There is an opportunity to further ensure public policies include evaluative thinking and practice. Should we take advantage of it? We—Courtney Bolinson and John Sherman, independent evaluators, Social Impact TIG chair and steering group member—firmly, say “yes.”
The opportunity: The federal Securities Exchange Commission (SEC) proposed rules to require publicly-traded companies (think about companies in mutual funds and your pension and 401k plans) to annually report climate-related information. Three areas of the SEC proposed rules require companies to:
- assess climate-related risks and their actual or likely material impacts on companies’ business, strategy, and outlook.
- assure the validity of their assessments.
- demonstrate how they are managing impacts.
Yet, the underlying evaluative thinking, practices and principles required to do each of these well is absent. For example, the proposed rules do not yet articulate:
- the needed competencies of third-party auditors, evaluators, or other measurement professionals that are to perform the assessment or assurances
- the importance of cultural competence in gathering impact and assessing data, and using impact results
- explicit reference to standards, such as the AEA-endorsed “Program Evaluation Standards”, that identify and define evaluation quality and guide evaluators, and which focus on five attributions of evaluation quality: utility, feasibility, propriety, accuracy, and accountability.
One more item: A key driver of the proposed rules is the definition of materiality (see item 1 above). In the eyes of the SEC, reasonable investors decide what is and is not material. They do so by having sufficient information from the companies and those impacted by the companies to decide if the companies have adequately considered those material impacts.
The SEC is silent on who the companies should include in determining and assessing materiality. In our evaluation world, community voices are critical to determining what to measure (i.e., what is material) and how to manage the results. Whether equitable, participatory, developmental, transformative, or indigenous-centered evaluation, community voices are central.
As preeminent evaluator and AEA member Deborah Rugg eloquently states, evaluation is a citizen’s right. We need to help ensure public policies include that right, adhere to AEA’s Guiding Principles especially Respect for People, and Common Good and Equity, and uphold the professional practice to “promote social justice and the public good.” The SEC proposed rules offer a critical opportunity for us to do so.
Want to explore this topic further and get involved? Consider joining the SIM TIG.
- AEA’s policy resources including the An Evaluation Roadmap for a More Effective Government (2019)
- SEC’s proposed disclosure rulemaking
- SEC’s sign-up for future rulemakings
This week, AEA365 is hosting Social Impact Measurement Week with our colleagues in the Social Impact Measurement Topical Interest Group. The contributions all this week to AEA365 come from our SIM TIG members. 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. The views and opinions expressed on the AEA365 blog are solely those of the original authors and other contributors. These views and opinions do not necessarily represent those of the American Evaluation Association, and/or any/all contributors to this site.e.