A person’s identity is a complex matter. While we have one body, we have multiple ways to self-identify: If you have kids, “parent” becomes one of your identities; doctors and nurses may identify as healthcare professionals; or we may identify as belonging to certain communities or physical locations. Of these many identities, those related to our race and ethnicity are the most complex social constructs the US government uses to categorize us.
Most federal government data collection relies on data collected at the state and local level. In order for national policymakers to make important decisions—like funding for maternal and child health programs or designating healthcare professional shortage areas—the data that they collect at state and local levels needs to be comparable.
The federal Office of Management and Budget (OMB) and a technical working group recently issued proposed changes to the federal Directive 15 that define how race and ethnicity are collected at many federal agencies, including the Census Bureau, which could create challenges for the comparability of available state and local data. The last time OMB changed this standard was almost 30 years ago. While these are just proposed changes (the final ruling is expected in the summer of 2024), states are likely to follow federal standards and collect data using the same categories that would allow state and federal agencies to compare local, state, and national numbers. This might mean that it will take two to three years to have enough data to compare county-level data because the implementation of revised standards will happen at different times.
The Beeck Center welcomes the update to the race and ethnicity standard. We urge OMB to partner more with states on data collection standards and support them on developing a reasonable timeline to implement recommendations, guide them on how to technically implement recommendations, and provide funds for states to modernize legacy systems that need to change in order to improve how data is collected.
The final rules of the Directive should include a detailed timeline for the implementation of the changes at federal agencies and how those timelines will affect states. States consist of multiple agencies that follow data reporting requirements from their corresponding federal partners. For example, central cancer incidence reporting systems are overseen by the Centers for Disease Control and Prevention, mental health crisis interventions by Substance Abuse and Mental Health Services Administration, and criminal history records follow the Federal Bureau of Investigation standards. States will benefit from an orchestrated approach led by the federal government once the updated guidance comes into effect. If there is any prioritization of federal systems or domains such as health and human services, it would be useful to know those systems in advance.
Technical assistance and guidance
The Directive as proposed acknowledges many challenges associated with more granular data collection. Federal partners that fall directly under the scope of the Directive should prepare detailed technical guides to answer common questions from state and local analysts around how to group free text entries, what to do with missing data, sample size thresholds that guide suppression of publication, and similar aspects of data management.
To build trust with people providing their data, states would also benefit from technical assistance or training materials on the best way to communicate why this data is being collected, how it is going to be used, and how it will be protected. For example, states will likely be asked by residents about the new Middle Eastern and North American categories, or why the Hispanic category is no longer a separate question.
There are hundreds of applications and systems that collect and house race and ethnicity data. Funding is required for the actual update of these systems that have end-user interfaces and back-end databases to hold the data. Ideally, states would be able to access new dedicated funding or receive clear guidance on how existing federal money could be used to make the necessary IT changes.
Implementation of the revised race and ethnicity standard recommendations will mean that millions of Americans are represented in government data in ways that previous data collection efforts didn’t capture. For the first time, state, local, and federal agencies can work together to ensure that no one slips through the cracks in receiving benefits of public policies.
You can submit your comments by April 12, 2023, here.