Given the limited time this directive allows, and the absence of additional resources provided to assist already-busy departments in performing the task, we expect many agencies will be inclined to focus on a few attainable projects and perform a review based only on readily available data. Using this approach, discovered bias will be minimal, if found at all. While this would narrowly satisfy the requirements of the EO, this is not a good-faith outcome.
At the outset of any data-driven project, the best practice would be to define, even reimagine, what success looks like. To the program manager, success can be finding no bias and returning to mission-critical activities. But to the President, department executives, and the public, success looks different. To them, success relies on accurate data collection and analysis that unequivocally demonstrates where bias does exist, and in what form. As a result, the government can implement appropriate and (often simple) corrective action to ensure fairness and equity across the board.
Considering the Chief Data Officer (CDO) of the United States is among the key stakeholders receiving this report, this objective, data-centric approach is the only credible approach.