Equipping the Evidence Ecosystem to Engage: New Expert Engagement Guides

By Nick Hart and Sara Stefanik

The Data Foundation's Center for Evidence Capacity published two new practitioner resources today: an Expert Engagement Guide on writing effective public comments on Notices of Proposed Rulemaking, and a companion Expert Engagement Guide on Information Collection Requests. A third Expert Engagement Guide, on System of Records Notices under the Privacy Act, will follow.

The Data Foundation's Expert Engagement Guides provide a practical resource to support the data and evidence community in its efforts to become more effective in the federal rulemaking and information collection processes that shape the data infrastructure we all depend on.

The Counterpart to Our Engagement Work

For years, the Data Foundation has worked to help federal agencies engage the public well. The Stakeholder Engagement Toolkit for Evidence Building, the Center for Evidence Capacity's sustained work on learning agendas and evaluation policy, our enablement in formulating the Federal Data Strategy in partnership with the White House Office of Management and Budget (OMB), our response to OMB's 2024 Request for Information on public participation and community engagement, and the resulting OMB Memorandum M-25-07 are all part of that effort. Good engagement requires technical capacity on the agency side: clear purpose, accessible formats, transparent decision-making, evaluation built in from the start.

Agency engagement is only half the equation. When agencies do open the door through a Federal Register notice, an Information Collection Request published on reginfo.gov, a System of Records Notice (SORN), or a Request for Information, the data and evidence community needs the capacity to engage back and to engage back well. "Well” here means with substance, sourcing, concrete proposals, and the technical fluency the federal data and evidence framework demands.

The two Expert Engagement Guides published by the Data Foundation are the productive counterpart to our ongoing and long-standing agency-engagement workstream. Where the Stakeholder Engagement Toolkit equips agencies to engage the public well, the Expert Engagement Guides equip the data and evidence community to engage agencies effectively.

What's in the Guides

Both guides are calibrated for the professional community the Data Foundation works alongside: knowledge brokers, researchers, data users in industry and academia, open data advocates, statisticians, evaluators, evidence-building practitioners, federal data leaders, fellow nonprofits, and the organizations that depend on, produce, or comply with federal data. The guides are not civics primers, and instead assume working familiarity with the federal data and evidence landscape. The guides are intended and designed to make the comments produced from within that ecosystem more effective, not more numerous. A key principle that the Data Foundation stresses in public commenting processes: Volume is not the standard; substance is.

• The NPRM guide addresses comments on substantive rulemakings under the Administrative Procedure Act (APA). It works through the Information Quality Act, the Foundations for Evidence-Based Policymaking Act, the OPEN Government Data Act, and the recommendations of the Administrative Conference of the United States (ACUS) as the operating frameworks for credible and useful comments. The NPRM guide covers how to build evaluation and data collection expectations into the record, how to align comments with the Data Foundation's policy priorities, and how to coordinate with the Data Foundation when we are already engaged. 
• The ICR guide addresses comments on Information Collection Requests (ICRs) under the Paperwork Reduction Act (PRA), the legal mechanism through which federal forms, survey, application, and reporting requirements are approved for domestic data. The ICR guide works through the four PRA statutory criteria (practical utility, burden estimate accuracy, quality and clarity, and burden minimization) as the working lens for any ICR comment. It explains the current two-window comment process (60 days to the agency, 30 days to OIRA), how to use the three-year renewal cycle for high-leverage influence, and how to deploy Standard Business Reporting (SBR) principles, structured machine-readable formats, and reuse of existing federal administrative and statistical data to drive burden reduction. Three recent Data Foundation ICR comments are discussed as examples for the National Science Foundation Standard Application Process Portal, the Department of Education National Assessment of Educational Progress, and the Department of Health and Human Services National Directory of New Hires.

Both guides include sections on coordinating with the Data Foundation when we are already preparing a community comment, and on what we look for in the central comments we file on behalf of the broader ecosystem or our Data Coalition members.

Why This Matters Now

The federal data and evidence infrastructure is at an inflection point. The Evidence Act passed its seven-year anniversary in 2026. The OPEN Government Data Act's DCAT-US 3.0 metadata compliance deadline arrives in September 2026. The Public Trust Rule on the fundamental responsibilities of recognized statistical agencies is one year into implementation. The Financial Data Transparency Act is moving from joint rulemaking into implementation. Chief Data Officers, Evaluation Officers, and federal statistical leadership are doing more, with less, under more scrutiny than at any point since the modern federal data framework was established.

In this environment, expert comments matter. The comments build a record that agencies respond to. The comments preserve standing for judicial review, when it is needed. Comments can shape OMB and OIRA decisions on information collection, and become the citable artifacts that inform the next round of policy. Most importantly, the comments signal to agencies that the data and evidence community is paying attention substantively, technically, and with continuity across administrations.

We want every comment our members, partners, and the broader ecosystem file to land with the weight it deserves. The Expert Engagement Guides are one of the ways the Center for Evidence Capacity is providing support. 

Where to Find Them

Both Expert Engagement Guides are available at datafoundation.org. Members of the Data Coalition can also access them through member channels, and we welcome coordination on active comment opportunities at info@datafoundation.org.

For Evidence Act resources and implementation tools that complement these guides, visit EvidenceAct.org.

The forthcoming SORN guide will join the set in the coming months as part of the Center for Evidence Capacity's continued work on modern privacy frameworks and CIPSEA implementation.

NICK HART is the President and CEO of the Data Foundation. 

SARA STEFANIK is the Director of the Data Foundation’s Center for Evidence Capacity. 

The Data Foundation's Expert Engagement Guides are produced by the Center for Evidence Capacity. The Data Foundation is a nonpartisan nonprofit organization that serves as the enduring policy nexus for federal data and evidence across administrations.