Governance + Equity + Evidence = What Counts

Reprinted from AGA's Journal of Government Financial Management

Governance, equity, and evidence are essential pillars of accountability and the prudent use of resources. The rapid government response to the COVID-19 crisis led to an outlay of taxpayer monies in excess of $1 trillion.1 This historic level of federal funding demands emphasis on compliance measures to guard against fraud, waste, and abuse among award recipients. Oversight is non-negotiable. It must ensure accountability and transparency based on evidence and outcomes. At the same time, oversight can measure community impact and equity in the use of funds to see how they stack up to mandates in diversity, equity, inclusion, and accessibility (DEIA).


Governance, equity, and evidence are part of the Three Lines of Defense Model,2 developed by the Institute of Internal Auditors, to help organizations identify structures and processes to meet objectives and manage risk. As management receives updates on activities, funding, and projections, internal audits deliver independent assurance of their validity. The methodology is based on the following principles:

Governance — Consists of processes that facilitate accountability, actions and insurance

Example: The Pandemic Response Accountability Committee (PRAC)3 promotes transparency and independent oversight of funding disbursed as a result of COVID-19.

Governing Bodies — Provide resources for organizations to achieve objectives and adhere to regulatory and ethical requirements

Example: The U.S. Department of the Treasury (Treasury) and the U.S. Department of Housing and Urban Development collaborated on a how-to guideto help state and local organizations properly manage fiscal recovery funds used for affordable housing efforts.

Management and First and Second Line Players — Achieve organizational objectives and mitigate risk

Example: The Office of Management and Budget (OMG) published OMB M-20-21, Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus, which directed agencies to consider specific principles, such as mission achievement and using data and evidence to achieve program objectives.

Third Line Players — Deliver independent, objective, assurance of the adequacy and effectiveness of governance, advice, and reports of findings to management

Example: Government Accountability Office (GAO) Pandemic Oversight5 issues findings and reports.

Third Line Independence — Aligned to objectivity, authority, and credibility

Example: The U.S. Department of Homeland Security (DHS) Office of the Inspector General (OIG) report6 addressed inequities related to COVID-19 vaccination center locations.

Collaboration Across the Enterprise — Creates and protects value

Example: A collaborative study7 by the National Academy of Public Administration (NAPA) and the National Association of Counties on federal assistance and innovative counties examined the allowed uses and controls in federal fiscal assistance to counties during eh pandemic and innovative strategies in the use of pandemic relief funding. One innovation that emerged from the COVID-19 crisis was the PRAC's emergency rental assistance dashboard,8 which helped users navigate a program for assistance with rent and utility expenditures.



Through a 2021 executive order,9 the White House directed the federal government to advance an ambitious equity agenda. In response, more than 90 federal agencies established more than 300 specific strategies and commitments to address systemic barriers in national policies and programs that affect underserved communities.

The American Rescue Plan Act (ARPA) was intended to expedite funding in a crisis and distribute it equitably.10 ARPA appropriated $21 billion for emergency rental assistance to augment state and local housing funds, health care insurance, broadband service, and technology modernization with an eye toward equity11 as it attempted to remedy negative economic impacts that thwarted community plans for long-term pandemic recovery. For example, negative economic impact as characterized by Salt Lake County, Utah, was economic harm caused by the public health emergency among local workers, households, small businesses, and industries. The county addressed equity and helped people who were disproportionately affected by using ARPA funds to create the Workforce Inclusion and Successful Employment (WISE) program. WISE assists low-income county residents with a household income at or below 200% of federal poverty guidelines.12 Through a five-year pilot that evaluates equity and impact in workforce development, WISE aims to help its clientele find better jobs.

The equity provisions in Treasury's State and Local Fiscal Recovery Funds (SLRF) programs suggest goals and targets that prioritize economic and racial equity in project implementation. The SLFRF Equity and Outcomes Resource Guide also offers an equity assessment tool13 that requires fund users to: 

  • Leverage outcome measures
  • Analyze factors underlying inequity
  • Include voices of community representatives
  • Target resources and strategies to minimize burden and maximize access
  • Publish transparent program results.

The U.S. Conference of Mayors shared a case study14 on the City of Boston's use of ARPA funding. City leaders first collected and incorporated feedback from the community before creating a series of equity-focused programs with ARPA funds. The result is the Health Equity Now Plan for better public health and safety by the year 2030. The plan serves to guide municipal planning, resiliency, and mobility going forward.

Boston's effort shows that equity is a foundational element of even-handed investment in communities with varying levels of income and access. In the future, governments can utilize many equity-related frameworks, tools, and provisions instituted through ARPA funds to guide equitable spending in their communities. Making equity an essential part of program design and performance data will lead to evidence for accountability in the area of equity.


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1. “The Federal Response to COVID-10,” Nov. 30, 2022.
2. Institute of Internal Auditors. “The IIA’s Three Lines Model: An Update on the Three Lines of Defense,” July 2020.
4. Treasury. “Affordable Housing How-To Guide,” July 2022.
6. DHS. OIG-22-74, Sept. 28, 2022.
7. NAPA. Coronavirus Relief Fund: Review of Federal Fiscal Assistance and Innovative County Response Strategies, March 2021.
8. See Endnote 3.
9. Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government.
10. Yarmuth, Rep. John A. H.R.1319, American Rescue Plan Act of 2021, Library of Congress, Feb. 24, 2021.
11. White House. "Strategic Plan to Advance DEIA in the Federal Workforce," Nov. 23, 2021.
13. Treasury. SLFRF Equity and Outcomes Resource Guide, June 14, 2022. (See Equity Assessment Tool.)
14. U.S. Conference of Mayors. "Promoting Equity Through ARPA Implementation," June 3, 2022. 

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