Implementing the Evidence Act may require significant changes to 3 areas of an organization: Policy, People & Technology. Image: Lila DK/Shutterstock.com
By: Carmen Robinson, ABSG Consulting Inc.Five years ago, the most comprehensive data governance law was passed in the U.S. On January 14, 2019, the “Foundations for Evidence-Based Policymaking Act of 2018,” also known as the “Evidence Act,” was passed into law.
The Evidence Act requires U.S. Government federal agencies to designate a non-political appointee as Chief Data Officer (CDO) to lead data governance and data management, and partner with agency Chief Information Officers (CIO) to protect and safeguard data.
The goals of the Evidence Act are laser-focused on creating the organizational infrastructure to leverage the power of data for the American people.
But five years into the journey, many agencies are only just beginning to implement many of the key provisions and requirements set forth by the law.
Why is the Evidence Act significant?
The Act mandates 24 federal agencies, previously grouped under the Chief Financial Officer Act (1990), take new measures to promote the use of data and evidence-building via 3 key provisions:
Provision 1: Advance Evidence-Building Activities
Under Title I of the Evidence Act, evidence is defined as “information produced as a result of statistical activities conducted for a statistical purpose.”
The Evidence Act requires federal agencies to designate three roles as key officials responsible for the implementation of the law: the Chief Data Officer, the Evaluation Officer, and the Statistical Official. Each is to play a critical role in advancing evidence-building activities, including but not limited to, increasing the availability and quality of data and evidence necessary to make informed decisions.
Provision 2: Develop and Maintain a Comprehensive Data Inventory
Title II of the Evidence Act requires federal agencies to maintain a comprehensive data inventory and publish open data, using standardized, machine-readable data formats. The Evidence Act also establishes agency CDOs as the key responsible party for managing agency data assets and creating governance policies to enable data sharing.
Provision 3: Make Data Available Without Sacrificing Confidentiality
The Evidence Act revises and reauthorizes the Confidential Information Protection and Statistical Efficiency Act of 2002 (CIPSEA) by adding additional safeguards and clarifying the criteria for Statistical Agencies.
Although over 125 federal agencies or units engage in statistical activities, most official federal statistics are produced by 13 agencies that have statistical work as their principal mission.
These 13 agencies play a significant role in strengthening public trust and supplying data that supports global research. The Statistical Agencies often aggregate and de-identify large volumes of data collected from the American people.
Key Steps to Implementing the Evidence Act
Data has become a central part of almost every aspect of modern-day life and was the likely catalyst for the establishment of the Evidence Act. As agencies around the federal government seek to establish a central framework for how data can be safely and responsibly managed, protected, and shared, they should each consider the human and financial capital required to implement such a massive organizational change.
Although the Evidence Act is certainly data-driven, the reality is that people are at the heart of its implementation. To successfully implement the Act, organizations should change their ways of working and build the infrastructure required to generate more meaningful evidence, based on reliable data.
In short, implementing the Evidence Act may require significant changes to 3 areas of an organization: Policy, People & Technology.
People
Since implementing the Evidence Act ultimately requires the adoption of a change management process, people are integral to the effort. There is no organizational change without the effort and intention of people.
When thinking of the people, leaders should minimally consider:
– How are we going to resource this?
– Are there people already doing similar tasks that can be elevated to lead parts of the implementation?
– Who are the groups who are likely to be most impacted?
While the Evidence Act requires a Chief Data Officer, an Evaluation Officer and a Statistical Officer to be appointed – who are accountable and responsible for an organization’s data and the safe management of it – this is a multi-channelled and multi-disciplinary process that will touch the whole organization. Change will generally be required, and people will be fundamental to its successful implementation. Demonstrating the benefits of these changes to everyone involved is therefore vital.
Policy
People will enact and technology will enable, but it is policy that will set the course of implementing the Evidence Act.
Organizations should invest time, energy, and effort at this stage to help meet the requirements made of them through the Act.
Policies are just words on the page if they are not crafted with the needs and constraints of the stakeholders in mind.
Lasting policy change requires thoughtful communication with stakeholders that will be involved in every step of the data journey – both internally and externally – to find out what their needs are, to understand them, and to measure them. It’s effectively creating a shopping list of policy needs. In tandem with this, an organization should also consider running a gap analysis.
In addition to internal and external stakeholders, organizations should consider the impact of related legislation, such as the Paperwork Reduction Act and Open Government Data Act. And, where feasible, develop policies that reinforce implementation of all related laws.
The ultimate goal is to establish policy frameworks that will become absorbed into the day-to-day operations of the organization. So, understanding where you are and what you have in place alongside any gaps that exist is crucial – yet is no small task.
Technology
Most organizations will rely on one or more technical solutions to assist with many of the requisite steps of good data governance, such as cataloguing, tagging metadata, and ensuring quality. Since most of the decision makers and data consumers are accessing data on a digital platform, it makes sense to implement digital controls.
However, rolling out data governance and implementing the Evidence Act typically works best when technology is a supporting cast member and not the star of the show. Technical solutions should support people and processes. Technology can turn a burdensome, slow, and manual process into a quick and painless experience for the user, but it’s important to reinforce that buying software will not automate processes that don’t exist.
To prepare for this technology, an organization’s people and policies should be working in conjunction to establish workflows and processes that are well communicated and used throughout the organization. Technology can first be used to take over the most administrative tasks (workflow management, emails, populating tags, checking for nulls, completed forms, etc.) that cost people lots of time, but can be automated with great success. And it can be used to do many of the required quality checks, safeguarding measures, data delivery, and more.
Conclusion
For data governance professionals, the implementation of the Evidence Act offers a great opportunity to support federal agencies as they select tools, technologies, and staff to support their compliance and unleash the power of their data.
But this is both complex and challenging involving process, people, and technology. Organizations should understand where they are, what they need, how implementation will be delivered, and the impact this will have internally and externally.
In this article, Carmen Robinson, Senior Principal Consultant at ABSG Consulting Inc. (“ABS Consulting”), Global Government Sector – looks at the implications of the Evidence Act and the key principles of process, people, & technology that organizations need to address when looking to implement the requirements of the Act.
Carmen has over 15 years’ experience in data wrangling, data governance, and data risk processes and is part of a team from ABS Consulting helping government organizations manage and implement the Evidence Act.
Key Bills Advancing, but No Path to Avoid Shutdown Apparent
TSP Adds Detail to Upcoming Roth Conversion Feature
White House to Issue Rules on RIF, Disciplinary Policy Changes
DoD Announces Civilian Volunteer Detail in Support of Immigration Enforcement
See also,
How Do Age and Years of Service Impact My Federal Retirement
The Best Ages for Federal Employees to Retire
How to Challenge a Federal Reduction in Force (RIF) in 2025
Should I be Shooting for a $1M TSP Balance? Depends…
