OMB Requests Comments on Proposal for Revising Race and Ethnicity Standards

By: Sheryl Harmening

On January 26, 2023, the Office of Management and Budget (OMB) announced its proposal for updating the standards used for collecting race and ethnicity data. OMB most recently updated these standards in 1997 through Standard Policy Directive 15 (SPD 15). The current review of SPD 15 is intended to better reflect the racial and ethnic diversity of the United States. 

The proposed revisions are the result of work by the Federal Interagency Technical Working Group on Race and Ethnicity Standards that was established by OMB in 2022. The Working Group includes representatives of government agencies that collect or use race and ethnicity data. The Working Group was tasked with providing recommendations on: 

• Whether the current race and ethnicity categories should be changed; 
• Whether updates should be made to the format, terminology, and wording of race and ethnicity questions; 
• Whether guidance for the collection and reporting of race and ethnicity data can be improved

Recommendations for Changes on Collecting Race and Ethnicity Data 

In a Federal Register Notice published on January 27, 2023, the Working Group presented the following recommendations:

1. Collect race and ethnicity data in a single question
   The Working Group found that the separation of race and ethnicity questions is confusing to many respondents who view both race and ethnicity as similar concepts. 
2. Add “Middle Eastern or North African” as a new category
   The Working Group found that persons from counties in the Middle East or North Africa (MENA), who are currently in the “White” race category, do not share the same experience as persons with European ancestry who are included in this category. A MENA category would include individuals who identify with nationalities and ethnic groups with origins in countries including but not limited to Lebanon, Iran, Egypt, Syria, Morocco, and Israel.
3. Require detailed collection of race and ethnicity categories
   The Working Group found that agencies collecting race and ethnicity data should collect data at a more granular level such as by country of origin.  

According to the notice published in the Federal Register, “the Working Group assessed the work by the previous 2014-2018 Federal Interagency Working Group for Research on Race and Ethnicity, existing Federal Government research, experiences from the 2020 Census, and the work of the Interagency Working Group on Equitable Data pursuant to Executive Order 13985” to develop these recommendations.  

Public Comment  

OMB is seeking public comment on the Working Group’s recommendations and other possible changes to the collection of race and ethnicity data. Comments are due by April 12, 2023. Proposals from the Working Group are not final and the Working Group will continue to hold meetings while OMB considers the current recommendations. 

The federal register notice provides a series of questions where the public has been asked to provide input in regard to each Working Group recommendation. For example, OMB has asked the public to comment on the following questions: 

• If a combined race and ethnicity question is implemented, what suggestions do you have for addressing challenges for data collection, processing, analysis, and reporting data? 
• Do [the] proposed nationality and ethnic group examples adequately represent the MENA category? 
• What should agencies consider when weighing the benefits and burdens of collecting or providing more granular data than the [current] minimum categories? 

Examples of Possible Self-Identification Forms 

OMB shared two examples of possible self-identification forms that would meet the recommendations of the Working Group. 

1. Proposed example of minimum categories when detailed data collection is not feasible:
   
2. Proposed example with detailed categories: 
   

Background on Standard Policy Directive 15 

The 1997 standards currently being used emphasize the use of self-identification over observer identification. They include two separate questions, one on race and one on ethnicity, but allow for a combined question. The standards suggest the ethnicity question should be asked first followed by the race question. The 1997 standards separated the former Asian/Pacific Islander category into two separate categories.

While the OMB considered the creation of a MENA category in 1997, it ultimately rejected that proposal. There were concerns about data collection and reconciliation with past data. OMB also raised concerns about having separate race and ethnicity categories but decided to move forward with this approach. 

One item in SPD 15 that has resurfaced in the Working Group proposals involves the approach to collecting data on race categories. SPD 15 does NOT recommend the use of a “two or more races” category for data collection. Instead, SPD 15 recommends that individuals be allowed to select one or more races among the choice of races. The current OMB notice similarly proposes to have individuals select one or more races rather than use a category of “two or more races.” 

Next Steps 

• OMB will continue to review current Working Group proposals in the coming months.  
• The Working Group will continue to study various issues regarding the collection and use of race and ethnicity data.  
• Public comments on the current recommendations of the Working Group are due to OMB by April 12, 2023. 

DCI will continue to monitor this subject and will provide more information on the implications of the proposed changes to the collection of race and ethnicity data.