EPTF Week: How Evaluators’ Responses to Federal Register Notices Can be Most Useful to the Government by Demetra Smith Nightingale

Hi, I’m Demetra Smith Nightingale currently at  the Urban Institute and previously at the US Department of Labor. I want to take the opportunity to briefly describe how responding to information government publishes in the Federal Register can be useful.

There are many different types of notices posted for public comment in the Federal Register, such as notices of proposed rules or termination of rules, proposed information collection requests for program reporting requirements, draft data collection instruments and data collection requests for evaluation projects, statistical survey information requests, or broader requests for information (RFIs) asking for input on specific or general policy issues.  Comments on RFIs, and not just on study-specific notices, provide an important mechanism for evaluators and researchers to provide input into issues on which the Federal government may be considering action.

A recent notice from the Office of Information and Regulatory Affairs at the Office of Management and Budget (OMB) is an example of an RFI with direct implications for the evaluation community.  The notice regards combining data sets for statistical and research purposes, and requests comments on: “(1) Current and emerging techniques for linking and analyzing combined data; (2) on-going research on methods to describe the quality of statistical products that result from these techniques; (3) computational frameworks and systems for conducting such work; (4) privacy or confidentiality issues that may arise from combining such data; and (5) suggestions for additional research in those or related areas.”

This is a case where the request stems from efforts by the Chief Statistician of the United States to establish priorities and coordinate research efforts across the Federal Statistical System to focus on improving federal statistics, including a priority to use new techniques and methodologies based on combining data from multiple sources. Future decisions the Federal government makes will have direct implications for data that evaluators might want to utilize for their projects. AEA provided formal comments and feedback to the RFI on behalf of the membership.

Hot Tips: Evaluator comments to this or any other relevant notice will be most useful to Federal agencies if a few key points are kept in mind:

  • Comments should directly address the topic at hand. Comments unrelated to the question under consideration will not be considered – this is not an opportunity to comment on unrelated matters (though many people do!).
  • Comments should be as clear and concise as possible. Federal staff often have very limited time to review and consider comments, so try to make your point clearly and concretely.
  • Comments are most helpful when you can provide specific examples or evidence of the effects that a proposed rule, grant notice, or data collection will have. It is more difficult for agencies to consider comments that are based only on your opinions or theoretical outcomes.
  • Be judicious when deciding whether to comment.  Provide comment when you have something worth saying.  That is, don’t become that person that comments on anything and everything just because you can.

The American Evaluation Association is celebrating AEA’s Evaluation Policy Task Force (EPTF) week. The contributions all this week to aea365 come from members of AEA’s EPTF. Do you have questions, concerns, kudos, or content to extend this aea365 contribution? Please add them in the comments section for this post on the aea365 webpage so that we may enrich our community of practice. Would you like to submit an aea365 Tip? Please send a note of interest to aea365@eval.org. aea365 is sponsored by the American Evaluation Association and provides a Tip-a-Day by and for evaluators.

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