With the release of Executive Order 14091, “Furthering Advancing Racial Equity and Support for Underserved Communities Through The Federal Government,” the Biden administration has taken decisive new action to embed equitable decisionmaking and service delivery in the day-to-day practice of government. This latest executive order (EO) extends the mandate of Executive Order 13985, which called on agencies to create Equity Action Plans to assess obstacles to equity in their organizations.

The new EO requires agencies to formally establish equity teams led by senior designees reporting to the agency secretary and directs agencies to submit annual agency equity plans. The EO also tasks agency heads with integrating equity-advancing strategies across agency planning processes and seeking community input as plans are developed. These requirements aren’t merely additional tasks—they reflect principles of best-in-class organizational change management.

As the Domestic Policy Council (DPC) and the Office of Management and Budget (OMB) begin to implement the new EO, they can learn from and build on the first set of Equity Action Plans.

Our forthcoming analysis of those plans shows that large federal agencies charted paths toward the EO’s goals but hadn’t yet outlined detailed implementation plans. 

Analysts with Urban’s Office of Race and Equity Research reviewed 24 agencies’ action plans and developed a rubric evaluating how well equity plan elements addressed 14 domains, including drivers of inequity, program or policy changes to incorporate equity, and implementation planning. Here’s what we found.

Enacting different types of equity

We categorized agency plans based on type of equity promised or delivered:

• Procedural equity relates to the fairness of processes, often in terms of access to services.
• Distributional equity relates to resource allocation and procurement that responds to a history of unequal treatment and outcomes.
• Structural equity relates to policies and the design of systems to minimize obstacles and change incentives in ways that promote equity.

We found most plans issued in 2022 included at least one major proposed action for each type. But overall, action plans focused more on procedural than distributional or structural equity proposals, which we suspect is because the 2021 EO provided more guidance on procedural matters, such as eligibility, rather than measurement of outcomes resulting from changes in eligibility rules.

For example, the US Department of Housing and Urban Development (HUD) indicated it would track the number of Fair Housing Act complaints “received, processed, and closed,” as well as cases referred and processed. This is a key output.

However, were HUD to focus on specific actions for expanding access to Federal Housing Authority loans, which have allowed more Black households to access homeownership, it could evaluate outcomes as well—like a decrease in the racial wealth gap, as homeownership contributes to the generational transmission of wealth.

As the new EO is implemented, the DPC and OMB can support agencies in moving from changes in process (procedural equity) to system-level strategies that include reallocation of resources (distributional equity) and policy change (structural equity). Agencies could then move beyond activity outputs and specify desired outcomes (like closing the employment gap by a certain percentage).

And to achieve those outcomes, agencies will need to diagnose and understand the structures and incentives that allowed unfair access and treatment to persist—and then change those structures.

The most compelling plans we reviewed clearly named obstacles to accessing services and situated those barriers in history. The Environmental Protection Agency’s (EPA’s) plan acknowledges that for decades, the decisions of the EPA and other regulators and officials contributed to the disproportionate pollution burden on people of color and underserved communities. The plan’s action step is clearly aligned with the barrier it seeks to mitigate: “EPA will develop a comprehensive framework for considering cumulative impacts in relevant EPA decisions and operationalize that framework in EPA’s policies, programs, and activities.”

Scoring performance

To measure progress, the federal government already uses various forms of scoring and reporting, including the Government Performance and Results Act, which requires agencies to set targets for desired outcomes and describe how they will meet them. This approach could extend to ensure a focus on equity in outcomes. Agencies could evaluate whether they’ve achieved goals equitably and what resources and actions are necessary to demonstrate population-level change. 

Our analysis indicated that agency equity plans would benefit from a broader range of outcome metrics. The metrics specified in the plans don’t yet capture inequities or disproportionalities, such as quantifying the proportion of children who needed support services but hadn’t received them or how the proportion of successful applicants from a demographic group compares with the proportion of eligible applicants in that group. This could enable agencies to devise specific strategies or remedy programs to serve more people.

EOs as change management

No previous administration has undertaken a comprehensive all-of-government initiative to redress structural bias and discrimination. There will surely be debate among policymakers and governance experts on the extent EOs are a necessary complement to legislation, and whether EOs are the best instrument to comprehensively define and guide a cross-agency set of goals and actions.

Many systems and institutions were intentionally designed to disenfranchise, and undoing that damage requires system redesign. These EOs could provide a blueprint to reverse engineer systems to deliver inclusive outcomes for all.