Number range CHAPTER

**U.S. Census Bureau Responses to the**

**Recommendations of the**

**Census Advisory Committee of Professional Associations**

**Made as a Result of the Meeting on May 18-19, 2006**

**[Recommendation 1]{.underline}**

**2010 Decennial Census Program**

**[Population Association of America Advisory Committee]{.underline}**

**2010 Census Communications Program**

"The Population Association of America Advisory Committee (PAA/AC)
submits the following:

A. The PAA/AC applauds the Census Bureau's commitment to basing the
Census 2010 communication program on research that would permit
targeting groups for which communications can result in the biggest
improvements in response and data quality. We urge the Census Bureau to
move quickly to use existing data to inform communications plans.

B. Consistent with the above recommendation regarding the integrated
communications strategy for the 2010 Census, the PAA/AC requests that it
be included in briefings on plans for research to determine targeted
populations."

**[Census Bureau Response]{.underline}**

A. The Census Bureau is developing a research plan as part of the
overall 2010 Census Communications planning process. Data on response
patterns from the 1990 and 2000 censuses and the American Community
Survey will help identify groups to target.

B. The Census Bureau will continue to brief the PAA/AC on research
plans.

**[Recommendation 2]{.underline}**

**Summary of Census Bureau Research Problems**

**[American Statistical Association Advisory Committee]{.underline}**

"The American Statistical Association Advisory Committee (ASA/AC)
commends the Census Bureau on constructing the summary of some of the
research priorities. We believe the contracts for students working on
census related research will stimulate increased interest in these
research areas."

**[Census Bureau Response]{.underline}**

We agree and we are looking forward to working with the committee on
this project.

**[Population Association of America Advisory Committee]{.underline}**

"The PAA/AC is very pleased that the Census Bureau will be funding
several training fellowships to support the study of population
statistics and related topics at the post graduate level. Although
fellows will not be bound to work at the Census Bureau, these
fellowships aim to recruit new professionals into the federal
statistical agencies, including the Census Bureau.

The PAA/AC strongly recommends that information about the training
fellowships and application procedures be disseminated to graduate
programs outside the field of statistics. In particular, the PAA/AC
notes that the field of demography is inherently inter-disciplinary.
Demographers come from many backgrounds including statistics, sociology,
geography, and other areas.

The PAA/AC therefore urges the Census Bureau not to limit the applicant
pool of graduate fellows to those in statistics programs. The PAA/AC
will be happy to work with the Census Bureau to inform the demographic
community about the fellowships."

**[Census Bureau Response]{.underline}**

Comments received/no response needed.

**[Recommendation 3]{.underline}**

**A Framework for Prioritizing Economic Statistics Programs**

**[American Economic Association Advisory Committee]{.underline}**

"The American Economic Association Advisory Committee (AEA/AC) submits
the following:

In a budget cutting environment, any responsible agency must come up
with priorities. Doing so, of course, does not imply that the agency
thinks the lower priority items are without merit. It merely reflects
the unfortunate fiscal reality. We applaud the explicit effort of the
Census Bureau to ask users which census products they use and how much
they value them. We also applaud the effort to assess the cost
efficiency and data quality of the surveys.

With that as background, we have several specific suggestions and
comments relating to the statistics gathered thus far:

1\. We believe it is vital that the Census Bureau gather information
from more of its users than just the Bureau of Economic Analysis (BEA)
and the Federal Reserve Board (FRB). Private industry users, for
example, are likely to be interested in many different surveys or to put
different values on the surveys. They are likely to be much more
interested in geographic detail, for example. We recommend working with
the National Association of Business Economics (NABE) and AUBER to help
find out such priorities. In addition to the ratings of surveys, we
recommend asking user communities to give rankings of survey usefulness.
We also recommend assessing user value by tracking downloads of data,
not just number of clicks.

2\. We think it is important to consider more carefully the
cost/efficiency measures of the surveys. Some surveys, for example, are
new and their costs reflect start-up costs that ought not to be included
in the ongoing survey costs. It is also important to think through
standard statistical issues with the measures. For example, does a
simple doubling of the number of respondents to a survey automatically
improve its ranking? Does the scale of the ranking measures make a major
difference to the results?

3\. We encourage the Census Bureau to consider the costs of
changing/streamlining existing surveys as an alternative to canceling
surveys completely. For example, there is potential cost savings from
consolidating the number of questions so that fewer forms could be used
in the Annual Survey of Services. Also, consider reducing the time
frequency of monthly surveys to quarterly, or adjusting the c.v.
standards to be slightly less stringent. These steps might not have much
impact on the value of the data but might allow for substantial cost
reductions. We recommend exploring these options.

4\. We also recommend that the Census Bureau consider cost sharing or
other forms of partnering. We recommend exploring the potential of
turning over some surveys being considered for elimination to large
trade associations or other private entities (e.g., the repair and
remodeling survey might be of interest to say, the National Association
of Realtors or National Association of Home Builders). In such a case,
the Census Bureau could operate in an advisory capacity.

5\. We caution the Census Bureau to be careful about concluding too much
from any particular rankings that are, by their nature, quite imprecise
and approximate. We recommend assessing the robustness of ranking to
alternative weights. The Census Bureau should also consider using shares
of Gross Domestic Product variation as a criterion for evaluating the
importance of a survey. We also recommend that census be circumspect in
releasing these types of information outside the narrow planning
community."

**[Census Bureau Response]{.underline}**

The Census Bureau agrees that any set of criteria for prioritizing
programs and balancing operating objectives (e.g., usefulness, cost, and
quality) must be applied judiciously, improved continuously, and used as
a framework and not a substitute for disciplined decision making.
Decisions to terminate, re-engineer, or streamline programs will use the
program rankings as a tool, not a panacea. The Census Bureau will work
with the National Association of Business Economics and other data user
groups to seek additional perspectives on ranking the usefulness of
economic programs. We also will investigate whether data downloads can
provide supplemental information related to survey usefulness and value.
We agree that cost efficiency measures must be used cautiously, and
additional information is needed to better understand the underlying
cost structure.

**[Recommendation 4]{.underline}**

**Communications Overview**

**[American Marketing Association Advisory Committee]{.underline}**

"The American Marketing Association Advisory Committee (AMA/AC) members
sincerely appreciate that the Census Bureau, the Communications
Directorate, and Mr. Jefferson Taylor prepared a detailed session to
cover planning for the marketing and partnership programs in support of
the 2010 Decennial Census on the agenda. The planning approach
recognizes the complex marketing activities that must be undertaken to
ensure a successful census.

Based on the presentations, questions and answers in the session, the
AMA/AC makes the following recommendations:

1\. The Census Bureau has documented the substantial lessons it learned
from the evaluation of the Partnership and Marketing Program for Census
2000 (Census 2000 Topic Report No. 6). We recommend that personnel who
were involved in preparing these evaluations be integral members of the
Census Bureau team that prepares and reviews the Request for Proposal
(RFP) for the 2010 Partnership and Marketing Program.

2\. As input to the marketing plan to be developed by the prime
contractor and to guide efforts to improve marketing effectiveness, we
recommend that the Census Bureau capture what is already known about
mail response rates and marketing activities; that it use a format
similar to that used by the Census Bureau two years ago to summarize the
state of knowledge with respect to enumeration problems (i.e., \[a\]
identify groups that had different response characteristics, including
groups that respond well; \[b\] identify reasons why people in those
groups fail to respond to the mail questionnaire; \[c\] identify
marketing actions that will address any problems and enhance response
rates in each group; \[d\] prioritize marketing action based on the size
of affected groups and the likely effectiveness of the actions.

3\. The AMA strongly supports the Census Bureau's efforts to create a
behavioral segmentation of the population to guide the development of
the communication program. The AMA recommends that the Census Bureau
continue to lead this effort rather than delegate the responsibility to
the prime contractor. The Census Bureau has the detailed knowledge and
data concerning levels of response and personal characteristics of
responders/non-responders from Census 2000 and the ACS. The level of
quantitative modeling required is often too detailed for advertising
agencies to implement.

4\. The AMA recommends that the Census Bureau use its behavioral
segmentation model to identify groups with low response probability. The
results can be used to prioritize objectives for both Marketing and
Partnership programs under the overarching goal of increasing responses
at earlier, less expensive points on the contact continuum: by mail,
e-mail, phone, in person interview. Research can be targeted to
understand why there is a lack of favorable behavioral response at each
of the various contact points. Research can determine whether
non-responders have no awareness or intention (attitude) to participate.
These findings would define the message or partnership activity
necessary to counteract the lack of response. Ultimately, these findings
would help identify potential media and partners to deliver the
components of the message to move response further up the response
funnel.

5\. The AMA recommends that the Census Bureau develop a model to
estimate the economic benefit from increasing responses at earlier, less
expensive points on the contact continuum relative to the cost for
marketing expenditures to drive the earlier responses. In particular,
the model should estimate the response function between the mail
response rate and (a) total marketing spending; (b) general media
spending; (c) media specific spending with respect to television, radio
direct mail, and out-of-home; (d) spending on partner programs; and (e)
spending on specific types of partners. To develop and calibrate this
model, several related steps will need to be implemented:

> a\. Topic Report No. 6 indicates that there is a lack of correlation
> between the intention to complete the census form and the actual
> behavior to complete the form. Therefore, testing that involves actual
> response behavior, particularly mail return of the form, will be
> required to understand marketing and partnership program
> effectiveness. It is important that the Census Bureau pull this
> testing forward in time so as to be prepared for the 2010 Census.
>
> b\. Small footprint, experimentally designed tests, which assess the
> effectiveness of both levels and mixes of media, are recommended.
> These would be similar to test markets that companies use to pre-test
> and optimize launches of new products. These should commence as
> quickly as possible and continue up to the 2010 Census.

c\. The 2008 Dress Rehearsal provides an ideal platform to understand
the relative effectiveness of both partnership programs and media.
Testing of both media and partnership program deployments should be
undertaken during the Dress Rehearsal.

d\. Response rates to the ACS by target group and (potentially) by
media/partnership program treatment can help to calibrate a response
model for Census 2010. The 2008 Dress Rehearsal should be used to
estimate the "translation" function between ACS response rates at each
stage of behavior (mail, phone, in-person) and the short form in the
Census test. There are theories that the relative response rate for the
Census short form could be higher because it is easier than the ACS to
complete, or lower because there is no "community benefit" to completing
the form. The comparison of ACS and the 2008 Dress Rehearsal would
provide facts needed to plan the 2010 effort.

e\. The AMA recommends that the Census Bureau explore the possibility of
using small-scale media tests in support of the ACS as a testing vehicle
for the 2010 marketing communications and partnership program efforts.
Such use would require the "translation function" described in the
preceding item.

> 6\. The AMA recommends that the selection of a contractor for the
> research evaluation of the marketing and partnership programs be
> selected separately from the prime contractor who will develop and
> implement the programs. This approach will maximize the potential to
> obtain an unbiased, fact-based evaluation of the program.
> Additionally, the Census Bureau should ensure consensus between the
> two contractors on the key consumer metrics and partnership
> performance metrics which will guide the evaluation.
>
> 7\. The AMA recommends that communications management review and
> selection process led by the Census Bureau actively focus how strategy
> and creative approaches will extend in an integrated manner to
> non-broadcast media, live executions (e.g., radio DJs), and
> partnership program use. This will require the prime agency develop or
> subcontract for a full range of creative units that are targeted to
> non-broadcast media in support of candidate campaigns. It will require
> that the review process allocate review time in keeping with the
> budget and objectives assigned to non-broadcast and partnership
> initiatives.
>
> 8\. The AMA is encouraged by the Census Bureau efforts to utilize new
> on-line and user generated content approaches to support the 2010
> Census. New media and user content, like blogs, may facilitate
> messages to micro targets and specific target languages. The AMA
> recommends that response data from the 2008 Dress Rehearsal be used to
> understand which targets (e.g., young singles) might be well-targeted
> through these tools. Also, the AMA recommends that the Census Bureau
> explore services used to track user generated content (e.g.,
> Intelliseek, Umbria) to identify Census related topics that arise in
> the 2008 Dress Rehearsal and identify key opinion sites to guide
> selection of online partners.
>
> 9\. The AMA recommends that the Census Bureau determine what best
> practices can be learned from word-of-mouth marketers like Tremor and
> BuzzAgent. These marketers specialize in influencing word-of-mouth
> outcomes. Their practices may be useful in designing the content and
> tools to be used in the partnership programs and in identifying
> potential community partners."

**[Census Bureau Response]{.underline}**

1\. The 2010 Census Communications team will work closely with staff
involved in the Census 2000 evaluations of the partnership and marketing
program, beginning with the draft Request for Proposals.

2\. The Census Bureau, as part of the 2010 Census Communications
research plan, will identify response patterns by demographic and
housing characteristics, identify barriers to responding, identify
messaging and tactics to improve response, and set priorities for the
marketing efforts. This information will be provided to the agencies
awarded the

2010 Census Communications contract.

3\. The Census Bureau plans to begin work on a behavioral segmentation
of the population based on the 1990 and 2000 censuses, and the American
Community Survey. In consideration of the AMA recommendation, and
depending on resources and timing, we will either complete the work
in-house or contract it out to an appropriate research company.

4\. The Census Bureau plans to use its behavioral segmentation model as
recommended.

5\. The research plan for the 2010 Census Communications effort will
include developing a model to estimate the economic benefit from
targeting different groups along a continuum of response from mailback
to nonresponse followup. For the decennial census, the points of contact
will be the initial questionnaire, a replacement questionnaire, and the
in-person interview.

a\. and b. We have investigated various ways to test marketing and
partnership using actual response behavior and have concluded that such
a test would be exorbitantly expensive and would not yield meaningful
results for these reasons. First, the partnership and marketing program
is multi-faceted, touching people through their places of worship, their
childrens' schools, their communities and using the news media,
advertising, and special events. The advertising alone (in 2000)
targeted over 20 different population groups in 15 languages and used
national and local television, radio, print, and out-of-home. Media
buying was targeted to reach 95-99 percent of key audiences 50 or more
times on average. This level of activity would have to be scaled back
and it would not be certain whether a scaled-back version would give us
a clear assessment of the program's effectiveness. Also, the cost of
researching and producing even a scaled-back advertising campaign would
be high.

c\. The Dress Rehearsal is not intended to serve as another test for
decennial programs and operations, but rather the opportunity to pull
together teachings from prior tests and see how they work together. In
the case of the communications program, funding is not available to test
program components to date, and significant funds are not likely to be
available until fiscal year 2008.

> We agree that the dress rehearsal is an ideal platform to understand
> how the communications program will work for 2010 to the extent that
> resources and the dress rehearsal site composition allow. Although
> there will be no formal testing of the communications program, there
> are a number of key processes that we plan to assess during the dress
> rehearsal and revise for the 2010 Census. Processes such as using
> response data to identify target audiences and language needs,
> printing, translation, distribution, product review, etc.
>
> In addition to the dress rehearsal, the Census Bureau is trying to
> identify research that can be done at low or no cost, relative to
> planning the

2010 Census Communications program. We would also like to continue
discussions with the AMA regarding research alternatives, solutions,
etc.

d\. and e. The Census Bureau will look into ways to better understand
the "translation" of response behavior for the ACS into short-form
census response behavior.

6\. The Census Bureau will select an [independent]{.underline}
contractor for the evaluation of the 2010 Census Communications program,
as was done for Census 2000. We will work with the AMA Committee to
determine the appropriate metrics.

7\. The Census Bureau will carefully examine ways to extend the
communications program both to non-broadcast media and also to other
entities, such as partners and governments. Our experience in Census
2000 demonstrated that there are various legal and cost constraints
involved in sharing some of the advertising with partners. We have been
looking into ways to do this for the 2010 Census.

8\. The Census Bureau has decided not to offer Internet response in the
Dress Rehearsal, but there is ample research, syndicated and public,
into the characteristics of users of new electronic media. As this is a
rapidly changing environment, we will continue to monitor usage.

9\. The 2010 Census Communications Acquisition Team will look into best
practices in word-of-mouth marketing.

**[Recommendation 5]{.underline}**

**Content, Including Mode Consistency**

[**American Statistical Association Advisory Committee**
**(ASA/AC)**]{.underline}

"The ASA/AC submits the following:

**[Research to Improve Census Imputation Methods]{.underline}**

1\. The use of administrative records as a source for imputation of
missing data appears very promising and the ASA/AC supports further work
in this area. Obtaining sufficiently high match rates to the
administrative source will be important in making this an effective
strategy.

2\. The ASA/AC recommends that the Census Bureau carefully consider the
privacy implications of using data that were collected for one purpose
for an entirely different purpose without the informed consent of the
respondent.

3\. The ASA/AC encourages further research on item imputation, including
an alternative approaches to hot-deck imputation beyond the Census
Bureau "flow basis" hot-deck procedure and on other strategies, such as
embodied by the Statistics Canada CANCEIS system, that incorporate
different conceptions of exchangeability between units."

**[Census Bureau Response]{.underline}**

The Census Bureau will conduct an extensive evaluation of the item
imputation process used in the 2006 Census Test. After the Test, the
Census Bureau will choose an item imputation methodology for the 2008
Census Dress Rehearsal and the 2010 Census. The issues raised by the
Committee will be a factor in that decision. Regardless of which item
imputation method is used in the 2010 Census, it is likely that research
will continue to identify possible improvements in item imputation.

**[Mode Consistency]{.underline}**

"The ASA/AC commends the Census Bureau's work on mode consistency
guidelines, and believes that this work would be beneficial to the
broader survey methods community in providing a framework for developing
multi-mode instruments and in identifying research to mitigate mode
effects caused by survey instruments. Thus, we recommend that the Census
Bureau publicly disseminate a document describing these guidelines such
as in a professional journal.

In support of current research to understand mode effects, the ASA/AC
would encourage efforts to clarify the ideal targets of measurement,
which might suggest useful study design strategies, such as using
multiple measurement modes on samples of individuals, and which might
help identify mode effects amidst other measurement error phenomena."

**[Census Bureau Response]{.underline}**

The Census Bureau concurs that the Mode Consistency Guidelines should be
publicly disseminated after they are finalized and agrees that further
research should be conducted in this area. We are currently in the
process of defining and prioritizing the evaluations and experiments for
the 2010 Census and will take this recommendation into account.

**[Population Association of America Advisory Committee
(PAA/AC)]{.underline}**

**[Allocation Flags]{.underline}**

"The PAA/AC commends the Census Bureau on conducting very competent
research focusing on improved imputation methods.

The results indicate that the advantages in using administrative records
to assign the missing person records of sex, age, race and Hispanic
origin are remarkable. These data assignments made from administrative
records are far superior to the null model of independence.

Clearly the proposed strategy for 2010 would be to use administrative
records, when possible, for sex, age, race, and Hispanic origin. The
issue of tenure and relationship would seem to require the hot deck
strategy. The Kappa values for these two variables using the hot deck
are fair to good.

Currently, the public use microdata files use one allocation flag if a
given record has been imputed. The PAA/AC urges the Census Bureau to use
separate flags for different allocation/assignment strategies.

Consider the case of a person not indicating the race response. This
value may be obtained in several ways:

1\. Imputing a race response from others within the same household who
have reported race

2\. Assigning race from administrative records data

3\. Using a hot deck approach

> 4\. Using whole household substitution
>
> 5\. Implementing some other strategy, not yet determined.

If the Census Bureau follows the present approach, it would use only one
allocation flag to tell the user that race has been assigned or imputed.
We encourage the Census Bureau to have multiple flags. If all of them
are zero, this tells the user that the data item was reported by the
respondent. If they are all not zero, then the user knows just how race
was assigned or imputed. This recommendation is particularly important
if an Administrative Records approach is used because this method is
not, strictly speaking, an imputation approach, but an assignment of
data."

**[Census Bureau Response]{.underline}**

The Census Bureau understands and appreciates the issue raised by the
Committee, and will consider how to address this issue in the process of
creating public use files.

**Administrative Records and Confidentiality**

"The use of administrative data to improve imputation methods represents
a potentially important innovation and we commend the Census Bureau for
experimenting with it. However, we must also ask the Census Bureau to
consider the directions in which this use might lead and to recognize
that any merged files will need extreme degrees of protection from other
agencies of government, as well as from persons and organizations
outside of government.

The very possibility of merging census records with administrative ones,
e.g., from the Social Security Administration, raises the prospect that
"super" records about individuals will be created, which could be
enticing to other agencies, such as the Department of Homeland Security.
It could dramatically undermine public confidence in the Census if any
handover of such records were to occur. These records, it should be
noted, entail the merger information collected for other purposes and
used, in this context, without the permission or even the knowledge of
the individuals involved.

Moreover, we want to remind the Census Bureau that resistance to a
regular census has increased in some countries where comprehensive data
files with information from administrative and other sources have been
created. In Germany after 1987, this resistance forced the abandonment
of the census.

This is the time to think about the potential directions that the
incorporation of administrative data into census operations might take."

**[Census Bureau Response]{.underline}**

The U.S. Census Bureau is mandated by law to use administrative records
to the maximum extent possible to reduce duplication, cost, and
respondent burden. In fact, the Census Bureau has been using
administrative records to support its demographic programs since the

1940 Census. Administrative records were instrumental in measuring the
first differential undercount. Our Intercensal Estimates, which are used
to allocate hundreds of billions in federal funds, are based on
administrative records. Recognizing the importance of administrative
records to Census Bureau programs, the Census Bureau recently
incorporated uses of these data into our Strategic Plan.

The Census Bureau also has conducted extensive research on the
feasibility and desirability of using administrative records to
supplement the decennial census, especially since the early 1990s. Such
research has shown that using administrative records to supplement the
decennial census is an inexpensive but effective means to improve
coverage.

The Census Bureau considers using administrative records to supplement
the decennial census only if the following criteria are met:

> ∙ Must improve accuracy
>
> ∙ Must be operationally feasible
>
> ∙ Must be legal, ethical, and comply with our policies

Subsequently, research has demonstrated that administrative records are
useful to:

> ∙ Fill out missing items, resulting in substantial error reduction.
>
> ∙ Augment lists of Group Quarters, improving coverage.
>
> ∙ Develop statistical models for identifying areas needing coverage
> follow-up, resulting in a decrease in within-household omissions.

The Census Bureau understands the Committee's concerns about
administrative records and would only use the data from other sources if
those data can be shown to improve the ultimate data products. The
Census Bureau also is cognizant of potential concerns, including those
you have raised. Title 13, United States Code, provides stringent
confidentiality protections to these data, just as it does to census and
survey information. Those constraints would prevent the Census Bureau
from handing over linked record files to other agencies in the future.
Nonetheless, we will test the messages we will use to inform the public
of our plans to minimize any concerns they may have. Furthermore, the
Census Bureau has no intent to replace respondent replies with data from
administrative records.

**[Final Format and Content for Race, Hispanic Origin, and
Ancestry]{.underline}**

"Because results from the 2005 test are not available yet, the PAA/AC
recommends that the Census Bureau delay a final decision on the final
format and content of the questions on race, Hispanic origin, and
ancestry until results from the 2005 test have been shared and discussed
with the PAA/AC and other appropriate census advisory committees."

**[Census Bureau Response]{.underline}**

The Census Bureau concurs.

**[Race and Hispanic Origin Collection, Editing, and Imputation
Procedures]{.underline}**

"The PAA/AC commends the Census Bureau for its continuous research on
the collection, editing, and imputation procedures for race and Hispanic
origin data.

> 1\. To maintain consistency with prior censuses, the PAA/AC recommends
> that the Census Bureau continue to use the Office of Management and
> Budget's (OMB's) Hispanic and race definitions to edit and assign
> write-in responses of national origin to the Hispanic and race
> questions. We further recommend thorough testing of alternative
> editing procedures.
>
> 2\. If there are changes in the editing procedures for race and
> Hispanic origin, the PAA/AC recommends the publication of crosswalk
> tables to allow comparison of old and new editing techniques."

**[Census Bureau Response]{.underline}**

The Census Bureau concurs.

**[Hispanic Origin]{.underline}**

"The PAA/AC is very appreciative of the efforts the Census Bureau is
making to attend to the well-known problems associated with the
Hispanic-origin question in Census 2000. However, the PAA/AC must
reiterate the concern expressed in its previous recommendation from the
October 2005 CACPA meeting (Recommendation 14) about the exclusion of
multiple-origin reporting on this question. Multiple reporting includes
the possibility of two or more different Latin American origins -- e.g.,
individuals who are of Cuban and Mexican ancestry -- or a Hispanic
origin and a non-Hispanic one.

The Census Bureau's response indicates that such multiple origins cannot
be recognized in the 2010 Census because of a lack of time to "design,
test, and analyze" a new question. However, we remain very concerned
about the lack of realism in Census Bureau reports of the
Hispanic-origin population. This population is likely to be
significantly larger than any other minority population by 2010.
Research shows, moreover, that the intermarriage rate by Hispanics is
substantial. Thus the population with mixed origins, at least one of
which is Hispanic, is increasing. In effect, the current Census Bureau
question treats Hispanic origins according to a one-drop rule. The
inability to report on the degree of overlap between the Hispanic
population and other major racial/ethnic populations is providing
Americans with a misleading picture of the evolution of the
racial/ethnic composition of the United States at a time of high levels
of immigration from Latin America and increasing racial/ethnic
intermarriage. Potentially, this inaccuracy could contribute to already
contentious views of Americans on immigration and the changes associated
with it.

We recommend, at a minimum, that the Census Bureau devise an
experimental panel for the 2010 Census to test an alternative
formulation of the Hispanic-origin question that allows for multiple
responses."

**[Census Bureau Response]{.underline}**

The issue of collecting multiple responses to the Hispanic-origin
question was first raised in Federal Register Notice No. 15 by the
Office of Management and Budget (OMB) on

October 30, 1997. Please see "Revisions to the Standards for the
Classifications of Federal Data on Race and Ethnicity. Federal Register:
October 30, 1997\" at the following Web site:
\<[www.whitehouse.gov/omb/fedreg/1997standards.html]{.underline}\>. In
the notice, OMB recognized the importance of allowing individuals to
select both "Hispanic origin" and "Not of Hispanic origin" for diversity
reasons. However, because of the lack of research in this area and
concerns about the possible impact of any change on the quality of the
origin data, the provision to allow respondents to select both "Hispanic
origin" and "Not of Hispanic origin" was not included in the 1997
standards. Thus, the current OMB guidelines on race and ethnic
collection suggest that respondents must be classified into one origin
response category. The OMB suggested further research on
multiple-response reporting to the Hispanic-origin question. The Census
Bureau responded to OMB and released Working Paper #77, "Analysis of
Multiple Origin Reporting to the Hispanic Origin Question in Census
2000\" by Roberto R. Ramirez, at the following Web site:
\<[www.census.gov/population/www/documentation/twps0077.html]{.underline}\>.
The Census Bureau plans to study the reporting of more than one origin
to the Hispanic-origin question in the future. However, at this point,
it would not be possible to design, test, and analyze a question to
elicit multiple responses on Hispanic origin and get approval from OMB
in time for the deadlines for content decision.

**[Mode Consistency]{.underline}**

"The PAA/AC commends the effort to date by the Working Group on Mode
Consistency. The Working Group's draft guidelines reveal the challenges
of ensuring universal presentation when questionnaires are administered
across different modes which may entail differences in question format,
phrasing, and questionnaire design, all of which can compromise data
quality. The issue of potential mode effects will become more evident
because both the 2010 Census and the ACS will employ multiple modes of
data collection (mail out/mail back questionnaires and telephone and
personal interviews) and use multiple instruments and questionnaires
(paper and electronic).

A. The PAA/AC recommends that the Census Bureau implement the following
two recommendations of the Mode Consistency Working Group:

• Clarify and document roles and responsibilities of different areas of
the Census Bureau in the development of the instruments for census and
other surveys to minimize the problem of fragmentation identified by the
Mode Consistency Working Group.

• Create an ongoing structural capability for addressing current and
future mode technical and policy issues.

B. In addition, while guidelines are important, their efficiency can
only be determined through research. Therefore, the PAA/AC strongly
recommends that the Census Bureau design and conduct research in the
following areas:

• Pretest of questionnaires that are not administered through mail
out/mail back.

• Pretest of questionnaires that are administered in languages other
than English, across different modes, to assess how mode consistency
effects may interact with other characteristics such as limited English
proficiency.

• Conduct a comparison of data responses from a random sample of
respondents to [similar]{.underline} questions administered using
multiple modes (mail out/mail back, telephone and personal interviews)
and multiple instruments (paper and electronic).

Mode consistency effects have the potential to seriously compromise data
quality in terms of reliability and validity. The PAA/AC looks forward
to hearing more about this important topic at future advisory committee
meetings."

**[Census Bureau Response]{.underline}**

The Census Bureau concurs. We are currently in the process of defining
and prioritizing the evaluations and experiments for the 2010 Census and
will take this recommendation into account.

**[Recommendation 6]{.underline}**

**Microdata Results from Business List Comparison Project**

[**American Economic Association Advisory Committee**
**(AEA/AC)**]{.underline}

"The AEA/AC applauds the joint effort by the Census Bureau and the
Bureau of Labor Statistics (BLS) to examine consistency of their
respective business lists. We encourage them to continue working on this
issue. In particular we recommend:

> 1\. There should be further work on following up the discrepancy in
> total employment between the two lists. In aggregate, on the matched
> sample the Census Bureau has about 5 percent higher employment. It is
> challenging to compare multi-establishment enterprises because of
> different rules for grouping these firms by the respective agencies.
> However, initial results indicate that the discrepancy holds at about
> the same rate for single unit enterprises. Since these groups can be
> more conveniently compared, it would be useful to examine this group
> in greater detail. For example, it would be useful to examine whether
> discrepancies vary systematically with characteristic of firms, such
> as state, firm size, industry, and age. Furthermore, it is important
> to compare the same establishments over different years to see when
> discrepancies materialize and whether they persist.
>
> 2\. We applaud the examination of the consistency in level. We also
> recommend comparing consistency in changes over time.
>
> 3\. We do not recommend solely examining a single year. By focusing on
> single-unit establishments, it might be possible to examine a number
> of years of data at low cost.
>
> 4\. We reiterate that it would be useful to compare employment of
> Professional Employer Organizations (PEO) across the Census Bureau and
> the BLS. A problem with PEOs is that a firm leasing an employee might
> be in one state while the employee works in another state. State
> agencies managing unemployment insurance programs will have an
> incentive to collect taxes on workers that will be covered in their
> states. Since the BLS data is based on these UI programs, the
> allocation of workers across states in this industry for the BLS could
> be quite different than in census data.
>
> 5\. We also recommend that the Census Bureau and BLS initiate a
> conversation with the public suppliers of the data, state by state, in
> order to better understand definitions, data quality, and other causes
> of discrepancies. Furthermore, private suppliers should be approached
> where appropriate. For example, payroll processors, such as ADP, may
> be able to add further insight."

**[Census Bureau Response]{.underline}**

We appreciate the Committee's suggestions and will move forward with
their recommendations as stated.

**[Recommendation 7]{.underline}**

**2010 Demographic Surveys Sample Redesign Issues**

[**American Statistical Association Advisory Committee**
**(ASA/AC)**]{.underline}

"The ASA/AC submits the following:

> 1\. The ASA/AC recommends that the Census Bureau identify how design
> and analysis goals for surveys in the 2010 Survey Redesign effort
> differ from the current goals of the ACS-driven map update process.
> The Census Bureau should use this information to evaluate how the
> Master Address File (MAF) update process should be modified to
> accommodate the use of MAF for the 2010 Survey Redesign.
>
> 2\. The ASA/AC recommends that the Census Bureau establish a formal
> and well-defined evaluation program for MAF. The goals of this program
> should include production of estimates of frame coverage and other
> survey quality measures, and identification of areas for targeted
> improvement of MAF. The evaluation program should include an annual
> (or regular and frequent) study to quantify the quality of MAF and
> update sources, and systems that track problems experienced in survey
> operations I counties.
>
> 3\. The ASA/AC recommends that the Census Bureau investigate methods
> to improve precision of direct ACS estimates for variables used in the
> 2010 Sample Redesign, and evaluate the correlation of ACS variables
> for sample design with variables of interest from the target surveys
> to assess their potential to improve the precision for survey
> estimates.
>
> 4\. Given that the new design may have to last for several years, the
> ASA/AC recommends that the Census Bureau consider the stability over
> time of the variables used for stratification, not just their
> correlation with the variables of interest at the time the sample is
> designed. The use of variables that are less stable can result in
> significant deterioration of the sample design over time.
>
> 5\. There are several reasons why integration of the ACS and the
> demographic surveys into a two-phase approach may be desirable,
> including reduced collection costs, improved quality, and more
> flexibility to mount new surveys. There are also some disadvantages,
> such as sub-optimal sample designs, response burden, and problems of
> respondent mobility between the ACS and the second phase survey. The
> ASA/AC recommends that the Census Bureau examine approaches being
> developed in other countries, particularly the Office for National
> Statistics in the United Kingdom."

**[Census Bureau Response]{.underline}**

**[American Statistical Association Advisory Committee]{.underline}**

1\. We agree. We plan to explore how the goals for the American
Community Survey (ACS)-driven Master Address File (MAF) update process
differ from the design and analysis goals for the 2010 Sample Redesign
surveys. One significant difference between the designs is that the
redesign surveys have primary sampling units (PSUs), and the ACS does
not. Because the surveys have a PSU-based design, the priorities for
updating the MAF for the redesign surveys will be different form the
ACS, which is in all counties. We will look further at the systems
currently used to update the MAF (e.g., the delivery sequence file, the
Community Address Updating System, etc.) and determine how best to
balance the use of these systems used by ACS with the current surveys'
needs.

2\. We have begun to implement an evaluation program, the Frame
Assessment for Current Household Surveys (FACHS). The FACHS has produced
the first set of quality measures for the MAF on the portion of the
country with a relatively higher percentage of incomplete addresses or
in non-permit issuing areas (mostly rural). The FACHS will also produce
coverage and content quality measures for the MAF for the entire Nation,
for new construction, and for several sub-universes where targeted MAF
improvements will more likely be needed. The FACHS evaluations will be
repeated to produce several sets of quality measures over time. We have
begun to communicate this evaluation plan across the Census Bureau and
with survey sponsors. For the longer term, we also have in our plan to
develop an evaluation program to conduct ongoing evaluations of the MAF
as related to our surveys\' needs.

3\. The Census Bureau is committed to, and is interested in, the
precision of all ACS estimates. Our research agenda for 2006 and 2007
includes a project to improve the precision of ACS estimates for small
areas, which the Census Bureau is considering to use to improve the 2010
Sample Redesign. We also plan to conduct research on the correlation of
ACS variables for both PSU stratification and systematic sampling sorts.

4\. We will add stability analysis to our research on variables to use
in stratification.

5\. We will explore other integration approaches, such as the approach
being developed by the Office of National Statistics in the United
Kingdom.

**[Population Association of America Advisory Committee]{.underline}**

"The PAA/AC submits the following:

**[LUCA/MAF]{.underline}**

"The PAA/AC commends the Census Bureau on the improvement of the Master
Address File (MAF), as a result of the TIGER/MAF realignment effort and
the Community Address and Updating Survey (CAUS).

The Census Bureau program for updating the Master Address File is
inadequate, however, because it lacks a component for regular contact
with local governments. The PAA/AC recommends an annual program similar
to the decennial Local Update of Census Address (LUCA) program to
continuously improve the quality of the MAF. State, local and tribal
government participation throughout the decade will enhance the Census
Bureau's efforts to identify new construction, demolished housing units,
and incorrect addresses. However, the Census Bureau will not begin
development of a continuously updated address file until after the 2010
Census."

**[Census Bureau Response]{.underline}**

The Census Bureau places a high value on input to its address list from
tribal and local governments as evidenced by its emphasis on the 2000
Census LUCA program and its commitment to enhancing LUCA for the 2010
Census. We also understand the importance of regular contact with local
governments; as an example, we have maintained a high and continuously
improving response to our annual Boundary and Annexation Survey in which
we collect data on corporate status and boundaries from local and tribal
government officials.

The 2010 LUCA program is imminent; we will be contacting all eligible
government participants about the program in January 2007 and begin
sending out review materials in July 2007. As we look ahead to the next
decade, we already are considering how we can best take advantage of
local knowledge to keep the Master Address File up-to-date. Last year,
we engaged Booz-Allen-Hamilton to prepare an analysis on future
maintenance of the MAF (*Post-2010 MAF Maintenance: Establishing the
Business Case,* January, 2006, attached). A key recommendation of the
report was for the Census Bureau to increase its use of local and tribal
address knowledge through an ongoing collaborative review.

The Census Bureau will continue to evaluate whether its expanding
technical capabilities and the increased availability of digital spatial
data from local governments and other sources can support a cost
effective and more continuous update of its address information through
partnerships with local and tribal governments.

**[Units in Structure]{.underline}**

"The PAA/AC recommends that a question on units in structure be added to
the 2010 Census questionnaire. It is essential for a full evaluation of
census coverage. This includes a possible post-census local review. The
Census Bureau should have some idea of how well it captured the housing
stock of an area, which will provide it with some degree of confidence
that these data are adequate for stratification and frame purposes for
post-2010 surveys. Moreover, knowledge of units in structure from the
census enumeration will help the Census Bureau in its efforts to
properly sort out apartment units in small multi-family buildings and
evaluate the adequacy of the MAF for these purposes."

**[Census Bureau Response]{.underline}**

Although we appreciate the possible benefit to coverage evaluation of
adding a units in structure question, the Census Bureau does not plan to
collect information about units in structure on the 2010 Census
questionnaire. There is limited space on the form. In addition, there is
limited space for items necessary to administer the census itself,
including questions to improve census coverage. Our experience in asking
units in structure leads us to conclude that it is less effective in
improving coverage than the questions we are including. Instead of
collecting units in structure on the short form, we will be collecting a
set of geographic coordinates for each structure when we conduct our
Address Canvassing operation to update the MAF. Each individual unit
within the structure will be "attached" to the coordinate for the
structure, and this information will be stored in the MAF and TIGER
database. Using the information from the coordinates for each structure,
we will be able to calculate the number of units in structure. By
storing this information in MAF and TIGER, it could potentially be
updated throughout the decade by the Demographic Area Address Listing
program, ACS, and the current surveys.

**[PSU Stratification]{.underline}**

"The PAA/AC submits the following:

> 1\. The PAA/AC's major recommendations in regard to using the ACS data
> for PSU stratification and selection and within-PSU selection are as
> follows:
>
> a\. First, in regard to the PSU stratification and selection, the
> PAA/AC notes that approximately 24 percent of U.S. counties have a
> population of 65,000 or more; 33 percent have between 20,000 and
> 65,000; and 43 percent of U.S. counties have less than 20,000. Before
> committing to a major departure from the "one-year" 2000 sample
> redesign, the Census Bureau should explore the feasibility of
> aggregating counties so that annual estimates can be developed in 2010
> that make sense for PSU stratification.
>
> b\. Second, in regard to within-PSU selection, we again recommend the
> feasibility of considering the aggregation of counties such that
> annual estimates can be used in 2010.
>
> 2\. The PAA/AC's major recommendation in regard to integrating the ACS
> with other household surveys is that this not be implemented too
> quickly. It is tempting to consider the efficiencies that could be
> gained by integrating these surveys. However, we caution that a lot of
> "eggs" are already in the ACS basket and we are concerned that if
> these national surveys are added to the collection, they will be
> jeopardized if the ACS falters."

**[Census Bureau Response]{.underline}**

1.a. We intend to aggregate counties into Primary Sampling Units (PSUs).
However, we will not be able to make all PSUs large enough to use
"one-year" ACS estimates because of field constraints on interviewer
assignment coverage.

1.b. As with 1.a., we intend to aggregate counties into PSUs. However,
we will not be able to make all PSUs large enough to use "one-year" ACS
estimates because of field constraints on interviewer assignment
coverage.

2\. We are not currently planning to integrate the ACS with other
surveys. However, as the ASA Committee suggested, we will investigate
what the Office of National Statistics in the United Kingdom is doing to
integrate surveys.

**[Recommendation 8]{.underline}**

**Aligning Data Requirements with Accounting Practices**

**[American Economic Association Advisory Committee]{.underline}**

"The AEA/AC commends the Census Bureau on its efforts to improve the
accuracy, response rates, and lower costs of its surveys by aligning its
questions with accounting conventions.

In response to the Census Bureau's query about experiences or
alternative organizational learning models, the Committee suggests the
following:

> 1\. As turnover occurs, consider replacing some existing survey
> statistician positions with professional accountants to create teams
> of specialized professionals (accountants, statisticians, economists,
> etc.) rather than attempt to increase significantly the accounting
> knowledge of all current survey statisticians. Businesses have used
> this team-of-experts model to successfully solve similar complex data
> analysis, production and reporting problems.
>
> 2\. One alternative organizational learning model not mentioned by the
> Census Bureau consists of joint session training programs. The NABE
> has used this model to teach new business economists about economic
> data: it brings together senior Census Bureau, BEA, BLS, FRB data
> producers and senior business economists who use the data to jointly
> teach new business economists about government data and how it is
> analyzed in a business setting. The Census Bureau could ask the
> American Institute of CPAs or FASB to work with them in a similar
> training/working setting to teach the Census Bureau statisticians and
> survey specialists how firm accountants view the Census Bureau's
> survey questions. This approach would enhance the other professional
> development methods mentioned by the Census Bureau, all of which the
> Committee endorses.
>
> 3\. Regarding the increasing complexity of the accounting system, the
> committee recommends the Census Bureau develop expertise in accounting
> software. For example, the Census Bureau could communicate with
> accounting software developers to inform them of the Census Bureau
> survey requirements and attempt to encourage the development of
> software modules that would facilitate reporting of survey data.

The Census Bureau asked if full or detail reporting at the establishment
level is still as relevant as it once was. The Committee acknowledged
the validity of the question and noted that it may vary by industry. For
example, manufacturing firms may have excellent raw material input-cost
related data by establishment, but at-best allocated revenue and
overhead cost information. Retail firms, on the other hand, might have
excellent revenue-related establishment information, but poor or
non-existent input-cost related information. To the extent the firm is
the most-relevant economic entity for analysis, establishment-level data
may be less necessary that it used to be. The Committee recognizes for
some measures, especially those related to labor, remain important at
the establishment level."

**[Census Bureau Response]{.underline}**

Budget permitting, we plan on hiring additional accountants. However, we
do feel that additional professional development should also include
accounting orientation. Our goal is not to turn survey statisticians
into accountants, but to provide them with knowledge to enable them to
recognize and resolve reporting problems and issues.

We agree that utilizing joint-session training is an efficient and
relatively low-cost method to transfer knowledge. We intend to explore
the committee's recommendation to develop such programs with the
American Institute of Certified Public Accountants, as well as other
professional accounting associations including the Institute of
Management Accountants.

Accounting software has become less complex as applications have moved
toward relational databases. We believe the issue is not with the
application developers, but rather the end users and that there is more
to be gained by improving the "sophistication" of survey teams about
accounting classification structure and chart of account design that
application developers or end users becoming knowledgeable about our
surveys.

**[Recommendation 9]{.underline}**

**Research on the Use of Population Estimates as Controls in the ACS**

**[American Statistical Association Advisory Committee]{.underline}**

"The ASA/AC encourages the Census Bureau to broaden its research
framework on ACS accuracy to include ideas from the literature on
combining information from multiple sources, one example being work that
has been done on using information on demographic sex ratios to improve
census coverage estimates.

The ASA/AC commends the Census Bureau for undertaking this research on
the effect of population controls on ACS estimates. This is an important
problem with far-reaching consequences. The four research priorities
outlined in the paper will result in a great deal of useful knowledge
about county-level population controls. The research proposed about the
accuracy of county by age by race by sex population estimates is
essential for deciding what levels of population controls should be
applied to the ACS.

We believe it would be helpful while conducting this research to define
the population parameters or the ACS. If you had a complete daily census
of all quantities of interest, what population parameters would you
report for the year? Evaluation of population controls for the ACS could
then be measured by how well the controlled estimates correspond to
population parameters of interest under various scenarios. When
comparing population-adjusted estimates with independent benchmarks, it
is important to ensure that the independent benchmark measures the
parameter being estimate.

The seasonality research is very important. It might be illuminating to
explore, using ACS data, how much of a role seasonality may play in the
accuracy of the population estimates. This could ultimately lead to
better models for the intercensal population estimates.

Some additional metrics might be useful in the Bureau's evaluation. In
addition to examining mean absolute percentage error of the population
estimates for different classifications, it would also be useful to
examine the distribution or percentiles of those areas. We recommend
in-depth examination of the outliers from the population models.

We recommend continued research on how to incorporate errors in the
population controls into measures of uncertainty for the ACS."

**[Census Bureau Response]{.underline}**

The Census Bureau agrees with the committee's recommendation that the
Census Bureau conduct evaluations and additional research to better
understand the relationship between the ACS population parameters and
the independent estimates produced by the Population Estimates Program.
Our evaluation on the quality of county level population estimates,
supplemented by results from the seasonality research, will provide a
great deal of information that will enhance our understanding of this
subject.

The Census Bureau also agrees with the recommendation to incorporate
additional metrics into our estimates analysis and plans to include an
examination of the distributions of the errors into the evaluation of
the state and county population characteristics. Additionally, we agree
that our analysis would be improved by using exploratory data analysis
and other statistical techniques to identify statistical outliers for a
more in-depth examination.

However, the Census Bureau does not agree with the recommendation to
incorporate errors in the population controls into measures of
uncertainty for the ACS. Rather, we would prefer to develop methods to
reduce or eliminate error components in the population estimates before
using the controls in the ACS weighting process.

**[Population Association of America Advisory Committee]{.underline}**

"The PAA/AC submits the following:"

**[Evaluation of Post-2000 County Estimates]{.underline}**

"The PAA/AC commends the Census Bureau on the planned research projects
to determine the type and level of population controls to use in the ACS
and to evaluate the post-2000 county estimates by demographic
characteristics.

Given the critical role of the Census Bureau estimates to distribute
federal funds and control numerous household surveys, the PAA/AC
recommends the Census Bureau use independent population estimates
developed by their state partners in the Federal/State Cooperative
Program for Population Estimates (FSCPE) as one type of evaluation of
the post-2000 estimates series."

**[Census Bureau Response]{.underline}**

The Census Bureau agrees with the recommendation to use independent
population estimates developed by members of the Federal State
Cooperative Program for Population Estimates (FSCPE) as one of the
benchmarks in the evaluation of the post-2000 estimates series. We are
also working with members of the FSCPE Steering Committee to increase
the participation of FSCPE members in the review of the Census Bureau
estimates. The agenda of the upcoming fall meeting of the FSCPE will
include training and workshops that focus on these data and methods used
to develop the Census Bureau estimates and techniques developed by state
partners to review the outputs of the estimates process.

**[Reliability of Small Area ACS Data]{.underline}**

"The PAA/AC commends the Census Bureau in its efforts to create useful
data for small areas from the ACS. The level of reliability of small
area estimates remains a big concern for many users, however. The Census
Bureau needs to provide the data user community with an update on the
level of sampling variability that is likely for estimates in places of
under 20,000 residents. Confidence intervals need to be presented for
key items such as poverty level for places, minor civil divisions
(MCDs), and/or census tracts of different sizes. We recommend that these
examples be drawn from the data already compiled for 2000 to 2005 in the
test areas. In addition, the Census Bureau should provide the data user
community with an update on what the confidence intervals will look like
for larger areas in the 20,000 to 65,000 population range, on both a
three-year and five-year basis."

**[Census Bureau Response]{.underline}**

The Census Bureau agrees that we should provide information about the
sizes of confidence intervals for areas of size greater than 20,000. We
are currently carrying out research on developing methods to reduce
variances of estimates for areas with smaller populations. We will need
to complete this work before presenting examples of the sizes of
corresponding confidence intervals. We anticipate that the results of
the research will be available in advance of the next meeting of the
Census Advisory Committee of Professional Associations.

**[Housing Unit-Based Population Estimates]{.underline}**

"The PAA/AC recognizes the difficult nature of corroborating intercensal
estimates of population and commends the Census Bureau for its efforts
on behalf of the data user community. The Census Bureau's own research
shows that housing unit based methods of population estimation hold
promise as an alternative to the current components of change approach.
The Census Bureau should continue to explore the utility of adopting
housing unit based methods of population estimation at county and
subcounty levels, as part of an integrated approach to the creation of
intercensal population estimates."

**[Census Bureau Response]{.underline}**

The Census Bureau agrees with the recommendation of the PAA/AC and plans
to continue to explore the utility of adopting housing unit based
methods of population estimation at county and subcounty levels as part
of an integrated approach to the creation of intercensal population
estimates. The Census Bureau has outlined an ambitious research plan to
enhance the current housing unit based approach and to identify areas
where the current component of change and housing unit approach produce
discrepant estimate results. We will work with the Research Subcommittee
of the Federal State Cooperative Program for Population Estimates to
review the plan and to identify resources that could work together to
implement the plan.

**[Recommendation 10]{.underline}**

**SIPP and Reengineering Our System to Measure the Dynamics of Economic
Well-Being**

**[American Marketing Association Advisory Committee]{.underline}**

"The AMA/AC does not believe that members of the AMA are core users for
SIPP data. AMA members have substantial interest in topics such as the
existence and nature of consumer relationships with financial
institutions, consumer financial planning, retirement planning,
extra-household financial arrangements, and childcare, but it is our
perception that AMA members typically rely on sources other than SIPP
for such information. Accordingly, we do not view AMA members as core
stakeholders in SIPP reengineering.

Having said that, it is difficult to provide concrete input at the
present time since it is not clear what information may be available
from administrative records. We will be happy to provide input as the
situation becomes more clear."

**[Census Bureau Response]{.underline}**

We will continue to hold periodic meetings discussing the design and
content of the new system and to keep you informed of development that
may be of interest.

**[American Statistical Association Advisory Committee]{.underline}**

"In regard to the use of administrative records in combination with
survey data, the ASA/AC has substantial concerns about the privacy and
confidentiality issues raised by the linkage of SIPP survey data with
variables that are available only on administrative records. We
recommend continued research on strategies that address privacy and
confidentiality concerns that further the goal of disseminating
information on the dynamics of economic well-being as broadly as
possible.

As a possible vehicle for addressing the imperative of disseminating
information on the dynamics of economic well-being while protecting the
confidentiality of micro-data records, the ASA/AC encourages
consideration of expanding the Census Research Data Center network,
perhaps very substantially, with the potential of broadening access both
for other federal agencies and for researchers across the country. To
this end, we encourage the Census Bureau to review and potentially
broaden the scope of research deemed to meet Title 13 criteria for being
useful to the Census Bureau."

**[Census Bureau Response]{.underline}**

The Census Bureau is aware of the confidentiality challenges and special
protections that may result from the use of administrative data in a
longitudinal context. The Disclosure Review Board, Census Bureau's
inter-divisional group charged with protecting the confidential of all
data products, will review the output from the prototype at each stage
of development and will assist in addressing confidentiality issues as
they arise. Our goal is to provide a public use file to the data user
community.

We are aware of the difficulty in providing external access to survey
data that has been matched with administrative records data. Once the
scope of the use of administrative records in the reengineering project
becomes clear, we expect to investigate all means possible, including
the Research Data Center (RDC) program, to make the matched survey and
administrative data available to independent researchers. Methodological
research, especially of new surveys, is always of interest to the Census
Bureau, and is allowed under the statute authorizing Special Sworn
Status employees to have access to confidential microdata (Title 13,
Section 23 (c)). In order to maintain both the fact and the appearance
of impartiality, the Census Bureau has not approved projects at the RDCs
that are solely interested in evaluation of public policy. Non-profit
organizations and academic institutions may apply through the
established National Science Foundation-sponsored process to open new
RDCs. However, the Census Bureau does not have the resources to greatly
expand the number of RDCs.

**[Population Association of America Advisory Committee]{.underline}**

"The Census Bureau is to be commended for its intent to reengineer the
Survey of Income and Program Participation in order to preserve its most
vital functions, improve data quality, and achieve necessary cost
efficiencies.

> 1\. As a first step, the PAA/AC recommends that the Census Bureau
> ascertain the areas of SIPP overlap in content with on-going surveys
> and administrative data, and make information on unique and duplicate
> items available to the broader user community for comment on
> information that must be preserved in new data collection.
>
> 2\. As the broad scope integration of administrative data in a
> longitudinal context may raise new confidentiality challenges, the
> PAA/AC encourages the Census Bureau to give careful consideration to
> the special protections that may be required.
>
> 3\. In light of the importance of SIPP to labor and welfare
> researchers, the PAA/AC recommends that the Census Bureau again invite
> comments from the American Economic Association Advisory Committee."

**[Census Bureau Response]{.underline}**

1\. One of the goals of the reengineered system is to make use of
existing survey data (the American Community Survey or the Current
Population Survey's Annual Social and Economic Supplement are currently
under consideration), as well as to capitalize on the advances that the
Census Bureau has made in acquiring and integrating administrative
records with survey data. We are in the process of determining the
alignment of the Survey of Income and Program Participation (SIPP) core
content with currently available administrative data sources (including
an evaluation of the coverage of the administrative records source and
the time lag between when the data are collected and when they are
available at the Census Bureau). The results of these alignment
"exercises" will have an impact on the content for the reengineered
system.

> The Census Bureau is committed to involving its many stakeholders in
> all phases of the design, development, and implementation of this
> reengineering. We will continue to work closely with federal and
> external stakeholders and data users to ensure that the content of the
> new survey instrument addresses their critical data needs and provide
> them with the results of the alignment exercises.

2\. The Census Bureau is aware of the confidentiality challenges and
special protections that may result from the use of administrative data
in a longitudinal context. The Disclosure Review Board, Census Bureau's
inter-divisional group charged with protecting the confidential of all
data products, will review the output from the prototype at each stage
of development and will assist in addressing confidentiality issues as
they arise.

3\. Since the CACPA meeting, we held a meeting with major federal
stakeholders, we conducted a roundtable at Brookings Institution
attended by federal, private, and congressional stakeholders, and are
planning another meeting, open to the public, tentatively scheduled for
later this summer at the Census Bureau's Headquarters in Suitland,
Maryland. We will consider contacting the AEA members directly in order
to obtain their comments and suggestions. In a further effort to obtain
and consider user suggestions, we have added a new button (labeled
Dynamics of Economic Well-Being) on the SIPP home page
(www.bls.census.gov/sipp) where interested parties can send messages to
us about their suggestions, concerns, etc., about the new program, as
well as find recent information about the new system. The Census Bureau
will continue to hold periodic meetings throughout the life cycle of
this reengineering in order to solicit input from our stakeholders.

**[Recommendation 11]{.underline}**

**[Resubmitted Recommendation: Foreign-born and Foreign-stock
Populations]{.underline}**

**[Population Association of America Advisory Committee]{.underline}**

"The PAA/AC finds the Census Bureau's response to Recommendation 3D from
the

October 20-21, 2005, CACPA meeting to be unsatisfactory. The PAA/AC had
recommended that the new Strategic Planning and Innovation Directorate
consider providing better and more comprehensive data on the
foreign-born and foreign-stock populations. In its recommendation, the
PAA/AC expressed particular interest in data that would allow the
identification and study of different generations (first, second, third
and higher), legal status, and improved measures of English and other
language proficiency among the foreign-born population.

In its response, the Census Bureau directed the PAA/AC to a link that
was supposed to contain a table package of the 2004 foreign-born
population released by the Immigration Statistics Staff in 2005. The
PAA/AC has two reactions to this response: First, the link is no longer
available, and the table package is not accessible for review. Second,
the table package was based on data from the Current Population Survey
(CPS).

The PAA/AC knows well that the CPS has been, for many years, the only
Census Bureau survey that allows the identification of the first,
second, and third generations. However, in recommending that the new
Strategic Planning and Innovation Directorate consider providing better
and more comprehensive data on the foreign-born and foreign-stock
population, the PAA/AC had hoped that there would be a more satisfactory
response than to simply refer to the CPS as the only source of data on
the foreign-born and foreign-stock populations.

The PAA/AC also found the Census Bureau's response to the recommendation
on improved measures of English and other language proficiency
inadequate. The Census Bureau's response was to refer to a 2003 study of
adult literacy by the National Center for Education Statistics in the
Department of Education, a study that primarily focused on
English-language literacy among the mainly native-born population.

In sum, the PAA/AC finds that the Census Bureau's response amounted to
basically doing nothing that would be new or innovative in terms of data
and research on the foreign-born and foreign-stock populations. This
reflects a failure to understand the importance and significance of the
Committee's recommendation regarding the foreign-born and foreign-stock
populations. The foreign-born and foreign-stock population is growing
rapidly, and is increasingly diverse along key characteristics such as
human capital, legal status, national origins, etc. In addition, the
foreign-born population is dispersing and increasingly settling in areas
that did not receive many immigrants in the past, such as small towns
and rural areas in the southern and midwestern regions of the United
States. These trends contain important demographic, social, economic,
and political implications, as well as for the many federal programs,
including voting rights, fair housing, healthcare, and educational
programs.

The PAA/AC therefore resubmits the following revised Recommendation 3D
from the

October 20-21, 2005 meeting:

The PAA/AC recommends that the new Strategic Planning and Innovation
Directorate consider providing better and more comprehensive data on the
foreign-born and foreign-stock populations. The foreign-born and
foreign-stock populations are increasing rapidly and are a growing
proportion of the U.S. population. This population is diverse in
national origins, human capital, legal status, etc., and is also
dispersing throughout the country. The PAA/AC is particularly interested
in data other than the Current Population Survey that would allow the
identification and better study of the foreign-born and foreign-stock
populations. The PAA/AC is particularly interested in data that would
allow the identification and study of the foreign-born and foreign-stock
populations by generation, including data on legal status (not limited
to citizenship status) and improved measures of language proficiency
(oral and written) in both English and other languages.

Second, given the importance of the topic of immigration for
researchers, and the visibility of the topic for public policy and in
public debate, the PAA/AC recommends that an update by the Immigration
Statistics Staff be included in the October 2006 agenda at the next
CACPA meeting."

**[Census Bureau Response]{.underline}**

First, the Census Bureau apologizes for providing an incorrect link. The
appropriate link refers to a table package ppl-176, and when typing the
document we accidentally substituted the numeral "1" for the letter "l,"
thus producing an incorrect link. It was inexcusable for us not to
provide a correct link. The correct link (for the Current Population
Survey) on characteristics of the foreign-born is
\<http://www.census.gov/population/www/socdemo/foreign/ppl-176.html\>.

The Census Bureau agrees with the committee's view on the importance and
significance of the foreign-born population. In 2007, we plan to publish
a CPS "Generations" report. This report will take advantage of CPS
information and analyze first, second, and third generation persons.

While the CPS provides an important source of data on the foreign-born
population, the Census Bureau is also looking at other sources of data.
With regard to the American Community Survey, our latest table package
is from 2003, and we expect to publish a 2004 table package within the
next few months. Our 2004 table package is expected to have additional
details not in prior table packages. The link for the American Community
Survey on characteristics of the foreign-born is

\<http://www.census.gov/population/www/socdemo/foreign/acst2.html\>.

We would like to bring to the committee's attention a set of detailed
tables we have constructed from Census 2000 on characteristics of the
foreign-born, by state and by country of origin. As of June 29, 2006,
not all states are published, but they have been produced, and you
should expect to see them on a flow basis in the very near future. The
link is
\<http://www.census.gov/population/www/socdemo/foreign/acst2.html\>.

In addition, we are working on a special mapping project that will
display the characteristics of foreign-born persons on U.S. maps, using
the above-mentioned Census 2000 data. It is scheduled to begin placing
them on our Web page later in 2006.

The Census Bureau is conducting research to prepare aggregate estimates
of legal status based on existing data. We are testing four
qualitatively different methods for constructing such estimates at the
national level.

The Census Bureau has expanded its use of questions on language use and
ability in recent years, but there are few opportunities to continue
this trend in the immediate future. The SIPP added a question on
language use beginning in 2003. However, the new Dynamics of Economic
Well-Being Program, which will replace SIPP, will have reduced content.
This will make it difficult to expand the series of questions on
language use and ability.

The CPS and ACS are also not good targets for adding new content on
language use. The CPS does not currently have a language use question at
all. The ACS question, as mentioned in the original Census Bureau
response, is identical to the question asked in each census since 1980.
Given the sensitivity of responses to small modifications in question
wording, a change would likely disrupt the time series. The benefits of
any modification to the question would have to be weighed against this
drawback.

Finally, there are practical limits to using Census Bureau
questionnaires to measure literacy in various languages, in that our
surveys have not traditionally contained "tests" of the population, and
it would require a policy change to move in this direction.

The Census Bureau welcomes the opportunity to provide the committee with
an update on the work of the Immigration Statistics Staff. The Census
Bureau provided an update to the Asian Committee of REAC at their May
2006 meeting and can provide an update to the PAA/AC at a future
meeting.

**[Recommendation 12 (GEO)]{.underline}**

**Resubmitted Recommendation: MAF/TIGER**

**[Population Association of America Advisory Committee]{.underline}**

"At the October 2005 CACPA meeting, the PAA/AC recommended that the
Census Bureau provide an inventory of internal MAF uses to the committee
before the May 2006 meeting and give a presentation on these uses at
that meeting. This would provide a better understanding of the multiple
uses of the MAF/TIGER database for Census Bureau operations and would
aid in integrating operations.

The response from the Census Bureau to the above was inadequate
concerning the level of detail about the universe selected for each
survey. Therefore, the PAA/AC is resubmitting this recommendation. (See
Recommendation 6, October 20-21, 2005, CACPA meeting)."

**[Census Bureau Response]{.underline}**

We do not fully understand why the previous response was not accepted,
and would be happy to discuss with you during your review of the
recommendations at the upcoming fall 2006 CACPA meeting.

**[Recommendation 13]{.underline}**

**Resubmitted Recommendation: Institutional Review Boards**

**[Population Association of America Advisory Committee]{.underline}**

"The PAA/AC reiterates and clarifies its previous Recommendation 2B (A)
from the

October 20-21, 2005, CACPA meeting.

Census users, particularly at universities, must routinely convince
their own Institutional Review Boards (IRBs) that the public use data
they employ qualify for an exemption from an institutional human
subjects review on their campus. The PAA/AC recommends that the Census
Bureau post on its web site a brief statement that users can adopt
addressing IRB concerns, such as the absence of personally identifying
information in census public use records."

**[Census Bureau Response]{.underline}**

The Census Bureau uses statistical methods to ensure that the statistics
we release do not identify individuals or businesses. These methods
include extensive review and analysis of all our data products, as well
as disclosure avoidance methodologies, such as data suppression and
modification to screen out data that might identify a specific
individual or business. To ensure these measures are implemented, the
Census Bureau has an internal Disclosure Review Board (DRB). This board
sets the confidentiality rules for all data product releases. A
checklist approach is used to ensure that potential risks to the
confidentiality of the data are considered and addressed before any data
are released. In addition, our Data Stewardship efforts extend beyond
the law to ensure that any decisions we make will fulfill our ethical
obligations to respect respondent privacy and protect the
confidentiality of the information entrusted to us. Our Privacy
Principles - *Necessity, Openness, Respect* and *Confidentiality* -
remind us of this promise and help to ensure the protection of personal
information throughout all of our activities. Further, they help to
guide us as we design surveys to consider respondents' rights and
concerns.

Information about how we protect personal information, including our use
of statistical safeguards and our Data Stewardship Program and policies,
is available on the Census Bureau Web site and can be accessed via the
following link:
\<[[http://www.census.gov/privacy/files/data_protection/002825.html]{.underline}](http://www.census.gov/privacy/files/data_protection/002825.html)\>.

**[Recommendation 14]{.underline}**

**Additional Recommendation: National and State Population Projections**

**[Population Association of America Advisory Committee]{.underline}**

"The PAA/AC is concerned about the Census Bureau's ability to produce
timely comprehensive population projections for the U.S. as a whole and
its states. The interim national projections consistent with Census 2000
were released in March 2004 and the interim state projections consistent
with Census 2000 were released in April 2005. Final national projections
consistent with the 1990 census were not released until January 2000 and
final state projections consistent with the 1990 census have still not
been released (although "state projections consistent with the 1990
census" were released in October of 1996).

The PAA/AC recommends that steps be taken such that a set of final
national and state projections consistent with the 2000 census can be
released before 2010."

**[Census Bureau Response]{.underline}**

The Census Bureau appreciates the interest of the committee in its
Population Projections Program and regrets the delay. We are moving to
replace two senior members of the Population Projections Branch who have
died in the last 12 months, (including the chief of the Branch), and one
other professional who retired. A set of national and state population
projections consistent with Census 2000 will be produced and
disseminated well before 2010.

**[Recommendation 15]{.underline}**

**Additional Recommendation: Meeting Materials**

**[American Statistical Association Advisory Committee]{.underline}**

"The ASA/AC requests that a single set of materials be compiled for the
meetings and sent to the Advisory Committee members at least two weeks
prior to the meeting."

**[Census Bureau Response]{.underline}**

The Census Bureau agrees that more timely transmittal of meeting
materials to members is key to a productive discussion of Census Bureau
issues. Your request that we provide a single set of meeting materials
two weeks in advance is not unreasonable. On occasion, however, we may
find it prudent to provide individual documents separate from the full
set, on an earlier schedule, to facilitate pre-meeting conference calls
with members or other needs. Similarly, as each paper presented at your
meetings is specifically developed by program managers to facilitate
advisory committee discussions, there may be an occasional instance
where final revisions may delay our provision of a finished paper with
the full set or within this time frame. These instances are infrequent,
however, and should not interfere with our goal of providing the full
set of documents to you within two weeks of the meetings.

**[Recommendation 16]{.underline}**

**Additional Recommendation: Timeliness of Responses to
Recommendations**

**[Population Association of America Advisory Committee]{.underline}**

"The Census Bureau's response to recommendations from the October 20-21,
2005 meeting was not sent to advisers until two days before the May
18-19, 2006 meeting. The PAA/AC members had no time to review this
document and could not direct questions to appropriate Census Bureau
staff during the meeting. The PAA/AC urges the Census Bureau to remedy
this situation for future meetings."

**[Census Bureau Response]{.underline}**

We are as distressed about the timing as is the Advisory Committee. We
have improved the procedure to expedite the review by all senior staff.

**[Recommendation 17]{.underline}**

**Additional Recommendation: Timeliness of Information on Meeting
Agenda**

**[Population Association of America Advisory Committee]{.underline}**

"In order to facilitate its work, the PAA/AC requests that the Census
Bureau inform the committee of topics and presentations at future CACPA
meetings as soon as these are available."

**[Census Bureau Response]{.underline}**

It is vital for the Advisory Committee's advice to be both timely and
relevant to ongoing Census Bureau activities. For that reason, we
sometimes delay the approval of the final agenda until we are clear
about the topics for which we need advice. On the other hand, it is
important that the Committee get the background material as far in
advance as possible; suggesting an early decision about topics is
useful. These tradeoffs sometimes delay the final decision, but we will
make every effort to decide on the agenda for forthcoming meetings as
quickly as possible and then inform the Committee.