One DSD People, Access and Culture · Practice note · Deeper method EAT Step 4 Walk-Through — Explore Strategies and Options IMPORTANT — Scope of this resource: This walks staff through the methodology of the DHS Equity Analysis Toolkit. It does not perform equity analyses. Actual equity analyses are conducted by the appropriate authorities — your Equity Champion, the One DSD Equity Team, or the DHS Equity Director for your work area. CONTENT EAT Step 4 Walk-Through — Explore Strategies and Options Resource type: Tier 1 Flagship — EAT Walk-Through (Methodology Education, Not Analysis) Adapted from: DHS Equity Analysis Toolkit Guide (Minnesota DHS) — Step 4: Benefits and Burdens (modification and strategy components) Library home: L01 EAT Walk-Through Library Companion to: T02_01 (EAT Overview), T02_04 (Step 3 Burdens/Benefits), T02_06 (Step 5 Implementation), T02_10 (IS/IS NOT) IMPORTANT — Scope of this resource: This walks staff through the methodology of the DHS Equity Analysis Toolkit. It does not perform equity analyses. Actual equity analyses are conducted by the appropriate authorities — your Equity Champion, the One DSD Equity Team, or the DHS Equity Director for your work area. What this step is for After Step 3/4 has identified who benefits and who bears burdens, the analysis must generate options. This walk-through covers how the EAT approaches strategy development: how to generate alternatives, how to center the communities most affected in that process, and — critically — how to understand the difference between strategies that mitigate a disparity and strategies that eliminate its root cause. Plain-language overview Once the equity analysis has identified disparate impacts, the question becomes: What can be done, and which option most advances equity? The DHS EAT Guide (https://mn.gov/dhs/) describes this as the moment where teams ask: "How can you modify the proposal to correct negative impacts and enhance positive impacts? Are there complementary strategies?" This is not just problem-solving — it is a disciplined process of generating, comparing, and prioritizing options through an equity lens. The Race Forward Racial Equity Impact Assessment (https://www.raceforward.org/sites/default/files/RacialJusticeImpactAssessment_v5.pdf) frames this as "examining alternatives or improvements": asking whether there are better ways to reduce racial disparities and what provisions could be changed or added to ensure positive impacts on racial equity and inclusion. Walk-through (the methodology) Generating alternatives Strategy development in the EAT framework begins with generating a genuine range of options — not a single pre-selected solution with alternatives added to satisfy the process. A genuine alternatives process: 1. Starts from the burdens and benefits identified in Step 4. Every strategy option should respond directly to a specific finding. "We found that Karen-origin applicants abandon applications at three times the rate of English-speaking applicants; here are three strategies that could address that specific barrier." 2. Includes options at different levels of systemic depth. Some options modify the immediate policy or practice (surface-level). Others change the underlying process or infrastructure (structural). Others address the root conditions that create the disparity (transformational). The GARE Racial Equity Toolkit (https://belonging.berkeley.edu/sites/default/files/ARCHIVE/gare-racial_equity_toolkit.pdf) emphasizes the distinction between transactional change (checkbox adjustments) and transformational change (authentic effort to address root causes). A good alternatives process includes options at both levels, so decision-makers can explicitly choose how deep to go. 3. Is generated with the communities most affected. The King County Equity Impact Review (https://blog.homelessinfo.org/wp-content/uploads/King-County-Equity-Impact-Review-checklist_Mar2017.pdf) includes in Phase 3: "Include upstream alternatives (and related costs) that target root causes to eliminate disproportionate impact." Root-cause alternatives are often best identified by the communities experiencing the problem — not by program staff alone. This is why Step 3 (community engagement) must precede strategy development. 4. Names tradeoffs honestly. Every option has costs — financial, operational, political, or temporal. A strategy that would significantly reduce a disparity may require resources that are not currently budgeted, or may require changes that extend the timeline. Name these tradeoffs explicitly. Centering communities most affected "Centering" communities most affected means more than consulting them. It means: • Using community-identified priorities as the primary criterion for evaluating strategy options, not the secondary criterion after organizational convenience. • Returning proposed strategies to community members for review before finalizing them. "This is what we heard from you; this is the strategy we are proposing; does this reflect your priorities?" • Including community members as co-designers of strategies where possible, not just validators of staff-designed options. • Acknowledging explicitly when a preferred community strategy cannot be implemented due to legal, fiscal, or other constraints — and explaining why, rather than simply presenting a constrained option as if it were the only possibility. Mitigation versus elimination: a critical distinction This distinction is one of the most important — and most often collapsed — in equity strategy development. Mitigation reduces the harm of a disparate impact without addressing its underlying cause. Example: adding a translation service to an application process that has structural barriers for immigrant communities reduces harm but does not eliminate the structural barrier. Elimination addresses the root cause of the disparity. Example: redesigning the application process so that it does not require documentation that immigrant communities systematically lack — eliminating the structural barrier, not just reducing its impact. Both mitigation and elimination strategies may appear in an equity analysis. The distinction matters for three reasons: 1. Mitigation strategies can normalize the disparity. If a program adopts translation services and considers the equity work done, it may never address the fact that the program itself was designed for a population that does not reflect the full served community. Mitigation can become an excuse for not pursuing elimination. 2. Elimination strategies are usually more resource-intensive. Changing the underlying policy or process takes more time, more political capital, and more organizational will than adding a complementary service. Decision-makers need to understand this tradeoff explicitly. 3. Communities experience the difference. Communities that bear the burden of a disparity can tell the difference between a program that addresses the root cause and one that adds a service layer on top of a broken foundation. Trust is built by moving toward elimination; it is eroded by repeated mitigation that never leads to change. The EAT framework expects both types of strategies to be identified. The decision about which to pursue — or in what combination — is made by the team and leadership, not by this resource. Prioritizing options The King County Equity Impact Review (https://blog.homelessinfo.org/wp-content/uploads/King-County-Equity-Impact-Review-checklist_Mar2017.pdf) provides useful criteria for prioritizing strategy options: • What is the likelihood that this option will impact equity (high, medium, or low)? • What is the cost of this action? • What needs to happen to increase the feasibility of this action? • What other resources are needed? • Who will implement the action? • What is the timing? Equity-first prioritization means that options with the highest equity impact receive serious consideration even when they are more costly or more difficult — not automatic selection, but genuine evaluation. Worked example fragment (anonymized, methodology illustration only) Continuing the anonymized waiver program scenario: After Step 4 identifies three primary burden areas (income documentation, language access, and immigration-related trust), the Equity Champion facilitates a strategy generation session that includes program staff and advocacy partners. Options generated for income documentation burden: 1. Mitigation: Accept sworn affidavits of income from community-based organizations, while keeping the documentation requirement itself. (Reduces harm; does not eliminate structural barrier.) 2. Mitigation: Assign a dedicated "application navigator" staff position to assist applicants with documentation. (Reduces harm; addresses capacity barrier but not the policy itself.) 3. Elimination: Remove the income documentation requirement for HCBS waiver programs where income is not legally required for eligibility determination. (Addresses root cause; requires policy change and legal review.) Community response: Advocacy partners indicate that Option 3 is strongly preferred and has been requested by communities for three years. Options 1 and 2 are appreciated but have been tried previously without significant impact on enrollment disparities. Decision: Option 3 is recommended as the primary strategy, with Option 1 as an interim mitigation strategy during the policy-change process. Option 2 is not recommended due to resource constraints and evidence of limited effectiveness. This resource walks through methodology only. The actual strategy development would be led by the Equity Champion and Equity Director. IS / IS NOT Strategy development IS — Strategy development IS NOT Generating a genuine range of options at different levels of depth — Selecting a pre-determined solution and adding options for process compliance Centered on community-identified priorities — Centered on organizational convenience Explicit about the distinction between mitigation and elimination — Treating mitigation as sufficient when elimination is possible and needed Honest about tradeoffs — cost, time, political difficulty — Presenting only the easiest option as if it were the most equitable A collaborative process with affected communities — A staff-only exercise that is presented to communities after the fact Common questions What if the most equity-advancing strategy is fiscally impossible? Name this constraint explicitly in the analysis. Document the recommended strategy, the fiscal constraint, and the gap between what equity requires and what is currently possible. This documentation serves two purposes: it provides an honest record of the decision, and it creates a basis for future resource requests. Equity constraints should be visible in the record, not quietly absorbed. What if community members and program staff recommend different strategies? This is a tension to surface, not to resolve by defaulting to staff preference. Bring the disagreement back to the Equity Director. Examine whether the program staff recommendation reflects genuine operational constraints or reflects a preference for less disruptive change. The EAT framework centers communities most affected — so when there is genuine disagreement, that principle guides the process. How many strategy options are "enough"? There is no set number. The goal is a genuine range that includes at least one option at each level of depth (surface, structural, root-cause). If all options are mitigation strategies, that is a finding worth naming — it means the analysis has not yet identified root-cause elimination options, and more work is needed. Connection to DSD goals DSD's commitment to transformational change — moving from transactional compliance to genuine systems-level equity advancement — is operationalized in this step. The distinction between mitigation and elimination is the distinction between checking a box and doing the work. DSD's six organizational goals require elimination strategies, not just mitigation. When to escalate / where to refer • If no elimination strategy can be identified: escalate to your Equity Director. The absence of a viable elimination strategy is a finding that should be documented and escalated, not quietly dropped. • If community members and program staff are in significant disagreement about strategies: escalate to your Equity Director for structured resolution. • If a recommended strategy would require changes to policy above the program area's authority: escalate to the appropriate level of DHS leadership, with a clear equity analysis supporting the recommendation. Reflective questions 1. Think about a change your program area made in the last two years. Was it a mitigation strategy or an elimination strategy? How do you know? 2. What would it mean for your team to genuinely center community priorities in strategy development — not just invite community input, but let it drive the options selected? 3. Have you ever seen a mitigation strategy that worked so well it prevented the organization from pursuing elimination? What did that look like? 4. What root causes of disparity in your program area have been identified but never fully addressed? What would elimination look like? 5. What makes a strategy option "realistic" — and whose definition of realistic is being used? Sources • DHS Equity Analysis Toolkit Guide — Minnesota DHS (https://mn.gov/dhs/) (primary source, Step 4 modification and complementary strategies) • Racial Equity Impact Assessment Guide — Race Forward (https://www.raceforward.org/sites/default/files/RacialJusticeImpactAssessment_v5.pdf) (section 8: examining alternatives or improvements) • King County Equity Impact Review — Phase 3: Analysis and Decision Process (https://blog.homelessinfo.org/wp-content/uploads/King-County-Equity-Impact-Review-checklist_Mar2017.pdf) • Racial Equity Toolkit — GARE, via Othering and Belonging Institute (https://belonging.berkeley.edu/sites/default/files/ARCHIVE/gare-racial_equity_toolkit.pdf) (transformational vs. transactional change) • One DSD Program Charter v1.1 (one-dsd-program-charter) Always defer to the person in front of you. Ask: What is the likelihood that this option will impact equity (high, medium, or low)? Ask: What is the cost of this action? Ask: What needs to happen to increase the feasibility of this action? Ask: What other resources are needed? Ask: Who will implement the action? Ask: What is the timing? Ask: What if the most equity-advancing strategy is fiscally impossible? For all staff, use EAT Step 4 Walk-Through — Explore Strategies and Options to define the decision, compare evidence and impacts, document limits, and name the owner; use the guidance in the immediate task, check impact and access, and ask for help when authority is unclear. Start by ask: What is the likelihood that this option will impact equity (high, medium, or low)? Do not replace official legal, policy, clinical, supervisory, program, or Tribal authority. Do not infer an individual's identity, preferences, needs, or experience from group-level information. State uncertainty, use current authoritative sources, and escalate when the decision exceeds the user's role. IMPORTANT — Scope of this resource: This walks staff through the methodology of the DHS Equity Analysis Toolkit. It does not perform equity analyses. Actual equity analyses are conducted by the appropriate authorities — your Equity Champion, the One DSD Equity Team, or the DHS Equity Director for your work area. Step 1. Ask: What is the likelihood that this option will impact equity (high, medium, or low)? Step 2. Ask: What is the cost of this action? Step 3. Ask: What needs to happen to increase the feasibility of this action? Step 4. Ask: What other resources are needed? Step 5. Ask: Who will implement the action? Step 6. Ask: What is the timing? Step 7. Ask: What if the most equity-advancing strategy is fiscally impossible? One DSD People, Access and Culture