1. We call on the Census Bureau to fully and expeditiously implement the updated race and ethnicity question established in OMB's 2024 Statistical Policy Directive No. 15 (2024 SPD 15) on the 2027 ACS.
We strongly support the proposal to implement the 2024 SPD 15 race and ethnicity question on the 2027 ACS. The Census Bureau’s extensive research informing the 2024 SPD 15 standards indicates that the combined question format with a distinct Middle Eastern/North African (MENA) category and detailed checkboxes and write-in spaces will yield more accurate, comprehensive, and useful data about the nation’s population. The modernized question will reduce the proportion of Latino individuals classified as “Some Other Race,” produce federal data about MENA communities for the first time ever, and provide more nuanced data about the diverse subgroups within the broader 1997 SPD 15 race and ethnicity categories. To achieve these improvements in data quality, the revised 2027 ACS question must include the minimum categories, detailed checkboxes, and write-in spaces with examples specified in Figure 1 of 89 FR 22182, “Revisions to OMB's Statistical Policy Directive No. 15: Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity”2, in accordance with OMB’s directive to use the most detailed version of the question categories “whenever possible.”
Coding and tabulation considerations:
The Census Bureau’s coding and tabulation of ACS race and ethnicity data collected using the updated question must also reflect this guidance from OMB. We call on the Bureau to report the most detailed race and ethnicity data possible for all categories on the revised question, while taking appropriate measures to protect the confidentiality of data for smaller demographic groups. Since research suggests that the number of individuals reporting more than one race and/or ethnicity category will significantly increase with the revised question, we urge the Bureau to begin reporting more granular race and ethnicity datasets based on multi-race/ethnic responses, in particular. For example, the Bureau should publish data and analysis on respondents who select Black/African American and Hispanic/Latino, and Black/African American and MENA, as well as respondent combinations of subgroups within these major categories (such as Black and Dominican), as long as respondent confidentiality is protected. We also note that the Bureau is long overdue in responding to public comments3,4,5,6 in response to its November 18, 2024, Federal Register Notice on the Proposed Race/Ethnicity Code List for the American Community Survey and the 2030 Census7 (2030 Code List). The Bureau must update stakeholders as soon as possible on the timeline for finalizing the code list and how it is incorporating public input on the final list.
The Census Bureau must also clearly communicate to the public how it will tabulate and report race and ethnicity data under the new standards. We urge the Bureau to publish guidance for data users with varying levels of technical expertise on how to compare and bridge data collected under the revised question with previous data. In particular, the Bureau must proactively educate stakeholders and the public about how its coding and tabulation schemes for the 2024 SPD 15 categories may lead to apparent demographic shifts to prevent potential misinterpretation of such changes. Given the likely increase in the number of people reported as “more than one race or ethnicity,” the Bureau must be very clear about when new coding and tabulation procedures, rather than actual demographic change, are likely the primary cause of such shifts."
Leveraging 2027 ACS implementation for further research:
Full implementation of the updated question format and minimum categories on the 2027 ACS will also be critical to understanding how the question performs in a large-scale data collection. As noted in our comments on the proposed 2030 Code List3 and comments submitted to the November 2024 meeting of the Census Bureau National Advisory Committee on Racial, Ethnic, and Other Populations8, the Bureau should leverage implementation of the SPD 15 question format on the ACS and other surveys to conduct ongoing research on the updated question’s performance. In particular, we urge the Census Bureau to use implementation on the 2027 ACS to evaluate how well the detailed checkboxes and write-in examples in the revised question format capture respondent intent. The Bureau must prioritize consultation with stakeholders throughout this research to better understand how specific groups, particularly Afro-Latino, MENA, and multiracial/multiethnic respondents, interpret and respond to the updated question. The Bureau should then use this research and stakeholder input to develop robust guidance for the public about the updated question in advance of its rollout on the 2030 Census.
The Bureau should also leverage implementation of the updated question format on the ACS to further evaluate its coding and tabulation schemes and better understand how data users interact with data collected through the revised question. The results of such research will allow the Bureau to further refine guidance for data users on tabulation and bridging before the 2030 Census. We call on the Bureau to carry out these and other research recommendations provided in our previous comments on the proposed 2030 Code List as it implements the updated race and ethnicity question on the 2027 ACS.