Standards for the Classification of Federal Data on Race and Ethnicity

Federal RegisterJun 9, 1994

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OFFICE OF MANAGEMENT AND BUDGET

Standards for the Classification of Federal Data on Race and

Ethnicity

AGENCY: Executive Office of the President, Office of Management and

Budget (OMB), Office of Information and Regulatory Affairs

ACTION: Advance Notice of Proposed Review and Possible Revision of

OMB's Statistical Policy Directive No. 15, Race and Ethnic Standards

for Federal Statistics and Administrative Reporting; and Announcement

of Public Hearings on Directive No. 15.

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SUMMARY: During the past few years, OMB's Statistical Policy Directive

No. 15, Race and Ethnic Standards for Federal Statistics and

Administrative Reporting, has come under increasing criticism. These

standards are used governmentwide for recordkeeping, collection, and

presentation of data on race and ethnicity in Federal statistical

activities and program administrative reporting. Since the standards

were first issued 17 years ago, citizens who report information about

themselves and users of the information collected by Federal agencies

have indicated that the categories set forth in Directive No. 15 are

becoming less useful in reflecting the diversity of our Nation's

population. Accordingly, OMB currently is undertaking a review of the

racial and ethnic categories in the Directive. (See Appendix for the

text of Directive No. 15.)

ISSUES FOR COMMENT: OMB is interested in receiving comments from the

public on (1) the adequacy of the current categories, (2) principles

that should govern any proposed revisions to the standards, and (3)

specific suggestions for changes that have been offered by various

individuals and organizations.

ADDRESS: Written comments on these issues may be addressed to Katherine

K. Wallman, Chief, Statistical Policy, Office of Information and

Regulatory Affairs, Office of Management and Budget, 725 17th Street,

NW., Washington, DC. 20503.

DATE: To ensure consideration, written comments must be provided to OMB

on or before September 1, 1994.

PUBLIC HEARINGS: To provide additional opportunities to hear views from

the public on Directive No. 15, OMB has scheduled a series of hearings,

as follows:

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Date/Time Location

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July 7, 1994 Thomas P. O'Neill, Jr. Federal Building Auditorium

10:00 a.m. 10 Causeway Street

Boston, Massachusetts

(Local arrangements contact: Harold Wood, Bureau of the

Census Regional Office, (617) 424-0500)

July 11, 1994 State Capitol Building

10:00 a.m. Old Supreme Court Chambers

200 East Colfax Street

Denver, Colorado

(Local arrangements contact: Jerry O'Donnell, Bureau of

the Census Regional Office, (303) 969-7750)

July 14, 1994 Federal Reserve Bank of San Francisco

10:00 a.m. Interpretive Center

101 Market Street

San Francisco, California

(Local arrangements contact: Vicki Cooper-Murphy, Bureau

of Labor Statistics Regional Office, (415) 744-7166)

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If you wish to present an oral statement at any of these hearings,

please contact the Statistical Policy Office (at the address below) by

telephone or fax (do no use electronic mail) by July 1, 1994, and

provide the following information: your name, address, telephone and

fax numbers, and the name of the organization which you represent.

After July 1, please call the appropriate local arrangements contact

identified above to be placed on the hearing schedule. Persons

testifying are asked to bring three (3) copies of their statement to

the hearing. Written statements will also be accepted at the hearings.

Depending on the number of persons who request to present their views,

the hearings in each location may be extended to the following day.

ADDRESS: Requests to be placed on the hearing schedule should be

directed to the Statistical Policy Office, Office of Management and

Budget, 725 17th Street, N.W., Washington, D.C. 20503. Telephone: (202)

395-3093. Fax number: (202) 395-7245.

ELECTRONIC AVAILABILITY AND COMMENTS: This document is available on the

Internet via anonymous File Transfer Protocol (ftp) from ftp.census.gov

/pub/docs/ombdir15.txt in ASCII format (do not use any capital letters

in the file name). For those who do not have ftp capability, the

document can also be obtained through the gopher (gopher

gopher.census.gov) and HTTP servers (accessible by mosaic, cello, lynx,

etc.), or by sending an electronic mail message to [email protected]

with the following lines in the message area:

open

get/pub/docs/ombdir15.txt

quit

Comments may be sent via electronic mail to an OMB x.400 mail

address, which is /s=ombdir15/c=us/admd=telemail/prmd=gov+eop. The

Internet address is [email protected]. Comments sent to this

address will be included as part of the official record. Do not use

this electronic mail address to have your name included in the hearing

schedule.

For assistance using electronic mail, ftp, gopher, or HTTP, please

contact your system administrator. You may also want to send an

electronic message to [email protected] with a subject of HELP and

nothing in the message area. You will receive by return electronic mail

``FAQ (Frequently Asked Questions)'' and more information on how to

access the services on census.gov.

FOR FURTHER INFORMATION CONTACT: Suzann Evinger, Statistical Policy

Office, Office of Information and Regulatory Affairs, Office of

Management and Budget, Telephone: (202) 395-3093.

SUPPLEMENTARY INFORMATION:

Background

Development of Directive No. 15.--Developmental work on the

categories in OMB's Directive No. 15 originated in the activities of

the Federal Interagency Committee on Education (FICE), which was

created by Executive Order in 1964. More than 30 Federal agencies were

members or regular participants in FICE's work to improve coordination

of educational activities at the Federal level. The FICE Subcommittee

on Minority Education completed a report in April 1973 on higher

education for Chicanos, Puerto Ricans, and American Indians and sent it

to then Secretary of Health, Education, and Welfare (HEW) Caspar

Weinberger for comment. He showed particular interest in the portion of

the report that deplored the lack of useful data on racial and ethnic

groups. Further, he encouraged the implementation of the report's

second recommendation which called for the coordinated development of

common definitions for racial and ethnic groups, and the Federal

collection of racial and ethnic enrollment and other educational data

on a compatible and nonduplicative basis.

In June 1974, FICE created an Ad Hoc Committee on Racial and Ethnic

Definitions whose 25 members came from Federal agencies with major

responsibilities for the collection or use of racial and ethnic data.

This Ad Hoc Committee was charged with developing terms and definitions

for the collection of a broad range of racial and ethnic data by

Federal agencies on a compatible and nonduplicative basis. It took on

the task of determining and describing the major groups to be

identified by Federal agencies when collecting and reporting racial and

ethnic data. While the Ad Hoc Committee recognized that there is

frequently a relationship between language and ethnicity, it made no

attempt to develop a means of identifying persons on the basis of their

primary language. The Ad Hoc Committee wanted to ensure that whatever

categories the various agencies used could be aggregated,

disaggregated, or otherwise combined so that the data developed by one

agency could be used in conjunction with the data developed by another

agency. In addition, the Ad Hoc Committee thought that the basic

categories could be subdivided into more detailed ethnic subgroups to

meet users' needs, but that to maintain comparability, data from one

major category should never be combined with data from any other major

category.

In the spring of 1975, FICE completed its work on a draft set of

categories, and an agreement was reached among OMB, the General

Accounting Office (GAO), the HEW's Office for Civil Rights, and the

Equal Employment Opportunity Commission (EEOC) to adopt these

categories for a trial period of at least one year. This trial was

undertaken to test the new categories and definitions and to determine

what problems, if any, would be encountered in their implementation.

At the end of the test period, OMB and GAO convened an Ad Hoc

Committee on Racial/Ethnic Categories to review the experience of the

agencies that had implemented the standard categories and definitions

and to discuss any potential problems that might be encountered in

extending the use of the categories to all Federal agencies. The

Committee met in August 1976 and included representatives of OMB; GAO;

the Departments of Justice, Labor, HEW, and Housing and Urban

Development; the Bureau of the Census; and the EEOC. Based upon the

discussion in that meeting, OMB prepared minor revisions to the FICE

definitions and circulated the proposed final draft for agency comment.

These revised categories and definitions became effective in September

1976 for all compliance recordkeeping and reporting required by the

Federal agencies represented on the Ad Hoc Committee.

Based upon this interagency agreement, OMB drafted for agency

comment a proposed revision of the race and ethnic categories contained

in its circular on standards and guidelines for Federal statistics.

Some agencies published the draft revision for public comment.

Following the receipt of comments and incorporation of suggested

modifications, OMB on May 12, 1977, promulgated for use by all Federal

agencies the racial and ethnic categories now contained in Directive

No. 15, the text of which appears in the Appendix. This meant that for

the first time, standard categories and definitions would be used at

the Federal level in reporting and presentation of data on racial and

ethnic groups. While OMB requires the agencies to use these racial and

ethnic categories, it should be emphasized that the Directive permits

collection of additional detail if the more detailed categories can be

aggregated into the basic racial and ethnic classifications set forth

in the Directive.

As demonstrated by this brief history, the present categories were

developed through a deliberate cooperative process; participation of

the agencies that use the categories was an essential element in that

process.

1988 Proposed Revision.--The standards promulgated in 1977 have not

been revised since that time. OMB did, however, publish in the January

20, 1988, Federal Register a draft Statistical Policy Circular

soliciting public comment on a comprehensive revision of existing

Statistical Policy Directives. Among the proposed changes was a

revision of Directive No. 15 that would have added an ``Other'' racial

category and required classification by self-identification. While this

proposal was supported by many multi-racial and multi-ethnic groups and

some educational institutions, it drew strong opposition from Federal

agencies such as the Civil Rights Division of the Department of

Justice, the Department of Health and Human Services, the EEOC, and the

Office of Personnel Management, and from large corporations.

Respondents who opposed the change asserted that the present system

provided adequate data, that any changes would disrupt historical

continuity, and that the proposed change would be expensive and

potentially divisive. Some members of minority communities interpreted

the proposal as an attempt to provoke internal dissension within their

communities and to reduce the official counts of minority populations.

Because it was evident from all of these comments that this proposal

would not be widely accepted, no changes were made at the time to

Directive No. 15.

1993 Hearings.--During 1993, Congressman Thomas C. Sawyer, Chairman

of the House Subcommittee on Census, Statistics, and Postal Personnel,

held a series of four hearings (April 14, June 30, July 29, and

November 3) on the measurement of race and ethnicity in the decennial

census. OMB testified at the hearing on July 29. Information on these

hearings may be obtained by contacting the Subcommittee at (202) 226-

7523.

Workshop.--As a first step in undertaking its review of the racial

and ethnic categories, OMB asked the Committee on National Statistics

(CNSTAT) of the National Academy of Sciences to convene a workshop to

provide an informed discussion of the issues surrounding a review of

the categories. Convened on February 17-18, 1994, the workshop included

representatives of Federal agencies, academia, social science research,

interest groups, private industry, and local school districts. A report

on the workshop will be forthcoming from CNSTAT.

Interagency Committee. OMB has established an Interagency Committee

for the Review of the Racial and Ethnic Standards, whose members

represent the many and diverse Federal needs for racial and ethnic

data, including statutory requirements for such data. The Committee

will be an integral part of this review process, by assisting OMB in

the evaluation and assessment of proposed changes, for example, on the

quality of resulting data and costs of implementation.

Suggested Changes and Criticisms

Your comments are invited on any aspect of Directive No. 15; if you

are satisfied with the existing racial and ethnic categories, it would

be useful for OMB to know that also. You may also wish to comment on

the following suggestions and criticisms about the Directive that OMB

received during the recent hearings and the CNSTAT workshop:

--adding a ``multi-racial'' category to the list of racial

designations so that respondents would not be forced to deny part of

their heritage by having to choose a single category;

--adding an ``other'' category for individuals of multi-racial

backgrounds and those who want the option of specifically stating a

unique identification;

--providing an open-ended question to solicit information on race

and ethnicity, or combining concepts of race, ethnicity, and ancestry;

--changing the name of the ``Black'' category to ``African

American'';

--changing the name of the ``American Indian or Alaskan Native''

category to ``Native American'';

--including Native Hawaiians as a separate category or as part of a

``Native American'' category (which would also include American

Indians, Aleuts, and Eskimos), rather than as part of the ``Asian or

Pacific Islander'' category;

--including Hispanic as a racial designation, rather than as a

separate ethnic category; and

--adding a ``Middle Easterner'' category to the list of ethnic

designations.

The critiques of the current standard and the proposals for change

include as well a number of other concerns. For example:

--The categories and their definitions have been criticized for

failing to be comprehensive and scientific. As cases in point, using

the present definitions there are no proper categories for the original

Indian population of South America or for Australian aborigines.

--Some have suggested that the geographic orientation of the

definitions for the various racial and ethnic categories is not

sufficiently definitive. They believe that there is no readily apparent

organizing principle for making such distinctions and that definitions

for the categories should be eliminated. Others disagree, stating that

the current definitions of the racial and ethnic categories have served

their uses well and thus should be maintained.

--The identification of an individual's racial and ethnic

``category'' often is a subjective determination, rather than one that

is objective and factual, no matter what the process for arriving at

the categories. Consequently, it has been suggested that it may no

longer be appropriate to consider the categories as a ``statistical

standard.''

--The issue of self-identification of race and ethnicity versus

third party identification also has been raised. This issue will merit

increased attention if multi-racial and/or multi-ethnic categories or

identification procedures are adopted.

--Some have proposed eliminating the five-category combined racial

and ethnic classification in favor of separate, mutually exclusive,

racial and ethnic categories. The combined format now permitted by the

Directive is particularly suitable for observer identification, and is

used by the Department of Health and Human Service's Office for Civil

Rights, the Equal Employment Opportunity Commission, and the Office of

Federal Contract Compliance because it facilitates aggregating data on

the minority groups with which these agencies are concerned. The use of

the Hispanic category in the combined format does not, however, provide

information on the race of those selecting it. As a result, the

combined format makes it impossible to distribute persons of Hispanic

ethnicity by race and, therefore, reduces the utility of the four

racial categories by excluding from them persons who would otherwise be

included. Thus, the two formats currently permitted by Directive No. 15

for collecting racial and ethnic data do not provide comparable data.

--The perceived importance of historical comparability of racial

and ethnic data has been questioned by some. Since the names of the

categories have changed in the decennial censuses, and agencies use

different methods even internally to collect the data, there is less

continuity in racial and ethnic data than many believed. As a result,

it has been suggested that this review of Directive No. 15 should have

a more forward-looking approach, rather than being bound by past

history.

--Some have suggested that consideration be given to collecting

racial and ethnic data using ``categories for response'' that can be

decoupled from ``categories for reporting data.'' For example, the

response categories could permit responses reflecting multiple origins;

later these data would be aggregated into reporting categories

following a set of standards and guidelines to make the reported data

more useful for various program, administrative, and statistical

purposes.

--There have also been suggestions that the classification of

persons by race and ethnicity be eliminated entirely. Proponents of

this view assert that the categories merely serve to perpetuate an

over-emphasis on race in America and contribute to the fragmentation of

our society.

Federal Uses of Racial and Ethnic Data

Given the broad range of suggestions and criticisms, OMB believes

that a comprehensive review of all the categories is warranted. It is

important to stress comprehensive, because these categories are not

used simply for statistical purposes. Thus, while the use of the racial

and ethnic categories in the collection of decennial census data is

most widely known--and has most often been cited in the 1993 hearings

and in the correspondence OMB receives--the categories are also used by

Federal agencies for civil rights enforcement and for program

administrative reporting. Some important examples of the Federal

Government's uses of racial and ethnic data are:

enforcing the requirements of the Voting Rights Act;

reviewing State redistricting plans;

collecting and presenting population and population

characteristics data, labor force data, education data, and vital and

health statistics;

establishing and evaluating Federal affirmative action

plans and evaluating affirmative action and discrimination in

employment in the private sector;

monitoring the access of minorities to home mortgage loans

under the Home Mortgage Disclosure Act;

enforcing the Equal Credit Opportunity Act;

monitoring and enforcing desegregation plans in the public

schools;

assisting minority businesses under the minority business

development programs; and

monitoring and enforcing the Fair Housing Act.

These examples of statutory requirements are mentioned to foster

public awareness and understanding of the Federal Government's many

different needs for racial and ethnic data. Appreciation of the

intended uses of the data helps determine what categories make sense.

Further, these uses need to be taken into account when changes to the

categories are suggested. In any event, OMB believes that it is

essential for the Federal agencies to study the possible effects of any

proposed changes to the categories on the quality and utility of the

resulting data for a multiplicity of purposes.

General Principles for the Review of the Racial and Ethnic