The federal White House Office of Management and Budget (OMB) is asking for public comments on potential revisions to its 1997 standards for collecting and reporting race and ethnicity data. All federal agencies must follow these standards.

The federal government is the largest collector of data in the country. Currently, federal agencies (education, housing, employment, health, small business, etc.) are NOT required to count detailed data for Asian American, Native Hawaiian and Pacific Islander communities. This means our communities remain misrepresented, left out of policy and program decisions and under-funded.

The last time these standards were revised was 1997 – this may be the only time in years to make a change.

The Asian & Pacific Islander American Health Forum, National Council of Asian Pacific Americans, Southeast Asia Resource Action Center and Asians Americans Advancing Justice| AAJC are coordinating efforts to ensure OMB hears from community organizations and the general public who would benefit from modernizing data collection.

Deadline for sign-on is Friday, April 28, 2017. For questions, please contact K.J. Bagchi at kj@ncapaonline.org.


Full letter text:

April 28, 2017

Office of the U.S. Chief Statistician
Office of Information and Regulatory Affairs
Office of Management and Budget
1800 G Street, 9th Floor
Washington, D.C. 20503

Re: OMB-2016-0008, Proposals from the Federal Interagency Working Group for Revision of the Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity

Dear Office of the U.S. Chief Statistician:

The undersigned XX organizations, representing a diverse spectrum of health, justice, civil rights and social services organizations welcome the opportunity to submit comments on potential changes to the Office of Management and Budget’s (OMB) Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity. As the nation continues to diversify and the population approaches majority-minority in 2044, accurate and standardized data collection and reporting of race and ethnicity is critical to ensuring that federal departments and agencies understand the needs of diverse communities and are able to effectively meet their obligations to serve the American people. Data collection and reporting is particularly salient for Asian American, Native Hawaiian and Pacific Islanders (AAs and NHPIs) who comprise over 20 million people, trace their heritage to more than 50 different countries and speak over 100 different languages.

AAs and NHPIs can differ dramatically across key social and economic indicators. For example, while only 6% of Filipino Americans nationwide live below the poverty line, approximately 26% of Hmong Americans are poor.  Similarly, about 49% of Marshallese lives below the poverty line, while only 5% of Fijians are poor.  Roughly 73% of Taiwanese Americans hold a bachelor’s degree, yet only 12% of Laotian Americans do.   Similarly, about 18% of NHPI adults have a bachelor’s degree, with about 3% of Marshallese compared to 18% of Native Hawaiians having bachelor’s degrees.  These data points underscore the importance of the type of detailed race and ethnicity data collected by federal departments. For these reasons, we issue the following recommendations:

Recommendation 1: Adopt the recommendations of the Census Bureau 2015 National Content Test for Proposed Additional Minimum Race and Ethnicity Categories
We strongly urge OMB to require all federal departments and agencies to collect, analyze, use, report and disseminate disaggregated data for Chinese, Filipino, Asian, Indian, Vietnamese, Korean, and Japanese, with Pakistani, Cambodian, and Hmong listed as “for example” write-in groups, and for Native Hawaiian, Samoan, Chamorro, Tongan, Fijian, Marshallese, with Palauan, Tahitian, and Chuukese, etc. listed as “for example” write-in groups (U.S. Census Bureau, 2015 National Content Test Race and Ethnicity Analysis Report, Figure 26). This is critical for understanding which Asian, Native Hawaiian and Pacific Islander groups are being served by agencies and which are underserved.

All federal departments and agencies should be required to collect, analyze, use, report, and disseminate data at these more granular levels. To that end, we believe that federal agencies should be required to collect detailed race and ethnicity data even when such data can not be responsibly reported due to statistical reliability and confidentiality concerns. This is so that we have the option to aggregate the data across time for the same group, (i.e., pool the responses across a period of time), which can address statistical reliability and confidentiality concerns.

In addition, this notice asks for comments on the costs and benefits of disaggregating data. We believe that the important benefits to government programs, communities, researchers, and advocates deeply outweigh any costs and burdens to implementing agencies.

Recommendation 2: Adopt a combined race and ethnicity question.
The Census Bureau’s 2015 National Content Test provides evidence for maximizing the response rates to race and ethnicity questions through changes in phrasing. Asians and Native Hawaiians and Pacific Islanders self-identified more often when they were posed a question that presented combined race and ethnicity. (NCT Final Results Test Table, H 31, pg 299). In addition, we recommend that regardless of the format used, there should be:

• A maximum number of checkboxes included, with the number used during the 2010 Census serving as a minimum
• A maximum number of examples, with the number used during the 2010 Census serving as a minimum
• NHPI response options should be clearly identified as separate from Asian American response options

Recommendation 3: Add a Middle Eastern and Northern African (MENA) Category
We support the recommendation of advocates in the MENA community to have distinct reporting categories for the community. Current OMB guidelines that classify persons from the MENA region as white by race are not accurate or useful, and confuse survey respondents as well as government and other agencies tasked with collecting information on and providing services to these populations. NCT results show that when a distinct MENA category was present, there was a significant decrease in responses for all other response categories, including a significant decrease in “Some Other Race” responses.  Therefore, we urge OMB to establish the new MENA category in revising the standards.

Recommendation 4: Change the terminology for Native Hawaiians and Pacific Islander Populations.
We strongly urge changing the terminology in the standards to “Native Hawaiian and Pacific Islanders” rather than the current “Native Hawaiian and Other Pacific Islander.” We developed this position with the Native Hawaiian & Pacific Islander Alliance as the term “Native Hawaiian and Other Pacific Islander” has fallen out of favor.

Recommendation 5: Remove the term “Far East” and “Negro” from the standards.
We support the recommendations to remove the terms ‘‘Negro’’ and ‘‘Far East’’ from the current standards.

Recommendation 6: When race and ethnicity data is presented, it should include all racial and ethnic categories and OMB should adopt the proposal to end the use of “All Other Races” as a designation in the standards.
As the diversity of the U.S. continues to increase, we believe that OMB needs to revise how data is presented on diverse communities as well as aligning terminology to recognize the breadth of racial and ethnic communities comprising the American public today and strive to reflect the importance of all communities. To that end, we believe it is a necessary and critical step for OMB to end the use of an “All Other Races” category in the standards, Demographics have significantly changed over the past twenty years. Asian Americans are the fastest growing race group in the United States, with 43% growth between the 2000 and 2010 Censuses. The NHPI population also grew rapidly between 2000 and 2010, at 35%, more than three times faster than the U.S. population as a whole. These communities are often lumped into “All Other Races,” thereby making these fast-growing communities invisible. The practice moving forward should be to have agencies report on the data for, at a minimum, all racial and ethnic categories, with the addition of data on detailed groups as available.

In summary, we thank OMB for the opportunity to comment on potential revisions to the 1997 data collection standards for race and ethnicity. As indicated in our comments, these standards and need for revisions are critical to ensuring that federal departments and agencies understand the needs of diverse communities and are able to effectively meet their obligations. As such, we recommend that OMB provide the public an opportunity to comment on any final changes recommended for adoption.

Sincerely,