OMB HOME • FEDERAL REGISTER NOTICES
Standards
for the Classification of
Federal Data on Race and Ethnicity
August
1995
AGENCY: Executive
Office of the President, Office of Management and Budget (OMB), Office
of Information and Regulatory Affairs
ACTION: Interim
Notice of Review and Possible Revision of OMB's Statistical Policy
Directive No. 15, Race and Ethnic Standards for Federal Statistics
and Administrative Reporting: Summary and Analysis of Public Comments
and Brief Discussion of Research Agenda
Summary: In
1977, OMB issued the Race and Ethnic Standards for Federal Statistics
and Administrative Reporting that are set forth in Statistical Policy
Directive No. 15. The standards in this Directive have been used for
almost two decades throughout the Federal government for recordkeeping,
collection, and presentation of data on race and Hispanic origin. The
standards have been used in two decennial censuses and in surveys of
the population, data collections necessary for meeting statutory requirements
associated with civil rights monitoring and enforcement, and in other
administrative program reporting.
During
the past several years, the standards have come under increasing criticism
from those who believe that the minimum categories set forth in Directive
No. 15 do not reflect the increasing diversity of our Nation's population.
Some have also proposed changing the names of some categories. In response
to the criticisms, OMB initiated a review of the Directive. As a first
step in this process, OMB asked the Committee on National Statistics
(CNSTAT) of the National Academy of Sciences to organize a workshop
to discuss issues to be addressed in the review. A report of the workshop,
held in February 1994, is forthcoming from CNSTAT. During 1994, the
review process also included (1) public hearings in Boston, Denver,
San Francisco, and Honolulu, (2) comment by Federal agencies on their
requirements for racial and ethnic data, (3) development of a research
agenda and related literature reviews, and (4) publication of a Federal
Register notice, 59 Fed. Reg. 29831 (1994). The June 9, 1994, notice
contained information on the development of the current standards and
requested public comment on: (1) the adequacy of current racial and
ethnic categories, (2) the principles that should govern any proposed
revisions to the standards, and (3) specific suggestions for change
that had been offered by individuals and interested groups over the
past several years. (See Appendix for the text of Directive No. 15.)
This Federal
Register notice (1) summarizes the suggestions for changes drawn from
public comments, research findings, and literature reviews, (2) briefly
discusses the research agenda for some of the significant issues that
have been identified, and (3) sets forth proposed principles to be
used in reaching a final decision on standards for the classification
of data on race and ethnicity. The issues, suggestions for change,
and pros and cons described in this notice are those raised in public
comment and do not reflect OMB positions or decisions. In addition
it should be noted that because the categories in Directive No. 15
have been useful for over 18 years for many purposes, an option under
consideration is to make no changes.
Important
dates in the balance of the review process are shown below. Various
agencies are conducting activities to support the review process; these
include work by the Bureau of the Census related to the 2000 Census
program mentioned below.
Fall
1995 |
OMB
analyzes Federal Register notice comments; receives results of
May 1995 CPS Supplement; continues to consult on options with
affected groups |
March
1996 |
Census
Bureau conducts National Content Test (NCT) in preparation for
2000 |
June
1996 |
Census
Bureau conducts Race and Ethnic Targeted Test (RAETT) in preparation
for 2000 Census |
November
1996 |
Bureau
of the Census provides test through January 1997 results from
National Content Test and Race and Ethnicity Targeted Test |
Spring
1997 |
OMB
publishes Federal Register notice on research results and proposed
decisions on changes, if any, to Directive No. 15 |
Mid-1997 |
OMB
publishes final decision regarding any changes to Directive No. 15 in a Federal Register notice |
ISSUES
FOR COMMENT: With this notice, OMB requests public comment on
the following: (1) are there any issues or options not listed that
should be considered before a final decision is made? (2) for each
option presented, are there additional pros and cons to consider?
(3) are there additional principles that should govern a final decision
on whether or how to revise the standards? and (4) which options
should be included for testing in 1996? This Federal Register notice
provides the last opportunity for public comment on priorities for
research in 1996.
All comments
received as a result of the June 9, 1994, notice have been reviewed
and considered in preparing this notice. It is not necessary to resubmit
comments sent previously.
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, NEOB, Room 10201, 725 17th Street,
N.W., Washington, D.C. 20503.
DATE: To
ensure consideration, written comments must be provided to OMB on or
before September 30, 1995.
ELECTRONIC
AVAILABILITY AND COMMENTS: This document is also accessible on
the U.S. Department of Commerce's FedWorld network under the
"OMB Library of Files." The Telnet address for FedWorld via
the Internet is fedworld.gov. The address (URL) for the World Wide Web
is http://www.fedworld.gov/ftp.htm#omb. For ftp access, ftp://fwux.fedworld.gov/pub/omb/omb.htm.
The telephone number for the FedWorld help desk is (703) 487-4608. For
assistance in using electronic mail, please contact your system administrator.
Comments
may be sent to OMB using the following Internet address: ombdir15(@)a1.eop.gov.
FOR
FURTHER INFORMATION CONTACT: Suzann Evinger, Statistical Policy
Office, Office of Information and Regulatory Affairs, Office of Management
and Budget, NEOB, Room 10201, 725 17th Street, N.W., Washington,
D.C. 20503. Telephone: 202-395-3093.
SUPPLEMENTARY
INFORMATION
A. Background
The United
States government has long collected statistics on race and ethnicity.
Such data have been used to study changes in the social, demographic, health,
and economic characteristics of various groups in our population. Federal
data collections, through censuses, surveys, and administrative records,
have provided an historical record of the Nation's population diversity
and its changing social attitudes and policy concerns. Since the 1960s,
data on race and ethnicity have been used extensively in civil rights monitoring
and enforcement covering areas such as employment, voting rights, housing
and mortgage lending, health care services, and educational opportunities.
These legislatively-based priorities created the need among Federal agencies
for compatible, nonduplicative data for the specific population groups
that historically had suffered discrimination and differential treatment
on the basis of their race or ethnicity. In response, the Office of Management
and Budget (OMB) issued in 1977 the "Race and Ethnic Standards for
Federal Statistics and Administrative Reporting" contained in Statistical
Policy Directive No. 15. These categories also implemented the requirements
of Public Law 94-311 of June 16, 1976, which called for the collection,
analysis, and publication of economic and social statistics on persons
of Spanish origin or descent. Hence, the population groups identified by
the Directive No. 15 racial and Hispanic origin categories reflected legislative
and agency needs, and not efforts by population groups to be specifically
identified.
In recent
years, Directive No. 15 has been criticized for not sufficiently
reflecting the Nation's diversity. In addition, some critics have
proposed changing the names of some categories. In a June 9, 1994,
Federal Register notice, OMB announced a review of Directive No. 15. As part of the review and public comment period, OMB held hearings
in Boston, Denver, San Francisco, and Honolulu. The June 9, 1994,
Federal Register notice contains additional background information
on the development of Directive No. 15; revisions proposed but not
made in 1988; congressional hearings before the House Subcommittee
on Census, Statistics, and Postal Personnel in 1993; a workshop conducted
by the Committee on National Statistics in 1994; work done by the
Interagency Committee for the Review of the Racial and Ethnic Standards;
and general principles for the review of the racial and ethnic categories.
In the
June 9, 1994, Federal Register notice, OMB cited specific concerns
the public had raised over the years regarding Directive No. 15. As
a result of the notice, the public commented on the need for new categories,
changes in current categories, whether racial and ethnic data should
be collected, legislative and programmatic needs for the data, and
the issue of self-identification versus observer identification. OMB
received nearly 800 letters in response to the 1994 Federal Register
notice and heard the testimony of 94 witnesses during the four public
hearings. OMB heard from a wide array of interested parties including
individuals, data users, and data providers from within and outside
the Federal Government.
This Federal
Register notice focuses primarily on the six major issues discussed
in comments from the public (Section B); the expected future research
agenda (Section C); and general principles for making a final decision
on standard racial and ethnic categories for Directive No. 15 (Section
D).
Historical
continuity of racial and ethnic data is important to many data users.
Over time, however, there have been variations in how the Nation's
principal population groups have been classified according to race
and ethnicity; such differences have occurred even within data sets.
In decennial censuses, for example, a question on race has been included
since 1790. There have been many changes in the broad racial categories,
the specific components of the categories, and whether data on ethnicity
were collected. Asian Indians, for example, were counted as "Hindus" in
censuses from 1920 to 1940, as "White" from 1950 to 1970,
and as "Asians or Pacific Islanders" in 1980 and 1990.
Numerous
studies reveal that identification of ethnicity is fluid and self-perceptions
of race and ethnicity change over time and across circumstances for
many people. This is especially true among persons with heterogeneous
ancestries. A study of the Current Population Survey showed 1 in 3
people reported an ethnicity in 1972 that was different from the one
they had reported in 1971. This level of inconsistency reflects the
fluidity of ethnicity as well as the effect of question design.
Major historical
inconsistencies in the data reflect social reality and public policy
as well as technical decisions by data developers. Most agree that
comparability over time is a desirable goal but that it is important
also to reflect changes in society as they occur. Thus, General Principles
9 and 10 (see section D below) call for conducting research before
any changes are made and for providing a crosswalk between old and
any new categories so comparisons can be made across time.
There are
also differences among data sets with respect to how race and ethnicity
are classified. On birth records, for example, the race of the baby's
mother and father are based on reports of the mother or family members.
The race of the baby, which is not reported on the birth record, was
once assigned for purposes of published statistics by an algorithm
based on the parents' races. Since 1989, however, the National Center
for Health Statistics has tabulated birth data according to the mother's
race. In censuses and surveys until 1970, racial data were usually
based on the observation of the government enumerator filling out the
questionnaire. Now, the usual practice is self-administered forms and
questionnaires, especially when the purpose of data gathering is to
obtain information on population characteristics. In the enforcement
of civil rights laws, however, the classification is often made by
employers or school administrators, and the observer's perception is
at issue. Whether someone is a victim of discrimination often turns
on the way in which others act on their perception of, for example,
the color of the individual's skin, the ethnic origin of his or her
last name, or the accent with which he or she speaks. Such issues do
not depend generally on the way in which the individual identifies
his or her racial or ethnic background. In sum, Federal data sets identifying
race and ethnicity are a mixture of self-identification by respondents
and the perceptions of observers.
Until the
current racial and ethnic standards were adopted in 1977, Federal data
collections used an assortment of definitions for broad racial categories.
In response to that problem, a Federal interagency committee recommended
development of common categories for racial and ethnic data. Directive
No. 15 provides a minimum set of standard categories and definitions
for presenting data on various racial and ethnic groups in our population.
The Directive requires compilation of data for four racial categories
(White, Black, American Indian or Alaskan Native, and Asian or Pacific
Islander), and an ethnic category to indicate Hispanic origin, or not
of Hispanic origin.
To date
evaluation of the quality of racial and ethnic data has been limited
to research conducted by the Bureau of the Census, the National Center
for Health Statistics (NCHS), and other parts of the Centers for Disease
Control and Prevention (CDC). Comparisons of data sets indicate high
consistency in individual responses for White and Black populations
(95 percent consistency) and for the Asian and Pacific Islander population
(90 percent consistency) in the 1990 census National Content Reinterview
Survey conducted by the Census Bureau. For American Indians and Alaskan
Natives, reporting is less consistent (63 percent consistency in the
1990 National Content Reinterview Survey). Reporting race is also less
consistent for multiple-race persons, Hispanics, the foreign born,
and persons who do not read or speak English well. NCHS found Asians
and American Indians are sometimes misreported as "White" on
death certificates, and this causes an underestimation of death rates
for these groups. Nevertheless, these data quality problems are not
so severe as to make the data unusable for most purposes.
Testimony
at the four public hearings in 1994 and letters to OMB requested data
on specific population groups that go beyond legislatively required
levels of detail. Some groups say they have suffered discrimination
in political and economic access but without data for their specific
population group, they feel that the discrimination is not recognized.
For others, the request for recognition of a particular nationality
group seems to be primarily a matter of pride and identification with
that population group.
Public
comment indicates self-identification is important to many people.
Some who commented requested different placement of their specific
group within a broad group. Many people of more than one race, who
under Directive No. 15 are told to choose one category that "most
closely reflects [their] recognition in [their] community," said
they wanted to reflect their full heritage, not just part of it.
B. Summary
of Issues and Suggestions Raised
in Public Comment; Research Findings
In the June
9, 1994, Federal Register notice, OMB asked for public comment 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.
This
section summarizes the public comment (including comments from Federal
agencies) that resulted from the June 9, 1994, Federal Register notice
as well as research findings related to the particular issues. In
an effort to be thorough in summarizing public comments the discussion
below of specific data collection and presentation categories (Issue
6) is necessarily lengthy.
The issues
and suggestions shown below are those raised in public comment and
do not reflect OMB positions or decisions. OMB will not make decisions
on the issues until mid-1997. The following six issues are discussed
in this section:
- ISSUE
1.
- Should
the Federal government collect data on race and ethnicity? Should
there be standards at all?
- ISSUE
2.
- Should
Directive No. 15 be revised? Should there be different collection
standards for different purposes?
- ISSUE
3.
- Should
"race/ethnicity" be asked as a single identification or should
"race" identification be separate from Hispanic origin or
other ethnicities?
- ISSUE
4.
- Should
self-identification or the perception of an observer guide the methods
for collection of racial and ethnic data?
- ISSUE
5.
- Should
population size and geographic distribution of groups be criteria
in the final decision of Directive No. 15 categories?
- ISSUE
6.
- What
should the specific data collection and presentation categories be?
This discussion includes a brief summary of public comments and previous
research findings. Briefly, suggestions that have been made include:
(a)
White (suggestions include adding categories for White ethnic
groups; adding a category for persons from the Middle East
or of Arab descent; and alternative wording for the category
name).
(b)
Black (suggestions include identification of geographic origin
of ancestors; adding a category for Creoles; and alternative wording
for the category name).
(c)
Asian or Pacific Islander (suggestions include having three separate
categories, one for Asians, one for Pacific Islanders, and one
for Native Hawaiians; adding a new category for original peoples
of acquired American lands ("indigenous populations")
that would include American Indians, Alaskan Natives, Native Hawaiians,
and native American Samoans and Guamanians; and specifying major
nationality groups).
(d)
American Indian or Alaskan Native (suggestions include retaining
the category with no change; expanding the definition of the category
to include the Native Hawaiians and the indigenous populations
of American Samoa and Guam; and alternative wording for the category
name).
(e)
Multiracial (suggestions ranged from not having any multiracial
category to six suggestions for ways to identify multiracial persons).
(f)
Hispanic origin (options include categories for subgroups; and
alternative wording for the category name).
Detailed
Discussion of the Six Issues
ISSUE 1. Should
the Federal government collect data on race and ethnicity? Should there
be standards at all?
Summary
of views expressed on whether the Federal government should collect
racial and ethnic data. Some agencies presently are required by Federal
statute and regulation to collect racial and ethnic data. (See, for
example, the Voting Rights Act of 1973 (1982) and the Civil Rights
Act of 1964.) To end the collection of racial and ethnic data for
these purposes, repeal of these statutes by Congress would be required.
The view of those who favor continued collection of racial and ethnic
data can be summed up by the words of the writer who said, "...the
measurable gains made in advancing a civil rights agenda to bring
all Americans into the economic, political, and social mainstream
would have been extremely difficult, if not impossible, if we did
not have adequate information on racial and ethnic groups."
Those who
favor no collection gave as their reasons the following: (1) doing
so is divisive, archaic, unscientific, and racist; (2) it should not
be a function of the Federal government (the government should be concerned
only with citizenship) and the government has no need to know (tracking
heritage is an individual choice and responsibility); (3) the government
should collect ethnicity or ancestry instead of race; (4) there are
no pure races, everyone is mixed, and therefore, the categories are
meaningless; (5) people do not know their complete ancestry; (6) we
are all supposed to have equal protection under the law (race neutral,
color blind); (7) we are all Americans, we are a melting pot, we are
one nation; (8) we are all human beings; (9) it is dehumanizing to
categorize people like nuts and bolts; and (10) it is upsetting (for
example, the categories are too limited; reminds people of the Nazi
holocaust).
Should
there be standards at all? Directive No. 15 is used widely and the
strong consensus of public comment was to continue the issuance of
standards for collecting data on race and ethnicity. The background
and demand for the issuance of Directive No. 15 in 1977 is reviewed
in 59 Fed. Reg. 29831, (1994).
As part
of the public comment period, Federal agencies were asked to provide
information about their requirements for data on race and ethnicity.
Federal agencies report that the standards in Directive No. 15 have
facilitated the exchange of data among agencies and among states, in
instances where data are not used exclusively within a particular agency
or program. Even where it is not required, Directive No. 15 standards
are often used in State and business record systems and by marketers
as a matter of convenience and to facilitate comparisons with other
data sets.
The information
also suggests, however, that Directive No. 15 may give a false sense
of comparability and continuity among data sets. Even where the definitions
of categories are comparable, there have been variations in collection
and processing procedures that lead to inconsistencies in the data.
Additional differences occur because of the mix of self-identification
and observer-identification of race and ethnicity.
Agencies
having statutory requirements to use racial and ethnic data for policy
development, program evaluation, and civil rights monitoring and enforcement:
(1) want historical continuity of the data; (2) generally oppose a "multiracial" category
because the persons seeking this category are already covered by existing
racial categories; (3) indicate that the perception of others is more
valid for evaluating discrimination than individual self-identification;
(4) note that standardized reporting formats, like the Employer Information
Report, EEO-1, rely on observer identification; (5) express concern
about the cost of making changes that will affect both Federal agencies,
respondents, and other governmental bodies; and (6) generally favor
the broad group structure of Directive No. 15 in its present format.
Data collection
agencies have legislative authority to collect racial and ethnic data
needed for Federal programs and in the case of the decennial census,
for redistricting. They also use racial and ethnic data for analyses
of social, economic, and health trends for population groups. These
agencies said: (1) the categories in Directive No. 15 confuse some
respondents because they are inconsistent, too broad for some purposes,
and the concepts of race, Hispanic origin, and ancestry overlap; (2)
historical continuity of the data is important; (3) it is important
to be able to aggregate any new categories back to the 1977 Directive
No. 15 categories; (4) corrections are needed in Directive No. 15 (for
example, there is no category for South American Indians and only Hispanic
Whites and Hispanic Blacks are identified in the minimum combined format);
(5) subgroups of Asians and Hispanics were most frequently cited as
a need but required data collection should be limited to groups with
sufficient numbers to generate meaningful estimates; (6) a few agencies
expressed interest in subcategories of the Black population (e.g.,
African, West Indian); and (7) for American Indians, some expressed
a need to require the identification of Federal- versus state-recognized
tribes. Many felt a "multiracial" category (that does not
specify the races) is too heterogeneous and affects the counts of other
groups in unknown ways. Agencies that collect health data particularly
need to know specific categories because some diseases and health problems
are more prevalent among certain racial and ethnic groups. Data collection
agencies are concerned about the significant operational, technical,
and cost issues of a "check all that apply" approach for
multiracial persons. For example, processing systems would have to
be changed to allow for reporting more than one category. Additionally,
Federal laws have been written with the assumption that persons identify
with one racial group; these laws would either have to be changed or
some method would have to be devised to meet legislative requirements.
Federal
agencies have interpreted Directive No. 15 to apply only to primary
data collection; data collection under grants may or may not comply
with it.
ISSUE
2. Should Directive No. 15 be revised? Should there be different
collection standards for different purposes?
Among those
who favor collection of racial and ethnic data, there is significant
difference of opinion as to whether Directive No. 15 should remain
essentially as it is or should be revised. While some believe there
should be no change in Directive No. 15, others say ethnic identification
is in constant flux and Directive No. 15 should be changed now and
subsequently reviewed periodically (for example, after every decennial
census). The Directive No. 15 categories are nearly two decades old
and many people say they no longer identify with the categories. Intermarriage,
changes in immigration flows, and changes in ethnic consciousness are
some of the reasons. These changes in our basic population structure
suggest an increasingly diverse society and unforeseen future needs
for racial and ethnic data.
Public
testimony and research indicate that race and ethnicity are subjective
concepts and inherently ambiguous. For purposes of collecting data
in the United States, race and ethnicity are cultural concepts and
social constructs. As stated in the current version of Directive No. 15, the racial and ethnic categories are not intended to reflect scientific
or anthropological definitions of who should be included in a particular
category. The definitions of the minimum set of population categories
under Directive No. 15 include references to color, ancestry, and geographic
origins in an effort to approximate social constructs of race prevalent
in the United States.
In line
with the subjective nature of the concept, research shows people change
how they classify themselves with respect to race and ethnicity. There
is significant inconsistency in the measurement of ethnicity particularly.
Research shows different responses are summoned by the format of questions
(open or specified categories), the number of categories, the examples
listed, changes in self-perceptions within groups and among age cohorts,
and the political climate.
The differing
views of whether Directive No. 15 should be revised relate to the purpose
for collecting such data. Federal agencies that use racial and ethnic
data for regulatory programs, civil rights monitoring and enforcement
generally oppose any revision of Directive No. 15 for the reasons described
in Issue 1. Directive No. 15 is seen as providing practical guidelines
for visual identification in a broad and relatively straightforward
manner of the population groups that have historically suffered discrimination.
Where trend
analysis of social and economic changes was the commenter's purpose,
more detailed categories were often favored. The preference varies
for other purposes such as policy development and program fund allocations.
In the public hearings and letters to OMB, persons concerned with self-identification
generally favored revisions that would provide more detailed categories
and more freedom of choice (see Issue 6).
Given the
distinct uses of racial and ethnic data in the Federal government (especially
trend analysis versus regulatory and civil rights monitoring and enforcement),
the possibility of a two-part Directive No. 15, with one part focusing
on each purpose, has been suggested as an option if there are changes
to Directive No. 15. Part A of Directive No. 15 could provide more
detailed standards for use when a major purpose is trend analysis (such
as in the decennial census and perhaps household surveys). Such a standard
would track the increasing diversity of the U.S. population and provide
better information to inform decisions about whether the categories
for administrative and enforcement purposes should be expanded. Part
B of Directive No. 15 could remain essentially unchanged for use in
program evaluations and civil rights monitoring and enforcement.
There are
disadvantages to having two levels of data collection specified in
the standards of a revised Directive No. 15. The most serious disadvantage
could be data sets with different counts of population groups that
cannot be related, a result of different coding and tabulation rules.
This is especially the case if the specific races of multiracial persons
are identified. Two sets of data could be confusing to data users who
may be unsure of which set to use for various purposes. To prevent
refocusing the problem from data collection to tabulation, there would
have to be generally agreed-upon procedures and guidelines for how
agencies would tabulate data for program purposes. The procedures should
ensure that detailed data collections could be tabulated back to the
broad categories of the 1977 Directive No. 15 in a standard way across
programs. Standard and generally agreed-upon tabulation rules would
be needed for the various combinations of multiracial entries, including
those where neither race is "White."
The Bureau of the Census already has procedures for aggregating detailed
data from the 1990 census to the broader categories of Directive No. 15. The reaggregations could become more complicated because of the different
assumptions that would be required. The requests of some groups who do
not feel they fit into existing categories (e.g., some Arabs, Creoles,
and Cape Verdeans) suggest that aggregations could become even more problematic.
Also, the quality of the reaggregated data can vary by geographic area.
Some say
cost should not be an "excuse" for failing to improve data
collection on race and ethnicity, especially where the data are used
for protection of civil rights. Others expressed concern about the
cost of making changes to Directive No. 15 when the broad categories
are acceptable choices for most of the population and cover programs
affecting almost all persons. Added costs associated with more detailed
categories are discussed in Issue 6 below.
Federal,
State, and local government agencies urged that any revisions ensure
that data can be tabulated back to the 1977 categories. Most expressed
a preference to maintain historical continuity of the two decades of
data sets with the understanding they are not perfectly comparable.
It was also recognized that final tabulations give the data an appearance
of comparability among data sets when actually there are differences
caused by data collection methods (especially self-identification versus
identification by observers). Nevertheless, the data are widely accepted
by courts and government agencies as reliable indicators of change
in housing patterns, redistricting, and labor markets.
If there
are revisions to Directive No. 15, research indicates that changes
in the race and ethnic categories on administrative records will present
problems in data comparability over time. The categories on the records
reflect what they were as of the time of initial enrollment and the
categories are generally carried without change for decades. Administrative
records are often collected from State and local sources, which have
a variety of recordkeeping practices, are not required to meet Directive
No. 15 (but often do), and are unlikely to collect information for
detailed categories. A few States now require a "mixed race" category.
There will be increasing value to the Federal government if State records
use the same categories as Directive No. 15.
Federal
and State government agencies emphasized that if there are revisions,
a reasonable amount of time needs to be given to phase in the changes.
ISSUE
3. Should "race/ethnicity" be asked as a single identification
or should "race" identification be separate from Hispanic
origin or other ethnicities?
Directive
No. 15 states that it is preferable to collect data on race and Hispanic
separately to allow flexibility. If a combined format is used to collect
racial and ethnic data the minimum acceptable categories are: American
Indian or Alaskan Native; Asian or Pacific Islander; Hispanic; White,
not of Hispanic origin; and Black, not of Hispanic origin. The use
of the Hispanic category in the combined format does not 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.
Public
testimony reflected some data problems with the standards in Directive
No. 15. The combined format does not provide for identification of
Asians or American Indians with Hispanic origins, and would classify
the people of Equatorial Guinea, who are geographically Africans but
who speak Spanish, as Hispanic. There is no apparent category for Central
and South American Indians.
Some persons
from non-Hispanic ethnic groups questioned why Hispanics had been singled
out as the only ethnic group specifically identified in Directive No. 15. Others objected to the term "non-Hispanic"
because it defines people by what they are not. For example, rather than "White,
not of Hispanic origin," a category might be "White, European
ethnicity" or "American Indian, Mexican." This approach
would require a question that identifies ancestry groups within the broad
race groups.
Most Federal
agencies did not comment on whether race and Hispanic origin should
be collected in one question or two questions, although many agencies
have been using the combined format for a number of years and have
developed data series with the resulting data. Those few that commented
were split on the issue.
The public
indicated differences of opinion also. Those who favored asking race
and Hispanic origin separately said Hispanics were a multiracial population
and a cultural (not a race) group. Many Latin American countries are
populated by immigrants from parts of Europe other than Spain. Many
wanted to identify Asian-Hispanics and American Indian-Hispanics. Research
shows Hispanics who self-identify as White also fare better economically;
thus, some said two questions were needed because ethnicity alone was
insufficient for determining which Hispanics are likely to be victims
of discrimination. Others were concerned with historical continuity
of data concepts and wanted to be able to generate statistics for the
total White and total Black population. When separate questions are
used to collect racial and ethnic data, there is also a technical matter
of which question should be asked first.
Some who
favored asking race/Hispanic origin as one question said many Hispanics
do not identify themselves as a race. Others favored this approach
as a way to end the practice of using the term "race" which
they see as a social rather than a scientific construct.
For some
individuals, race and ethnicity may not be clearly separable. One proposed
solution is to ask a single race/ethnicity question (that is, one question
in which "Hispanic" is included in the list with the broad
race categories) and allow respondents to mark all that apply. Hispanics
who identify with a race category could mark both categories. Hispanic
respondents who do not identify with any race category could mark "Hispanic" only.
The question would correspond to self-perceived membership in population
groups defined by cultural heritage, language, physical appearance,
or other characteristics.
Some research
supports the public comments that some respondents are confused about
how to respond to separate race and Hispanic origin items. In the 1990
census, 4 in 10 Hispanics marked "Other" in the race question
and about 10 percent of the population did not respond to the Hispanic
origin item. The 1990 census reinterview study, in which the answers
given by a sample of respondents to the 1990 census were compared with
answers they gave in a reinterview after the census, also showed that
Hispanics had high levels of inconsistent reporting in the race item.
These results indicate the question may not be operating as intended.
Cognitive
research shows that many Hispanics perceive redundancy in separate
race, Hispanic origin, and national origin questions. Some Hispanic
respondents do not identify with the Black or the White category, and
are offended by an "Other race" category (which they interpret
to mean that Hispanics are less important than other races since they
do not have their own "label"). For some, "White" is
synonymous with "Anglo" meaning non-Hispanic. For example,
in a focus group, a Mexican-American man said that where he lived people
were either Mexicans or Anglos. He was confused by a race question
that seemed to be trying to make him say he was White and to his mind,
non-Hispanic. In an analysis of the responses of Hispanics to the race
question in the 1990 Panel Study of Income Dynamics, Cubans were the
most likely and Mexican-Americans the least likely to identify themselves
as "White." Cognitive research shows some Hispanics, especially
the foreign born, expect to see a single category for Hispanics.
If race
and Hispanic origin are asked as two separate questions, there is the
issue of whether to ask race or Hispanic origin first. Research done
since 1987 indicates that additional instructions and asking Hispanic
origin first reduce nonresponse to that question. Asking Hispanic origin
first also reduces reporting as "other race" and increases
reporting as "White" by U.S.-born Hispanics but not by immigrants.
A large minority of respondents still report as "other race." The
Census Bureau will conduct research in the 1996 National Content Test
for the 2000 census to determine whether placing the Hispanic item
first affects consistency of responses and reporting in the race category
among subgroups not adequately represented in other studies.
The future
research agenda is described in Section C below.
ISSUE
4. Should self-identification or the perception of an observer
guide the methods for collection of racial and ethnic data?
At the
heart of criticisms and public requests for review of Directive No. 15 is the feeling of some persons, particularly those of mixed heritage,
that they cannot accurately identify their race and ethnicity as they
prefer in Federal data systems using the current categories. They say
the government should not limit their choice of identification. As
stated in the second principle for the review of racial and ethnic
categories (Section D below), ideally OMB prefers that self-identification
should be facilitated to the greatest extent possible but there are
data collection systems where observer identification is more practical.
Federal censuses, surveys, and vital records give preference to using
self-identification; that is, having the individual (or in some cases
a proxy respondent) provide the information requested about his or
her race and Hispanic origin.
Research
shows that ethnic groups evolve and may modify their preferred ethnic
group names; individuals may represent their affiliation with groups
differently depending on the situation and may alter their perceived
ethnic membership over time. Category names need to be acceptable and
generally understood both by members and nonmembers of the groups to
which they apply.
Self-identification
is not the preferred method among Federal agencies concerned with monitoring
and enforcement of civil rights. They prefer to collect racial and
ethnic data by visual observation. Since discrimination is based on
the perception of an individual's race or Hispanic origin, these agencies
oppose any changes that would make it more difficult to collect data
by observation. Such proposed changes include the suggested "multiracial" category
as well as identification of national origins and ethnicities (for
example, "Arab" or "Cape Verdean"). These agencies
say that if categories are more detailed and include nationality groups,
or if there is a "multiracial" category (and especially if
the multiple races have to be identified), it would be virtually impossible
to give instructions for how to classify by visual observation. Additionally,
they report it is their experience that direct inquiry about a person's
race, ethnicity, or national origin sometimes raises concerns among
employees or other respondents about the purpose of collecting the
data.
American
Indian groups express concern about self-identification. Tribal recognition
of status as an American Indian or Alaskan Native (Alaskan Indian,
Eskimo, or Aleut) is a legal definition, not one of long-ago ancestry.
In the 1990 census, 8.7 million persons reported in the ancestry question
that they were American Indian but only 1.9 million reported American
Indian race. Only 3 of 4 who reported "American Indian" as
their race gave "American Indian" as their first ancestry;
about 9 percent gave an European first ancestry. There are also regional
effects in reporting American Indian as a race related to the prevalence
of intermarriage, migration, Federal recognition of regional tribes,
and attitudes towards Indians.
Development
of Federal data sets includes increased use of administrative records
matched to survey data for trend analysis. This makes the issue of
data collection methods, both by observation and self-identification,
a greater technical difficulty than in the past. Where identification
is by observers or proxy respondents, blood relatives may be identified
differently in administrative records and an individual may be identified
differently among data sets.
ISSUE
5. Should population size and geographic distribution of groups
be criteria in the final decision of Directive No. 15 categories?
Many of
the groups for which data collection has been requested are numerically
small and often are found primarily in specific geographic areas. In
national sample surveys, these factors often make it unreasonably costly
or burdensome on the public to collect reliable data. A question that
allows for self-identification to the greatest extent possible may
be very lengthy. Some see this as a technical problem, others do not.
There are
difficulties with using size of population as a basis for making a
population group a specific category. The size of the population is
itself a subject of controversy at times.
For sample
surveys, how small is "too small"? Sample data can provide
only an estimate of a number and not, with 100-percent certainty, the
true number itself. The smaller the group, the more unreliable estimates
are with respect to sampling error. For example, in the Current Population
Survey (CPS), a national survey of households, summary measures such
as means and percentage distributions are shown only when the population
base is 75,000 or greater. An example of how much sampling error increases
in a survey as the population size of a group decreases can be provided
for a characteristic such as the poverty rate. If the estimated poverty
rate for the total U.S. population is about 14 to 15 percent (a 90-percent
confidence interval), then for a population group of 1 million persons,
the poverty rate would be about 8 to 21 percent; for a population group
of 500,000 persons, the poverty rate would be about 6 to 23 percent;
and for a population group of 200,000 persons, the poverty rate would
be about 1 to 28 percent. (A 90-percent confidence interval can be
interpreted roughly as providing 90-percent confidence that the true
number falls between the upper and lower limits.) The accuracy and
reliability of an estimate depends not only upon sample sizes, but
also upon whether the groups are "controlled" (i.e., weighted
to independent estimates). Estimates of the Asian and Pacific Islander
population from the 1994 March Current Population Survey differed by
about 20 percent from demographic estimates due primarily to this factor.
One person
suggested that groups should constitute at least one percent of the
population (nationally, about 2.6 million in 1994) to be considered
as a separate category. A time frame and data source would have to
be agreed upon if such a guideline were considered.
ISSUE
6. What should the specific data collection and presentation
categories be?
There are
no clear, unambiguous, objective, generally agreed-upon definitions
of the terms, "race" and "ethnicity." Cognitive
research shows that respondents are not always clear on the differences
between race and ethnicity. There are differences in terminology, group
boundaries, attributes, and dimensions of race and ethnicity. Historically,
ethnic communities have absorbed other groups through conquest, the
expansion of national boundaries, and acculturation.
Groups
differ in their preferred identification. Concepts also change over
time. Research indicates some respondents are referring to the national
or geographic origin of their ancestors, while others are referring
to the culture, religion, racial or physical characteristics, language,
or related attributes with which they identify. The 1977 Directive
No. 15 categories are a mix of these. The categories do not represent
objective "truth" but rather, are ambiguous social constructs
and involve subjective and attitudinal issues.
Some said
the categories should reflect ancestry or cultural affiliation rather
than skin color. Some wanted to indicate they were "American"
and had ancestry from a particular geographic region ("hyphenated
Americans") while others opposed this ("we are all Americans").
Cognitive research indicated that some people use race and ethnic origin
interchangeably; they see little difference between the two concepts.
Most people do understand the concept of ancestry.
Some groups
stated that their preference was for standard categories that would
maximize the size of their population because they believed larger
numbers provide importance in society and greater political leverage.
In short,
groups differed in what they considered the most desirable standard.
It is impossible to satisfy every request for racial and ethnic categories
that OMB received; such a list would be both lengthy and contradictory.
Some persons requested religious identification; this option is not
discussed below because the Federal collection of religious affiliation
has been interpreted as possibly violating the separation of church
and state.
Some suggested
a completely open-ended question with no standard categories for data
collection; rather, standards would be set for data tabulation. An
open-ended question is discussed in part (e), Multiracial option (2)(cc).
Below is
a discussion of public comment with regard to the current broad categories
of "White," "Black," "Asian or Pacific Islander," "American
Indian or Alaskan Native," and "Hispanic origin." Part
(e) below discusses options with respect to classification of persons
of multiple races, a category that does not exist in the current standards.
Where possible, in the discussion of options and their pros and cons,
past research results are included.
As part
of the discussion of options, the cost of proposed changes with respect
to collecting, tabulating, and analyzing data is an essential consideration
(see Section D, General Principle 8). Any changes in Directive No. 15 will be imposed on tens of thousands of State and local agencies
such as law enforcement agencies (through the Uniform Crime Reporting
system), school districts, the business community, and others required
to use the Directive in reporting these data to the Federal government.
If administrative records for Federal programs have to be completely
updated to meet a new standard, there will be significant costs to
entities that report to the Federal Government. For example, the State
of Florida estimates it would cost $2 million to change school enrollment
records.
Changes
in the current Directive No. 15 would also entail additional processing
costs as software and sometimes data capture methods would have to
be changed. For example, it is more expensive to capture and code handwritten
responses to open-ended questions than fixed, pre-determined categories.
Some of the increased costs associated with categories more detailed
than the current Directive No. 15 would include:
- interviewer
training for implementing changes in collecting these data and
updating of interviewer instruction manuals;
- additional
interview time to collect more detailed data;
- the technical
and practical difficulty of administering more detailed or more complex
categories (such as long lists of nationalities, especially if multiple
responses are allowed) in telephone surveys;
- increases
in computer reprogramming and data processing costs;
- increases
in the likelihood of litigation over data aggregation and processing
decision rules;
- increases
in the costs of disseminating data in hard copy or electronic format
and storing larger computer data files;
- updating
program manuals, regulations, and recordkeeping requirements to reflect
changes; and
- making
data analysis more complex.
The cost
considerations described above apply, in varying degrees, to any change
and so are not described further in the discussion below of pros and
cons for the various options raised in public comment.
(a)
White
In Directive
No. 15, the "White" category includes persons having origins
in any of the original peoples of Europe, North Africa, or the Middle East.
The public comment included suggestions for subcategories and related changes
in terminology to collect more detailed information on White ethnic groups
according to the geographic region of their ancestors. This summary reports
only on options proposed during public hearings and in the public comment
period. It also highlights pros and cons for these options as raised in
public comment or shown by research. Inclusion in the summary does not
reflect OMB endorsement of the comments or suggestions. Requests included:
Options
Suggested in Public Comments:
(1) Collect
data for White ethnic groups according to the country of ancestral
origin (for example, German, Scottish, or Irish). Some prefer other
terms such as "European-American," or "German-American"
and some requested that "European" be further subcategorized
into
"Western European" and "Eastern European." Some suggested
subcategories for identifying the original peoples of Europe, North Africa,
and Southwest Asia (Middle East).
Pros of
Option (a)(1):
- Collection:
Some persons identify more with their ancestry than with "White"
as a racial category.
- Tabulation
and analysis: Indicates the ethnic diversity of the "White" population.
Cons of
Option (a) (1):
- Collection:
--Physical space on forms: if national origin groups are listed,
considerably more space would be needed.
--Telephone
interviews: more difficult than currently, especially if national
origin groups are listed; more time consuming to ensure that
respondent is given the opportunity to understand the possible
choices.
--Data
quality: effect on counts of specific nationality groups if country
not listed as an example; count also affected by which nationalities/countries
are listed; respondent may be confused between reporting ancestry
(e.g., German) versus country of birth (e.g., Russia); and some
respondents do not know their ancestry.
--Categories
not required by Federal legislation/programs and States unlikely
to collect this detail in administrative records. --Visual observation:
nationality not easily determined.
- Tabulation
and analysis: Need rules for tabulating multiple ancestries. More
categories add costs for tabulation and analysis. It is more complex
to analyze and report on many nationalities as compared with single
race categories.
(2)
Create a separate category for Arabs/Middle Easterners (currently
included as part of the "White" category) in order
to distinguish this population from persons of European descent
in the "White"
category. The public comment offered different suggestions for
the name of the category and how to define the population group
it would be intended to cover. Some comments supported a separate
category for the decennial census enumeration, but not necessarily
adding a separate category to the minimum set of racial and ethnic
categories in Directive No. 15. These suggestions included:
--
Create a geographically oriented category called "Middle Eastern" (based
not on race but on region of origin) for persons from the Middle
East/North Africa and West Asian region, regardless of their race,
religion, or language group. It would include Arab states, Israel,
Turkey, Afghanistan, and Iran. Some suggested also including Pakistanis
and Asian Indians in their geographic definition of the term. Data
availability on subsets of the Middle Eastern regional category
was also requested. Some comments referred to the "Middle
Eastern" category as an ethnic identifier; some favored the
addition of a "Middle Eastern" category to the list of
basic racial and ethnic categories; and others suggested a "Middle
Eastern" subcategory be created within the "White"
category. Those preferring a "Middle Eastern" to an "Arab" category
felt that the category would build on the other regionally defined
categories, consolidate people from different countries but with
similar cultural/geographic experiences regardless of race, and distinguish
them from persons of European descent in the
"White" category.
--
Add an ethnic category called "Arab-American" based on
a linguistic and cultural approach to the minimum set of categories
in Directive No. 15. Those who preferred the term, "Arab" said
Arabs, like Hispanics, are an ethnic group of mixed race and have
a shared language and culture. They would make "Arab" a
separate category rather than part of the "White" category;
they would leave North Africans, who are not Arabs, as part of
the "White" category.
--
Reclassify "Muslim West Asians" as part of the "Asian
or Pacific Islander" category.
Pros
of Option (a)(2):
- Collection:
--A separate category would satisfy Arab/Middle Eastern respondents
who do not think of themselves as "White" or
as having any identity in common with Europeans.
--A
separate category would facilitate self-identification
and could possibly improve the quality of the data on
Arabs/Middle Easterners.
--Telephone
survey: Easy to ask if it is the only category added; however,
if additional categories are added, it may be problematic.
- Tabulation
and analysis: --Would provide treatment comparable to Hispanics
(and in some data sets, specific Asian nationality groups).
--Data
could be used in policy development, in delivery of services
and needs assessments, for civil rights monitoring and
enforcement, and in health research.
--Reflects
the ethnic diversity of the "White" category.
Cons
of Option (a)(2):
- Collection:
--Requires space on form for an additional category.
--There
was no general agreement in public comment about the
geographic definition of "Middle East." For
example, there is disagreement in public comment about
whether Pakistanis and Asian Indians are included if
the term, "Middle Eastern"
is used. The term, "Arab" clarifies that Asian
Indians and Pakistanis would remain classified with Asians,
which some consider preferable for historical continuity;
no requests were received from Asian Indians or Pakistanis
to be reclassified. Public testimony indicated inconsistencies
in understanding which countries should be included as "Arab."
--Identification
by observers: because some Arabs are light-skinned and
some are dark-skinned, identification by visual observation
is prone to error.
- Tabulation
and analysis:
--A separate Arab/Middle Eastern category may affect the historical
comparability of data in the "White" category and may
affect the counts of other racial groups since Arabs are a mixed
racial group.
--Adds
a category on many national surveys for a geographically
concentrated population (about half of the Arab population
is concentrated in Detroit, New York, Los Angeles, and
Washington, D.C.).
--Relatively
small population (less than 900,000 according to the 1990 census,
although Arab groups claim 1-3 million). Geographically, "Middle
Easterner" as a category would include persons other than
Arabs.
(3)
Alternative words suggested for "White" include "Caucasian"
and "Anglo."
Pros
of Option (a)(3):
- Collection:
"Caucasian" preferred by some respondents.
Cons
of Option (a)(3):
- Collection:
"Anglo" generally refers to Whites of European ancestry
and excludes Hispanics; this would affect historical continuity.
The term tends to be used regionally and may not be generally
understood.
Past
research results/literature review: Some object to the term "White" (for
example, in cognitive research one said, "white is the color
of paint" and in a letter another said, "I am not the
color of this paper"). Some preferred the term, "Caucasian."
Ethnicity is largely symbolic or optional for many Whites. Whites
often reported inconsistently, as "American," or not at
all in response to the 1990 census ancestry question. A significant
number of Whites do not strongly identify with a specific European
ethnicity. This has been the case for decades. For example, only
about 55 percent of matched persons who reported English, Scottish,
or Welsh in the March 1971 Current Population Survey (CPS) reported
the same origin in March 1972. The "example effect"
is very strong for White ancestry groups. For example, in two surveys
held five months apart, 40 million people reported English as their
ancestry and in the other, nearly 50 million said they were English.
The only difference was placement of a question on language use in
their home (English for 90 percent of the population) after the ancestry
question in the second survey and farther apart in the first survey. "German" was
the first example in the 1990 census ancestry question and, as a
result, the German population appeared to grow very rapidly. Some
Whites, however, do identify strongly with their ancestry and were
confused by the 1990 census race question which listed nationality
groups for Asians and Hispanics but not for Whites.
(b)
Black
The term "Black" in
Directive No. 15 refers to a person having origins in any of the Black
racial groups of Africa. There were suggestions to change the definition
to "persons having origins in any of the Black peoples of Africa," or
to define the term to include all Black persons regardless of country
of origin or country of citizenship. Requests were made to identify
Blacks according to the geographic region of their ancestors. "African-American" and
"Black African-American" were suggested as names for the
category [the suggestions of "Black American" and "Amerofian" (described
as Blacks who are American Natives, European, and West African) are
not discussed below]. This summary reports only on options proposed
during public hearings and in the public comment period. It also
highlights pros and cons for these options as raised in public comment
or as shown by research. Inclusion in the summary does not reflect
OMB endorsement of the comments or suggestions. Requests included:
Options
Suggested in Public Comments:
(1)
Collect data for Black ethnic groups according to geographic origin
of Black ancestors (African, Haitian, Jamaican, Caribbean, West
Indian, Brazilian, Ethiopian, etc.).
Pros
of Option (b)(1):
- Collection:
Easy to ask in a telephone survey. Some persons identify
more with their ancestry than with "Black" as a
racial category.
- Tabulation
and analysis: useful for research on health, diversity, needs
assessments, trends analysis; does not affect historical continuity.
Indicates the ethnic diversity of the Black population
Cons
of Option (b)(1):
- Collection:
--Determining geographic origin or nationality/ancestry by
visual observation would be difficult and prone to error.
--If
national origin groups are listed, considerably more
space would be needed on forms.
--Telephone
interviews would be more difficult than currently, especially
if national origin groups are listed; more time consuming
to ensure that respondent is given the opportunity to understand
the possible choices.
- Tabulation
and analysis: Data not needed for Federal program evaluation
and enforcement. States are unlikely to collect this detail in
administrative records. Count of specific nationality groups
could be affected if respondent is confused between reporting
ancestry (e.g., Haitian) versus country of birth (e.g., Virgin
Islands); some respondents do not know their ancestry. Rules
would be needed for tabulating multiple ancestries. More categories
add costs for tabulation and analysis. It is more complex to
analyze and report on many nationalities as compared with single
race categories.
(2)
Create a separate category for Louisiana (French) Creoles. They
objected to categorization with Blacks as they are a multiracial/ethnic
group (African, French, American Indian, and Hispanic).
Pros
of Option (b)(2):
- Collection:
Easy to ask in a telephone survey if it is the only category
added; however, if additional categories are added may be
problematic.
Cons
of Option (b)(2):
- Collection:
Extra space on forms; extra time in telephone interview.
- Tabulation
and analysis: Small population size. Affects historical continuity
of data sets.
(3)
Use the alternative term, "African American" or "Black,
African-American."
Pros
of Option (b)(3):
- Collection:
Commonly-used identification for Blacks born in the United
States or Blacks whose parents are Americans.
Cons
of Option (b)(3):
- Collection:
--Excludes Africans who are not American citizens.
--Term
generally refers to Blacks but respondents could reasonably
be confused as to whether to include Whites, Asians,
or others born in Africa (especially North Africa). Could
affect historical comparability of data.
--Blacks
born in Brazil or the Caribbean (especially immigrants)
do not identify with the term, "African American." Some
Blacks who have been in the United States for generations
have no record of where in Africa their ancestors were
born and do not wish to be called "African-Americans."
--Use
of "American" increases respondent error by persons
who are not Black but who wish to identify as "Americans."
- Tabulation
and analysis: refers to a continent, not a country.
(4)
Provide a separate category for Cape Verdeans (Portuguese and African
ancestry from Cape Verde on the western tip of Africa. This is
mostly a multiracial population. "Cape Verdean" is generally
considered a national, ethnic and linguistic designation rather
than a racial designation). The category could be an ethnic category
rather than a racial category as is the case for persons of Hispanic
origin.
Pros
of Option (b)(4):
- Collection:
Would satisfy Cape Verdean respondents and is easy to ask.
- Tabulation
and analysis: useful for civil rights monitoring and enforcement
in State of Massachusetts.
Cons
of Option (b)(4):
Past
research results/literature review: In surveys from 1989 to 1991,
more Blacks said it did not matter if they were called
"Black" or "African American" than said they
preferred one over the other. Among those with a preference, the
ratio choosing
"Black" over "African-American" was 1.2 to 1.
In a 1993 survey in the Chicago area, a majority of Blacks preferred "African
American" for their ethnicity and "Black" for their
race but the proportion had declined since 1991.
Several
studies of Blacks with roots in the Caribbean or Africa show they
do not feel they share a common history or culture with American-born
Blacks and distinguish themselves from this population. Further
research is needed on the terminology that is generally understood
or most acceptable. In the 1990 census, about 370,000 persons wrote
in an entry classified as "Black"; about three-fourths
of these were ethnic subgroups such as Jamaican and Haitian. Cognitive
research suggests that many foreign-born Blacks interpreted the
race question in terms of national origin rather than race.
(c)
Asian or Pacific Islander
The definition
used for "Asian or Pacific Islander" in Directive No. 15
refers to a person having origins in any of the original peoples of
the Far East, Southeast Asia, the Indian subcontinent, and the Pacific
Islands. This area includes, for example, China, India, Japan, Korea,
the Philippine Islands, the Hawaiian Islands, and Samoa. Public comment
indicated confusion about which countries are included in this definition,
particularly for "Indian subcontinent"
and whether the aboriginal peoples of Australia are included in this
category. Requests were made to have separate categories for Asians
and Pacific Islanders and to provide additional subcategories under "Asians" to
describe better this diverse population; to move Native Hawaiians,
American Samoans, and Chamorros to either a separate category or
to the "American Indian or Alaskan Native"
category. This summary reports only on options proposed during public
hearings and in the public comment period. It also highlights pros
and cons for these options as raised in public comment or shown by
research. Inclusion in the summary does not reflect OMB endorsement
of the comments or suggestions. Requests included:
Options
Suggested in Public Comments:
(1)
Make two categories, one for "Asians" and one for "Pacific
Islanders." Pacific Islanders include indigenous populations
from American Samoans, Carolinians and Chamorros, and Native Hawaiians,
as well as other population groups in the Pacific Islands. Native
Hawaiians have a specific legal status in Federal statutes different
from other indigenous Pacific Islanders.
Pros
of Option (c)(1):
- Collection:
--Easy to ask in a telephone survey.
--Categories
are mutually exclusive.
- Tabulation
and analysis:
--Pacific Islanders are culturally and ethnically distinct from
Asians so separate data would be useful for trends analyses, needs
assessments, and health research. Historical continuity can be
maintained by aggregating "Pacific Islanders" with
"Asians."
--Separate
categories for Pacific Islanders and for Native Hawaiians
would meet program needs of the Department of Veterans
Affairs to report on veterans from specific minority
groups.
Cons
of Option (c)(1):
- Collection:
--Adds a category.
--Respondents
may be confused as to the exclusion or inclusion of Native
Hawaiians and other indigenous populations which could
seriously affect data quality.
--Effect
on data collected by visual observation is unknown.
- Tabulation
and analysis:
--Pacific Islanders are geographically concentrated and a relatively
small population group for a separate category.
(2)
Specify major Asian nationality groups.
Pros
of Option (c)(2):
- Collection:
Done successfully in the 1990 census.
- Tabulation
and analysis: Indicates diverse and significant differences in
the characteristics of the Asian population; potentially useful
in analyses of health and other trends.
Cons
of Option (c)(2):
- Collection:
--Requires significant physical space on forms.
--Telephone
interviews: tedious to read long lists.
--Identification
by observers: difficult to determine specific nationality.
(3) Develop
a new category for original peoples of acquired American lands ("indigenous" populations).
This would include persons having origins in any of the original peoples
of North America who maintain cultural identification through tribal
affiliation or community recognition (American Indians, Alaskan Indians,
Aleuts, and Eskimos); the Hawaiian Islands; American Samoa; Guam; and
the Northern Marianas. Some suggested this be a "Native American" category.
Refer also to Option (d)(2) below.
Pros of
Option (c)(3):
Cons of
Option (c)(3):
- Collection:
--This might be viewed as a political category rather than as one
commonly recognized by most individuals in society.
--Respondent
error likely both on forms and in telephone surveys as "indigenous" or "original
peoples" are not familiar terms to most of the population;
the term, "native" is interpreted to mean any person
born in a particular area. No generally-understood choice for
the category name.
--Unknown
how data collected by visual observation would be affected.
- Tabulation
and analysis:
--Opposed by most American Indian tribal governments and organizations
as they preferred to maintain a category which refers specifically
to American Indians.
--Heterogeneous
population in terms of characteristics; data would be less
useful than currently for policy development, trend analyses,
and needs assessment. Not useful for health research. American
Indians were particularly concerned about possible effects
on the quality of data needed for programs and funding.
(4) Have
a separate category for Native Hawaiians (defined as individuals who
are descendants of the aboriginal people who, prior to 1778, occupied
and exercised sovereignty in the area that now constitutes the State
of Hawaii). Change "Hawaiian" to "Hawaiian, part-Hawaiian,"
because most Native Hawaiians are part Hawaiian and many, in the past,
have categorized themselves as "White."
Pros of
Option (c)(4):
- Collection:
--Clearcut, simple and mutually-exclusive category for those who
identify as Native Hawaiians.
--Easy
to ask in a telephone survey.
- Tabulation
and analysis:
--American Indian groups, concerned with an accurate count of their
population, preferred this option to including Native Hawaiians in
the "American Indian or Alaskan Native" category.
--Provides
specific information for policy development, trends analyses,
needs assessments, program evaluation, health research, and
civil rights enforcement.
Cons of
Option (c)(4):
- Collection:
--Adds a category.
--High
respondent error likely as some persons born in Hawaii but
who do not have their origins in any of the original peoples
of Hawaii likely to be confused by the term "Native." Because
the Native Hawaiian population is relatively small (211,000
according to the 1990 census race question), respondent error
could seriously affect the count.
--Unknown
how data collected by visual observation would be affected.
--Addition
of "Part-Hawaiian" will affect historical comparability
of "White" category in Hawaii to some small extent.
- Tabulation
and analysis: very small population group.
Past research
results/literature review: The proportion of Asian and Pacific Islanders
such as Cambodians and Laotians (groups not listed separately) reporting
in the "other race" response circle to the 1990 census race
item may be due to question design. Additionally, persons who were
not Asians or Pacific Islanders marked the circle for "Other Asian
or Pacific Islander." Of persons marking the "Other Asian
or Pacific Islander" circle in the 1990 census, 54 percent of
the write-ins were not consistent with the marked circle and nearly
40 percent were Hispanic group write-ins.
(d)
American Indian or Alaskan Native
The category
of American Indian or Alaskan Native in Directive No. 15 includes persons
having origins in any of the original peoples of North America and who
maintain cultural identification through tribal affiliations or community
recognition. This summary reports only on options proposed during public
hearings and in the public comment period. It also highlights pros and
cons for these options as raised in public comment or shown by research.
Inclusion in the summary does not reflect OMB endorsement of the comments
or suggestions. Requests included:
Options
Suggested in Public Comments:
(1) Suggestions
for change in category title include: "American Indian, Alaskan
Indian, Eskimo, and Aleut"; "American Indian, Alaskan Indian,
Aleut, or Eskimo"; "Federally Recognized American Indian
and Alaskan Native"; and "Native American." Some prefer "Alaska
Native" to "Alaskan Native." Suggestions also include
collecting information on Tribal enrollment.
Pros of
Option (d)(1):
- Collection:
"Alaskan Indian," "Eskimo," and "Aleut" are
more specific terms than "Alaskan Native" and reduce respondent
error.
- Tabulation
and analysis:
--"Federally recognized American Indian and Alaskan Native" meets
Federal program needs as it indicates the legal (rather than racial)
status of persons in this category. The federal trust responsibility
to provide various educational, health, and housing services extends
only to federally recognized American Indian and Alaskan Native tribes
and their members and descendants of members. More people self-identify
as being of American Indian or Alaskan Native race or descent than
are enrolled in tribes or can prove descendance, which tribal governments
feel deprives their people of benefits rightfully belonging to them
under Federal programs.
--Inclusion
of the term, "Federally recognized" will affect historical
continuity but for the future, it could clarify the intention
of the category and reduce the changes over time in the numbers
included in the category.
Cons of
Option (d)(1):
- Collection:
--The term, "Alaskan Native" results in respondent error
because some persons born in Alaska but who do not have Alaskan Indian,
Eskimo, or Aleut origins are confused by the term.
--Some
individuals of tribes not Federally recognized may not be aware
of the status of their tribe (e.g., State recognized tribes
or tribes awaiting recognition).
--When
tribal enrollment/descendance is not required information, possible
overcoverage occurs because the category is marked by many persons
with American Indian ancestry but no legal tribal affiliations
or community recognition. This possible overcoverage could become
more serious if there is an instruction to "check all that
apply" to allow multiracial persons to identify their specific
racial groups and they respond in terms of ancestry further back
than their immediate parents.
--The
term, "Native American," is an unacceptable term to
many American Indians. It is also confusing to some persons who
are not American Indians but who use the term to indicate they
were born in the United States. The term appears to include Native
Hawaiians although this is not entirely clear. "Aboriginal
population,"
while technically correct, is considered by many to be a demeaning
term. "Indigenous populations" include persons having
origins in any of the original peoples of North America, the Hawaiian
Islands; American Samoa; Guam; and the Northern Marianas Islands.
The terms, "aboriginal population," "indigenous
populations,"
and "original peoples," are not generally understood
and would likely result in misreporting.
--It
is unclear where South American Indians, Russian and European
aboriginal tribes, or Australian aborigines who have immigrated
to the United States are classified. Some think the current Directive
No. 15 categories exclude these populations. Others include in
the definition of "American Indian," all the aboriginal
peoples of North America (except Eskimos and Aleuts) and of Central
and South America. Some suggest a separate category for "other
indigenous tribes" to include tribes such as Mapuchi and
Mayan.
(2) Change
the category to include Native Hawaiians and other indigenous populations.
Suggested category names include: "American Indian, Alaskan Native,
or Native Hawaiian"; "American Indian, Alaskan Native, Native
Hawaiian, and American Samoan"; "aboriginal population";
"indigenous populations"; and "Indigenous/Aboriginal People" (also
see discussion under (c)(3) above).
Pros of
Option (d)(2):
- Tabulation
and analysis: Native Hawaiians are not Asians or immigrants to
the United States.
Cons of Option
(d)(2):
- Tabulation
and analysis:
--There is a legal distinction between "American Indians and
Alaskan Natives" and "Native Hawaiians." Native Hawaiians
are not eligible for the majority of programs and services available
to American Indians and Alaskan Natives. Indian tribes are self-governing
political entities. For example, the legislative mandates for Indian
Health Service and the Bureau of Indian Affairs pertain only to American
Indians and Alaskan Natives. On the other hand, some programs for "Native
Americans" includes Native Hawaiians as well as American Indians
and Alaska Natives. Native Hawaiians are of Polynesian/Pacific Islander
descent and are not descendants of the original peoples of North
America. They have a distinct culture and social environment. The
category would be too heterogeneous for health research.
--Would
affect historical continuity of the data: effect on the data
for carrying out trust obligations toward American Indians
and Alaskan Natives is unknown.
--Western
Samoa is an independent nation and how to report could be a problem.
(3) Collect
information on specific tribal affiliation and distinguish between
Federally-recognized tribes and State-recognized tribes (Tribal affiliation
is based on criteria established by the tribe, not self-identification.).
Pros of
Option (d)(3):
- Tabulation
and analysis: Meets Federal agency needs for policy development,
trends analyses, needs assessments, and program evaluation and
enforcement. A way to distinguish between legal and ancestral identification
with the American Indian category.
Cons of
Option (d)(3):
Past research
results/literature review: Of persons reporting as "American Indian" in
the 1990 census, 13 percent did not specify a tribe; this was an improvement
from the 1980 census results. There was higher than expected growth
rate of American Indians from 1980 to 1990 (as well as from 1970 to
1980) which raises questions about what the census race question is
measuring for this population. Some of the change is attributed to
growth and improvements in the census and outreach programs, some to
misreporting (for example, some Asian Indian parents reported their
children as American Indian), and some to shifts in self-identification
from White to American Indian. The quality of the data for the American
Indian population is of yconcern since it is a relatively small population
(about 2 million in 1990) and the data are used to disburse Federal
program funds to American Indian tribal and Alaska Native Village governments.
About 2 million persons said they were American Indian in the race
question of the 1990 census; however, 8.7 million included American
Indian in their response to the ancestry question.
(e)
Multiracial
How to
classify persons who identify with more than one race is perhaps the
issue that has engendered the most controversy in the present review.
For the most part, the public comment used the term, "multiracial"
to refer to persons of two or more races. A variety of options were suggested
in public comment for how to collect racial data from multiracial persons.
They are shown below, followed by pros and cons cited for each option.
Table 1 summarizes the options. This summary reports only on options
proposed during public hearings and in the public comment period. It
also highlights pros and cons for these options as raised in public comment
or shown by research. Inclusion in the summary does not reflect OMB endorsement
of the comments or suggestions.
In Latin
America, a racially mixed society, there is an array of terms to describe
gradations of skin color. This has not been the history of the United
States in this century where the terminology implies
"pure" races such as White or Black, rather than biracial or
multiracial categories. In 1960, there were about 150,000 interracial
marriages compared with 1.5 million in 1990. In the 1990 census, about
4 percent of couples reported they were of different races or one was
of Hispanic origin. Such households had about 4 million children.
Directive
No. 15 says that persons of mixed racial and ethnic origins should
use the single category which most closely reflects the individual's
recognition in his or her community. The public comments indicate that
multiracial persons objected to this instruction. The commenters indicate
that a single category does not reflect how they think of themselves.
From their perspective, the instruction requires them to deny their
full heritage and to choose between their parents. They feel they are
being required to provide factually false information. They maintain
that the current categories do not recognize their existence. They
say they could mark "Other" where that category is provided
but they feel it is demeaning. They want to identify their multiple
races, but say that those who prefer to choose one of the existing
broad categories could do so.
One concern
of those who oppose a category for multiracial persons is that it will
reduce the count for persons in the basic categories. Organizations
representing multiracial persons disagree. They say minority groups
could gain numbers as some persons are now classified as "White" under
the "choose one" rule. As reflected in the options listed
below, there was disagreement as to whether identification should include
specific races. If specific races are identified, there might be some
flexibility in how users could tabulate data. For some, this is seen
as an advantage. For others, it is seen as a disadvantage because different
tabulation rules would result in different counts of groups.
Some asked
how far back in one's ancestry respondents should go in deciding to
identify multiple races. Most who commented meant only the race or
Hispanic origin of parents. This would require additional instructions
and may not be acceptable to those who wish to identify their earlier
ancestry. Presumably, persons would be instructed to list all races
if the parent(s) were also of multiple races; this concerned those
who oppose a multiracial category.
The discussion
below refers to "race" but some respondents suggested multiple "ancestry" (listing
both parents) should be the focus instead. Asking about ancestry focuses
the questions back in time and conveys an historical and geographic
context which some feel is clearer than the ambiguity of "race" or "ethnicity."
Table
1. Summary of Options for Identification
of Multiracial Persons
(e)(1) |
Multiracial
identification not allowed (must pick one broad category): |
(aa) |
Individual
chooses the one with which he or she most closely identifies |
(bb) |
Mother's
category is designated |
(cc) |
Father's
category is designated |
(dd) |
Race
of minority-designated parent (if one is White) |
(e)(2) |
Multiracial
identification allowed: |
(aa) |
"Multiracial"
category -- self-identification (SI) or observer identification
(OI) |
(bb) |
"Mark
all that apply" from list of specific categories -- SI
only |
(cc) |
Open-ended
question -- SI or OI |
(dd) |
"Other"
-- SI only |
(ee) |
Mother's
and father's geographic ancestry -- SI only |
(ff) |
Skin-color
gradient chart -- SI or OI |
Options
Suggested in Public Comments:
Option (e)(1): Mark
one broad category with which the respondent most closely identifies (categories
are same or similar to current list)
Pros
to Option (e)(1) -- mark one broad category:
- Collection:
--Physical space on forms and questionnaires same as now.
--Identification:
most people identify with only one of the current categories;
facilitates collection by observers where that method is used;
persons of multiracial heritage who identify with one broad
category do not have difficulty responding.
--Telephone
survey: easy to ask.
- Tabulations
and analysis:
--Easier than options that allow the identification of multiple races.
--Meets
needs of Federal agencies concerned with program evaluation
and civil rights monitoring and enforcement.
--This
is the only option that meets the needs of the Indian Health Service
which is responsible for health care of anyone who is a Federally-recognized
American Indian or Alaskan Native, regardless of the proportion
of Indian blood or which parent has Indian blood.
--Maintains
historical continuity of data.
--Categories
are the same or similar to those used in State and local administrative
records and historical Federal administrative records.
--Federal
laws are written based on the assumption that people identify with
one Directive No. 15 category. For civil rights monitoring and
enforcement, respondents clearly fall in or out of a particular
category. Would address concerns of those who believe a "multiracial" category
would compromise effective implementation of civil rights laws.
Cons
to Option (e)(1) -- mark one broad category:
- Collection
-- identification and count issues:
--Having to choose one racial category upsets some respondents, especially
those with immediate multiracial heritage, who identify with more
than one race/ethnicity; telephone interviewers ask race in early
part of interview and then must deal with an unhappy respondent for
the remainder of the questions; and Federal agencies must respond
to those upset by the policy.
--Nonresponse
rates may increase for persons who wish to identify with more
than one race but who are instructed to select the one category
with which they most closely identify.
--As
the size of the Hispanic population increases, a larger number
and proportion of that population group may mark "Other"
or not respond. The 1994 pretest of the Survey of Income and Program
Participation showed some Hispanics would report in the multiracial
category.
--Inconsistencies:
The same person is likely to be identified differently across
administrative records and surveys which reduces analytic usefulness
of the data. If mother's race is used to assign the child's race
as in birth records, the classifications may be different than
the person's self-identification.
--There
is a significant number of interracial marriages among Asians
and Whites. For example, in the 1990 census, in California, nearly
one-fourth of children with any Asian background were White and
Asian. Asian groups contend they are undercounted when forced
to identify with one category only. One study of the 1990 census
indicates that the children of these marriages are more likely
to identify themselves as "White" than as "Asian."
- Tabulations:
Option (e)(1)(dd), in which the race of the minority-designated parent
is designated as the person's category, requires additional rules
if one parent is not White.
- Analysis:
--Does not sufficiently reflect Nation's diversity; no information
for multiracial persons about differences in health, economic status,
and likelihood of discrimination.
--Not
as useful in health research as identification of the specific
mixtures. All of the current racial categories are said to
be too broad for analysis of health risks and economic trends;
for example, a study found that 25 percent of those in the "Asian
or Pacific Islander" category smoked, but this ranged
from 20 percent of Filipinos to 72 percent of Laotians.
Option
(e)(2)(aa): "Multiracial" category (SI or OI) (Note:
May ask respondent to specify races but not necessarily)
Pros
to Option (e)(2)(aa) -- "Multiracial" category:
- Collection
if specific races are not identified:
--Physical space on forms: adds one racial category.
--Meets
demand of some multiracial respondents, especially those whose
parents are of different races.
--Telephone
survey: easy to ask if it is the only category added; however,
if additional categories are added may be problematic.
--Somewhat
more amenable to identification by observers than any other option
for multiracial persons (however, compared with observer identification
in Option (e)(1), this option is likely to result in an undercount
and a substantially different distribution of current broad categories).
- Tabulation
and analysis:
--A few States have passed laws to include this category in their administrative
records. Currently they proportion their multiracial counts among the
OMB categories for Federal reporting purposes based on percentages
of minorities in the general population, although it is not clear what
geographic level they are using (National, State, local, school districts,
etc.) when they refer to "general population." A change by
OMB to a "multiracial" category would reduce costs for these
few States because they would not have to maintain data in two different
ways.
--Indication
of population diversity.
--Potentially
useful in analyzing trends such as education and employment, especially
if specific categories are identified.
Cons
to Option (e)(2)(aa) -- "Multiracial" category:
- Collection:
--Requires testing for effect on respondents, response rates, and
data quality. Multiracial persons who previously identified principally
with one broad category may become unsure of what is being asked.
Multi-ethnic persons of the same race (e.g., a White person of
English and German descent) may find the questions confusing.
It is not clear how multiracial Hispanics would answer.
--The
category is imprecise and specific instructions would be required
on whether respondents should answer in terms of the races
of their parents only or further back. Imprecision of the category
leads to possible confusion since, if one goes back far enough,
many Americans are of mixed racial heritage (for example, many
Whites have American Indian heritage and many Blacks have African,
White, and American Indian heritage).
--Have
to determine an acceptable category name. Suggestions included:
Multiple races; Mixed race; Multiracial; Tan American; TIRAH
(Tan InterRacial American Humankind); Mixed origins; Mestee;
More than one race; and Mulatto. Some of these suggestions apply
only to Black and White mixtures. Cognitive research shows that
most people understand the terms, "multiracial" and "biracial."
--Requires
establishment of a category (and the associated extra costs)
but the category may be used by only a small proportion of the
population. Some school systems allow use of a "multiracial"
category and report it is used by less than 2 percent of students.
--Where
identification is by an observer: unknown what criteria an observer
would use to identify persons of more than one race; identification
of specific races unlikely or too inaccurate to be useful; because
of likely mismatch, unclear how it would affect a count of mixed
race persons; broad category of blood relatives likely to be
identified differently, especially in administrative records;
and the same person is likely to be identified differently across
administrative records and surveys which reduces the analytic
usefulness of the category.
- Tabulations
and analysis:
--The category is not an alternative in the administrative records
of many State and local governments.
--If
specific races are identified through an open-ended question,
the development of a classification system for tabulating responses
would be required; choices may be controversial and challenged.
--If
specific races are not indicated, the general category is too heterogeneous
for meaningful analysis or for use in civil rights monitoring and
enforcement. A heterogeneous category does not provide sufficient
information for health researchers (disease risk specific to racial
and ethnic groups, monitoring of historical trends) and would complicate
the design, conduct, and evaluation of health intervention programs.
It is unclear how such a heterogeneous category could be used in
civil rights monitoring and enforcement and such efforts could
be more difficult and costly.
--There
would be a major effect on historical continuity if specific races
are not indicated because it may reduce the count of the current
broad categories and in unknown ways. Some expressed concern that
if specific races are not known, the category has the potential
for increasing racial segregation, discrimination, and the stigmatization
of broad categories (other than White) which may result in less
effective enforcement of civil rights laws.
--Persons
with the same general cultural heritage and with similar physical
characteristics may be classified differently.
Option
(e)(2)(bb): "Mark all that apply" (SI only)
Pros
of Option (e)(2)(bb) -- mark all that apply:
- Collection:
--If no new categories are added, physical space on forms and questionnaires
same as now.
--Meets
desire for self-identification of many multiracial respondents.
- Tabulation
and analysis:
--Detail allows flexibility. Indicates extent and makeup of Nation's
diversity.
--Can
maintain some historical continuity by aggregating specific
categories into current broad categories (for example, a person
who has one Black parent and one White parent could be tabulated,
depending on the purposes of the data, in three ways: White,
Black, or Black/White). See related discussion below under "cons."
--Decision
rules about aggregations of detailed categories could be discussed
and documented. Currently, we do not know what basis multiracial
people use for marking their specific identity as a broad category.
--Provides
potentially useful subgroup information for health researchers
in terms of race-specific diseases, especially if the race of each
parent is identified. For example, one study found a difference
in the probability of low birth weight between Black mother-White
father and White mother-Black father populations; small-for-gestational-age
rates and preterm delivery rates also vary by race of the mother.
Cons
of Option (e)(2)(bb) -- mark all that apply:
- Collection:
--Telephone survey: Difficult and may negatively affect data quality.
--In
personal interviews, must use a flash card (can list responses
on control card if survey will be done by telephone later);
tedious in large households.
- Tabulations
and analysis:
--Complex because of the many possible combinations. Historical continuity
of counts and characteristics would be problematic. In the 1980 and
1990 censuses, for example, race was reported as "Black" for
two-thirds of children in families with one Black parent and one White
parent present. For families with a White parent and an Asian or Pacific
Islander (API) parent, the proportion of children whose race was reported
as "API" versus "White" was different in the last
two censuses. Allocation rules would be controversial even if the objective
is to achieve historical continuity to the extent possible (especially
for characteristics).
--Aggregation
decision rules would be required and may be subject to controversy.
--Current
Federal laws are premised on persons identifying with one racial
group. It is not clear what the impact would be for persons identifying
as multiracial.
Option
(e)(2)(cc): Open-ended question (SI or OI) (allows multiple responses)
Pros
of Option (e)(2)(cc) -- open-ended question:
- Collection:
--Physical space on questionnaire/forms less than currently.
--Telephone
survey: easy to ask if it is the only category added; however,
if additional categories are added may be problematic.
--Meets
desire for self-identification of many multiracial respondents,
those who want to answer "American," and persons from
small national-origin groups. Respondents likely to be satisfied
since they are not restricted by pre-defined categories. One
study of an open-ended question showed only 13 percent of Hispanic
respondents used the conventional racial designations of "White"
or "Black." For these Hispanics, self-identification
was based more on cultural and ethnic identity. In the 1990 census,
about 90 percent of the population reported an ancestry in the
open-ended question; only 0.7 percent were uncodable responses;
but about 10 percent did not respond to the question.
- Tabulations
and analysis:
--Detail allows maximum flexibility and provides sociologically rich
information for analyzing trends. Provides subgroup information useful
to health researchers in terms of race-specific disease risk.
--Can
maintain some historical continuity by aggregating specific
categories into broad categories in 1977 Directive No. 15 (except
see cons below and under (e)(2)(bb), "tabulations and
analysis").
--Does
not require respondent to indicate a preferred race; if desired,
the tabulation rules can imply a priority by following the order
of responses.
Cons
of Option (e)(2)(cc) -- open-ended question:
- Collection:
--Unlikely States would collect data this way for their administrative
records and thus, there would likely be a mismatch among data
sets (also negative effect on analysis when trying to compare
results among data sets).
--Same
person likely to be identified differently across administrative
records and surveys which reduces analytic usefulness.
--Does
not allow for observer identification.
- Tabulations
and analysis:
--Must develop a classification system to categorize hundreds of possible
responses and the choices can be controversial. See discussion above
in (e)(2)(bb) under cons, "tabulations and analysis."
--Negative
effect on counts of broad categories and data quality, including
considerations listed below: (1) Religions given as responses
cannot be tabulated into a broad category. This generates complaints
(because of separation of church and state, religions cannot
be tabulated by government agencies) and increases the effective
nonresponse rate.
(2)
National origins or nationalities are likely answers. Data collection
agencies would have to code to broad categories based on probability
(e.g., "English" likely to be White but could be Black
or Asian also).
(3)"American" is
a frequent response (the 6th ranked group in the 1990 census ancestry
question with 12.4 million such responses or 5 percent of all responses)
and cannot be coded to a broad category (effectively increases
nonresponse rate). Foreign born and non-English speakers showed
greater difficulty with open-ended write-in questions such as the
1990 census ancestry question.
--Negative
effect on data quality: citing examples is interpreted as influencing
respondents and giving no examples can also have significant effect
on counts of broad categories. Research from the 1980 and 1990
censuses indicates high levels of inconsistent responses to open-ended
questions and strong "example" effects. For instance,
from 1980 to 1990, the number of Cajuns, which was an example in
the ancestry question in 1990 but not in 1980, grew from 30,000
to 600,000. French, which was dropped as an example in 1990, declined
from 13 million to 10 million.
--It
is sometimes hard to interpret what respondents intend by their
responses.
Option
(e)(2)(dd): "Other -- specify" (SI) at end of list
of broad categories
Pros
of Option (e)(2)(dd) -- "other":
- Collection:
--Does not take up much physical space on the questionnaire.
--Telephone
survey: easy to ask if it is the only category added; however,
if additional categories are added may be problematic.
--Identification
issues: respondents likely to find it easier to express their
identity since they are not restricted to only the pre-defined
categories (for example, those who want to answer
"American" can do so); can ask multiracial respondents
to choose one racial category but if they refuse, they can specify
all the categories they choose; and allows identification of multiple
and single categories not listed elsewhere (e.g., Indians of South
and Central American background).
- Tabulations
and analysis:
--Detail allows maximum flexibility and provides sociologically rich
information for analyzing trends. Potentially provides subgroup information
useful to health researchers in terms of race-specific disease risk.
--Can
maintain historical continuity by aggregating specific categories;
however, see discussion in (e)(2)(bb) under cons,
"tabulations and analysis."
Cons
of Option (e)(2)(dd) -- "other":
- Collection:
--Some people are offended by identification as "Other";
when this proposal was made by OMB in 1988, it was not widely accepted
and so was not adopted.
--Same
person likely to be identified differently across administrative
records and surveys which reduces analytic usefulness.
--If "Hispanic" is
not listed as a separate category, research shows an extremely
high percentage of "Other" responses are Hispanics
who do not identify with one of the listed race categories.
- Tabulations
and analysis:
--Must develop a classification system to categorize hundreds of possible
responses and the choices can be controversial. See discussion in (e)(2)(bb)
under cons, "tabulations and analysis."
--Detailed
information not needed for program evaluation or civil rights
monitoring and enforcement.
--If
specific responses are not coded, the category is too heterogeneous
to be useful.
--Negative
effects on counts of broad categories and data quality, including
considerations listed below:
(1) Religions given as responses cannot be tabulated into a broad
category. This generates complaints (because of separation of church
and state, religions cannot be tabulated by government agencies)
and increases the effective nonresponse rate.
(2)
National origins or nationalities are likely answers. Data collection
agencies would have to code to broad categories based on probability
(e.g., "English" likely to be White but could be Black
or Asian also).
(3) "American" is
a frequent response (the 6th ranked group in the 1990 census ancestry
question with 12.4 million such responses or 5 percent of all responses)
and cannot be coded to a broad category (effectively increases
nonresponse rate).
--Negative
effect on data quality: citing examples is interpreted as influencing
respondents and giving no examples can also have significant effect
on counts of broad categories.
--It
is sometimes hard to interpret what respondents intend by their
responses.
Option
(e)(2)(ee): Mother's and Father's Geographic Ancestry (SI only)
(Respondent would be given a numbered geographic list and mark the
appropriate numbers to indicate the region of origin of ancestors
who migrated to the United States)
Pros
of Option (e)(2)(ee) -- geographic ancestry:
- Collection:
--No overlapping categories.
--One
clear concept, geographic origin of ancestors. In the 1990
census ancestry question, virtually all of the responses were
national origin rather than ethnic origin (e.g., "Italian"
more often than "Amalfi" or "Calabrian").
--Telephone
survey: can do but not easily.
- Tabulations
and analysis: Geographic origin may be a better indicator of health
differences than race for many people. Tabulations would be lengthy
but not difficult.
Cons
of Option (e)(2)(ee) -- geographic ancestry:
- Collection
-- identification issues:
--People who can mark their race may not know the geographic region
of origin of their ancestors or parents (e.g., adoptees).
--Likely
to be a high rate of error in the "North America" category
(only American Indians could correctly mark this category but
it is likely those born in the United States would also mark
it).
--Same
person likely to be identified differently across administrative
records and surveys which reduces analytic usefulness.
--Many
people have ancestors from several different geographic regions
and reports are often inconsistent among data sets.
- Collection
-- physical space on forms: considerably more than currently.
- Tabulation
and analysis: Does not meet Federal program needs or provide historical
continuity (for example, a person from Africa might be White or Black).
Option
(e)(2)(ff): Skin-Color Gradient Chart (SI or OI) This is a suggestion
for a numbered chart, a scale of skin-tone colors, reproduced on
forms. Respondents would check the skin-tone number closest to the
color of the individual respondent.
Pros
of Option (e)(2)(ff) -- skin color chart:
Cons
of Option (e)(2)(ff) -- skin color chart:
- Collection:
--Identification: offensive to many; same person likely to be identified
differently across administrative records and surveys which reduces
analytic usefulness; individuals could change skin colors over
a lifetime as a result of exposure to sunlight or disease.
--Telephone
survey: impossible.
--Costly:
requires precise, multicolor printing (color tones will vary
among forms) when one-color (usually black) printing is now the
case for most forms and questionnaires.
- Tabulation
and analysis:
--No historical continuity; does not meet program needs.
--Skin
color (melanin content) is not the sole way people identify
their race and ethnicity. Culture, geography, and history,
for example, are also considerations for many. For example,
Black Africans and very dark Asian Indians may have similar
skin tones but do not consider themselves in the same race
category.
--Blood
relatives may be coded differently.
--Not
useful for health research or other types of socioeconomic research.
Past research
results/literature review on a multiracial category: Some persons of
mixed parentage or parents of interracial children who want to report
more than one race are unsure how to respond. In the 1990 census, 98
percent of the population identified in one category; only 2 percent
provided write-in multiple responses to the race question despite the
instruction to mark one race only. Developing instructions for who
should and who should not mark a
"multiracial" category is difficult; in a 1994 pretest of the
Census Bureau's redesigned Survey of Income and Program Participation,
some persons thought they were being asked what race they would like
to be if they could be multiracial even though their parents were from
the same racial group.
(f)
Hispanic origin
Directive No. 15 defines Hispanic as a person of Mexican, Puerto Rican, Cuban, Central
or South American, or other Spanish culture or origin, regardless of race.
There is significant confusion in public comment as to whether Spaniards,
Portuguese, Brazilians, and American Indians with a mixed heritage of Mexican
or Central or South American tribes are included in the category, "Hispanic
origin." Three major questions were raised. One is whether Hispanic
origin should be a category in a single "race/ethnicity"
question or whether there should be a question about Hispanic origin
separate from race (discussed in Issue 3 above). The other two questions,
on heterogeneity of the category and terminology, are discussed below.
This summary reports only on options proposed during public hearings
and in the public comment period. It also highlights pros and cons for
these options as raised in public comment or shown by research. Inclusion
in the summary does not reflect OMB endorsement of the comments or suggestions.
Requests included:
Options
Suggested in Public Comment:
(1) Collect
data for population subgroups of the "Hispanic origin" category.
Pros
of Option (f)(1):
- Tabulation
and analysis: The category, "Hispanic origin," represents
a heterogeneous population. Information on subgroups describes
the significant social, economic, and health differences among
the Puerto Rican, Mexican-American, Cuban, and other Hispanic populations.
Cons
of Option (f)(1):
- Collection:
Visual identification of nationality groups is difficult.
(2) Alternative
or additional words suggested for "Hispanic" include
"Latino/Hispanic Origin," "Latino," "Latin," "Latin
American," and
"Hispanics from the Americas" (to exclude persons from Spain
and the Philippines). Persons of Mexican ancestry did not agree on terminology
for their group. Some wanted "Pre-Columbian" because of their
Mestizo (Indian) background. Others disagreed saying some Mexicans have
European background. Some preferred the term, "Chicano" to
identify Mexican-Americans while others found the term offensive.
Pros
of Option (f)(2):
- Collection:
Some respondents prefer an alternative.
Cons
of Option (f)(2):
- Collection:
The term, "Latino," includes a diverse group of people
from many national origins, races, and backgrounds. Some understand
the term, "Latin" or "Latino" to include Europeans
such as Italians, French, Portuguese, Romanians, and Spaniards.
Cognitive research by the Census Bureau indicates some understand "Latino" as
meaning from Latin America, "Hispanic" as meaning someone
who speaks Spanish, and "of Spanish origin" as someone
from Spain or with a distant relative who was Hispanic.
Past research
results/literature review: Results from the 1990 census showed that
the Hispanic population of some 22.4 million grew by 53 percent from
1980 to 1990. Immigration accounted for about half the growth. Overall,
the Census Bureau considers the quality of census and survey data for
Hispanic origin to be good. Nevertheless, evaluations show high nonresponse
(10 percent; research shows most are not Hispanics) and misreporting
(for example, some non-Hispanics report in the "Mexican-Amer." category
to indicate they are American). In the 1990 census race question, two
in three persons who did not mark a race circle, wrote in a response
reflecting Hispanic ethnicity. Among persons who indicated in the 1990
census that they were of Hispanic origin, 52 percent marked the "White" circle
and 43 percent marked the "Other race" circle. Based on evaluations
of the 1980 Census and 1990 Census pretests, it appears that persons
reporting
"Other Spanish/Hispanic," included Brazilians and other persons
of Portuguese descent who feel the term, "Hispanic," also applies
to them.
C. Future
Research Agenda
Agency staff
and funding for research and testing associated with possible changes are
very limited. As a result, plans necessarily have to be developed within
those resource constraints and may change. Within available resources,
Federal agencies are conducting research through 1996 to inform decisions
on selected options. A brief summary of the future research agenda, as
of April 1995, is presented in this section. The number of issues that
can be tested in 1995 and 1996 is limited. This Federal Register notice
provides the last opportunity for public comment on priorities for research
in 1996.
Research
Agenda
The Interagency
Committee's Research Working Group, which is co-chaired by the Bureau of
the Census and the Bureau of Labor Statistics, reviewed all the criticisms
and suggestions for changing the current categories that appeared in OMB's
June 9, 1994, Federal Register notice, including requests received during
the public comment period to expand the standards by establishing additional
categories for specific population groups. Some of the more significant
issues that have been identified for research and testing are: classification
of multiracial persons; combining race and Hispanic origin; combining concepts
of race/ethnicity/ancestry; changing the names of current categories; and
adding new classifications. The Race and Ethnic Targeted Test, to be conducted
by the Bureau of the Census in 1996, will be the major opportunity to test
three to four options on race and ethnicity.
The Bureau
of Labor Statistics designed a Supplement to the May 1995 Current
Population Survey (CPS) to provide information about three issues
with respect to Directive No. 15. They are (1) what proportion of
respondents will choose a "multiracial" category and how
that may impact on the data for the other racial categories; (2)
inclusion of an Hispanic category in the list of races; and (3) preferences
concerning specific terms such as "African American" and "Latino."
To gather this information, the Supplement is divided into four panels,
and a random sample of approximately 15,000 of the 60,000 CPS households
will receive one of the following four survey instruments.
Panel
1: Separate race and Hispanic origin questions; no multiracial
category
Panel
2: Separate race and Hispanic origin questions; with a multiracial
category and races specified
Panel
3: A combined race and Hispanic origin question; no multiracial
category
Panel
4: A combined race and Hispanic origin question; with a multiracial
category and races specified
In addition,
all households in the May Supplement will be asked questions about
their ancestry, preferences concerning specific terms, and use of languages
other than English in the home. The ancestry and language questions
are included to help explain differences in reporting by households
with similar racial characteristics. Results of this test are expected
to be available in late Fall 1995.
Multiracial
Category.-- Research and testing of a multiracial category is especially
important since it could have a significant impact on the usefulness
of data resulting from the current racial and ethnic categories. An
important aspect of this issue on which research needs to be conducted
is the extent to which persons of mixed racial heritage will identify
in a separate multiracial category on surveys and censuses.
To begin
research on this issue, a multiracial response option was included
in operational pretests for the revised Survey of Income and Program
Participation involving 292 households in the Atlanta, Boston, and
Chicago metropolitan areas during April and May 1994. Despite the small
sample size, the results were somewhat informative for two reasons:
(1) a higher percentage (7.3 percent) of persons reported in the multiracial
category than have done so in some of the records from school and military
systems cited in various public hearings and conferences, and (2) in
nearly two-thirds (65 percent) of the 55 write-ins to the multiracial
item, the respondent reported as Hispanic (23 cases or 42 percent)
or as Hispanic and some other race group. The higher percentage reporting
as multiracial might reflect the sites of the pretest and the oversampling
of low and high income areas. The high proportion of multiracial responses
involving Hispanics does indicate that a multiracial category might
draw disproportionately more responses from Hispanics than from the
other racially mixed persons for whom many were seeking this option.
These results underscored the importance of testing the multiracial
category in larger samples (as in the May 1995 CPS Supplement), as
well as perhaps the need for additional definitions or instructions
for the category if the intention is to draw responses primarily from
persons whose parents are of different races. These early findings
also served to indicate that cognitive research would aid in developing
that Supplement.
In preparation
for the May 1995 CPS Supplement, cognitive research interviews were
conducted in 1994 and early 1995 with individuals who have parents
of different races, as well as individuals who may identify with only
one race, even though they may have a mixed heritage. The main objective
of this cognitive research was to examine how individuals view race
and ethnicity and how they might interpret and respond to a race question
that provides a "multiracial, specify"
option.
Combining
Race and Hispanic Origin. -- The May 1995 CPS Supplement will provide
needed research on whether a combined race/Hispanic ethnicity question
should be used instead of separate questions on race and Hispanic ethnicity.
Important reasons to research this issue are that some Federal agencies
have been collecting and reporting data in a combined format for a
number of years, and a high percentage of Hispanics selected "other
race" in the 1990 decennial census race question when race and
ethnicity were collected in two separate questions. Research questions
include examining the effects of having a single race and Hispanic
ethnicity question on the counts for other races and for Hispanics;
examining which subgroups to include as "Hispanic"; determining
what percentage of administrative record data bases already use "Hispanic" as
a racial category and what percentage of respondents in these data
bases are missing information on Hispanic ethnicity; and deciding if
Hispanic ethnicity should be assumed to take priority over other racial
categories (e.g., Black Hispanics).
In considering
this issue, one should bear in mind that the concepts of race, ethnicity,
and ancestry are not clearly or consistently distinguished in the U.S.
population. For example, some Hispanics regard the "Hispanic" designation
as a "racial" category, defining
"race" in terms of national origin and cultural characteristics.
As discussed below, it has been suggested, therefore, that census and
survey respondents be asked about only a single concept -- perhaps ethnicity
or race/ethnicity -- corresponding to self-perceived membership in population
groups that might define themselves by cultural heritage, language, physical
appearance, behavior, or other characteristics.
Combining
Concepts of Race/Ethnicity/Ancestry.--Directive No. 15 has been criticized
for not clearly distinguishing among race, ethnicity, and ancestry.
Directive No. 15 specifically notes the absence of anthropological
or other scientific bases for their separate designation. Varied and
possibly inconsistent definitional criteria, such as geographic origin,
cultural origin, cultural identification and affiliation, community
recognition, and race itself, are used to describe the terms. The current
Federal categories have created five single aggregations from heterogeneous
and highly diverse populations. Since ethnic groups evolve and may
change their group name over time, research is needed on the basic
concepts to be measured as well as on the popular terminology respondents
use to refer to their ethnic group. This research will be helpful in
determining those response categories which would provide useful information
about our Nation's population.
The research
on this issue needs to consider a number of implications of combining
the concepts. The consolidation of questions of "race,"
"ethnicity," and "ancestry" into a single question
of "ethnicity"
(or "race/ethnicity") or of "identified population groups" would
eliminate the distinction between race and ethnicity indicated in Directive
No. 15. Consolidation of the categories would also address the issue
of including Hispanics as a racial designation rather than as a separate
ethnic category. Under consolidation, Hispanic would be included as an
ethnic or racial/ethnic category along with other categories previously
classified as races. If, in addition to consolidating categories, respondents
are allowed to select more than one ethnic or racial/ethnic identity,
the issue of "multiracial"
identification might also be addressed. The combined question would most
likely solicit multi-ethnic as well as multiracial responses. In the
1990 census ancestry question, which allows multiple reporting of ethnicities,
about 30 percent of the population reported multiple ancestries. Such
a large proportion of multiple responses would present processing problems
for Federal agencies. The consolidation of race and ethnicity would interrupt
the continuity of categorization in the race and ethnicity questions
in recent decades; however, continuity is already imperfect due to changes
in questions and response options.
Terminology
for Categories.--This issue is concerned with whether to replace or
revise current terminology for Black, Hispanic, or American Indian
racial/ethnic categories for data collection and data reporting with
terms that have been suggested such as African American, Latino/Latina,
and Native American. Research is needed to determine whether, and in
what ways, any proposed changes in terminology may affect reporting
or data collection. If a change in terms produces a change in coverage,
it is useful to know what that change signifies. Any replacement of
terminology should consider: (1) that the new terms might have meanings
different from the old terms for respondents while, for the users,
the old and new categories might appear synonymous; (2) that as current
usage changes, terms are likely to have different meanings to people,
and the new terms may exclude persons who were comfortable with the
old terms but who may not perceive themselves as "fitting" under
the new designation; and (3) the extent to which definitions need to
accompany new categories. Questions about preferences for various terms
are included on the May 1995 CPS supplement.
Additional
research plans:
- The
Census Bureau is conducting cognitive research from February through
July 1995 on issues such as a multiracial category, marking all
categories that apply, terminology, and a combined race/Hispanic
origin/ancestry question. Research on the classification of "Native
Hawaiian" is also planned. The extent of research is dependent
upon available resources. The Census Bureau also plans to conduct
two tests in 1996: the National Content Test (NCT) and the Race
and Ethnic Targeted Test (RAETT). The NCT is designed to test selected
population and housing questions for the 2000 census. It will be
a national sample of 35,000 to 50,000 households. To determine
what information respondents will provide in a self-reporting context,
the Census Bureau has identified a multiracial category or response
option (for example, multiple responses) as a high priority for
panels on the 1996 National Content Test. Other issues to be tested
in the NCT include terminology and the placement of the Hispanic
origin question first, followed immediately by the race question.
The RAETT, which will include a reinterview, will provide the most
extensive opportunity to test several options for collecting racial
and ethnic data. The proposed sample of about 90,000 households
will be targeted to a diverse sample of racial and ethnic populations.
The Census Bureau expects that the RAETT will allow further testing
of a multiracial classification, terminology, and other selected
options.
- The National
Center for Health Statistics and the Office of the Assistant Secretary
for Health will conduct research on the effects of changes in racial
classification on birth certificate records.
- The Centers
for Disease Control and Prevention is undertaking a project to evaluate
the recording of racial classifications on death certificates. This
study will involve a survey of a sample of funeral directors with
the aim of improving the quality of racial data reported on death
certificates.
- A literature
search on work related to racial classification in the health field
(using MEDLINE) is being conducted by the Department of Health and
Human Services (DHHS).
- An inventory
of DHHS minority health data bases is being developed by the DHHS.
It will provide information on what data are available and data collection
problems that have been encountered.
- The National
Center for Education Statistics (NCES) is conducting a Spring 1995
survey to obtain information: (a) how schools currently students'
collect racial and ethnic data; (b) how administrative records containing
racial and ethnic data are maintained and reported; (c) what State
laws mandate or require of school systems with respect to collecting
data on race and ethnicity; and (d) current issues in schools regarding
race and ethnicity categories.
D. General
Principles for the Review of the Racial and Ethnic Categories
The criticisms
and suggestions for changing Directive No. 15 have underscored the importance
of having a set of general principles to govern the current review process.
The following principles were drafted in cooperation with Federal agencies
serving on the Interagency Committee. The principles listed below are those
OMB may use to guide final decisions on standards for the classification
of racial and ethnic data. The principles are, for the most part, the same
as those published in the June 9, 1994, Federal Register notice. There
are changes to Principles 2, 5, 6, and 8. Principles 12 and 13 are new.
The public is invited to comment on these or suggest additional principles.
- The
racial and ethnic categories set forth in the standard should not
be interpreted as being primarily biological or genetic in reference.
Race and ethnicity may be thought of in terms of social and cultural
characteristics as well as ancestry.
- Respect
for individual dignity should guide the processes and methods for
collecting data on race and ethnicity; ideally, respondent self-identification
should be facilitated to the greatest extent possible, recognizing
that in some data collection systems observer identification is more
practical.
- To the
extent practicable, the concepts and terminology should reflect clear
and generally understood definitions that can achieve broad public
acceptance. To assure they are reliable, meaningful, and understood
by respondents and observers, the racial and ethnic categories set
forth in the standard should be developed using appropriate scientific
methodologies, including the social sciences.
- The racial
and ethnic categories should be comprehensive in coverage and produce
compatible, nonduplicated, exchangeable data across Federal agencies.
- Foremost
consideration should be given to data aggregations by race and ethnicity
that are useful for statistical analysis and program administration
and assessment, bearing in mind that the standards are not intended
to be used to establish eligibility for participation in any Federal
program.
- The standards
should be developed to meet, at a minimum, Federal legislative and
programmatic requirements. Consideration should also be given to
needs at the State and local government levels, including American
Indian tribal and Alaska Native village governments, as well as to
general societal needs for these data.
- The categories
should set forth a minimum standard; additional categories should
be permitted provided they can be aggregated to the standard categories.
The number of standard categories should be kept to a manageable
size, as determined by statistical concerns and data needs.
- A revised
set of categories should be operationally feasible in terms of burden
placed upon respondents; public and private costs to implement the
revisions should be a factor in the decision.
- Any changes
in the categories should be based on sound methodological research
and should include evaluations of the impact of any changes not only
on the usefulness of the resulting data but also on the comparability
of any new categories with the existing ones.
- Any revision
to the categories should provide for a crosswalk at the time of adoption
between the old and the new categories so that historical data series
can be statistically adjusted and comparisons can be made.
- Because
of the many and varied needs and strong interdependence of Federal
agencies for racial and ethnic data, any changes to the existing
categories should be the product of an interagency collaborative
effort.
- Time
will be allowed to phase in any new categories. Agencies will not
be required to update historical records.
- The new
directive should be applicable throughout the U.S. Federal statistical
system. The standard or standards must be usable for the decennial
census, current surveys, and administrative records, including those
using observer identification.
The agencies
recognize that these principles may in some cases represent competing
goals for the standard. Through the review process, it will be necessary
to balance statistical issues, needs for data, and social concerns.
The application of these principles to guide the review and possible
revision of the standard ultimately should result in consistent, publicly
accepted data on race and ethnicity that will meet the needs of the
government and the public while recognizing the diversity of the population
and respecting the individual's dignity.
Sally Katzen
Administrator,
Office of Information and Regulatory Affairs
APPENDIX
DIRECTIVE
NO. 15
RACE
AND ETHNIC STANDARDS FOR FEDERAL STATISTICS
AND ADMINISTRATIVE REPORTING
(as
adopted on May 12, 1977)
This Directive
provides standard classifications for recordkeeping, collection, and presentation
of data on race and ethnicity in Federal program administrative reporting
and statistical activities. These classifications should not be interpreted
as being scientific or anthropological in nature, nor should they be viewed
as determinants of eligibility for participation in any Federal program.
They have been developed in response to needs expressed by both the executive
branch and the Congress to provide for the collection and use of compatible,
nonduplicated, exchangeable racial and ethnic data by Federal agencies.
1. Definitions
The basic racial
and ethnic categories for Federal statistics and program administrative
reporting are defined as follows:
a. American
Indian or Alaskan Native. A person having origins in any of
the original peoples of North America, and who maintains cultural
identification through tribal affiliations or community recognition.
b. Asian
or Pacific Islander. A person having origins in any of the original
peoples of the Far East, Southeast Asia, the Indian subcontinent,
or the Pacific Islands. This area includes, for example, China, India,
Japan, Korea, the Philippine Islands, and Samoa.
c. Black. A
person having origins in any of the black racial groups of Africa.
d. Hispanic. A
person of Mexican, Puerto Rican, Cuban, Central or South American or
other Spanish culture or origin, regardless of race.
e. White. A
person having origins in any of the original peoples of Europe, North
Africa, or the Middle East.
2. Utilization
for Recordkeeping and Reporting
To provide
flexibility, it is preferable to collect data on race and ethnicity separately.
If separate race and ethnic categories are used, the minimum designations
are:
- a. Race:
- - American
Indian or Alaskan Native
- Asian or Pacific Islander
- Black
- White
- b. Ethnicity:
- - Hispanic
origin
- Not of Hispanic origin
When race
and ethnicity are collected separately, the number of White and Black
persons who are Hispanic must be identifiable, and capable of being
reported in that category.
If a combined
format is used to collect racial and ethnic data, the minimum acceptable
categories are:
American
Indian or Alaskan Native
Asian or Pacific Islander
Black, not of Hispanic origin
Hispanic
White, not of Hispanic origin.
The category
which most closely reflects the individual's recognition in his community
should be used for purposes of reporting on persons who are of mixed
racial and/or ethnic origins.
In no case
should the provisions of this Directive be construed to limit the collection
of data to the categories described above. However, any reporting required
which uses more detail shall be organized in such a way that the additional
categories can be aggregated into these basic racial/ethnic categories.
The minimum
standard collection categories shall be utilized for reporting as follows:
a. Civil
rights compliance reporting. The categories specified above will
be used by all agencies in either the separate or combined format
for civil rights compliance reporting and equal employment reporting
for both the public and private sectors and for all levels of government.
Any variation requiring less detailed data or data which cannot be
aggregated into the basic categories will have to be specifically
approved by the Office of Management and Budget (OMB) for executive
agencies. More detailed reporting which can be aggregated to the
basic categories may be used at the agencies' discretion.
b. General
program administrative and grant reporting. Whenever an agency
subject to this Directive issues new or revised administrative reporting
or recordkeeping requirements which include racial or ethnic data,
the agency will use the race/ethnic categories described above. A
variance can be specifically requested from OMB, but such a variance
will be granted only if the agency can demonstrate that it is not
reasonable for the primary reporter to determine the racial or ethnic
background in terms of the specified categories, and that such determination
is not critical to the administration of the program in question,
or if the specific program is directed to only one or a limited number
of race/ethnic groups, e.g., Indian tribal activities.
c. Statistical
reporting. The categories described in this Directive will be
used at a minimum for federally sponsored statistical data collection
where race and/or ethnicity is required, except when: the collection
involves a sample of such size that the data on the smaller categories
would be unreliable, or when the collection effort focuses on a specific
racial or ethnic group. A repetitive survey shall be deemed to have
an adequate sample size if the racial and ethnic data can be reliably
aggregated on a biennial basis. Any other variation will have to
be specifically authorized by OMB through the reports clearance process.
In those cases where the data collection is not subject to the reports
clearance process, a direct request for a variance should be made
to OMB.
3. Effective
Date
The provisions
of this Directive are effective immediately for all new and revised recordkeeping
or reporting requirements containing racial and/or ethnic information.
All existing recordkeeping or reporting requirements shall be made consistent
with this Directive at the time they are submitted for extension, or not
later than January 1, 1980.
4. Presentation
of Race/Ethnic Data
Displays of
racial and ethnic compliance and statistical data will use the category
designations listed above. The designation "nonwhite" is not
acceptable for use in the presentation of Federal Government data. It is
not to be used in any publication of compliance or statistical data or
in the text of any compliance or statistical report.
In cases
where the above designations are considered inappropriate for presentation
of statistical data on particular programs or for particular regional
areas, the sponsoring agency may use:
(1) The
designations "Black and Other Races" or "All Other Races," as
collective descriptions of minority races when the most summary distinction
between the majority and minority races is appropriate;
(2) The
designations "White," "Black,"and "All Other
Races" when the distinction among the majority race, the principal
minority race and other races is appropriate; or
(3) The
designation of a particular minority race or races, and the inclusion
of "Whites" with "All Other Races," if such a collective
description is appropriate.
In displaying
detailed information which represents a combination of race and ethnicity,
the description of the data being displayed must clearly indicate that
both bases of classification are being used.
When the
primary focus of a statistical 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 0and to describe data relating to the remainder of the population
by an appropriate collective description.
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