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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

FAMOUS FRIDAY: Chrissy Teigen

download (1) (1)This week’s Famous Friday will be featuring the ever so fabulous Chrissy Teigen. Chrissy was born on November 30, 1985 in Delta, Utah. She is of Thai and German ancestry. Her family moved around quite a bit in her childhood before finally settling down in Huntington Beach, California. It was there that she was discovered by a photographer, and soon after that her modeling career took flight. One of her first ever modeling jobs was being cast as an alternate for the popular game show Deal or No Deal. Since then she has modeled for brands spanning from Nike to Nine West. She has also appeared in several magazines, including Italian Vogue!

Chrissy is married to the super talented singer songwriter John Legend. They first met at one of his video shoots while he was ironing his clothes. They became friends after the shoot, and eventually John popped the question! Chrissy and John both have a very large social media following, and have captured the hearts of people everywhere. They also just welcomed their first child into the world.

Chrissy also loves to cook. She has her very own food blog, and she uses it as an outlet to express herself. She was actually featured in her own special on the cooking channel. How cool! She is also co-host of the very popular and very hilarious show: Lip Sync Battle!

Anyone who follows Chrissy on social media knows that she has a heart of gold, and is totally hilarious and charming. It is her great personality that helps her with the negativity of haters. She says that they used to get to her at first, but now she simply ignores them. I really think that she is someone that is so cool, carefree and that lots of people would love to be real life best friends with. 


-Lexi Brock, Project RACE Teens, President

photo credit:*

Time to Shop!


You can help Project RACE, a non-profit organization, by shopping at today. They will donate a small percentage of your sale to us to further our work for the multiracial community. IT DOES NOT COST YOU ANYTHING! Just go here


Charleston, South Carolina

Today we are sending our thoughts and prayers to the community of Charleston, South Carolina. The multiracial community continues to hope for healing for the families,  friends, and members of the congregation. We will continue to fight against racism wherever it occurs.


An Open Letter to the Multiracial Community

by  Susan Graham for Project RACE

I spent two days recently involved in a meeting of the National Advisory Committee on Racial, Ethnic, and Other Populations. Call them NAC, as in they have a knack, except they don’t. I had my usual reaction to their meetings. I’ll explain to you how they go.

They start with almost three hours of opening remarks, executive remarks, and a short 2020 Census update. They pat each other on the back and tell everyone what they and others did during the last six months when they last met. I intentionally skip the first three hours, so I’m already ahead. OK, now down to some real work. Oops, it’s lunch time!

After lunch, everyone was ready for a siesta, but there was work to be done. Presenters came up to the front of the room with their slideshows in hand. One woman made a very strong point of saying things like “we use actual people!” and “….again, real people.” Lest we forget about the fake people they must use to project inaccurate data.

What stood out for me was that everyone there was supposedly a hand-picked expert on race and ethnicity and was there to speak of group issues. However, they all drew on their own races or ethnicities. From the long-haired woman who talked about Hawaiians, to the white woman staunchly advocating for American Indians, to the slow-talking man who represented the MENA (Middle Eastern North African) group, they each pushed their own agenda.

The problem for the multiracial population is that there was no one there to represent us. I always expect to see at least someone else from the multiracial groups there, but no—never. Eric Hamako, who was on the NAC at one time, did nothing when he was there and even less since. The Internet is filled with groups that claim to represent multiracial people, so where are they? By the way, Project RACE not only spent two days listening, but sent a statement, which was disseminated to all the committee members.

It is beyond me how the Census Bureau holds a two-day meeting on race and ethnicity and says so little. I don’t know how or why they do that. I do remember one thing I heard from Nicholas Jones, Census Bureau Race Guru, “We have ongoing dialogue with OMB.” I’m glad they have that ongoing dialogue, because we sure don’t. The Office of Management and Budget (OMB) is staying very quiet and all we know is that this committee and the Census Bureau will have their recommendations to OMB sometime in 2016.

Then what happens? This is very important. The multiracial population has one last chance to get our recommendations heard by OMB. One last chance. OMB and NAC have already received over 4500 letters from the MENA community. The only way to let OMB and the Census Bureau know that we want them to use the respectable term “multiracial,” is to have a letter writing campaign. Unless we, the multiracial community, can pull together, as we did in the 1990s, and come to some way to do this thing together, don’t count on any letters. That would truly be a shame.

Some individuals in the multiracial community do not understand what the government has to do with race and ethnicity, and why we should worry about a box on the census form. As one individual said about multiracial people in one group, “ They are more concerned about checking off a box under the term “multiracial” rather than being concerned about the practical implication of that. I for one do not need a box on the Census to validate my identity.” Checking a box on the census is not meant to validate racial identity. This poor fella is so mislead. Many people who came before him and laid the groundwork for multiracial gains would be turning over in their graves to see how he has twisted the meaning and work of the multiracial advocacy.

I don’t care all that much about the boxes on the census, which happens every ten years. It’s what happens between those years and how the boxes affect people’s perceived identity that matters. When OMB decides on racial categories and nomenclature, it does so for each and every government agency. It affects the forms that are used not only by the Census Bureau, but when we apply for jobs, finance our homes and our cars, drive, go to the hospital and on and on. It affects dollars our communities get and the terminology other people use to describe us, especially our children. Every minority group in America “gets” how important it is, even though one multiethnic person in Southern California obviously doesn’t get it.

Therefore, I am stating that Project RACE will work with any organization or individual to add the term “multiracial” in some way to the 2020 Census. All you have to do to receive important notifications is put yourself on the email list at our website It’s up to you now.


FYI-Official Business

Below are the abbreviated comments from Project RACE in response to the current Federal Register notice regarding the 2020 Census. The comments were submitted on January 14, 21015. We are awaiting confirmation notification. Staying current with the planning for the 2020 Census and drafting responses to official notices is just one of the things Project RACE does for the multiracial community.


January 14, 2015

Re: Comments on 2015 National Content Test

Project RACE (Reclassify All Children Equally) respectfully submits the comments below regarding the 2015 Optimizing Self-Response and Census Tests. We are the national advocates for multiracial children and their families. We are often rendered invisible by federal agencies in the discussions and planning for racial and ethnic classifications. We are concerned with ways to enhance the quality, utility, and clarity of the information to be collected in the 2020 Census regarding race and ethnicity.

As you know, the 2000 Census partially accommodated multiracial respondents by allowing us to check more than one racial box. The request by the multiracial community to use the preferred term “multiracial” was denied then and for the 2010 Census. As a result, multiracial respondents who checked more than one race are called “MOOMs” (Check One Or More), “Two or More Race People,” or “In Combination” respondents for purposes of tabulation. Tabulation wording does influence common usage because it is a descriptor of the total numbers.

OMB advised federal agencies to utilize “in combination” in its guidance for federal data on race and ethnicity in December, 2000. However, there has been much confusion about the nomenclature since 1997 when OMB specified, “When the primary focus of a report is on two or more specific identifiable groups in the population, one or more of which is racial or ethnic, it is acceptable to display data for each of the particular groups separately and to describe data relating to the remainder of the population by an appropriate collective description.”

Our requests for utilizing the word “multiracial” on the federal forms has been denied, even though it is important for multiracial children to see a descriptive word for themselves that is correct, respectful, and accurate. We work with many schools, medical facilities, clinical trials, etc. that do use the term “multiracial” on the forms with these directions: If you are multiracial, you may select two or more races. We would like to see testing of this wording on the instructions for the 2020 Census. Census Bureau personnel have indicated that will not happen. We have not been given any reason and our suggestion was not tested.

The instructions for indicating a person’s races are critical to the clarity of the category, which can affect the total numbers of people across all racial classifications. The multiracial population needs assurance that we will not lose numbers based on how the question is asked. “Mark X one or more boxes” proved to be confusing. Our hope is that the testing of “Mark all boxes that apply…note, you may report more than one group” will prove more effective for the multiracial population.

It would be very meaningful to the multiracial population if the appropriate term is at the very least used for tabulation, replacing “in combination.” Ironically, the Census Bureau often uses the term “multiracial” when discussing this population and in presentations, but not in its “official” data collection. If you seek clarity, the term “alone” should be dropped or changed to “racial,” and the term “in combination,” should be changed to “multiracial.” To give an example, consider that the decisions of the OMB and Census Bureau are often reflected by the media. When we see a racial and ethnic pie chart in a newspaper or Internet story, we want to see the multiracial community represented as “multiracial,” not “combination people” or “other.” Both OMB and Census personnel know perfectly well that proper nomenclature is extremely important when used to describe race and ethnicity, yet it is completely disregarded when it comes to only one population group—multiracial.

Additionally, it is reprehensible that OMB Bulletin No 00-02, Guidance on Aggregation and Allocation of Data on Race for Use in Civil Rights Monitoring and Enforcement (March 9, 2000) sets forth racially insensitive instructions in its EEO Enforcement instructions, whereby a person who checks more than one race is assigned to one of their minority races. Discrimination is often the result of a person designating more than one race, and to be reassigned to one race only defeats the purpose of enforcement of Title VI of the Civil Rights Act of 1964. Unfortunately, we see cases where multiracial children are bullied because they are multiracial, and they have no protection in that eventuality under the OMB guidelines.

We ask that these issues be revisited in testing for the 2020 Census. Changing “in combination” to “multiracial” would mean government acceptance of a word that is very widely used by non-governmental entities. It would also indicate sensitivity for proper nomenclature that is given to other racial groups, which we have been asking for since 1990. Any consideration that can be given to this demographic group that is rapidly and substantially increasing would be appreciated by the multiracial community.



Susan Graham

Executive Director

Project RACE




















A Heads Up to the Multiracial Community-IMPORTANT

A Heads Up to the Multiracial Community-IMPORTANT



Not all leadership in the Multiracial Community are looking out for your best interests. Be very careful. One “leader” took a position recently about a report that came out by an unofficial source, a slick report called “Race and Ethnicity in the 2020 Census: Improving Data to Capture a Multiethnic America.” What’s wrong with that? Plenty is wrong in the 36-page tome and who is promoting it.

First, the small collaboration that supports this report is made up of three small organizations: The Leadership Conference Educational Fund (LCEF), Asian Americans Advancing Justice (AAJC), and the National Latino Elected and Appointed Officials (NALEO).

Let’s look at the LCEF. Its president and CEO is Wade Henderson. Gosh that name sounds familiar! Ohhhhhh, wait, Henderson was the Washington Bureau director of the NAACP back when we were fighting for a place at the table and for multiracial people. He was adamantly against a multiracial box and/or multiple check-off boxes.

The AAJC is afraid of losing population numbers, just like the rest of us. I’m not sure they belong on this bandwagon except when it comes to adding Asian sub-identifiers.

NALEO is Arturo Vargas’ organization. Uh oh, his name is familiar, too. He’s on the National Advisory Committee on Racial, Ethnic, and Other Populations. Arturo is a likeable guy—unless you cross him and/or the Hispanic population. They do deserve a place on the NAC Committee, and in this report, although it is just another reminder that the Census Bureau is really running the show instead of the Office of Management and Budget (OMB), where the decisions on race and ethnicity are really made. Arturo is the guy to do this, and we’re glad they didn’t choose somebody else like a Hispanic/Latino advocate who is pretending to represent the multiracial community.

Speaking of the Census Bureau, Terri Ann Lowenthal was the principal author of the report. Big surprise (yawn). Terri Ann was a staffer for Representative Thomas Sawyer during the 1990s. She was no friend of the multiracial community, although she shared with me once that she had a “mixed” kid. She left the government so that she could work for the government. Yes, you read that right. She became a kind of consultant to OMB, the Census Bureau. She is a good soldier and writes whatever the bureaucrats want her to write.

One more interesting thing about this report is that “the staff of the U.S. Census Bureau” helped with this report. OK, so the usual suspects are in bed together again and still. Business as usual. Just don’t get too cozy thinking this is an independent undertaking.

I’ve read the report—twice, so you don’t have to, It’s a big report in very small type, but I urge you to come to your own conclusions. You can read it here:

My job is to go through these things for you and report the truth. I have highlighted the most important parts. I do believe that anyone commenting on the report should read it thoroughly and report back to the multiracial community on those things that concern us, not only one race or ethnicity (i.e. the Hispanic question). So here we go.

First, the writers pat everyone on the back. They applaud everyone from A to Z, but that’s the custom. If you ever get a chance, listen to any Census Bureau Internet webcast and hear it for yourself. You’ll feel like a Dallas Cowboy Cheerleader.

I will say that the report gives excellent background on the history of the U.S. Census until it gets to page 4, which is also the first of only a handful of times the word “multiracial” is used. The point of reading through all the text is to get to the standards that were set by the 2000 census, but then comes the BIG OMISSION: it gives the five racial categories and two ethnicity questions, and doesn’t as much as mention the big deal of checking two or more races! Trust me, it was the question leading up to the 2000 census, and they completely overlook it in an important place in the report.

So what does this all mean to us? It means that sometime between September, 2015 and April 1, 2017, revisions could (and let’s face it, will) set off an OMB review. They do this via a Federal Register notice, which will only be seen by those OMB intends for it to seen by. We are not on their list. Why? Because the one guy, Brian Harris-Kojetin, who handles these things at OMB will not answer our calls and emails. Hmmpffff, we’ve been ignored by bigger people! Like Nicholas Jones, who is the Chief of Racial and Ethnic whatever at the Census Bureau. The multiracial community is precisely the kind of stakeholder that should be notified so we can write letters.


They talk about AQE testing, which is yet another acronym for something that means testing. OK, I can share. It stands for Race and Hispanic Origin Alternative Questionnaire Experiment. They go into requests for new categories (i.e. MENA, which stands for people of Middle Eastern and North African descent), voting rights, redistricting, employment, education, fair housing, healthcare, poverty, and even criminal justice and how they are all affected by clarity in civil rights. They sum it up thusly: “First, for purposes of implementing and enforcing many civil rights laws—especially in the voting rights arena—data on the Hispanic or Latino population are treated on par with data on the five race groups, experts note.” Wait a minute. Where are the multiracial groups, which they refer to as “combination people”? Oh, that’s right. They don’t take our group into consideration for civil rights matters.

Stay with me now. Here it comes. Right on page 17:


“The updated Education Department categories do

not ask Hispanics to report a race; they also collapse

multiple race responses into one, unspecific category of

“Two or more races,” instead of assigning multiracial

individuals to their respective race choices.(Endnote 65) The latter

practice is especially worrisome to civil rights data users,

given the growth in the multiracial and multiethnic

populations. The percentage of the population reporting

multiple races grew by nearly a third (32 percent) between

2000 and 2010, compared to an overall 10 percent

growth in the U.S. population.(Endnote 66) Failure to capture multiple

race responses as part of specific race groups can

adversely affect the ability of educational institutions to

meet minority student enrollment thresholds under various

education programs.”


Do we really need to be reminded of what a mess the Department of Education (DOE) made with their interpretation of OMBs guidelines and the fact that OMB left enough loopholes land for them to do this? They don’t even mention that the Census Bureau not only collapses multiple race responses into one, unspecified category of “Two or more races,” but calls us Two or More Race (TOMR!!) people. This entire paragraph is unnecessary unless the authors are looking to follow DOEs horrible civil rights injustices like taking students who check Hispanic and anything else and making them only Hispanic. They conclude that: “Civil rights advocates note that census race and ethnicity data are the most comprehensive, objective tool for understanding the intersection of issues that can be barriers to equality of opportunity and social justice.” Oh yes! We get that, but are we included? Not so much.

We finally get to the RECOMMENDATIONS chapter. What are these folks trying to get to? What do they want to see? Let’s look at the question of whether there should be a combined format question. It’s really none of our business with the exception of whether they would retabulate the Hispanic numbers into only one category, in which case, it certainly is our business because we would lose numbers. We can play this game, too, if only we were invited to play. On the MENA question, again, not our business unless….By the way, if they decide not to add the MENA category, watch them blame us–little, insignificant in every other way, us.

There it is: our BIGGEST problem. They don’t have any recommendations about the multiracial community. They don’t address the evil retabulation. They don’t say a word about our request to be recognized respectfully as “multiracial,” and not “combination people,” “Two or More Races” (TOMR) folks, or their other name, the “Mark One or More” (MOOM) population.

My very favorite paragraph of the entire report comes on page 19:


“Stakeholder Engagement

  1. The Census Bureau and OMB should keep civil rights

stakeholders apprised of research and testing plans and

outcomes, and establish opportunities for meaningful

and timely dialogue and consultation with civil rights

leaders, experts, and organizations, before key decisions

are made with respect to the 2020 census race and

ethnicity questions and the Standards for Classification

of Federal Data on Race and Ethnicity and related

implementation guidance.”


We’re civil rights stakeholders. All I could note in the space next to that paragraph is, “NO SHIT.”

There are 17 recommendations in all. But the endnotes are fun, too. For example, the report refers to a day-long roundtable in July 2014 hosted by the three organizations that ordered this report. It refers to them as “respected” civil rights yada, yada, yadas, Endnote 4 adds this tidbit:

The July 31, 2014, roundtable, “Race and Ethnicity

Data in the 2020 Census: Ensuring Useful Data

for Civil Rights Purposes,” was an invitation-only,

closed door, and off-the-record event. It took place in

Washington, DC.”


OK, full disclosure, but come on! It sure sounds like they are pretty proud of their special invitation only, closed door, and off-the-record selves. I certainly understand how multiracial population leaders would not want to do the in-depth work to detangle this mess. Yes, this is still about the multiracial group. We don’t mind playing bad cop to a good cop, as long as that cop is doing the same in-depth work that we’re doing. It’s only fair.

Susan Graham

Executive Director

Project RACE



Important CENSUS Information

Important Census Information

 Today I attended a meeting of the National Advisory Committee on Racial, Ethnic, and Other Populations. It was an important meeting for the multiracial population because recommendations were made for future testing for the 2020 CENSUS.

I was able to have a letter to the committee included in the meeting records and was given the opportunity to give a very brief oral statement to the committee. This was the statement I gave on behalf of the multiracial population:

 Meeting Comments

Susan Graham, Project RACE

 Only one item concerning the multiracial population was addressed in the handouts from the March meeting: multiracial respondents are not always aware they have the option to select more than one race. I will address solutions for this item in my allotted time, and ask you to also read my written letter to this committee in full, which addresses additional issues.

The instructions for race selection on the AQE and 2010 Census were the same:

Mark (x) one or more boxes.

Project RACE works to ensure that multiracial children and our families have forms that reflect appropriate, respectful, and dignified terminology. Concise and very simple, we do not disturb any data or cause any changes in tabulation. We have had extremely positive feedback for our preferred instructions, which are:

Mark one. If you are multiracial, you may select two or more.

In the 1990s, we were advised by OMB to choose one word to describe people who are of more than one race. We agreed on the same word along with other advocates. That word was “Multiracial.” Yes, times change, nomenclature changes, public preferences change, but the preferred term is still Multiracial. It is not “Mark Two or More Races” people, or the “Race in Combination” population.

Some possible changes are being tested in the race category, one of which is to add the Hispanic/Latino option. The instructions could then be:

Mark one. If you are multiracial or multiethnic, you may select two or more.

Isn’t America truly becoming multiracial and multiethnic? Why not use accurate and respectful terminology beginning with the 2020 Census? Project RACE urges you to include our model in further testing.


Multiracial Community Slammed by Census Bureau

Census Bureau Slams Multiracial Community
Multiracial people are non-existent at the federal level of government in the United States. A new 31 person Census Advisory Committee was announced late last week, which EXCLUDES anyone from the multiracial advocacy community or even the academics who write about the multiracial experience.
The committee will advise the Census Bureau about racial and ethnic and “other populations.” Represented on the committee include the following populations:
  • Blacks or African-Americans
  • Hispanics/Latinos
  • Middle Easterners
  • Asians
  • Native Hawaiians/Pacific Islanders
  • American Indians
  • Alaska Natives
  • Homeless
  • Young Children
  • Poverty
  • Social Justice, but not for the multiracial community
  • LGBT Health
  • Privacy advocacy
  • Education
The committee is filled with social policy people, psychologists, social workers, academics and people who have been the darlings of the Census Bureau for years and years. The entire multiracial community should be aware of this and be willing to advocate for the rights of multiracial people in Washington. It would be great if the academics who study the multiracial community actually do something for it. Talk and/or take action, your choice.
We have been in contact with United States Senator Dianne Feinstein about the multiracial community being dismissed by the Census Bureau and OMB, but the Senator has no comment at this time. She is up for reelection and is apparently very busy holding fundraisers; too busy to worry about multiracial children. We urge you to contact your elected officials in Washington, let them know about this situation with the Census Bureau and OMB, and ask for them to represent multiracial children, teens, adults and our families.
Susan Graham
Executive Director
Project RACE