a

GAO

United States Government Accountability Office

Report to the Subcommittee on 

Technology, Information Policy, 

Intergovernmental Relations and the 

Census, Committee on Government 

Reform, House of Representatives

August 2004 2010 CENSUS

Counting Americans 

Overseas as Part of the 

Decennial Census 

Would Not Be 

Cost-Effective

GAO-04-898
www.gao.gov/cgi-bin/getrpt?GAO-04-898.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Patricia A. 

Dalton at (202) 512-6806 or 

daltonp@gao.gov. 

Highlights of GAO-04-898, a report to the 

Subcommittee on Technology, Information 

Policy, Intergovernmental Relations and 

the Census, Committee on Government 

Reform, House of Representatives 

August 2004

2010 CENSUS

Counting Americans Overseas as Part of 

the Decennial Census Would Not Be 

Cost-Effective 

The Bureau generally implemented the overseas census test on schedule and 

consistent with its research design. Still, participation was poor, with just 

5,390 questionnaires returned from the three test sites—France, Kuwait, and 

Mexico. Moreover, because of the low response levels, obtaining those 

questionnaires proved to be quite expensive—around $1,450 per response, 

which is far costlier on a unit basis than the 2000 Census. Although the two 

are not directly comparable because the 2000 Census included operations 

not used in the overseas test, the 2000 Census cost around $56 per 

household. Further, boosting the response rate globally might not be 

practical. On the domestic front, during the 2000 Census, the Bureau spent 

$374 million on a months-long publicity campaign that consisted of 

television and other advertising that helped yield a 72-percent return rate. 

Replicating this level of effort on a worldwide basis would be difficult, and 

still would not produce a complete count. Ensuring a smooth overseas 

count could also stretch the Bureau’s resources. For example, at each test 

site the Bureau encountered various challenges that needed to be resolved 

such as French privacy laws. Moreover, managing a complex operation from

thousands of miles away also proved difficult. 

Enumerating Americans in Mexico and France 

The approach used to count the overseas population in the 2004 test—a 

voluntary survey that largely relies on marketing to secure a complete count, 

lacks the basic building blocks of a successful census. The Bureau has done 

some initial research on alternatives, but all require more extensive review. 

Given that the Bureau already faces the difficult task of securing a 

successful stateside count in 2010, having to simultaneously count 

Americans abroad would only add to the challenges facing the Bureau. 

The U.S. Census Bureau (Bureau) 

has typically counted overseas 

members of the military, federal 

civilian employees, and their 

dependents. However, it usually 

excluded private citizens residing 

abroad. In July 2004, the Bureau 

completed a test of the practicality 

of counting all overseas Americans. 

GAO was asked to assess (1) 

whether the Bureau implemented 

the test consistent with its design, 

and (2) the lessons learned from 

the test results. 

Congress may wish to consider 

eliminating funding for additional 

research related to counting 

Americans abroad as part of the 

decennial census, including funding 

for tests planned in 2006 and 2008. 

However, funding for the 

evaluation of the 2004 test should 

continue as planned, particularly to 

inform congressional decision 

making on this issue. Should 

Congress desire better data on 

overseas Americans for certain 

policymaking and other 

nonapportionment purposes, 

Congress may wish to consider 

funding research on the feasibility 

of counting this group using 

alternatives to the decennial 

census. To facilitate this, we 

recommend that the Bureau, in 

consultation with Congress, 

research options such as a separate 

survey, administrative records, and 

data exchanges with other 

countries’ statistical agencies. The 

Bureau agreed with our 

conclusions and recommendations. 
Page i GAO-04-898 2010 Census

Contents

Letter 1

Results in Brief 2

Background 4

Scope and Methodology 6

2004 Overseas Test Was Generally Implemented as Designed 7

Overseas Census Test Results Were Disappointing and Costly 9

Conclusions 20

Matters for Congressional Consideration 21

Recommendations for Executive Action 21

Agency Comments and Our Evaluation 22

Appendix

Appendix I: Comments from the Department of Commerce 23

Tables Table 1: Key Components of Overseas Enumeration Were 

Generally Implemented as Planned 8

Table 2: Comparison of Responses Received for 2004 Overseas 

Census Test 9

Figures Figure 1: Key Decisions Facing Congress on Enumerating 

Americans Abroad 6

Figure 2: Census Bureau Ads Placed in the International Herald 

Tribune 10

Figure 3: Census Materials Were Prominently Displayed in Various 

Locations in France and Mexico 14

Figure 4: Key Building Blocks of a Successful Census 16

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Page 1 GAO-04-898 2010 Census

United States Government Accountability Office

Washington, D.C. 20548

A

August 19, 2004 Letr

The Honorable Adam H. Putnam

Chairman

The Honorable Wm. Lacy Clay

Ranking Minority Member

Subcommittee on Technology, 

Information Policy, Intergovernmental Relations

and the Census

Committee on Government Reform

House of Representatives

Although more than four million American citizens are believed to reside 

abroad, the precise number of overseas Americans is unknown. The U.S. 

Census Bureau (Bureau), the federal agency tasked with counting the 

nation’s population every 10 years, has generally included in the census 

overseas members of the military, federal civilian employees, and their 

dependents (a group known collectively as “federally affiliated” 

individuals), but has typically excluded private citizens such as retirees, 

students, and business people.1

Under the Constitution and federal statutes, the Bureau has discretion over 

whether to count Americans abroad. However, in recent years, the Bureau’s 

policy of excluding private citizens from the decennial census has been 

called into question. For example, advocates of an overseas census claim 

that better demographic data on this population group would be useful for 

a variety of policy-making and business purposes, and would better 

represent their unique interests in Congress. Moreover, in January 2001, 

Utah sued the Bureau’s parent agency, the U.S. Department of Commerce, 

claiming that it lost a congressional seat because the 2000 Census excluded 

the state’s 11,000 Mormon missionaries and other private citizens living 

abroad.2

 According to the Congressional Research Service, Utah would 

have gained a congressional seat had an additional 855 people been 

1

 Only the 1970, 1990, and 2000 Censuses used counts of federally affiliated personnel for 

purposes of apportioning Congress.

2 Utah v. Evans, 143 F. Supp. 2d 1290 (D. Utah 2001), aff’d, Utah v. Evans, 534 U.S. 1038 

(2001).
Page 2 GAO-04-898 2010 Census

included in the state’s apportionment totals.3 Utah’s suit, however, was 

unsuccessful. 

As we noted in our May 2004 report on this issue, counting Americans 

abroad as an integral part of the 2010 Census would be a monumental task 

that would introduce new resource demands, risks, and uncertainties to an 

endeavor that was already facing a variety of difficulties.4

 Specific 

challenges include policy questions such as who should be counted and 

how should the data be used, as well as logistical difficulties such as 

ensuring a complete count and verifying U.S. citizenship. 

To assess the practicality of counting overseas Americans, the Bureau held 

a test enumeration from February through July 2, 2004, in France, Kuwait, 

and Mexico. As agreed with your offices, we assessed (1) whether the 

Bureau implemented the test consistent with its design, and (2) the initial 

lessons learned from the test results and their implications for future 

overseas enumerations. 

To address these objectives, we reviewed applicable planning and other 

documents, and interviewed knowledgeable Bureau officials and 

representatives of private organizations who helped the Bureau promote 

the census at the three test sites. Further, to review how the Bureau was 

implementing the census at the test locations, we made on-site inspections 

in Paris, France, and Guadalajara, Mexico. We conducted our work from 

March through July 2004, in accordance with generally accepted 

government auditing standards. 

Results in Brief The Bureau generally implemented the 2004 overseas census test 

consistent with its research design. Key elements of the Bureau’s plan, 

such as developing a questionnaire specifically for overseas Americans and 

launching a marketing campaign designed to publicize the test, were 

generally carried out as planned. Moreover, the test was conducted on 

schedule. 

3

 Congressional Research Service, House Apportionment: Could Census Corrections Shift 

a House Seat?, RS21638 (Washington, D.C.: Oct. 8, 2003).

4

 GAO, 2010 Census: Overseas Enumeration Test Raises Need for Clear Policy Direction, 

GAO-04-470 (Washington, D.C.: May 21, 2004).
Page 3 GAO-04-898 2010 Census

However, the response levels fell far short of what the Bureau planned for 

relative to the number of questionnaires it printed. For example, although 

the Bureau printed about 520,000 census forms for the three test sites—

France, Kuwait, and Mexico—the actual number of paper responses it 

received only totaled 1,783, as of the end of the test in early July 2004. 

Another 3,607 responses were received via the Internet. Further, because 

of the low response levels, the data were expensive to obtain on a unit cost 

basis—around $1,450 per return. In contrast, the unit cost of the 2000 

Census was about $56 per household. Although the 2000 Census costs are 

not directly comparable to the 2004 overseas test because the 2000 test 

included operations not used in the overseas test, the 2000 Census was the 

most expensive census in our nation’s history. 

Further, substantially boosting overseas response levels might be 

infeasible. For example, during the 2000 Census, the Bureau spent $374 

million on a months-long publicity campaign that consisted of television, 

radio, and other forms of advertising that helped secure a 72-percent return 

rate. Replicating this level of effort on a worldwide basis would be 

impractical at best, and would not produce a complete count. Indeed, even 

after the Bureau’s aggressive publicity effort in 2000, it still needed to 

follow-up with about 42 million households that did not complete their 

census forms. 

Ensuring a smooth overseas count could also stretch the Bureau’s 

resources, and thus detract from domestic efforts. For example, at each 

test site the Bureau encountered various difficulties that needed to be 

worked out. The difficulties included addressing French privacy laws and 

delivery problems in Kuwait. Moreover, managing a complex operation 

from thousands of miles away was also hard. This was particularly evident 

in the logistical challenges the Bureau had in overseeing the performance 

of the private firm hired to publicize the census at the three test sites.

The Bureau’s longstanding experience in counting the nation’s population 

has made it clear that a cost-effective census is assembled from key 

building blocks that include mandatory participation, a complete and 

accurate address list, and the ability to follow-up with nonrespondents. 

The approach the Bureau used to count the overseas population—a 

voluntary survey that relies heavily on marketing to secure a complete 

count—largely for reasons of practicality, lacks these building blocks, and 

it is unlikely that any refinements to this basic design would produce 

substantially better results. What’s more, the Bureau already faces the 

difficult task of securing a successful stateside count in 2010. Having to 
Page 4 GAO-04-898 2010 Census

count Americans abroad would only add to the challenges facing the 

Bureau. 

Given the obstacles to a cost-effective count of overseas Americans as part 

of the decennial census, Congress may wish to consider eliminating 

funding for the research, planning, and development activities related to 

counting this population group using the Bureau’s current approach, 

including funding for tests planned in 2006 and 2008. However, funding for 

the evaluation of the 2004 test should continue as planned because it could 

provide useful data to Congress. Moreover, should Congress determine 

that a count of overseas Americans might be useful for certain policymaking and other nonapportionment purposes, Congress may wish to 

consider authorizing and funding research on the feasibility of counting 

Americans abroad using alternatives to the decennial census. 

To facilitate congressional decision making, we recommend that the 

Bureau, in consultation with Congress, research potential alternatives to 

the decennial census such as conducting a separate survey, examining how 

administrative records could be refined to produce a more accurate count 

of overseas Americans, and exchanging data with other countries’ 

statistical agencies and censuses, subject to applicable confidentiality and 

other provisions. Once Congress knows the tradeoffs of these various 

options, it would be better positioned to provide the Bureau with the 

direction it needs so that the Bureau could then develop and test an 

approach that meets congressional requirements at reasonable resource 

levels.

The Secretary of Commerce forwarded written comments from the U.S. 

Census Bureau on a draft of this report. The comments are reprinted in the 

appendix. 

The Bureau agreed with our conclusions and recommendations. 

Furthermore, the Bureau noted, “should Congress request and fund” 

further research on counting overseas Americans, it would be equipped to 

do that research itself.

Background According to the Bureau, no accurate estimate exists of the total number of 

Americans living abroad. The Constitution and federal law give the Bureau 

discretion to decide whether to count American citizens living abroad. In 

prior censuses, the Bureau has generally included “federally affiliated” 

groups—members of the military and federal employees and their 
Page 5 GAO-04-898 2010 Census

dependents—but has excluded private citizens residing abroad from all but 

the 1960 and 1970 Censuses. The 2000 Census, using administrative 

records, found 576,367 federally affiliated Americans residing overseas, 

including 226,363 military personnel, 30,576 civilian employees, and 

319,428 dependents of both groups. 

In response to congressional direction and the concerns of various private 

organizations, the Census Bureau launched a research and evaluation 

program to assess the practicality of counting both private and federally 

affiliated U.S. citizens residing abroad. The key part of this effort, the 

enumeration, took place from February 2004 through July 2, 2004, in 

France, Kuwait, and Mexico. To promote the overseas census test the 

Bureau relied on third parties—American organizations and businesses in 

the three countries—to communicate to their members and/or customers 

that an overseas enumeration of Americans was taking place and to make 

available to U.S. citizens either the paper questionnaire or Web site 

address. 

Currently, the Bureau is processing and analyzing the overseas 

questionnaire data and plans to complete an evaluation of the test results in 

early 2005. The Bureau estimates that it will have spent approximately $7.8 

million in fiscal years 2003 through 2005 to plan, conduct, and evaluate the 

2004 test. The Bureau has requested additional funds for fiscal year 2005 to 

plan for further testing scheduled for 2006. The Bureau also plans to 

include overseas testing in the 2008 dress rehearsal if it were to receive the 

necessary funding.5

 

In May 2004 we reported on the design of the overseas enumeration test 

and concluded that because of various methodological limitations, the test 

results will only partially answer the Bureau’s key research objectives 

concerning feasibility (as measured by such indicators as participation and 

number of valid returns), data quality, and cost. Further, we noted that the 

Bureau should not decide on its own whether or not to enumerate 

Americans overseas, and in fact would need congressional guidance on 

how to proceed. As shown in figure 1, the key decisions facing Congress in 

this regard include, in addition to the threshold question of whether 

American residing overseas should be counted, how the data should be 

5

 At this point, the Bureau does not have cost data beyond fiscal year 2005. Therefore, it is 

unknown what the costs will be for implementing and evaluating the 2006 overseas test or 

the 2008 overseas dress rehearsal.
Page 6 GAO-04-898 2010 Census

used and whether to enumerate this population group as part of the 

decennial census. 

Figure 1: Key Decisions Facing Congress on Enumerating Americans Abroad 

We also recommended that if further testing were to occur, that the Bureau 

resolve the shortcomings of the design of the 2004 test and better address 

the objectives of an overseas enumeration.

Scope and 

Methodology

As agreed with your offices, our objectives for this report were to assess 

(1) whether the Bureau implemented the test consistent with its design, 

and (2) the initial lessons learned from the test results and their 

implications for future overseas enumerations. To assess the first objective, 

we interviewed Bureau officials and compared the Bureau's test plans with 

what was actually done at the three test sites. We visited Paris, France, and 

Guadalajara, Mexico, to obtain the views of 12 private, civic, and other 

Yes

Yes No

Source: GAO analysis.

No

Would 

introduce new 

resource 

demands, risks, 

and challenges

For purposes of 

congressional

apportionment 

and/or 

redistricting?

No further 

research and 

development

Consider 

counting 

Americans 

abroad via other 

data collection 

efforts 

Should 

Americans 

abroad be 

counted?

How should data be used?

Enumerate as 

part of 

decennial 

census
Page 7 GAO-04-898 2010 Census

organizations on the implementation of the overseas census test, and/or to 

confirm at 36 organizations the availability of census material. In addition, 

to a more limited extent, we interviewed officials from third party 

organizations in Kuwait via the telephone or e-mail. We judgmentally 

selected these organizations because they had agreed to display census 

promotional materials and, in some cases, had also agreed to do one or 

more of the following activities: make available paper copies of the census 

questionnaire, publish information in a newsletter, post a link to a Web site, 

send outreach e-mail to members, and/or create speaking opportunities to 

discuss the census. The results of these visits are not necessarily 

representative of the larger universe of third-party organizations. 

To assess the implications of the test results on future overseas 

enumerations and the 2010 census, we obtained from Bureau officials 

preliminary results of the overseas census by test site and response mode 

as well as cost data. We also interviewed officials from the Bureau and 

third-party organizations to determine what lessons were learned from the 

test and the implications on future overseas enumeration efforts. 

2004 Overseas Test 

Was Generally 

Implemented as 

Designed

The Bureau’s design for the 2004 overseas enumeration test was generally 

implemented as planned and completed on schedule. The Bureau’s design 

had four key components: the mode of response, the questionnaire 

designed specifically for Americans living overseas, three test sites, and an 

outreach and promotion program designed to communicate and educate 

Americans abroad that a test census was being conducted. Table 1 

describes each of these components in greater detail.
Page 8 GAO-04-898 2010 Census

Table 1: Key Components of Overseas Enumeration Were Generally Implemented as Planned

Source: GAO.

However, while the test was generally implemented as designed, our earlier 

report pointed out several methodological limitations with the design, such 

as not being able to calculate response rates because the universe of 

Americans is unknown or not being able to measure the quality of data 

because of the impracticality of developing an address list. As we discuss 

later in this report, it is these methodological limitations that impede the 

Bureau’s ability to implement a successful overseas enumeration. 

Key overseas test 

component What the Bureau planned

Generally 

implemented 

as planned? GAO observations

Census form response 

mode

Census questionnaire will be available 

in paper format or via the Internet.

Yes Paper version of the census form was available at 

various locations at the test sites.

Questionnaire was available for completion on the 

Internet. 

Paper version was also available in Spanish in 

Mexico. 

Census test questions 2000 decennial short form 

questionnaire will be modified for the 

overseas enumeration.

Yes Asked respondents to provide their passport 

numbers and social security numbers to verify 

citizenship.

Asked respondents about their employment status—

military, federal, or other. 

Asked for information on everyone in the household 

even if the person was not a U.S. citizen.

Test sites Conduct test in three geographically 

diverse areas with large American 

populations, and where administrative 

records may be available to help verify 

results. 

Yes Overseas test was implemented in three countries: 

France, Kuwait, and Mexico. 

Outreach/

Promotion 

Contract with a public relations firm to 

develop a communications strategy to 

inform and motivate respondents living 

in the selected countries to answer the 

census. 

Yes Public relations firm hired to develop a 

communication strategy.

Strategy relied on public and private organizations in 

each of the test sites.

Organizations displayed promotional materials about 

the test, communicated test census to members, and 

distributed the paper census forms to American 

residents. 
Page 9 GAO-04-898 2010 Census

Overseas Census Test 

Results Were 

Disappointing and 

Costly

Although the 2004 overseas enumeration test ended in early July 2004 and 

the Bureau has just begun evaluating the results, the response levels were 

poor, and very expensive to obtain on a per unit basis. The response level 

to the overseas enumeration suggests that the current approach to 

counting overseas Americans—a voluntary survey that relies heavily on 

marketing to get people to participate—by itself cannot secure a successful 

head count. Further, obtaining the additional resources needed to produce 

substantially better results may not be feasible, and still not yield data that 

are comparable in quality to the stateside enumeration. 

Response Levels Were 

Disappointing and Costly to 

Obtain 

The 5,390 responses the Bureau received for this test were far below what 

the Bureau planned for when printing up materials and census forms. 

While the Bureau ordered 520,000 paper forms for three test sites, only 

1,783 census forms were completed and returned. Of these, 35 were 

Spanish language forms that were made available in Mexico. The 

remaining 3,607 responses were completed via the Internet. Table 2 below 

shows the number of census questionnaires that the Bureau printed for 

each country and the number of responses they actually received in both 

the paper format and via the Internet. 

Table 2: Comparison of Responses Received for 2004 Overseas Census Test

Source: U.S. Census Bureau.

a

This includes 100,000 forms printed in Spanish.

b

This includes 35 Spanish forms returned.

Because of the low response levels, in early April 2004, the Bureau reversed 

its decision to not use paid advertising and in May 2004 initiated a paid 

advertising campaign in France and Mexico. This included print and 

Number of responses 

by mode

Test sites

Number of forms printed 

for each test site Paper Internet

Total number of 

responses received

Mexico 430,000a 869b 1,130 1,999

France 75,000 886 2,219 3,105

Kuwait 15,000 28 258 286

Total 520,000 1,783 3,607 5,390
Page 10 GAO-04-898 2010 Census

Internet ads in France and print and radio ads in Mexico. See figure 2 for 

examples of the ads used in the paid advertising campaign.

Figure 2: Census Bureau Ads Placed in the International Herald Tribune

A Bureau official told us the ad campaign for the 2004 overseas test cost 

about $206,000. This official said there were surplus funds available in the 

project budget to use for this purpose due to lower than expected 

processing and postage costs for the overseas test. While the Bureau saw 

Source: GAO.
Page 11 GAO-04-898 2010 Census

some increase in the number of responses after the paid advertising 

campaign began, this official said the increase was slight. 

Return on Investment for 

Overseas Enumeration is 

Low

Not only were response levels low, they were extremely expensive to 

obtain on a unit basis—roughly $1,450 for each returned questionnaire, 

based on the $7.8 million the Bureau spent preparing for, implementing, 

and evaluating the 2004 overseas test. In contrast, the unit cost of the 2000 

Census was about $56 per household. Although the two surveys are not 

directly comparable because the 2000 Census costs covered operations not 

used in the overseas test, the 2000 Census was still the most expensive 

census in our nation’s history.

Securing a Higher Return 

Rate Would Be an 

Enormous Challenge 

The main reason for the high unit cost is the low return rate. However, 

significantly boosting participation levels may not be feasible. The 

Bureau’s experience in the 2000 Census highlights the level of effort that 

was needed to raise public awareness about the census and get people to 

complete their forms. For the 2000 decennial, the Bureau spent $374 

million on a comprehensive marketing, communications, and partnership 

effort. The campaign consisted of a five-part strategy conducted in three 

waves beginning in the fall of 1999 and continuing past Census Day (April 1, 

2000). The effort helped secure a 72-percent return rate. Specific elements 

included television, radio, and other mass media advertising; promotions 

and special events; and a census-in-schools program. Thus, over a period 

of several months, the American public was on the receiving end of a 

steady drumbeat of advertising aimed at publicizing the census and 

motivating them to respond.

The Bureau also filled 594 full-time partnership specialist positions. These 

individuals were responsible for mobilizing support for the census on a 

grassroots basis by working with governmental entities, private companies, 

and religious and social service groups, and other organizations. 

Replicating this level of effort on a worldwide basis would be impractical, 

and still would not produce a complete count. Indeed, even after the 

Bureau’s aggressive marketing effort in 2000, it still had to follow-up with 

about 42 million households that did not return their census forms. 

Moreover, because there are no reliable figures on the number of 

Americans residing overseas, the Bureau would not have a good measure 

of the number of people that did not participate, or the overall quality of the 

data. 
Page 12 GAO-04-898 2010 Census

Ensuring a Smooth 

Overseas Enumeration 

Could Stretch the Bureau’s 

Resources

The Bureau’s experience in conducting the 2004 overseas test underscored 

the difficulties of administering a complex operation from thousands of 

miles away. Not surprisingly, as with any operation this complex, various 

challenges and unforeseen problems arose. While the Bureau was able to 

resolve them, its ability to do so should there be a full overseas 

enumeration as part of the 2010 Census, would be highly questionable as 

far more resources would be required. This was particularly evident in at 

least two areas: grappling with country-specific issues and overseeing the 

contractor responsible for raising public awareness of the census at the 

three test sites.

Country-specific Issues Created 

Implementation Problems

The Bureau encountered a variety of implementation problems at each of 

the test sites. In some cases the problems were known in advance, in 

others, glitches developed at the last minute. Although such difficulties are 

to be expected given the magnitude of the Bureau’s task, a key lesson 

learned from the test is that there would be no economy of scale in ramping 

up to a full enumeration of Americans abroad. In fact, just the opposite 

would be true. Because of the inevitability of country-specific problems, 

rather than conducting a single overseas count based on a standard set of 

rules and procedures (as is the case with the stateside census), the Bureau 

might end up administering what amounts to dozens of separate 

censuses—one for each of the countries it enumerates—each with its own 

set of procedures adapted to each country’s unique requirements. The time 

and resources required to do this would likely be overwhelming and detract 

from the Bureau’s stateside efforts. 

For example, during the overseas test, the Bureau found that French 

privacy laws restrict the collection of personal data such as race and ethnic 

information. However, these data are collected as part of the decennial 

census because they are key to implementing a number of civil rights laws 

such as the Voting Rights Act. 

Addressing France’s privacy laws took a considerable amount of 

negotiation between the two countries, and was ultimately resolved after a 

formal agreement was developed. The Bureau issued and posted on its 

Web site an advisory that informed Americans living in France that it was 

not mandatory to respond to the questionnaire, the only recipient of the 

collected data is the Census Bureau, the data will be kept for one year, and 

the respondent has a right to access and correct the data collected. The 

Bureau was able to collect race and ethnic data—generally a prohibited 

practice without the respondents’ permission—only after it received 
Page 13 GAO-04-898 2010 Census

special approval from a French government agency. Initially, however, it 

looked as if the Bureau might have to redesign the census form if it wanted 

to use it in France.

In Kuwait, delivery of the census materials was delayed by several weeks at 

the beginning of the test because they were accidentally addressed to the 

wrong contractor. Ultimately, the U.S. Embassy stepped-in to accept the 

boxes so that the enumeration could proceed. In Mexico, there was some 

initial confusion on the part of Mexican postal workers as to whether they 

could accept the postage-paid envelopes that the Bureau had provided to 

return the paper questionnaires for processing in the United States. 

Because of the small number of countries involved in the test, the Bureau 

was able to address the various problems it encountered. Still, the Bureau’s 

experience indicates that it will be exceedingly difficult to identify and 

resolve in advance all the various laws, rules, societal factors, and a host of 

other potential glitches that could affect a full overseas enumeration. 

On-site Supervision of 

Contractor Was Problematic

As noted previously, the Bureau hired a public relations firm to develop a 

communications strategy to inform and motivate respondents living in the 

test countries to complete the census. The firm’s responsibilities included 

identifying private companies, religious institutions, service organizations, 

and other entities that have contact with Americans abroad and could thus 

help publicize the census test. Specific activities the organizations could 

perform included displaying promotional materials and paper versions of 

the census questionnaire, publishing information in a newsletter, and 

posting information on their Web sites. Although the public relations firm 

appeared to go to great lengths to enlist the participation of these various 

entities—soliciting the support of hundreds of organizations in the three 

countries—the test revealed the difficulties of adequately overseeing a 

contractor operating in multiple sites overseas. 

For example, the public relations firm’s tracking system indicated that 

around 440 entities had agreed to perform one or more types of 

promotional activities. However, our on-site inspections of several of these 

organizations in Paris, France, and Guadalajara, Mexico, that had agreed to 

display the census materials and/or distribute the questionnaires, 

uncovered several glitches. Of the 36 organizations we visited that were 

supposed to be displaying promotional literature, we found the information 

was only available at 15. In those cases, as shown in figure 3, the materials 

were generally displayed in prominent locations, typically on a table with 

posters on a nearby wall. 
Page 14 GAO-04-898 2010 Census

Figure 3: Census Materials Were Prominently Displayed in Various Locations in 

France and Mexico

Five of these 15 organizations were also distributing the census 

questionnaire, but the forms were not readily accessible.

However, at 21 sites we visited, we found various discrepancies between 

what the public relations firm indicated had occurred, and what actually 

took place. For example, while the firm’s tracking system indicated that 

questionnaires would be available at a restaurant and an English-language 

bookstore in Guadalajara, none were available. In fact, the owner of the 

bookstore told us that no one from the Census Bureau or the public 

Source: GAO.

Census materials 

display in Mexico

Census materials 

display in France
Page 15 GAO-04-898 2010 Census

relations firm had contacted her about displaying materials for the 

overseas test. 

At the University of Guadalajara, although the tracking system indicated 

that an official had been contacted about, and agreed to help support the 

census test, that official told us no one had contacted him. As a result, 

when boxes of census materials were delivered to his school without any 

explanatory information, he did not know what to do with them, and had to 

telephone the U.S. Consulate in Guadalajara to figure out what they were 

for. 

Likewise, in Paris, we went to several locations where the tracking system 

indicated that census information would be available. None was. In fact, 

at some of these sites, not only was there no information about the census, 

but there was no indication that the organization we were looking for was 

at the address we had from the database. 

The results of the overseas test point to the difficulties of overseeing the 

contractor’s performance. As census materials were made available at 

scores of locations across the three test countries, it would have been 

impractical for the Bureau to inspect each site. The difficulty of 

supervising contractors—and any field operation for that matter—would 

only be magnified in a global enumeration.

The Design of the Overseas 

Census Lacks the Building 

Blocks of a Successful 

Census

The Bureau’s experience in counting the nation’s population for the 2000 

and earlier censuses sheds light on some of the specific operations and 

other elements that together form the building blocks of a successful head 

count (see fig. 4). 
Page 16 GAO-04-898 2010 Census

Figure 4: Key Building Blocks of a Successful Census

While performing these activities does not necessarily guarantee a costeffective headcount, not performing them makes a quality count far less 

promising and puts the entire enterprise at risk. The current approach to 

counting overseas Americans lacks these building blocks, as most are 

infeasible to perform on an overseas population. Each is discussed in 

greater detail below. 

• Mandatory participation: Under federal law, all persons residing in 

the United States regardless of citizenship status are required to 

respond to the decennial census. By contrast, the overseas enumeration 

test was conducted as a voluntary survey where participation was 

optional. The Bureau has found that response rates to mandatory 

surveys are higher than the response rates to voluntary surveys. This in 

turn yields more complete data and helps hold down costs. 

Source: GAO.

Early 

agreement 

on design

Ability to 

follow up with 

nonrespondents

Cost model to 

estimate needed 

resources

Targeted and 

aggressive 

marketing 

campaign

Mandatory 

participation

Ability to detect 

invalid responses

Complete and 

accurate 

address list

Field infrastructure 

to execute 

census and deal 

with problems

Ability to 

measure 

coverage and 

accuracy
Page 17 GAO-04-898 2010 Census

• Early agreement on design: Both Congress and the Bureau need to 

agree on the fundamental design of an overseas census. Concurrence 

on the design helps ensure adequate planning, testing and funding 

levels. Conversely, the lack of an agreed-upon design raises the risk that 

basic design elements might change in the years ahead, while the 

opportunities to test those changes and integrate them with other 

operations will diminish. Under the Bureau’s current plans, after the 

2006 test, the Bureau would have just one more opportunity to test its 

prototype for an overseas enumeration—a dress rehearsal in 2008. Any 

design changes after 2008 would not be tested in a real-world 

environment. 

The design of the census is driven in large part by the purposes for 

which the data will be used. Currently, no decisions have been made on 

whether the overseas data will be used for purposes of congressional 

apportionment, redistricting, allocating federal funds, or other 

applications. Some applications, such as apportionment, would require 

precise population counts and a very rigorous design that parallels the 

stateside count. Other applications, however, could get by with less 

precision and thus, a less stringent approach. 

As we noted previously, Congress will need to decide whether or not to 

count overseas Americans, and how the results should be used. The 

basis for these determinations needs to be sound research on the cost, 

quality of data, and logistical feasibility of the range of options for 

counting this population group. Possibilities include counting 

Americans via a separate survey, administrative records such as 

passport and voter registration forms, and/or records maintained by 

other countries such as published census records and work permits. 

The Bureau’s initial research has shown that each of these options has 

coverage, accuracy, and accessibility issues, and some might introduce 

systemic biases into the data. Far more extensive research would be 

needed to determine the feasibility of these or other potential 

approaches. Once Congress knows the tradeoffs of these various 

alternatives, it will be better positioned to provide the Bureau with the 

guidance it needs to go beyond research and conduct field tests of 

specific approaches. The Bureau can conduct the research, or it can 

contract it out. Indeed, the National Research Council of the National 

Academy of Sciences has conducted a number of studies on the 

decennial census, including a review of the 2000 Census and an 

examination of reengineering the 2010 Census. 
Page 18 GAO-04-898 2010 Census

• A complete and accurate address list: The cornerstone of a 

successful census is a quality address list. For the stateside census, the 

Bureau goes to great lengths to develop what is essentially an inventory 

of all known living quarters in the United States, including sending 

census workers to canvass every street in the nation to verify addresses. 

The Bureau uses this information to deliver questionnaires, follow up 

with nonrespondents, determine vacancies, and identify households the 

Bureau may have missed or counted more than once. Because it would 

be impractical to develop an accurate parallel address list for overseas 

Americans, these operations would be impossible and the quality of the 

data would suffer as a result.

• Ability to detect invalid returns: Ensuring the integrity of the census 

data requires the Bureau to have a mechanism to screen out invalid 

responses. Stateside, the Bureau does this by associating an 

identification number on the questionnaire to a specific address in the 

Bureau’s address list, as well as by field verification. However, the 

Bureau’s current approach to counting overseas Americans is unable to 

determine whether or not a respondent does in fact reside abroad. So 

long as a respondent provides certain pieces of information on the 

census questionnaire, it will be eligible for further processing. The 

Bureau is unable to confirm the point of origin for questionnaires 

completed on the Internet, and postmarks on a paper questionnaire only 

tell the location from which a form was mailed, not the place of 

residence of the respondent. The Bureau has acknowledged that 

ensuring such validity might be all but impossible for any reasonable 

level of effort and funding. 

• Ability to follow up with non-respondents: Because participation in 

the decennial census is mandatory, the Bureau sends enumerators to 

those households that do not return their questionnaires. In cases 

where household members cannot be contacted or refuse to answer all 

or part of a census questionnaire, enumerators are to obtain data from 

neighbors, a building manager, or other nonhousehold member 

presumed to know about its residents. The Bureau also employs 

statistical techniques to impute data when it lacks complete information 

on a household. Thus, by the end of each decennial census, the Bureau 

has a fairly exhaustive count of everyone in the nation. As noted above, 

because the Bureau lacks an address list of overseas Americans, it is 

unable to follow up with nonrespondents or impute information on 

missing households. As a result, the Bureau will never be able to obtain 

a complete count of overseas Americans.
Page 19 GAO-04-898 2010 Census

• Cost model for estimating needed resources: The Bureau uses a 

cost model and other baseline data to help it estimate the resources it 

needs to conduct the stateside census. Key assumptions such as 

response levels and workload are developed based on the Bureau’s 

experience in counting people decade after decade. However, the 

Bureau has only a handful of data points with which to gauge the 

resources necessary for an overseas census, and the tests it plans on 

conducting will only be of limited value in modeling the costs of 

conducting a worldwide enumeration in 2010. 

The lack of baseline data could cause the Bureau to over- or 

underestimate the staffing, budget and other requirements of an 

overseas count. For example, this was evident during the 2004 overseas 

test when the Bureau estimated it would need around 100,000 Spanishlanguage questionnaires for the Mexican test site. As only 35 Spanishlanguage questionnaires were returned, it is now clear that the Bureau 

could have gotten by with printing far fewer questionnaires for Mexico. 

However, the dilemma for the Bureau is that its experience in the 2004 

overseas test cannot be used to project the number of Spanish-language 

questionnaires it would need for Mexico or other Spanish-speaking 

countries in 2010. Similar problems would apply to efforts to enumerate 

other countries.6

• Targeted and aggressive marketing campaign: The key to raising 

public awareness of the census is an intensive outreach and promotion 

campaign. As noted previously, the Bureau’s marketing efforts for the 

2000 Census were far-reaching, and consisted of more than 250 ads in 17 

languages that were part of an effort to reach every household, including 

those in historically undercounted populations. Replicating this level of 

effort on a global scale would be both difficult and expensive, and the 

Bureau has no plans to do so. 

• Field infrastructure to execute census and deal with problems: 

The Bureau had a vast network of 12 regional offices and 511 local 

census offices to implement various operations for the 2000 Census. 

This decentralized structure enabled the Bureau to carry out a number 

of activities to help ensure a more complete and accurate count, as well 

as deal with problems when they arose. Moreover, local census offices 

are an important source of intelligence on the various enumeration 

6

 The Bureau plans to destroy all unused questionnaires for the 2004 test.
Page 20 GAO-04-898 2010 Census

obstacles the Bureau faces on the ground. For example, during the 2000 

Census, the Bureau called on them to identify hard-to-count population 

groups and other challenges, and to develop action plans to address 

them. The absence of a field infrastructure for an overseas census 

means that the Bureau would have to rely heavily on contractors to 

conduct the enumeration, and manage the entire enterprise from its 

headquarters in Suitland, Maryland. 

• Ability to measure coverage and accuracy: Since 1980, the Bureau 

has measured the quality of the decennial census using statistical 

methods to estimate the magnitude of any errors. The Bureau reports 

these estimates by specific ethnic, racial, and other groups. For 

methodological reasons, similar estimates cannot be generated for an 

overseas census. As a result, the quality of the overseas count, and thus 

whether the numbers should be used for specific purposes, could not be 

accurately determined. 

Conclusions The 2004 test of the feasibility of an overseas enumeration was an 

extremely valuable exercise in that it highlighted the numerous obstacles 

to a cost-effective count of Americans abroad as an integral part of the 

decennial census. Although more comprehensive results will not be 

available until the Bureau completes its evaluation of the test early next 

year, a key lesson learned is already clear: The current approach to 

counting this population group—a voluntary survey that largely relies on 

marketing to ensure a complete count—would be costly and yield poor 

results. The tools and resources the Bureau has on hand to enumerate 

overseas Americans are insufficient for overcoming the inherent obstacles 

to a complete count, and it is unlikely that any refinements to this basic 

design would produce substantially better results, and certainly not on a 

par suitable for purposes of congressional apportionment.

What’s more, the Bureau already faces the difficult task of carrying out a 

cost-effective stateside enumeration in 2010. Securing a successful count 

of Americans in Vienna, Virginia, is challenging enough; a complete count 

of Americans in Vienna, Austria—and in scores of other countries around 

the globe—would only add to the difficulties facing the Bureau as it looks 

toward the next national head count. As a result, we believe that any 

further tests or planning activities related to counting Americans overseas 

as part of the decennial census would be an imprudent use of the Bureau’s 

limited resources.
Page 21 GAO-04-898 2010 Census

That said, to the extent that Congress desires better data on the number 

and characteristics of Americans abroad for various policy-making and 

other nonapportionment purposes that require less precision, such 

information does not necessarily need to be collected as part of the 

decennial census, and could, in fact, be acquired through a separate survey 

or other means. To help inform congressional decision making on this 

issue, including decisions on whether Americans should be counted and 

how the data should be used, it will be important for Congress to have the 

results of the Bureau’s evaluation of the 2004 overseas census test. Equally 

important would be information on the cost, quality of data, and logistical 

feasibility of counting Americans abroad using alternatives to the decennial 

census. Once Congress knows the tradeoffs of these various alternatives, it 

would be better positioned to provide the Bureau with the direction it 

needs so that the Bureau could then develop and test an approach that 

meets congressional requirements at reasonable resource levels. 

Matters for 

Congressional 

Consideration

Given the obstacles to a cost-effective count of overseas Americans as part 

of the decennial census and, more specifically, obtaining data that is of 

sufficient quality to be used for congressional apportionment, Congress 

may wish to consider eliminating funding for any additional research, 

planning, and development activities related to counting this population as 

part of the decennial headcount, including funding for tests planned in 2006 

and 2008. However, funding for the evaluation of the 2004 test should 

continue as planned to help inform congressional decision making. 

Should Congress still desire better data on the number of overseas 

Americans, in lieu of the method tested in 2004, Congress might wish to 

consider authorizing and funding research on the feasibility of counting 

Americans abroad using alternatives to the decennial census. 

Recommendations for 

Executive Action

To facilitate congressional decision making, we recommend that the 

Secretary of Commerce ensure that the Bureau completes its evaluation of 

the 2004 overseas census test as planned. Further, to the extent that 

additional research is authorized and funded, the Bureau, in consultation 

with Congress, should explore the feasibility of counting overseas 

Americans using alternatives to the decennial census. Potential options 

include

• conducting a separate survey, 
Page 22 GAO-04-898 2010 Census

• examining how the design and archiving of various government agency 

administrative records might need to be refined to facilitate a more 

accurate count of overseas Americans, and 

• exchanging data with other countries’ statistical agencies and censuses, 

subject to applicable confidentiality and other provisions. 

Consideration should also be given to whether the Bureau should conduct 

this research on its own or whether it should be contracted out to the 

National Academy of Sciences.

Agency Comments and 

Our Evaluation

The Secretary of Commerce forwarded written comments from the U.S. 

Census Bureau on a draft of this report on August 5, 2004, which are 

reprinted in the appendix. The Bureau agreed with our conclusions and 

recommendations. Furthermore, the Bureau noted, “should Congress 

request and fund” further research on counting overseas Americans, it 

would be equipped to do that research itself.

As agreed with your offices, unless you release its contents earlier, we plan 

no further distribution of this report until 30 days from its issue date. At 

that time we will send copies to other interested congressional committees, 

the Secretary of Commerce, and the Director of the U.S. Census Bureau. 

Copies will be made available to others upon request. This report will also 

be available at no charge on GAO’s Web site at http://www.gao.gov.

If you or your staff have any questions concerning this report, please 

contact me on (202) 512-6806 or by e-mail at daltonp@gao.gov or Robert 

Goldenkoff, Assistant Director, at (202) 512-2757 or goldenkoffr@gao.gov. 

Key contributors to this report were Ellen Grady, Lisa Pearson, and 

Timothy Wexler. 

Patricia A. Dalton

Director

Strategic Issues
Page 23 GAO-04-898 2010 Census

Appendix I

Comments from the Department of Apendxies

Commerce ApendxiI
Appendix I

Comments from the Department of 

Commerce

(450315) Page 24 GAO-04-898 2010 Census
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