Dear Office of Science and Technology Policy:
The Southern Economic Advancement Project (SEAP) is submitting comments regarding Federal Register document 87 FR 54269 – Request for Information on Equitable Data Engagement and Accountability by the Office of Science and Technology Policy (OSTP). We appreciate that OSTP and the Subcommittee on Equitable Data are interested in how to collaborate with community groups on the production of equitable data. These comments focus on how to engage with and support community groups regarding their data needs.
SEAP is a public policy, and technical assistance organization focused on the 12-state Southern region. The South suffers some of the greatest economic disparities, disproportionately due to the high concentrations of vulnerable populations, rural areas lacking healthcare access, and the brittle nature of public infrastructures for health, social welfare, and economic security.
SEAP partners with dozens of organizations, from small nonprofits to state and federal government agencies, to tackle these challenges. Our partners frequently look to us for up-to-date data on these issues. Responding to this need, we utilize existing and create or curate new datasets. We develop data resources with three key principles – awareness, accessibility, and representation. The quality and usefulness of any data, most importantly, depends upon accurate representation. Based on SEAP’s experience in the South, we offer the following comments.
AN EXAMPLE OF SUCCESSFUL COLLABORATION
The American Rescue Plan Act (ARPA) is an example of successful collaboration between the Federal government, local communities, and organizations like SEAP. Shortly after the legislation was signed into law in March 2021, SEAP received numerous assistance requests from local governments in understanding the legislation and learning how other local governments were utilizing the funds. Responding to this need, we work as a bridge, elevating questions up to the US Department of Treasury and subsequently distributing information throughout the region.
SEAP created a suite of data resources utilizing Federal data and curated data that was missing in the ARPA conversation. We have dashboards to help local leaders understand their existing populations (Census Bureau data), where their communities felt ARPA funds would be best spent (SEAP survey data), and how ARPA funds are allocated at the local level (SEAP-collected data from local government websites). The bridgework with Treasury has led to national recognition of SEAP’s work, including participation in a Pandemic Response Accountability Committee roundtable. This collaboration is successful because communication to our Federal partners and throughout the South is open and frequent; no question goes unanswered and there is a dedication to consistently updating data and resources.
INCREASE OPPORTUNITIES FOR COMMUNITY-BASED ORGANIZATIONS
There are a variety of opportunities to hold government accountable by increasing the opportunities to use data through data formats and feedback mechanisms. SEAP recommends the following:
- Make the resources public and in easily accessible formats, like spreadsheets and interactive images, that can be downloaded. PDFs and other documents that are difficult to machine read and parse provide limited accessibility.
- Offer live trainings and then have those available as bookmarked videos for search ease, so people can reference how to use data for accountability. A live training also offers an opportunity for a real-time conversation to quickly respond to questions. The corresponding video posted on an Agency’s webpage creates an additional resource that people can access as needed.
- Create a public reporting mechanism for flagging issues – like the “reporting waste, fraud, and abuse” on pandemicoversight.gov or the Count Question Resolution program at the Census Bureau. This shows that government is invested in making data resources better and also gives the public an idea of how quickly it takes to resolve issues.
- Gain understanding of how people utilize data by surveying end users and community groups. Asking who folks go to with questions or data needs will indicate the community data leaders.
MAKING DATA MORE ACCESSIBLE
In addition to public resources and training opportunities, ensuring this content is widely accessible is essential for reaching all Americans.
One significant thing to consider is the infrastructure where data is made available as well as where it is consumed. Understandably, many datasets are available in digital formats; however, the reliability of internet access is not equal throughout the country. In addition, the devices used to access data vary. An analog support system, such as a phone number, where community groups and other members of the public can request data could fill those infrastructure gaps.
Another significant, and far too overlooked, accessibility issue is developing data resources for the multitude of audiences that need access to it. One piece of that is creating data resources in non-English languages, with specific attention paid to ensuring those represented in the data understand the data. For example, Georgia has a small Haitian-speaking population. If there is data available that represents that community, it should be available in Haitian.
Developing resources with visual and audio support is important. Visual cues such as alt-text and image descriptions provide useful context for people with difficulties viewing images. Enabling closed captioning for videos aids people with auditory challenges. Providing sign language during presentations and transcripts after presentations also provides auditory support. Similarly, developing resources for people with different levels of cognitive abilities allows for additional accessibility and use of data.
Providing data in consistent structures and formats, across the Federal datasets, ensures that data can be compared and utilized for many purposes. Supporting documentations such as data dictionaries and how-to guides are useful for understanding Federal data. Finally, including information such as frequency of data updates, contact person, and any other support like working groups is essential for data use. SEAP is happy to engage in more depth on any of these topics.
The Southern Economic Advancement Project