across the country, particularly at the local level. Local efforts to promote equity and change government decisionmaking practices intensified significantly over the past two years, particularly in the wake of 2020’s protests. But foundational work preceded and informed much of that, especially the work of the Government Alliance on Race and Equity (GARE), a project of Race Forward and the University of California, Berkeley’s Othering and Belonging Institute. GARE has worked to equip city and county governments with racial equity impact assessment and other tools to improve decisionmaking and the design and delivery of government programs. GARE’s work emphasizes that the assessment part of governing for equity is, first and foremost, about changing what questions get asked when policy is made—thus improving policymaking and implementation and not just making pro-equity policy choices on a given issue. Other leaders in this local work include PolicyLink, as part of its All-In Cities initiative; Living Cities, a consortium of the nation’s largest financial institutions and philanthropic donors, in its work to “operationalize racial equity,” especially in local government and cross-sector initiatives; and New America, a think tank, through its New Practice Lab. 

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Strategic questions about assessing and advancing racial equity

This pioneering work has generated a number of key questions. Some are definitional and foundational: What is equity, and what does it require? This has moved beyond the principle that policies must not be racially discriminatory—typically conceived as a treat-everyone-the-same approach that is still contested in many areas of government policy. But in moving beyond that approach and instead responding to a diverse range of needs, abilities, and disadvantages among those served by government, another question arises: Does equity in governing also require making amends—through reparations or other means—for years of discrimination and cumulative disadvantage that racism and other forms of exclusion have caused? For many advocates and policymakers, assessing equity raises fundamental questions that range from the moral and political to the constitutional. 

Other questions are more instrumental, centered on where to focus first and how to expand support for more expansive approaches to policymaking over time. Should equity efforts address the full range of government policies, from criminal justice and workforce development to housing, infrastructure, environmental policy, and more? Or should efforts start with a few key policy domains and agencies to generate faster impacts, learning, and support? What is the role of communities and civil society groups and how should their voices be heard in the work of government? Are promising models, such as the use of “social audits” and participatory budgeting, worth integrating into efforts to operationalize equity in governing? More broadly, what are the best ways to go beyond basic consultation and support empowered participation by the public and especially by historically marginalized groups? How can those efforts best be joined with effective government action, i.e., delivering results, not just greater community “voice”? 

Finally, some questions are organizational and operational. Are equity-focused efforts, at any level of government, best housed in existing agencies like a budget bureau, human resources, or contract compliance unit? Or should there be a new, cross-cutting senior executive function with oversight and assessment authority over government functions as well as support functions to build the capacity of agencies? Should an equity office be independent of the legislature or executive, like an inspector general or New York City’s Independent Budget Office? Or would that hamper its ability to push for change in institutional practices? 

Cutting across these questions is the need to make judgments in context and learn and adapt over time. Under what conditions is one answer better than the other? And when should a given approach modify its methods or increase its scope? 

This much is clear: Because of activist communities and pioneering work by nonprofits and some governments, we now can learn from practical experience and ongoing experimentation, which in turn can foster wider adoption and improvement of racial equity tools and practices. Operationalizing equity in governing is no longer a set of isolated innovations. It has emerged as a dynamic field of knowledge and practice. 

In taking stock of these efforts, we focus on policy decision tools to advance racial equity while being mindful of the need to apply similar assessments on other dimensions, such as gender, sexuality, class (often measured by income level or educational attainment), and geography at multiple scales. 

While some of America’s local governments are blazing a trail for peers around the world, in certain ways, our federal government is lagging other wealthy nations. Those nations are ahead of us when it comes to routinely and systematically considering the potential impacts of national policy proposals—for example, the impacts of annual budgets and proposed regulations on different groups (e.g., by gender, sexuality, race and ethnicity, or socioeconomic status) and places (e.g., regions, or rural versus urban areas). 

The United Kingdom, for example, has for over a decade required that annual budget proposals include a distributional analysis of likely impacts on different groups in its population and parts of the country. This work features a published analysis as well as internal “green book” guidance, offering a form of equity assessment for the preparation of agency spending proposals. The U.K. also requires equity assessments as part of all regulatory and legislative proposals with estimated monetary impacts over a certain threshold. 

In 2019, the Organisation for Economic Co-operation and Development (OECD), a think tank and policy development forum for the wealthy economies, published a review of annual budgeting procedures by member states. OECD found that at least 10 nations apply some form of equity assessment, with gender equity assessment especially prominent, as part of budget preparation and review; the U.S. is not yet one of them. The European Union has been a particularly important force for learning and change in its member nation-states. 

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How this analysis is organized

In our larger report to come, we will recommend changes to accelerate progress in governing and share in-depth working examples of that progress across the U.S. To set the stage for that, in this research brief, we offer a functional typology of equity assessment mechanisms in use by governments in the U.S.—distinguishing the motivations that drive them and highlighting several new or unrealized opportunities. We also summarize the major recurring challenges confronting the wider adoption and effective use of equity assessments. 

Improving these governing practices and the tools that support them is both practical and moral. Practically, it is a critical step toward grounding equity work in data, analysis, and the routine practice of making and implementing policy—thus achieving greater equity by documenting gaps and their drivers and by helping devise effective solutions. And morally, America, especially its institutions of representative government at all levels, must be more accountable to its promise of fairness and equal opportunity for all. We begin by reviewing the evolution and range of equity analyses as a tool to help make that possible. 

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The evolution of equity analysis in public policy

For decades, analysts, advocates, and policymakers have worked to understand the equity implications of public policy decisions. This often is done through “distributional” or similar analytic frameworks that focus on disaggregated rather than aggregated patterns—the drivers of income and wealth gaps by race, for example, not just median income. Broadly, we can think of equity analysis as seeking to understand how different groups, places (geographies), industries, institutions, and other stakeholders are affected by policy design and implementation, in order to make the process and outcomes of policymaking more fair and equitable. 

Much foundational work has been grounded in empirical analyses of policies already adopted. That is, equity analyses often examine the effects of past policy design and implementation choices to understand the differential effects of policy, from education to employment, health, the environment, and other domains. For example, how have changes in the minimum wage affected the median incomes of male versus female workers, or Black workers versus white workers? How can we distinguish these impacts while recognizing that workers from different groups are unevenly distributed across industries, occupations, and jobs at or near the minimum wage? Similarly, an analysis of regulatory policy might examine the effects of past rulemaking and enforcement on one type of business or one group of business owners versus others. We also see this type of work in analyses of government contracting opportunities or credit availability for different groups of business owners, whether those groups are defined by race, gender, location (owners in small towns versus large urban areas, for example), or in other ways.  

However, disaggregated analyses can only be performed where the right data are available and reported. We saw this during the first months of the COVID-19 pandemic. First, case data were not disaggregated in official reporting. When they were disaggregated by race and other factors, we immediately saw that people of color were disproportionately at risk of contracting the virus, suffering more severe symptoms, and dying. Further data and research helped us understand why: People of color and low-income workers were more likely to hold jobs with greater exposure to customers or coworkers infected by the virus—–for example, jobs in retail, food processing, and public services. And they were also more likely to suffer from preexisting health problems and a lack of medical care to fight the virus. This understanding, and its influence on policy when mobilized by advocates and government, would have been impossible without reliable, disaggregated data.  

We also learn about the present and make more informed forecasts from trend analyses of past disparities by race, gender, class, and other persistent dimensions of inequality. Analysts and advocates use such findings to highlight disparities and make predictions about the likely impacts of new policy proposals. In other words, equity analysis has long been more than backward-looking and diagnostic. It has generated new and important policy ideas and strategies, from programs to expand college or health care access to more tailored, “user-centered” designs for cash benefits delivery and even innovative land use and investment policies to address the racial wealth gap. 

As we previewed above, what’s new, and what we and others are advocating, is formally and routinely embedding equity impact assessment (including analysis of likely impacts on racial equity) in government consideration of policy proposals. Another significant innovation is ensuring the active participation and voices of affected stakeholders in the work of assessment. For example, Race Forward’s widely used question framework emphasizes both process and product. It identifies and engages stakeholders in assessing inequities and their causes, the relevance of a policy proposal, alternatives for improving it, and the most appropriate indicators of success. Using the example of federal welfare reform in the 1990s, one longtime practitioner reminded us, “Success was defined mainly as reducing the welfare rolls, not people being better off.” Different definitions of success can lead to dramatically different choices, efforts, and outcomes at any level of government and in any policy domain. 

Examining policy effects on racial equity ex ante, as proposals are shaped and debated, and formally institutionalizing that examination in public sector decisionmaking is a sea change in American governance. And it is very much a work in progress.  

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The four functions of equity assessment tools

Across the country, there are a variety of racial equity impact assessment tools and approaches currently in use, and others under consideration. The typology we propose here centers on function—i.e., what exactly the tool is intended to inform or trigger. We observe assessments serving four distinct decision support functions: legislative scoring; enhanced review; resource allocation plans and targeting tools; and performance management in program delivery. 

Functions of racial equity impact assessmentLegislative scoring: Equity impact assessment as a tool required in the legislative process, across policy domains or in selected domains, for policy proposals that meet certain conditions 

The first decision support function is equity assessment as legislative scoring, or rating policy proposals (not just pricing them) once they clear the initial phases of the lawmaking process—e.g., approval by a legislative committee

For example, in Washington, D.C.’s Racial Equity Achieves Results (REACH) Act of 2020, the city council adopted the legislative scoring use of racial equity assessment, effectively imposing the requirement on itself and creating a new city office to produce the required analyses. The results of those analyses are not legally binding, but rather meant to inform and influence the lawmaking process. 

At the federal level, the aforementioned House and Senate bills introduced last year fall into this category; the Senate version is called the Fiscal Analysis by Income and Race (FAIR) Scoring Act. As part of developing a proposal for equity scoring in federal legislation, the PolicyLink/Urban Institute Equity Scoring Initiative (ESI) compared equity scoring requirements in Washington, D.C., Minneapolis, Montgomery County, Md., and other localities, and documented criminal-justice-specific scoring requirements in multiple states. The ESI team finds that most of these systems provide specific guidance on what analyses are required, and varying degrees of discretion over which types of bills are exempt or covered, along with provisions to rate (score) a given legislative proposal on a spectrum of positive, negative, or neutral impacts on racial equity, with estimates of how likely those impacts are.

Another set of legislature-centered efforts is analyses by external watchdog groups of annual budget proposals—a broader, albeit unofficial kind of scoring. There often are no requirements in place for public agencies, the chief executive (mayor or county executive, governor, or president) responsible for preparing an annual budget proposal, or lawmakers to define equity assessment standards, let alone make the public budgeting process accountable to them. 

The Center on Budget and Policy Priorities, a longtime analyst of equity implications of federal budget and policy proposals, also operates a State Fiscal Project and acts as a national convener and resource for a network of state-based watchdog groups. The Center has articulated principles for an “antiracist, equitable state response” to COVID-19 relief and recovery, highlighting both the spending and revenue choices in state budgets and addressing the equity stakes of responding to short-term needs while also making longer-term transformative investments. The state-based groups in the network have presented similar frameworks for their states. For example, the Massachusetts Budget and Policy Center has defined “an antiracist state budget” as a core pillar of the group’s larger Envisioning Equity framework, and New Jersey Policy Perspective applied racial equity analyses in its breakdown of the governor’s FY 2023 budget proposal. These efforts combine the rating of budgets with recommended policy alternatives to further racial equity in specific ways. 

But state-level budget assessment and advocacy work are strikingly difficult due to the lack of transparency in budget deliberations. State legislative rules and norms for budget debate and adoption often make budgeting a nontransparent insider’s game; negotiations are conducted largely behind closed doors, with few (if any) public hearings and very limited legislative floor time, debate, or public comment. Unlike a governor’s proposed budget made public months in advance, the publicly visible budget decision process in state legislatures can often be counted in hours, or at most, a few days. 

Enhanced review: Equity impact assessment as a tool added to reviews already required in a policy domain 

Last summer, following years of advocacy and intense public debate over housing affordability, resident displacement, and other impacts of large-scale rezonings, the New York City Council passed a law requiring the executive branch to produce a racial equity impact study (EIS) for proposed rezonings. Nationwide, advocates have compared this sort of EIS to the environmental impact statements long required for certain development projects. From the standpoint of justice, an equity EIS—like other equity impact assessments and environmental impact assessments—is meant to promote procedural as well as substantive fairness. If there is a meaningful impact on future land use policy (a significant power zealously guarded by local government), this type of required assessment could have a substantial influence on investment decisions, racial settlement by neighborhood, and generational wealth, including impacts on the wealth gap by race, neighborhood, and other traits. 

In the same vein, agencies at multiple levels of government are using screening and mapping tools and making them available on an open-source basis for others to use. For example, the Environmental Protection Agency recently updated its Environmental Justice Screening and Mapping Tool (EJScreen), outlining how the agency uses the tool in its environmental justice work and highlighting its potential uses and limitations. EJScreen can map racial settlement patterns with environmental quality risks and other social and economic indicators. The agency’s public release stresses that the tool can be used as a guide for planning and decisionmaking as well as an awareness-builder, but also that it does not offer a true environmental risk assessment for proposed policies or projects. Similarly, California has published the CalEnviroScreen, which maps indicators such as children’s lead risk from housing, water contaminants, and air quality by detailed substate geography, including disadvantaged communities. 

Resource allocation plans and targeting tools: Equity impact assessment as a tool to guide the allocation of resources, typically by executive agencies 

In 2021, the city of Chicago produced the nation’s first-ever racial equity impact assessment to guide the allocation of federal Low-Income Housing Tax Credits, the single largest source of capital subsidy for building or renovating affordable rental housing. The assessment is included in the city’s federally mandated allocation plan for these tax credits, and outlines the equity-focused public engagement process the city used and a wide range of equity-centered questions and factors employed in the decisionmaking process, as well as recommended actions in eight major issue areas. The plan prioritizes those eight areas as leverage points for changing measurable outcomes, from expanding access to business opportunities for Black, Indigenous, and People of Color (BIPOC) real estate developers to creating housing production targets to meet the needs of specific subpopulations and neighborhoods in the city, tailoring the services linked to new housing developments and more. 

Conversely, as mentioned in our introduction, the federal government’s Climate and Economic Justice Screening Tool, released in a beta version for comment in February, is not an allocation plan but a geospatial analytic tool to inform resource allocation. Its main purpose is to help federal agencies fulfill President Biden’s Justice40 pledge that 40% of the benefits of climate action go to disadvantaged communities. But like the EJScreen tool, this one is open source to encourage wider use. 

The Justice40 pledge and screener tool foreground a larger need to which we return below: Government leaders need to better demonstrate and explain how these kinds of tools will combine with regulatory design, operational capacity building, and other essential efforts to shift outcomes—i.e., to deliver greater equity, not just plan for it. For example, California targets investments using cap-and-trade funds to disadvantaged communities, using the CalEnviroScreen tool for that purpose. There also is a vigorous analytic and monitoring process with researchers and advocates using publicly available data to assess the equity impacts of cap and trade and other environmental justice issues. 

But key unrealized opportunities are evident as well—for example the generational opportunity in planning for equity in the nearly $1 trillion provided by the federal Infrastructure Investment and Jobs Act (IIJA) of 2021. Applying equity assessment and equity-centered practices to infrastructure is important when looking forward, but also when considering the lasting damage urban renewal and other capital programs have done in low-income communities and communities of color. Yet with the exception of a handful of federal programs, states—which will allocate the largest share of IIJA funding—are not required to explain how equity impacts will influence their allocation of infrastructure resources to serve some communities rather than others. Nor do states have to specify the standards for project planning and delivery that also shape equity impacts. The new federal law adds the largest single infusion of infrastructure capital in many years, but in general, state and local governments allocate even more infrastructure money from their own revenues, and they call most of the shots on infrastructure priorities and specific projects. 

Finally, in the domain of public health, California requires counties to monitor racial and socioeconomic disparities in COVID-19 positivity rates within counties and submit action plans to address those disparities. Likewise, several states used the Centers for Disease Control and Prevention’s Social Vulnerability Index to target their vaccine distribution and other public health strategies. 

Performance management in program delivery: Equity impact assessment as a tool to improve policy implementation 

This function, closest to frontline implementers and their practices, often joins new analytic tools and methods for training and other capacity-building supports; reporting or other transparency requirements; innovative applications of data science; and an organizational mindset of learning-as-we-go, or “getting better at getting better.” 

The city of Seattle and surrounding King County, Wash. were pioneers here, adopting this function across all public agencies. This function, unlike the others above, is tied to managerial effectiveness and performance management. But we should not think of it only in terms of the inner workings of government agencies. Many public policies work through private delivery systems, both for-profit and nonprofit. Government rules and benefits for health care, small businesses, affordable housing development, workforce development, and other priorities are delivered through a range of private institutions, from commercial banks, real estate developers, and fintech companies to private hospitals, colleges, and training providers—relying heavily on their delivery capabilities and ingrained practices. 

New America’s New Practice Lab has made notable contributions to this kind of racial equity analysis, inspired in part by the breakdowns in delivery of unemployment insurance and other benefits during the worst of the pandemic recession in 2020. This type of equity assessment is widely applicable and does not depend on new legislative mandates (though they can help). It is an old axiom in the public policy field that much policy “making” actually happens in program delivery—i.e., in the frontline implementation choices that shape critical outcomes, including who gets served and how well. 

These four distinct functions of racial equity impact assessment share certain operational fundamentals. For most types of policy analysis (for example, in functions one through three above), lawmakers or executives must: assign the analytic work to specific agencies or other bodies to produce specified analysis (who produces what), at clearly indicated moments in the decisionmaking process (when), and in some cases, ensure that the standards of that analysis are met by monitoring results over time (how well). 

By law, the Congressional Budget Office (CBO) does this in the scoring of legislative proposals at the federal level; for example, by specific conventions known as scoring rules, with legislative process rules such as points of order tied to the CBO’s findings. But for now, that scoring does not include equity impact assessment except in limited ways. And, as the Equity Scoring Initiative has pointed out in the context of this first function (legislative scoring), many racial equity impact assessments adopted across the country lack such triggers or enforcement mechanisms for now. But the CBO experience shows that scoring mechanisms can be developed and integrated into the legislative process. 

Researchers and advocates can also do equity impact assessments, often funded by philanthropy and using publicly generated and available data. Much analysis of COVID-19 equity impacts and needs was carried out this way. We also see this work by environmental justice organizations, children’s advocacy organizations, housing analysts, criminal justice reformers, immigration experts, and others. Making reliable data with racial and other equity dimensions publicly available empowers community advocates, so that government does not exclusively define the frames of analysis and terms of debate. This was pioneered decades ago by “citizen science.”     

As varied as they are, racial equity impact assessments share some common threads beyond those operational specifications. These substantive emphases distinguish the new practice of racial equity impact assessment in governing from traditional equity analysis in public policy, even equity analysis by race. First, advocates, public officials, and the communities they represent emphasize the enduring effects of historical injustices, or legacy effects—foregrounding the principles of restorative or reparative justice. Many earlier-generation equity analyses did not do this explicitly, if at all. Much earlier work simply did not consider reparative policy measures—in criminal justice, education, land and business ownership, or other areas—in the realm of possibility. But now, following 2020’s protests for racial justice and years of work by advocates and scholars, as well as shifts in racial attitudes, several cities and states are even exploring reparations for slavery. 

Second, these applications of equity assessment consistently emphasize the importance of policymakers and implementers learning from the lived experiences of affected groups or communities, not just from credentialed experts. Like the first common thread, this one is not entirely new. The city and regional planning field, for example, has long emphasized the importance of gathering and using local knowledge or community knowledge to shape plans and improve projects. And policy analysis has employed surveys, focus groups, ethnographic fieldwork, and other methods to examine policy from the vantage point of intended beneficiaries. But lived experience is increasingly seen as a critical source of knowledge to inform policy, for reasons of fairness as well as basic effectiveness. The rise of “needfinding” and other user-centered design methods in business—for example, to create demonstrably better products and delivery systems—and growing interest in public interest technology appear to be reinforcing this positive shift in public policy and management. 

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Recurring challenges for racial equity impact assessment—and where we go from here

Our research has turned up many creative examples of new or enhanced tools in use, as outlined in the typology. On one hand, this is a healthy reminder that government can innovate. Governing can be done differently, across the full spectrum of policymaking and implementation—from enacting laws and issuing regulations to creating reviews, risk assessments, resource allocation plans, and an array of implementation improvements. It is a testament to creativity and persistence by leaders and staff inside and outside of government. 

On the other hand, our research points to several important and recurrent challenges for the field of racial equity impact assessment and the effective practice of equity by government. These challenges include: 

  • Expanding data collection and reporting. Equity analysis cannot be done without reliable data reported on a predictable schedule and disaggregated by group, geography, or other traits. In many domains of policymaking and implementation at all levels of government, there are gaps in what we collect and report. Interest and progress in data science—and bringing data scientists to many units of government to tackle important problems—is generating new conviction about the value of having data of the requisite kinds. But we need to redouble a commitment to disaggregated, high-quality data collection and regular reporting in order to make data widely available for analysis and deliberation that inform public judgment and government decisions. Such public engagement will also improve data over time by informing what matters, how it gets measured, and how best to encourage the effective and creative use of data (such as through open data innovation challenges). 
  • Adding accountability mechanisms and mobilizing support for better results. For now, most of the examples we have covered do not include built-in enforcement mechanisms such as consequences for nonperformance, and in many cases, they include only basic transparency mechanisms such as periodic reporting by executive agencies. Achieving results with equity impact assessment rests on the shoulders of motivated public officials and a well-informed, organized, and mobilized civil society pressing for and supporting better results. To some degree, this will always be true in a democratic society. But the gaps underscore the importance of designing more robust mechanisms to support accountability, whether in the form of independent assessments or more developed benchmarks that define good practice and good progress from a given starting point. Strengthening the field nationally to share learnings will be important for this goal. 
  • Improving public engagement as a strategic muscle. A large body of research and commentary has underscored how limited, inflexible, and perfunctory much public engagement by legislative bodies, public agencies, and other government entities remains in American governance. Not surprisingly, this is an important challenge for the nascent practice of racial equity impact assessment. In particular, leaders we spoke to emphasized the need to: 1) draw on lived experiences or community insights to inform choices about metrics and, especially, standards of success; and 2) ensure more transparent and representative public input overall. There is much actionable knowledge to draw on, including well-documented, recent, pandemic-inspired innovations—some of them tied to the cases we have highlighted in this brief and many emphasizing collaborative governance (also known as “co-governance”) between public officials and civil society stakeholders. There is a substantial role for philanthropy here in funding analysis, advocacy, and the capacity needed to operate these governance innovations well (we return to this broader need below). 
  • Changing agency culture, including assumptions and norms. Time and again, experienced practitioners have seen the need to lay groundwork that enables productive learning and improvements within government. Effective equity practice will need to work with public agencies to overcome defensiveness and fear of failure and criticism, and also to confront a lack of knowledge about systemic racism or biases and overt resistance to operating differently. Race Forward, which operates the Government Alliance on Race and Equity—by far the largest program of technical support and peer learning—calls this “normalizing” the conversation. Last year’s review of equity assessment and practice by the White House Office of Management and Budget also underscored the need for organizational change management and culture building.  
  • Building operating capacity, including innovation capacity. The capacity gaps in government are wide and deep, and they reflect both long-run underinvestment in capacity and the higher expectations we now have of our public institutions. By analogy to transformation in business, higher education, or other sectors, creating an antiracist government that is also better able to understand and advance equity on other dimensions depends on developing certain basic forms of expertise and staff capacity. But it also calls for modernizing in the broad sense: building innovation capacity driven by the goal of better outcomes. Organizations in all sectors need this, and there are a variety of efforts to hire people with innovation expertise and also provide more professional development in this area, for both government and nonprofit organizations. Building the capacity to conduct and use racial equity analyses should be central to that work. 

In sum, calling for new habits and dramatically different results—from lawmaking to implementation—demands significant investments in new capacity. As a number of leaders shared with us, a substantial part of this must at least initially come from private, philanthropic donors whose support can outlast the terms of elected officials, operate above the fray of partisanship, and build lasting community and analytic capacity. Ultimately, that kind of support is no substitute for commitment within government, but it is essential, and currently far too limited relative to the needs and opportunities we face. 

These four challenges—better data, accountability, public engagement, and capacity—interact in multiple ways. For example, a culture of risk aversion in the public sector undermines needed innovation of many kinds, not just the effective use of racial equity impact assessment. This in turn reinforces gaps in reported data—why discuss something if there is little solid evidence to go on? A lack of operating capacity reinforces data and accountability gaps, as well as the familiar pattern—documented since the 1960s—in which government agencies with little track record of effective public engagement do not see much upside in working to improve the way they do it. 

But the opposite is also true: Gains on each of these fronts can reinforce gains on the others, in a virtuous cycle. This too has been documented over and over in other arenas of government innovation and performance leadership. As singular as racial injustice and racism are in our society, we need not treat the practice of racial equity by government as unrelated to or utterly unlike other efforts to transform how, and how effectively, government operates. Indeed, as we will explore in more depth later this year, there are many reasons to better align these related efforts—in essence, a commitment to effective government that serves all and earns correspondingly broad-based public trust and confidence. 

That final point underscores a different kind of challenge that leaders in the field highlighted for us: the need to enable a much broader and more diverse constituency—a bigger tent of allies—to recognize the stakes and support change. Racial equity impact assessment offers a way to ground policymaking and implementation in universal human rights and widely shared aspirations that government should work to effectively serve everyone.  

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Racial equity impact assessment, like other forms of equity analysis, is a work in progress. But in a relatively short period of time, led by communities of color and their allies, it has drawn the interest of policymakers, policy implementers, and the public across a wide range of political jurisdictions and policy domains. It builds on earlier foundations of equity analysis—especially in law, the social sciences, philosophy, and management—and represents a break from past practice in a number of important and ambitious ways. 

We look forward to working with other institutions and community leaders, building on the basic typology and tackling the challenges we have outlined here. In our next report, we will offer an in-depth look at practices in equity assessment and how to make it a more effective tool for creating a more equitable and just society. Working together, we can sharpen our goals, methods, and—most importantly—the tangible impacts of a better way of governing. We believe that delivering more equitable decisionmaking and outcomes can help deliver justice to those who fight for and deserve it, and make a better and more fair nation for everyone, from the economy and environment to everyday well-being. It is in the nature of real democracy that our fortunes are linked. 

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  • Acknowledgements and disclosures

    Support from the Robin Hood Foundation, New York’s largest povertyfighting philanthropy, made this project possible. In addition, we are grateful to the following for helpful feedback on an earlier draft: Cathy Albisa, Fatimah Al-Khaldi, Rekha Balu, MarySue Barrett, Tonantzin Carmona, Grieve Chelwa, Karilyn Crockett, Darrick Hamilton, Makada Henry-Nickie, Josh Kirschenbaum, Amy Liu, Brandon McKoy, Julie Nelson, Manuel Pastor, Andre Perry, Chansi Powell, Elizabeth Reynoso, J. Phillip Thompson, and Clarence Wardell. 

  • Footnotes
    1. The Equity Scoring Initiative is part of a larger effort by PolicyLink and its partners to create an anti-racist federal government, with tools, recommendations, and other supports for the executive and legislative branches, while promoting equity by gender, geography, income, education, and other dimensions as well.
    2. Throughout the brief, we focus on equity innovations in U.S. governance. Participatory assessment itself, and centering such assessment on equity, has long been employed in traditions such as participatory action research. It has been used in the U.S. and much more widely used in the global South, often by nongovernmental institutions to inform the design and implementation of government programs.