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.

 

Sincerely,

Susan Graham

Executive Director

Project RACE