by Meghan Maury
I recently did a short webinar on how to write effective public comments on federal data collections. If you missed it, you can watch the recording here:
I wanted to pull out a few highlights, because this is one of those processes that looks incredibly dry from the outside… but is actually one of the most direct ways you can shape what the government does.
So what is this, really?
The federal government runs a lot of programs. Everything from SNAP and WIC to student loans and public health surveys. All of those programs rely on collecting information from people.
Back in the late 1970s, folks got pretty fed up with how much paperwork the government was asking for. So Congress created the Paperwork Reduction Act, which basically says: you cannot ask the public for information because you feel like it. You have to justify it.
And, importantly, you have to ask the public what they think.
That happens at two points in the process. First, when an agency proposes a new, revised, or renewed data collection. Second, when it goes to the Office of Management and Budget for final approval. At both stages, the public can submit comments.
On paper, this is just a procedural step. In practice, it is one of the few places where you can directly influence what data gets collected, how it gets collected, and who gets counted.
How to make your comment actually matter
This is where people tend to get stuck. The good news is that effective comments are not about being the smartest person in the room. They are about being clear, strategic, and useful.
A few takeaways from the webinar:
Start with your goal. What do you want to change? You do not need to respond to everything. Focus where you have leverage.
Use the PRA’s criteria. Frame your comment around necessity, usefulness, and burden. This is how agencies are required to think, so meet them there.
Be concrete and propose solutions. “This is burdensome” will not get you very far. “This will require X hours from Y population and reduce response rates” is much harder to ignore. Even better if you offer a fix.
Clarity beats perfection. You are not writing for style points. You are writing to influence a decision.
Use real-world examples. This is often the most powerful thing you can do. Show how a question will land in practice, who it might exclude, or what it might miss.
And one thing I always try to emphasize: this is a long game. Comments do not just affect the immediate decision. They shape future versions of a collection, create a record for oversight or litigation, and signal what a field cares about.
This is one of the most underused tools we have
I genuinely love this process. I know that makes me a little bit of a nerd, but hear me out.
If you care about data, this is where a lot of the real decisions get made. Not just whether data exists, but what gets asked, how questions are framed, and who gets included or excluded.
It is not flashy. It is not fast. But it is real. And it works.
Come to Take Action Office Hours
To make this easier, I am starting monthly Take Action Office Hours where you can come with questions, ideas, or drafts. Details and sign-up here.
If you are wondering whether something is worth commenting on, trying to figure out how to frame your argument, or just want a second set of eyes, this is for you.
If something is time-sensitive, feel free to reach out directly at info@dataindex.us. And if you have not watched the webinar yet, I would encourage you to check it out. It goes deeper into both the process and the strategy.
I really do believe this is one of the most practical ways to participate in democracy. You do not need permission, and you do not need to be an expert. You just need to show up and say something useful.