Leadership Conference Comments on the Current Population Survey (CPS)

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August 26, 2025

Kyra Linse
Survey Director, Current Population Surveys
U.S. Census Bureau
4600 Silver Hill Road
Washington, DC 20233

Re: Comments on the Information Collection Request for CPS Basic Demographic Items (FR Doc. 2025-11855; Docket ID USBC-2025-0009)

Dear Ms. Linse,

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, and its Census Task Force co-chairs, Asian Americans Advancing Justice | AAJC and NALEO Educational Fund, we appreciate the opportunity to comment on the Census Bureau’s proposed extension and expansion of its Current Population Survey (CPS) Basic Demographic Items. We applaud the bureau’s efforts to modernize this critical survey and respectfully submit the following recommendations to strengthen its implementation.

Importance of SPD15 Implementation in the CPS

The CPS has long been a cornerstone of federal labor force statistics, necessary for both our democracy and economy, providing monthly insights into employment, unemployment, and workforce participation. Its strength lies in the timeliness of its labor market data and in thier demographic detail, which allows researchers and policymakers to examine disparities across communities. The survey’s demographic items, such as age, sex, marital status, education, race, origin, Armed Forces status, and family income are essential for monitoring how different groups experience economic opportunity and challenges.

We support the Census Bureau’s testing and full implementation of the 2024 SPD15 standards in the CPS as it prepares to adopt the 2024 standards in its other data collections. Testing and implementing the 2024 SPD15 standards in the CPS is especially significant because these revisions will allow for greater visibility of detailed racial and ethnic groups within federal labor data. The 2024 SPD15’s new Middle Eastern/North African (MENA) category, combined race and ethnicity question design, and requirement to collect data on detailed subgroups will allow for more accurate respondent self-identification, better recognition of multiracial and multiethnic identities, and improved comparability across federal surveys. These improvements will help to address long-standing gaps in federal data. For historically undercounted or misclassified groups, these changes represent a major step toward ensuring more accurate representation in federal statistics and the policymaking they inform.

Insights from the comparison of CPS data collected under the 1997 and 2024 SPD15 standards can also help to inform successful implementation of the new standards in other Census Bureau data collections, such as the American Community Survey. These revisions may lead to shifts in population distributions across racial and ethnic categories, which in turn would affect weighting, labor force estimates, and analyses of disparities. In its analyses of results from testing of the 2024 SPD15 standards on the CPS, the Census Bureau must prioritize measuring how well the updated questions capture respondent intent and how question instructions and interview methodology can best support accurate and consistent responses. This analysis should include quantitative and qualitative testing, as well as consultation with a diverse range of stakeholders, to better understand patterns of response to the 1997 and 2024 SPD15 race and ethnicity items.

Data Quality, Comparability, and Clarity

While the adoption of the 2024 SPD15 standards is an important step toward more accurate federal race and ethnicity data, proper guidance for respondents on the new question design will be critical to their successful implementation. To help stakeholders and the public understand the changes, the bureau should provide more public-facing guidance on how the combined race and ethnicity question under the 2024 SPD15 standards differs from the two questions used under the 1997 standards in language, structure, and interviewer protocols. To ensure the accuracy of data collected under the 2024 standards, testing of their initial implementation on the CPS should include quantitative and qualitative analysis of question stems, instructions, and interviewer protocols used to elicit responses, as these features can strongly influence how respondents understand and answer questions. Such testing can help the Census Bureau refine question instructions and other guidance to help respondents correctly interpret categories, reducing error and improving comparability across modes.

We also encourage the bureau to outline how it will assess the consistency of responses across different interviews and over time. Response consistency testing is vital for understanding whether the revised question is capturing stable identity reporting or whether changes in measurement are driving artificial variation. Qualitative methods, such as re-interviewing or focus groups with CPS respondents, are a critical complement to quantitative assessment of any differences. The Census Bureau should also consult with stakeholder experts from any groups where significant differences in responses are expected or observed to better understand what may be driving these differences and how to improve consistency.

Equally important, the bureau should develop and clearly communicate data bridging methods to connect CPS estimates collected under the 1997 standards with those collected under SPD-15. Without bridging tools such as dual coding, crosswalks, or parallel testing, analysts may misinterpret measurement changes as real demographic shifts. Given the CPS’s central role in producing monthly and annual labor force statistics, continuity is essential. The bureau must also provide accessible, clear information about how the revised standards have affected the tabulation and reporting of persons who are “two or more races or ethnicities” or how persons in each minimum category are reported as either “alone” or “alone or in combination.” Guidance on bridging methods will allow policymakers, researchers, and advocates to track long-term trends in employment and disparities with confidence, while also taking advantage of the improved accuracy and inclusivity that SPD15 brings.

Respondent Burden and Methodology

While we strongly support modernization through SPD15 implementation, we note that the notice does not provide sufficient detail on expected respondent burden or methodological design. Without this information, it is difficult to evaluate the efficiency of the proposal or assess whether the new question design will affect the amount of time respondents spend completing the race and ethnicity item.

We urge the bureau to publish clear and disaggregated burden estimates associated with the 2024 SPD15 question. This should include any estimated changes to the time per interview, the overall effect on respondent burden, and information about whether current CPS survey infrastructure and interviewer training can accommodate the new categories without disruption. Greater detail on the methodology — such as pilot sample size, mode of administration, and planned analysis — will also allow the public to better understand and evaluate the effectiveness of the proposed changes. Given existing research showing that respondents often find the combined race and ethnicity format more intuitive, the Bureau should assess not only whether burden increases but also whether the revised design results in time savings or greater ease of response.

Collecting complete and high quality race and ethnicity data should be a guiding principle in implementing changes to these items on the CPS. Minimizing respondent burden is also an important goal that should be carefully balanced with the benefits of collecting more accurate and comprehensive data. If the adoption of the 2024 SPD15 question increases interview length, the bureau should explore ways to offset this by streamlining other items or optimizing question design. Tools such as automated quality checks, pre-loaded response categories, or adaptive interviewer aids may also help reduce respondent fatigue and error. Minimizing burden not only helps ensure compliance with the Paperwork Reduction Act, but it also strengthens data quality by reducing the likelihood of incomplete or rushed responses.

Conclusion

We strongly support the Census Bureau’s initiative to incorporate the 2024 SPD15 standards into the CPS. These changes will improve the accuracy, representativeness, and usefulness of one of the nation’s most critical labor force surveys. By refining burden estimates, clarifying methodological details, testing question stems and prompts, ensuring response consistency, and developing robust data bridging methods, the bureau can ensure a smooth transition and strengthen the value of CPS data for policymakers, researchers, advocates, and the public. We also wish to reiterate that the Census Bureau must prioritize meaningful consultation with stakeholders from impacted communities as it moves forward with implementing the 2024 SPD15 standards on the CPS and other data collections, as this consultation is critical to understanding patterns in data collected under the new question design.

We appreciate this opportunity to provide comments and look forward to continued engagement as these important updates are implemented. For any questions, please contact Meeta Anand, senior program director of census and data equity at The Leadership Conference on Civil and Human Rights, at [email protected].

Sincerely,

The Leadership Conference on Civil and Human Rights
Asian Americans Advancing Justice | AAJC
NALEO Educational Fund

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