The U.S. Office of Management and Budget (OMB) is currently in the process of revising Statistical Policy Directive No. 15: Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity (Directive 15), which sets forth the minimum categories that federal agencies must use when they collect information on race and ethnicity.
The resources below provide background on the current standards and information on the initial revisions proposed by OMB’s Federal Interagency Technical Working Group on Race and Ethnicity Standards.
The Leadership Conference’s comment letter on proposed revisions:
OMB’s Federal Register Notice soliciting public input on initial proposals to revise federal race and ethnicity data standards closed on April 27, 2023. The Leadership Conference and our Census Task Force co-chairs submitted a comment letter signed by 121 national and state organizations in response to the initial proposals.
Revisions to Directive 15 are a prerequisite to modernizing the race and ethnicity questions used in the decennial census, federal surveys, and other federal data collection programs. Extensive research over more than a decade by the U.S. Census Bureau indicates that the current standards do not align with the way many U.S. residents self-identify, resulting in inaccurate or incomplete federal data. Guided by this research, our comment recommends the following:
- Adoption of a combined race and ethnicity question format. To ensure more inclusive data collection and reduce selection of “Some Other Race” responses in the decennial census, we urge OMB to revise its standards to favor the collection of race and ethnicity data through a combined question format instead of through separate questions for ethnicity and race.
- Addition of a new category for persons of Middle Eastern or North African (MENA) origin that is geographically based and separate from the White category. We urge OMB to include MENA as a minimum ethnicity reporting category within the combined question for all purposes for which federal agencies collect and publish race and ethnicity data.
- Requiring the collection of more granular data for all minimum race and ethnicity categories. OMB should require, rather than simply encourage, agencies to collect and publish more detailed data for all minimum race and ethnicity categories whenever possible.
See here for comment letters submitted by The Leadership Conference’s coalition partners!
Resources on current OMB standards
History and Implications of OMB Race and Ethnicity Data Standards. This webinar from The Leadership Conference includes a history of the standards and efforts to revise them, an overview of research findings supporting the need for several key revisions to the standards, and a discussion of the uses and implications of federal race and ethnicity data for civil rights programs, research, and policy development. Slides and other resources from the webinar are available here.
Directive 15 Fact Sheet: This fact sheet provides guidance on the U.S. Office of Management and Budget’s (OMB) Statistical Policy Directive No. 15 and explains why OMB Directive 15 no longer reflects the full racial and ethnic diversity of the nation’s population or the way many people choose to identify themselves. It also outlines improvements that many civil rights stakeholders are calling for to modernize the standards.
Full text of Directive 15: Last updated in 1997, OMB’s Statistical Policy Directive No. 15: Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity (Directive 15) sets forth the minimum set of categories that federal agencies must use when they collect information on race and ethnicity.
Resources on proposed revisions
Federal Register Notice providing initial proposals from the Federal Interagency Technical Working Group on Race and Ethnicity Standards for revising OMB’s Directive 15. Responses to this notice will be shared with the working group to help the working group develop their final recommendations to OMB for revisions to Directive 15.
FAQ: Updating OMB’s Race and Ethnicity Data Standards: This FAQ from The Leadership Conference Education Fund provides background on the current standards, information on the key revisions proposed, and an overview of OMB’s revision process and opportunities for stakeholder input.
Fact sheet and FAQ: Why do we need a combined race and ethnicity question? Among the key proposed revisions is the adoption of a combined race and ethnicity question format. Under OMB’s current standards, race and ethnicity data are collected through two separate questions, with the ethnicity question (asking about Hispanic or Latino origin) placed before the race question. This FAQ from The Leadership Conference Education Fund explains why adopting a combined question would be a critical step forward in allowing more people to see themselves accurately reflected in federal data.
Webinar and FAQ on the proposed combined race and ethnicity question from the NALEO Educational Fund. Also see NALEO’s comment letter and sign-on comments.
The U.S. Census Bureau’s 2010 Census Race and Hispanic Origin Alternative Questionnaire Experiment (AQE). Conducted during the 2010 Census with a sample size of roughly 500,000 addresses, the AQE focused on improving the race and Hispanic origin questions by testing different questionnaire design strategies. The results of the AQE showed that a combined race and ethnicity question format significantly reduced the proportion of respondents selecting “Some Other Race” (which is harder to analyze) and improved data accuracy and reliability.
The U.S. Census Bureau’s 2015 National Content Test – Race and Ethnicity Analysis Report. Conducted using a nationally representative sample of 1.2 million housing units in the United States, including Puerto Rico, the 2015 National Content Test (NCT) assessed optimal design elements for questions on race and ethnicity in preparation for the 2020 Census. Analysis of the NCT showed that a combined question with a distinct Middle Eastern/North African (MENA) category more accurately reflects how many people self-identify, yielding higher quality data. The results also showed that a combined question would not reduce reporting for any of the major race categories except White, compared to data collected through separate questions.
Resources on adding a MENA ethnicity category as part of a combined race and ethnicity question from Arab American Institute’s Yalla! Count MENA IN campaign. Also see AAI’s comment letter.
Comment letter and community sign-on letter from Asian Americans Advancing Justice | AAJC urging OMB to further data disaggregation standards for Asian Americans, Native Hawaiian, and Pacific Islander communities as it updates Directive 15.
Comment letter from Natives Count. This comment letter from the Natives Count working group lays out recommendations to improve data collection for American Indians and Alaska Natives while respecting the unique government-to-government relationship of the United States to Tribal Nations.
Comment letter from MALDEF, discussing implications of the proposed revisions for Latinos in the U.S. and their interactions with federal agencies.
Comment letter from the National Urban League and and the National Coalition on Black Civic Participation, co-conveners of the Census Black Roundtable and the Unity Diaspora Coalition.
Panelist presentations from “A Renewed Direction for Directive 15: A Convening on OMB Race and Ethnicity Data Standards Revision
Brief History of OMB Race and Ethnicity Data Standards
- Terri Ann Lowenthal, Census expert and consultant to The Leadership Conference
Initial Proposals For Updating Statistical Policy Directive No. 15
- Bob Sivinski, U.S. Office of Management and Budget, Chair of Federal Interagency Technical Working Group on Race and Ethnicity Standards
- Karen Battle, U.S. Census Bureau, Co-Chair of Federal Interagency Technical Working Group on Race and Ethnicity Standards
Spotlight on U.S. Census Bureau Research to Inform Discussions for Improving Federal Race and Ethnicity Data Standards
- Nicholas Jones, U.S. Census Bureau, Senior Advisor, Race/Ethnicity Research and Outreach, Population Division
- Roberto Ramirez, U.S. Census Bureau, Assistant Division Chief, Special Population Statistics, Population Division
Disaggregating Data by Age and Administrative Records
- Dr. Bill O’Hare, consultant to The Leadership Conference Education Fund and The Count All Kids Campaign
Clarification of ACS Race and Ethnicity Data from 2019 to 2021
- In this memo, Dr. Bill O’Hare clarifies and expounds on his presentation at The Leadership Conference’s convening on Directive 15. The presentation focused on the change in ACS race and ethnicity data for young children from 2019 to 2021.