A look at the evidence-based reform path DOGE did not take

Terry Gerton Your recent article is really, I think, one of the early retrospective looks at the first six months of the Department of Government Efficiency and its reform efforts. What prompted you to write this article?

Ally Coll I’ve been studying this phenomenon of evidence-based policymaking for a while now, and I had been steeped in the framework before the election and before the Department of Government Efficiency was even created. And as I saw DOGE go about, you know, some of its early reform efforts, I always had in the back of my mind evidence-based policymaking as a possible avenue for government reform. And so I was watching over the first few months to see the extent to which it might or might not be incorporating that kind of a framework. And as I saw it develop, I recognized that there were many, many ways in which I did not think it was adhering to an evidence-based approach, and that bringing some awareness for other people about the existence of this approach might give people a new way to think about what DOGE was doing and whether it’s being as effective as it could be at achieving its goals.

Terry Gerton Well, there is a statutory basis for evidence-based policymaking. Tell us what you observed here and why you’re making the contention that DOGE has actually moved away from evidence-based policymaking?

Ally Coll So evidence-based policymaking in the federal government has been on the rise really since I’d say the 1980s, beginning with cost-benefit analysis that was initiated under the Reagan administration, and eventually it evolved to congressional language actually requiring agencies to engage in an evidence-based approach. And that came about in 2018 through the Foundations for Evidence-Based Policymaking Act, often just called the Evidence Act. And the Evidence Act requires agencies to prioritize both evidence building in its policy agenda  —so to think about what kind of evidence might be helpful in establishing its programs and priorities — and then also to engage in a continuous evaluation of those programs. So it’s not an approach where you just build a bunch of evidence and then go out and do things and stop testing that. Evidence-based policymaking, as defined under the Evidence Act, asks agencies to keep testing and evaluating their programs for effectiveness as they go along. So agencies have made a lot of progress. Many agencies have now some program or a chief evaluation officer. They often have a whole office that’s been dedicated to conducting the activities that are required under the Evidence Act. And DOGE has actually, in the cases of some agencies, started to eliminate those offices entirely or those positions, not seeing them as a priority. And in other cases, for example, with Department of Education and USAID, they’ve made efforts just to eliminate the activities of the agency altogether, which obviously would include inherently the evidence-based policymaking activities they might’ve been doing under the Evidence Act.

Terry Gerton Tell me more about your particular evidence for this move away. You mentioned the Department of Education. Talk a little bit more about what kind of evidence Department of Ed would have been collecting and how it could be used, where it might be now.

Ally Coll Department of Ed is a great example because they’ve actually been on the forefront of evidence-based policymaking. Way before the Evidence Act was enacted in 2018, they had already been engaging in evidence- based policymaking, really starting in earnest around 2002 with the No Child Left Behind Act. And somewhat controversially, they were one of the first agencies to start conducting randomized control trials, RCTs, of their programs to get a better sense of what was actually effective and working. And that move toward RCTs kind of came from the same hesitation that some conservative lawmakers have about the Department of Education that’s leading now to its dismantling, which was a question about, how necessary is this agency? How effective is it at doing what it purports to be doing? But RCTs were an example of assessing that question in an evidence-based way, right? Rather than making an assumption that the agency isn’t being effective, they actually instituted programs and evaluation functions to see which programs were working well and which weren’t.

So Department of Education releases really robust reports on an annual basis about the extent to which it’s been evaluating its programs and what it’s learning. There’s a trove of data and information that’s housed there that DOGE could be assessing. It doesn’t even require new evidence building, though that would be good as well. But even just assessing the level of data and information Department of Education has already collected about its activities would have been another approach. Instead of taking initially efforts to just wind up the agency, DOGE could have taken efforts to go through all that data and get a sense of, maybe some programs aren’t as effective as we want them to be, and those are a place to redirect funds or potentially cut funds. But maybe there are some programs that are really effective and we want to keep those around. So one of my arguments is that that kind of approach would have been a more  evidence-based and grounded way to go about achieving some of the goals that DOGE set out at the beginning of the administration.

Terry Gerton I’m speaking with Ally Coll. She’s an associate professor at the City University of New York School of Law. Well, speaking about that approach, most people would not argue that the federal government didn’t need some reform, doesn’t need some reform. What would an evidence-based approach to reform look like from the beginning?

Ally Coll So evidence-based policymaking, I think, shares a basic goal with what DOGE set out to do, which is to fund more of what works and less of what doesn’t. And I think that’s a pretty unobjectionable goal. No matter what your views are on policy or how big the federal government should be, if the federal government is acting, we want it to be spending dollars wisely. And we want to be running programs that work for people. When programs don’t work for people, they have huge opportunity costs. First of all, for those dollars that could have been spent more wisely on programs that would achieve their goal, but also for the people who participate in those programs, right? If someone goes to the government for help with a particular problem and that program doesn’t turn out to be helpful at solving the problem, and they could have perhaps gone to a different kind of community-based program and gotten the help they needed, that’s an opportunity cost for people. And it also creates distrust between people and their government. So I think the broad goal of funding more of what works and less of what doesn’t is pretty unobjectionable. And as you say, I think many people would agree that that’s a good undertaking for the government.

But evidence-based policymaking goes further by saying the way we make that decision about what works, and what doesn’t, needs to be grounded in some evidence and some data. And agencies should go about making prioritizations for which programs to fund and which maybe not to fund, based on data that either already exists or that they might go out and collect and build to better inform their efforts. So I think an evidence-based approach would do exactly that. It would set some questions about what the goals of the agency are, how they wanna go about achieving those goals, and then go out and build or collect evidence to make sure that what they’re doing is as effective as possible. What DOGE has been doing, you now, with the metaphor of the chainsaw, is really more taking a much more drastic approach to cuts and looking at budgets on a really macro level, eliminating entire departments, eliminating entire units within agencies, cutting headcount really drastically. As opposed to kind of taking this more micro approach by looking at individual programs and agencies and departments and saying, you know, which are really actually working well for the American people and which might not be doing exactly what we hoped that they would do.

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Terry Gerton Given the azimuth that you’ve just described in DOGE’s efforts so far, what would it take to recenter evidence as part of the administration’s reform efforts?

Ally Coll Yeah, well, I’ve really been advocating for Congress to get more involved here. You know, we’ve been operating in a system where Congress is the one that creates these agencies and gives them various directives. They’re also the branch of government that’s responsible for funding the agencies through the appropriations process. And historically, Congress has been a little bit open-ended in the directives that it’s given to the agencies, and it’s giving them a lot of discretion to implement kind of an overarching goal. And I think this moment shows that perhaps this is a time for Congress to get more specific about what exactly it wants these agencies to be doing and how it wants them to go about doing that, those programs and priorities. So I think that was at the heart of the Evidence Act and why Congress enacted it. But the Evidence Act is general, right? It applies to every single agency exactly the same way. And I think this is a moment where Congress should consider writing statutes that are specific to each agency. Congress has the final say here under our constitutional system. They could say, we don’t want you to eliminate programs unless you’ve already gone through an evidence-based approach, determining which programs should stick around or which programs we should cut. I think that really is the solution, is for Congress to take back its constitutional power to say exactly what it wants these agencies to be doing and how.

Terry Gerton Have you heard anything from Congress in response to your efforts?

Ally Coll So I think Congress is in a moment of trying to respond in a strategic way as much as they can to what’s happening right now. It’s really difficult, as some people have been saying, to put Humpty Dumpty back together again, as some of these agencies have experienced unprecedented and really drastic cuts. I think Congress right now is sort of in a responsive mode to requests, for example, to eliminate the Department of Education. I think before they are able to really consider this more thoughtful approach, they’re going to have to respond to the Trump administration’s request that they pass legislation to eliminate Department of Education, for example. I’m personally hopeful that that’s the kind of initiative that, at the end of the day, may not have political will in Congress, and we may see Department of Education stick around. And I think that moment is where Congress could write some new parameters for DOE into legislation. So let’s not cut it entirely, but let’s maybe take this moment to maybe pass some legislation that’s a bit more specific about what we do want the department to do and how we want them to do it.