Comments on the American Community Survey Disability Questions

Uncategorized 04.24,24

View a PDF of the comments here.

April 24, 2024

Ms. Sheleen Dumas
Department PRA Clearance Officer
Office of the Under Secretary for Economic Affairs

U.S. Department of Commerce
1401 Constitution Ave., NW
Washington, DC 20230

Submitted via http://www.regulations.gov

Re: Agency Information Collection Activities; Submission to the Office of Management and Budget (OMB) for Review and Approval; Comment Request; The American Community Survey (ACS) and Puerto Rico Community Survey (PRCS); FR Doc. 2024–06256

Dear Ms. Dumas,

On behalf of The Leadership Conference on Civil and Human Rights, a coalition charged by its diverse membership of more than 240 national organizations to promote and protect the civil and human rights of all persons in the United States, we appreciate this opportunity to comment on the Census Bureau’s recent Request for a Revision of a Currently Approved Collection (request for revision). We appreciate the bureau’s decision to forgo any changes to the American Community Survey (ACS) disability questions in 2025. We also sincerely appreciate the bureau’s more recent efforts to more adequately engage with the disabled community and disability researchers.

While we appreciate the current pause on changes to these questions, we would strongly like to underscore the need for meaningful engagement on this issue, as well as to underscore the need to research and collaborate in order to identify the most inclusive and accurate ways to measure disability. The request for revision notes that the vast majority of comments it received related to proposed changes to the ACS disability questions focused on the failure to include disabled people in the process. We agree that this lack of engagement was a major concern.

The request for revision, however, also states that “The Census Bureau and National Center for Health Statistics (NCHS) stand behind the statistical validity of the 2022 ACS Content Test results and the practical utility of the proposed disability change. However, we recognize that statistical validity and practical utility for NCHS should be only two components of the decision about whether to change questions on the ACS—we must also consider the needs of other data users inside and outside of government.”[1]

As articulated by the National Partnership for Women & Families’ comment to this federal notice submitted on April 19, 2024, we have several concerns that arise from the quote above.

  1. Many concerns articulated by advocates and researchers about the Content Test’s scope and decision criteria have not been addressed,
  2. It is unclear what other components will be part of any decision to change ACS disability questions or how such components will be developed, and
  3. We are concerned about the path forward, as these statements indicate the Census Bureau may not be sufficiently open to considering new proposals from disability researchers and the disabled community.

While the bureau acknowledges in this request for revision that additional components must be considered in this disability collection moving forward, there is no clear specificity regarding what those components might be, how they will be developed, or how they will be considered. For example, we believe that additional components of the decision to change the ACS questions should include disability prevalence, the impact of the change of measurement on programs and funding, inclusivity of the measurements of different types of disabilities, utility of the measurements for various other agencies and programs, inclusivity of the process in generating the measurements, and more. While we appreciate the bureau acknowledging “the needs of other data users inside and outside of government” in making this decision, the importance of these data go well beyond the needs of just data users — just as the importance of the ACS and the bureau’s work reaches well beyond just creating estimates.

As the bureau moves forward, we appreciate the opportunity to engage on next steps and look forward to working together to develop additional testing strategies based on new proposals created in collaboration with the disabled community and disability researchers. For example, we would recommend conducting a National Academies of Sciences, Engineering, and Medicine (NASEM) study to further determine best practices and needs for disability data collection. We hope that the renewed commitment to engagement with the disabled community and disability researchers can lead to fruitful partnerships and inclusive ways of thinking about the ways in which disability data are collected.

Thank you for your consideration of our concerns and views. Please direct any questions about these comments to Meeta Anand, senior program director, census and data equity, at The Leadership Conference ([email protected]).

Sincerely,

The Leadership Conference on Civil and Human Rights

[1]  Agency Information Collection Activities; Submission to the Office of Management and Budget (OMB) for Review and Approval; Comment Request; The American Community Survey (ACS) and Puerto Rico Community Survey (PRCS), 89 Fed. Reg. 20,630 (March 25, 2024).