March 16, 2001
Katherine K. Wallman
Chief Statistician
Office of Management and Budget
Room 10201
New Executive Building
725 17 th Street, N.W.
Washington, DC 20503
RE: Provisional Guidance on the Implementation of the 1997 Standards for Federal Data on Race and Ethnicity
Dear Dr. Wallman:
On behalf of the Asian & Pacific Islander American Health Forum, we are writing to provide comments and recommendations in response to the “Provisional Guidance on the Implementation of the 1997 Standards For Federal Data on Race and Ethnicity,” issued on December 15, 2000. We commend the Office of Management and Budget (OMB) for soliciting public comments on this Provisional Guidance so that it will be responsive to the needs of communities. In this spirit, we request that you consider and implement the following comments and recommendations.
The Asian & Pacific Islander American Health Forum (the Health Forum) is a national organization dedicated to promoting policy, program and research to improve the health status of all Asian Americans and Pacific Islanders (AAPI). Since 1992, the Health Forum has been designated by the Census Bureau as a national census information center (CIC) for Asian Americans and Pacific Islanders (AAPI). This program, the Asian & Pacific Islander Center for Census Information and Services (ACCIS), serves the census data needs of organizations concerned with identifying, defining, and serving the AAPI communities throughout the United States.
Data is the driving force for almost all federal programs and services. Without specific, timely and accurate data about Asian American and Pacific Islander communities’ needs and challenges, federal programs and services may not be inclusive of or responsive to this population. The absence or inadequacy of available data often excludes Asian American and Pacific Islanders from participation in federal programs and services. Many federal agencies either do not collect the necessary data or collect incomplete data on the race or ethnicity of their consumers and users. Therefore, these agencies are unable to provide meaningful information on the needs and utilization of their programs and services by Asian Americans and Pacific Islanders (President’s Advisory Commission on Asian Americans and Pacific Islanders’ Interim Report to the President and the Nation, January 2001, pg. 31).
Disaggregation of Data by Subgroup
The Health Forum strongly supports OMB’s expectations for agencies to “provide as much detail as possible on the multiple race responses.” We encourage the collection, tabulation, and reporting of data on Asian American, Native Hawaiians and Pacific Islanders (AA/NHOPI) subgroups whenever possible. As you know, AA/NHOPIs are a very heterogeneous population, with a spectrum of socio-economic statuses, languages, and cultures. Data that is not disaggregated by subgroup masks the health needs of vulnerable populations and is unable to provide useful information for addressing these needs. We urge that OMB’s expectations be elevated to stronger language in the Provisional Guidance. For example, OMB could require such additional disaggregation by AA/NHOPI subgroups in geographic areas or data sets where the AA/NHOPI populations are significant, e.g. at a minimum, in the ten states where AA/NHOPIs are most populous and constitute 80% of the national total.
Thresholds for Suppression of Cells and Access to Data
Given our relatively small population sizes AA/NHOPIs are particularly vulnerable to the loss of valuable information due to suppression of data cells. The Health Forum is concerned that arbitrarily high thresholds for minimum cell size will further exacerbate problems of lack of data and deny communities adequate information for addressing important health and other service needs. OMB’s guidance indicates that agencies do not use a common set of standards for evaluating confidentiality and quality issues. We urge OMB to develop uniform national standards that would allow the provision of as much data as possible to communities, while protecting confidentiality. Thresholds for these standards should be sufficiently low (statistically, expected cell sizes of less than five do not have validity), while providing full access of suppressed data to researchers and others with the standard assurances of confidentiality. For example, confidentiality may be maintained through the deletion of unique identifiers such as age and sex. Researchers may also be able to tabulate the data in alternative categories to increase cell sizes and preserve confidentiality.
One example of the need for cell size standards is the use of arbitrarily high population thresholds in data products to be released by the Census Bureau (see OMB Guidance, pg. 38). In producing the public-use microdata files (PUMS), the Census Bureau plans to use a minimum population threshold of 100,000. In the Summary File 2 and Quick Tables, population thresholds of 100 have been proposed, while in other products, thresholds have not yet been determined. As you are aware, when communities that make up a small percentage of a total population are stratified by geography, age, gender and other characteristics, cell sizes can become exceedingly small. Yet information about these particularly vulnerable populations remains critical for service providers in meeting the community’s needs. Providing useful information for Native Hawaiians and Other Pacific Islanders (whose total population is expected to be under 400,000) is a clear example of the barriers posed by unnecessarily high thresholds. In an effort to recognize the needs of these smaller populations, the Health Forum recommends that OMB develop a common set of standards for evaluating confidentiality and quality issues as outlined above.
In the case of cells that must be suppressed, we recommend that categories be retained but that data be replaced with a notation instead of collapsing the cells. We would further recommend the use of notation adopted by the Department of Health and Human Services’ Healthy People 2010 which provides a reason when data is not available (DHHS Healthy People 2010, Reader’s Guide, pg. 5).
- DNA = Data have not been analyzed
- DNC = Data are not collected
- DSU = Data are statistically unreliable.
- NA = Not applicable.
Ensuring Implementation of 1997 Standards
Currently only six federal departments and six federal agencies of the 32 have implemented the 1997 OMB Standards in their national data collection and reporting (President’s Advisory Commission on Asian Americans and Pacific Islanders’ Interim Report to the President and the Nation, January 2001, pg. 100). Some agencies still do not collect any data at all about AA/NHOPIs or only report such data in an “other” category, and few agencies disaggregate “Asian” from “Native Hawaiian and Other Pacific Islander.” We recommend that OMB take a proactive role in reviewing each agencies progress in implementing the 1997 Standards, especially as it may have the opportunity to provide education and training on this Provisional Guidance.
Again, we appreciate this opportunity to comment on the Provisional Guidance and acknowledge OMB’s leadership in the development of these important standards.
Sincerely,
Tessie Guillermo
Executive Director
