Public Comments | Inequality and Poverty

EPI comments on OMB’s methods and leading practices for advancing equity and support for underserved communities

Submitted via

Shalanda Young
Acting Director, Office of Management and Budget
725 17th St., NW
Washington, DC 20503

Re: Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government

Dear Ms. Young,

The Economic Policy Institute (EPI) is a nonprofit, nonpartisan think tank created in 1986 to include the needs of low- and middle-income workers in economic policy discussions. EPI conducts research and analysis on the economic status of working America, proposes public policies that protect and improve the economic conditions of low- and middle-income workers, and assesses policies with respect to how well they further those goals. In 2008, EPI established the Program on Race, Ethnicity and the Economy (PREE) to bolster the organization’s mission through a focused and integrated approach to exploring how race, ethnicity, gender and class intersect to uniquely affect economic outcomes. EPI submits these comments on the Office of Management and Budget (OMB) request for information on “Methods and Leading Practices for Advancing Equity and Support for Underserved Communities.” The comments are most relevant to the following areas: 1. Equity Assessments and Strategies and 2. Barrier and Burdern Reduction.

EPI acknowledges the significance of the Biden administration’s stated commitment to advancing racial equity. The Biden administration has promised to assess whether there needs to be structural changes across federal agencies and in the implementation of federal policy, such that they no longer bar people of color and members of underserved communities from benefitting from those policies and those agencies’ work. To that end the administration has committed to bolstering its data infrastructure such that instances of disparate treatment can be better monitored and documented, as well as partnering with organizations across the country who have specialized in engagement with underserved communities to better carry out the Order. These initiatives represent important steps toward the stated goal of “advancing racial equity and support for underserved communities”.

EPI also recognizes that the vision of racial equity put forward by the Executive Order is limited in scope when compared to the depth of racial disparities present in the United States. The EO has taken up a definition of equity that equates it with fairness and impartial treatment, specifically with respect to access to federal programs and participation in federal contracting and procurement. While these goals are important steps towards racial equity, the narrow vision of equity they represent leaves several domains of racial inequityiii unaddressed.

A more expansive vision of racial equity would also have racial justice — the redress of past exclusion and injustice — as a major component. It would further seek to address the root causes of racial disparities that lead to underserved communities’ greater need for federal programs and benefits which are largely focused on poverty reduction. In other words, the ultimate goal of the administration’s focus on racial equity must be to minimize, if not eliminate, racial disparities in economic outcomes. Such a vision would entail not just removing barriers towards participation in existing federal programs but would commit to the further development of those programs and/or establishing new federal policies and programs to address the root causes of racial economic inequality.

As a test case for applying this expanded view of racial equity, consider the racial wealth gap. According to the 2019 Survey of Consumer Finances, the median white family has 8 times the wealth of the median Black family and 5 times the wealth of the median Latinx family. President Biden has publicly acknowledged the impact that the Tulsa Race Massacre and incidents like it across the country played in curtailing Black Americans’ prospects for building and maintaining intergenerational wealthiii. The federal government itself played a role in allowing the racial wealth gap to continue to expand across the 20th century through a lack of consistent regulation in the housing market, disinvestment in Black communities, as well as poorly implemented federal policy that did not properly account for its effect on Black communities (i.e., the federal highway systems near erasure of some communities’ opportunities for growth)iv. These structural barriers hindered the effectiveness of any individual efforts to improve one’s economic standing. As a result, racial disparities in wealth, income, employment, and wages persist despite greater educational attainment among Black Americans. greater educational attainment among Black Americansv.

The racial wealth gap that has emerged because of these historical events and failures of federal policy will require more than granting disadvantaged groups unimpeded access to opportunities for building wealth moving forward. It will require redress of past harm done to Black American families (e.g., through direct wealth transfers). While the Biden administration has put forth proposals for addressing the racial wealth gap, including steps to expand homeownership and provide student debt relief, investment in expanded data collection with regards to wealth must also be a priority for evaluating the effectiveness of those proposals as well as others. Currently, the Survey of Consumer Finances is the most detailed collection of data on family assets, debts and net worth. Expanding the scope of this survey would allow for more detailed analysis of the full wealth distribution (including the top 1%) as well as intersections with race, ancestry, gender and place. This expanded data collection would also be an important resource for any future studies of reparations for Black Americans.

The existing Executive Order thus marks a step on a much a lengthier path towards a full conception of racial equity, and we look forward to seeing the Biden administration take additional steps along that path in the future. As the administration seeks to assess existing federal programs and policies for poverty reduction to ensure that they meet the stated criteria of racial equity (i.e., fair and impartial access), they should also address instances where the features of said programs are not consistent with the programs’ stated goals. The history of federal policy in the United States is marked by instances where policies designed to be expansive have been watered down and saddled with features that limit their ability to help people.

For example, the fact that Social Security excluded domestic and agricultural workers (thus excluding most Black workers at the time) in its initial implementation is well-known, and the EO’s commitment to racial equity is designed to prevent such exclusions in current and future policy. However, both the low cap on taxable earnings for Social Security, as well as planned increases in the current full retirement age, limit the program’s progressivity and keep access to full benefits disproportionately away from groups of people with shorter life spans on average (Black and Native Americans in particular). While we understand that the Social Security Administration (SSA) ceased collection and reporting of race and ethnicity data when they transitioned to more “expedient and cost-efficient procedures”, the absence of this data limits our ability to understand how the nation’s most successful anti-poverty social insurance program can more equitably serve all people.

Removing barriers towards and expanding access to federal poverty prevention programs like SNAP and TANF falls under the current scope of the Executive Order, and these are necessary policies for the administration to pursue. The administration should also re-examine the fundamental limitations baked into TANF, namely its block-grant nature, that reflect the spirit of conciliation and deference to negative stereotypes about poor (mostly Black and brown) families that programs like AFDC were designed to supportvi. Further, given the immense benefit that expanded provision of SNAP brought to families throughout the pandemicvii, existing “normal” provision of SNAP should also be re-assessed to determine whether the loss in food security a return to normal would bring is consistent with the administrations stated goals and values.

A more comprehensive review of existing federal policy—one that goes beyond the goals of access-focused racial equity—would be a strong step forward towards reducing racial disparities and making the administration’s commitment to racial justice clear. Consistent collection of reliable data by which to evaluate economic outcomes and identify shortcomings in equitable access to federal programs is a necessary investment in pursuit of those goals. With regards to program participation, this involves the use of a uniform system for collecting, documenting, and categorizing racial and ethnic data across all federal agencies. Allowing data systems to “talk to each other” is also important in understanding how different demographic groups access and utilize the expansive web of federal programs, and not just individual programs.

Finally, these efforts must be accompanied by periodic evaluation of programs with respect to clearly defined racial equity goals for participation and economic outcomes. In addition to formal program evaluation methods, the administration must also work with community-based organizations that have established relationships of trust in marginalized communities to develop ways to receive direct feedback regarding the enrollment process, needlessly restrictive eligibility rules, burdensome reporting requirements, and preferred methods of benefit distribution.

The 2016 and 2020 elections exemplified how important presidential leadership is for setting the tone and course of the nation’s priorities and discourse on race. Still, the greatest threat to racial equity is the systems, structures and institutions that have perpetuated inequality despite significant changes in the law or changes in presidential leadership. An important key to seizing the opportunity to remedy and redress systemic racism involves finding ways to institutionalize efforts to advance racial equity that will survive beyond the Biden administration.

One of the things that works to the government’s advantage is the fact those employed in government agencies often remain across transitions in leadership. The administration must tap into this valuable resource and the extensive institutional knowledge they possess in a way that encourages a vested interest in the success of racial equity goals.


Valerie Wilson
Economist and Director of the Program on Race, Ethnicity and the Economy
Economic Policy Institute

Kyle Moore
Economist, Program on Race, Ethnicity and the Economy
Economic Policy Institute



i. Kilolo Kijakazi, Jonathan Schwabish, and Margaret Simms, Racial Inequities Will Grow Unless We Consciously Work to Eliminate Them, Urban Institute, July 1, 2020.    

ii. Valerie Wilson, “Inequities exposed: How COVID-19 widened racial inequities in education, health, and the workforce,” Testimony before the U.S. House of Representatives Committee on Education and Labor, Washington, D.C., June 22, 2020.

iii. Joe Biden, “Remarks by President Biden Commemorating the 100th Anniversary of the Tulsa Race Massacre,” Tulsa, Oklahoma, June 1, 2021.

iv. Johnny Miller, “Roads to Nowhere: How Infrastructure Built on American Inequality,” Guardian, February 21, 2018.

v. Janelle Jones, John Schmitt, and Valerie Wilson, 50 Years after the Kerner Commission African Americans are Better Off in Many Ways but Are Still Disadvantaged by Racial Inequality, Economic Policy Institute, February 26, 2018.

vi. Ali Safawi and Liz Schott, To Lessen Hardship, States Should Invest More TANF Dollars in Basic Assistance for Families, Center on Budget and Policy Priorities, January 12, 2021.

vii. U.S. Department of Agriculture, “USDA to Provide Critical Nutrition Assistance to 30M+ Kids Over the Summer” (press release), April 26, 2021.