Report Overview

In March 2024, the federal government announced a critical step forward in improving data collections related to race and ethnicity across all federal agencies. Two key pillars of the announced revision of the Office of Management and Budget’s (OMB) Statistical Policy Directive 15, or SPD 15, are a) making changes to the minimum reporting categories that add Middle Eastern and North African and Hispanic/Latino to a combined category of race and ethnicity; and b) making detailed reporting categories, such as Vietnamese, Samoan, Haitian, and Cherokee, the default expectation for all federal agency data collections.

This policy brief focuses on timely and successful implementation of the second dimension of detailed reporting categories, which we refer to as the “data disaggregation pillar.” OMB’s update to SPD 15, and the associated Final Recommendations Report of the Federal Interagency Technical Working Group on Race and Ethnicity Standards, leave three important gaps in preparation for successful implementation that need to be remedied as soon as possible, which include:

  • No existing inventory or baseline database of all federal agency data collections and the extent to which they provide disaggregated data;
  • No named body that monitors, evaluates, and provides technical assistance across agencies to move towards full compliance on data disaggregation; and
  • No formal and regular mechanism for community input and expertise, including from industry and scientific researchers who work on matters of data equity.

First, the Chief Statistician of the United States must publish a data disaggregation inventory of all current federal agency data collections by September 2024, with an indication of whether, and to what extent, detailed ethnicity data are provided in the collection and publication of statistical data tables and individual-level microdata. In order for federal agencies to successfully produce Agency Action Plans for SPD 15 implementation within the announced 18-month period (i.e. by September 2025), a baseline inventory that will inform the second pillar of SPD 15 must be published no later than September 2024.

In addition, by June 2024 the Chief Statistician must clearly designate a centralized, coordinated body within the Office of Statistical Programs & Standards that will monitor, evaluate, and provide technical assistance across agencies to move towards full compliance on data disaggregation over the next five years. At present, the information provided in the March 2024 update to SPD 15 specifies particular roles for the Office of Information and Regulatory Affairs (OIRA) with respect to approving exemption requests on data disaggregation, and the Interagency Committee on Race and Ethnicity Standards to conduct research as needed to inform future changes to SPD 15. In order to ensure timely, effective, and coordinated progress across all federal agencies on the data disaggregation pillar, OMB needs to name and provide staffing, resources, and authority to an entity that can provide this coordinated implementation function, with the ability to provide annual reports on progress to Congress and the general public.

Key performance indicators on implementation should track: 1) the scale, scope, and timeliness of progress to 100% compliance on data disaggregation at the level of federal agency and at the level of the data collection; 2) the ability of community organizations to have a formal and regular role in informing implementation; 3) the transparency of activities and deliverables pertaining to SPD 15 implementation; and 4) the accessibility of data in formats that provide meaningful insights to audiences of varying abilities and needs for language assistance.

Finally, the Chief Statistician must convene the Interagency Committee on Race and Ethnicity Standards by June 2024 and begin receiving input on the collection of detailed categories by September 2024 from experts in community organizations and scientific research institutions. Important items for successful implementation of the data disaggregation pillar include: 1) providing options for more checkboxes in digital forms under each minimum category, 2) including detailed checkboxes under multiple categories — such as Dominican appearing under both Black and Hispanic or Latino — 3) specifying strict criteria that agencies must meet in order to receive an exemption from OIRA to opt out of the requirement to collect detailed racial data, and 4) creating key performance indicators and guidance for monitoring and evaluation of successful implementation – not only at the level of federal agency, but also at the level of each data collection (such as the American Housing Survey and the National Health Interview Survey).

Importantly, the federal government needs to provide the funding necessary to implement, track, and evaluate progress towards full compliance over the next five-year period, and in line with the good data governance principles outlined in this report.