11 minutes

Run the review on one draft

A repeatable equity review you can copy and run on one real policy, guidance document or work instruction, with a worked finding and a way to route what you do not own.

What you’ll be able to do

Run an equity review on one real draft policy or guidance document, and record each finding with the sentence, who is affected, what you would change and who owns the change.
Compare the responses to this question and explain your choice: How do you spend the three days?
Draft a policy equity review for your work, including purpose and who is bound, what the draft asks people to do, the four findings.

Work in order, and stop polishing

The review has an order, and the order matters more than the thoroughness. Purpose and who is bound come first, because a requirement whose purpose nobody can state is not a wording problem. Then list what the draft asks people to do, because the four findings are easier to see against a list of tasks than against paragraphs. Then the findings. Then the floor. Routing last, once you know which findings are yours.

Here is one finding at three levels of quality. Vague: “the documentation section may create barriers for some applicants.” Better: “Section 4 requires original documents, which is hard for people who do not have stable housing.” Usable: “Section 4, first sentence: The applicant must submit original documents. People living in shelters, in group settings or with family often cannot produce originals, and replacing a lost record costs a fee and several weeks. Suggested wording: The applicant may submit copies. The division may request an original only when a copy cannot be verified, and will say why in writing. This section is ours; I have made the change in the draft.”

The difference between the second and the third is about ten minutes of your time and the entire likelihood that anything changes. A drafter working to a deadline will accept wording they can paste. They will rarely invent new wording for a problem someone else described, because inventing it under deadline is the riskiest thing on their desk.

A policy equity review

One page you can copy and run on a single draft policy, guidance document or work instruction.

Purpose and who is bound Name the document — law, rule, policy, guidance or work instruction — what it is for, and who has to follow it: staff, counties, providers, applicants, or all of them. Write the one thing a reader should be able to do after reading it. If you cannot write that sentence, the review starts there.

What the draft asks people to do List every action the draft requires of someone outside DHS, one per line: a document to obtain, an appointment to attend, a form to complete, a channel to use, a deadline to meet. Mark each one that costs money, transportation, time off work, an interpreter or a second appointment.

The four findings Quote the sentence and give its location for each. Unnecessary barrier: a step the purpose does not require. Unclear requirement: a sentence a careful reader could satisfy two ways. Unintended disparate effect: a requirement not equally available across the state. Hidden assumption: the picture of a person the sentence was written around. Add who is affected, what happens to them, and the wording you suggest instead.

The floor Check what the draft cannot write below: accessible documents and usable forms; effective communication, including interpreters and captioning; meaningful language access, with the documents that decide a service translated; nondiscrimination in how the requirement is applied. Say in the body of the document how each is met, who arranges it and how long it takes, rather than leaving an offer of other formats at the end.

What you changed, what you routed, what you left Three short lists. Changed: the wording you replaced, and why. Routed: each finding outside your control, with the sentence, the effect, suggested wording and the office it went to. Left: what you considered and decided not to change, with the reason, so the next reader inherits the thinking instead of repeating it.

Copy the five fields into a blank page, run them against one real draft this week, make the changes you own, send the routed findings with suggested wording, and give the drafter the changed and left lists.

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One finding, three ways of writing it

“The documentation section may create barriers for some applicants. Recommend review.”

The drafter cannot tell which sentence, which applicants, or what to do. It arrives as criticism, generates a meeting, and leaves as nothing.

Changes that usually need nobody's permission

Delete a requirement your own section added that nothing above it requires.
Replace “appropriate documentation” with the list of what actually counts.
Say what a deadline is counted from, and whether the days are calendar or business days.
Add a second way to submit alongside the online one.
Name a person and a direct number instead of a title and a shared inbox.
Define a program term the first time it appears, or stop using it.
Move the interpretation, translation and format arrangements into the body of the document, with who arranges them and how long they take.
Write down the discretion a worker actually has, and what should guide it.

Send wording, not concern

What you can change

You control how precise the review is that you hand to the person who owns the draft.

What to watch for

Do not raise a concern and wait to be asked what you meant. A concern costs the drafter a meeting they do not have time for; a sentence costs them a paste.

Your next step

Before you send your review, check that every finding quotes a sentence, names who is affected and offers replacement wording, and that the last section says plainly what you have already changed.

Your review finds that an automatic denial notice, owned by another division, gives no reason a reader can understand. What do you send that office?

A note asking them to review their notices for plain language.

The exact notice, the sentence as it currently reads, what a reader cannot tell from it, suggested replacement wording, and a question about who can approve the change.

A copy of your full review with the finding highlighted.

A request that the notice be suspended until it can be rewritten.

Try a situation

You are asked to review a two-page draft guidance document about a new reporting requirement before it goes to the division's leadership. You have three days. The draft has a clear purpose, one sentence that can be read two ways, a submission channel that is online only, a program term that appears nowhere else, and an accessibility line at the end saying materials are available in other formats on request.

How do you spend the three days?

Read for clarity and fix the wording problems; the channel and the accessibility line are someone else's decisions.

Run the review in order: confirm the purpose and who is bound, list what the draft asks people to do, write the four findings with quoted sentences and suggested wording, check the floor, then split the findings into what you change and what you route.

Send the draft to a community organization for comment and wait for their response before writing your review.

Carry this forward

The review runs in a fixed order — purpose and who is bound, what the draft asks people to do, the four findings, the floor, then routing — because rewriting a sentence inside a requirement that should not exist wastes the effort.
A finding is usable when it quotes the sentence, names who is affected, says what happens to them and offers replacement wording. A finding that names a concern is a feeling; a finding that offers wording is a decision someone can make.
Most drafts hold a few findings you can fix yourself and one or two that belong to another office. Route the second kind with the same precision, and say what you have already changed.
Write down what you considered and decided not to change, and why. The next reader inherits the reasoning instead of repeating the discovery.

A completed equity review you can copy, a worked comparison of three ways to write the same finding, and a knowledge check on routing a finding you do not own.

Run the review on one draft this week. Make the changes you own, send the findings you do not own with suggested wording to the office that owns them, and tell the drafter what changed and why.

Your next step

Name the draft you will review.

Name the draft, the day you will review it, and who owns it

Name the one finding you expect to be hardest to raise, and how you will word it

Name the office you will route anything outside your control to, and what you will send them

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Mark this lesson complete

Participation and course completion in this program do not count toward DHS-required training credits unless management, a director, or DHS leadership expressly approves an exception.