What gets measured gets done.
It’s a popular catchphrase in business these days. Most folks probably don’t go a week without hearing it from a colleague or in a meeting. Succinct and to the point, the phase captures the idea that measuring results will ensure that time and attention will be placed on achieving a particular goal.
All too often, however, it’s the inverse that accurately describes what takes place; we set the metrics to measure the things we know we can do and achieve. In other words,
What gets done gets measured.
One of the places I see this most often is with diversity and inclusion metrics. And it is certainly what came to mind as I read the recent announcement from the SEC outlining what it will require of the agencies it regulates to document their diversity and inclusion initiatives (Diversity Assessment Report for Entities Regulated by the SEC).
Actually, “require” is too strong a term – as stated in the form provided for submitting a diversity assessment report, “use of the Joint Standards by a regulated entity is voluntary, as are conducting a self-assessment of diversity policies and practices, and submitting diversity assessment information to the SEC.”
They couldn’t have made the assessment less meaningful if they had tried.
Back when these standards were in the formation stage (2013-14), I authored a response to the request for comments to the Proposed Interagency Policy Statement Establishing Joint Standards for Assessing the Diversity Policies and Practices of Entities Regulated by the Agencies.1
My response encouraged the agencies to include a section on actual outcomes in addition to any discussion of policies and programs, noting that:
“the presence of policy and existence of metrics are not sufficient indicators of the financial industry’s progress toward diversity and inclusion in its workforce, leadership and business practices; only the disclosure of the outcomes from these practices can satisfy the goal of promoting transparency and accountability regarding diversity and inclusion for the regulated agencies’ many stakeholders.”
Unfortunately, outcomes didn’t make the final cut.
What does the assessment include? The same things that most organizations measure when it comes to diversity and inclusion: the presence of policy, the active engagement of senior leadership, availability of mentoring and development programs, etc. (There are two small tables for very basic workforce and supplier demographics, but nothing that tracks changes over time).
Anyone who’s spent any time volunteering for United Way or working with logic models can tell you that most of the questions are about inputs and processes. They are not outcomes or impact. They provide no indication of whether or not anything is actually working.
But they are easy to do and document. So what gets done gets measured.
The joint standards were prompted by Section 342 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 which required the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA), Bureau of Consumer Financial Protection (CFPB), and Securities and Exchange Commission (SEC) to each establish an Office of Minority and Women Inclusion (OMWI). The Act also instructed each agency to develop standards for assessing the diversity policies and practices of entities it regulated. Since some entities subject to the regulations from more than one agency, they agreed to work together to develop joint standards. ↩