Census Funding – Testimony of Karen K. Narasaki

On April 24, 2007 Karen K. Narasaki, President and CEO of the Asian American Justice Center, testified on on behalf of the Leadership Conference on Civil Rights regarding FY ’08 Census Bureau funding before the House Subcommittee on Information Policy, Census, and National Archives Committee on Oversight and Government Reform.

Introductory Statement

In 1990, the US Census Bureau conducted its decennial count of individuals residing in the United States. The count disproportionately missed ethnic minorities, children, and immigrants. Asian Americans were among the disproportionately undercounted due to obstacles including cultural and linguistic barriers. For Census 2000, with the hard work of the Census Bureau on outreach initiatives in collaboration with the national community education outreach projects by many community based organizations, the Census Bureau was able to improve its count of the American population. However, there were still issues of undercount for many of the same communities.

While the ideal for a census is to achieve a complete count of all persons in the country, perfection in this context is impossible. The pragmatic reality is that the Census Bureau constantly strives to achieve the most accurate count possible and one that is better than counts achieved previously. The 2010 census will provide the Census Bureau with even more challenges in achieving an accurate count. The demographics of 2010 have changed drastically from 2000.

Some communities, such as the Latino American and Asian American communities have experienced high growth rates in some communities. There is an increase in African and Caribbean immigrants. There are generally high levels of mobility for many who move from state to state, city to city. Additionally, recent natural disasters have displaced many people from their homes and have created a more complex, less traditional or static sense of household for many people. The Census Bureau must be able to understand these communities and situations and the unique barriers to an accurate count that may exist for them.

The Census Bureau also has to account for the fact that people are reluctant to voluntarily provide personal information to the government in an age of identity theft and in the wake of immigration raids and other dragnets that post-9/11 policies have created. Combined with the growing privacy concerns that have arisen from disclosures this decade that the Census Bureau has inappropriately shared information with government agencies, an increasing number of people, particularly minorities, are fearful of providing even the most basic of information asked on the census. The Census Bureau must overcome the many obstacles created by these factors in order to get an accurate count.

As we look towards Census 2010, there are many areas of improvement needed to achieve an even more accurate count of our population. The written testimony will address some of the obstacles that exist in achieving an accurate count and how we believe the Census Bureau can address them.

Organizational Background

The Asian American Justice Center (AAJC), formerly known as the National Asian Pacific American Legal Consortium (NAPALC), is a national non-profit, non-partisan organization that works to advance the human and civil rights of Asian Americans through advocacy, public policy, public education, and litigation.

AAJC has three affiliates: The Asian American Institute (AAI) in Chicago; the Asian Law Caucus (ALC) in San Francisco and; the Asian Pacific American Legal Center (APALC) in Los Angeles, all of which have been engaged in working with their communities to ensure an accurate count during past decennial census. APALC is a Census Information Center and established a Demographic Research Unit to make Census 2000 and other relevant research more accessible to the growing Asian American and Pacific Islander community and the organizations that serve it. AAJC also has over 100 Community Partners serving their communities in 24 states and the District of Columbia.

Together with our Affiliates and our Community Partners, AAJC has been extensively involved in working to eliminate the problems that have historically resulted in undercounting and underreporting of Asian Americans in federal data collection and analysis efforts, and in particular the decennial census count. AAJC conducted an extremely successful national Census 2000 outreach and educational project focused on the Asian American community. Through this project, AAJC and its Affiliates distributed over 750,000 linguistically and culturally appropriate community education materials and hosted or participated in over 865 community education activities, including panel discussions, presentations and press conferences.

Since the 2000 Census, AAJC has not paused in its efforts to ensure accurate and appropriate federal data collection and reporting on Asian Americans. AAJC has been a member of the Decennial Census Advisory Committee since the beginning of 2000. In 2005, AAJC became a member of the reconstituted and downsized 2010 Census Advisory Committee. In its advisory role, AAJC is able to assist the Census Bureau in understanding what research and programs would help the Bureau to effectively address the cultural differences and intricacies in various hard-to-reach communities, particularly in the Asian American communities, in order to get the most accurate count possible.

Additionally, AAJC currently co-chairs the Leadership Conference on Civil Rights’ (LCCR) Census Task Force. LCCR is the nation’s oldest, largest, and most diverse civil and human rights coalition, with nearly 200 member organizations working to build an America as good as its ideals. In its leadership capacity on LCCR’s Census Task Force and in my leadership capacity as the Vice Chair of LCCR, AAJC has kept LCCR members informed of important census policy issues and has facilitated conversation among the groups to build consensus recommendations for various census policy and outreach issues. One of the purposes for census data is the enforcement of civil rights laws and LCCR members are experts on related data issues and the need for accurate counts and data.

AAJC is pleased to provide comments on ongoing preparations for the 2010 Decennial Census survey by the Census Bureau. AAJC would like to request that this written statement be formally entered into the hearing record.

Undercount Concerns

Since 1940, the Census Bureau has attempted to measure its ability to accurately count the people in America whether it was through Demographic Analysis or the use of a separate coverage measurement survey. Duplicate responses lead to overcounts, while omissions, or missed persons, lead to undercount. Subtracting overcounts from undercounts results in a net undercount or overcount for each census. It is important for the Census Bureau to check its ability to achieve an accurate count through a coverage management program.

For each decennial census from 1940 to 1980, the national net undercount went down, as did the net undercount for specific population subgroups. However, since 1940, there has always existed a differential undercount – that is, non-Hispanic whites had lower undercount rates than people of color, or, stated another way, people of color were missed by the census more often than non-Hispanic whites. The differential undercount was also reduced each decennial census since 1940.

The 1990 census was a watershed moment for the Census Bureau. It was the first census that was less accurate than the one previous. The differential undercounts were the highest the Census Bureau had ever recorded. We also learned from 1990 that it was not only African Americans who suffered significant differential undercounts but also Latino Americans and Asian Americans. American Indians on reservations had the highest undercount of any groups in the 1990 census, with an undercount rate over 12 percent. The undercount of children was generally disproportionate. Children made up a quarter of the overall population in 1990, but accounted for slightly more than half of all persons missed by the Census Bureau. The undercount of children of color was even more disproportionate. For example, the undercount for African American children was twice as high as that for non-Hispanic white children.

In 2000, the Census Bureau worked to improve the accuracy of the count. Unfortunately, it was unclear how well the Census Bureau was able to count people. The final coverage measurement, the Accuracy and Coverage Evaluation (Revision II) (“A.C.E. Revision II”), results showed a net national overcount of about one-half a percent. However, a net national overcount/undercount of around zero masks a much larger counting problem. While it appeared that the net undercount for the entire population and the net undercount for some race groups were reduced, the results did not fit historical patterns for these race groups.

For example, the A.C.E. Revision II showed that Asian Americans nationally had a slight overcount. However, some of the Asian American subgroups believed that they were actually undercounted. This was particularly true for Southeast Asian communities. There was a relatively high rate of duplication for Asian Americans in college living away from home, which likely offset any undercount of Asian Americans. Despite the fact that in the end, the Census Bureau did not have confidence in the detailed findings and decided not to adjust the census numbers, the National Academy of Sciences’ National Research Council did conclude with a fair amount of confidence that the net undercount and differential undercount by race/ethnicity were reduced from 1990. However, the panel also concluded that there existed a differential undercount of racial minorities in the 2000 census.

For the 2010 census, it is important to look at what the Census Bureau is planning on doing to address the undercount and overcount issues. The Census Bureau is making a concentrated effort to minimize the overcount; its Fiscal Year 08 budget request includes development of a “master unduplication system.” The budget request also makes note of the fact that the Census Bureau will “continue the research and implementation of methodologies to address multiple enumerations.” For the 2008 Dress Rehearsal, coverage improvement operations include “the unduplication of persons and housing units,” as well as the use of software for “improving the unduplication operation.”

Unfortunately, it’s less clear what specific steps the Census Bureau will take to address the undercount. The Fiscal Year 08 budget makes references to research on “coverage probes” and residence rules, which the Census Bureau believes might help identify households at risk of undercounting. However, beyond these general statements about research on “coverage probes,” the Census Bureau has not provided specifics of how they are going to go about developing these coverage probes and how they will use residence rules to help identify these households and undercount in 2010. What we do know is that if the Census Bureau takes concrete steps to address the overcount, but does not succeed in adequately addressing the undercount, we are likely to see a higher net undercount and higher differential undercount.

The 2008 dress rehearsal will give us an opportunity to check in to see how well the Census Bureau is doing counting people. The Census Bureau plans on utilizing a coverage measurement survey to test how well they are counting people. This will give the Bureau a chance to address potential undercount problems in 2009 and 2010 by possibly increasing their partnership and outreach efforts to ensure that the traditionally hard to count areas are being reached. While the measurement of undercount and overcount produced for the 2010 will not be used for statistical adjustment purposes, the Census Bureau need funds in place to carry out the coverage measurement survey. The information is still needed in order to figure out how well the Census Bureau did in accurately counting people, how accurate the census was from community to community, and if the resulting census count was fair.

Importance of Funding for Partnerships

The 2000 census partnership and outreach program was credited by many in the civil rights community and in the Census Bureau for helping to achieve one of the most accurate counts for many of our hard to count communities. Establishing partnerships with hard-to-count communities has been shown to reduce non-response follow-up costs and improve accuracy. As noted above, while the 2000 count was better than in the previous year, there is still a ways to go and improvements to be made to help achieve an even more accurate count in the face of growing privacy fears and concerns about potential government misuse. We believe that a partnership and outreach program that builds upon the successes in 2000 is a critical step towards a more accurate count.

The partnership program promotes a more accurate count by having government leaders, school leaders, faith-based leaders, and other kinds of community leaders communicate with their constituents about the importance of filling out their census form to the success of the economy and their community – their neighbors, their kids, their schools and so forth. This has proven to be a great success as respondents are interacting with leaders that they trust, rather than with a stranger representing the federal government, and have been more willing to participate in the census program.

The Census Bureau itself has noted the value of a strong partnership program. Despite touting the benefits of a strong and vibrant partnership and outreach program, the Census Bureau has not provided a specific plan for the partnership program, other than to say that the partnership program will mainly be addressed in Fiscal Year 09. The Census Bureau is not planning to increase the funding for partnership workers in the regions in Fiscal Year 08. Rather, they are simply going to do the planning in 2008 while maintaining the small number of partnership workers who are currently out there and expanding the partnership program in Fiscal Year 09.

The Census Bureau is delaying its partnership work until 2009 because there is no funding for the partnership program in Fiscal Year 08. Director Kincannon testified that the Census Bureau had in fact requested $18 million for the partnership program in Fiscal Year 08 from OMB. Unfortunately, as Director Kincannon further testified, OMB zeroed that request out. The result is that the White House failed to request any money for the partnership program for Fiscal Year 08.

If the Census Bureau does not get adequate funding specifically in Fiscal Year 08 to do the partnership and outreach program, then the accuracy of the count, particularly of hard-to-count communities, is at risk. The reality is that advance planning is necessary to implement an effective partnership and outreach program. Time is needed for the Census Bureau to do the outreach to the organizations for the partnership program as well as to reach out to local governments and get them engaged in these efforts. Time is also needed for the CBOs, schools, churches and other partner groups to gear up for their outreach campaign to their constituents. Time is also need to allow these partner groups to raise funds from local philanthropists and other sources to do the outreach work. This time, and the advance planning, is particularly important for minority communities to adequately provide the outreach necessary for its constituents. Inadequate or nonexistent partnerships and outreach will result in high undercounts and differential undercounts.

This is simply unacceptable. In 1998, the Census Bureau’s Regional Partnership budget was almost $6 million, with a ramp up budget of over $30 million for 1999 and almost $58 million in 2000. The total cost for the Regional Partnership program for the 2000 Census was $93,280,154. This budget was separate from the budget for the advertising contract. The Census Bureau today is behind the curve compared to where it was in 1998 regarding the partnership program and is jeopardizing the accuracy of its count in 2010. It needs the money in 2008 to begin developing an effective partnership program. 2008 is critical to the recruitment of the partnership specialists, the training of recruited specialists, and for these specialists to begin to develop the contacts they need for a successful program. Even if the Census Bureau was to receive full funding in 2009 plus the amount they requested from OMB for 2008, they would not be able to make up for lost time. Waiting until 2009 to fund the partnership program is will jeopardize the overall count as well as severely undermine minority counts.

Concerns of the Civil Rights Community Regarding Execution

Language Assistance Program

We are concerned about the Census Bureau’s plans to provide language assistance to the many limited-English people that need help filling out their forms. Lack of English fluency is a real barrier in getting many limited English proficient persons to fill out their surveys. The Census Bureau’s own focus group research found that Asian Americans believed that lack of in-language questionnaires and lack of English-language fluency were among the major barriers to having greater participation in the census among the Asian American communities. The focus group research also noted that some in the Arab American community are not comfortable enough speaking or reading English to complete the census forms. The Census Bureau must develop a language assistance program that addresses the language barrier to census participation.

The Census Bureau made strides to address respondents’ language ability issues during the 2000 census. The Census 2000 mailout/mailback questionnaires were printed in six languages – English, Spanish, Chinese, Tagalog, Vietnamese, and Korean. The Census Bureau also produced Language Assistance Guides in 49 languages other than English. While the Census Bureau is to be commended for undertaking a variety of language assistance initiatives, the expansion of which was a significant improvement over the effort in 1990, there was still more that needed to be done. For example, the Census Bureau did not provide enough translated materials and questionnaires to meet the need and the demand. The Census Bureau also did not produce materials in a timely manner whereby the translated materials that were shared were shared so late in the process that they were not useful. There was no consistency in the translations used across Census Bureau materials, as there was no consistency in the language assistance provided from region to region, and locality to locality. Finally, there was inadequate publicity and coordination with CBOs to get what materials they did have. The Census Bureau must learn from these problems to build upon the successes of the 2010 program to make a more effective program in 2010 Director Kincannon noted in a hearing before the appropriations subcommittee that the Census Bureau’s language plans are improved over 2000. He further states that the same or greater number of languages will be involved in the preparation of questionnaires so that the Bureau can have questionnaires or questionnaire guides in many different languages. The Census Bureau also plans to have dual English-Spanish questionnaires that will be mailed in the original mailing of the census targeted to census tracts identified by ACS data where there are predominances of households where Spanish is spoken in the household. The Census Bureau tested the dual questionnaire; it showed that the dual questionnaire increases response rates, not only among people who speak Spanish, but among people who speak English in the home.

While the Census Bureau should be commended for the work that they have done to ensure that Spanish speakers are adequately assisted, we are very concerned that the Census Bureau has not done enough to begin planning for the other languages that must be assisted during the 2010 Census. The Bureau’s plan to provide numbers that people can call to receive language assistance is a good starting point but, as they say, the devil is in the details. Planning must begin now in order to have time to recruit non-response follow up interviewers and bilingual operators to man telephone assistance centers from communities so that the languages spoken in those communities are represented and to develop a translated glossary of terms for them to use. Advertising availability is also key. We were very pleased to see the Census Bureau conduct a series of extensive focus groups with hard to reach communities, including language minority groups. We applaud the Bureau’s efforts to do the focus groups language minorities in their native languages. However, the Census Bureau needs to begin turning this information into action.

When you factor in the development of appropriate materials for promotion and outreach – leaflets for handing out to people, posters and other promotional materials – and questionnaire aids in different languages, the Census Bureau needs to start the process today. The Census Bureau is waiting for the awarding of the advertising contracts and the communication contracts.

Translation is done one the basis of contracts, and there will be advertising and communication contracts or subcontracts that will be contracted out to reach specific hard-to-reach communities. However, the Census Bureau requested funding in the 2008 budget to plan the integrated communications strategy starting 2008. Then that strategy will be used going forward with requests for additional money to implement that strategy, presumably in Fiscal Year 09.

Unfortunately, that will be too late for some of the languages that the Bureau must cover. Some languages are simply more difficult to work with, such as some of the Asian languages. From the translations to the hiring of linguistically competent workers, more time will be needed to ensure that these communities actually receive assistance for the 2010 Census. One of the common complaints AAJC received following the 2000 census from local Asian American community-based organizations was that the Bureau was late in making critical decisions on the translations materials and there was no centralized clearinghouse of translated materials. Because of the lateness of the Bureau’s decisions, CBOs did not have sufficient time to determine what needed to be produced to supplement the offerings nor were they able to adequately utilize the materials produced by the Census Bureau.

Advertising Campaign

It is clear that more money is needed in the budget for advertising in language and to target language minority communities. The Census Bureau must also begin thinking about the language component of its paid advertising campaign. During the 2000 Census, AAJC heard from local CBOs that the Census Bureau’s innovative advertising campaign did not reach many ethnic groups who needed in-language media the most. The 2000 campaign targeted the Asian American groups with the highest number of LEP individuals, but unfortunately, did not also target the smaller ethnic groups who have the highest rates of limited English proficiency and the highest percentage of linguistically isolated households. With a limited budget the advertising campaign failed to cover an adequate number of Asian languages and cultures, and the advertising agency was forced to make generalizations based on sometimes inadequate research. Planning that begins today will allow the Census Bureau to make the appropriate funding requests to ensure that they are able to provide the language assistance needed.

Recruitment and Hiring

Director Kincannon testified that another component of the language assistance program will be recruiting locally for temporary workers. The Census Bureau must recruit 1 million temporary workers to get the 500,000 temporary workers they will need to execute the 2010 census. Director Kincannon’s commitment to recruiting, and presumably actually hiring, people who are “indigenous” to the communities where they will be working, indicates his recognition of the utility of the knowledge these workers bring – from the local knowledge of language to the local knowledge of neighborhood and culture.

For the 2000 census, OPM waived the citizenship requirement for the hiring of the temporary workers for the census. This helped the Census Bureau to ensure that the person knocking on the door for the 2010 Census looked like and sounded like the person answering the door. This is particularly useful in collecting complete information from immigrant respondents, where they are more likely to be mobile, have complex household arrangements, and lack English-language skills and thus harder to count. People are more likely to respond to enumerators who share their same cultural background, language, and other such factors. Another exemption utilized by the Census Bureau in 2000 was an exemption for federal retirees to work as a temporary worker for the census that ensured that their retirement/pension was not impacted by their work with the Census Bureau. This is particularly relevant as we now see a huge wave of new retirees leaving the work force, which provides the Census Bureau an opportunity to recruit these new retirees so that the Bureau’s temporary work force better reflects the population in this county. These two exemptions were key to helping to recruit the necessary workers. The Census Bureau should begin working with the necessary agencies to set those policies in place sooner rather than later – the decision to waive must be made early to avoid the confusion and uneven implementation of the waivers during the 2000 census. It will only help their recruitment, especially of bilingual workers for the various language groups.

Additionally, the Census Bureau should constantly strive to achieve a more diverse full time workforce. Many of the groups have met with the Census Bureau to discuss their concerns that the Bureau’s workforce, particularly at the senior management level, is not as diverse as it could be. We believe that the Census Bureau must implement a hiring policy that recognizes the importance of having experts on various hard-to-count communities, including the Asian American, Pacific Islander and other minority communities, throughout the Bureau’s operations. In particular, it is important for the Census Bureau to recruit and hire qualified persons of these communities in senior positions. These positions are particularly important for those programs and offices that are charged with ensuring that Census Bureau programs are adequately and appropriately addressing the outreach and data generated for these communities.

Agreement with U.S. Immigration & Customs Enforcement

The Census Bureau must also begin working with the U.S. Immigration & Customs Enforcement (“ICE”) to limit their enforcement activity during the 2010 Census process. Unfortunately, enforcement efforts by the Immigration and Naturalization Service (INS), ICE’s predecessor, despite a commitment to limit activity during the census, may have caused many immigrants to avoid participating in Census 2000. The INS was slow to come out with guidance to its regional offices concerning enforcement during the census and failed to adequately communicate policy early in the process resulting in raids conducted in Arizona, Oklahoma, Washington State and Texas even after the release of guidance requesting offices to limit highly visible enforcement activities. Many immigrants, who had initially been convinced that they could safely participate in the census, were frightened because of the raids that took place. The Census Bureau can ill afford this chilling effect, especially in light of recent data sharing and privacy concerns that have surface recently (please see the last section for further information on these concerns).

American Community Survey

Finally, while this hearing is focused on the preparations for the 2010 Census, I would be remiss if I failed to mention that another key component that requires oversight is the implementation of the American Community Survey (ACS). While the 2010 Census is important for reapportionment purposes, ACS data is equally important for nonpolitical purposes, such as governmental planning, appropriations and work done by non-governmental agencies. Because the ACS replaces the long form of the decennial census, it is important that the quality of data captured by the ACS is at a minimum the same as the long form. Ideally, the quality of data would be better, since the move to the ACS was designed to improve our ability to capture more current data. While 2005 was the first year of full implementation of the ACS, there remain issues regarding the implementation of the ACS and its ability to capture data, particularly for hard-to-count communities, including smaller population groups. Concerns include whether there is adequate language outreach to languages other than Spanish, the quality of data generally and specifically with regards to smaller populations, and the inclusion or exclusion of group quarters, such as dorms, prisons, and nursing homes. I look forward to a future hearing that delves deeper into the implementation of the American Community Survey.

Content Determination

The Census Bureau is to be commended for its process in making the content determination. Regardless of whether we were on the same side of any particular issue, the Census Bureau always made an effort to invite our input as members of the 2010 Census Advisory Committee on content issues.

The final content decisions came about as a result of a content development process that began early in the decade and included a series of tests that ended in a national content test in 2005. These tests were designed to examine alternative versions of questions and response categories to determine which version would elicit the highest and most accurate response rates. The Census Bureau summarized its research from the decade and proposed what it believed was the appropriate content for the 2010 census questionnaire.

The Census Bureau then held a Special Joint Meeting of the Census Advisory Committees on November 30, 2006, which focused solely on the content for the 2010 census survey. The Census Bureau presented its recommendations and provided an extensive dialogue between committee members and the Bureau. The committees then met themselves to discuss the soundness of the Bureau’s content proposal. The committees in attendance were:

• 2010 Census Advisory Committee</DI