As part of the Association of American Medical Colleges' Multisector Partner Group, Moms Clean Air Force offered input on and endorsed this letter.
Date: May 17, 2024
To: Cherie Klein
The Office of Management and Budget Executive Office of the President
725 17th Street, NW
Washington, DC 20503
Re: Methods and Leading Practices for Advancing Public Participation and Community Engagement With the Federal Government, Document Number: 2024-05882 (88 FR 19885)
The AAMC Center for Health Justice (Center) appreciate the opportunity to provide comments on the White House Office of Management and Budget’s (OMB) efforts to develop a government-wide framework for public participation and community engagement.
The Association of American Medical Colleges (AAMC) is a nonprofit association dedicated to improving the health of people everywhere through medical education, health care, medical research, and community collaborations. Its members are all 158 U.S. medical schools accredited by the Liaison Committee on Medical Education; 13 accredited Canadian medical schools; approximately 400 academic health systems and teaching hospitals, including Department of Veterans Affairs medical centers; and more than 70 academic societies. Through these institutions and organizations, the AAMC leads and serves America’s medical schools, academic health systems and teaching hospitals, and the millions of individuals across academic medicine, including more than 193,000 full-time faculty members, 96,000 medical students, 153,000 resident physicians, and 60,000 graduate students and postdoctoral researchers in the biomedical sciences. Following a 2022 merger, the Alliance of Academic Health Centers and the Alliance of Academic Health Centers International broadened participation in the AAMC by U.S. and international academic health centers.
The goal of the Center, founded in 2021, is for all communities to have an opportunity to thrive — a goal that reaches well beyond medical care. Achieving health equity means addressing the common roots of health, social, and economic injustices and implementing policies and practices that are explicitly oriented toward creating genuine opportunity for health. The Center for Health Justice partners with public health and community-based organizations, government and health care entities, the private sector, community leaders, and community members to build a case for health justice through research, analysis, and expertise. For more information, visit www.aamchealthjustice.org.
I. General Comments on the Goals and Purpose of the Framework
The Center commends OMB for its proactive steps to broaden and diversify avenues for public engagement in governmental decision-making. We also appreciate that one of the goals of this endeavor is to include perspectives from individuals and organizations connected to historic and contemporary injustices and inequities. Notably, in the request for information (RFI), OMB highlights a growing body of research demonstrating public demand for increased transparency and responsiveness from the government.1 It also cites evidence correlating the utilization of public feedback on government programs with an increase in trust.2
Community engagement is at the heart of the Center’s mission, serving as a fundamental component of our research, policy, and programmatic activities. Consistent with this ethos, the OMB’s definition of “community engagement” and “public participation” recognizes the importance for agency actions to “build trust […], long-term, and two-way relationships with all communities.” We concur and firmly believe that common guidelines, best practices, and government initiatives that promote community engagement should be rooted in trust, respect, and a shared vision. It is also essential that these actions are collectively developed with the community to ensure their effectiveness, relevance, and sustainability.
As one example of how the Center embodies these principles, we disseminated this RFI to our health equity community, comprising over 1,600 members (Collaborative for Health Equity: Act, Research, Generate Evidence (“AAMC CHARGE”),3 as well as the Center’s Multisector Partner Group (MPG) which plays a pivotal role in shaping the strategy and agenda of the Center.4 We also collected input from these groups on three specific questions in the RFI and those recommendations are incorporated and sometimes quoted in the comments below. Notably, many members of the MPG share our support for the OMB’s effort to build a community engagement framework and some may be submitting independent responses to the RFI. To learn more about the members of the MPG, visit www.aamchealthjustice.org/multisector-partner-group.
II. Public Engagement with the Federal Government
The OMB has solicited input on methods the government can employ to facilitate public participation in decision-making processes. The responses from the community to the Center regarding this RFI predominately focused on two themes: fostering meaningful engagement with diverse populations and innovative processes for engagement.
Fostering Meaningful Engagement with Diverse Populations
*Definition of Meaningful Engagement
In the RFI, OMB references “meaningful participation” and effective involvement to characterize public engagement in decision-making processes. However, unlike its definitions for terms like “public participation” and “community engagement” (as outlined in Section II of the RFI), the OMB does not offer clear definitions or additional context for these terms.
Several community respondents underscored the importance for OMB to explore methods to “authentically” or meaningfully engage communities. Notably, the Environmental Protection Agency (EPA) is actively considering strategies through its recent RFI on its draft Meaningful Involvement Policy which will replace the 2003 policy upon finalization. Both the 2003 and draft policy provide robust guidance on how to meaningfully engage communities. However, the proposed policy includes a new Public Participation Model, including specific steps the agency can take to ensure effective public engagement.5 We recommend OMB leverage the EPA’s extensive research and feedback it received through the public comment process, which included responses from state-based agencies, community-based committees, community organizations, and others.
*Building Public Trust
Community responses to the Center also highlighted the need for OMB and agencies implementing any new framework to develop resources (e.g., toolkits, guiding principles, educational resources) to build and uphold trust, accountability, and transparency. In 2021, the Center launched the Principles of Trustworthiness Toolkit6, co-created with community members from seven geographies across the U.S., which provides guidance on how to build authentic, long-term community partnerships. To apply and evaluate these Principles, we launched the Principles of Trustworthiness Toolkit Pilot Project and have awarded four multisector community partnerships funds to formally use the Toolkit and contribute to its evaluation over one year. We believe the toolkit could be immediately integrated with OMB’s community engagement framework, better ensuring that agencies authentically partner with communities and build trust with members of those communities. The Center would be more than happy to work with the OMB to incorporate the principles and corresponding toolkit into the public engagement framework.
Innovative Processes for Engagement
*Development of a Public Community Engagement Dashboard
Substantial activity, discourse, and community collaboration occurs in online forums and web-based platforms. The OMB should explore the development of a public-facing community engagement website. This platform could feature important announcements and provide a concise overview of opportunities for public comment on governmental initiatives such as proposed guidance or regulations. While such a platform would improve access to government information, particularly regarding opportunities offered through the government’s formal notice and comment process, OMB must also account for the limitations of web-based platforms. Therefore, if OMB decides to pursue an online platform to help promote this tremendous effort, we also recommend prioritizing accessibility and user-friendliness to ensure inclusivity.
*Utility and Accessibility of Information
As the OMB develops the public participation framework, it is imperative to ensure accessibility for individuals with disabilities and those with low literacy levels or language barriers. This necessitates the creation of communications in multiple languages, alternative communication formats such as video recordings, auxiliary aids, and easy to understand pamphlets. This effort would align with the Department of Health and Human Services Office of Civil Rights’ recent rule to strengthen prohibitions against discrimination on the basis of disability (as referenced in the Center’s comments to HHS7). Notably, this new rule also provides clear definitions of accessibility for websites and mobile applications, bringing them in alignment with the recently published Department of Justice standards and the Americans with Disabilities Act.
*Formal Notice and Comment Process
We also strongly urge OMB to explore methods for soliciting public input beyond the formal notice and comment process. Submitting public comments through the Federal Register or other online portals can limit the input received to comments from individuals already familiar with this process. To improve public comment mechanisms, OMB could consider the following:
- Input from Diverse Communities and Locales—Collect input in diverse settings and locales such as faith-based groups, barbershops, community centers, and libraries.
- Usability Considerations—Ensure RFIs and other supplementary materials and/or announcements are easy to download, print, and disseminate.
- Time of Public Listening Sessions—For agencies that are permitting oral feedback through public listening sessions in lieu of written comments, consideration should be given to the time the listening sessions are held. For instance, the public listening session for this RFI took place from 1:30-3:00pm ET, a timeframe that coincides with typical business hours. Scheduling listening sessions during work hours may significantly disadvantage individuals unable to participate due to work commitments or other obligations. We recommend OMB consider alternative timing for listening sessions (e.g., after 5pm, on weekends) to ensure broader accessibility and inclusivity. Standardization of this process across agencies would also be beneficial. Finally, consideration for the length of time typically allotted for public comment should be evaluated. Time slots could be shortened to 30 or 15 minutes to minimize waiting
- Design and Format—Re-evaluate the design, format, and usability of regulations.gov, where individuals/organizations submitting comments are required to navigate as directed by the Federal Register. The online instructions for submission, often requiring the use of a corresponding Docket ID, are not user friendly or intuitive, posing submission challenges. We appreciate user friendly platforms that enhance accessibility, helping to broaden the reach and participation in federal initiatives. One example of this is the website for this RFI at www.performance.gov.
III. Broadening Diversity and Reach
The OMB also requested comments on methods to engage a wider and more diverse spectrum of individuals and groups in government activities or opportunities, particularly those who may typically be overlooked. The following recommendations encapsulate the fundamental themes the Center heard from the community:
*Mechanism for Community Engagement
A successful framework for engagement must also include a process for community feedback through workgroups and advisory committees. This should apply to policies, regulations, programs, operations, and activities and should extend throughout the lifecycle of the government activity, from inception to implementation/completion. When feasible, there ought to be compensation for the time and advice provided.
As we heard from a community member. in furtherance of ensuring diverse input, the government should also establish local offices and/or programs that are “staffed by people with lived experience in historically marginalized communities, who go to, participate in, and listen to community issues and concerns, and help identify community priorities and strengths. Summaries of these reports and observations should be shared with and approved by the communities engaged and become incorporated into agency decision making processes.”
*Diverse Partnerships and Collaborations
The OMB should develop alliances with youth-based groups, Historically Black Colleges and Universities (HCBUs), academic medical centers, community-based organizations, and other entities capable of broadening the government’s outreach to diverse networks and communities.
As one community member noted, “[o]ne of the most important - and frequently most difficult - parts of engagement is connecting the organizations and agencies that need public engagement with members of the public who have relevant experience to share. Too often engagement opportunities are shared only in small professional circles or on wonky government websites, with little or no effort to get the word out beyond that echo chamber.”
*Data Collection and Narratives
Extraordinary efforts are currently underway across agencies to develop Agency Action Plans on Race and Ethnicity Data as required by OMB’s recent updates to its Statistical Policy Directive No. 15 (SPD 15). As agencies progress in implementing these updated standards with OMB’s support, we recommend OMB consider how the government’s new community engagement framework could further inform or augment these initiatives (see the Center’s comments to OMB on the revisions to SPD 158).
We also recommend the incorporation of additional forms of data outside of data currently collected such as personal narratives and lived experiences to inform decision-making. Personal stories offer unique insights into the real-world impact of policies and government programs, helping to elevate traditional data collection methods to include a more holistic and nuanced perspective of community needs (see AAMC Center for Health Justice environmental justice storytelling campaign, Community Voices for Action: Harnessing the Power of Environmental Justice Storytelling9).
*Strategies for Equitable Grantmaking
As stated in the AAMC’s comments to OMB in response to the RFI on Methods and Leading Practices for Advancing Equity and Support for Underserved Communities Through Government we would like to reiterate this recommendation: “[c]onsideration should be given to factors that limit the pool of potential grantees, including broadband and telecom infrastructure issues impacting access to resources and funding opportunities, especially for rural and low-income areas (i.e., the digital divide). To increase accessibility for those communities and enact greater equity in grantmaking practices, agencies should assess constraints on current grant application systems, relying, in part, on community insight to help identify areas for improvement. Agencies should also ensure the utility and accessibility of information for people with disabilities, low literacy, and/or language barriers which may require the incorporation of alterative communication formats such as auxiliary aids or video capabilities.”10
IV. Implementation Considerations
It is worth nothing that OMB references over 10 Executive Orders and Memorandums in the RFI which “require agencies to develop better mechanisms to receive direct feedback from and engage with the people, organizations, and communities served by the Federal Government.” In future updates on the public engagement framework, it would be beneficial for OMB to communicate its efforts to integrate
existing guidance and clarify how specific elements of the Framework align with each respective directive (where applicable). In the interest of accountability, we also recommend OMB integrate evidence-based mechanisms for reviewing the design and development of the community engagement plan and these mechanism and metrics must be co-developed with the community.
The AAMC Center for Health Justice has developed extensive relationships across various sectors, including trusted partnerships with individuals, organizations and community leaders who are deeply committed to advancing health equity and social justice in partnership with the federal government. As evident throughout these comments, we strongly believe that community wisdom should guide our collective initiative toward creating lasting solutions that address the diverse needs of all individuals and communities. We value the opportunity to contribute to such a significant initiative and are grateful that we are able to amplify the expertise of the Center’s community.
For questions about these comments or if there is an interest in learning more about how the OMB might use the Center’s Principles of Trustworthiness, please contact me or my colleague Daria Grayer, MA, JD, Director of Policy and Regulations (dgrayer@aamc.org).
Philip M. Alberti, PhD
Founding Director, AAMC Center for Health Justice Senior Director, Health Equity Research and Policy
cc: David J. Skorton, MD, AAMC President and Chief Executive Officer Heather Pierce, JD, MPH, AAMC Acting Chief Scientific Officer
1 89 Fed. Reg. 19885
2 Id.
3 For information about CHARGE, visit: https://www.aamchealthjustice.org/get-involved/aamc-charge.
4 For information about the current members of the AAMC’s Multisector Partner Group, visit: https://www.aamchealthjustice.org/multisector-partner-group. “This group from diverse backgrounds and sectors — including and beyond health care and academic medicine — have been selected to serve three-year terms. The group will use their expertise and leadership to contribute to the strategy and agenda of the Center for Health Justice, and to advance its mission to build cross-sector partnerships that address the complex constellation of social and political factors that contribute to community health and health inequities.” Id.
5 Environmental Protection Agency Draft Meaningful Involvement Policy, https://www.epa.gov/system/files/documents/2023-12/final_meaningful-involvement- policy_eams_11.7.2023_508.pdf (Accessed May 13, 2024)
6 AAMC Center for Health Justice, Principles of Trustworthiness, https://www.aamchealthjustice.org/our- work/trustworthiness/trustworthiness-toolkit.
7 AAMC Center for Health Justice letter to HHS on proposed updates to Section 504 of the Rehabilitation Act, https://www.aamc.org/media/71091/download?attachment (November 2023).
8 AAMC Center for Health Justice Comments on Proposed OMB Statistical Standard 15 https://www.aamc.org/media/66246/download?attachment (April 2023).
9 AAMC Center for Health Justice, Environmental Justice Storytelling Campaign https://www.aamchealthjustice.org/our-work/environmental-justice/storytelling (accessed May 14, 2024) 10 AAMC Comments on Methods on Advancing Equity across the Federal government, https://www.aamc.org/media/55326/download?attachment (July 2021).