Statistical Agencies: Collection and Reporting of Race and Ethnicity Data

Published by the Government Accountability Office on 1997-04-23.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                          United States General Accounting Office

GAO                       Testimony
                          Before the Subcommittee on Government Management,
                          Information, and Technology
                          Committee on Government Reform and Oversight
                          House of Representatives

For Release on Delivery
Expected at
9:30 a.m. EDT
                          STATISTICAL AGENCIES
April 23, 1997

                          Collection and Reporting of
                          Race and Ethnicity Data
                          Statement of Bernard L. Ungar, Associate Director
                          Federal Management and Workforce Issues
                          General Government Division


Statistical Agencies: Collection and
Reporting of Race and Ethnicity Data

               Mr. Chairman and Members of the Subcommittee:

               I am pleased to be here today to discuss the reporting of race and ethnicity
               data. Our testimony today focuses on two issues you asked us to address:
               (1) our prior work on the collection and reporting of race and ethnicity
               data by the Bureau of the Census for the decennial census, as well as by
               other federal agencies; and (2) state reporting of race and ethnicity data to
               federal agencies for health and educational purposes. My comments are
               based on our prior work in this area, our current monitoring of plans and
               preparations for the 2000 Decennial Census, and limited data collection we
               did in selected states in April 1997 in response to your request.

               Over the years, our work has shown that the collection of these types of
               data is technically complex and publicly controversial. It is technically
               complex because race and ethnicity are not objectively definable
               characteristics, making measurement difficult. Also, in many instances, a
               person self-identifies his or her own race and ethnicity; in other instances
               another party may categorize that person’s race and ethnic designation by
               observation, which can produce inconsistent results. In addition, the
               manner in which different organizations may ask for racial or ethnic
               information, as well as how this information is compiled or aggregated,
               can lead to inconsistent results. Measurement of race and ethnicity is also
               controversial because some individuals have strong feelings about how
               they are classified and are uncomfortable, when presented with a list of
               classifications, if a particular “category” is not available for them to select.
               For example, some people who are multiracial want to be able to reflect
               this heritage by designating themselves as such; however, they may not be
               provided this choice. Alternatively, some people may oppose the use of a
               multiracial category because it could result in a reduction in the number of
               individuals classified in their racial category, and they view this as
               potentially reducing any benefits this particular group may receive. Some
               state and federal program or administrative officials raise concerns about
               a multiracial category because it may (1) add costs from the need to
               change forms and computer software, (2) not provide any analytical
               benefits, or (3) result in reporting inconsistencies and impede analyses of

               The United States government has long collected statistics on race and
Background     ethnicity. Such data have been used to study changes in the social,
               demographic, health, and economic characteristics of various groups in
               the population. Federal data collections, through censuses, surveys, and

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administrative records, have provided a historical record of the nation’s
population diversity.

Since the 1960s, data on race and ethnicity have been used extensively in
civil rights monitoring and enforcement covering such areas as
employment, voting rights, housing and mortgage lending, health care
services, and educational opportunities. Legislatively based requirements
in these areas created the need among federal agencies for compatible,
nonduplicative data for the specific population groups that historically had
suffered discrimination and differential treatment on the basis of their race
or ethnicity. We have attached a listing of some of the statutes that require
the collection and reporting of racial or ethnic data.

In the mid-1970s, the Office of Management and Budget (OMB), in
conjunction with several federal agencies, undertook a collaborative effort
to standardize racial and ethnic data collected and published by federal
agencies. The result of this effort was OMB’s 1977 publication of the “Race
and Ethnic Standards for Federal Statistics and Administrative Reporting”
contained in Statistical Policy Directive No. 15. These standards also
implemented the requirements of Public Law 94-311 of June 16, 1976,
which called for the collection, analysis, and publication of economic and
social statistics on persons of Spanish origin or descent. Directive 15,
which has not been changed since it was initially published, provides
standard classifications for recordkeeping, collection, and presentation of
data on race and ethnicity in federal program administrative reporting and
statistical activities. These classifications include four races—American
Indian or Alaskan Native, Asian or Pacific Islander, Black, and White; and
one ethnicity—Hispanic origin or not of Hispanic origin.

The standard collection categories are to be used for (1) civil rights
compliance reporting by both the public and private sectors and all levels
of government; (2) new and revised general program administrative and
grant reporting by federal agencies; and (3) statistical reporting by federal
agencies. According to OMB’s Chief Statistician, even though states are
not directed to follow OMB’s guidance except when reporting to the
federal government, in practice they generally do. The Directive states that
its purpose is not to limit the collection of data to the five categories—four
racial and one ethnic. However, any required reporting that uses more
detail must be organized in such a way that the additional categories can
be aggregated into the basic racial/ethnic categories. One notable
exception to the standard has been the Bureau of the Census, which was

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                             granted an exemption allowing it to include an “other” (write-in) response
                             to the race question in the 1980 and 1990 Censuses.

                             During the past several years, the standards have come under increasing
                             criticism from those who believe that the minimum categories set forth in
                             Directive No. 15 do not reflect the increasing diversity of our nation’s
                             population. Some have also proposed changing the names of some
                             categories. Because of these criticisms, OMB is in the process of
                             determining whether Directive No. 15 should be modified. Among the
                             changes being considered are whether a multiracial category should be
                             included; and whether “race/ ethnicity” should be asked as a single
                             identification, or whether “race” identification should be separate from
                             Hispanic origin.

                             Even if federal classifications for race and ethnicity were agreed upon, it is
Collection of Race           extremely difficult to obtain accurate and consistent data on the number
and Ethnicity Data by        of individuals within each classification. Our prior work on the Bureau of
the Bureau of the            the Census’ collection of race and ethnicity data during the 1990 Census
                             indicates that the question or questions used to elicit information on an
Census and Other             individual’s race and ethnicity will affect how an individual classifies
Federal Agencies             himself or herself. Consequently, if the results of different surveys using
                             different questions or a different series of questions to obtain race and
                             ethnic data from the same population were compared, it would be likely
                             that different proportions of respondents would be classified as White,
                             Black, Asian or Pacific Islander, or American Indian or Alaskan Native; or
                             of Hispanic origin. This work also demonstrated that external pressures on
                             the Bureau can result in the use of questions that may not provide as
                             accurate a count of racial and ethnic groups as would be possible if other,
                             alternative questions were used. Our prior work on federal agencies’ use
                             of race and ethnic definitions found that other factors can also affect the
                             quality of racial and ethnic data collected, including the fact that all states
                             may not use the same classifications as the federal government, and the
                             fact that some racial and ethnic data are obtained by
                             observer-identification rather than by self-reporting.

1990 Decennial Census        In 1993, we reported and testified that experience from the 1990 Decennial
Experience With Collecting   Census provided valuable lessons for future censuses.1 One lesson was the
Race and Ethnic Data         need to develop a consensus on the race and ethnicity questions as early in

                              Federal Data Collection: Measuring Race and Ethnicity Is Complex and Controversial
                             (GAO/T-GGD-93-21, April 14, 1993) ; and Census Reform: Early Outreach and Decisions Needed on
                             Race and Ethnic Questions (GAO/GGD-93-36, Jan. 28, 1993).

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                         the decade as possible. Another was the need for the Bureau of the Census
                         to continue efforts to improve race and ethnic data quality to ensure that
                         the quality of data collected is acceptable.

Consensus Not Achieved   In the 1990 Census, the Bureau was unable to build a consensus on its
                         recommended version of how Asian and Pacific Islanders were to be
                         represented in the race question despite implementation of a special
                         testing and consultation program. As a result, the final format of the race
                         question was decided late in the decade after protracted debate and was
                         contrary to the Bureau’s initial recommendations.

                         The Bureau, after testing alternative versions of the Asian and Pacific
                         Islander questions during the 1986 Los Angeles, Mississippi, and National
                         Content tests, among other tests, determined that a short version of the
                         race question was likely to produce data on the Asian and Pacific Islander
                         population that was as good as other test versions of the race question.
                         The short version provided a space for Asian and Pacific Islanders to write
                         in their specific groups, such as Chinese or Asian Indian. Other test
                         versions would have called for Asian and Pacific Islanders to mark
                         separate, prelisted, detailed groups of this racial category, as was done in
                         the 1980 Census. The Bureau’s research suggested that the write-in option
                         would produce a somewhat higher proportion of the population reporting
                         as Asian and Pacific Islanders than would the use of a question with
                         prelisted groups. Despite its research, the Bureau was unable to convince
                         the Asian and Pacific Islander community that the short version of the race
                         question should be used. Responding to congressional direction and
                         pressures from the Asian and Pacific Islander community, the Bureau
                         reconsidered its original decision and chose to include in the 1990 census
                         a version of the race question with prelisted Asian and Pacific Islander

                         This experience demonstrated the need for the Bureau to begin to work
                         early in the decade to work with a diverse group of customers, including
                         organizations representing the interests of various race and ethnic groups,
                         to identify data needs for the 2000 census and the best ways these needs
                         can be met. In congressional hearings, representatives of the Asian Pacific
                         Islander community said that the Bureau had not solicited their
                         participation in the early phases of redesigning the race question. The
                         advisory committees representing minority communities had not been
                         established until 1986 for the 1990 Census. This was the same year that the
                         major tests were held that drove the debate on the race question and the
                         Bureau’s initial recommendation. Several representatives said that the

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                      Bureau had already formulated the census questions before the
                      committees began to meet.

                      In contrast to the situation in preparation for the 1990 census, Census
                      advisory committees for the 2000 census were chartered in February 1994.
                      These committees included the African-American Population, American
                      Indian and Alaska Native Populations, Asian and Pacific Islander
                      Populations, and the Hispanic Population. The committees held a series of
                      meetings during 1995 prior to the June 1996 National Content test, at
                      which time the Bureau tested several variations of questions designed to
                      obtain race and ethnicity information. Another meeting of these advisory
                      committees was held in December 1996 to discuss major findings from
                      that survey. According to Census officials, the results of this survey and
                      the race and ethnicity tests should be available in early May 1997.

Data Quality Issues   Census Bureau evaluations suggested that the data from the 1990 race and
                      Hispanic origin questions were generally of high quality. However, the
                      evaluations also suggested that some problems associated with collecting
                      data on Hispanics that confronted the Bureau in 1980 continued. For
                      example, in both the 1980 and 1990 Censuses, the Bureau found that
                      Hispanics had difficulty classifying themselves by race, and this difficulty
                      led to inconsistent reporting by Hispanics when they initially completed
                      the census questionnaire compared to their responses when they were
                      interviewed as part of a quality check. Also, for both the 1980 and 1990
                      Censuses, the Bureau estimated that nearly all—97.5 percent in 1990 and
                      95 percent in 1980—of the respondents who reported being in the “other
                      race” category were persons of Hispanic origin.

                      The problems experienced in connection with the Hispanic origin question
                      stemmed, at least in part, from the format and sequence of the Hispanic
                      origin and race questions. According to the Bureau, both Hispanics and
                      non-Hispanics have had difficulty dealing with this issue. Some Hispanics
                      equate their “Hispanicity” with race and have had difficulty classifying
                      themselves by the standard race categories. In 1990, about 40 percent of
                      Hispanics marked the “other race” category; they either indicated they
                      were Hispanic in the Hispanic origin question or indicated they were
                      Hispanic in the write-in space provided in the race question. According to
                      the Bureau, some non-Hispanics, having already responded to the race
                      question, skipped over the Hispanic origin question when they should have
                      indicated that they were not of Hispanic origin.

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                      As part of OMB’s ongoing effort to determine whether Statistical Policy
                      Directive 15 should be revised, OMB and the Census Bureau are working
                      together to determine whether race/ethnicity should be asked as a single
                      identification or whether the race identification should be separate from
                      Hispanic origin or other ethnicities. Research on the effect of keeping
                      race/ethnicity as a single identification or separate was conducted during
                      the May 1995 Current Population Survey conducted by the Census Bureau,
                      as well as during the June 1996 Race and Ethnic Targeted Test. Results
                      from the May 1995 survey indicated that, among other things, placing the
                      Hispanic origin question before the race question significantly reduced
                      nonresponse to the Hispanic origin question. The survey also found that
                      placing the Hispanic origin question before a race question that did not
                      include a multiracial option (1) reduced the percentage of persons
                      reporting in the “other race” category on the race question, and
                      (2) increased reporting by Hispanics in the White category of the race
                      question. The results of the June 1996 test are due in May 1997.

Agencies’ Use of      In our 1992 report on agencies’ use of consistent race and ethnic
Consistent Race and   definitions, we found that the eight agencies we reviewed, including the
Ethnic Definitions    Department of Health and Human Services and the Department of
                      Education, used the standard definitions of Directive No. 15 in the data
                      collection operations we examined.2 However, we also found some
                      consistency problems in the agencies’ reporting when they used data not
                      controlled by federal collection rules or data based on

                      The consistent use of definitions by federal agencies is to be accomplished
                      by an OMB control procedure that is designed to help ensure that
                      standards are properly incorporated in data collection efforts. OMB’s
                      Office of Information and Regulatory Affairs is required to approve all
                      federal data collection instruments and methodologies before an agency
                      begins collecting data. This control process is designed to monitor the use
                      of standards in the development of the data collection methodologies. In
                      our 1992 report, we found that another practice that helps ensure that the
                      policy’s definitions are followed is the federal statistical agencies’
                      extensive use of the Census Bureau support and products that also are
                      governed by the rules of Directive No. 15. For example, the National
                      Center for Education Statistics (NCES) and the National Center for Health
                      Statistics (NCHS), as well as other federal agencies, use elements of the

                      Federal Data Collection: Agencies’ Use of Consistent Race and Ethnic Definitions (GAO/GGD-93-25,
                      Dec. 15, 1992).

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                       Decennial Census or the monthly Current Population Surveys in their
                       reports. As a result, the data agencies use from these sources should have
                       been collected using methodologies that OMB has approved.

                       Inconsistent reporting of racial and ethnic data by federal agencies can
                       arise when an agency uses state-provided data. The management of state-
                       or local-generated data is outside of federal jurisdiction. State-provided
                       data can be inconsistent, for example, if states categorize race and
                       ethnicity differently, if state data are incomplete, or if states categorize
                       multiracial/ethnic peoples differently than specified by OMB Directive No.
                       15. Some school districts collecting race and ethnic data also use a special
                       category to classify people of mixed race or ethnicity, thus creating
                       difficulties when data contained in this category are aggregated into the
                       five Directive 15 categories. State use of a multiracial category could
                       become a greater potential source of inconsistency in the future, because
                       the number of multiracial and ethnic families has grown significantly over
                       the last 20 years.

                       Inconsistent reporting of racial and ethnic data can also arise when others
                       determine an individual’s race or ethnicity, generally from observation.
                       OMB’s Directive recommends that the category most closely reflecting the
                       individual’s recognition in his community should be used for purposes of
                       reporting on persons who are of mixed racial and/or ethnic origins.
                       Department of Education officials told us that some states determine a
                       student’s race or ethnicity by that of the mother, whereas others use the
                       father’s race or ethnicity. Because the label applied by state policy may not
                       be the same label applied had OMB’s guidance been used, inconsistencies
                       may arise in the racial categorization of those of mixed race.

                       States collect data on race and ethnicity in various programs, often to
State Collection of    comply with federal requirements. You asked that we provide information
Race and Ethnicity     on the types of race and ethnicity data states are collecting in the areas of
Data for Health and    health and education. You specifically asked us to include information on
                       states that have enacted laws requiring the use of a multiracial category.
Educational Purposes   To respond to your request, we focused on state reporting of race and
                       ethnic data on births and deaths in the health area and on student
                       enrollment in public schools in the education area. At the federal level,
                       NCHS and NCES have responsibility for compiling and reporting data
                       nationally on these topics and work cooperatively with the states to obtain
                       the data. Accordingly, we obtained information from NCHS and NCES on
                       their process for collecting state data as well as from a study recently

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sponsored by NCES on racial and ethnic classifications used by public

In addition, we obtained information on the collection of race and ethnic
data from health departments in nine states—Alabama, Georgia, Illinois,
Indiana, Maryland, New Jersey, Ohio, Texas, and Washington. Of these
nine states, Georgia and Indiana have implemented state laws requiring all
state agencies to use a multiracial category under certain circumstances.
We also contacted education officials in the District of Columbia and in 12
states—California, Georgia, Illinois, Indiana, Maryland, Michigan, North
Carolina, New York, Ohio, Pennsylvania, Texas, and Virginia—as well as
representatives from 23 local school systems in 8 of these jurisdictions. Of
those states, five have laws requiring the use of a multiracial category
under certain circumstances. We contacted local school representatives to
get an indication of the types of racial and ethnic data schools were
collecting and, if the state had implemented a law or requirement for use
of a multiracial category, whether schools were implementing the
requirement. We selected the five states that have laws requiring schools’
use of a multiracial category and North Carolina because it has
administratively mandated the use of a multiracial category in its school
system. We judgmentally selected local school systems to achieve
geographic dispersion. Due to the limited scope of our work, we cannot
project our findings to jurisdictions or school systems we did not contact.

Health department officials in all nine states said they are collecting race
and ethnicity data from birth and death certificates, aggregating these
data, and reporting the data to NCHS, in accordance with guidance and
instructions provided by NCHS. According to these officials, the guidance
and instructions used conform to OMB’s Statistical Directive No. 15.

State education officials in the 12 states and the District of Columbia said
they are collecting race and ethnicity data from schools and aggregating
these data. Most of these officials said that data are reported to the federal
government in the five categories contained in the directive. Officials from
Georgia and Indiana, which are two states that have implemented
legislation requiring the use of a multiracial category, said they are
reporting race and ethnicity data to the federal government in the five
categories contained in the directive. However, in order to report these
data, these officials said that individuals in the multiracial category must
be allocated to the other racial and/or ethnic categories. In contrast, an
Ohio education official said that this state, which has a state law requiring
the use of a multiracial category, uses six categories to report these data,

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                            including a multiracial category. Based on discussions with state and local
                            education officials, the forms used to collect racial and ethnic information,
                            the categories used to classify race and ethnicity, and who classifies
                            students vary from school to school.

Five States Have Laws       Georgia, Illinois, Indiana, Michigan, and Ohio have enacted laws that
Requiring the Use of a      include the term multiracial with respect to collecting data on race and
Multiracial Category        ethnicity. Georgia, Indiana, and Michigan have passed legislation requiring
                            the addition of a multiracial category on all state forms that have a listing
                            of racial and ethnic classifications from which one must select. Illinois and
                            Ohio have similar legislation that applies only to educational departments
                            and schools; however, Illinois’ law specifies that the category of
                            multiracial is to be collected and reported only if the data are for state or
                            local use. Although Illinois’ and Ohio’s laws do not define multiracial, the
                            other three states’ laws define multiracial as having parents of different
                            races. For federal reporting purposes, laws in Georgia and Michigan
                            provide for reallocating multiracial individuals into the five federal
                            categories on the basis of the rate that the general population comprises
                            each classification. Ohio’s law, in contrast, requires that the parent,
                            guardian, or custodian of each student have the opportunity to designate
                            the appropriate federal racial category for the student. Georgia’s,
                            Indiana’s, and Ohio’s laws are being implemented. According to an
                            education official in Illinois, that state is delaying implementation of its
                            law until OMB makes a determination on revising Statistical Directive 15.
                            Michigan’s law, according to state education officials, is to be
                            implemented during the 1997-1998 school year when forms are scheduled
                            to be revised to include a separate question to collect data on whether the
                            individual is also multiracial. A summary of the scope and implementation
                            status of laws in the five states is attached to this statement.

Collection of Race and      We focused our efforts on the collection of race and ethnicity data for
Ethnicity Data for Health   health purposes on data collected in connection with births and deaths.
Purposes                    NCHS is responsible for compiling national statistics on births and deaths.
                            To do this, it is to work cooperatively with state health departments which
                            administer birth registration and death reporting systems under the laws
                            and regulations of the states. Birth certificates are to be used to compile
                            annual vital statistics on the number and rate of births by such
                            characteristics as place of birth and residence of mother. Population
                            composition and growth are to be also estimated using these data, and the
                            data are to be used in planning and evaluating programs in public health

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and other areas. Information from death certificates is to be used for many
purposes, including assessing the general health of the population,
examining medical problems that may be more prevalent among certain
population groups, and identifying geographic areas with elevated death
rates from selected causes of death.

NCHS has developed model birth and death certificates that states can use
in recording vital data on births and deaths. Information on the birth
certificate can be provided by a number of individuals, including the
mother and/or father, a physician or other hospital personnel, or a
midwife. To obtain data on race and ethnicity, the model birth certificate
includes a question on whether the mother is or is not of Hispanic origin,
and the same question on the father as well. NCHS guidance clearly states
that this information is not part of the race item, and that a person of
Hispanic origin may be of any race. Thus, the Race and Hispanic origin
questions are asked independently in the model certificates. A blank space
follows the Hispanic origin question so that the person completing the
form can write in the race of the mother, as well as the race of the father.
Instructions for completing that block direct that the information should
be obtained from the parent or parents, or other informant, and that the
entry reflect the response of the informant. For Asians and Pacific
Islanders, the national origin of the mother and father, such as Chinese,
Japanese, Korean, Filipino, or Hawaiian, is to be entered. If the informant
indicates that the mother and/or father is of “mixed race,” both races or
ancestries are to be entered.

Birth certificates do not record the race of the child. Beginning in 1989,
NCHS guidance recommends that health officials categorize births by the
race of the mother, as recorded on the birth certificate. If the mother does
not state her race on the certificate, then the baby’s race is imputed to be
the race of the father. Prior to 1989, newborns with two parents of the
same race were classified as that race; newborns with one nonwhite
parent were classified as the race of the nonwhite parent. When both
parents were nonwhite but of different races, the newborn was assigned
the father’s race; except that if either parent was Hawaiian, the newborn
was classified as Hawaiian.3

With regard to death certificates, funeral directors are responsible for
getting the death certificate completed. Information is to be obtained from

 This change in policy was brought about because it brought a more uniform approach to tabulating
the increased incidence of interracial births and nonmarital births than did the necessarily arbitrary
combination of parental races. In addition, the model birth certificate was modified in 1989 to include
more questions directly associated with the mother’s health and health behaviors.

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the spouse, one of the parents, children, or another relative of the
decedent, or a physician. In contrast to the birth certificate, which requires
data on whether the mother or father is of Hispanic origin and the race of
the mother or father, the death certificate requires this information on the

According to officials in nine state health departments, these states follow
NCHS’ model and guidance when obtaining this information. Birth and/or
death certificates provided us by seven of these states confirmed that their
forms provide a space in which any race or racial makeup can be
provided. For reporting purposes, NCHS has developed a coding system
and guidance for categorizing and reporting race and ethnicity responses.
This guidance includes 7 codes for Hispanic origin, as well as up to 16
codes for race. The race category includes White, Black, Indian, five
categories for Asian or Pacific Islander, Other Entries, and Not Reported.
According to NCHS officials, an additional 6 coding categories for other
Asian or Pacific Islanders, for a total of 11, were being used by California,
Hawaii, Illinois, New Jersey, New York State, New York City, Minnesota,
Texas, and Washington. NCHS provides the option to other states on
whether to use the more detailed categories for Asian or Pacific Islanders.
If an individual were to record his or her race as more than one race on
the certificate, NCHS’ guidelines provide that the first race listed should be
used for coding purposes, or if the individual reports percentages, the race
having the highest percentage should be coded. Thus, even though an
individual can indicate a makeup of various races, for purposes of
aggregating the data, the individual is coded as belonging to one race by
health officials.

Of the nine states whose health departments we contacted, Georgia and
Indiana have laws requiring the use of a multiracial category when
collecting race and ethnicity data. According to a Georgia Department of
Public Health official, birth and death certificates were not modified to
accommodate the law because the law requires that forms be modified
only if they contain a list of categories from which one must select, and
Georgia’s birth and death certificates do not contain such a list. This
health department official said that when an individual indicates that he or
she is multiracial, the state obtains data on which races the individual
belongs to and then follows NCHS’ protocol for coding racial data. For
example, if Black is the first race mentioned, the person is coded as Black.
If White is the first race mentioned, the person is coded as White. This
official said that if some other race is mentioned first, the person is coded
as an “other” race because all of the other races are very small in the state.

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According to this official, the Department has also included a field in its
database to indicate if the individual considers himself or herself
multiracial. These data are separate and not reported to NCHS. This
official said that Georgia started collecting the multiracial data about 1 or
2 years ago, but that it has not used the multiracial data to perform any
special statistical analyses. Furthermore, he said that the number of
individuals classified as multiracial is small, and that the data would not
likely be used for analytical purposes because a racial designation is
generally not a good indicator of health problems. Likewise, Indiana’s law,
passed in 1995, requires the addition of a multiracial category on forms
that contain a listing of racial categories. An Indiana health official said
that the state has not changed its forms, practices, or procedures for
collecting racial or ethnic data on birth or death certificates. This state
uses birth and death certificates that do not contain a listing of categories.
According to this official, the health department has not added a separate
multiracial category in the state’s database so that the number of
multiracial persons could be tabulated by computer.

None of the officials in the seven state health departments we contacted
that do not require the category of multiracial indicated the need for one
or were sure of how it would be used if collected. For example, according
to an Illinois Department of Public Health official, the multiracial
classification would not be useful with respect to conducting vital
statistical or health analyses. According to this official, if additional data
were to be collected for vital statistical health analyses, these data should
include socioeconomic data. Similarly, an Alabama Department of Public
Health official stated that, currently, the state does not need a multiracial
category because, in her view, the state has a relatively few number of
individuals who could be classified as such. Therefore, she said that
NCHS’ classifications were currently sufficient for determining different
racial and ethnic groups’ lifestyles that affect health.

The Department of Health and Human Services’ National Committee on
Vital and Health Statistics, Subcommittee On Health Statistics for Minority
and Other Special Populations, has reviewed state legislation requiring the
use of a multiracial category. According to a subcommittee member, of
some concern to the subcommittee is the fact that some state laws call for
reallocating the number of multiracial people to OMB’s five categories for
federal statistics on the basis of the racial and ethnic distribution of the
general population. She also said that reallocating multiracial people on
this basis would tend to misrepresent the number of individuals in each of

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                         Statistical Agencies: Collection and
                         Reporting of Race and Ethnicity Data

                         the five categories because the multiracial population does not have the
                         composition of the racial and ethnic distribution of the general population.

Collection of Race and   NCES is the primary federal organization for collecting, analyzing, and
Ethnicity Data for       reporting data related to education. NCES collects data through a variety
Educational Purposes     of means, including periodic surveys and data reported by states from data
                         contained in administrative records, including school enrollment records.
                         In 1994, NCES updated its 1974 national standards for student data to
                         establish current and consistent terms, definitions, and classification
                         codes to maintain, collect, report, and exchange comparable information
                         about students.4 Its 1994 handbook, intended as a reference document,
                         includes the types of information that could be collected about individual
                         students and maintained in records, and discusses race/ethnicity
                         classifications and definitions. The racial and ethnic classifications and
                         definitions are those contained in OMB’s Statistical Directive No.
                         15—American Indian or Alaskan Native, Asian or Pacific Islander, Black,
                         Hispanic, and White. The handbook recommends that Blacks and Whites
                         be separate from Hispanic. That is, students should be classified as
                         Hispanic, Black (not Hispanic) or White (Not Hispanic).

                         In the spring of 1995, NCES sponsored a survey as part of the research
                         being conducted by OMB to review the current categories in its Statistical
                         Directive. NCES’ March 1996 report summarized its findings with regard to
                         racial and ethnic classifications used by public schools.5 In summary,
                         73 percent of 926 public schools responded that they used only the five
                         standard federal categories to classify the race and ethnicity of students.
                         Of the remaining 27 percent of the schools, 10 percent responded that they
                         used “other” or “undesignated,” with space for indicating a specific race or
                         ethnicity; 5 percent used “other,” without space for specification; 7 percent
                         used additional racial and ethnic categories, such as “Filipino”; 5 percent
                         used a general multiracial category; and the remaining 2 percent used
                         specific combinations of the five standard federal categories or used an
                         “unknown” category (such as “Black/White,” or an “unknown” category).6
                         Additional differences were found in how racial and ethnic data were

                          National Center for Education Statistics: Student Data Handbook for Early Childhood, Elementary,
                         and Secondary Education, U.S. Department of Education, Office of Educational Research and
                         Improvement (NCES-94-303, June 1994).
                         National Center for Education Statistics: Racial and Ethnic Classifications Used by Public Schools,
                         U.S. Department of Education, Office of Educational Research and Improvement (NCES 96-092,
                         March 1996).
                          Percentages do not sum to 100 because respondents could select any and all categories that applied to
                         their schools.

                         Page 13                                                                           GAO/T-GGD-97-92
Statistical Agencies: Collection and
Reporting of Race and Ethnicity Data

aggregated into the five federal categories before reporting the data to the
federal government, as well as differences in who identified the race and
ethnicity of the children. For example, about half of the 27 percent of
schools that used other classifications reported that the central district
office handled the task of aggregating this information, while many of the
remaining schools reported that students were allocated by the school
among the five standard federal categories based on which ones the
school considered most appropriate. With respect to who identified a
student’s race or ethnicity, 73 percent of the schools reported that they
asked parents. At 22 percent of the remaining schools, respondents
reported that teachers or administrators assigned students to categories
based on observation; while the remaining 5 percent reporting using some
other method. Most respondents reported that revisions to Directive No.
15 were not an issue or were only a minor issue in terms of their
applicability to students enrolled in their schools. However, between 3 and
12 percent of schools reported that issues such as adding a general
“multiracial” category, adding an “other” category, or changing the
terminology used in the racial categories was significant.

The 5 states that have already enacted laws requiring schools to add a
multiracial category were included in the 12 states and the District of
Columbia whose education departments we contacted. Of these five
states, three—Ohio, Georgia, and Indiana—said they have implemented
requirements that the multiracial option be included as a category when
selecting options for race and ethnicity. All of the eight local school
systems we contacted in these three states (three in Ohio, three in
Georgia, and two in Indiana) said they were using a multiracial category
for school enrollment. According to education department officials in Ohio
and Georgia, the legislation was the result of the efforts of a small group of
individuals in each of their respective states.

According to an Indiana Department of Education official, the schools in
Indiana are implementing the requirement in a variety of ways. For
example, in some instances school administrators may classify students
into different race and ethnic categories, while in other schools or school
systems, parents may classify their children. We contacted two schools in
Indiana and found that schools in that state were inconsistent in who
classified students into race and ethnic categories. The Indiana
Department of Education official said that when reporting data to the
federal government, the state Department of Education allocates those
students who are classified as multiracial into the Black, White, American
Indian or Alaskan Native, or Asian or Pacific Islander category on the basis

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Statistical Agencies: Collection and
Reporting of Race and Ethnicity Data

of the percentage of these races in the state as a whole. The remaining two
states—Michigan and Illinois—have yet to implement their legislation.
According to Michigan Department of Education officials, Michigan was
allowed to use up its stock of forms prior to collecting the new data.
Currently, forms for collecting racial and ethnic data are being revised for
the 1997-98 school year. According to an Illinois State Board of Education
official, Illinois is not implementing its legislation until OMB reaches a
final decision on whether, and if so, how, Statistical Directive 15 is to be

A few states, such as North Carolina and Florida, have administratively
decided to collect multiracial data. According to a North Carolina
Department of Public Instruction official, the administrative order has
been in effect for the past 1 to 2 years and gives parents who wish to
classify their child as multiracial the option of doing so. School
registration forms we obtained from three North Carolina school systems
listed a multiracial category. Two North Carolina local school systems
provided space on their registration forms for race or ethnicity to be
written in; however, one of these local system’s guidance instructed school
administrators to code this information as Black, White, Hispanic,
American Indian, Asian, or Other. A North Carolina education official said
that currently, fewer than 200 of the 1.2 million students in that state’s
schools were estimated to be using the multiracial classification. This
official stated that schools within North Carolina could be using different
methods to classify these students as another race when aggregating race
and ethnic data for federal reporting purposes.

Several other states are considering including a multiracial category for
educational reporting purposes. For example, a California Department of
Education official said that a ballot measure is currently being considered
that would mandate the use of a multiracial category when collecting data
on students’ race and ethnicity. He said that the state uses OMB Statistical
Directive 15 to obtain data from the schools on race and ethnicity. The
state also collects data on individuals of Philippine origin due to a state
mandate. This official said that the state would need to resolve several
issues before adopting a multiracial category. These issues include the
cost of requiring that data be collected and the usefulness of the data to
the Department. For example, this official was not certain what utility the
multiracial category provided educators, or what educators could do with
these data if they had them.

Page 15                                                      GAO/T-GGD-97-92
Statistical Agencies: Collection and
Reporting of Race and Ethnicity Data

A Texas Education Agency official said that Texas is currently considering
a proposed bill that would include a multiracial category. Currently, the
state is looking at the practical implications of implementing the proposed
legislation. That is, the state is assessing the potential cost of requiring
these data be collected and ways that the new data could be linked to data
previously collected. According to this official, even though the state uses
OMB’s Statistical Directive No. 15 for federal reporting purposes, some
schools in the state collect additional data and break out the racial or
ethnic classifications in more detail than required.

The varying situations in the Washington D.C. metropolitan area with
regard to identifying race and ethnicity at the time of school enrollment
provide a good illustration of the complexity and controversial nature of
this issue. The school registration form used in the District of Columbia
provides a space for the parent or guardian of the child to write in a race
or ethnicity. Categories are not prelisted on the form. The school system,
however, tabulates data based on the five federal categories.

Virginia’s Department of Education has provided guidance to the state’s
school systems directing them to use the five categories specified in
Statistical Directive No. 15 when reporting data to the department, and
informing them that it can only accept data in these five categories.
However, an education department official said that schools can collect
any detailed data they want on students’ race and ethnicity. The city of
Alexandria uses OMB’s five categories for collecting data on school
enrollment, and school system representatives told us that the lack of a
multiracial category has not been a major issue. In contrast, Fairfax
County has added a multiracial category to its school registration form.
According to a school system representative, this category was added in
1994 as a result of concerns expressed by a number of county residents.
The school system allocates multiracial students to the other five
categories when aggregating data and reporting it to others. Arlington
County schools also use the five categories in OMB’s directive. However,
in 1993, the county added an “other” category out of concern that a
significant number of students did not fit into the five categories and so a
student or parent could use a classification other than those listed on the
school forms. However, Arlington County, after receiving a notice from the
state that it would not accept data reported in any categories other than
the five specified by OMB, discontinued using the “other” category in 1996.

Montgomery County, Maryland, schools prelist the five categories on its
school enrollment forms. An official of the Montgomery County schools

Page 16                                                      GAO/T-GGD-97-92
Statistical Agencies: Collection and
Reporting of Race and Ethnicity Data

said that some parents have expressed concern about there being only five
categories. The official said that the school board discussed the issue, but
has decided to wait to see what changes, if any, the federal government
makes. According to the official we spoke with, the issue is very much a
concern in Montgomery County schools because the county is home to
many multiracial families. In Prince George’s County, a school official told
us that the school system uses only the five standard categories but has
been approached about the issue of more categories on some occasions.
However, the school system is also under a federal court desegregation
order. The order requires the school system to report race and ethnic data
in a certain format to the court annually.

California provides another example of the diverse way in which racial
and ethnic data can be collected. California state education officials said
that even though the state reports racial and ethnic data to the federal
government in accordance with OMB’s guidance, schools in that state are
asked to break out race and ethnicity data into seven categories. These
categories include OMB’s classifications of White, Black, Hispanic,
American Indian or Alaskan Native, but the classification for Asian is
separated from Pacific Islander. As noted earlier, the state also separates
information on those of Philippine ancestry. However, these officials said
that schools may collect more detailed data to determine the
representation in their school districts. According to one state official, the
state does not dictate or control the amount or type of information schools
collect because such matters are believed best left to local control. San
Diego, for example, lists 19 racial and ethnic categories plus a multiracial
category on its school registration form. The instructions on the form state
that one of the 19 listed categories is to be selected, but that a person can
also select the multiracial category. If this latter category is chosen,
additional categories are to be written on the form. San Francisco’s city
schools use nine categories and do not use a multiracial category. Long
Beach collects only the seven state required categories of racial and ethnic
information, but also collects over 50 different language categories on
each student. Because the state may receive additional categories of racial
and ethnic data from some schools, the state, at times, has to aggregate the
data to conform to OMB’s five classifications. A state education official
said that this has not caused the state any problems.

Mr. Chairman, this concludes my prepared statement. I would be pleased
to respond to questions from you or other Members of the Subcommittee.

Page 17                                                       GAO/T-GGD-97-92
Appendix I

Examples of Federal Laws Requiring the
Collection of Data on Race and Ethnicity

Agency or program requiring race and
ethnic data                                 Description of data requirement                Legal authority
Federal Home Loan Mortgage Corporation      The corporation is required to collect data    12 U.S.C. § 1456(e)(1)(A)
                                            relating to its mortgages on housing
                                            consisting of 1 to 4 dwelling units. These
                                            data shall include the income, census tract
                                            location, race, and gender of mortgagors.
Government National Mortgage Association    The corporations shall collect data relating   12 U.S.C. § 1723a.(m)(1)(A)
and Federal National Mortgage Association   to their mortgages on housing consisting of
                                            one to four dwelling units. These data shall
                                            include the income, census tract location,
                                            race, and gender of mortgagors.
Community Development Financial             The Fund shall require each community          12 U.S.C. § 4714(b)
Institutions Fund                           development financial institution or other
                                            organization receiving Fund assistance to
                                            compile such data, as is determined to be
                                            appropriate by the Fund, on the gender,
                                            race, ethnicity, national origin, or other
                                            pertinent information concerning individuals
                                            that utilize the services of the assisted
Department of Education, Office of          All statistics and other data collected and    20 U.S.C. § 6011(j)(4)
Educational Research and Improvement        reported by the Office shall be collected,
                                            cross-tabulated, analyzed, and reported by
                                            sex within race or ethnicity and economic
                                            status whenever feasible.
Department of Education                     Shall carry out an ongoing evaluation of      20 U.S.C. § 6491(c)(1)(e)
                                            programs designed to help disadvantaged
                                            children meet high standards. The
                                            evaluation shall, when feasible, collect,
                                            cross-tabulate, and report data by sex within
                                            race or ethnicity and socioeconomic status.
Department of Education, Office of          Shall collect and report data for the National 20 U.S.C. § 9010(b)(1)(C)
Educational Research and Improvement        Assessment of Educational Progress. The
                                            data shall include information on special
                                            groups, including, whenever feasible,
                                            information collected, cross-tabulated,
                                            analyzed, and reported by sex, race or
                                            ethnicity, and socio-economic status.
Department of Labor, Rehabilitation         Requires an annual report on vocational        29 U.S.C. § 712
Services Administration                     rehabilitation and other rehabilitation
                                            services from information collected on each
                                            client. The information shall set forth a
                                            complete count of such cases in a manner
                                            permitting the greatest possible
                                            cross-classification of data. The data
                                            elements shall include, but not be limited to,
                                            age, sex, race, ethnicity, etc.

                                            Page 18                                                                    GAO/T-GGD-97-92
                                               Appendix I
                                               Examples of Federal Laws Requiring the
                                               Collection of Data on Race and Ethnicity

Agency or program requiring race and
ethnic data                                    Description of data requirement                 Legal authority
Veterans Administration, Center for Minority   Requires social and demographic research 38 U.S.C. § 317(d)(5)
Veterans                                       on the needs of veterans who are minorities
                                               and the extent to which veterans’ programs
                                               meet the needs of minority veterans, without
                                               regard to any law concerning the collection
                                               of information from the public.
Department of Commerce                         Requires a survey to compile registration     42 U.S.C. § 2000f.
                                               and voting statistics. The survey and
                                               compilation shall only include a count of
                                               persons of voting age by race, color, and
                                               national origin. The law also has a proviso
                                               that no person shall be compelled to
                                               disclose his race, color, or national origin
                                               and that every person interrogated orally, by
                                               written survey or questionnaire, or by any
                                               other means shall be fully advised about his
                                               right to refuse to furnish such information.
Department of Housing and Urban                Requires studies with respect to the nature      42 U.S.C. § 3608(e)
Development                                    and extent of discriminatory housing
                                               practices and requires information on the
                                               race, color, religion, sex, national origin,
                                               age, handicap, and family characteristics of
                                               persons and households who are applicants
                                               for, participants in, or potential beneficiaries
                                               of, programs administered by the
                                               Department of Housing and Urban
                                               Development. The Department shall collect
                                               the information relating to those
                                               characteristics the Department determines
                                               necessary and appropriate without regard to
                                               any other provision of law.

                                               Source: GAO analysis of selected legislation.

                                               Page 19                                                                GAO/T-GGD-97-92
Appendix II

States With Laws Requiring a Multiracial

                                  Law              As of April 1997 is law
               State              enacted          being implemented?        Agencies covered
               Georgia            1994             Yes                       All state agencies
               Illinois           1994             No                        Schools
               Indiana            1995             Yes                       All state agencies
               Michigan           1995             No                        All state agencies
               Ohio               1992             Yes                       Schools
               Source: State laws and state officials.

(410133)       Page 20                                                                 GAO/T-GGD-97-92
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