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MASC’s Comment on Proposed Federal Standards

URGENT ACTION NEEDED REGARDING THE CENSUS

A comment period has opened with the Office of Management and Budget (OMB) to express your thoughts on combining the Latino ethnicity question with the racial identity question.  If this change goes through, this will be the first time in US history where Latinos/as of Mixed Ancestry will be able to identify a mixed identity.  The OMB sets standards for the entire federal government to follow, including the Census Bureau, as well as state and local governments and agencies that do business with the federal government.  Please click HERE to learn what you can do.

You do not have to be mixed Latino to care about mixed Latino identity.  Leave your comment to show your support for all people to have greater freedom to identify.

To learn more about the proposed change visit the Federal Register’s website HERE.

The OMB uses 11 principles for guiding the categories they choose to use.  Below is a copy of MASC’s official position as expressed in a comment we delivered to the OMB.  Bold text are the principles as stated by the OMB:

MASC supports revision of Office of Management and Budget (OMB) standards to enable mixed identification as both Latino/Hispanic and non-Latino/Hispanic.  The proposed combined Latino identity and race question enables this identification due to the ability to “mark one or more” categories.  We believe this is consistent with the evaluation principles used in past standards as described below:

  1. The racial and ethnic categories set forth in the standard should not be interpreted as being scientific or anthropological in nature.

No change is proposed to the existing categories, rather we propose multiple identification similar to what has already been implemented for existing racial categories.

  1. Respect for individual dignity should guide the processes and methods for collecting data on race and ethnicity; respondent self-identification should be facilitated to the greatest extent possible.

Persons of mixed Latino and non-Latino identity due to mixed ancestry have had their dignity diminished by the inability to recognize all of who they are; essentially forced to choose between their parents and pick “sides” when they are truly full members of multiple races/ethnicities.

  1. To the extent practicable, the concepts and terminology should reflect clear and generally understood definitions that can achieve broad public acceptance.

Again, no change is proposed to the existing categories.

  1. The racial and ethnic categories should be comprehensive in coverage and produce compatible, nonduplicated, exchangeable data across Federal agencies.

In a combined question format this would simply be another version of “Two or more races.”  As a separate question there would be the creation of a “Two or more ethnicities” which has been a proven solution for the race question.

  1. Foremost consideration should be given to data aggregations by race and ethnicity that are useful for statistical analysis, program administration and assessment, and enforcement of existing laws and judicial decisions, bearing in mind that the standards are not intended to be used to establish eligibility for participation in any Federal program.

The same policies for data aggregation may be used with multiple Latino and non-Latino responses.

  1. While Federal data needs for racial and ethnic data are of primary importance, consideration should also be given to needs at the State and local government levels, including American Indian tribal and Alaska Native village governments, as well as to general societal needs for these data.

Many local agencies, non-profits, and media outlets are already combining racial data collected from the Census’s separate questions into a single dataset essentially modifying racial self-identification.  Combining the questions will bring the Census more in-line with these trends.

  1. The categories should set forth a minimum standard; additional categories should be permitted provided they can be aggregated to the standard categories. The number of standard categories should be kept to a manageable size, as determined by statistical concerns and data needs.

There is no proposed change to the minimum standard.

  1. A revised set of categories should be operationally feasible in terms of burden placed upon respondents and the cost to agencies and respondents to implement the revisions.

Respondents have already shown acceptance of the multiple response option.

  1. Any changes in the categories should be based on sound methodological research and should include evaluations of the impact of any changes not only on the usefulness of the resulting data but also on the comparability of any new categories with the existing ones.

The Alternative Questionnaire Experiment (AQE) has already determined the soundness of the methodology with a combined format resulting in no decreases to the Latino/Hispanic population. 

  1. Any revision to the categories should provide for a crosswalk at the time of adoption between the old and the new categories so that historical data series can be statistically adjusted and comparisons can be made.

Again, no new categories are being introduced and the AQE has demonstrated that there will be no decrease in Latino population.  If anything, the Latino population may go up as those that were not choosing a Latino identity because there was no multiple response option may begin identifying as Latino on the surveys.

  1. Because of the many and varied needs and strong interdependence of Federal agencies for racial and ethnic data, any changes to the existing categories should be the product of an interagency collaborative effort.

Studies by Trejo and Duncan and by Emeka and Vallejo have shown that Current Population Survey (CPS) data and American Community Survey (ACS) data have been skewed by the inability of Latinos of mixed ancestry to identify with multiple categories.  The Bureau of Labor Statistics may be interested in improved quality of CPS data as would any other agency making use of Census Bureau data.