Capitalizing on an Important Step Forward in Data Disaggregation and the Collection of Race and Ethnicity Data


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History of Race and Ethnicity Data Collection in the U.S.

Initially developed in 1977, the Office of Management and Budget (OMB) issued standards to ensure consistency on race and ethnicity data collection throughout the federal government. Entitled Statistical Policy Directive №15 (SPD 15), it required for the first time that the federal government use the categories American Indian or Alaskan Native, Asian or Pacific Islander, Black, and White when collecting information about race — and to use Hispanic origin or Not of Hispanic origin when collecting ethnicity. This helped ensure compliance with new civil rights laws at a time when the Asian and Pacific Islander community was growing rapidly. There were 1.5 million Asian and Pacific Islanders counted in the 1970 Census and 3.7 million in 1980.

The standards were revised in 1997, creating separate categories for “Asian” and “Native Hawaiian or Other Pacific Islander.” Respondents were also allowed to report multiple races, reflecting the increasing number of people who identified as multiracial. In the 1990 Census, 7.3 million people identified as Asian, and by 2000 that figure had risen to almost 12 million either alone or in combination with another race. These revisions helped reflect not only demographic shifts in the United States, but also how the very notion of race and ethnicity had changed in the nearly 20 years since SPD 15 had first been developed.

Groundbreaking and Critical Advancement in Race and Ethnicity Data Collection

Although efforts in 2016 and 2017 to revise the standards in advance of the 2020 Census stalled, OMB released new updated standards in March. In addition to requiring the collection of further detail beyond the minimum categories, the standards call for using one combined question to ask about race and ethnicity as well as the inclusion of a Middle Eastern or North African category. These revisions reflect recommendations Advancing Justice — AAJC has made through direct engagement with OMB and within our community comments here and our affiliation comment here.

These updates mark an important step forward in allowing for more disaggregated data on Asian American communities, who are among the fastest growing and most diverse racial groups in the United States. Often viewed as homogenous, these communities include around 40 detailed subgroups that can differ dramatically across key social and economic indicators. For example, in the context of health disparities, U.S.-born Vietnamese American women are four times more likely to die of breast cancer than any other Asian American group. Korean American children are “four times more likely to have no health insurance as compared to others.” Data disaggregation is critical because it allows us to see these differences. When data are not disaggregated, broad trends can mask much more negative or nuanced outcomes for specific subgroups of people, leaving their needs and issues invisible and unmet.

Historically, most agencies opted not to disaggregate their data by subgroup despite having the option to do so under the previous standards. As we detail in Assessing Availability and Quality of Administrative Records for Asian Americans and Native Hawaiians and Pacific Islanders: Introduction and Federal Database Analysis, even when data on race and ethnicity are collected on federal administrative data forms, the categories are usually limited to the 1997 definitions required by OMB. As noted in the table showing how different federal agencies collect race information in their forms, the Census Bureau collects the most information on disaggregated data. However, only seven other agencies and subagencies collect forms with disaggregated data out of the total 33 agencies and subagencies that collect race and ethnicity data.

Requiring the collection of additional detail beyond the minimum underscores the necessity of data disaggregation for accuracy and advocacy. OMB’s decision emphasizes the importance of data disaggregation to so many communities because these new standards will help make once invisible communities more visible. Our analysis of comments submitted in response to the January 27, 2023 Federal Register Notice “Initial Proposals for Updating OMB’s Race and Ethnicity Statistical Standards” revealed that Asian American organizations overwhelmingly supported data disaggregation. We encourage Asian American organizations to continue voicing their priorities during the implementation process.

Moving the Ball Forward: Implementation Process and Public Engagement

The announcement of the new revised standards is merely the first step in the long-awaited modernization of our nation’s race and ethnicity standards. We look forward to beginning the substantive work of implementing these revisions together with OMB, other agencies, and our partners. Further research is needed to better inform implementation of the standards, including ensuring the detailed groups used will in fact elicit the best responses across all racial and ethnic groups, such as through proper signaling to the diverse set of detailed subgroups in each category. OMB and other agencies must continue meaningful engagement with community groups as they begin to implement these revised standards; continued coordination with advocacy groups will ensure that data are accessible and usable for the broader public — not just federal agencies and experts.

To this end, the new revised standards provide opportunities for the public to engage:

  1. OMB will establish an “Interagency Committee on Race and Ethnicity Statistical Standards, [convened] by the Chief Statistician of the United States, that will maintain and carry out a Government-wide research agenda and undertake regular reviews of SPD 15. These reviews will take place on a 10-year cycle and will include opportunity for public input. […] Notwithstanding this regular review cycle, OMB may decide at any time to initiate a review of SPD 15.”
    What You Can Do! OMB listed several topics for further research prior to the next SPD 15 review. Some of these topics may be of particular interest to you and your community. For example, topics might include how to collect race and ethnicity consistently across different languages including translations of the question, how to evaluate the ability of detailed checkboxes to generate high-quality data as demographics shift over time, and how to enhance question design and inclusive language to encourage respondents to select multiple race and/or ethnicity categories when appropriate. You should weigh in with the Interagency Committee on Race and Ethnicity Statistical Standards on their identified topics for further research, as well as provide additional potential research topics that would be pertinent for your community. These might include how to best bridge data collected under the previous standards with data collected under the new standards and how to best signal to the diverse subgroups in your community which group they belong.
  2. The revised standards set an 18-month deadline for agencies to publish online an Action Plan on Race and Ethnicity Data that outlines how they plan to comply with these standards in five years. To this end, the new revised standards provide opportunities for the public to engage and make sure their communities are represented.
    What You Can Do! Federal agencies must be in compliance with the new standards within five years and must publicly publish their action plan to achieve compliance within 18 months of the standards’ publication date. You can identify agencies of interest to you and your community and proactively engage with them on the development of their action plan, helping them understand the needs of your community and best practices to ensure compliance with the new standards.
  3. Recognizing the need to “balance […] consistency with the ability to adapt to change and meet specific program needs,” the standards allow for agencies to “submit a request” to OMB’s Office of Information and Regulatory Affairs (OIRA) for an exemption or variance. There are only certain instances when exemptions would be granted, however. An exemption may be granted if the “potential benefit” of collecting the “detailed data would not justify the additional burden to the agency and the public or the additional risk to privacy or confidentiality.” They may also request a variance to the detailed categories to be collected if the agency determines “that collecting different detailed data categories than the ones listed in SPD 15 provides more useful or accurate data for the collection’s specific context and intended uses. […] OIRA will review agency requests for exceptions and variances, and they will only be approved if they contain sufficient justification.” Any variation must be specifically authorized by OIRA through the Paperwork Reduction Act (PRA) information collection approval process and, by law, the PRA process in most cases includes at least three months of public comment.
    What You Can Do! It will be important to monitor attempts by agencies to request an exemption or variance and to provide public comments if agencies of interest submit such a request. Additionally, if you believe that different detailed groups ought to be collected by a particular agency, you can proactively engage with them about potentially submitting a request for the use of different detailed groups and help to provide the justification for such a request.

The successful implementation of SPD 15 will require both significant public outreach by OMB to underrepresented communities, like Asian Americans, as well as meaningful engagement by communities in the process. As OMB outlined in the revised standards, their recommendations were informed by public comment and listening sessions. It is important that our communities continue to engage with OMB and other federal agencies tasked with implementing these new standards, making their voices heard so that they are fully and accurately represented — statistically and, by extension, politically.

This article was written by the Vice President of Census and Voting Programs and the Director of Research at Asian Americans Advancing Justice | AAJC.

Asian Americans Advancing Justice | AAJC has a mission to advance the civil and human rights of Asian Americans and to build and promote a fair and equitable society for all. Visit our website at advancingjustice-aajc.org.



Advancing Justice – AAJC
Advancing Justice — AAJC

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