The way the federal government collects race and ethnicity data has long been imperfect. But the Office of Management and Budget’s (OMB’s) recent announcement proposing initial revisions to its common standards for collecting race and ethnicity data—known as Statistical Policy Directive No. 15, or SPD15—is an important step toward gathering more inclusive, comprehensive race and ethnicity data.
In its nearly half-century of existence, SPD15 has only been updated once. The 1997 standards currently in use collect race data by asking respondents to identify with one or more of five minimum reporting race categories: American Indian or Alaska Native, Asian, Black or African American, Native Hawaiian or other Pacific Islander, and White. They then collect ethnicity data using a separate question: “Are you Hispanic or Latino?”
A team at the Urban Institute is among more than 18,000 research, membership, and advocacy organizations and individuals who have offered a range of ideas in response to OMB’s request for comments on their proposed revisions to SPD15. In our public comment letter, we highlight a few key factors for consideration:
- Collecting race and ethnicity information in a single, combined question would conflate multiple constructs about how people self-identify and potentially result in underreporting of racial identities, including among Latinx people.
- To capture more consistent information, SPD15 revisions could establish recommended subcategories for collecting more disaggregated data than the minimum categories allow. In determining whether the burden of collecting detailed race information outweighs the benefits for key stakeholders, agency staff should prioritize community and individual consent, balance individual burden versus community benefit, empower full community participation to influence these decisions, and center communities that have historically experienced harm because of the weaponization of data, including Black and Indigenous communities.
- With guidance on appropriate use and ways to avoid harm to underrepresented communities, agencies can use data science and statistical methods (including imputation to support data linkages and analysis) when self-reported and self-identified data cannot be collected.
OMB’s current proposals to revise SPD15 would transform the collection of race and ethnicity data and change key federal datasets—like Census Bureau data that shape decisions about how hundreds of billions of dollars in federal funds flow to communities each year. Our suggestions aim to ensure that changes to SPD15 allow more people to see their racial and ethnic identities reflected in data collection and that federal agencies gathering these data are meaningfully engaging with key stakeholders and community members.
SPD15 must be routinely evaluated and revised to ensure accurate data collection
Race is a social construct that changes in meaning according to political, social, and economic conditions. Within the past two decades, the US has experienced significant demographic shifts and important racial-reckoning movements, making the current revision of SPD15 necessary.
These events have led to significant changes in how numerous communities think about their race, how others identify them, and what types and the extent of systemic oppression they endure. Many advocates and stakeholders, including those from Latinx and Middle Eastern or North African communities, have long been requesting revisions to current SPD15 standards because they don’t feel the current minimum reporting race categories include options that fit with how they experience and report their race. Key among OMB’s proposed changes to SPD15 is adding “Middle Eastern or North African” (MENA) as a new minimum reporting category, replacing the current practice of directing MENA respondents to select white as their race.
Given the fluid, ever-evolving nature of how people perceive and define their race, federal agencies will need to conduct ongoing evaluations and revisions of SPD15 standards to ensure they accurately capture the diversity of racial identities. Updates that add or sunset categories as appropriate could help identify disparities in outcomes across health, education, and other systems. This, in turn, could better inform targeted strategies aimed at improving differential outcomes for people most disenfranchised and obscured by previous SPD15 standards, such as Indigenous, Latinx, and Asian American and Pacific Islander communities.
Community partnerships are integral to ongoing evaluation of SPD15
In our comment letter, we detail several strategies agencies can use to meaningfully partner with community members to determine whether collecting detailed race and ethnicity data beyond the minimum categories is appropriate. Agencies can use many of those same strategies to engage communities in evaluations of SPD15.
Among those strategies are using focus groups and message testing, allotting additional resources to allow agency staff to partner more closely with community leaders to raise awareness about new collection methods, and developing collaborative governance structures that empower communities historically obscured by SPD15 to fully participate in decisionmaking about how and why their data are collected.
Another approach agencies can use is creating community advisory boards, where members regularly share perspectives from their communities and explore with agencies the impacts of new SPD15 standards as they’re adopted. This would not only provide a structure for agency staff to receive regular feedback about whether standards consistently and accurately capture race and ethnicity information; it would also help agencies determine whether new collection methods are improving outcomes for those whom SPD15 has historically oppressed the most. Insights from community advisory boards could help key stakeholders, including chief data officers, chief statistical officers, and new positions implied by Executive Order 14091, determine whether revisions to SPD15 standards are adequate.
Communities have long waited to see their realities meaningfully and continuously reflected in the collection and use of their race and ethnicity data. This revision cycle provides an opportunity for OMB to build trust with communities that have previously been obscured in federal race and ethnicity data. Federal agencies can show their commitment to empowering historically oppressed groups by collaborating with communities to ensure data collection efforts reflect communities’ needs and revising SPD15 standards as needed.