OMB Guidance on the Implementation of its
1997 Standards for Federal Data on Race and Ethnicity
New Guidance Released
The Office of Management and Budget (OMB) released its “Provisional Guidance on the Implementation of the 1997 Standards for Federal Data on Race and Ethnicity” for public comment on December 15, 2000. The provisional guidance applies to all federal government agencies that maintain, collect, or present data on race and ethnicity for statistical purposes, program administrative reporting, or civil rights compliance reporting. The proposed methodologies have a significant impact on the ability of Asian American and Pacific Islander communities to obtain and utilize information to improve health and well-being.
In 1997, the OMB released standards for race and ethnicity data collection, maintenance, and presentation for all federal agencies. The 1997 standards contained two significant changes: 1) it required the use of a minimum of five race categories (Asian, Native Hawaiian and Other Pacific Islander, American Indian/Alaska Native, Black/African American, and White), and two ethnicity categories (Hispanic/Latino, and Not Hispanic/Latino) and 2) it also required agencies to allow individuals to choose more than one racial category to reflect multiple racial heritages. The Provisional Guidance sets standards for how agencies will tabulate and present data collected under the 1997 standards, and in particular, data on individuals who indicate more than one racial category.
APIAHF Provides Recommendations to OMB
The Asian and Pacific Islander American Health Forum (APIAHF) analyzed the proposed guidance for its potential impact on Asian American, Native Hawaiian and Pacific Islander (AA/NHOPI) communities and provided three primary recommendations for improvement.
1. Disaggregate data by subgroup.
APIAHF encourages the collection, tabulation, and reporting of data on AA/NHOPI subgroups whenever possible. Asian Americans, Native Hawaiians and Pacific Islanders (AA/NHOPI) 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 about further disaggregation 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.
2. Develop standards on thresholds for suppression of cells and access to data.
OMB’s guidance indicates that agencies do not use a common set of standards for evaluating confidentiality and quality issues, leading to varying thresholds for suppression of data cells depending on the particular agency. Given relatively small population sizes, AA/NHOPIs are particularly vulnerable to the loss of valuable information due to the suppression of data cells. APIAHF is concerned that arbitrarily high thresholds for minimum cell size will further exacerbate these difficulties and deny communities adequate information for addressing important health and other service needs. 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.
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 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, p. 5).
DNA = Data have not been analyzed
DNC = Data are not collected
DSU = Data are statistically unreliable.
NA = Not applicable.
3. Ensure implementation of 1997 OMB Standards
Currently only six federal departments and six federal agencies out of thirty-two 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, p. 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 active role in reviewing each agency’s progress in implementing the 1997 Standards, especially as it may have the opportunity to provide education and training on its Provisional Guidance.
For More Information
The Provisional Guidance on the Implementation of the 1997 Standards for Federal Data on Race and Ethnicity is available at http://www.whiteh o use.gov / omb/inforeg/i ndex.html – click on “Statistical Policy” at the top, then scroll down to “Data on Race and Ethnicity.” To view the 1997 Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity, click on “Appendix A”. Please contact APIAHF Policy Analyst, Jan Liu at jliu@apiahf.org or 415-954-9952 for more information about APIAHF’s comments to OMB.
