United States General Accounting Office

GAO Testimony

Before the Subcommittee on Government Management,

Information, and Technology

Committee on Government Reform and Oversight

House of Representatives

For Release on Delivery

Expected at

9:30 a.m. EDT

Wednesday

April 23, 1997

STATISTICAL AGENCIES

Collection and Reporting of

Race and Ethnicity Data

Statement of Bernard L. Ungar, Associate Director

Federal Management and Workforce Issues

General Government Division

GAO/T-GGD-97-92

Statement 

Statistical Agencies: Collection and

Reporting of Race and Ethnicity Data

Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today to discuss the reporting of race and ethnicity

data. Our testimony today focuses on two issues you asked us to address:

(1) our prior work on the collection and reporting of race and ethnicity

data by the Bureau of the Census for the decennial census, as well as by

other federal agencies; and (2) state reporting of race and ethnicity data to

federal agencies for health and educational purposes. My comments are

based on our prior work in this area, our current monitoring of plans and

preparations for the 2000 Decennial Census, and limited data collection we

did in selected states in April 1997 in response to your request.

Over the years, our work has shown that the collection of these types of

data is technically complex and publicly controversial. It is technically

complex because race and ethnicity are not objectively definable

characteristics, making measurement difficult. Also, in many instances, a

person self-identifies his or her own race and ethnicity; in other instances

another party may categorize that person’s race and ethnic designation by

observation, which can produce inconsistent results. In addition, the

manner in which different organizations may ask for racial or ethnic

information, as well as how this information is compiled or aggregated,

can lead to inconsistent results. Measurement of race and ethnicity is also

controversial because some individuals have strong feelings about how

they are classified and are uncomfortable, when presented with a list of

classifications, if a particular “category” is not available for them to select.

For example, some people who are multiracial want to be able to reflect

this heritage by designating themselves as such; however, they may not be

provided this choice. Alternatively, some people may oppose the use of a

multiracial category because it could result in a reduction in the number of

individuals classified in their racial category, and they view this as

potentially reducing any benefits this particular group may receive. Some

state and federal program or administrative officials raise concerns about

a multiracial category because it may (1) add costs from the need to

change forms and computer software, (2) not provide any analytical

benefits, or (3) result in reporting inconsistencies and impede analyses of

trends.

Background The United States government has long collected statistics on race and

ethnicity. Such data have been used to study changes in the social,

demographic, health, and economic characteristics of various groups in

the population. Federal data collections, through censuses, surveys, and

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administrative records, have provided a historical record of the nation’s

population diversity.

Since the 1960s, data on race and ethnicity have been used extensively in

civil rights monitoring and enforcement covering such areas as

employment, voting rights, housing and mortgage lending, health care

services, and educational opportunities. Legislatively based requirements

in these areas created the need among federal agencies for compatible,

nonduplicative data for the specific population groups that historically had

suffered discrimination and differential treatment on the basis of their race

or ethnicity. We have attached a listing of some of the statutes that require

the collection and reporting of racial or ethnic data.

In the mid-1970s, the Office of Management and Budget (OMB), in

conjunction with several federal agencies, undertook a collaborative effort

to standardize racial and ethnic data collected and published by federal

agencies. The result of this effort was OMB’s 1977 publication of the “Race

and Ethnic Standards for Federal Statistics and Administrative Reporting”

contained in Statistical Policy Directive No. 15. These standards also

implemented the requirements of Public Law 94-311 of June 16, 1976,

which called for the collection, analysis, and publication of economic and

social statistics on persons of Spanish origin or descent. Directive 15,

which has not been changed since it was initially published, provides

standard classifications for recordkeeping, collection, and presentation of

data on race and ethnicity in federal program administrative reporting and

statistical activities. These classifications include four races—American

Indian or Alaskan Native, Asian or Pacific Islander, Black, and White; and

one ethnicity—Hispanic origin or not of Hispanic origin.

The standard collection categories are to be used for (1) civil rights

compliance reporting by both the public and private sectors and all levels

of government; (2) new and revised general program administrative and

grant reporting by federal agencies; and (3) statistical reporting by federal

agencies. According to OMB’s Chief Statistician, even though states are

not directed to follow OMB’s guidance except when reporting to the

federal government, in practice they generally do. The Directive states that

its purpose is not to limit the collection of data to the five categories—four

racial and one ethnic. However, any required reporting that uses more

detail must be organized in such a way that the additional categories can

be aggregated into the basic racial/ethnic categories. One notable

exception to the standard has been the Bureau of the Census, which was

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granted an exemption allowing it to include an “other” (write-in) response

to the race question in the 1980 and 1990 Censuses.

During the past several years, the standards have come under increasing

criticism from those who believe that the minimum categories set forth in

Directive No. 15 do not reflect the increasing diversity of our nation’s

population. Some have also proposed changing the names of some

categories. Because of these criticisms, OMB is in the process of

determining whether Directive No. 15 should be modified. Among the

changes being considered are whether a multiracial category should be

included; and whether “race/ ethnicity” should be asked as a single

identification, or whether “race” identification should be separate from

Hispanic origin.

Collection of Race

and Ethnicity Data by

the Bureau of the

Census and Other

Federal Agencies

Even if federal classifications for race and ethnicity were agreed upon, it is

extremely difficult to obtain accurate and consistent data on the number

of individuals within each classification. Our prior work on the Bureau of

the Census’ collection of race and ethnicity data during the 1990 Census

indicates that the question or questions used to elicit information on an

individual’s race and ethnicity will affect how an individual classifies

himself or herself. Consequently, if the results of different surveys using

different questions or a different series of questions to obtain race and

ethnic data from the same population were compared, it would be likely

that different proportions of respondents would be classified as White,

Black, Asian or Pacific Islander, or American Indian or Alaskan Native; or

of Hispanic origin. This work also demonstrated that external pressures on

the Bureau can result in the use of questions that may not provide as

accurate a count of racial and ethnic groups as would be possible if other,

alternative questions were used. Our prior work on federal agencies’ use

of race and ethnic definitions found that other factors can also affect the

quality of racial and ethnic data collected, including the fact that all states

may not use the same classifications as the federal government, and the

fact that some racial and ethnic data are obtained by

observer-identification rather than by self-reporting.

1990 Decennial Census

Experience With Collecting

Race and Ethnic Data

In 1993, we reported and testified that experience from the 1990 Decennial

Census provided valuable lessons for future censuses.1

 One lesson was the

need to develop a consensus on the race and ethnicity questions as early in

1

Federal Data Collection: Measuring Race and Ethnicity Is Complex and Controversial

(GAO/T-GGD-93-21, April 14, 1993) ; and Census Reform: Early Outreach and Decisions Needed on

Race and Ethnic Questions (GAO/GGD-93-36, Jan. 28, 1993).

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the decade as possible. Another was the need for the Bureau of the Census

to continue efforts to improve race and ethnic data quality to ensure that

the quality of data collected is acceptable.

Consensus Not Achieved In the 1990 Census, the Bureau was unable to build a consensus on its

recommended version of how Asian and Pacific Islanders were to be

represented in the race question despite implementation of a special

testing and consultation program. As a result, the final format of the race

question was decided late in the decade after protracted debate and was

contrary to the Bureau’s initial recommendations.

The Bureau, after testing alternative versions of the Asian and Pacific

Islander questions during the 1986 Los Angeles, Mississippi, and National

Content tests, among other tests, determined that a short version of the

race question was likely to produce data on the Asian and Pacific Islander

population that was as good as other test versions of the race question.

The short version provided a space for Asian and Pacific Islanders to write

in their specific groups, such as Chinese or Asian Indian. Other test

versions would have called for Asian and Pacific Islanders to mark

separate, prelisted, detailed groups of this racial category, as was done in

the 1980 Census. The Bureau’s research suggested that the write-in option

would produce a somewhat higher proportion of the population reporting

as Asian and Pacific Islanders than would the use of a question with

prelisted groups. Despite its research, the Bureau was unable to convince

the Asian and Pacific Islander community that the short version of the race

question should be used. Responding to congressional direction and

pressures from the Asian and Pacific Islander community, the Bureau

reconsidered its original decision and chose to include in the 1990 census

a version of the race question with prelisted Asian and Pacific Islander

categories.

This experience demonstrated the need for the Bureau to begin to work

early in the decade to work with a diverse group of customers, including

organizations representing the interests of various race and ethnic groups,

to identify data needs for the 2000 census and the best ways these needs

can be met. In congressional hearings, representatives of the Asian Pacific

Islander community said that the Bureau had not solicited their

participation in the early phases of redesigning the race question. The

advisory committees representing minority communities had not been

established until 1986 for the 1990 Census. This was the same year that the

major tests were held that drove the debate on the race question and the

Bureau’s initial recommendation. Several representatives said that the

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Bureau had already formulated the census questions before the

committees began to meet.

In contrast to the situation in preparation for the 1990 census, Census

advisory committees for the 2000 census were chartered in February 1994.

These committees included the African-American Population, American

Indian and Alaska Native Populations, Asian and Pacific Islander

Populations, and the Hispanic Population. The committees held a series of

meetings during 1995 prior to the June 1996 National Content test, at

which time the Bureau tested several variations of questions designed to

obtain race and ethnicity information. Another meeting of these advisory

committees was held in December 1996 to discuss major findings from

that survey. According to Census officials, the results of this survey and

the race and ethnicity tests should be available in early May 1997.

Data Quality Issues Census Bureau evaluations suggested that the data from the 1990 race and

Hispanic origin questions were generally of high quality. However, the

evaluations also suggested that some problems associated with collecting

data on Hispanics that confronted the Bureau in 1980 continued. For

example, in both the 1980 and 1990 Censuses, the Bureau found that

Hispanics had difficulty classifying themselves by race, and this difficulty

led to inconsistent reporting by Hispanics when they initially completed

the census questionnaire compared to their responses when they were

interviewed as part of a quality check. Also, for both the 1980 and 1990

Censuses, the Bureau estimated that nearly all—97.5 percent in 1990 and

95 percent in 1980—of the respondents who reported being in the “other

race” category were persons of Hispanic origin.

The problems experienced in connection with the Hispanic origin question

stemmed, at least in part, from the format and sequence of the Hispanic

origin and race questions. According to the Bureau, both Hispanics and

non-Hispanics have had difficulty dealing with this issue. Some Hispanics

equate their “Hispanicity” with race and have had difficulty classifying

themselves by the standard race categories. In 1990, about 40 percent of

Hispanics marked the “other race” category; they either indicated they

were Hispanic in the Hispanic origin question or indicated they were

Hispanic in the write-in space provided in the race question. According to

the Bureau, some non-Hispanics, having already responded to the race

question, skipped over the Hispanic origin question when they should have

indicated that they were not of Hispanic origin.

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As part of OMB’s ongoing effort to determine whether Statistical Policy

Directive 15 should be revised, OMB and the Census Bureau are working

together to determine whether race/ethnicity should be asked as a single

identification or whether the race identification should be separate from

Hispanic origin or other ethnicities. Research on the effect of keeping

race/ethnicity as a single identification or separate was conducted during

the May 1995 Current Population Survey conducted by the Census Bureau,

as well as during the June 1996 Race and Ethnic Targeted Test. Results

from the May 1995 survey indicated that, among other things, placing the

Hispanic origin question before the race question significantly reduced

nonresponse to the Hispanic origin question. The survey also found that

placing the Hispanic origin question before a race question that did not

include a multiracial option (1) reduced the percentage of persons

reporting in the “other race” category on the race question, and

(2) increased reporting by Hispanics in the White category of the race

question. The results of the June 1996 test are due in May 1997.

Agencies’ Use of

Consistent Race and

Ethnic Definitions

In our 1992 report on agencies’ use of consistent race and ethnic

definitions, we found that the eight agencies we reviewed, including the

Department of Health and Human Services and the Department of

Education, used the standard definitions of Directive No. 15 in the data

collection operations we examined.2

 However, we also found some

consistency problems in the agencies’ reporting when they used data not

controlled by federal collection rules or data based on

observer-identification.

The consistent use of definitions by federal agencies is to be accomplished

by an OMB control procedure that is designed to help ensure that

standards are properly incorporated in data collection efforts. OMB’s

Office of Information and Regulatory Affairs is required to approve all

federal data collection instruments and methodologies before an agency

begins collecting data. This control process is designed to monitor the use

of standards in the development of the data collection methodologies. In

our 1992 report, we found that another practice that helps ensure that the

policy’s definitions are followed is the federal statistical agencies’

extensive use of the Census Bureau support and products that also are

governed by the rules of Directive No. 15. For example, the National

Center for Education Statistics (NCES) and the National Center for Health

Statistics (NCHS), as well as other federal agencies, use elements of the

2

Federal Data Collection: Agencies’ Use of Consistent Race and Ethnic Definitions (GAO/GGD-93-25,

Dec. 15, 1992).

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Decennial Census or the monthly Current Population Surveys in their

reports. As a result, the data agencies use from these sources should have

been collected using methodologies that OMB has approved.

Inconsistent reporting of racial and ethnic data by federal agencies can

arise when an agency uses state-provided data. The management of stateor local-generated data is outside of federal jurisdiction. State-provided

data can be inconsistent, for example, if states categorize race and

ethnicity differently, if state data are incomplete, or if states categorize

multiracial/ethnic peoples differently than specified by OMB Directive No.

15. Some school districts collecting race and ethnic data also use a special

category to classify people of mixed race or ethnicity, thus creating

difficulties when data contained in this category are aggregated into the

five Directive 15 categories. State use of a multiracial category could

become a greater potential source of inconsistency in the future, because

the number of multiracial and ethnic families has grown significantly over

the last 20 years.

Inconsistent reporting of racial and ethnic data can also arise when others

determine an individual’s race or ethnicity, generally from observation.

OMB’s Directive recommends that the category most closely reflecting the

individual’s recognition in his community should be used for purposes of

reporting on persons who are of mixed racial and/or ethnic origins.

Department of Education officials told us that some states determine a

student’s race or ethnicity by that of the mother, whereas others use the

father’s race or ethnicity. Because the label applied by state policy may not

be the same label applied had OMB’s guidance been used, inconsistencies

may arise in the racial categorization of those of mixed race.

State Collection of

Race and Ethnicity

Data for Health and

Educational Purposes

States collect data on race and ethnicity in various programs, often to

comply with federal requirements. You asked that we provide information

on the types of race and ethnicity data states are collecting in the areas of

health and education. You specifically asked us to include information on

states that have enacted laws requiring the use of a multiracial category.

To respond to your request, we focused on state reporting of race and

ethnic data on births and deaths in the health area and on student

enrollment in public schools in the education area. At the federal level,

NCHS and NCES have responsibility for compiling and reporting data

nationally on these topics and work cooperatively with the states to obtain

the data. Accordingly, we obtained information from NCHS and NCES on

their process for collecting state data as well as from a study recently

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sponsored by NCES on racial and ethnic classifications used by public

schools.

In addition, we obtained information on the collection of race and ethnic

data from health departments in nine states—Alabama, Georgia, Illinois,

Indiana, Maryland, New Jersey, Ohio, Texas, and Washington. Of these

nine states, Georgia and Indiana have implemented state laws requiring all

state agencies to use a multiracial category under certain circumstances.

We also contacted education officials in the District of Columbia and in 12

states—California, Georgia, Illinois, Indiana, Maryland, Michigan, North

Carolina, New York, Ohio, Pennsylvania, Texas, and Virginia—as well as

representatives from 23 local school systems in 8 of these jurisdictions. Of

those states, five have laws requiring the use of a multiracial category

under certain circumstances. We contacted local school representatives to

get an indication of the types of racial and ethnic data schools were

collecting and, if the state had implemented a law or requirement for use

of a multiracial category, whether schools were implementing the

requirement. We selected the five states that have laws requiring schools’

use of a multiracial category and North Carolina because it has

administratively mandated the use of a multiracial category in its school

system. We judgmentally selected local school systems to achieve

geographic dispersion. Due to the limited scope of our work, we cannot

project our findings to jurisdictions or school systems we did not contact.

Health department officials in all nine states said they are collecting race

and ethnicity data from birth and death certificates, aggregating these

data, and reporting the data to NCHS, in accordance with guidance and

instructions provided by NCHS. According to these officials, the guidance

and instructions used conform to OMB’s Statistical Directive No. 15.

State education officials in the 12 states and the District of Columbia said

they are collecting race and ethnicity data from schools and aggregating

these data. Most of these officials said that data are reported to the federal

government in the five categories contained in the directive. Officials from

Georgia and Indiana, which are two states that have implemented

legislation requiring the use of a multiracial category, said they are

reporting race and ethnicity data to the federal government in the five

categories contained in the directive. However, in order to report these

data, these officials said that individuals in the multiracial category must

be allocated to the other racial and/or ethnic categories. In contrast, an

Ohio education official said that this state, which has a state law requiring

the use of a multiracial category, uses six categories to report these data,

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including a multiracial category. Based on discussions with state and local

education officials, the forms used to collect racial and ethnic information,

the categories used to classify race and ethnicity, and who classifies

students vary from school to school.

Five States Have Laws

Requiring the Use of a

Multiracial Category

Georgia, Illinois, Indiana, Michigan, and Ohio have enacted laws that

include the term multiracial with respect to collecting data on race and

ethnicity. Georgia, Indiana, and Michigan have passed legislation requiring

the addition of a multiracial category on all state forms that have a listing

of racial and ethnic classifications from which one must select. Illinois and

Ohio have similar legislation that applies only to educational departments

and schools; however, Illinois’ law specifies that the category of

multiracial is to be collected and reported only if the data are for state or

local use. Although Illinois’ and Ohio’s laws do not define multiracial, the

other three states’ laws define multiracial as having parents of different

races. For federal reporting purposes, laws in Georgia and Michigan

provide for reallocating multiracial individuals into the five federal

categories on the basis of the rate that the general population comprises

each classification. Ohio’s law, in contrast, requires that the parent,

guardian, or custodian of each student have the opportunity to designate

the appropriate federal racial category for the student. Georgia’s,

Indiana’s, and Ohio’s laws are being implemented. According to an

education official in Illinois, that state is delaying implementation of its

law until OMB makes a determination on revising Statistical Directive 15.

Michigan’s law, according to state education officials, is to be

implemented during the 1997-1998 school year when forms are scheduled

to be revised to include a separate question to collect data on whether the

individual is also multiracial. A summary of the scope and implementation

status of laws in the five states is attached to this statement.

Collection of Race and

Ethnicity Data for Health

Purposes

We focused our efforts on the collection of race and ethnicity data for

health purposes on data collected in connection with births and deaths.

NCHS is responsible for compiling national statistics on births and deaths.

To do this, it is to work cooperatively with state health departments which

administer birth registration and death reporting systems under the laws

and regulations of the states. Birth certificates are to be used to compile

annual vital statistics on the number and rate of births by such

characteristics as place of birth and residence of mother. Population

composition and growth are to be also estimated using these data, and the

data are to be used in planning and evaluating programs in public health

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and other areas. Information from death certificates is to be used for many

purposes, including assessing the general health of the population,

examining medical problems that may be more prevalent among certain

population groups, and identifying geographic areas with elevated death

rates from selected causes of death.

NCHS has developed model birth and death certificates that states can use

in recording vital data on births and deaths. Information on the birth

certificate can be provided by a number of individuals, including the

mother and/or father, a physician or other hospital personnel, or a

midwife. To obtain data on race and ethnicity, the model birth certificate

includes a question on whether the mother is or is not of Hispanic origin,

and the same question on the father as well. NCHS guidance clearly states

that this information is not part of the race item, and that a person of

Hispanic origin may be of any race. Thus, the Race and Hispanic origin

questions are asked independently in the model certificates. A blank space

follows the Hispanic origin question so that the person completing the

form can write in the race of the mother, as well as the race of the father.

Instructions for completing that block direct that the information should

be obtained from the parent or parents, or other informant, and that the

entry reflect the response of the informant. For Asians and Pacific

Islanders, the national origin of the mother and father, such as Chinese,

Japanese, Korean, Filipino, or Hawaiian, is to be entered. If the informant

indicates that the mother and/or father is of “mixed race,” both races or

ancestries are to be entered.

Birth certificates do not record the race of the child. Beginning in 1989,

NCHS guidance recommends that health officials categorize births by the

race of the mother, as recorded on the birth certificate. If the mother does

not state her race on the certificate, then the baby’s race is imputed to be

the race of the father. Prior to 1989, newborns with two parents of the

same race were classified as that race; newborns with one nonwhite

parent were classified as the race of the nonwhite parent. When both

parents were nonwhite but of different races, the newborn was assigned

the father’s race; except that if either parent was Hawaiian, the newborn

was classified as Hawaiian.3

With regard to death certificates, funeral directors are responsible for

getting the death certificate completed. Information is to be obtained from

3

This change in policy was brought about because it brought a more uniform approach to tabulating

the increased incidence of interracial births and nonmarital births than did the necessarily arbitrary

combination of parental races. In addition, the model birth certificate was modified in 1989 to include

more questions directly associated with the mother’s health and health behaviors.

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the spouse, one of the parents, children, or another relative of the

decedent, or a physician. In contrast to the birth certificate, which requires

data on whether the mother or father is of Hispanic origin and the race of

the mother or father, the death certificate requires this information on the

decedent.

According to officials in nine state health departments, these states follow

NCHS’ model and guidance when obtaining this information. Birth and/or

death certificates provided us by seven of these states confirmed that their

forms provide a space in which any race or racial makeup can be

provided. For reporting purposes, NCHS has developed a coding system

and guidance for categorizing and reporting race and ethnicity responses.

This guidance includes 7 codes for Hispanic origin, as well as up to 16

codes for race. The race category includes White, Black, Indian, five

categories for Asian or Pacific Islander, Other Entries, and Not Reported.

According to NCHS officials, an additional 6 coding categories for other

Asian or Pacific Islanders, for a total of 11, were being used by California,

Hawaii, Illinois, New Jersey, New York State, New York City, Minnesota,

Texas, and Washington. NCHS provides the option to other states on

whether to use the more detailed categories for Asian or Pacific Islanders.

If an individual were to record his or her race as more than one race on

the certificate, NCHS’ guidelines provide that the first race listed should be

used for coding purposes, or if the individual reports percentages, the race

having the highest percentage should be coded. Thus, even though an

individual can indicate a makeup of various races, for purposes of

aggregating the data, the individual is coded as belonging to one race by

health officials.

Of the nine states whose health departments we contacted, Georgia and

Indiana have laws requiring the use of a multiracial category when

collecting race and ethnicity data. According to a Georgia Department of

Public Health official, birth and death certificates were not modified to

accommodate the law because the law requires that forms be modified

only if they contain a list of categories from which one must select, and

Georgia’s birth and death certificates do not contain such a list. This

health department official said that when an individual indicates that he or

she is multiracial, the state obtains data on which races the individual

belongs to and then follows NCHS’ protocol for coding racial data. For

example, if Black is the first race mentioned, the person is coded as Black.

If White is the first race mentioned, the person is coded as White. This

official said that if some other race is mentioned first, the person is coded

as an “other” race because all of the other races are very small in the state.

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According to this official, the Department has also included a field in its

database to indicate if the individual considers himself or herself

multiracial. These data are separate and not reported to NCHS. This

official said that Georgia started collecting the multiracial data about 1 or

2 years ago, but that it has not used the multiracial data to perform any

special statistical analyses. Furthermore, he said that the number of

individuals classified as multiracial is small, and that the data would not

likely be used for analytical purposes because a racial designation is

generally not a good indicator of health problems. Likewise, Indiana’s law,

passed in 1995, requires the addition of a multiracial category on forms

that contain a listing of racial categories. An Indiana health official said

that the state has not changed its forms, practices, or procedures for

collecting racial or ethnic data on birth or death certificates. This state

uses birth and death certificates that do not contain a listing of categories.

According to this official, the health department has not added a separate

multiracial category in the state’s database so that the number of

multiracial persons could be tabulated by computer.

None of the officials in the seven state health departments we contacted

that do not require the category of multiracial indicated the need for one

or were sure of how it would be used if collected. For example, according

to an Illinois Department of Public Health official, the multiracial

classification would not be useful with respect to conducting vital

statistical or health analyses. According to this official, if additional data

were to be collected for vital statistical health analyses, these data should

include socioeconomic data. Similarly, an Alabama Department of Public

Health official stated that, currently, the state does not need a multiracial

category because, in her view, the state has a relatively few number of

individuals who could be classified as such. Therefore, she said that

NCHS’ classifications were currently sufficient for determining different

racial and ethnic groups’ lifestyles that affect health.

The Department of Health and Human Services’ National Committee on

Vital and Health Statistics, Subcommittee On Health Statistics for Minority

and Other Special Populations, has reviewed state legislation requiring the

use of a multiracial category. According to a subcommittee member, of

some concern to the subcommittee is the fact that some state laws call for

reallocating the number of multiracial people to OMB’s five categories for

federal statistics on the basis of the racial and ethnic distribution of the

general population. She also said that reallocating multiracial people on

this basis would tend to misrepresent the number of individuals in each of

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the five categories because the multiracial population does not have the

composition of the racial and ethnic distribution of the general population.

Collection of Race and

Ethnicity Data for

Educational Purposes

NCES is the primary federal organization for collecting, analyzing, and

reporting data related to education. NCES collects data through a variety

of means, including periodic surveys and data reported by states from data

contained in administrative records, including school enrollment records.

In 1994, NCES updated its 1974 national standards for student data to

establish current and consistent terms, definitions, and classification

codes to maintain, collect, report, and exchange comparable information

about students.4

 Its 1994 handbook, intended as a reference document,

includes the types of information that could be collected about individual

students and maintained in records, and discusses race/ethnicity

classifications and definitions. The racial and ethnic classifications and

definitions are those contained in OMB’s Statistical Directive No.

15—American Indian or Alaskan Native, Asian or Pacific Islander, Black,

Hispanic, and White. The handbook recommends that Blacks and Whites

be separate from Hispanic. That is, students should be classified as

Hispanic, Black (not Hispanic) or White (Not Hispanic).

In the spring of 1995, NCES sponsored a survey as part of the research

being conducted by OMB to review the current categories in its Statistical

Directive. NCES’ March 1996 report summarized its findings with regard to

racial and ethnic classifications used by public schools.5

 In summary,

73 percent of 926 public schools responded that they used only the five

standard federal categories to classify the race and ethnicity of students.

Of the remaining 27 percent of the schools, 10 percent responded that they

used “other” or “undesignated,” with space for indicating a specific race or

ethnicity; 5 percent used “other,” without space for specification; 7 percent

used additional racial and ethnic categories, such as “Filipino”; 5 percent

used a general multiracial category; and the remaining 2 percent used

specific combinations of the five standard federal categories or used an

“unknown” category (such as “Black/White,” or an “unknown” category).6

Additional differences were found in how racial and ethnic data were

4

National Center for Education Statistics: Student Data Handbook for Early Childhood, Elementary,

and Secondary Education, U.S. Department of Education, Office of Educational Research and

Improvement (NCES-94-303, June 1994).

5

National Center for Education Statistics: Racial and Ethnic Classifications Used by Public Schools,

U.S. Department of Education, Office of Educational Research and Improvement (NCES 96-092,

March 1996).

6

Percentages do not sum to 100 because respondents could select any and all categories that applied to

their schools.

Page 13 GAO/T-GGD-97-92
Statement 

Statistical Agencies: Collection and

Reporting of Race and Ethnicity Data

aggregated into the five federal categories before reporting the data to the

federal government, as well as differences in who identified the race and

ethnicity of the children. For example, about half of the 27 percent of

schools that used other classifications reported that the central district

office handled the task of aggregating this information, while many of the

remaining schools reported that students were allocated by the school

among the five standard federal categories based on which ones the

school considered most appropriate. With respect to who identified a

student’s race or ethnicity, 73 percent of the schools reported that they

asked parents. At 22 percent of the remaining schools, respondents

reported that teachers or administrators assigned students to categories

based on observation; while the remaining 5 percent reporting using some

other method. Most respondents reported that revisions to Directive No.

15 were not an issue or were only a minor issue in terms of their

applicability to students enrolled in their schools. However, between 3 and

12 percent of schools reported that issues such as adding a general

“multiracial” category, adding an “other” category, or changing the

terminology used in the racial categories was significant.

The 5 states that have already enacted laws requiring schools to add a

multiracial category were included in the 12 states and the District of

Columbia whose education departments we contacted. Of these five

states, three—Ohio, Georgia, and Indiana—said they have implemented

requirements that the multiracial option be included as a category when

selecting options for race and ethnicity. All of the eight local school

systems we contacted in these three states (three in Ohio, three in

Georgia, and two in Indiana) said they were using a multiracial category

for school enrollment. According to education department officials in Ohio

and Georgia, the legislation was the result of the efforts of a small group of

individuals in each of their respective states.

According to an Indiana Department of Education official, the schools in

Indiana are implementing the requirement in a variety of ways. For

example, in some instances school administrators may classify students

into different race and ethnic categories, while in other schools or school

systems, parents may classify their children. We contacted two schools in

Indiana and found that schools in that state were inconsistent in who

classified students into race and ethnic categories. The Indiana

Department of Education official said that when reporting data to the

federal government, the state Department of Education allocates those

students who are classified as multiracial into the Black, White, American

Indian or Alaskan Native, or Asian or Pacific Islander category on the basis

Page 14 GAO/T-GGD-97-92
Statement 

Statistical Agencies: Collection and

Reporting of Race and Ethnicity Data

of the percentage of these races in the state as a whole. The remaining two

states—Michigan and Illinois—have yet to implement their legislation.

According to Michigan Department of Education officials, Michigan was

allowed to use up its stock of forms prior to collecting the new data.

Currently, forms for collecting racial and ethnic data are being revised for

the 1997-98 school year. According to an Illinois State Board of Education

official, Illinois is not implementing its legislation until OMB reaches a

final decision on whether, and if so, how, Statistical Directive 15 is to be

revised.

A few states, such as North Carolina and Florida, have administratively

decided to collect multiracial data. According to a North Carolina

Department of Public Instruction official, the administrative order has

been in effect for the past 1 to 2 years and gives parents who wish to

classify their child as multiracial the option of doing so. School

registration forms we obtained from three North Carolina school systems

listed a multiracial category. Two North Carolina local school systems

provided space on their registration forms for race or ethnicity to be

written in; however, one of these local system’s guidance instructed school

administrators to code this information as Black, White, Hispanic,

American Indian, Asian, or Other. A North Carolina education official said

that currently, fewer than 200 of the 1.2 million students in that state’s

schools were estimated to be using the multiracial classification. This

official stated that schools within North Carolina could be using different

methods to classify these students as another race when aggregating race

and ethnic data for federal reporting purposes.

Several other states are considering including a multiracial category for

educational reporting purposes. For example, a California Department of

Education official said that a ballot measure is currently being considered

that would mandate the use of a multiracial category when collecting data

on students’ race and ethnicity. He said that the state uses OMB Statistical

Directive 15 to obtain data from the schools on race and ethnicity. The

state also collects data on individuals of Philippine origin due to a state

mandate. This official said that the state would need to resolve several

issues before adopting a multiracial category. These issues include the

cost of requiring that data be collected and the usefulness of the data to

the Department. For example, this official was not certain what utility the

multiracial category provided educators, or what educators could do with

these data if they had them.

Page 15 GAO/T-GGD-97-92
Statement 

Statistical Agencies: Collection and

Reporting of Race and Ethnicity Data

A Texas Education Agency official said that Texas is currently considering

a proposed bill that would include a multiracial category. Currently, the

state is looking at the practical implications of implementing the proposed

legislation. That is, the state is assessing the potential cost of requiring

these data be collected and ways that the new data could be linked to data

previously collected. According to this official, even though the state uses

OMB’s Statistical Directive No. 15 for federal reporting purposes, some

schools in the state collect additional data and break out the racial or

ethnic classifications in more detail than required.

The varying situations in the Washington D.C. metropolitan area with

regard to identifying race and ethnicity at the time of school enrollment

provide a good illustration of the complexity and controversial nature of

this issue. The school registration form used in the District of Columbia

provides a space for the parent or guardian of the child to write in a race

or ethnicity. Categories are not prelisted on the form. The school system,

however, tabulates data based on the five federal categories.

Virginia’s Department of Education has provided guidance to the state’s

school systems directing them to use the five categories specified in

Statistical Directive No. 15 when reporting data to the department, and

informing them that it can only accept data in these five categories.

However, an education department official said that schools can collect

any detailed data they want on students’ race and ethnicity. The city of

Alexandria uses OMB’s five categories for collecting data on school

enrollment, and school system representatives told us that the lack of a

multiracial category has not been a major issue. In contrast, Fairfax

County has added a multiracial category to its school registration form.

According to a school system representative, this category was added in

1994 as a result of concerns expressed by a number of county residents.

The school system allocates multiracial students to the other five

categories when aggregating data and reporting it to others. Arlington

County schools also use the five categories in OMB’s directive. However,

in 1993, the county added an “other” category out of concern that a

significant number of students did not fit into the five categories and so a

student or parent could use a classification other than those listed on the

school forms. However, Arlington County, after receiving a notice from the

state that it would not accept data reported in any categories other than

the five specified by OMB, discontinued using the “other” category in 1996.

Montgomery County, Maryland, schools prelist the five categories on its

school enrollment forms. An official of the Montgomery County schools

Page 16 GAO/T-GGD-97-92
Statement 

Statistical Agencies: Collection and

Reporting of Race and Ethnicity Data

said that some parents have expressed concern about there being only five

categories. The official said that the school board discussed the issue, but

has decided to wait to see what changes, if any, the federal government

makes. According to the official we spoke with, the issue is very much a

concern in Montgomery County schools because the county is home to

many multiracial families. In Prince George’s County, a school official told

us that the school system uses only the five standard categories but has

been approached about the issue of more categories on some occasions.

However, the school system is also under a federal court desegregation

order. The order requires the school system to report race and ethnic data

in a certain format to the court annually.

California provides another example of the diverse way in which racial

and ethnic data can be collected. California state education officials said

that even though the state reports racial and ethnic data to the federal

government in accordance with OMB’s guidance, schools in that state are

asked to break out race and ethnicity data into seven categories. These

categories include OMB’s classifications of White, Black, Hispanic,

American Indian or Alaskan Native, but the classification for Asian is

separated from Pacific Islander. As noted earlier, the state also separates

information on those of Philippine ancestry. However, these officials said

that schools may collect more detailed data to determine the

representation in their school districts. According to one state official, the

state does not dictate or control the amount or type of information schools

collect because such matters are believed best left to local control. San

Diego, for example, lists 19 racial and ethnic categories plus a multiracial

category on its school registration form. The instructions on the form state

that one of the 19 listed categories is to be selected, but that a person can

also select the multiracial category. If this latter category is chosen,

additional categories are to be written on the form. San Francisco’s city

schools use nine categories and do not use a multiracial category. Long

Beach collects only the seven state required categories of racial and ethnic

information, but also collects over 50 different language categories on

each student. Because the state may receive additional categories of racial

and ethnic data from some schools, the state, at times, has to aggregate the

data to conform to OMB’s five classifications. A state education official

said that this has not caused the state any problems.

Mr. Chairman, this concludes my prepared statement. I would be pleased

to respond to questions from you or other Members of the Subcommittee.

Page 17 GAO/T-GGD-97-92
Appendix I 

Examples of Federal Laws Requiring the

Collection of Data on Race and Ethnicity

Agency or program requiring race and

ethnic data Description of data requirement Legal authority

Federal Home Loan Mortgage Corporation The corporation is required to collect data

relating to its mortgages on housing

consisting of 1 to 4 dwelling units. These

data shall include the income, census tract

location, race, and gender of mortgagors.

12 U.S.C. § 1456(e)(1)(A)

Government National Mortgage Association

and Federal National Mortgage Association

The corporations shall collect data relating

to their mortgages on housing consisting of

one to four dwelling units. These data shall

include the income, census tract location,

race, and gender of mortgagors.

12 U.S.C. § 1723a.(m)(1)(A)

Community Development Financial

Institutions Fund

The Fund shall require each community

development financial institution or other

organization receiving Fund assistance to

compile such data, as is determined to be

appropriate by the Fund, on the gender,

race, ethnicity, national origin, or other

pertinent information concerning individuals

that utilize the services of the assisted

institution.

12 U.S.C. § 4714(b)

Department of Education, Office of

Educational Research and Improvement

All statistics and other data collected and

reported by the Office shall be collected,

cross-tabulated, analyzed, and reported by

sex within race or ethnicity and economic

status whenever feasible.

20 U.S.C. § 6011(j)(4)

Department of Education Shall carry out an ongoing evaluation of

programs designed to help disadvantaged

children meet high standards. The

evaluation shall, when feasible, collect,

cross-tabulate, and report data by sex within

race or ethnicity and socioeconomic status.

20 U.S.C. § 6491(c)(1)(e)

Department of Education, Office of

Educational Research and Improvement

Shall collect and report data for the National

Assessment of Educational Progress. The

data shall include information on special

groups, including, whenever feasible,

information collected, cross-tabulated,

analyzed, and reported by sex, race or

ethnicity, and socio-economic status.

20 U.S.C. § 9010(b)(1)(C)

Department of Labor, Rehabilitation

Services Administration

Requires an annual report on vocational

rehabilitation and other rehabilitation

services from information collected on each

client. The information shall set forth a

complete count of such cases in a manner

permitting the greatest possible

cross-classification of data. The data

elements shall include, but not be limited to,

age, sex, race, ethnicity, etc.

29 U.S.C. § 712

(continued)

Page 18 GAO/T-GGD-97-92
Appendix I 

Examples of Federal Laws Requiring the

Collection of Data on Race and Ethnicity

Agency or program requiring race and

ethnic data Description of data requirement Legal authority

Veterans Administration, Center for Minority

Veterans

Requires social and demographic research

on the needs of veterans who are minorities

and the extent to which veterans’ programs

meet the needs of minority veterans, without

regard to any law concerning the collection

of information from the public.

38 U.S.C. § 317(d)(5)

Department of Commerce Requires a survey to compile registration

and voting statistics. The survey and

compilation shall only include a count of

persons of voting age by race, color, and

national origin. The law also has a proviso

that no person shall be compelled to

disclose his race, color, or national origin

and that every person interrogated orally, by

written survey or questionnaire, or by any

other means shall be fully advised about his

right to refuse to furnish such information.

42 U.S.C. § 2000f.

Department of Housing and Urban

Development

Requires studies with respect to the nature

and extent of discriminatory housing

practices and requires information on the

race, color, religion, sex, national origin,

age, handicap, and family characteristics of

persons and households who are applicants

for, participants in, or potential beneficiaries

of, programs administered by the

Department of Housing and Urban

Development. The Department shall collect

the information relating to those

characteristics the Department determines

necessary and appropriate without regard to

any other provision of law.

42 U.S.C. § 3608(e)

Source: GAO analysis of selected legislation.

Page 19 GAO/T-GGD-97-92
Appendix II 

States With Laws Requiring a Multiracial

Category

State

Law

enacted

As of April 1997 is law

being implemented? Agencies covered

Georgia 1994 Yes All state agencies

Illinois 1994 No Schools

Indiana 1995 Yes All state agencies

Michigan 1995 No All state agencies

Ohio 1992 Yes Schools

Source: State laws and state officials.

(410133) Page 20 GAO/T-GGD-97-92
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