Friday, July 12, 2024: U.S. Census Bureau Requested Public Comments on ACS Timeline for Implementing Updated Directive on Race & Ethnicity Data Standards
The U.S. Census Bureau published a Notice in the Federal Register seeking public comment on its proposed timeline to implement the Office of Management and Budget’s (“OMB”) updated Statistical Policy Directive No. 15 (“SPD 15”) for Federal race and ethnicity data on the American Community Survey (“ACS”). The Census Bureau will consider the feedback it gathers in response to this Notice as it continues to evaluate the practicability of implementing the updated race and ethnicity data standards into either the 2026 ACS or the 2027 ACS. In the Notice, the Bureau recognized that implementing the updated SPD 15 in the ACS as quickly as possible is essential, and indicates that based on their initial assessment, implementation in ACS data collection will be targeted for 2027, with dissemination of data products to then begin in 2028.
Comments are due by August 12, 2024, and may be submitted here or here.
How We Got Here
On March 28, 2024, the White House Office of Management and Budget (“OMB”) released its finalized revisions to its SPD 15 (“2024 SPD 15”). That Directive contains common definitions to allow the federal government to compare race and what OMB calls “ethnicity” data across federal agencies. Federal contractors use SPD 15 primarily to identify the races and national origins of applicants and employees for use in Affirmative Action Plans and discrimination analyses. The finalized revisions updated the previous 1997 version of SPD 15 (“1997 SPD 15”).
OMB directed the applicable federal agencies to implement program changes as soon as possible but no later than March 28, 2029. (Our story here details those changes).
Proposed Timeline Details
Apart and independently from a 2027 ACS implementation of the 2024 SPD 15, the Census Bureau is also considering using bridging techniques, or crosswalking, to produce a limited set of experimental data products earlier than the schedule outlined below. If deemed feasible, these early experimental data products would likely be a subset of tables from the 5-year data products that would reflect data from 2022-2026, crosswalked with the updated race and ethnicity data standards.
The Census Bureau has conducted an assessment of what would be necessary to implement the 2024 SPD 15 in the ACS in either: a) the 2026 ACS with dissemination of data products to then begin in 2027, or b) the 2027 ACS with dissemination of data products to then begin in 2028. This assessment considered multiple factors such as:
- The amount of additional time needed for ACS activities to ensure accurate implementation. The most challenging tasks include revising and testing procedures for processing data and developing updated data products.
- Necessary scope and schedule changes for competing ongoing high-priority projects. The Census Bureau has a number of critical data modernization projects underway that are expected to use many of the same resources needed for implementation of the 2024 SPD 15 in the ACS.
- The need and timing for additional expert resources. Implementing the 2024 SPD 15 in the ACS requires the availability of dedicated resources with subject matter expertise.
- When and how to obtain external stakeholder feedback on Census Bureau implementation plans. Transparent engagement with stakeholders is highly valued and will inform deliberations.
Implementing the 2024 SPD 15 as quickly as possible must be balanced against the risks of major errors, the Bureau noted. Information gathered through the requested public comments will allow the Census Bureau to update this assessment to include additional costs, risks, and benefits faced by non-Federal users of ACS data.
Timeline for 1-Year and 5-Year Data
The Bureau’s plan to implement the updated standards in 2027 would mean that the first ACS 1-year estimates under the updated standards would be released in September 2028 for the 2027 ACS 1-year data. The first 5-year estimates produced solely using the data collected under the 2024 SPD 15 would be available in the 2027-2031 ACS 5-year data, scheduled for release in December 2032. Should a determination be made to instead implement the updated standards in 2026, these release dates would be moved up by one year. For example, the first ACS 1-year data using the updated standards would be released in September 2027, and the first ACS 5-year estimates would be released for the 2026-2030 ACS data in December 2031. Note that this alternative schedule would align the 5-year ACS estimates with the 2030 Decennial Census data.
Crosswalking Plan
Once the ACS program begins collecting data using the updated race and ethnicity data standards, the data produced in the 5-year estimates will be crosswalked to the updated race and ethnicity groups until there are five years of data collected in the updated format. For example, the 2023-2027 ACS 5-year estimates would contain data collected in years 2023 through 2026 using the 1997 SPD 15 and data collected in 2027 using the 2024 SPD 15. In those 2023-2027 ACS 5-year estimates, data collected in 2023 through 2026 would be crosswalked to the updated race and ethnicity categories, and data products would comply with the 2024 SPD 15. Crosswalking procedures would be required for all data collected under the 1997 SPD 15 for each 5-year file produced until there are a full 5 years of data available that have been collected under the 2024 SPD 15, as follows:
- 2023-2027 5-Year Estimates: Crosswalking required for years 2023, 2024, 2025, 2026
- 2024-2028 5-Year Estimates: Crosswalking required for years 2024, 2025, 2026
- 2025-2029 5-Year Estimates: Crosswalking required for years 2025, 2026
- 2026-2030 5-Year Estimates: Crosswalking required for years 2026
- 2027-2031 5-Year Estimates: No crosswalking required
This proposed data release schedule will impact all data products that are cross-tabulated by race and ethnicity.