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United States Census Bureau reporting shows that from 2010 to 2020, the White population declined 8.6% to 204 million. The multiracial population increased 276% to 39 million.

This degree of change warrants a rethinking of race and ethnicity reporting. The Office of Management and Budget (OMB) has done just that. Its recent “Initial Proposals for Updating OMB’s Race and Ethnicity Statistical Standards” (Proposal) could affect federal reporting requirements including EEO-1 data collection and the detail that federal contractors provide the Office of Federal Contract Compliance Programs (OFCCP).

What is Behind the Recommendations?

There is an important additional reason to review the way the federal government collects race and ethnicity information. The catch-all “Some Other Race” (SOR) survey category was the third largest race group identified in the 2020 Census, behind the White population and the Black population. For the 2020 Census, SOR became the second-largest category reported.

SOR was intended to be a small “residual” category for respondents who do not identify with any of the outlined OMB race categories. Nevertheless, in the 2010 Census six percent of all respondents, twenty million people, identified as SOR. The number soared past forty million in the 2020 Census. Of that number, nearly 30 million provided no additional detail, making it impossible to categorize race or ethnicity.

SOR is a legally required selection choice on the “Decennial Census” (Census) and the American Community Survey (ACS). The Census is the survey held every 10 years querying age, date of birth, race, and ethnicity. The government uses the information for legislative redistricting and funds allocation. The ACS is an ongoing collection of information including educational background, employment, and home-keeping costs. The Census Bureau employs ACS data to create the “EEO Tabulation” that federal contractors use to determine the availability of women and minorities in Affirmative Action Plans. It is important that the Census get these numbers right.

OMB has the authority to set federal standards for “statistical collection procedures and methods,” 44 U.S.C. 3504(e)(3). In 1997, the OMB issued Statistical Policy Directive No. 15: Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity (SPD 15), which outlines race and ethnicity reporting for all federal agencies. OMB now plans to use its authority to, among other things, rewrite SPD 15 to reduce the number of Census respondents who identify as “Some Other Race.”

What Does the Proposal Recommend?

In 2022, OMB convened a “Federal Interagency Technical Working Group on Race and Ethnicity Standards” (Working Group) to review SPD 15. The Working Group’s Proposal would

  • Combine the currently separated race and Hispanic/Latino ethnicity questions
  • Create a new reporting category for those from the Middle East and North Africa (MENA)
  • Allow data collection on race and ethnicity at additional levels of detail (identification as “Caribbean,” “Polish,” etc.)
  • Make a variety of terminology changes (for example, discontinue use of the terms “negro,” “majority” and “minority”)

The Working Group stresses that the Proposal is subject to change. OMB held three “Town Hall” listening sessions in March 2023, and states that more will come. It is soliciting written comments, due April 12, 2023 (see details at the Working Group website).

Changes to Reporting – More Choice

In 2015, OMB performed a study involving 1.2 million households to evaluate alternate methods of collecting race and ethnicity data. The 2015 Census Report suggested that the current survey format, which locates questions on race and ethnicity in separate sections of the survey confuses people, encourages overuse of SOR, and decreases overall response rates.1

The 2015 Report suggested that asking about race and ethnicity in one place improves response rates. The Report found that many people identify by nationality or ethnic sub-group rather than race or ethnicity. This is reflected in the 2023 Proposal recommendation, which would combine race and ethnicity reporting and incorporate a new level of nationality-focused detail:

omb race details form

Excerpt of Proposal Figure 2: Combined Question with Minimum and Detailed Categories

In addition, both the 2015 Report and 2023 Proposal recommend creating a new ethnicity category, Middle Eastern or North African (MENA). Per the Proposal, “Many in the MENA community do not share the same lived experience as White people with European ancestry, do not identify as White, and are not perceived as White by others.”

The MENA recommendation follows the Working Group’s principle that “respect for individual dignity should guide the processes and methods for collecting data on race and ethnicity”. In the past, Europeans and the direct descendants of Europeans defined racial and ethnic categories around the world. Today’s system, based on self-identification and respect, is a great leap forward.

The 2015 Census Report suggests that the MENA category will improve the accuracy of the Census and decrease use of SOR.

How Will OMB Manage Detailed Self-Identification Information?

The Proposal recommends detailing multiple race and ethnicity sub-categories and allowing multiple selections (see Figure 2 above: “select all that apply and add additional details”). Detailed data may help researchers identify the size, location and needs of specific populations. It will, however, present significant complications for collecting, processing and reporting. How is OMB to organize the data? Can OMB roll multiple responses up to a specific race? Will more people be checking more than one box increase the number of those reporting as multiracial (currently the “Two or More” Census option). Will multiracial then become the new SOR? OMB is soliciting input on how to address these and related issues:

omb current federal register notice 5

OMB Town Hall, March 14, 2023 – Implementation Guidance Request

The Working Group recommends that SPD 15 require data collection on race and ethnicity at the detailed category levels unless “an agency determines that the potential benefit of the detailed data would not justify the additional burden to the agency and the public or the additional risk to privacy or confidentiality.” An agency could allow higher-level record- keeping under “minimum” categories:

omb race checklist simple

Proposal Figure 3: Combined Question with Minimum Categories

So, while the Census and the ACS formats may change significantly, future EEO-1, Affirmative Action Plan, and other Federal reporting might not look very different than today….

Other Complications

The Proposal points out, “the race and ethnicity categories set forth are sociopolitical constructs.” The categories have nothing to do with biology and genes. They represent our very unscientific thinking about ourselves.

One thing that the OMB Working Group heard during its Town Hall meeting of March 14, 2023 is that even members of a particular group think about themselves, and want to be identified, in very different ways.

omb current federal register 4

OMB Town Hall, March 14, 2023 – Summary of Proposed Vocabulary Changes

The Proposal states that during listening sessions held by prior Working Groups, participants supported adding detailed categories for the Black or African American category for identification for descendants of enslaved Americans such as ‘‘American Freedman’’ or ‘‘American Descendant of Slavery.’’ This detail is not included in the recommended collection form (see Figure 2 above). Most comments during the OMB’s March 2023 Town Hall were by individuals of African descent discussing their preferences for self-identification. Some were very much for – and others very much against – a sub-category that refers to slavery.

The 2015 Study projects that including the MENA category will further decrease the number of survey recipients identifying as White. As noted above, the Census is already reporting a declining percentage of Whites. Could classification and terminology changes that hasten Whites falling out of the “majority” category become a hot-button issue?

 

Conclusion

The Proposal focuses on changing race and ethnicity reporting categories to increase Census participation. However, the 2020 Census User Experience Survey Report found that only three percent of respondents were dissatisfied with the 2020 Census. Of this small, dissatisfied minority, more were concerned about sharing information with the government than with the format of the race/ethnicity question. Nevertheless, the Proposal does not address concerns about the survey’s purpose and utility.

Why is race/ethnicity reporting important? The data collected is critical to understanding the needs of specific communities. Survey information helps governments and non-governmental organizations and other organizations allocate resources and benefits. This is particularly true in medicine, for example, where those of shared origin can share inherited medical conditions. In the workplace, the information helps strategize culture, build business plans and influences hiring, training, and retention.

Government and business leaders should get together to communicate why race/ethnicity surveys are beneficial. While redefining questionnaire format and terminology is very important, a good communication plan could do as much, or more, to improve Census response.

1According to Merriam-Webster, “Today, race refers to a group sharing some outward physical characteristics and some commonalities of culture and history. Ethnicity refers to markers acquired from the group with which one shares cultural, traditional, and familial bonds.”

Author

Paul McGovern
Managing Partner
Praxis Compliance

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