Comments to the Office of Management and Budget (OMB)

Comments to the Office of Management and Budget (OMB)

April 19, 2017

Comments on Proposals From the Federal Interagency Working Group for Revision of the Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity

Project RACE (Reclassify All Children Equally) is the national organization advocating for the multiracial community. Our population requires changes in the racial and ethnic classifications in this country so that we are counted correctly and accurately for research, making and enforcing laws, redistricting, school data, etc., but also for medical reasons. We have no idea what the health risks are for our population because we have not been included on forms requiring health information. These are matters of life and death. To that end, we are commenting on the Proposals From the Federal Interagency Working Group for Revision of the Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity,

In order to maintain our confidence in Federal statistics, our recommendations will address the multiracial population, which is also called “two or more races” and we hope will be taken under consideration by the OMB.

We are in favor of the combined format, as outlined by the Federal Interagency Working Group, because it is inclusive and provides for equitable and balanced results for our population. Testing for the 2015 National Content Test (NCT) by the Census Bureau showed, in fact, that there was consistency for multiracial individuals with this method. It did reduce reporting of Some Other Race, which we address below. It also appears to better reflect self-identity, which is critical to the multiracial population.

The salience of terminology used for race and ethnicity classifications and other language in the standard are critical to our community, and should have been addressed by the working group. Specifically, it is crucial that instructions are included in every instance where racial and ethnic data are collected as follows: Paper collection: Mark all boxes that apply. Note: You may report more than one group. Online collection: Select all boxes that apply. Note: You may report more than one group. These formats are the only way we can be assured that our respondents will, in fact, know they can check two or more races. These formats have been tested during the NCT by the Census Bureau and have been shown to offer the best guidance for and assurance of the most accurate resulting numbers. The new instructions increased the rate of consistency of multiple-responses when compared to the old instructions. We strongly recommend this critical approach to ensure that our population, which is often seemingly forgotten by the OMB, be counted as accurately as possible.

We also recognize problems with “Some other race” or “Other” categories and the multiracial population. If someone writes in “multiracial,” “biracial,” or “mixed,” for example, they should be tabulated and reassigned to the “two or more races” category. “Some other race” was the third highest category on previous decennial censuses, which caused much confusion and resulted in an undercount of the multiracial population. Federal agencies other than the Census Bureau commonly utilize some type of “Other” category and proper guidance should be provided by the Federal Interagency Working Group.

It is our hope that our suggestions will be taken seriously by OMB in its review of Federal Register Comments. Thank you.

Susan Graham for the members of Project RACE

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