a

GAO

United States General Accounting Office

Report to the Subcommittee on 

Technology, Information Policy, 

Intergovernmental Relations, and the 

Census, Committee on Government 

Reform, House of Representatives

May 2004 2010 CENSUS

Overseas Enumeration 

Test Raises Need for 

Clear Policy Direction

GAO-04-470
www.gao.gov/cgi-bin/getrpt?GAO-04-470.

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 

daltonpj@gao.gov. 

Highlights of GAO-04-470, a report to the 

Subcommittee on Technology, Information 

Policy, Intergovernmental Relations, and 

the Census, Committee on Government 

Reform, House of Representatives 

May 2004

2010 CENSUS

Overseas Enumeration Test Raises Need 

for Clear Policy Direction 

Although the overseas enumeration test was designed to help determine the 

practicality of counting all Americans abroad, because of various 

methodological limitations, the test results will only partially answer the 

Bureau’s key questions concerning feasibility, data quality, and cost. For 

example, one research questions asks, “How good is the quality of the data?” 

However, the Bureau will only measure item nonresponse, which indicates 

whether a person completed a particular question. As a measure of quality, 

it is far from complete. Similarly, although a key research objective was to 

determine the cost of counting Americans overseas, the Bureau’s data will 

not inform the cost of conducting future tests or an overseas enumeration in 

2010. Overall, the Bureau overstated the test’s ability to answer its key 

research objectives. 

Counting Americans Abroad Would be a Monumental Challenge 

Overseas Americans have various rights and obligations to federal programs 

and activities. For example, Americans abroad are generally taxed on their 

worldwide income and can vote in federal elections, but are generally not 

entitled to Medicare benefits. There is nothing in the Constitution, federal 

law, or court decisions that would either require the Bureau to count 

overseas Americans, or not count this population group. As a result, 

Congress would need to enact legislation if it wanted to require the Bureau 

to include overseas Americans in the 2010 Census. Counting Americans 

abroad as part of the census would add new risks to an enterprise that 

already faces an array of challenges. Therefore, it will be important for 

Congress to decide whether overseas Americans should be counted as part 

of the census or counted as part of a separate survey or whether there are so 

many obstacles to a successful count regardless of the approach that the 

Bureau should shelve any plans for further research and testing. To the 

extent a second test is required, the Bureau will need to take steps to 

develop a more rigorous design. 

In the 1990 and 2000 Censuses, U.S. 

military and federal civilian 

employees overseas were included 

in the numbers used for 

apportioning Congress. Currently, 

the U.S. Census Bureau (Bureau) is 

assessing the practicality of 

counting all Americans abroad by 

holding a test census in France, 

Kuwait, and Mexico. GAO was 

asked to (1) assess the soundness 

of the test design, and (2) examine 

what past court decisions have 

held about Americans’ rights and 

obligations abroad. 

In order to give the Bureau as 

much planning time as possible, 

Congress may wish to consider 

coming to an early decision on 

whether the Bureau should be 

required to enumerate all overseas 

Americans, and if so, whether they 

should be counted as part of the 

decennial census or by some other, 

separate data collection effort. 

Should Congress desire an 

overseas count, it should consider 

telling the Bureau how the data 

would be used. Further, the 

Bureau should address the 

shortcomings of the 2004 test 

design, in part by being more 

transparent about what the test can 

and cannot measure. The Bureau 

generally concurred with our 

findings and recommendations, but 

believes it has already been clear 

about the test’s limitations. Still, 

the Bureau agreed it will be critical 

to point out the various limitations 

that may affect congressional 

deliberations on this matter. 
Page i GAO-04-470 2010 Census

Contents

Letter 1

Results in Brief 3

Background 5

Scope and Methodology 9

Design Limitations Could Undermine the Usefulness of the Overseas 

Test 10

Overseas Test Design Has Other Shortcomings 21

The Rights and Obligations of Americans Overseas Vary 25

Conclusions 30

Matters for Congressional Consideration 31

Recommendations for Executive Action 31

Agency Comments and Our Evaluation 32

Appendixes

Appendix I: Comments from the Department of Commerce 35

Appendix II: Criteria for Evaluating Census Research Design for Overseas 

Enumeration Test 40

Appendix III: 2004 Overseas Test Census Questionnaire 43

Tables Table 1: Treatment of Certain Population Groups Living or Working 

Overseas in the Decennial Censuses, 1900-2000 7

Table 2: Research Questions Have Methodological Limitations That 

Could Reduce the Bureau’s Ability to Address Research 

Objectives 11

Table 3: The Applicability of Federal Programs to Americans 

Overseas Varies 25

Figure Figure 1: Census Bureau Poster Advertising the Overseas 

Census 17

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Page 1 GAO-04-470 2010 Census

United States General Accounting Office

Washington, D.C. 20548

A

May 21, 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

One of the thornier issues facing the U.S. Census Bureau (Bureau) as it 

prepares for the 2010 Census is whether to count American citizens 

residing abroad, and if so, how to use the results. Under federal law, the 

Bureau has discretion over whether to count this population group. Thus, 

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

groups—members of the military and federal employees and their 

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

the 1960 and 1970 Censuses.1

 Moreover, when these overseas groups were 

included in the census, their population totals were generally not included 

with the counts used for apportioning Congress. 

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

Americans living abroad.2

 Further, while it is unclear how counting these 

individuals would affect congressional apportionment and other purposes 

for which census data are used, in some instances it could be significant. 

For example, in January 2001, Utah sued 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.3

 Although the suit was unsuccessful, according to a report by the 

1

 U.S. Bureau of the Census, Americans Overseas in U.S. Censuses, Technical Paper 62 

(November 1993) hereinafter Americans Overseas. 

2

 According to the Bureau, the apportionment counts from the 2000 Census included only 

federally affiliated groups (226,363 military personnel, 30,576 civilian employees, and 

319,428 dependents of both groups). The Bureau did not collect data on other Americans 

living abroad for 2000.

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

(2001).
Page 2 GAO-04-470 2010 Census

Congressional Research Service, Utah would have gained a congressional 

seat had an additional 855 people been counted in the census.4

In response to congressional direction and the concerns of various 

stakeholder groups representing overseas Americans, 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, 

as well as their dependents. The first step of this effort, a test enumeration 

of Americans residing in France, Kuwait, and Mexico, is currently 

underway. A sound feasibility test is essential because the Bureau has 

already identified a number of operational, conceptual, and policy issues 

that would make an accurate count of overseas Americans even more 

difficult than the stateside enumeration, an endeavor that is a daunting 

challenge in its own right. As a second step, the results of the 2004 test will 

be used to provide information and recommendations for another overseas 

enumeration test planned for 2006.

To facilitate Congress’s oversight of the test and provide information for 

future decision making on this issue, you asked us to review the overseas 

test design. As agreed with your offices, we (1) assessed the soundness of 

the Bureau’s test design and its suitability for addressing the Bureau’s 

specific research questions, and (2) examined what past court decisions 

have held about Americans’ rights and obligations abroad that could help 

inform whether and how they should be included in the census. 

To meet these objectives, we interviewed knowledgeable Bureau officials; 

reviewed pertinent documents such as test plans; and examined relevant 

statutes, court decisions, and legal analyses. We also systematically rated 

the soundness of the Bureau’s test design using a checklist of over 30 

design elements that, based on our review of program evaluation literature, 

are important for a sound study plan. We conducted our work from June 

2003 through February 2004, in accordance with generally accepted 

government auditing standards. 

This report is the second in our ongoing series on the planning and 

development of the 2010 Census. In a study issued earlier this year, we

4

 Congressional Research Service, House Apportionment: Could Census Corrections Shift 

a House Seat?, RS21638 (Washington, D.C.: Oct. 8, 2003).
Page 3 GAO-04-470 2010 Census

described the various challenges facing the 2010 Census, and the need for 

the Bureau to address cost and design issues.5

 

Results in Brief The Bureau designed the 2004 test to help determine the practicality of 

collecting data from U.S. citizens living overseas. However, because of 

various methodological limitations, the test results will only partially 

answer the Bureau’s key objectives concerning feasibility (as measured by 

such indicators as participation and number of valid returns), data quality, 

and cost. Although some of the methodological limitations stem from the 

inherent challenges of enumerating Americans abroad, others are due to 

the way in which the Bureau is implementing the test. Overall, the Bureau 

overstated the test’s ability to answer its key research objectives and, as a 

result, congressional decision making on this issue will be that much more 

difficult.

For example, one of the Bureau’s research questions asks, “How good is the 

quality of the data?” However, the only measure of quality available to 

address this is the percentage of respondents who did not complete a 

particular question. As the Bureau acknowledges, this measure of 

nonresponse is an incomplete measure of the quality of the data. Similarly, 

although a key research objective was to determine the cost of counting 

Americans overseas, the Bureau did not develop a research question to 

address this variable and, more importantly, the cost information that the 

Bureau will collect will be limited to the test sites. It will not inform the 

cost of conducting future tests or an overseas enumeration in 2010.

Americans residing abroad do not have the same rights and obligations 

under federal programs and activities as compared to their stateside 

counterparts. On the one hand, overseas citizens are generally taxed on 

their worldwide income, can vote in federal elections, and can receive 

Social Security benefits. On the other hand, they are generally not entitled 

to Medicare benefits, or, if they reside outside of the United States for more 

than 30 days, Supplemental Security Income. 

With respect to the census, the Bureau has discretion over whether or not 

to count Americans overseas. There is nothing in the Constitution, federal 

law, or court decisions that would either require the Bureau to count or not 

5

 U.S. General Accounting Office, 2010 Census: Cost and Design Issues Need to Be 

Addressed Soon, GAO-04-37 (Washington, D.C.: Jan. 15, 2004).
Page 4 GAO-04-470 2010 Census

count Americans abroad. As a result, Congress would need to enact 

legislation if it wanted to require the Bureau to include overseas Americans 

in the 2010 Census.

The full results of the overseas enumeration test will not be known until 

2005, when the Bureau anticipates it will complete a series of evaluations. 

However, the Bureau’s experience thus far makes it clear that an accurate 

count of U.S. citizens abroad as part of the 2010 Census would be 

extremely difficult, and would introduce new resource requirements, risks, 

and uncertainties to an endeavor that already faces a host of difficulties. 

At the same time, to the extent that better demographic data on overseas 

Americans might be useful for various policymaking and other 

nonapportionment purposes, it does not necessarily need to come from the 

decennial census. Such information could be acquired through a separate 

survey or alternative data collection effort, although it would still be a 

difficult task. 

It will be important for Congress to come to an early decision on whether 

the Bureau should be required to count Americans abroad as part of the 

2010 Census or as part of a separate data collection effort or whether there 

are so many hurdles to a successful overseas enumeration regardless of the 

approach that the Bureau should abandon any plans for further research 

and testing. Should Congress desire an overseas count, be it part of the 

decennial census or a separate effort, it should consider providing the 

Bureau with input on whether the data would be used for purposes of 

apportionment, redistricting, allocating federal funds, or a tally of the U.S. 

overseas population. Armed with this information, the Bureau would be 

better positioned to design a test that would more accurately assess the 

specific resources and methodology needed to accomplish the type of 

census that Congress desires. Moving ahead with a second test without 

this information would be an imprudent use of the Bureau’s resources. 

Further, to the extent that a second test of enumerating Americans abroad 

is needed in 2006, we recommend that the Secretary of Commerce direct 

the Bureau to resolve the shortcomings of the design of the 2004 test and 

better address the objectives of an overseas enumeration. At a minimum, 

specific steps should include (1) being more transparent with Congress and 

other stakeholders on what variables and research questions the Bureau 

can and cannot assess, (2) explore developing broader measures of data 

quality, and (3) developing a cost model to provide the Bureau and 
Page 5 GAO-04-470 2010 Census

Congress with better estimates of the budgetary impact of conducting an 

overseas census under different methodological and other scenarios.

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

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

appendix I. 

The Bureau generally agreed with our conclusions and recommendations 

but took exception to our finding and related recommendation that the 

Bureau needs to be more transparent with Congress and other 

stakeholders regarding the variables and research questions it can and 

cannot answer. The Bureau maintains that it has always been clear that the 

test is only a “most basic assessment of feasibility.” Still, the Bureau agreed 

that as it completes its evaluations and documents its findings from the 

test, it will be “critical” to highlight the various limitations that could affect 

congressional deliberations on this subject. 

Background The Census Bureau has discretion under the Constitution and federal 

statutes to decide whether to count Americans residing overseas. The 

federal decennial census is conducted pursuant to the requirement 

imposed by Article I, Section 2, Clause 3 of the Constitution, and Section 2 

of the Fourteenth Amendment, that Congress enumerate “the whole 

number of persons in each State” as the basis for apportionment of seats in 

the United States House of Representatives. Under the Constitution, the 

census is to be conducted every 10 years “in such Manner as [Congress] 

shall by Law direct.” Congress has exercised its authority under the 

Constitution by passing the Census Act, which assigns to the Secretary of 

Commerce the responsibility of “tak[ing] a decennial census of population 

as of the first day of April” of each census year.6

 The Secretary does so with 

the assistance of the Census Bureau and its Director.7

The statutes governing the earliest censuses provided that enumerators 

should record all persons reported to them within their respective districts 

as having a usual place of abode there or as usually residing within that 

district, even though such persons might be “occasionally absent at the

6

 13 U.S.C. § 141(a).

7 Id. §§ 2, 21.
Page 6 GAO-04-470 2010 Census

time of enumeration.”8 Statutes governing later censuses, including the 

current provisions in Title 13 of the United States Code, contain no similar 

provision, or any provision specifically governing the enumeration of 

inhabitants of the United States who are outside of its borders on the 

enumeration date.

To determine who should be included in the census, the Bureau applies its 

“usual residence rule,” which has been defined as the place where a person 

lives and sleeps most of the time. People who are temporarily absent from 

that place are still counted as residing there.9

 One’s usual residence is not 

necessarily the same as one’s voting residence or legal residence. 

Noncitizens living in the United States are counted in the census, 

regardless of their immigration status.

Historically, the census has focused primarily on the domestic population 

and typically has not included any procedures designed to enumerate 

Americans residing outside of the United States. The first attempts to count 

Americans residing overseas were in the 1830 and 1840 censuses, which 

included procedures for counting the “crews of naval vessels at sea.”10 The 

naval personnel included in those censuses, however, were not allocated to 

any individual state, and thus were not included in the apportionment 

population.11 

As shown in table 1, various overseas population groups were included in 

the census at different times. For example, while federally affiliated 

personnel were typically included in the enumerations that took place from 

1900 through 2000, only the 1970, 1990, and 2000 censuses used the 

numbers for purposes of apportioning Congress. At the same time, private 

citizens living abroad were included only in the 1960 and 1970 censuses, 

but not for purposes of apportionment. 

8 See 41 U.S. Op. Att’y. Gen. 31, 32 (1949), which gives citations to early statutes.

9 District of Columbia v. United States Department of Commerce, 789 F. Supp. 1179, 1180 

(D.D.C. 1992).

10 Thomas R. Lee & Lara J. Wolfson, The Census and the Overseas Population, 2 Election L. 

J. 343, 344 (2003) (hereinafter referred to as Overseas Population), citing Americans 

Overseas at 10.

11 Id.
Page 7 GAO-04-470 2010 Census

Table 1: Treatment of Certain Population Groups Living or Working Overseas in the Decennial Censuses, 1900-2000

Source: U.S. Bureau of the Census, Americans Overseas in the U.S. Censuses, Technical Paper 62 (Washington, D.C.: November 1993). 

Notes: 

✔ = Included in the population count used for congressional apportionment.

X = Counted in the census, but not included in the population totals used for apportionment.

a

This table excludes the officers and crew of merchant marine vessels because available data were 

unclear as to whether these groups were included in the overseas enumerations or the stateside 

counts in the decennial censuses.

In response to congressional direction and the concerns of various 

business, political, and other groups that represent overseas Americans, 

the Census Bureau embarked on a research and evaluation program aimed 

at determining the feasibility, quality, and cost of counting both federally 

affiliated and private citizens living abroad. The test enumeration began 

February 2004 and is to run through July 2004 at three sites: France, 

Kuwait, and Mexico. 

The Bureau selected these countries based on several criteria including 

their geographic diversity, the fact that large numbers of U.S. citizens reside 

there, and because of the existence of administrative records that can be 

used to compare to the test census counts for evaluation purposes. The 

Bureau estimated the implementation costs for the 2004 test at 

approximately $2.5 million in fiscal year 2004. Further, the Bureau 

estimates that by the end of fiscal year 2004, it will have spent an additional 

$3.5 million for planning and preparation during fiscal years 2003 and 2004.

Americans can participate in the test census by completing a short-form 

paper questionnaire that is available at embassies, consulates, and other 

organizations that serve overseas Americans, or by completing the form on 

the Internet. The Bureau hired a public relations firm to develop a 

communications strategy to inform and motivate respondents living in the 

selected countries to answer the census. Responses from the paper and 

the Internet returns will be captured in order to analyze, among other 

Population groupa 1900 1910 1920 1930 1940 1950 1960 1970 1980 1990 2000

U.S. military personnel stationed abroad or at sea 

and their dependents

X X X X X X X ✔ X ✔ ✔

Federal civilian employees stationed abroad and 

their dependents

X X X X ✔ X ✔ ✔

Persons abroad working for the American Red Cross 

or in the consular service and their dependents

X X X

Private U.S. citizens abroad for an extended period X X
Page 8 GAO-04-470 2010 Census

things, the demographic characteristics of respondents and patterns of 

item nonresponse. The Bureau plans to conduct a 2006 overseas test if 

Congress appropriates requested funds in fiscal years 2005, 2006, and 2007. 

If Congress then indicates its desire that the Census Bureau conduct a 

general overseas enumeration in 2010, the Bureau will seek a 

supplementary appropriation in calendar year 2007 for that purpose and to 

conduct a 2008 overseas dress rehearsal beginning in 2007.

A sound test is essential in order for the Bureau, Congress, and other 

stakeholders to resolve the numerous logistical, conceptual, policy, and 

other questions that surround the counting of overseas Americans. They 

include:

• Who should be counted? U.S. citizens only? Foreign-born spouses? 

Children born overseas? Dual citizens? American citizens who have no 

intention of ever returning to the United States? Naturalized citizens? 

• How should overseas Americans be assigned to individual states? For 

certain purposes, such as apportioning Congress, the Bureau would 

need to assign overseas Americans to a particular state. Should one’s 

state be determined by the state claimed for income tax purposes? 

Where one is registered to vote? Last state of residence before going 

overseas? These and other options all have limitations that would need 

to be addressed.

• How should the population data be used? To apportion Congress? To 

redistrict Congress? To allocate federal funds? To provide a count of 

overseas Americans only for general informational purposes? The 

answers to these questions have significant implications for the level of 

precision needed for the data and ultimately, the enumeration 

methodology. 

• How can the Bureau verify U.S. citizenship? Administrative records 

such as passports and Social Security data have limitations. For 

example, Americans can reside in Mexico and Canada without a 

passport and many Americans overseas do not have Social Security 

numbers, especially dependents. 

• How can the Bureau ensure a complete count without a master address 

list? The foundation of the stateside decennial census is a master 

address list. Because the list is essentially the universe of all known 

living quarters in the United States, the Bureau uses it to deliver 
Page 9 GAO-04-470 2010 Census

questionnaires, follow up with nonrespondents, determine vacancies, 

and determine individuals the Bureau may have missed or counted more 

than once. The Bureau lacks a complete and accurate address list of 

overseas Americans. Consequently, these operations would be 

impossible and the quality of the data would suffer as a result. 

• Can administrative records be used to help locate and count overseas 

Americans? Administrative records such as passport and visa files, 

voter registration forms, as well as records held by private companies 

and organizations have the potential to help the Bureau enumerate 

Americans abroad. However, the accuracy of these records, the 

Bureau’s ability to access them, confidentiality issues, and the 

possibility of duplication all remain open questions.

• Do certain countries have requirements that could restrict the Bureau’s 

ability to conduct a count? According to the Bureau, in planning the 

overseas test, the Bureau was informed that French privacy laws 

prohibit asking about race and ethnicity, two questions that are included 

on the U.S. census questionnaire. Although the Bureau worked with 

French officials to address this problem, the extent to which the Bureau 

will encounter restrictions in other countries, or whether other 

countries will cooperate with the Bureau at all, is unknown.

Scope and 

Methodology

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

(1) assess the soundness of the Bureau’s test design and its suitability for 

addressing the Bureau’s specific research questions, and (2) examine what 

past court decisions have held about Americans’ rights and obligations 

abroad that could help inform whether and how they should be included in 

the census. 

To assess the soundness of the Bureau’s 2004 overseas enumeration test 

design, we interviewed knowledgeable Bureau officials and reviewed 

existing documents that described the Bureau’s test objectives, research 

questions, and test plans. We then systematically rated the Bureau’s 

approach using a checklist of over 30 design elements that, based on our 

review of program evaluation literature, are relevant to a sound study plan. 

For example, we reviewed the Bureau’s approach to determine, among 

other things, (1) how clearly the Bureau presented the research objectives, 

(2) whether the research questions matched the research objectives, 

(3) whether potential biases were recognized and addressed, and (4) the 

appropriateness of the data collection strategy for reaching the intended 
Page 10 GAO-04-470 2010 Census

sample population. See appendix II for a complete list of the 30 design 

elements. 

We supplemented our ratings on the suitability of the test by gathering 

additional information through telephone and in-person interviews with 

representatives of several stakeholder organizations that represent various 

groups of Americans residing abroad. The organizations included 

Democrats Abroad, Republicans Abroad, Association of Americans 

Resident Overseas, and the American Business Council of the Gulf 

Countries. In addition, we interviewed representatives of the Mexican 

American Legal Defense and Educational Fund, National Coalition for an 

Accurate Count of Asians and Pacific Islanders, and California Rural Legal 

Assistance, Inc., to get their perspectives on the Bureau’s plans for 

counting American citizens living in Mexico, particularly migrant and 

seasonal farm workers, a group that the Bureau had trouble counting 

during the 2000 Census. These three organizations, while not actively 

involved in the planning of the overseas enumeration test, are members of 

the Secretary of Commerce’s Decennial Census Advisory Committee, a 

panel that advises the Bureau on various census-related issues.

To examine what past court decisions have held about Americans’ rights 

and obligations living abroad, including their right to be counted in the 

census, we reviewed a judgmental selection of five federal laws and/or 

programs that cover large numbers of Americans stateside, in order to 

determine how those laws and programs treat U.S. citizens should they live 

overseas. We examined federal election law, federal income tax law, and 

federal laws relating to Social Security benefits, Supplemental Social 

Security Income, and Medicare. For each of these laws and programs, we 

reviewed relevant statutes, court decisions, and legal analyses. 

We requested comments on a draft of this report from the Secretary of 

Commerce, which were sent to us April 13, 2004 (see app. I). We address 

them in the Agency Comments and Our Evaluation section of this report.

Design Limitations 

Could Undermine the 

Usefulness of the 

Overseas Test

According to the Bureau, its objectives for the 2004 overseas test are “to 

determine the feasibility, quality, and cost of collecting data from U.S. 

citizens living overseas.” To meet those objectives, the Bureau developed 

eight research questions designed to gather data on such salient factors as 

participation levels, data quality, and the relative response from the two 

enumeration modes (Internet and paper questionnaire; see appendix III for 

a sample of the paper questionnaire). To assess the overseas test the 
Page 11 GAO-04-470 2010 Census

Bureau is planning to complete a series of evaluations due in early 2005. 

The test objectives and related research questions are appropriate as 

written, but, as shown in table 2, because of various methodological 

limitations, the data that will result from the test will not fully answer key 

questions concerning feasibility, data quality, and cost. In short, the Bureau 

overstated the research test’s ability to answer its key research objectives 

and, as a result, congressional decision making on this issue will be that 

much more difficult.

Table 2: Research Questions Have Methodological Limitations That Could Reduce the Bureau’s Ability to Address Research 

Objectives 

Census Bureau research question

Indicators the Bureau will 

measure Methodological limitations

1. What is the level of participation 

from U.S. citizens overseas?

Participation counts from the three 

test sites

• The universe of overseas Americans is unknown so 

participation rates cannot be determined. 

• The Bureau has not developed residence rules for 

overseas enumeration; therefore, who should participate is 

unclear. 

• Dual nationals and certain other groups may have difficulty 

accessing Internet and other response options.

2. How good is the quality of the 

data?

Item nonresponse • The Bureau acknowledges that item nonresponse does not 

provide a comprehensive measure of quality. 

3. To what level of geography can the 

Bureau geocode the overseas 

population?

Ability to geocode addresses • People with noncity-style addresses such as post office 

boxes will be excluded.

4. How effective is the overseas 

marketing program?

Participation and public 

awareness

• Participation data are not available for measuring 

effectiveness. 

• Public awareness of marketing will be difficult to measure.

5. Can administrative records be 

used effectively?

Estimates from administrative 

records compared to the 

enumeration results

• A large disparity between administrative records counts will 

make it difficult to determine effectiveness.

• Administrative records were developed for different 

purposes, therefore, comparing against overseas data may 

yield inconclusive results.

6. What is the relative response from 

the two enumeration modes (Internet 

and paper return) and their 

effectiveness?

Responses by mode and site 

(France, Kuwait, Mexico)

• Because the universe of Americans is unknown, analysis is 

limited to providing counts.

7. Can the Bureau successfully 

implement an appropriate invalid 

return detection (IRD) system in an 

overseas enumeration?

Number of valid returns (a valid 

return is a questionnaire where at 

least one person in the household 

checked the U.S. citizen box, 

provided a valid Social Security or 

passport number, and was subject 

to and passed an algorithm. All 

other returns are invalid.) 

• The Bureau was unable to negotiate use of passport files 

with the State Department and they will not be used for 

IRD.

• The Bureau cannot verify a questionnaire’s point of origin 

received via Internet and therefore cannot determine 

whether respondents are truly living in the test sites. 

• Some people may be reluctant to provide a Social Security 

or passport number. 
Page 12 GAO-04-470 2010 Census

Source: GAO analysis.

Research Question #1: 

Participation Data Could be 

Unreliable 

For the decennial census, the Bureau uses participation data as a key 

indicator of public cooperation with the census. The Bureau measures 

participation levels by what it calls the “return rate,” which it calculates as 

a percentage of all forms in the mailback universe (excluding vacant and 

nonexistent housing units) from which it receives a questionnaire. 

Stateside, the Bureau is able to perform this calculation because, as noted 

above, it has a master address list of all known housing units in the United 

States, an inventory that takes the Bureau several years and considerable 

resources to compile. 

However, no such address list exists for overseas Americans. 

Consequently, participation rates for overseas Americans cannot be 

calculated and the Bureau will only be able to tally the number of 

responses it receives (both overall for each site and within several 

demographic categories) and compare the results to counts obtained from 

administrative records. The sources for the records include a combination 

of tax, Medicare, and State Department data, as well as foreign census data 

if available. For a variety of reasons—some of which the Bureau has 

already acknowledged—the information generated from this exercise may 

not be relevant.

First, the administrative records were developed for different purposes, 

and as a result, are not well suited as a base for comparing against overseas 

counts; thus, their relevance is uncertain. As the Bureau has already 

reported, each of the records it plans to use to compare to the census 

counts has coverage limitations.12 Further, as each of these records is 

associated with particular demographic groups, they could introduce 

8. What are the primary barriers of 

integrating an overseas enumeration 

with the stateside enumeration 

process?

Lessons learned • Overseas and stateside data will not be integrated in this 

test.

• Unforeseen problems could exist that will not be revealed 

until the data are actually integrated.

(Continued From Previous Page)

Census Bureau research question

Indicators the Bureau will 

measure Methodological limitations

12 U.S. Census Bureau, Issues of Counting Americans Overseas in Future Censuses 

(Washington, D.C.: Sept. 27, 2001) hereinafter Issues of Counting Americans Overseas.
Page 13 GAO-04-470 2010 Census

systemic biases (we discuss potential problems with administrative 

records in greater detail below, under Research Question #5). 

Second, the census counts could be problematic because it is unclear who 

should participate in the overseas census, which in turn could confuse 

potential respondents. For the stateside enumeration, to determine where 

an individual should be counted, the Bureau uses the concept of “usual 

residence,” which it defines as “the place where a person lives and sleeps 

most of the time.” The Bureau has developed guidelines, which it prints on 

the stateside census questionnaire, to help people figure out who should 

and should not be included. However, the Bureau has not developed 

similar guidance for the overseas test. According to the Bureau, this was 

intentional; because this was an initial feasibility test, the Bureau did not 

want to restrict response, but rather to encourage the widest possible 

participation. 

Further, the guidance the Bureau has developed, which is available on its 

Web site and promotional literature, is vague and could confuse potential 

respondents. For example, the guidelines inform potential respondents 

that, “All U.S. citizens living in France, Mexico and Kuwait, regardless of 

shared citizenship, can and should participate in the test. U.S. citizens on 

vacation or on short business trips should not.” Unclear is what constitutes 

a short or long business trip. Is it 3 weeks or 3 months? Does it matter 

whether one stays in a hotel or an apartment? Also, should naturalized U.S. 

citizens, some of whom may not return to the United States, participate? 

What about children born in the United States to noncitizens, but who only 

lived in the United States a short time? Should students spending a 

semester abroad but who maintain a permanent residence stateside be 

included? Without clear residence rules and appropriate guidance 

indicating who should be counted, it is quite possible that some people 

might inappropriately opt in or out of the census, which would reduce the 

quality of the data. Bureau officials have told us that they are working to 

develop residence rules that it will apply if there is a second overseas 

enumeration test in 2006. 

Participation data might also be problematic because the Bureau’s 

enumeration methods strategy might not be as effective with certain 

groups compared to others. To the extent this occurs, it could introduce a 

systemic undercount. This is particularly true for dual nationals who, for 

cultural reasons, may not think of themselves as American citizens. 
Page 14 GAO-04-470 2010 Census

For example, according to representatives of two advocacy groups we 

contacted, Mexican dual nationals include migrant farm workers, a group 

that often consists of poor, less-educated people living in rural areas. They 

noted that this population group has low literacy levels and thus might not 

understand the questionnaire, and is not likely to have Internet access. At 

the same time, they are not likely to pick up a copy of the questionnaire at 

an embassy. Further, the barriers that make it difficult to count migrant 

farm workers in the United States, such as a distrust of government and the 

fact that they may speak indigenous languages, also make it difficult to 

count this group in Mexico. 

Research Question #2: 

Information on Data Quality 

Will be Limited

The Bureau plans on measuring the quality of the data collected in the 

overseas test by tabulating item nonresponse, which refers to whether a 

respondent completed a particular question. The Bureau is to calculate 

this information by enumeration mode, test site, and various demographic 

categories. The Bureau also plans to compare this measure of nonresponse 

for key variables to those obtained in an earlier, stateside test held in 2003 

by tabulating the rate respondents did not complete a particular question.

According to the Bureau, patterns of item nonresponse are critical for 

improving question design, training, and procedures. However, as the 

Bureau acknowledges in its study plan for evaluating the quality of the 

overseas enumeration data, item nonresponse by itself does not address 

the quality of the data. Thus, at the end of the test, the Bureau will have, at 

best, only limited information on the quality of the overseas data. 

By comparison, the Bureau’s guidelines for measuring data quality in other 

surveys they conduct use measures such as coverage, unit response rates, 

imputation rates, and data collection errors. Because the Bureau lacks 

information on the universe of overseas Americans it will be unable to 

calculate these indicators. Therefore, it is misleading for the Bureau to 

state in its research objectives that it will determine the quality of the 

overseas data, when in fact it will deliver something far more limited. 

Comprehensive measures of data quality are critical because they could 

help Congress decide whether the data are sufficiently reliable to use for 

specific purposes. If the numbers were to be used to obtain a simple count 

of Americans abroad, absolute precision is not as critical. However, for 

other uses of the data, particularly congressional apportionment and 

redistricting, the quality of the data would need to be far higher. 
Page 15 GAO-04-470 2010 Census

Research Question #3: The 

Bureau Will be Unable to 

Geocode Certain U.S. 

Addresses 

Counting people in their correct locations is essential for congressional 

apportionment, redistricting, and certain other uses of census data. With 

respect to Americans abroad, if the data are to be used for apportionment, 

the Bureau would need to assign respondents to a specific state. For 

purposes of redistricting and allocating federal funds, the Bureau would 

need to assign overseas respondents to specific neighborhoods and street 

addresses in the United States—a far more challenging task. Geocoding is 

the process of linking an address in the Bureau’s Master Address File 

(MAF) to a geographic location in the Bureau’s geographic database, 

known as the Topologically Integrated Geographic Encoding and 

Referencing (TIGER) mapping system. To obtain this information, the 

overseas enumeration form asks respondents to indicate their U.S. state of 

last residence, and their last street address within that state.

Although the Bureau is assessing the level of geography to which it can 

geocode the overseas population, an important limitation is that the Bureau 

will not be able to make this assessment for people who live in certain 

noncity-style U.S. addresses; that is, U.S. addresses without a housing 

number and/or street name. Specifically, people whose U.S. addresses 

consist of a post office box will be excluded from the study. For the 

stateside enumeration, Bureau employees canvass the country, identify 

noncity-style addresses, and mark the locations of those residences on a 

map. During the 2000 Census, around 20 percent of U.S. households had 

noncity-style addresses.

Indeed, the overseas enumeration questionnaire instructs respondents not

to provide a post office box number for their last stateside address. 

However, if a respondent’s address includes a post office box or rural route 

number, it is unclear how they are supposed to complete this question. 

Also unclear is how migrant farm workers, who may not have had an 

address in the United States, would complete this question.

To the extent they leave the question blank, the Bureau would be unable to 

distinguish between those people who did so because they have a noncitystyle address, or left it blank for privacy or other reasons. This could affect 

the accuracy of the Bureau’s assessment. Moreover, the construction of the 

question could introduce a systemic bias because those states with large 

rural areas are more likely to have noncity-style addresses. 

The Bureau’s evaluation plan recognizes that respondents in the 2004 

overseas enumeration test may provide noncity-style addresses which 

cannot be geocoded by the TIGER system. The Bureau intends to provide 
Page 16 GAO-04-470 2010 Census

data on how many city-style and noncity-style addresses could be 

geocoded. 

Research Question #4: 

Measuring the Marketing 

Program’s Effectiveness Will 

be Difficult

Although the Bureau has taken a number of steps to publicize the overseas 

enumeration, evaluating the effectiveness of that effort will present a 

challenge. The Bureau awarded a $1.2 million contract to a public relations 

firm to develop a promotion strategy for the overseas enumeration test. As 

part of that effort, the public relations firm identified a number of 

stakeholder organizations that represent U.S. citizens living overseas in 

each of the three test countries. The organizations included advocacy 

groups, universities, church groups, and corporations. 

The Bureau anticipates that these stakeholders will help get the word out 

via e-mail, newsletters, and other media that a test census of Americans 

overseas is underway. In addition, the Bureau is to provide copies of the 

overseas questionnaire to stakeholders so that they can distribute them to 

their members and constituents. As noted earlier, questionnaires will also 

be available on the Internet, as well as at public places that Americans may 

visit, such as embassies and consulates. The Bureau has produced posters 

and pamphlets to promote the test (see fig. 1). The Bureau also plans to 

have articles about the census test placed in newspapers and magazines 

and stories run on local television and radio. Although paid advertising 

was not part of its original plans, the Bureau later decided to run a limited 

amount of paid advertising in Mexico and France.
Page 17 GAO-04-470 2010 Census

Figure 1: Census Bureau Poster Advertising the Overseas Census

Source: U.S. Census Bureau.

Are you a U.S. citizen?

Here’s how.

Fill out a U.S. Census questionnaire, available

February–July 2004 at www.census.gov/overseas04 

It’s easy, important — and confidential.

U.S. Department of Commerce • Economics and Statistics Administration • U.S. CENSUS BUREAU • DB-3210

Get Counted.
Page 18 GAO-04-470 2010 Census

The Bureau will attempt to gauge the effectiveness of the marketing 

program by measuring participation (as measured by the number of 

responses) and public awareness. According to the Bureau, respondents 

who submit a questionnaire via the Internet will be asked to complete a 

short survey eliciting information on how they learned about the census 

test and what motivated them to participate. No similar survey is planned 

for people who pick up their surveys at an embassy or other distribution 

site. Thus, the Bureau will not have a parallel set of data from a group of 

respondents that might be demographically or behaviorally different from 

Internet respondents. 

The Bureau does, however, expect to conduct focus group interviews and 

debriefings to obtain feedback from mail respondents and stakeholder 

organizations. Focus group interviews targeting nonrespondents are 

planned as well.

Yet, as the Bureau acknowledges, participation, or the final count of U.S. 

citizens living in the selected countries, will only be an indicator of the 

number of people that heard about the test, completed the questionnaire, 

and submitted it to the Census Bureau. It will not be able to measure the 

Bureau’s success in getting Americans to respond because the universe of 

Americans overseas is unknown. 

Public awareness will also be difficult to measure because it includes an 

unknown number of people who were aware that a test census was being 

conducted but chose not to respond. Nevertheless, as noted above, the 

Bureau intends to interview both respondents and nonrespondents in an 

effort to determine their awareness and motivation for responding or not 

responding to the census test. To the extent the Bureau conducts these 

interviews, it will be important for it to include hard-to-count groups, such 

as dual nationals and migrant farm workers, that may have been outside 

the reach of the Bureau’s marketing campaign. 

Research Question #5: Use 

of Administrative Records 

Needs to be Thoroughly 

Tested

The Bureau plans on using administrative records such as Medicare and 

passport data to provide comparison information to assess 

(1) participation, (2) an invalid return detection system, and (3) the 

records’ potential use for building an address list. Specifically, the Bureau 

plans to compare the number of people counted at each site to federal tax, 

Medicare, U.S. Department of State, and foreign census records. While it is 

important for the Bureau to assess the utility of administrative records, it is 

unclear from the Bureau’s study plans how it will make this determination 
Page 19 GAO-04-470 2010 Census

given what Bureau officials have said is a large disparity between 

administrative record counts on the number of Americans living overseas 

at the three test sites. 

Further, because these administrative records were developed for different 

purposes and as a result are not well suited as a base for comparing against 

overseas counts, their relevance is uncertain. For example, not all 

American citizens who live abroad file tax returns; dependents are not 

always listed on tax returns; and dependents that are included in the tax 

form may not be U.S. citizens. After living abroad 30 days, Americans are 

no longer eligible for Medicare benefits; therefore, Medicare records may 

not be the most useful and only apply to U.S. citizens over 65 years old. 

U.S. State Department records are nonofficial and according to the Bureau 

inaccurate because the Department of State does not officially track either 

the number or location of U.S. citizens living in other countries. Finally, the 

type of administrative records kept by each country is unknown and earlier 

Bureau research found that census data from foreign countries do not 

contain the detailed information required for apportionment, redistricting, 

or other census uses.13

Research Question #6: 

Effectiveness of 

Enumeration Methods Will 

be Difficult to Assess

To determine the relative response from the two enumeration modes and 

their relative effectiveness, the Bureau will look at such data as the timing 

of returns by mode and site, and whether one mode provided more valid 

returns than the other. Respondents can either fill out a paper 

questionnaire or complete the form on the Internet. The Bureau will 

deploy an invalid return detection system to determine whether a form is 

valid and responses will be tallied by mode and by country. 

However, the Bureau recognizes that its analysis will contain several 

limitations. Key among them is that it will not be able to determine 

participation rates because the universe of Americans overseas is 

unknown. As a result, the analysis is limited to a count of the total number 

of forms returned at each site. In light of this and other limitations, it is 

unclear what conclusions the Bureau will be able to draw about the 

effectiveness of the two response modes. 

13 Issues of Counting Americans Overseas, U.S. Census Bureau.
Page 20 GAO-04-470 2010 Census

Indeed, just because one enumeration mode results in a larger number of 

returns from a particular demographic groupolder Americans, for 

examplemay not necessarily have anything to do with the mode itself. As 

a result, it would be inappropriate to say that one enumeration method was 

more effective than the other in counting senior citizens. This is because 

there are other factors that can influence the mode such as advertising or 

accessibility to the Internet or the paper questionnaire. Overall, while it 

will be important to collect information on the returns by method of 

enumeration, this information should not be construed as a measure of the 

effectiveness of that mode.

Research Question #7: 

System to Detect Invalid 

Returns Has Shortcomings 

Part of the processing of overseas returns involves validating that the 

respondents are within the scope of the enumeration; that is, that they in 

fact reside in one of the three overseas test areas. Thus, the Bureau needs a 

better method to detect invalid returns. 

To determine whether responses are within scope, the overseas 

enumeration questionnaire asks respondents to provide their Social 

Security and U.S. passport numbers. Although we agree with the 

importance of determining whether respondents reside overseas, the 

Bureau’s analysis will not assess this. Rather, the Bureau defines a valid 

return as one where at least one person in the household checked the U.S. 

citizen box on the questionnaire, provided a valid Social Security or U.S. 

passport number, and has been subject to and passes an algorithm that 

analyzes data from the questionnaire. All other returns are invalid. Thus, 

what the Bureau is really measuring is whether a questionnaire is eligible 

for further processing, and not whether the respondent lives abroad. Put 

another way, anyone who completes a questionnaire with valid data, 

including Social Security numbers, would be considered a valid return, 

regardless of whether the individual lived in the test areas. 

This is not an unlikely scenario given the way the Bureau set up its Internet 

site. Indeed, anyone—even if they live outside of the three test sites-can 

be included in the overseas count, so long as they provide the required 

information. The reason they can slip through the invalid return detection 

system is because the Bureau is unable to confirm the point of origin for 

questionnaires completed on the Internet. The Bureau is aware of this gap 

in the invalid return detection system, but has been unable to resolve this 

condition.
Page 21 GAO-04-470 2010 Census

Another potential problem is the Bureau’s sole reliance on Social Security 

numbers to validate returns for the 2004 test. The Bureau had also wanted 

to use passport numbers to validate returns. Although the Bureau has been 

negotiating with the Department of State for access to the passport 

database, the Bureau does not expect this to occur in time for use in the 

2004 test. Bureau officials said they were aware that there was a strong 

possibility that they would not be able to gain access to the passport file 

because the Bureau had not worked with Department of State data and that 

a memorandum of understanding would first need to be in place before the 

data would be released. Nevertheless, the Bureau believes that the impact 

of this would be low if it could be shown that using Social Security 

numbers alone to validate returns was sufficient. 

A third potential problem is that some people may be reluctant to provide 

their Social Security and passport numbers for privacy reasons. Based on 

the Bureau’s research, requesting this information could reduce 

participation levels. 

Research Question #8: 

Overseas Enumeration Will 

Not be Integrated With the 

Stateside Enumeration 

The Bureau, based on its earlier research, has already identified a list of 

barriers to integrating overseas with stateside data. They include different 

questionnaire content for the overseas form, detecting and eliminating 

duplication within and between overseas and stateside enumerations, 

timely geocoding of addresses, and limited resources. 

The Bureau plans to document the lessons learned from the 2004 overseas 

test and how they might apply to a more integrated test in 2006. In 

particular, the Bureau is to focus on the issues encountered or associated 

with collecting, capturing, and processing overseas data. While it will be 

important for the Bureau to thoroughly document these issues and their 

implications for integrating the two data sets, the Bureau does not intend to 

actually integrate any data from the overseas test with data being collected 

from a parallel stateside test it’s conducting at three Georgia counties and 

in Queens, New York. Without an actual integration, the Bureau may miss 

problems that will not likely be detected until a next test in 2006. 

Overseas Test Design 

Has Other 

Shortcomings

In addition to the limitations noted above, the overseas enumeration test 

has other limitations that will affect the Bureau’s ability to answer its key 

research objectives.
Page 22 GAO-04-470 2010 Census

Cost Data Will Not Identify 

the Cost of Conducting 

Future Tests or an Overseas 

Enumeration in 2010

Although one of the Bureau’s objectives for the overseas enumeration test 

is to determine the cost of collecting data from overseas citizens, the 

Bureau’s test design lacked a specific research question aimed at obtaining 

this information. More importantly, the cost information that the Bureau 

will collect will be of limited value because it will not be used to estimate 

the costs of future tests, nor model the costs of conducting a broader 

overseas enumeration in 2010. 

The Bureau developed a cost model for the 2000 Census that provided the 

agency with an automated means to estimate staffing and budget 

requirements. The Bureau used the cost model to support the budget 

process, as well as to answer questions from Congress, the Office of 

Management and Budget (OMB), and our office. The cost model could also 

estimate the budgetary impact of certain assumptions and alternative 

census-taking scenarios. 

The Bureau maintains that it would need more data than those that are now 

available to develop a cost model for an overseas enumeration in 2010. 

Nevertheless, while only at the beginning stages, the Bureau has some data 

points to begin developing a cost model for overseas enumeration or, at a 

minimum, for identifying major cost components. For example, Bureau 

officials told us that their agency will track and report the marketing, 

printing, postage, data capture, and processing costs for conducting the 

overseas enumeration at the three test sites. All of the costs provided by 

the Bureau are direct costs and could be specifically and uniquely 

attributed to a cost model for the overseas enumeration. Indirect costs, 

however—those that are not easily attributable to the overseas 

enumeration such as executive management or technical labor—would still 

need to be determined and captured. 

Cost will be an important factor to consider when making a decision on 

whether to enumerate Americans overseas. The cost of the 2010 Census, 

now estimated at more than $11.3 billion in current dollars, is the most 

expensive enumeration in the nation’s history. Consequently, it will be 

critical for the Bureau to have a mechanism for accurately and quickly 

estimating overseas enumeration costs so that Congress, other oversight 

groups, and the Bureau itself can have reliable information on which to 

base or advise decisions. 
Page 23 GAO-04-470 2010 Census

Testing Questionnaire 

Would Help Ensure Clarity 

and Accurate Responses

Testing a questionnaire with a sample of intended respondents before it is 

distributed is a standard approach that survey organizations employ to 

ensure questions are clear and understandable, and that respondents will 

be able to provide accurate information. In short, testing is an important 

quality assurance procedure that increases the likelihood that respondents 

will provide the information needed and help reduce the likelihood of 

inaccurate responses. 

The Bureau is aware of the benefits of testing questionnaires. In 

preparation for the 2000 Census, Congress budgeted millions of dollars for 

the Bureau to develop and test questionnaires during the 1990s, which it 

did using focus groups and one-on-one interviews. Moreover, the Bureau’s 

policy requires that demographic survey questionnaires be tested. 

However, the Bureau did not test the overseas enumeration questionnaire. 

Instead, the Bureau gave stakeholders the opportunity to review and 

comment on the questionnaire before it went to OMB for final approval. 

Stakeholder feedback was generally positive. One change that was made in 

response to stakeholder feedback was that “United States” was added to 

“passport” in the question that asked for a respondent’s passport number. 

While sharing the questionnaire with stakeholders is important, it should 

not be seen as a replacement of questionnaire testing. 

According to Bureau officials, the Bureau developed the overseas 

questionnaire by modifying the Census 2000 short form to collect data 

needed for the overseas count. New questions asked respondents for their 

employment status, Social Security number, and passport number. The 

Bureau believed that the new questions did not require testing. However, 

as stated earlier, collecting Social Security numbers and passport numbers 

could be problematic. While some stakeholders believed this to be 

acceptable, other stakeholders believe it could reduce participation, 

especially in Mexico where dual nationals reside. In addition, the 

questionnaire requests data on everyone in the household even if a person 

is not a U.S. citizen. These questions could be seen as too intrusive and 

potentially could stop someone from completing the form, thus resulting in 

an undercount. Since there was no testing of the questionnaire, the Bureau 

cannot be certain of the impact of these questions.
Page 24 GAO-04-470 2010 Census

Data Analysis Will Not 

Provide Congress with 

Requested Information

In a 2001 report to Congress, “Issues of Counting Americans Overseas in 

Future Censuses,” the Bureau indicated that it would provide Congress 

with data on the number of people in the military, federal, private business, 

nonprofit, and other categories. However, the Bureau is only collecting 

data on the number of military and federal workers; people working in 

other sectors will be grouped in an “other” category. The reason that the 

Bureau is unable to provide the additional breakdown is because the length 

of the questionnaire did not allow for additional check boxes. Therefore, 

the Bureau collapsed people working in the private sector and nonprofit 

organizations and others into one category. 

The Bureau Has Identified a 

Number of New Challenges 

to Counting Overseas 

Americans

The soundness of the test design notwithstanding, the Bureau has already 

identified several country-specific challenges to counting American 

citizens at each of the test sites. Together, they suggest that an 

enumeration of Americans on a more global scale in 2010 would introduce 

a number of unforeseen obstacles that the Bureau would need to address 

on a country-by-country basis. For example, shortly before the test was to 

begin in France, the French government contacted the Census Bureau 

indicating that French law prohibited the collection of race and Hispanic 

origin data. Furthermore, they were also opposed to the U.S. government 

asking for information on persons who were not American citizens. The 

Bureau worked with the French government and it was agreed that an 

advisory would be posted on the Internet site explaining that under French 

law it was not mandatory to respond to the questionnaire. 

Problems have also surfaced in Mexico and Kuwait. Stakeholders and 

Bureau officials have told us that the mail system in Mexico is not always 

reliable. The concern is that the questionnaires may not make it to the 

Census Bureau, or arrive too late to be processed. In Kuwait, security 

concerns have prevented the Census Bureau from posting the location of 

sites where Americans can pick up the questionnaire. While the impact of 

these problems is difficult to quantify, it may prevent some Americans from 

completing the questionnaire and being counted. 
Page 25 GAO-04-470 2010 Census

The Rights and 

Obligations of 

Americans Overseas 

Vary

Americans residing abroad do not have the same rights and obligations 

under federal programs and activities as Americans living in the United 

States. In order to determine the rights and obligations of Americans 

residing abroad, one must examine the specific statutes governing each 

program. For this study, we examined whether overseas Americans can 

vote in federal elections; are subject to federal income tax; and can receive 

Social Security, Supplemental Security Income, and Medicare benefits (see 

table 3). Stateside, these programs cover millions of Americans; whether 

and how they extend to Americans living overseas could help inform the 

treatment of U.S. expatriates in the decennial census, to the extent there 

are any patterns. 

Table 3: The Applicability of Federal Programs to Americans Overseas Varies

Source: GAO analysis of applicable statutes and court decisions.

Voting Rights American citizens who reside outside of the United States have the right to 

vote in federal elections under the 1986 Uniformed and Overseas Citizens 

Absentee Voting Act (UOCAVA).14 Under this law, U.S. citizens residing on 

foreign soil can vote in federal elections as absentee voters of their last 

state of residence, even if they have no intention of ever returning to the 

United States. (American citizens residing in U.S. territories, however, 

cannot so vote. The territories include Puerto Rico, the Northern Mariana 

Islands, the U.S. Virgin Islands, Guam, and American Samoa.)

Federal program Applicability to U.S. citizens residing overseas

Voting U.S. citizens residing outside of the country have the right to vote 

in federal elections in their last state of residence as outlined in 

federal statute.

Federal income tax U.S. citizens are taxed on their worldwide income, subject to 

certain exclusions in the Internal Revenue Code.

Social Security 

payments

Americans living abroad are entitled to receive benefits, subject 

to a few exceptions.

Supplemental 

Security Income

Individuals are not entitled to benefits once they reside outside of 

the United States for 30 days.

Medicare No coverage for Americans outside of the United States, with a 

limited exception for services occurring near U.S. borders.

14 42 U.S.C. §§ 1973ff-1 to 1973ff-6.
Page 26 GAO-04-470 2010 Census

UOCAVA repealed legislation enacted in 1955 that was designed to prevent 

members of the Armed Forces and their families from being denied their 

voting rights when absent from their home or in a far-off place. The goal 

was to make it easier for military personnel to cast votes in any federal 

primary, general, or special election through absentee balloting 

procedures.15 While the 1955 law was amended several times to, among 

other purposes, specifically include other Americans living overseas, in 

1986 Congress acknowledged that there was a legitimate need for further 

legislation. UOCAVA’s main purpose was to facilitate absentee ballot 

voting, while also providing “for a write-in absentee ballot that may be used 

in Federal general elections by overseas voters who, through no fault of 

their own, fail to receive a regular [State] absentee ballot in sufficient time 

to vote and return the ballot prior to the voting deadline in their State.”16

Federal Income Tax U.S. citizens are taxed on their worldwide income, subject to certain 

exclusions specified in the Internal Revenue Code. In 1913, the enactment 

of the Sixteenth Amendment to the U.S. Constitution gave Congress “the 

power to lay and collect taxes on income, from whatever source derived, 

without apportionment among the several States, and without regard to 

any census or enumeration.” After ratification of this constitutional 

provision, Congress imposed a tax on the net income of every U.S. citizen, 

wherever they lived.17 

That the Constitution vests Congress with the power to tax Americans 

living overseas on their income earned outside of the United States was 

reinforced by the Supreme Court in 1924 when it ruled: “[g]overnment, by 

its very nature, benefits the citizen and his property wherever found, and 

therefore has the power to make the benefit complete. Or, to express it 

another way, the basis of the power to tax was not and cannot be made 

dependent upon the situs of property in all cases, it being in or out of the 

United States, nor was not and cannot be made dependent upon the 

domicile of the citizen,

15 Bush v. Hillsborough County Canvassing Bd., 123 F. Supp. 2d 1305, 1310-12 (N.D. Fla. 

2000).

16 H.R. Rep. No. 99-765 at 5 (1986), cited in Bush at 1310-11.

17 Revenue Act of 1913, ch. 16, § IIA, 38 Stat. 114, 166.
Page 27 GAO-04-470 2010 Census

that being in or out of the United States, but upon his relation as citizen to 

the United States and the relation of the latter to him as citizen.”18 

There are statutory exclusions, however. Generally, a U.S. citizen or 

resident may exclude a portion (ascending each year to $80,000 during or 

after 2002) of his earned income if he is a resident of a foreign country for a 

full calendar year or is physically present in a foreign country for 330 days 

of any 12 consecutive months and otherwise meets certain requirements.19 

This foreign earnings exclusion principally aims to encourage U.S. citizens 

and residents to work abroad without worrying about how it might 

increase their tax liability. Indeed, in view of the nation’s continuing trade 

deficits, Congress deemed it important to allow Americans working 

overseas to contribute to the effort to keep American business 

competitive.20

Social Security Payments The Social Security Act provides individuals over the age of 62 who have 

worked for a minimum number of years with monthly benefit payments.21 

Social Security checks generally follow recipients wherever they go around 

the world, subject to only a few exceptions.22 In fact, Social Security 

payments continue no matter how long a beneficiary stays outside of the 

United Stateseven if the individual retires overseas.23 Thus, if you are a

18 Cook v. Tait, 265 U.S. 47, 56 (1924).

19 26 U.S.C. § 911.

20 Tobias M. Lederberg, The Qualified Individual Under I.R.C. Section 911 (d) After Jones 

v. Commissioner: Rethinking Characteristics of Eligibility for the Foreign Earned 

Income Exclusion, 10 B.U. International Law Journal 143, 145 (1992).

21 See 42 U.S.C. § 402; see also Sarah H. Bohr, Overview of Social Security Insurance 

Benefits and Supplemental Security Income, 40 Soc. Sec. Rep. Ser. 685, 687 (1993).

22 U.S. citizens living in certain specified countries, for example Cuba and North Korea, 

cannot receive social security payments while they reside there. Once they leave those 

countries, they can receive all of their withheld payments.

23 James R. Whitman, Venturing Out Beyond the Great Wall of Medicare: A Proposal to 

Provide Medicare Coverage Outside the United States, 8 Elder L.J. 181, 208 (2000) 

hereinafter (Venturing Out).
Page 28 GAO-04-470 2010 Census

U.S. citizen residing abroad you generally continue to receive your monthly 

benefits.24

Supplemental Security 

Income

Supplemental Security Income (SSI) is a “need-based” program designed to 

help individuals who are over the age of 65, blind, or disabled.25 SSI 

benefits cease once a recipient remains outside the United States for a 

period of at least 30 days.26 If the recipient returns to this country within 30 

days, SSI benefits are to continue as before.27

Medicare Coverage Since Medicare became effective almost 35 years ago, the program has 

excluded coverage for health care services received outside of the United 

States, even if those services are medically necessary.28 There is a limited 

exception for services occurring near U.S. borders.29

The constitutionality of foreign exclusion was raised in a 1986 court 

decision.30 In that case, plaintiffs argued that by leaving Medicare 

beneficiaries without health care coverage once they leave the United 

States, the foreign exclusion deters these same individuals from traveling 

overseas and consequently infringes on their constitutional right to travel 

24 See Your Payments While You Are Outside the United States, SSA Publication #05-10137, 

ICN 480085, July 2002.

25 42 U.S.C. §§ 1381 – 1383c.

26 The Social Security Administration considers individuals as being abroad if they have 

been away from the United States for at least 30 consecutive days, and until they return and 

stay in the United States for at least 30 consecutive days.

27 42 U.S.C. § 1382(f); see Califano v. Aznavorian, 439 U.S. 170 (1978).

28 Medicare became effective in July 1966. See Social Security Amendments of 1965, Pub. L. 

No. 89-97, 79 Stat. 286 (codified in scattered sections of 42 U.S.C.). At that time, it already 

included the foreign exclusion. Id. at §1862(a)(4) (codified at 42 U.S.C. § 1395y(a)(4)).

29 Medicare’s foreign exclusion generally denies payment for all medical services received 

outside the United States, subject only to the Canadian travel exception and the exceptions 

for emergency inpatient care where a foreign hospital is closer to the site of an emergency 

occurring within the United States and nonemergency inpatient care where the foreign 

hospital is closer to the patient’s U.S. residence than a domestic hospital. 42 U.S.C. § 

1395y(a)(4).

30 Milkson v. Secretary of Health and Human Services, 633 F. Supp. 836 (E.D.N.Y. 1986).
Page 29 GAO-04-470 2010 Census

abroad. The district court, however, found the Medicare foreign exclusion 

to pass constitutional muster. The court reasoned that the difficulties of 

administering medical services abroad and the concern that Medicare 

funds be spent within the United States were not particularly compelling, 

but were rationally based. It thus concluded that the foreign exclusion 

satisfied the rational basis test and summarily dismissed the plaintiff’s 

claim.31

Legislation Would be 

Needed To Require the 

Census Bureau to 

Enumerate Americans 

Abroad

The Bureau has the discretion to decide whether to count American 

citizens abroad. Indeed, there is nothing in the Constitution, the Census 

Act, or court decisions that would require the Bureau to count Americans 

living overseas, or to not count such individuals. Consequently, if Congress 

wanted to require the Census Bureau to include this population in the 2010 

Census, legislation would be needed. 

The issue of whether, and if so how, to count Americans living overseas 

was raised in federal court after both the 1990 and 2000 censuses. 

Massachusetts challenged the results of the 1990 Census claiming that it 

lost a seat in the House of Representatives as a result of the Secretary of 

Commerce’s decision to enumerate and apportion federal employees 

stationed abroad.32 Conversely, Utah challenged the results of the 2000 

Census maintaining that it lost a congressional seat because no overseas 

Americans other than federally affiliated groups were included in the 

apportionment numbers.33 In both cases, the courts determined that the 

Census Bureau has discretion under the Constitution and the Census Act to 

decide whether to count Americans residing overseas.

31 Both Social Security and Medicare are premised upon the idea that “you get what you put 

in” because funds for each program are paid out of employee and employer payroll 

withholding taxes. Both utilize the same criteria to determine eligibility. Yet, Social Security 

payments follow beneficiaries overseas, no matter how long they remain outside the Untied 

States, while Medicare benefits stop at the border. And while SSI is entirely funded by the 

federal government without the help of payroll withholding taxes, the government allows 

beneficiaries to receive benefits if they remain outside the United States for up to 30 days. 

See Venturing Out at 207-208.

32 Franklin v. Massachusetts, 505 U.S. 788 (1992).

33 Utah v. Evans, 143 F. Supp. 2d 1290 (D. Utah 2001).
Page 30 GAO-04-470 2010 Census

Conclusions The design of the Bureau’s overseas enumeration test falls short in many 

respects, and the data that the Bureau will collect as a result of this 

exercise may only partially answer key questions relating to feasibility, 

cost, and data quality. The Bureau overstated the test’s ability to answer its 

key research objectives and, as a result, congressional decision making on 

this issue will be that much more difficult.

The full results of the overseas enumeration test will not be available until 

early 2005, when the Bureau expects to issue the last of a series of 

evaluations. However, its experience thus far has made it clear that 

counting Americans abroad as an integral part of the 2010 Census would be 

an extraordinary challenge, one that would introduce new resource 

demands, risks, and uncertainties to an endeavor that is already costly, 

complex, and controversial. 

That said, to the extent that better data on the number and characteristics 

of Americans abroad might be useful for various policymaking and other 

nonapportionment purposes, such information does not necessarily need 

to come from the decennial census. This data could, in fact, be acquired 

through a separate survey or some other type of data collection effort, 

although it would still be a difficult undertaking. 

The Bureau is unlikely to decide—and in fact should not decide—on its 

own, whether or not to enumerate Americans abroad, and will need 

congressional guidance on how to proceed. Therefore, to give the Bureau 

as much planning time as possible, it will be important for Congress to 

soon decide whether the Bureau should be required to count this 

population group as part of the 2010 Census or as part of a separate data 

collection effort or whether there are so many obstacles to a successful 

overseas count regardless of the approach that the Bureau should shelve 

any plans for further research and testing. 

Should Congress desire an overseas count—as part of the decennial census 

or a separate effortit should consider providing the Bureau with input on 

how it expects to use the data on overseas Americans. The purposes of the 

data drive the design of the enumeration; therefore, once the Bureau has a 

clear idea on how the data will be used, it would be better positioned to 

plan a test that will more accurately assess the feasibility of the 

procedures, methodology, and resource requirements needed to 

accomplish the type of count that Congress desires. Moreover, if a second 

test of enumerating Americans abroad is needed in 2006, it will be 
Page 31 GAO-04-470 2010 Census

important for the Bureau to address the shortcomings of the design of the 

2004 overseas test. Conducting a second test without this information and 

a sound design to fulfill it would not be cost-effective. 

Matters for 

Congressional 

Consideration

In order to give the Bureau as much planning time as possible, Congress 

may wish to consider coming to an early decision on whether the Bureau 

should be required to enumerate overseas Americans, and if so, whether 

they should be counted as part of the decennial census or by some other, 

separate data collection effort. Should Congress desire an overseas 

count—be it part of the decennial census or a separate data collection 

effortit should consider telling the Bureau how the data would be used 

(e.g., for purposes of apportionment, redistricting, allocating federal funds, 

or a tally of the U.S. overseas population). This information would enable 

the Bureau to more thoroughly evaluate procedures and resources needed 

to meet Congress’s specific requirements, and ultimately provide Congress 

with better information with which to gauge the feasibility of such an 

approach.

Recommendations for 

Executive Action

To the extent that the Bureau proceeds with plans to conduct a second 

feasibility test in 2006, we recommend that the Secretary of Commerce 

direct the Bureau to take appropriate steps to improve the soundness of the 

test design and better address the objectives of an overseas enumeration. 

Specific steps should include the following 12 actions:

• Be more transparent with Congress and other stakeholders on what 

variables the Bureau is able to quantitatively measure, as well as what 

research questions the Bureau can and cannot answer.

• Develop and pretest clear residence rules and appropriate guidelines on 

who should be included in the count to prevent confusing prospective 

respondents.

• Ensure that its outreach and promotion strategy, data collection 

methods, and other aspects of the design are free from cultural and 

other biases that could introduce systemic errors.

• Explore the possibility of developing more comprehensive measures of 

data quality.
Page 32 GAO-04-470 2010 Census

• Test the Bureau’s ability to geocode certain noncity-style addresses such 

as those with post office box numbers.

• Research how best to market the overseas census to hard-to-count 

groups and other, less visible, segments of a country’s overseas 

American population.

• Develop procedures to determine whether a return is within the scope 

of the enumeration—i.e., that it is truly from an overseas source.

• Actually integrate overseas data with stateside data to more thoroughly 

test this activity.

• Develop a cost model to provide the Bureau and Congress with better 

estimates of the costs of conducting an overseas census under different 

methodological and other scenarios.

• Thoroughly pretest the overseas questionnaire with various groups of 

potential respondents to ensure the questions are clear, appropriate, and 

can be accurately answered by the unique population groups that are 

found overseas. 

• Add more response options to the questionnaire item concerning 

respondents’ primary activity. Specific information on whether an 

individual is retired, a student, or working for a private company, etc., 

could provide the Bureau with valuable data on the characteristics of 

overseas Americans that could be important for some of the purposes 

for which the data might be used, and just as important, could provide 

the Bureau with invaluable marketing data that the Bureau could use to 

develop a more effective outreach and promotion campaign.

• Work with Congress and other stakeholders to develop a broad 

consensus on what would be acceptable levels of accuracy, 

completeness, participation, and other key measures of performance.

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 April 13, 2004, which are 

reprinted in appendix I. The Bureau generally agreed with our key findings, 

conclusions, and recommendations, and suggested some additional 

context, technical corrections, and clarifications, which we have 

incorporated.
Page 33 GAO-04-470 2010 Census

The Bureau disagreed with our recommendation that it be more 

transparent with Congress and other stakeholders on what variables the 

Bureau is able to quantitatively measure, as well as what research 

questions the Bureau can and cannot answer. The Bureau believes that it 

has always been transparent about its plans and the likely limitations of 

this first test. 

Although the Bureau’s test plan describes the limitations associated with 

answering its various research questions, nowhere does it disclose that its 

fundamental research objective to “determine the feasibility, quality, and 

cost of collecting data from U.S. citizens living overseas” will only be 

partially answered. Indeed, none of the documentation we reviewed, 

including the test project plan or briefing slides provided to congressional 

staff in April 2003, indicated either explicitly or implicitly that this test was, 

as the Bureau maintains, “only the most basic assessment of feasibility,” or 

that the Bureau would not be able to fully answer its key questions 

regarding feasibility, data quality, and cost. For example, as noted in our 

report, even though one of the principal objectives of the test was to 

determine the cost of collecting data from U.S. citizens living overseas, the 

Bureau’s test design lacked a research question for this objective. 

The Bureau agreed, however, that as it completes its evaluations and 

documents its findings from the test, it will be “critical” to highlight the 

various qualitative and quantitative limitations that could affect 

congressional deliberations on this subject. 

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.
Page 34 GAO-04-470 2010 Census

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

contact me at (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 Lisa Pearson, Charlesetta Bailey, Betty 

Clark, Ellen Grady, Ronald La Due Lake, Andrea Levine, and Daniel 

Messler.

Patricia A. Dalton

Director

Strategic Issues
Page 35 GAO-04-470 2010 Census

Appendix I

Comments from the Department of Apendxies

Commerce ApendxiI
Appendix I

Comments from the Department of 

Commerce

Page 36 GAO-04-470 2010 Census
Appendix I

Comments from the Department of 

Commerce

Page 37 GAO-04-470 2010 Census
Appendix I

Comments from the Department of 

Commerce

Page 38 GAO-04-470 2010 Census
Appendix I

Comments from the Department of 

Commerce

Page 39 GAO-04-470 2010 Census
Page 40 GAO-04-470 2010 Census

Appendix II

Criteria for Evaluating Census Research 

Design for Overseas Enumeration Test ApendxiI

1. How clearly are the objectives of the research design presented?

a. Are the test/research objectives and/or questions specified clearly in 

the design? 

b. Are concepts defined where necessary? 

2. How sound is the research design? 

a. Do the research questions match the research objectives? 

b. Is the rationale for the determination of the size and type of sample 

explained? 

c. Are potential biases recognized and addressed (e.g., cultural bias, 

question item bias, or sample bias)? 

d. Does the sample selection reflect the full range and full cycle of 

entities or processes that should be considered? 

3. How appropriate is the data collection strategy? 

a. Is the mode of data collection stated clearly?

b. Is the timing and frequency of data collection considered? 

c. Is the data collection method appropriate for reaching the intended 

sample population? 

d. Is the data collection instrument appropriate for the sample 

population? 

e. Is a plan for administering and monitoring the data collection 

discussed in the design? 

f. How well does the design address factors that may interfere with 

data collection? 

g. How well are methods for assuring adequate response rates 

addressed?
Appendix II

Criteria for Evaluating Census Research 

Design for Overseas Enumeration Test

Page 41 GAO-04-470 2010 Census

4. How thoroughly did Census test the survey instrument(s)?

a. Were any new survey items cognitively tested?

b. Were field tests conducted to identify the best question wording and 

determine whether changes in questions are likely to achieve the 

change objectives?

c. Were research studies used to address possible changes in the 

questionnaire?

5. How involved were relevant stakeholders in the research planning?

a. Were relevant stakeholders for the research objectives identified?

b. Were stakeholders involved in the planning or review of the methods 

of data collection?

c. Were appropriate stakeholders participants in the review and testing 

of the questionnaire? 

6. How sound is the design’s plan for reaching the target sample?

a. Are the goals of the outreach strategy feasible?

b. Are the methods of the outreach strategy viable? 

7. How sound is the plan for implementing test site activities?

a. Does the design consider possible mistakes and their consequences 

(including their seriousness)?

b. Does the design assure that sufficient evidence will be gathered to 

answer the research questions?

c. Does the design consider the level of difficulty in obtaining the data? 

8. How good is the relationship between the research design and the time 

and resources allocated?

a. Does the execution of the design appear feasible within the stated 

time frame?
Appendix II

Criteria for Evaluating Census Research 

Design for Overseas Enumeration Test

Page 42 GAO-04-470 2010 Census

b. Do the proposed resources for the execution of the design appear 

feasible?

c. Are the roles and responsibilities of key parties specified? 

9. How well does the design develop a data analysis plan?

a. Is the method of enumeration clearly presented?

b. Are the proposed analytical techniques for analysis presented?

c. Does the design provide a basis for comparing the results of the 

research?

d. Does the design discuss the possible limitations of the findings/test 

results?
Page 43 GAO-04-470 2010 Census

Appendix III

2004 Overseas Test Census Questionnaire ApendxiI

The Census Bureau estimates that, for the average

household, this form will take about 10 minutes to complete,

including the time for reviewing the instructions and answers.

Comments about the estimate should be directed to:

Paperwork Project 0607-0903, U.S. Census Bureau, 4700

Silver Hill Road, Stop 1500, Washington, DC 20233-1500. You

may e-mail comments to Paperwork@census.gov; use

"Paperwork Project 0607-0903" as the subject.

FOREIGN ADDRESS AND TELEPHONE NUMBER

Please provide the complete address and

telephone number for this residence.

C.

OMB No. 0607-0903: Approval Expires 12/31/2004

DC

This is the official form for all persons living at this address in France, Kuwait, and

Mexico. It is quick and easy, and your answers are protected by law. Complete this

census form and help us develop new methods for the next census.

NUMBER OF PERSONS IN HOUSEHOLD

How many persons were living in this household on

April 1, 2004?

A.

U.S. DEPARTMENT OF COMMERCE Economics and Statistics Administration

U.S. CENSUS BUREAU

Number of persons

Start Here

Form DO-1 (10-10-2003)

2004

Overseas

Test

Census

Go to www.census.gov/census2004

OR

Fill out this form with a black or blue pen and mail it

back in the envelope provided.

Choose one way to provide your census information:

Telephone number

Country

Address

Beginning on the next page, please answer the

following questions for each person living in this

household. Start with the name of any adult living

here. We will refer to this person as Person 1.

Respondents are not required to respond to any information

collection unless it displays a valid approval number from the

Office of Management and Budget (OMB). This test has been

approved and given the following OMB number: 0607-0903.

FOR OFFICE USE ONLY

A. JIC1 B. JIC2 C. JIC3 D. JIC4

➞

If you are completing more than one form for this

household, provide this information.

FORM OF FORMS

B.

NOTE: This form has space to report six

persons. If there are more than six persons

living here, complete additional forms as

needed.
Appendix III

2004 Overseas Test Census Questionnaire

Page 44 GAO-04-470 2010 Census

Source: U.S. Census Bureau.

Note: This appendix does not include the entire census questionnaire. The same questions are asked 

of person 1 through person 6, as such, only questions for person 1 have been included. 

Person 1

NOTE: Please answer BOTH Questions 11 and 12.

Is this person Spanish/Hispanic/Latino? Mark the

"No" box if not Spanish/Hispanic/Latino.

11.

Yes, Puerto Rican

Yes, Cuban

What is this person’s race? Mark one or more races to

indicate what this person considers himself/herself to be.

12.

White

Black, African Am., or Negro

American Indian or Alaska Native — Print name of enrolled or principal tribe.

Japanese

Korean

Vietnamese

Native Hawaiian

Guamanian or Chamorro

Samoan

Other Pacific Islander — Print race.

Asian Indian

Chinese

Filipino

Other Asian — Print race.

What is Person 1’s name? Print name below.

Last Name

First Name MI

1.

2. Is this person a U.S. citizen?

Yes

No

Male

Female

What is this person’s age and what is this person’s date

of birth?

10.

Month Day Year of birth

✗

✗

No, not Spanish/Hispanic/Latino

Yes, Mexican, Mexican Am., Chicano

Yes, other Spanish/Hispanic/Latino — Print group.

9. What is this person’s sex? Mark ONE box.

Age on April 1, 2004

If more persons live here, continue with Person 2.

➞

➞

Street

Number

State ZIP Code

City

Apt. No./Location

What is the last U.S. address at which this person resided

in the state reported in Question 7? NOTE – A Post Office

Box number may not be used as a stateside address.

8.

What is this person’s U.S. state of last residence or, if

military, home state of record?

7.

– –

None

4. What is this person’s Social Security Number?

Print a 9-digit Social Security Number in the boxes below.

What is this person’s U.S. passport number?

Print the passport number in the boxes provided.

Print numbers in boxes.

Form DO-1 (10-10-2003) 2

What is this person’s primary activity? Mark ONE box.

Answer this question only if this person is 16 years old or over.

5.

Serving on active duty in the U.S. Armed Forces, military Reserves,

or National Guard

Employed by the U.S. government

Other – Print primary activity

6. ✗

None

Never lived in the U.S. – Skip to Item 9

Never lived in the U.S.

✗

3. Where was this person born?

In the United States – Print name of state.

Outside the United States – Print name of foreign country, or Puerto

Rico, Guam, etc.

(450236)
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