Recommendations from the Interagency Committee for the Review of the Racial and Ethnic Standards to the Office of Management and Budget Concerning Changes to the Standards for the Classification of Federal Data on Race and Ethnicity

AGENCY: Executive Office of the President, Office of Management and Budget (OMB), Office of Information and Regulatory Affairs

ACTION: Notice and Request for Comments

SUMMARY: OMB requests comments on the recommendations that it has received from the Interagency Committee for the Review of the Racial and Ethnic Standards (Interagency Committee) for changes to OMB's Statistical Policy Directive No. 15, Race and Ethnic Standards for Federal Statistics and Administrative Reporting (See Appendix 1 for the text of the standards in Directive No. 15, originally issued in 1977). The Interagency Committee's report and recommendations, which are published in Appendix 2 in their entirety, are the result of a four-year, comprehensive review of the current standards.

DATES: To ensure consideration during the final decision making process, written comments must be provided to OMB no later than [INSERT DATE 60 DAYS FROM DATE OF PUBLICATION].

ADDRESSES: Written comments on the recommendations may be addressed to Katherine K. Wallman, Chief Statistician, Office of Information and Regulatory Affairs, Office of Management and Budget, NEOB, Room 10201, 725 17th Street, N.W., Washington, D.C. 20503.

Comments may also be submitted by facsimile to 202-395-7245, or by electronic mail to OMBDIR15@A1.EOP.GOV (please note that "1" in "A1" is the number one and not the letter "l"). Be sure to include your name and complete postal mailing address in the comments sent by electronic mail. If you submit comments by facsimile or electronic mail, please do not also submit them by regular mail.

Electronic availability and addresses: This Federal Register Notice, as well as the June 9, 1994 and the August 28, 1995 Federal Register Notices related to the review, are available electronically from the OMB Homepage on the World Wide Web: /OMB/fedreg/, and in paper copy from the OMB Publications Office, 725, 17th Street, NW, NEOB, Room 2200, Washington, D.C. 20503, telephone: (202) 395-7332, facsimile: (202) 395-6137.

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 current standards were developed in cooperation with the Federal agencies to provide consistent and comparable data on race and ethnicity throughout the Federal government for an array of statistical and administrative programs. Development of the data standards stemmed in large measure from new responsibilities to enforce civil rights laws. Data were needed to monitor equal access to housing, education, employment opportunities, etc., for population groups that historically had experienced discrimination and differential treatment because of their race or ethnicity. The categories that were developed represent a political-social construct designed to be used in the collection of data on the race and ethnicity of major broad population groups in this country, and are not anthropologically or scientifically based. The standards are used not only in the decennial census (which provides the "denominator" for many measures), but also in household surveys, on administrative forms (e.g., school registration and mortgage lending applications), and in medical and other research.

The standards provide a minimum set of categories for data on race and ethnicity.

The current standards have four categories for data on race (American Indian or Alaskan Native, Asian or Pacific Islander, Black, and White) and two categories for data on ethnicity ("Hispanic origin" and "Not of Hispanic origin"). The standards als o permit the collection of more detailed information on population groups provided that any additional categories can be aggregated into the minimum standard set of categories. Self-identification is the preferred means of obtaining information about an individual's race and ethnicity, except in instances where observer identification is more practical (e .g., completing a death certificate).

The categories in Directive No. 15 do not identify or designate certain population groups as "minority groups." As the Directive explicitly states, these categories are not to be used for determining the eligibility of population groups for pa rticipation in any Federal programs. Directive No. 15 does not establish criteria or qualifications (such as blood quantum levels) that are to be used in determining a particular individual's racial or ethnic classification. Directive No. 15 does not tell an individual who he or she is, or specify how an individual should classify himself or herself.

B. Review Process

Particularly since the 1990 census, 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 that has resulted primarily from growth in immigration and in interracial marriages. In response to the criticisms, OMB announced in July 1993 that it would undertake a comprehensive review of the current categories for data on race and ethnicity.

This review has been conducted over the last four years in collaboration with the Interagency Committee for the Review of the Racial and Ethnic Standards, which OMB established in March 1994 to facilitate the participation of Federal agencies in the review.

The members of the Interagency Committee, from more than 30 agencies, represent the many and diverse Federal needs for data on race and ethnicity, including statutory requirements for such data.

The principal objective of the review is to enhance the accuracy of the demographic information collected by the Federal Government. The starting point for the review was the current minimum set of categories for data on race and ethnicity that have provided 20 years of information for a variety of purposes, and the recognition of the importance of being able to maintain this historical continuity. The review process has had two major elements: (1) public comment on the present standards, whi ch helped to identify concerns and provided numerous suggestions for changing the standards; and (2) research and testing related to assessing the possible effects of suggested changes on the quality and usefulness of the resulting data.

Public input, the first element of the review process, was sought through a variety of means: (1) During 1993, Congressman Thomas C. Sawyer, then Chairman of the House Subcommittee on Census, Statistics, and Postal Personnel, held four hearings that included 27 witnesses, focusing particularly on the use of the categories in the 2000 census. (2) At the request of OMB, the National Academy of Sciences' Committee on National Statistics (CNSTAT) conducted a workshop in February 1994 to articulate issues surrounding a review of the categories. The workshop included representatives of Federal agencies, academia, social science research institutions, interest groups, private industry, and a local school district. (A summary of the workshop, Spotlight on Heterogeneity: The Federal Standards for Racial and Ethnic Classification, is available from CNSTAT, 2101 Constitution Avenue, N.W., Washington, D.C. 20418.) (3) On June 9, 1994, OMB published a Federal Register (59 FR 29831-29835) Notice that contained background information on the development of the current standards and requested public comment on: the adequacy of current racial and ethnic categories; the principles that should govern any proposed revisions to the standards; and specific suggestions for change that had been offered by individuals and interested groups over the past sev eral years. In response, OMB received nearly 800 letters. As part of this comment period and to bring the review closer to the public, OMB also heard testimony from 94 witnesses at hearings held during July 1994 in Boston, Denver, San Francisco, and Hon olulu. (4) In an August 28, 1995, Federal Register (60 FR 44674-44693) Notice, OMB provided an interim report on the review process, including a summary of the comments on the June 1994 Federal Register Notice, and offered a final opportunity for comment on the research to be conducted during 1996. (5) OMB staff have also made themselves available to discuss the review process with various interested groups and have made presentations at many meetings.

The second element of the review process involved research and testing of various proposed changes. The categories in OMB's Directive No. 15 are used not only to produce data on the demographic characteristics of the population, but also for ci vil rights enforcement and program administration. Research would enable an objective assessment of the data quality issues associated with various approaches to collecting data on race and ethnicity. For that reason, the Interagency Committee's Research Working Group on Racial and Ethnic Standards, which is co-chaired by the Bureau of the Census and the Bureau of Labor Statistics, reviewed the various criticisms and suggestion s for changing the current categories, and developed a research agenda for some of the more significant issues that had been identified. These issues included collecting and classifying data on persons who identify themselves as "multiracial"; combining race and Hispanic origin in one question or having separate questions on race and Hispanic origin; combining the concepts of race, ethnicity, and ancestry; changing the terminology used for particular categories; and adding new categories to the current minimum se t.

Because the mode of data collection can have an effect on how a person responds, the research agenda addressed the issue of how an individual responds when an interviewer collects the information (in an in-person interview or a telephone intervi ew) versus how an individual responds in a self-administered situation, such as in the decennial census when a form is filled out and mailed back. In addition, cognitive research interviews were conducted with various groups to provide guidance on the wording of the questions and the instructions.

The research agenda included several major national tests during the last two years, the results of which are discussed throughout the Interagency Committee's report:

(1) In May 1995, the Bureau of Labor Statistics (BLS) sponsored a Supplement on Race and Ethnicity to the Current Population Survey (CPS). The findings were made available in a 1996 report, Testing Methods of Collecting Racial and Ethnic Information: Results of the Current Population Survey Supplement on Race and Ethnicity, available from BLS, 2 Massachusetts Avenue, N.E., Room 4915, Postal Square Building, Washington, D.C. 20212, by calling 202-606-7375. The results were also summarized in an October 26, 1995, news release, which is available electronically at http://stats.bls.gov/news.release/ethnic.toc.htm. (2) The Bureau of the Census, as part of its research for the 2000 census, tested alternative approaches to collecting data on race and ethnicity in the March 1996 National Content Survey (NCS). The Census Bureau published the results in a December 1996 report, Findings on Questions on Race and Hispanic Origin Tested in the 1996 National Content Survey; highlights of the report are available at http://www.census.gov/population/www/socdemo/96natcontentsurvey.html. (3) In June 1996, the Census Bureau conducted the Race and Ethnic Targeted Test (RAETT), which was designed to permit assessments of effects of possible changes on smaller popul ations not reliably measured in national samples, including American Indians, Alaska Natives, detailed Asian and Pacific Islander groups (such as Chinese and Hawaiians) and detailed Hispanic groups (such as Puerto Ricans and Cubans). The Census Bureau r eleased the results in a May 1997 report, Results of the 1996 Race and Ethnic Targeted Test; highlights of the report are available at http://www/census.gov/population/www/documentation/twps-0018.html. Single copies (paper) of the NCS and RAETT reports may be obtained from the Population Division, U.S. Bureau of the Census, Washington, D.C. 20233; telephone 301-457-2402.

In addition to these three major tests, the National Center for Education Statistics (NCES) and the Office for Civil Rights in the Department of Education jointly conducted a survey of 1,000 public schools to determine how schools collect data o n the race and ethnicity of their students and how the administrative records containing these data are maintained to meet statutory requirements for reporting aggregate information to the Federal Government. NCES published the results in a March 1996 report, Racial and Ethnic Classifications Used by Public Schools. The report is available electronically at http://www.ed.gov/NCES/pubs/98092.html. Single paper copies may be obtained from NCES, 555 New Jersey, NW, Washington, D.C. 20208-5574, or by calling 202-219-1442.

The research agenda also included studies conducted by the National Center for Health Statistics, the Office of the Assistant Secretary for Health, and the Centers for Disease Control and Prevention to evaluate the procedures used and the qualit y of the information in administrative records on race and ethnicity such as that reported on birth certificates and recorded on death certificates. Since these data are used in studies of diseases and of the health and well-being of major population groups, these studies investigated possible impacts of suggested changes on data needed for medical and health research.

C. Overview of Interagency Committee Report

This Federal Register Notice makes available for comment the Interagency Committee's recommendations for how OMB should revise Directive No. 15. These recommendations are elaborated in the Interagency Committee's Report to the Office of Management and Budget on the Review of Statistical Policy Directive No. 15 which is published in its entirety as part of this Notice. The report consists of six chapters. Chapter 1 provides a brief history of Directive No. 15, a summary of the issues considered by the Interagency Committee, a review of the research activities, and a discussion of the criteria used in conducting the evaluation. Chapter 2 discusses a number of general concerns that need to be addressed when considering any changes to the current standards. Chapters 3 through 5 report the results of the research as they bear on the more significant suggestions OMB received for changes to Directive No. 15.

Chapter 6 gives the Interagency's Committee's recommendations concerning the various suggested changes based on a review of public comments and testimony and the research results.

This Notice affords a final opportunity for the public to comment before OMB acts on the recommendations of the Interagency Committee. None of the recommendations has been adopted and no interim decisions have been made concerning them. OMB ca n modify or reject any of the recommendations, and OMB has the option of making no changes. The report and its recommendations are published in this Notice because OMB believes that they are worthy of public discussion and that OMB's decision will benefi t from obtaining the public's views on the recommendations. OMB will announce its decision in mid-October 1997, so that changes, if any, can be incorporated into the questions for the 2000 census "dress rehearsal," which will be conducted in spring 1998.

ISSUES FOR COMMENT: With this Notice, OMB requests comments on the recommendations it has received from the Interagency Committee for the Review of the Racial and Ethnic Standards concerning the revision of Statistical Policy Directive No. 15. These recommendations are contained in Chapter 6 of the Interagency Committee's report.

The complete report is included in this Notice because Chapters 1 through 5 provide both a context and the bases for the Interagency Committee's recommendations outlined in Chapter 6. As an aid in evaluating the recommendations, readers may wis h to refer to the set of general principles (see Chapter 1) that were developed at the beginning of the Directive No. 15 review to govern the process -- a process that has attempted to balance statistical issues, needs for data, social concerns, and the personal dimensions of racial and ethnic identification. The committee recognized that these principles may in some cases represent competing goals for the standard. For example, having categories that are comprehensive in the coverage of our Nation's diverse population (Principle 4) and that would facilitate self-identification (Principle 2) may not be operationally feasible in terms of the burden that would be placed upon respondents and the public and private costs that would be associated with implementation (Principle 8). The following are just a few examples of questions that might be considered in assessing the recommendations using the general principles:

As reflected in the general principles, the goal has been to produce a standard that would result in consistent, publicly accepted data on race and ethnicity which will meet the needs of the Federal Government and the public, while recognizing the diversity of the population and respecting the individual's dignity. We would appreciate receiving your views and comments on any aspects of the Interagency Committee's recommendations, as well as on the extent to which the recommendations were successful in meeting the goals of the governing principles.

_______________________
Sally Katzen
Administrator, Office of Information and Regulatory Affairs


APPENDIX 1
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 record keeping, 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:

2. Utilization for Record keeping 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:

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:

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:

3. Effective Date

The provisions of this Directive are effective immediately for all new and revised record keeping or reporting requirements containing racial and/or ethnic information. All existing record keeping 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:

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 and to describe data relating to the remainder of the population by an appropriate collective description.


APPENDIX 2
REPORT TO THE OFFICE OF MANAGEMENT AND BUDGET
ON THE REVIEW OF
STATISTICAL POLICY DIRECTIVE NO. 15

Prepared By
Interagency Committee for the Review of the
Racial and Ethnic Standards
(Transmittal Memorandum)

May 28, 1997
MEMORANDUM FOR KATHERINE K. WALLMAN
Chief Statistician
Office of Management and Budget

FROM: Interagency Committee for the Review of the Racial and Ethnic Standards

SUBJECT: Transmittal of Report and Recommendations on the Review of Directive No. 15

We are pleased to transmit to you the attached report that provides the recommendations of the Interagency Committee for the Review of the Racial and Ethnic Standards for modifying OMB's Statistical Policy Directive No. 15, Race and Ethnic Standards for Federal Statistics and Administrative Reporting. These recommendations, which are outlined in Chapter 6 of the report, represent our best technical and professional advice for how these data standards could better reflect the increasing racial and ethnic diversity of our Nation's population, while maintaining historical continuity.

Our recommendations for Directive No. 15 are the product of a three-year review process that is briefly described in Chapter 1 of the report. During that time, we developed and carried out a research program to evaluate various proposals for revising the standards. Chapter 2 discusses some general concerns relevant to consideration of any changes in the standards. Chapters 3 through 5 report on the extensive research efforts, including three national tests, that have been conducted to test alternative approaches for questions to collect data on race and ethnicity. The Interagency Committee's recommendations, presented in Chapter 6, are based on our evaluation of the research results and consideration of related public comments and testimony.

We hope that the Office of Management and Budget will find this report with its accompanying recommendations informative and helpful in making its decision on what changes to adopt, if any, in the Federal standards for reporting data on race and ethnicity.

Attachment


REPORT TO THE OFFICE OF MANAGEMENT AND BUDGET
ON THE REVIEW OF
STATISTICAL POLICY DIRECTIVE NO. 15

Table of Contents

CHAPTER 1. Introduction
1.1 Overview
1.2 History of Directive No. 15
1.3 Concerns About the Current Standards
1.4 Principles for the Review Process
1.5 Overview of Research Activities
1.6 Evaluation of Research Results

CHAPTER 2. Issues of General Concern
2.1 Overview
2.2 Satisfying Statutory and Program Needs
2.3 Voting Rights Issues
2.4 Data Continuity Concerns
2.6 Financial Costs

CHAPTER 3. Reporting More Than One Race
3.1 Background
3.2 Current Practice
3.3 Overview of Research on Reporting More Than One Race
3.3.1 Surveys to Explore Options
3.3.2 Cognitive Research to Guide Survey Design
3.4 Evaluating Research on Options for Reporting More Than One Race
3.4.1 Data Comparability
3.4.2 Should a multiracial category be listed among the response options to the question on race?
3.4.3 If a multiracial category is listed, should a "follow-up" format be used, in which individuals who select the category are asked to specify their racial identities?
3.4.4 Should a multiple-response format be used, in which the respondent is instructed to "mark one or more races"?
3.4.5 Should a multiple response format be used in which the respondent is instructed to "mark all that apply" on the race question?
3.4.6 Are there other options for reporting more than one race by respondents?3.5 Trends With Respect to Reporting Multiple Races
3.5.1 Trends Contributing to Reporting of Multiple Races
3.5.1.1 Increases in Interracial Marriages and Households and Births to Parents of Different Races
3.5.1.2 State Requirements for Multiracial Reporting
3.5.2 Public Sentiment
3.6 Measurement Concerns and Opportunities Related to Reporting More Than One Race
3.6.1 Meeting Legislative and Program Needs
3.6.2 Defining and Using the Term "Multiracial"
3.6.2.1 Definition of "Multiracial"
3.6.2.2 Using a Stand-Alone "Multiracial or Biracial" Category or Including a Follow-up Question
3.6.3 Using a "Mark One or More" or a "Mark All That Apply" Instruction in the Race Question
3.6.4 Issues Related to Primary and Secondary Data Collection
3.7 Some Implications of Allowing the Reporting of More Than One Race
3.7.1 Possible Effects on Reporting by Particular Population Groups
3.7.2 Tabulation of Multiple Responses
3.7.3 Monetary Costs and Resource Burdens

CHAPTER 4. A Combined Race and Hispanic Origin Question
4.1 Background
4.2 Concepts of Race and Ethnicity
4.3 Self-Identification
4.4 Some Alternative Formats for Questions
4.5 Research on Data Quality
4.5.1 Reporting in the "Other Race" Category by Hispanics
4.5.2 Item Nonresponse in the Race Question
4.5.3 Item Nonresponse in the Hispanic Origin Question
4.5.4 Reporting Inconsistency
4.6 Measures to Correct Misreporting in the Race Question and the Hispanic Origin Question
4.7 The Effects of Combining the Race Question and the Hispanic Origin Question into a Single Question
4.7.1 Results From the May 1995 CPS Supplement on Race and Ethnic Origin 4.7.2 Results From the Race and Ethnic Targeted Test
4.7.2.1 Reporting of Hispanic Origin
4.7.2.2 Reporting of Multiple Races
4.7.2.3 Summary of Findings
4.8 Public Sentiment
4.9 Additional Cost Concerns

CHAPTER 5. Other Possible Changes
5.1 Background
5.2 Specific Suggestions
5.3 Evaluation of the Possible Effects of Suggested Changes
5.3.1 Changes related to American Indians and Alaska Natives
5.3.1.1 Should the term "American Indian" or "Native American" be used?
5.3.1.2 Should the term "Alaska Native" or "Eskimo and Aleut" be used?
5.3.1.3 Should a distinction be made between federally recognized and nonfederally recognized tribes?
5.3.1.4 What is the best way to elicit tribal affiliation?
5.3.1.5 Should the definition of the "American Indian or Alaskan Native" category be changed to include Indians indigenous to Central America and South America?
5.3.2 Changes related to Asian and Pacific Islanders
5.3.2.1 Should the "Asian or Pacific Islander" category be split into two categories? If yes, how should this be done?
5.3.2.2 Should specific groups be listed under the Asian or Pacific Islander category?
5.3.2.3 Should the term "Guamanian" or "Chamorro" be used?
5.3.3 Changes related to Hawaiians
5.3.3.1 Should the term "Native Hawaiian" or "Hawaiian" be used?
5.3.3.2 Should Hawaiians continue to be included in the "Asian or Pacific Islander" category; be reclassified and included in the "American Indian or Alaskan Native" category; or be established as a separate, new category?
5.3.4 Other terminology issues
5.3.4.1 Should the term "Black" or "African American" be used?
5.3.4.2 Should the term "Hispanic" or "Latino" be used?
5.3.4.3 Should more than one term be used for Black or for Hispanic?
5.3.5 Other new category issues
5.3.5.1 Should an Arab or Middle Eastern category be created and, if so, how should it be defined?
5.3.5.2 Should a Cape Verdean category be created?

CHAPTER 6. Recommendations and Major Findings
6.1 Summary of Recommendations and Major Findings
6.1.1 Recommendations concerning reporting more than one race
6.1.1.1 Findings concerning a method for reporting more than one race
6.1.1.2 Findings concerning different formats for reporting more than one race
6.1.2 Recommendations concerning a combined race and Hispanic ethnicity question
6.1.2.1 Findings concerning whether race and Hispanic origin should be combined into a single question
6.1.2.2 Findings concerning different formats if race and Hispanic origin are combined in a single question
6.1.3 Recommendations concerning the retention of both reporting formats
6.1.4 Recommendation concerning the ordering of the Hispanic origin and race questions
6.1.5 Recommendation concerning adding Cape Verdean as an ethnic category
6.1.6 Recommendation concerning the addition of an Arab or Middle Eastern ethnic category
6.1.7 Recommendation concerning the addition of any other categories to the minimum set
6.1.8 Recommendation concerning changing the term "American Indian" to "Native American"
6.1.9 Recommendation concerning changing the term "Hawaiian" to "Native Hawaiian"
6.1.10 Recommendation concerning the classification of Hawaiians
6.1.11 Recommendations concerning the use of Alaskan Native instead of Eskimo and Aleut
6.1.12 Recommendations concerning the classification of South and Central American Indians
6.1.13 Recommendations concerning the term or terms to be used for the name of the Black category
6.1.14 Recommendations concerning the term or terms to be used for Hispanic
6.2 Comparison of the Current Standards with the Recommended Standards
6.2.1 The Current Standards in Directive No. 15
6.2.2 Recommended Standards
6.3 Recommendations for Further Research


CHAPTER 1. Introduction

1.1 Overview

This report evaluates a variety of proposals for modifying the Office of Management and Budget's (OMB) Statistical Policy Directive No. 15, "Race and Ethnic Standards for Federal Statistics and Administrative Reporting." The Directive sets forth a minimum set of categories for collecting and presenting data on race and Hispanic origin. This basic set of categories has served as the guideline for Federal Government data collections since it was issued in May 1977. The report presented here, including its recommendations, is the culmination of three years of research undertaken by Federal agencies to evaluate the possible impact of suggested changes on the quality and cost of the resulting data. It is the work of the Interagency Committee for the Review of the Racial and Ethnic Standards and its Research Working Group on Racial and Ethnic Standards. OMB established the Interagency Committee in 1994 to evaluate various proposed changes and provide recommendations. The committee created the Research Working Group to develop and carry out a research agenda for evaluating the proposals.

The report consists of six chapters. This first chapter provides a brief history of Directive No. 15, a summary of the issues considered by the Interagency Committee, a review of the research activities over the past three years, and a discussion of the criteria used in conducting the evaluation. Chapter 2 discusses several general concerns that need to be addressed when considering any changes to the current standards. Chapters 3 through 5 report the research results as they bear on the more significant suggestions for changes to Directive No. 15. These suggestions include, but are not limited to, permitting respondents to report multiple racial backgrounds, a single question on race and ethnicity that would include Hispanic as a category, expanding the minimum set of categories to include other specific ethnic or racial groups, and adding to, or replacing the names of categories used to identify specific racial or ethnic groups. Chapter 6 presents the committee's recommendations on various suggested changes based on its evaluation of the research results and consideration of related public comments and testimony.

1.2 History of Directive No. 15

The United States Government has long collected statistics on race and ethnicity. Such data have been used to monitor 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, health status, and policy concerns.

Since the 1960s, data on race and ethnicity have been used extensively in monitoring and enforcing civil rights laws covering areas such as education, employment, housing and mortgage lending, health care, voting rights, and the administration of justice. These legislatively based priorities created the need among Federal agencies for compatible, nonduplicative data for population groups that historically had suffered discrimination on the basis of their race or ethnicity. In response, OMB issued, in 1977, the current set of categories for use in the collection and presentation of data on race and ethnicity. The 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.

The current standard provides that, if racial and ethnic data are collected separately, the minimum racial categories are:

For ethnicity, the categories are:

The current categories originated in the work of the Federal Interagency Committee on Education (FICE) whose membership represented some 30 Federal agencies. In June 1974, FICE created an Ad Hoc Committee on Racial and Ethnic Definitions, whose 25 members came from Federal agencies with major responsibilities for the collection or use of data on race and ethnicity. This ad hoc committee was charged with developing terms and definitions for a broad range of data on race and ethnicity to be collected by Federal agencies on a compatible and nonduplicative basis. The committee sought to ensure that the categories could be aggregated, disaggregated, or otherwise combined so that the data developed by one agency could be used in conjunction with the data developed by another agency. The committee also suggested that the basic categories could be subdivided into more detailed ethnic subgroups to meet users' needs, but that to maintain comparability, data from one major category should never be combined with data from any other category.

In the spring of 1975, FICE completed its work on a draft set of categories. An agreement was reached among OMB, the General Accounting Office (GAO), the Department of Health, Education, and Welfare's (HEW) Office for Civil Rights, and the Equal Employment Opportunity Commission (EEOC) to adopt these categories for a trial period of at least one year. This trial was undertaken to test the new categories and definitions and to determine what problems, if any, would be encountered in their implementation.

At the end of the test period, OMB and GAO convened an Ad Hoc Committee on Racial/Ethnic Categories to review the experience of the agencies that had implemented the standard categories and definitions and to discuss any potential problems that might be encountered in extending the use of the categories to all Federal agencies. The Committee met in August 1976 and included representatives of OMB; GAO; the Departments of Justice, Labor, HEW, and Housing and Urban Development; the Bureau of the Census; and the EEOC. Based upon the discussion in that meeting, OMB prepared minor revisions to the FICE definitions and circulated the proposed final draft for agency comment. These revised categories and definitions became effective in September 1976 for all compliance record keeping and reporting required by the Federal agencies represented on the Ad Hoc Committee.

Based upon this interagency agreement, OMB drafted for agency comment a proposed revision of the "race and color designations in Federal statistics" contained in its circular on Standards and Guidelines for Federal Statistics. Some agencies published the draft revision for public comment. Following receipt of comments and incorporation of suggested modifications, OMB, on May 12, 1977, promulgated the racial and ethnic categories now set forth in Directive No. 15. Thus, for the first time, standard categories and definitions were to be used by all Federal agencies in both the collection and the presentation of data on race and ethnicity. The categories and definitions were developed primarily on the basis of geography; therefore, they were not to be interpreted as being scientific or anthropological in nature. The racial and ethnic categories in the Directive reflected, in particular, agency needs for data for use in monitoring and enforcing civil rights laws.

Although the standards given in Directive No. 15 have not been revised since 1977, OMB did publish in the January 20, 1988, Federal Register a draft Statistical Policy Circular soliciting public comment on a comprehensive revision of existing Statistical Policy Directives. Among the proposed changes was a revision of Directive No. 15 that would have added an "Other" racial category and required classification by self-identification. This proposal was supported by many multiracial and multiethnic groups and some educational institutions, but it drew strong opposition from large corporations and Federal agencies such as the Civil Rights Division of the Department of Justice, the Department of Health and Human Services, the EEOC, and the Office of Personnel Management (OPM). Critics asserted that the present system provided adequate data, that any changes would disrupt historical continuity, and that the proposed changes would be expensive and potentially divisive. Some members of minority communities interpreted the proposal as an attempt to provoke internal dissension within their communities and to reduce the official counts of their populations. Because it was evident from all of these comments that this proposal would not be widely accepted, no changes were made to Directive No. 15.

1.3 Concerns About the Current Standards

The population of the United States has become increasingly diverse during the 20 years that the current standards have been in effect. During the 1980s, immigration to the United States from Mexico, Central and South America, the Caribbean, and Asia reached historic proportions. The 1990 census data show that the population of the United States is more racially and ethnically diverse than ever. Furthermore, as a result of the growth in interracial marriages, there is an increase in the number of persons born who are of mixed race or ethnicity. In recent years, Directive No. 15 has been criticized for not sufficiently reflecting this growing diversity.

In addition, there have been a number of other concerns expressed. For example:

The following are some of the suggestions for changes to the current categories that OMB received during the current review process:

During 1993, Thomas C. Sawyer, then Chairman of the House of Representatives' Subcommittee on Census, Statistics, and Postal Personnel, held four hearings on the measurement of race and ethnicity in the decennial census. In testimony on July 29, 1993, OMB announced that it would undertake a comprehensive review of the categories, including an analysis of the possible effects of any proposed changes to the categories on the quality and utility of the resulting data that are used for a multiplicity of purposes.

As a first step, OMB asked the Committee on National Statistics (CNSTAT) of the National Academy of Sciences to convene a workshop to provide an informed discussion of the issues surrounding a review of the categories. The workshop, held on February 17-18, 1994, included representatives of Federal agencies, academia, social science research institutions, interest groups, private industry, and a local school district.

1.4 Principles for the Review Process

In March 1994, OMB established and held the first meeting of the Interagency Committee for the Review of the Racial and Ethnic Standards, whose members from more than 30 agencies represent the many and diverse Federal needs for data on race and ethnicity, including statutory requirements for such data. Given the range of suggestions and criticisms concerning Directive No. 15, OMB sought in constituting the committee to have all agency stakeholders participate in this comprehensive review of the standards. Agencies represented on the Interagency Committee included:

Department of Agriculture
National Agricultural Statistics Service
Economic Research Service
Department of Commerce
Bureau of the Census
Department of Defense
Defense Manpower Data Center
Office of the Secretary
Department of Education
National Center for Education Statistics
Office for Civil Rights
Department of Health and Human Services
Administration for Native Americans
Agency for Health Care Policy and Research
Centers for Disease Control and Prevention
Indian Health Service
National Center for Health Statistics
National Institutes of Health
Office for Civil Rights
Office of Minority Health
Office of Refugee Resettlement
Department of Housing and Urban Development
Department of the Interior
Bureau of Indian Affairs
Department of Justice
Bureau of Justice Statistics
Civil Rights Division
Immigration and Naturalization Service
Department of Labor
Bureau of Labor Statistics
Office of Federal Contract Compliance Programs
Department of Transportation
Bureau of Transportation Statistics
Department of Veterans Affairs
Equal Opportunity Employment Commission
Federal Reserve Board
National Science Foundation
Office of Personnel Management
Small Business Administration
U.S. Commission on Civil Rights
Office of Management and Budget, ex officio

The Interagency Committee developed a set of general principles to govern the review process. This process was designed not only to evaluate suggestions received from the public but also to balance statistical issues, data needs, social concerns, and the personal dimensions of racial and ethnic identification. These principles were as follows:

1. The racial and ethnic categories set forth in the standards 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.

2. 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.

3. 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.

4. The racial and ethnic categories should be comprehensive in coverage and produce compatible, nonduplicative, exchangeable data across Federal agencies.

5. 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.

6. 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.

7. 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, determined by statistical concerns and data needs.

8. 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.

9. 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.

10. 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.

11. 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.

12. Time will be allowed to phase in any new categories. Agencies will not be required to update historical records.

13. 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 committee recognized that these principles may in some cases represent competing goals for the standards. By applying these principles to the review process, the committee hoped to produce a standard that would result in consistent, publicly accepted data on race and ethnicity that would meet the needs of the Federal Government and the public while, at the same time, recognizing the diversity of the population and respecting the individual's dignity.

OMB invited comment on the principles when they were published in a June 9, 1994, Federal Register Notice. That Notice also contained background information on the development of Directive No. 15; the revision proposed but not made in 1988; the 1993 congressional hearings; and the CNSTAT workshop. OMB requested public comment on the adequacy of the current categories, as well as on the suggested changes it had received over the years. As part of the public comment period, OMB also held hearings in Boston, Denver, San Francisco, and Honolulu during July 1994. OMB received nearly 800 letters in response to the 1994 Federal Register Notice and heard testimony of 94 witnesses during the four public hearings. A wide array of interested parties provided comments, including individuals, data users, and data providers from within and outside the Federal Government.

1.5 Overview of Research Activities

The Interagency Committee created a Research Working Group to outline an agenda for researching and testing key concerns. The Research Working Group, in August 1995, issued the "Research Agenda for the Review of the Racial and Ethnic Categories in Directive No. 15," based on an examination of the information in the June 1994 Federal Register Notice, the public comments it engendered, and previous research. This agenda identified five central research issues together with a number of questions associated with these issues. Some of the questions cut across several of the central issues, and others were unique to a particular issue. In developing the research agenda, the Research Working Group gave equal weight to the conceptual and the operational questions that must be answered before any changes to Directive No. 15 can be considered. The five central issues were:

The most important conceptual questions surrounding these issues were (1) who are the stakeholders, (2) how are various terms used and understood, (3) what is the respondent's view of the task of self-identification, (4) what would be the effects of any changes on population counts and historical trends, and (5) what would be the effects of any changes on the quality and usefulness of the resulting data? The most important operational questions were (1) how would the changes affect data collection procedures, (2) what differences might there be between collection and reporting categories, (3) how could continuity be maintained, (4) how should any changes be implemented, and (5) how might cognitive research assist in implementing any changes? In addition to recommending research that should be done, the Research Working Group both encouraged and supported a number of more specific research projects carried out by the individual agencies.

The first national test related to the central issues was the May 1995 Supplement on Race and Ethnicity to the Current Population Survey (CPS), which had a sample of approximately 60,000 households and more than 100,000 persons. The supplement, sponsored by the Bureau of Labor Statistics and conducted by the Bureau of the Census, tested the effects of: (1) adding a multiracial category to the list of races, and (2) including "Hispanic" as a category on the race question. Respondents also were asked about their preferences for terms to describe themselves (e.g., African-American or Black and Latino or Hispanic). Originally, questions concerning the respondent's understanding of the concepts of race, ethnicity, and ancestry were to be included, but extensive cognitive testing prior to creating the survey instrument indicated that these types of questions were confusing and difficult to administer in a large-scale survey. Additional analysis of open-ended responses by cognitive researchers provided possible explanations for the inconsistencies in some respondents' answers to the race and ethnicity questions.

As a part of the research on the subject content for the 2000 census, the Bureau of the Census tested alternative versions of questions on race and Hispanic origin in the March 1996 National Content Survey (NCS). This test was designed to provide information on how members of approximately 90,000 households identify their race and ethnicity in a self-reporting context, in contrast to the CPS Supplement which was administered by interviewers either in person or by telephone. Some NCS panels, comprising about 18,000 households, tested the effects of adding a multiracial category to the race question, placing the Hispanic origin question immediately before the race question, and combining both of these changes. The NCS sample was not designed to detect possible effects of different treatments on relatively small population groups, such as American Indians and Alaskan Natives, detailed Asian and Pacific Islander groups (such as Chinese and Hawaiians), or detailed Hispanic origin groups (such as Puerto Ricans and Cubans). Moreover, because the results were based on the responses from households in the national sample that mailed back questionnaires, the results do not represent the entire national population.

In contrast to the NCS, the Race and Ethnic Targeted Test (RAETT) was designed by the Bureau of the Census to provide findings for smaller population groups. Conducted in June 1996, the RAETT sample included approximately 112,000 urban and rural households. The sample was taken from geographic areas of the country with concentrations of different racial and ethnic populations including American Indians, Alaskan Natives, Asians, Pacific Islanders, Hispanics, Blacks, and White ethnic groups. This design permits assessments of the effects of changes on relatively small populations not reliably measured in national samples. The RAETT tested and evaluated the effects of adding a "multiracial or biracial" category; having instructions in the race question to "mark one or more" or to "mark all that apply; placing the Hispanic origin item before the race item; combining race, Hispanic origin, and ancestry in a single, two-part question; using a combined "Indian (Amer.) or Alaska Native" category; and using a "Native Hawaiian" or "Hawaiian" category.

In the spring of 1995, the National Center for Education Statistics and the Office for Civil Rights in the Department of Education conducted a survey of a thousand public schools. This survey obtained information on how schools currently collect data on students' race and ethnicity, how administrative records containing data on race and ethnicity are maintained and reported, what state laws mandate or require of school systems with respect to collecting data on race and ethnicity, and current issues in schools regarding categories for reporting data on race and ethnicity.

The Centers for Disease Control and Prevention held a Workshop on the Use of Race and Ethnicity in Public Health Surveillance. The workshop had three objectives: (1) to describe the current measures of race and ethnicity and their use in public health surveillance, (2) to assess the use of data on race and ethnicity in surveillance for planning, operation, and evaluation of public health programs, and (3) to propose better use of existing measures for race and ethnicity or to identify alternative measures. The limitations inherent in the current concepts, measures, and uses of race and ethnicity in public health surveillance were identified, and recommendations were made regarding their improvement.

The National Center for Health Statistics and the Office of Public Health and Science sponsored interviews with 763 multiracial and Hispanic women who had a baby during the preceding three years. The purpose of the study was to determine the effects of different question formats on reporting of race on birth certificates. The standard open-ended race question was compared with two experimental versions: (1) an open-ended race question that included the term "multiracial" as one of several examples, and (2) a "mark all that apply" format. When possible, results were compared with the race the respondent recorded on the youngest child's birth certificate.

A literature search on work related to racial classification in the health field (using MEDLINE) was conducted by the Department of Health and Human Services (HHS). An inventory of HHS minority health data bases that provides information on the data available and on the data collection problems that have been encountered was developed.

A focus group was conducted with state and local government members of the Association of Public Data Users. The participants were asked about possible effects of various suggested changes on their organizations. An expert on redistricting and reapportionment was interviewed concerning the effects these same changes might have on reapportionment and redistricting following the 2000 census. A survey of a small number of businesses and professional associations that rely on Federal statistics also was undertaken to ascertain views about the time and costs involved if various changes were made.

1.6 Evaluation of Research Results

Although some of the issues surrounding the proposed revisions may ultimately be settled through policy discussion and the criteria used may at times be subjective, there is an important place in the discussion for empirically grounded research. Thus, this evaluation, while considering such subjective information as stakeholder positions and respondent burden, focuses on the following objective criteria:

To facilitate the use of research results to evaluate alternatives and develop recommendations, the Research Working Group has acted as a clearinghouse for data gathering activities. As such, the Research Working Group has monitored various projects and overseen the consolidation of results in a form intended to be useful for policy makers.

CHAPTER 2. Issues of General Concern

2.1 Overview

This section provides a discussion of several general concerns that the Research Working Group considered during its review of Directive No. 15. They are: (1) statutory and programmatic needs of the Federal agencies for data on race and ethnicity, (2) voting rights issues, (3) data continuity concerns, and (4) financial costs of making changes to the Directive. These concerns merit general consideration because they must be confronted to some degree when dealing with any of the proposed changes. The relationship of specific suggested changes to these concerns will be addressed in later chapters.

2.2 Satisfying Statutory and Program Needs

Federal agencies that collect data on race and ethnicity include, but are not limited to, the Bureau of the Census, the Bureau of Labor Statistics, the Centers for Disease Control and Prevention, the National Center for Health Statistics, and the National Center for Education Statistics. Agencies use data on race and ethnicity for administrating Federal programs, for enforcing the civil rights laws, and for analyses of social, economic, and health trends for population groups.

A principal driving force in the 1970s for the development of the current standards was the need for data on race and ethnicity to enforce the civil rights laws. Some of the agencies that use these data for monitoring and enforcing civil rights laws include the Equal Employment Opportunity Commission (EEOC), the U.S. Commission on Civil Rights, the Civil Rights Division of the Department of Justice, the Office of Federal Contract Compliance Programs in the Department of Labor, the Office for Civil Rights in the Department of Education, and the Office for Civil Rights in the Department of Health and Human Services. State and local governments, educational institutions, and private sector employers use the categories when providing data on race and ethnicity to meet Federal reporting requirements.

Reliable and consistent information is important for enforcing Federal laws. In recent U.S. Supreme Court decisions involving education, employment, and voting rights, the Court has interpreted the Fourteenth Amendment to the United States Constitution to require that governmental decision-making based on racial classifications be subjected to "strict scrutiny" to determine whether it is "narrowly tailored" to meet "compelling State interests." Changes in Directive No. 15 could affect the ability of agencies to carry out the court's mandate. If, for instance, allowing individuals to identify with more than one race would make it more difficult to identify the members and characteristics of a particular racial or ethnic group (such as American Indians and Alaska Natives, or Asians and Pacific Islanders), then determining whether a "compelling State interest" exists with regard to such persons--and whether the government's action is narrowly enough tailored to meet that interest--could become correspondingly more difficult.

Generally, the statutes that require collection of data on race and/or ethnicity do not specify the exact categories that Federal agencies must use. Most of these laws simply require that data on race and ethnicity be collected. The following examples illustrate statutory requirements that specify the exact categories particular agencies must use:

2.3 Voting Rights Issues

Concerns have been raised that changes to the current categories for data on race and ethnicity may affect the usefulness of the data for congressional reapportionment, legislative redistricting, and enforcement of the Voting Rights Act.

Following each decennial census, congressional reapportionment--the redistribution of the 435 seats in the U.S. House of Representatives among the 50 States--is calculated using the population totals for each state and the formula of "equal proportions" adopted by the Congress in 1941 (United States Code, Title 2, Section 2a). Redistricting is the process of redrawing the boundaries of congressional, state, and local legislative districts in accordance with the Fourteenth Amendment's "one-person/one-vote" principle and the standard of population equality as set forth in Wesberry v. Sanders, Reynolds v. Sims, and subsequent court decisions. Changes to Directive No. 15 would be expected to affect congressional reapportionment and one-person/one-vote compliance in redistricting only to the extent that such changes affect the overall response to the decennial census.

Charges of minority vote dilution--the claim that the redistricting plan or at-large election system minimizes or cancels out the voting strength of a minority group--under Section 2 of the Voting Rights Act (which applies nationwide) are usually determined by reference to decennial census data on race and ethnicity. In addition, compliance with Section 5 of the Voting Rights Act--which requires Federal preclearance for new voting practices and procedures in certain states--also is generally determined by reference to decennial census data on race and ethnicity. Changes to Directive No. 15 could have implications for the effective implementation of the Voting Rights Act.

Decennial census data are used to determine the count and distribution of the voter-eligible minority population. Proof that it is possible to draw a district with a voter-eligible minority population in the majority is usually needed to establish a vote dilution claim under Section 2 of the Voting Rights Act. Changes to the current categories that alter the counts of voter-eligible minorities could affect the ability of such groups to mount successful vote dilution claims. The Attorney General's preclearance determinations pursuant to Section 5 of the Voting Rights Act--whether to grant or deny Section 5 preclearance--are often affected by the size and distribution of the minority population.

In addition, data on race and ethnicity from the decennial census frequently are used as independent variables in statistical procedures that estimate group voting behavior, particularly when counts of registered voters by race or ethnicity are not available. These estimates of group voting behavior are essential to vote dilution claims under Section 2 of the Voting Rights Act, as well as to the analysis of many types of voting changes under Section 5 of the Voting Rights Act.

2.4 Data Continuity Concerns

If changes are made to the Federal standards for collecting data on race and ethnicity, it will be critically important to data users to understand the impact of those changes vis-a-vis the categories they have been using for the past 20 years. The acceptance of new ways of reporting race and ethnicity may require supporting information so that users can assess the magnitude of changes to current time series. To that end, alternative methods of tabulating multiple responses on race into the current minimum set of categories must be investigated further.

2.5 Financial Costs

If OMB were to revise the categories for data on race and ethnicity by modifying Directive No. 15, a sizeable number of Federal agencies and others would have to change data collection forms, computer programs, interviewers' and coders' manuals, and other related materials for their data systems. Although Directive No. 15 is a standard for use by Federal agencies, many State and local agencies and private sector entities also follow the Federal standards for collection, record keeping, and presentation data on race and ethnicity. On the other hand, there will be other costs incurred if changes are not made to the current categories, and these costs are also discussed in this section.

If a decision were made either to use separate questions exclusively, or to use a combined format always, or to use a "mark one or more" reporting option for race, or to add a "multiracial" category, there would also be costs for redesigning data editing, coding, and processing systems to accommodate the changes.

Other costs would be associated with changing data base management, retrieval and aggregation programs, and historical table formats. Data base management systems might have to be significantly expanded to provide data comparability with historical series. Procedures might have to be developed for editing multiple responses to achieve this comparability. Staff would have to be trained in the new procedures resulting from any change to the current categories. Since the estimated transition time for changing EEOC data bases would be 2-3 years, data for these years could be severely hampered for enforcement purposes. This would likely result in additional costs for protracted processing of grievances.

The Health Resources and Services Administration (HRSA) of the Department of Health and Human Services has noted that substantial changes for 23 categorical grant programs would be required for competing and noncompeting grant application materials, data entry and report programs, and the preference/priority databases. Alterations in the current collection categories for data on race and ethnicity would require restructuring of the definitions and data collection tools designed to report cross-cutting outcome measures for Title VII and VIII Health Professions and Nursing education and training programs.

During informal discussions, company representatives offered a few examples of the potential impact on private sector employers if changes to the categories were to be made. The costs of making changes to forms is considered to be minimal. Changes in the data systems would be more expensive than changes in the forms, since this effort would be very labor intensive. In addition, if there were new categories, employees might have to be resurveyed in order to update the information on race and ethnicity.

Any changes from the current collection mechanism would entail major program changes for the 700 institutions participating in the seven student assistance campus-based loan and scholarship programs. Review and revision of records for eligibility and fiscal accounting data would be required, including manual review of data, computer programming changes, and changes to the scope of work for contract services. In addition, the Student Financial Aid Guideline and the User Manual for the Electronic Reporting System would require review and revision. Moreover, changes in definitions would require that schools reconcile past and current submissions of data for compatibility to enable HRSA to make appropriate awards to participating institutions.

The Administration on Children and Families (ACF) of the Department of Health and Human Services considers the overall effect of change to the racial and ethnic categories to be marginal. ACF collects data on race and ethnicity for several internal data systems (e.g., foster care, personnel, grant-related information). However, in relation to the total cost of maintenance of these internal data systems, possible changes in the classification of data on race and ethnicity are likely to have only marginal effects. Alterations to racial and ethnic categories used for data systems maintained by private contractors for ACF (e.g., Head Start, Child Abuse and Neglect, Developmentally Disabled, Native American) would not likely cause excessive burden to the data collection effort.

In addition, ACF has data systems that are legislatively mandated and involve data collections by states (such as temporary assistance to needy families, child support enforcement). If the alterations to existing systems are profound, states might be resistant to change or they might seek Federal funds to defray costs of updating state data systems, particularly to meet Federal reporting requirements.

While financial costs would be incurred if changes are made to Directive No. 15, there are other types of costs associated with not making changes. Problems that exist with use of the current Directive will not be resolved. These continuing problems include lack of standardization for classifying data on race and ethnicity across state and Federal agencies; less than optimal participation in Federal surveys (especially item nonresponse); misidentification of individuals and groups in surveys; inaccurate counts and rates; inaccurate research; inaccurate program design, targeting and monitoring; and possibly misallocation of funds. There will continue to be inconsistency even within the same Federal agency if Hispanic origin data continues to be collected using either the combined format or two separate questions. It is not uncommon for the denominator of a rate for Hispanics to be based on data collected using separate questions on race and ethnicity while the numerator is based on data collected using the combined format.

Chapter 3. Reporting More Than One Race

3.1 Background

This chapter addresses issues related to whether or not the Federal standards for data on race and ethnicity should provide an option that permits the reporting of more than one race. The chapter discusses different approaches that have been studied by Federal agencies to provide such an option. It presents findings of the research conducted by Federal agencies on the alternative approaches and identifies potential implications of providing or not providing a response option for reporting more than one race. Following a review of the current standards and an overview of the research conducted, the chapter addresses the following questions:

Sections 3.5 through 3.7 discuss some of the trends, concerns, and potential implications related to adding (or not adding) an option for reporting more than one race to the Federal standard for collecting and reporting racial categories, including the effects on such areas as legal and program needs, measurement issues, and data production.

3.2 Current Practice

Directive No. 15 provides a minimum set of racial and ethnic categories--four categories for data on race (White, Black, American Indian or Alaskan Native, and Asian or Pacific Islander) and two categories for data on ethnicity (Hispanic origin and not of Hispanic origin). The current standard permits Federal agencies to use more detailed categories for collecting data on population groups, so long as the data collection is organized in a way that makes it possible for the agencies to aggregate the more detailed designations into the Directive No. 15 categories.

For persons who identify with more than one race, Directive No. 15 indicates that the single racial category which most closely reflects the individual's recognition in his or her community should be used. Directive No. 15 does not provide for identifying two or more races.

3.3 Overview of Research on Reporting More Than One Race

To assist OMB in deciding whether or not the Federal standard should provide for reporting more than one race, Federal agencies have conducted several major surveys to test the possible effects on data quality of various options. Major objectives of the research and testing programs carried out in 1995 and 1996 have included:

3.3.1 Surveys to Explore Options

The Current Population Survey, conducted jointly by the Bureau of Labor Statistics (BLS) and the Bureau of the Census, included a Supplement on Race and Ethnicity in May 1995 (the CPS Supplement). The CPS Supplement was designed to test the effect of asking questions about race and Hispanic ethnicity, with and without a multiracial response option. As part of its research and testing program for Census 2000, the Bureau of the Census conducted two additional studies--the National Content Survey (also known as the 1996 census survey or the Census 2000 survey) and the Race and Ethnic Targeted Test (the RAETT)--to explore the implications of using different formats for questions on respondents' racial identification and reporting of Hispanic origin.

3.3.2 Cognitive Research to Guide Survey Design

The agencies conducted extensive cognitive research to pretest the racial and ethnic categories and the sequencing of the questions on race and Hispanic origin in the survey instruments. An interagency team conducted cognitive research on several versions of the CPS Supplement questionnaire designed for face-to-face and telephone interviews. The race question included a multiracial category, with a follow-up question for reporting the races with which the respondent identified. The questionnaire was tested with a range of racial and ethnic groups in various regions of the United States, and respondents from all groups were able to report that the term "multiracial" meant more than one race. (McKay and de la Puente, 1995)

The Bureau of the Census conducted cognitive research on two different options for reporting more than one race on the race item in a mail survey form. The options consisted of including (1) a "multiracial" category in the race question, and (2) an instruction to mark one or more of the racial categories provided in the race question.

The cognitive research guided the placement of a separate multiracial category in the race item, determined the appropriate number of write-in lines to the multiracial-response box, identified the appropriate terminology for soliciting response from persons of mixed racial parentage (without providing a definition of "multiracial" for this population), and guided the development of the instructions allowing respondents to choose more than one box. Because the cognitive research revealed that some respondents believed the term "multiracial" meant more than two races, the wording "multiracial or biracial" was used in the NCS and the RAETT to convey to respondents that the category is to be used by those who identify with two or more racial groups. (Gerber and de la Puente, 1996)

The cognitive research also was used to develop a "mark one or more" instruction, indicating that respondents could mark more than one racial category as applicable. The initial cognitive work, which offered respondents the choice of marking one racial category or marking more than one racial category, asked those selecting more than one group to specify the race with which they most identified.

Cognitive interviews tested several versions of this question. A number of problems were identified in these interviews. First, some respondents could not absorb or understand the complex instructions that were necessary. Second, the formatting (which was subject to space limitations) made it difficult for some respondents to read and absorb the question fully. Third, respondents who expected a "multiracial" category were disappointed that this response option was not provided. And finally, some respondents were not comfortable with being asked to designate a single race, when they did not want to discount any part of their racial heritage. The question that was ultimately used asked respondents merely to mark the boxes, without also asking them to designate the race with which they most identified. (Gerber and de la Puente, 1996)

Respondents for the cognitive research were recruited on the basis of interracial parentage or ancestry. In testing the use of multiracial reporting options in both the interview and self-administered mail modes, researchers found that many of the respondents recruited based on known multiracial status did not choose to report as multiracial. Reasons they gave for not selecting the multiracial category included: identification with the racial and cultural group of one parent; acceptance of the racial identity perceived to be conferred by their community; and a lack of identification with a "multiracial" group encompassing members of different racial ancestries. (McKay and de la Puente, 1995; Gerber and de la Puente, 1996)

3.4 Evaluating Research on Options for Reporting
More Than One Race

The sections that follow present results from the CPS Supplement, the National Content Survey, and the RAETT as they bear on the alternative approaches outlined at the beginning of this chapter (See section 3.1). Brief descriptions of these surveys follow.

The Current Population Survey is a monthly national sample survey of approximately 60,000 households; it routinely collects information on the race and ethnic origin of household members using the current Directive No. 15 categories. The May 1995 CPS Supplement collected additional racial and ethnic data on the households under four different panel conditions:

The CPS Supplement had a response rate of 82.9 percent.

The National Content Survey (NCS), conducted from March through June 1996, was a mail survey of 94,500 households drawn from 1990 decennial census "mail back areas" representing about 95 percent of the country. The NCS included thirteen panels, four of which were designed to evaluate the effects of adding a " multiracial or biracial" category and reversing the sequence of the questions on race and Hispanic origin. It is less representative of American Indians and Alaska Natives, given that about 25 percent of those populations live outside "mail back areas."

The NCS panels were as follows:

Each of the four questionnaires was mailed to a panel of about 6,000 households. The response rate for the four panels was 72 percent; the results are thus based on approximately 18,000 households. Computer-assisted telephone reinterviews were conducted with each household that had completed and returned the NCS form. Because the NCS sample excluded households outside 1990 census mailback areas, and some households did not return a questionnaire, results from the NCS cannot be generalized to the entire national population.

The RAETT, conducted by the Bureau of the Census in the summer of 1996, was the principal vehicle for testing and evaluating several important proposed changes for the race question. The RAETT targeted 112,000 households in areas that have, relative to the Nation as a whole, high concentrations of households in any one of six specified racial or ethnic groups: White ethnic (whether European, Canadian, or American), Black, American Indian, Alaska Native, Asian or Pacific Islander, and Hispanic origin. A total of 58,911 questionnaires were returned, yielding an overall response rate of 53 percent. The RAETT included questions designed to test the effects of a "multiracial or biracial" category as well as "mark one or more" and "mark all that apply" approaches to reporting more than one race, and a combined question on race and Hispanic origin, using eight different panels or versions of the questionnaire. The RAETT panels were as follows:

Each of these surveys provides important information about options for collecting and classifying data on race and ethnicity, but each also has its limitations. The CPS Supplement is nationally representative and data were gathered for over 80 percent of the sample, but it could not provide reliable information for smaller groups in the population. The NCS is close to being nationally representative and its use of a mail out/mail back questionnaire is particularly relevant for designing the 2000 census, but the response rate was only 72 percent, and it too could not provide reliable information for smaller groups.

The RAETT design provides a good test of the possible effects of suggested new racial categories because it focuses on populations for which the national surveys often do not provide sufficiently large samples. However, even with a 100 percent response to the RAETT, results could be generalized only to the population in the census tracts in each targeted sample frame. The actual response rate averaged 53 percent, and the response rates in some targeted samples were as low as 34 percent. The sample design of RAETT also does not permit results for different targeted samples to be combined.

3.4.1 Data Comparability

A key concern of some Federal agencies, reflected in the principles that have guided the review of the current standards, has been the comparability of data from any new categories with information produced under the existing categories. In its report on the RAETT, the Bureau of the Census presented -- for purposes of illustration -- different approaches for tabulating the data, using the information provided in the write-in entries to the "multiracial or biracial" category and in multiple responses to the race question. Some of these classification approaches provide examples of procedures that could be developed and used by the agencies as "bridges" between the current and any new classification. The three illustrative approaches were termed the single-race approach, the all-inclusive approach, and the historical series approach. They may be characterized as follows:

Single-race approach. Responses indicating only one racial category would be assigned to that category. Responses from individuals who reported multiple races would be classified into a separate "multiple race" category. This method provides a lower bound for the number who identify with a given category. The results from this approach are readily available from standard tabulations.

All-inclusive approach. Responses are classified into each racial category specified using the minimum set of categories in Directive No. 15. With a single race/ethnicity question using the combined format in Directive No. 15, the all-inclusive Hispanic proportion would be most comparable to the proportion reporting Hispanic when there are separate questions, one for race and one for ethnicity.

The sum of the percentages reported for the four separate racial categories would exceed 100 percent, because multiple race responses would be counted in each reported racial category. In spite of this disadvantage, the all-inclusive approach would provide information on the total number of times the racial category had been selected.

Historical series approach. Unlike the single race or the all-inclusive approach, the historical series approach can take on many variations, just one of which was used in the RAETT illustrative tabulations. The intent of this approach is to classify data into categories that resemble those that have been used historically to enforce current civil rights laws. An individual's response (or responses) is classified into one and only one category, in a set of mutually exclusive and exhaustive categories that add up to 100 percent. For example, in the report on the RAETT, which tested a " multiracial or biracial" category with a write-in to specify races as well as other options for reporting more than one race, the historical series approach classified into the Asian or Pacific Islander category responses of (1) only the Asian or Pacific Islander category, (2) the Asian or Pacific Islander category and also White, (3) the Asian or Pacific Islander category and Other Race, and (4) the Asian or Pacific Islander category and the multiracial category, with no specification of additional races. The "multiracial" or "other" category in the historical series was a residual category which consisted of responses to the "multiracial" category that did not specify any races; and responses of two race categories other than "White" or "Some Other Race." A more complete description of the historical series approach is provided in the RAETT report.

Under the historical series approach, the percentages allocated to each of the major categories were comparable to the data collected without a multiple race reporting option (Panel A of the RAETT), except for the Alaska Native targeted sample. The discrepancy in this group may be due to the fact that this particular targeted sample suffered from both a small sample size and from an extremely low response rate (34 percent).

3.4.2 Should a multiracial category be listed among the response options to the question on race?

The CPS Supplement on Race and Ethnicity, the National Content Survey, and the Race and Ethnic Targeted Test all allowed testing of the effects of adding a multiracial category to the list of races. The CPS Supplement used the term "multiracial" to identify the category, and the NCS and the RAETT used the term "multiracial or biracial."

CPS Supplement. In the CPS Supplement, the race question on Panels 2 and 4 included a " multiracial" category; results were very similar -- a little more than 1.5 percent identified as multiracial in each panel.

Table 3.1 shows that the multiracial response option drew respondents primarily from the American Indian, Eskimo, and Aleut population, and from those who reported in the "Something Else" category. Without a multiracial response category, about 1 percent reported as American Indian, Eskimo, and Aleut. With a multiracial category, about 0.75 percent reported in the American Indian, Eskimo, and Aleut category only.

The proportions reporting in the White category, in the Black category, and in the Asian or Pacific Islander category were not affected by the introduction of the multiracial option in the CPS Supplement.

Table 3.1 Racial Distribution from the First Question in the
CPS Supplement Assessing Racial Identity (In percent)

Race/Ethnicity Panel
1 2 3 4
White 79.88 79.74 75.78 74.66
Black 10.29 10.66 10.60 10.27
Hispanic - - 7.53 8.20
American Indian/Eskimo/Aleut 0.97 0.73 1.06 0.79
Asian/Pacific Islander 3.83 3.25 3.25 3.30
Something Else 4.68 3.70 1.50 0.92
Don't Know/Not Applicable 0.34 0.26 0.28 0.32
Total Multiracial - 1.65 - 1.55
Totals 100.00 100.00 100.00 100.00

Panel 1 - separate Hispanic question, no multiracial category
Panel 2 - separate Hispanic question, multiracial category
Panel 3 - no separate Hispanic question, no multiracial category
Panel 4 - no separate Hispanic question, multiracial category.

From Tucker et al., 1996.

National Content Survey. In the NCS, the race question included a multiracial category (using the term "multiracial or biracial") in two of four panels. The percent of respondents identifying themselves as multiracial on the NCS was 1.2 percent on the panel with the race question first (Panel 2), and 1.1 percent on the panel with the Hispanic-origin question first (Panel 4). Thus, as in the CPS, less than 2 percent of the total population chose the multiracial category on the NCS. Hispanics on the NCS were more likely than the total population to identify as multiracial (6.7 percent in Panel 2 and 10.0 percent in Panel 4.)

The addition of a multiracial category had no statistically significant effect on the percentage of persons who reported as White, as Black, as American Indian, or as Asian or Pacific Islander regardless of whether the race or the Hispanic-origin question was asked first. However, the relatively small sample size in the NCS might not detect changes that were substantively important for small populations.

For example, although not statistically significant, the declines in the proportion reporting in the Asian or Pacific Islander category, from 4.0 percent to 2.7 percent in panels where the race question came first, and from 3.4 percent to 2.8 percent when the Hispanic-origin question was asked first, suggested that further analyses should be undertaken. An analysis of the Asian or Pacific Islander write-in responses for those who reported in the multiracial category revealed that if these write-in responses had been reported solely as Asian or Pacific Islander, the proportion of the population in that category would have increased to about 3 percent. These findings, however, cannot be used to draw a firm conclusion about the effects of adding a multiracial category on reporting as Asian and Pacific Islander because the sample sizes were too small.

Adding a multiracial category significantly decreased reporting in the "Other race" category when race was asked first, from 3.3 percent to 1.7 percent. Reporting as "Other race" decreased only 0.3 percent with a multiracial category when the Hispanic-origin question was asked first.

Race and Ethnic Targeted Sample. The RAETT used a total of eight panels, Panels A through H (with A as the control panel). Three of the panels specifically tested the effects of reporting more than one race. In Panel B, the RAETT tested the effects of including a "multiracial or biracial" category. In Panel C, it tested the effects of instructing respondents to "mark one or more" in response to the race question; and in Panel H, it tested the effects of instructing respondents to "mark all that apply" in response to the race question. The results are discussed in succeeding sections of this chapter.

To determine the effects of including a multiracial category, responses to Panel B are compared with responses to Panel A. The findings indicate that the availability of the option to report as "multiracial or biracial" had the most substantial effect in the Asian and Pacific Islander and in the Alaska Native targeted samples. In the other targeted samples, use of the multiracial category had no significant effect on how race was reported. The percentages using the multiracial category in each of the other targeted samples were under 1.0 percent for the White ethnic and the Black targeted samples, 2.33 percent for the Hispanic targeted sample, and 3.67 percent for the American Indian targeted sample. (See Table 3.2.)

Table 3.2 Percent Using Multiracial Category, by Targeted Sample

Targeted Sample "Multiracial or
Biracial" Category
(Panel B)
White ethnic 0.41
Black 0.95
Hispanic 2.33
American Indian 3.67
Asian and Pacific Islander 7.58
Alaska Native 7.07

From Bureau of the Census, 1997.

In the Asian and Pacific Islander targeted sample, 7.58 percent in Panel B selected the multiracial category, and another 3.06 percent marked more than one race, even though they were instructed to mark only one. The corresponding percentages in the Alaska Native targeted sample were 7.07 percent and 6.32 percent.

The RAETT results show that, if there were the addition of a new category (e.g., multiracial), the proportion reporting in at least one of the current categories may be reduced. In the Asian and Pacific Islander targeted sample, about 2 percent fewer reported in the White (only) category in Panel B, and about 4.5 percent fewer reported in the Asian and Pacific Islander (only) category. Within the Asian and Pacific Islander category, the Hawaiian and the Asian Indian categories had the largest drops in reporting from Panel A to Panel B. However, the response rate for the Asian and Pacific Islander targeted sample was only 55 percent, and the possible impact of nonresponse bias on these comparisons is not known without further research. (See Table 3.3.)

Table 3.3 Comparison of Panel A and Panel B
(With a Multiracial Category) for the Asian and
Pacific Islander Targeted Sample, by Race: 1996 RAETT

Race Count or Estimate Difference
(Panel B
minus
Panel A)
No multiracial response option (Panel A) "Multiracial or Biracial" category (Panel B)
White ethnic 20.56 18.47 * -2.09
Black 5.99 6.05 0.07
American Indian and Alaska Native 0.31 0.36 0.06
Asian and Pacific Islander 64.95 60.48 * -4.47
Chinese 17.76 17.50 -0.26
Filipino 19.72 18.71 -1.01
Hawaiian 9.20 5.48 * -3.72
Korean 1.55 1.59 0.05
Vietnamese 1.40 1.50 0.10
Japanese 8.21 8.22 0.00
Asian Indian 1.24 0.48 * -0.76
Samoan 1.01 1.37 0.36
Guamanian 0.00 0.29 * 0.29
Other Asian and Pacific Islander 4.85 5.33 0.47
Other race 4.44 4.00 -0.44
Multiracial -- 7.58 --
Unrequested multiple response 3.76 3.06 -0.70

* An asterisk indicates that the difference is statistically significant at the 90-percent confidence interval assuming there is no bias due to a low response rate.

From Bureau of the Census, 1997, Table 1-4R, p. D-6.

In the Alaska Native targeted sample, the response rate was only 34 percent, leading again to the possibility of nonresponse bias and the need for further research. This, and the fact that the percent reporting White (only) increased by about 4.5 percent with the addition of a multiracial category, suggests that the group reporting in Panel A was different in some way from the group reporting in Panel B. In this targeted sample, the multiracial category drew primarily from the American Indian and Alaska Native category. (See Table 3.4).

Table 3.4 Comparison of Panel A (No Multiracial Category)
and Panel B (With a Multiracial Category)
for the Alaska Native Targeted Sample, by Race: 1996 RAETT

Race Count or Estimate Difference
(Panel B
minus
Panel A)
No multiracial response option (Panel A) "Multiracial or Biracial" category (Panel B)
White 12.55 16.99 4.44
Black 0.56 1.05 0.49
American Indian and Alaska Native 79.36 65.26 *-14.10
Asian and Pacific Islander 2.23 3.16 0.93
Other race 0.14 0.15 0.01
Multiracial -- 7.07 --
Unrequested multiple response 5.16 6.32 1.16

* An asterisk indicates that the difference is statistically significant at the 90-percent confidence interval as long as there is no bias due to a low response rate. From Bureau of the Census, 1997.

3.4.3 If a multiracial category is listed, should a "follow-up" format be used, in which individuals who select the category are asked to specify their racial identities?

All three of the major research surveys--the CPS Supplement, the NCS, and the RAETT-- used a two-part question to evaluate the effects of a follow-up question on reporting by different racial groups.

CPS Supplement. The responses on the CPS Supplement to the follow-up question for individuals who identified themselves as multiracial are shown in Table 3.5.

Table 3.5 Racial Distribution from First Question in
CPS Supplement Assessing Racial Identity,
Detailed Identification for "Multiracials" in
Panels 2 and 4 (In percent)

Breakdown of Responses to a
Follow-up Question
Panel 2 Panel 4
"Something else" as only one race 0.51 0.22
Only 1 race (of those provided) 0.53 0.15
White-Black/Black-White 0.09 0.16
American Indian + 1 race 0.20 0.28
Asian/Pacific Islander + 1 race 0.07 0.28
1 race + Something else 0.16 0.07
Other 2 races 0.00 0.20
3 or more races 0.08 0.21
No race/don't know/not applicable 0.02 0.00
Total Multiracial Responses 1.65 1.55

From Tucker, et al., 1996.

With the exception of respondents who named only one race, the "American Indian + one other race" group had the highest frequency in both panels, followed by "Asian/Pacific Islander + one race" on Panel 4. All but a small percentage of the Hispanics who used the multiracial category reported only an Hispanic ethnic group. (McKay, Stinson, de la Puente, and Kojetin, 1996)

More than 60 percent of multiracial responses on Panel 2 and close to 20 percent of multiracial responses on Panel 4 did not provide two or more different races. Respondents who reported only a single race, or reported ethnicities as races, were designated as "unconfirmed multiracials." With the addition of an Hispanic category, there was a 90 percent decline among Hispanic "unconfirmed multiracials" between Panels 2 and 4. There was also a 60 percent decline in such entries for non-Hispanics between Panels 2 and 4, which is not readily explained by the presence of the Hispanic category on Panel 4. (See Table 3.6.)

The decline in "unconfirmed multiracials" among Hispanics in Panel 4 may reflect the effect of the combined race and Hispanic origin question on Hispanic reporting. In the case of non-Hispanics, the decline might result from the absence of the influence of a preceding Hispanic origin question.

Table 3.6 Percentage "Multiracials" and "Unconfirmed" Multiracials

Panel 2
separate questions
Panel 4
(combined questions)
Multiracial "Unconfirmed"
Multiracials
Multiracial "Unconfirmed"
Multiracials
Named 1 race in response
Hispanic 2.21 10.73 0.00 0.71
Non-Hispanic 4.81 45.77 5.15 17.02
Named 2 or more races in response
Hispanic 3.53 4.60 22.79 0.00
Non-Hispanic 26.02 2.33 52.46 1.88
Totals 36.57 63.43 80.40 19.60

From McKay, Stinson, de la Puente, and Kojetin, 1996.

Researchers were able to compare the racial identification of CPS respondents on the CPS control card, which represents the current time series, with their racial identification on the CPS Supplement. Table 3.7 displays the results.

Table 3.7 Racial Identifications on CPS Control Card and CPS Supplement

Panel Race on CPS Control Card Race on CPS Supplement
Same Race Another race "Something Else" "Multiracial"
1 White 95.80 1.15 3.05 ---
Black 95.02 1.84 3.14 ---
American Indian,
Eskimo, or Aleut
74.50 20.78 4.72 ---
Asian or Pacific
Islander
90.91 3.06 6.03 ---
2 White 95.64 0.88 2.34