2020 CENSUS

Local Administrative 

Records and Their Use 

in the Challenge 

Program and 

Decennial

Report to the Chairman, Committee on 

Homeland Security and Governmental 

Affairs, U.S. Senate

February 2013

GAO-13-269

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-269, a report to the 

Chairman, Committee on Homeland Security 

and Governmental Affairs, U.S. Senate 

February 2013

2020 CENSUS

Local Administrative Records and Their Use in the 

Challenge Program and Decennial

Why GAO Did This Study

The Bureau’s Population Estimates 

Challenge Program gives local 

governments the opportunity to 

challenge the Bureau’s annual 

estimates of their population counts 

during the years between decennial 

censuses. Challenges rely on local

administrative records, such as 

building and demolition permits. In

addition to their role in the challenge 

program, these and national 

administrative records, such as tax 

data and Medicare records, could save 

the Bureau money if they are used to

help build the Bureau’s master address 

list, and reduce the need for certain 

costly and labor-intensive door-to-door 

visits among other things. GAO was 

asked to review changes to the 

challenge program and the Bureau’s 

use of administrative records.

This report describes the changes to: 

(1) how local administrative records will 

be used in the challenge program; (2) 

how the Bureau will assure the quality 

of population estimates updated by the 

challenge program; and describes (3) 

what plans, if any, the Bureau has to 

use the types of local administrative 

records used for the challenge 

program to improve the cost or quality 

of the 2020 Decennial Census. 

GAO reviewed documentary and 

testimonial evidence from Bureau 

officials and state and local data 

experts. Additionally, GAO interviewed 

Bureau officials to identify changes to 

the challenge program and reviewed 

documentation on the challenge 

program’s quality assurance 

processes. GAO provided a draft of 

this report to the Department of 

Commerce. In response the Bureau

provided technical comments, which 

were incorporated as appropriate.

What GAO Found

The Census Bureau (Bureau) issued significant changes to rules governing the 

records that communities use to challenge the Bureau’s population estimates. 

Previously, the Bureau routinely accepted all challenges, largely without regard 

to the data sources cited or provided so long as they supported the calculations 

and covered the appropriate reporting periods. According to Bureau officials, 

these changes are based on research that shows that estimates based on some

methods and records (e.g., births, deaths, and migration) are substantially more 

accurate than estimates based on others. Among other changes, the Bureau 

modified procedures so that challenges by subcounty governments to the 

Bureau’s estimates of people living in housing units will no longer affect countylevel population estimates. Moving forward, any such challenge resulting in an 

increase in the estimate of a subcounty population will be offset by a downward 

revision to the population estimate of all other communities in the same county.

Also, the Bureau plans to routinely review population challenges in light of each 

community’s population growth trend. Corroborating data will be required for 

challenges inconsistent with the trend.

Challenge program officials told GAO that in the past the program focused quality 

assurance on (1) reviewing the calculations in the documentation submitted by 

local governments as part of challenge submissions and (2) checking documents 

and calculations for internal consistency. Moving forward, the Bureau is 

preparing a quality assurance plan for Bureau staff who review challenges to 

better ensure proper handling and processing of challenges, as well as the 

review of calculations. 

The Bureau’s 2020 research and testing program is exploring the use of local 

administrative records for the 2020 Census, such as those used in the challenge 

program, but this effort is a lower priority than research on the use of national 

records, in part because national administrative records show greater promise

than local records for controlling costs. Bureau officials said local records show 

the most promise for supporting the development of the 2020 address list. 

Specifically, the Bureau is exploring how it can use local records to more 

seamlessly and continually update address lists and maps, rather than waiting to 

receive such information as part of a one-time decennial update. Bureau officials 

stated that it is important to continue research on local records because they may 

be helpful in targeting decennial operations to hard-to-count groups or those in 

certain geographic areas. However, the results of 2010 Census research and 

testing on national records have led Bureau officials to conclude that continuing 

research on national records should be a higher priority.

View GAO-13-269. For more information, 

contact Robert Goldenkoff at (202) 512-2757 

or goldenkoffr@gao.gov.
Page i GAO-13-269 Census Challenge Program

Letter 1 

Background 3

The Bureau Revised Rules Governing Data Sources and Procedures 

for the Challenge Program to Improve Accuracy of Population 

Estimates 5

The Bureau Reviews Quality of Calculations and Requires Local 

Governments to Certify that Data Are Accurate 10

The Bureau has Limited Plans for Using Local Records to 

Supplement National Records for 2020 11

Agency Comments and Our Evaluation 14

Appendix I Objectives, Scope, and Methodology 16

Appendix II Comments from the Department of Commerce 17

Appendix III GAO Contact and Staff Acknowledgments 19

Table

Table 1: The Challenge Program Resulted in Larger Percentage 

Increases in Estimated Population for Smaller 

Communities than for Larger Ones from 2001 to 2008 5

Figures

Figure 1: Changes in Administrative Records Accepted by the 

Challenge Program 8

Figure 2: Potential Uses of Administrative Records the Bureau Is 

Considering for the 2020 Census 13

Contents 
Page ii GAO-13-269 Census Challenge Program

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Page 1 GAO-13-269 Census Challenge Program

United States Government Accountability Office

Washington, DC 20548

February 21, 2013

The Honorable Thomas R. Carper

Chairman

Committee on Homeland Security and Governmental Affairs

United States Senate

Dear Chairman Carper:

With a life cycle cost of around $13 billion, the 2010 Census was the most 

expensive population count in U.S. history, costing over 50 percent more 

than the $8.1 billion 2000 Census.1 The U.S. Census Bureau (Bureau) 

estimates that if it used the same approach to count people in 2020 as it 

did in 2010, it could potentially cost around $25 billion, or $151 to count 

each housing unit compared to the $97 it cost in 2010.2

Administrative records could save the Bureau money if the Bureau uses 

them to reduce the need for certain costly and labor-intensive door-todoor visits by Bureau employees, such as collecting data in-person from 

nonrespondents, supporting quality control, or helping to evaluate the 

quality of the census. The Bureau has initially estimated that by 

expanding the use of administrative records it could save up to $2 billion 

by reducing the workload from these and other operations. Administrative 

records are already used by the Bureau’s Population Estimates 

Challenge Program, which gives local governments the opportunity to 

challenge the Bureau’s annual estimates of their population counts during 

The Bureau is

considering a number of ways to control the costs of the 2020 Census 

including the expanded use of administrative records, that is, data 

collected and maintained by other organizations for the purpose of 

administering programs and providing services, such as Medicare 

enrollment data or Selective Service System registration address 

information. The Bureau made limited use of administrative records for 

the 2010 Census. For example, the Bureau used United States Postal 

Service files to update its address list, and federal agency records, such 

as those from the Department of Defense, were used to count military 

and federal civilian employees stationed outside of the United States.

 

1

In constant 2010 dollars. 

2

This assumes real costs grow at the same rate they did between 1990 and 2010.

 
 

Page 2 GAO-13-269 Census Challenge Program

the years between decennial censuses. Under the challenge program, 

local governments use their own local administrative records to question 

the Bureau’s official population statistics. While not affecting 

congressional apportionment or redistricting, the challenges can affect 

other uses of census data, such as various state and federal assistance 

programs where funding and eligibility are based in whole or in part on 

population size. Over the past several months, the Bureau considered 

various changes to the challenge program that are designed to, among 

other improvements, enhance the accuracy of the intercensal estimates. 

The Bureau issued the final rule in the January 3, 2013, Federal 

Register,3

Given the importance of accurate population estimates, you asked us to 

describe these changes. This report describes (1) how local 

administrative records will be used in the challenge program and (2) how 

the Bureau will assure the quality of population estimates updated by the 

challenge program. Moreover, you asked us to describe the role 

administrative records could play in controlling census costs. Accordingly, 

this report describes what plans, if any, the Bureau has to use the types 

of local administrative records currently used for the challenge program to 

improve the cost or quality of the 2020 Decennial Census.

and the changes became effective as of February 4, 2013.

For all three objectives, we reviewed documentation from the Bureau on 

2020 research and testing of administrative records, including local 

records. We reviewed documentary and testimonial evidence from 

Bureau officials and state and local data experts to identify specific 

processes and local records used under the challenge program. 

Additionally, we interviewed Bureau officials to identify changes to the 

challenge program and reviewed documentation on the challenge 

program’s quality assurance processes from the Bureau Population 

Division officials responsible for implementing the program. More 

information on our scope and methodology can be found in appendix I.

We conducted our work from September 2012 to February 2013 in 

accordance with all sections of GAO’s Quality Assurance Framework that 

are relevant to our objectives. The framework requires that we plan and 

perform the engagement to obtain sufficient and appropriate evidence to 

meet our stated objectives and to discuss any limitations in our work. We 

 

3

78 Fed. Reg. 255 (Jan. 3, 2013).
 

Page 3 GAO-13-269 Census Challenge Program

believe that the information and data obtained, and the analysis 

conducted, provide a reasonable basis for any findings and conclusions in 

this product.

Administrative records are a growing source of information about 

individuals and households. Administrative records include records from 

government agencies, such as tax data and Medicare records, as well as 

commercial sources from major national data vendors. National 

administrative records refer to data compiled and maintained nationwide, 

including files compiled for the purpose of administering federal 

programs. In comparison, data compiled and maintained by municipalities 

are referred to as local administrative records, such as building permits 

and local tax records.4

According to Bureau officials, for the 2020 Census, the Bureau is 

researching how to determine the quality and usefulness of administrative 

records for obtaining addresses or information about individuals. 

Administrative records could reduce the cost of the census if they can 

help the Bureau reduce the workload for several operations, including 

address list building; quality assurance; and nonresponse follow-up, 

which, at $1.6 billion in 2010 and lasting several weeks, was the largest 

and most costly census field operation.5

The Bureau already uses administrative records to produce annual 

population estimates for the nation, states, counties, cities, towns, and 

townships as part of its program to estimate changes in population size 

and distribution since the previous census. The Bureau produces 

estimates at the state and county-level based on births, deaths, migration, 

and changes in the number of people who live in group quarters, such as 

college dormitories and nursing homes. Estimates of the population of 

The Bureau’s 2020 research and 

testing program has nine research and testing projects that are exploring 

the expanded use of administrative records for these purposes.

 

4

The Bureau’s access to and use of administrative records is governed by agency-specific 

statutes. For example, the Bureau has access to tax data under 26 U.S.C. § 6103(j)(1) “for 

the purpose of, but only to the extent necessary in, the structuring of censuses . . . and 

conducting related statistical activities.”

5

During nonresponse follow-up the Bureau sends enumerators to collect data from 

households that did not mail back their census forms. Nonresponse follow-up procedures 

instruct enumerators to make up to six attempts to contact a household. 

Background 
 

Page 4 GAO-13-269 Census Challenge Program

subcounty communities—which consist of both incorporated places, such 

as cities, boroughs, and villages, and minor civil divisions, such as towns 

and townships6

Local governments may challenge these population estimates through a 

process established by the Bureau’s Population Estimates Challenge 

Program.

—are primarily based on data on housing units, 

occupancy rates, and persons per household plus an estimate of the 

population in group quarters.

7

• building permits, 

Local data sources for challenges have included

• non-permitted construction, 

• demolition permits, 

• non-permitted demolitions, 

• certificates of occupancy, 

• utility connection data, and

• real and personal property tax information on residential units. 

The Bureau permitted localities to submit challenges for population 

estimates from 2001 to 2008. Counties and subcounties could challenge 

the Bureau’s estimate based on evidence that the number of housing 

units in their locality differed from the Bureau’s estimate of housing units. 

From 2001 to 2008, the Bureau reports revising population estimates 

from 287 challenges. These challenges were from 211 governments in 36 

states and the District of Columbia. There were as few as 3 challenges in 

2001 and as many as 61 each in 2006 and 2007. In 2010, the Bureau 

temporarily halted the challenge program beginning for estimates from 

2009 to accommodate the 2010 decennial census. The Bureau is 

resuming the challenge program in 2013.

 

6

Subcounty area estimates also include selected county equivalent areas, including 

Anchorage municipality, Juneau city and borough, Sitka city and borough, and Wrangell 

city and borough, Alaska; San Francisco city, California; Broomfield city and Denver city, 

Colorado; Washington city, D.C.; Georgetown-Quitman County unified government, 

Webster County unified government, Columbus city (Muskogee County), and CussetaChattahoochee County unified government, Georgia; Lexington-Fayette urban county, 

Kentucky; New Orleans city (Orleans parish), Louisiana; Anaconda-Deer Lodge County, 

Montana; Philadelphia city, Pennsylvania; Lynchburg, Moore County metropolitan 

government and Hartsville/Trousdale County, Tennessee; and the independent cities in 

Maryland, Missouri, Nevada, and Virginia.

7

The program was initiated under 15 C.F.R. Part 90—Procedure for Challenging Certain 

Population and Income Estimates. 
 

Page 5 GAO-13-269 Census Challenge Program

According to the Bureau, communities that challenged their population 

estimate saw their estimate revised upward by an average of about 9.4 

percent over the 8-year period. These challenges ranged from an 

estimated increase of over 186 percent for Bluffton, South Carolina, in 

2008, to a decrease of almost 18 percent for Winthrop, Massachusetts, 

during the same year. In total, four communities submitted challenges 

containing evidence that resulted in a decrease in population.

The effect of the program on smaller communities that participated was 

much larger, on average in percentage terms, than it was for larger 

communities that participated. According to Bureau data summarizing the 

program, communities with populations of less than 100,000 averaged an 

almost 13 percent upward revision in their population estimate—including 

the results of the challenge—compared to an average revision of less 

than 2 percent for communities with a population of more than 1 million 

(see table 1).

Table 1: The Challenge Program Resulted in Larger Percentage Increases in Estimated Population for Smaller Communities 

than for Larger Ones from 2001 to 2008 

Population <100,000

≥100,000 

and <500,000

≥500,000 and

<1 million ≥1 million

All 

communities

Average change in population 1,985 8,916 21,332 31,080 7,283

Average percent change in population 12.9% 4.1% 3.0% 1.5% 9.4%

Source: GAO analysis of unaudited Census Bureau information.

On August 10, 2012,8 the Bureau proposed significant changes to rules 

governing the challenge program, and the final rules were issued on 

January 3, 2013, effective February 4, 2013. The overall objective of the 

changes is to improve the accuracy of the population estimates by (1) 

strengthening evidentiary standards and limiting the scope of the program 

and (2) enhancing certain procedures.

 

8

77 Fed. Reg. 47,783 (Aug. 10, 2012).

The Bureau Revised 

Rules Governing Data 

Sources and 

Procedures for the 

Challenge Program to 

Improve Accuracy of 

Population Estimates
 

Page 6 GAO-13-269 Census Challenge Program

Previously, the Bureau provided communities that chose to challenge 

their population estimate with examples of the types of records they could 

use to support their calculations, including permits for new residential 

construction, public utility connection data, real and personal property tax 

information on residential units, and records of annexations and other 

types of legal boundary changes. In practice, according to agency 

officials, the Bureau generally accepted all challenges, largely without 

regard to the data sources provided so long as they supported 

calculations of population change and covered the reporting periods 

required by the challenge program. The rule changes are intended to 

improve the quality of data that communities use to challenge the 

Bureau’s population estimates and will affect the scope of what county 

and state governments can challenge. According to Bureau officials, 

these changes are based on research that shows that estimates based

on some methods and records (e.g., births, deaths, and migration) are 

substantially more accurate than estimates based on others. The rules 

vary for different levels of government—subcounty, county or equivalent, 

and state.

Subcounty.

9 Under the new rules, subcounty governments should use 

building, demolition, and mobile home permits, and group quarter counts 

to challenge population estimates. The Bureau plans to reject challenges 

that rely solely on other types of data, except in cases where the data 

provide overwhelming evidence that the Bureau’s estimate of population 

growth is in error.10

County and equivalent. Under the changes, county governments and 

their equivalents should use birth and death records, immigration data, 

and group quarters counts to challenge population estimates—a 

significant reduction in the types of records from what the Bureau has 

For example, according to a senior Bureau official, 

research shows that public utility records can vary widely in their reliability 

to indicate population growth, as well as in their availability to the public. 

Therefore, utility records will be treated as corroborating, or secondary, 

evidence to support other preferred data expected to be provided in 

support of challenges. Utility records were ordinarily accepted as a basis 

for successful challenges in the past.

 

9

Subcounty is defined as a division of a county.

10According to Bureau officials, this would be an error in Bureau estimation processing or 

an error in the data used by the Bureau for estimation.

The Bureau Changed the 

Challenge Program to 

Standardize Evidentiary 

Requirements and Limit 

the Scope
 

Page 7 GAO-13-269 Census Challenge Program

historically accepted. According to Bureau officials, research conducted 

over the past several years has demonstrated that county-level estimation 

methods based on other data sources do not produce, on average, as 

accurate estimates of population. Consequently, the Bureau plans to 

reject county-level challenges relying on other data sources. Under the 

changes, the Bureau will only accept county-level challenges to either the 

accuracy of the data the Bureau itself used when producing estimates or 

to whether the Bureau carried out its estimation procedures properly, 

such as in handling data files properly or carrying out calculations. Bureau 

officials acknowledged that local governments might see this reduction in 

the scope of permissible county-level challenges as being too restrictive, 

as evidenced by some public comments submitted in response to the 

proposed changes. Bureau officials stated that they will continue their 

dialogue with representatives of the Federal-State Cooperative for 

Population Estimates—a partnership between the Bureau and state 

governments—and other researchers about improving methods of 

estimating population, and may revisit the structure of the challenge 

program if future research demonstrates that an alternative method of 

estimating county population consistently outperforms that used by the 

Bureau. Figure 1 shows changes in the types of administrative records 

accepted by the challenge program.
 

Page 8 GAO-13-269 Census Challenge Program

Figure 1: Changes in Administrative Records Accepted by the Challenge Program

a

State. The Bureau will generally no longer permit state governments to 

submit their own challenges. Bureau officials stated that counties and 

cities are the most appropriate entities to submit a population challenge 

for their community because they have greater knowledge of their 

population. Bureau officials also said that they want to avoid situations 

where a state may challenge estimates for communities where respective 

local governments disagree with such challenges. The Bureau will allow 

states to submit challenges for counties or equivalents where there is no 

seat of government, such as in certain New England states and in parts of 

Alaska, but will otherwise require all communities affected by a challenge 

to have their government communicate directly with the Bureau.

According to Bureau officials, the Bureau would consider other types of records when they provide 

overwhelming evidence that Bureau estimates of population growth are incorrect.

The changes to procedures are intended to improve the accuracy of 

revisions to population estimates stemming from challenges. The Bureau 

modified procedures so that challenges by subcounty governments to the 

Bureau’s estimates of people living in traditional housing—not living in 

group quarters arrangements—will no longer affect county-level 

Other Changes to 

Procedures are Intended to 

Improve Accuracy of 

Population Estimates
 

Page 9 GAO-13-269 Census Challenge Program

population estimates. Previously, successful subcounty challenges were 

added to respective county-level populations. The Bureau justifies the 

change with its research demonstrating that its method for estimating the 

county population that lives in housing is generally better than the method 

typically used to challenge subcounty estimates. According to Bureau 

officials, the method used to challenge subcounty estimates introduced 

an upward bias for communities that were experiencing population 

decline or a slowing of population growth. According to the change, any 

challenge that results in an increase to the estimate of a subcounty 

community’s population living in traditional housing will be offset by a 

downward revision to the estimate for all other communities in the same 

county, in effect reallocating the estimated population within the county. 

Bureau officials emphasized that under the new procedures, as before, if 

a government successfully challenges the Bureau’s estimate of the 

population living in group quarters arrangements within its community, the 

revision will be added to the county population as well, and will not be 

offset by changes to populations in other communities in the county.

The Bureau also changed procedures so that it routinely reviews 

subcounty population challenges in light of each community’s population 

growth trend, requiring corroborating information when a government 

claims population growth that is inconsistent with the trend. For example, 

one local government in the Midwest successfully challenged the 

Bureau’s 2006 population estimate and received an increased population 

estimate of about 5.5 percent, even though evidence it submitted showed 

the number of housing units in the community was about 3.5 percent 

lower than the Bureau’s original calculation for that year. Another local 

government successfully challenged the Bureau’s 2007 population 

estimate and received an increased population estimate of about 7.4 

percent, even though its evidence showed an increase in housing units of 

only about 0.8 percent. According to 2010 Census counts in both of these 

cases, the average actual annual population growth over the decade was 

far below the challenge result, and the trend in population was declining. 

A senior Bureau official with whom we spoke said that, in addition, this 

and other changes in procedures will reduce the incentive that some 

communities have had to file a challenge in order to provide a community 

only a temporary reprieve from an otherwise declining trend in their 

population.
 

Page 10 GAO-13-269 Census Challenge Program

Challenge program officials told us that the program focuses its quality 

assurance on (1) reviewing the calculations presented in the 

documentation submitted by local governments as part of challenge 

submissions and (2) checking documents and calculations for internal 

consistency. Specifically, different worksheets local governments could 

choose to complete under the program have different data and 

calculations required to support a challenge, which Bureau staff review for 

accuracy and consistency. For example, Bureau staff would identify when 

local governments provided data on local building permits with a 

significant lag time, and then revise the submitted calculations 

accordingly since some of the buildings would thus have been 

constructed outside the time frame for which the population change was 

being estimated.

Bureau officials told us that the Bureau assures quality of locallysubmitted records by requiring a community’s highest elected official—

such as a mayor or county commission chair—to certify the validity of 

data used in any challenge to a population estimate that its government 

submits. The Bureau takes such certification at “face value” and does not 

examine the quality of these records, which Bureau officials said would be 

prohibitively time consuming to investigate or verify. Bureau officials said 

that no change to that approach is planned for the future of the program. 

However, the Bureau is considering how to describe a quality threshold 

that local records should satisfy, or steps that local governments can take 

to check the quality of their records.

Additionally, the Bureau distributes a review guide containing 

standardized procedures to local governments that are interested in 

participating in the challenge program. The guide includes instructions on 

filling out standardized worksheets and descriptions of the types of 

administrative records that can be relied on as sources of data for the 

challenge. According to Bureau officials, this helps to ensure consistency 

across challenges and potential revisions to population estimates.

Moving forward, according to officials, the Bureau is preparing a quality 

assurance plan for Bureau staff who review challenges to better ensure 

proper handling and processing of challenges, as well as the review of 

calculations. The Bureau intends to develop the plan over the coming 

months, after the program has resumed. The Bureau is also undertaking 

an agency-wide effort to update its record keeping policies, which would 

include revising rules for retaining documentation submitted as part of the 

challenge program. Changes to record keeping policies would help the 

Bureau maintain challenge program documentation—including

The Bureau Reviews 

Quality of 

Calculations and 

Requires Local 

Governments to 

Certify that Data Are 

Accurate 
 

Page 11 GAO-13-269 Census Challenge Program

calculations of revised estimates—in the event the Bureau needs to 

perform any follow-up reviews.

In our review of the 287 challenges submitted to the Bureau resulting in 

revised population estimates from 2001 to 2008, we identified a number 

of cases where documentation of challenges appeared either incomplete 

or inconsistent. For example, in some cases, documentation of 

corrections to local government’s calculations was missing, as was 

certification from a community’s highest elected official that data 

submitted with a challenge were valid. Also missing were notices to local 

governments from the Bureau on whether challenges were accepted. A 

lack of documentation could make it difficult for an independent 

verification of the integrity of the program. We discussed these 

documentation issues with Bureau officials. In response, they explained 

the steps they were taking to address them, such as documenting a 

record keeping policy for the program that includes descriptions of what 

documentation to create for each challenge and checklists of specific 

items to be retained in files. Bureau officials agreed to provide us with 

copies of the revised record keeping policy when the challenge program 

is resumed later in 2013. Because of these planned actions, we are not 

making a recommendation to the Bureau at this time.

The Bureau is exploring the use of local records for the 2020 Census, but 

this effort will be of a lower priority than research on the use of national 

administrative records, in part because national records show greater 

promise than local records for controlling costs. The Bureau’s research on 

the use of national administrative records for the 2020 Census is focused 

on their possible use for such purposes as (1) building the address list, 

(2) counting people, and (3) quality assurance and evaluation processes. 

In contrast, Bureau officials believe that the use of local administrative 

records is most likely to support the development of the 2020 address list. 

The Bureau has used local census records in this regard in prior 

decennials.

In previous enumerations, the Bureau developed its address list in part by 

going door-to-door and canvassing every block in the country to verify 

street addresses. However, the process of going door-to-door is labor 

intensive. As a result, for 2020, the Bureau is exploring how to reduce 

much of the costly, national canvassing done in the past by combining 

both local and national administrative data with the United States Postal 

Service data it already uses, allowing the Bureau to continuously update 

its master address file throughout the decade. In particular, the Bureau is 

The Bureau has 

Limited Plans for 

Using Local Records 

to Supplement 

National Records for 

2020 
 

Page 12 GAO-13-269 Census Challenge Program

considering how it can more seamlessly integrate regular input from local 

government address lists and related geographic information systems into 

its existing address list and map development processes. The Bureau 

would like to update this information continuously rather than wait to 

receive the input as part of a one-time decennial update. In addition, the 

Bureau will research the quality of these updates to determine the extent 

to which it can rely on them without necessarily having to verify them 

door-to-door.

Bureau officials stated that if time and resources permit, the Bureau will

consider other ways that local records can be used to supplement the use 

of national records. The officials stated that while it is important to 

continue research on local records, because they may be helpful in 

targeting decennial operations to hard-to-count groups or those in certain 

geographic areas, the results of 2010 Census research and testing on 

national records has led Bureau officials to conclude that continuing 

research on national records, such as those listed in figure 2, should be a 

higher priority. Bureau officials believe that research on the more broadly 

available national records could yield cost savings more quickly than 

research on locally available records, and that given resource constraints, 

they should attempt to “lock in” at least some of the more likely cost 

savings before pursuing more uncertain ones. Moreover, legislation may 

be needed to allow the Bureau to expand its use of national records for 

decennial purposes. Figure 2 shows the national and local records the 

Bureau is considering and the operations these records could support.
 

Page 13 GAO-13-269 Census Challenge Program

Figure 2: Potential Uses of Administrative Records the Bureau Is Considering for 

the 2020 Census

Beyond helping to develop the address list, local administrative records 

that have been used in the challenge program, such as school enrollment 

data, could supplement national records to either improve or evaluate the 

counting of targeted populations. Some Bureau stakeholders have 

suggested to the Bureau that these records, in some locations, may be 

more comprehensive and accurate than those records on which the 

Bureau already relies. For example, the Bureau is researching how 

statewide data, such as Supplemental Nutrition Assistance Program data 

from Illinois, Maryland, New York, and Texas, could enhance person and 

housing unit coverage—access to similar records is under negotiation 

with several other states. By matching records in these files with the 2010 

Census and other administrative records, the Bureau is determining their 

suitability for use to identify addresses or people and their characteristics, 

as well as their accuracy. Additionally, the Bureau is considering research 

on other state-level files, such as those maintained by Bureau partners in 

Florida and Montana, which maintain records on utility use and residential 

construction, respectively.

However, the Bureau would face some challenges using these records for 

decennial purposes. Bureau officials said local records are generally 

more difficult to systematically access or to apply broadly to census
 

Page 14 GAO-13-269 Census Challenge Program

operations. In some cases, laws restrict the use of these records to 

certain purposes, so the Bureau may need to negotiate their use with 

various parties or work towards legislative change. For example, going 

beyond school system enrollment data and obtaining access to student 

and school lunch data that might help target hard-to-reach populations is 

restricted to use for educational purposes by the Family Educational 

Rights and Privacy Act.

11 Additionally, some of these records are not 

aggregated nationally, which could make it difficult for the Bureau to 

obtain them. According to the Bureau, in other cases such as the 

Supplemental Nutrition Assistance Program, not all states maintain 

records equally well. If the Bureau ultimately has the time and resources 

to supplement national data with local data, officials stated that they will 

work to address these issues.

We provided a draft of this report to the Department of Commerce. In 

response, we received written comments from the department, which are 

reprinted in appendix II. In its comments, the department stated that it 

appreciates the time and effort that we put into the draft report and 

thanked us for responding to technical comments provided earlier by 

Bureau staff. 

As arranged with your office, unless you publicly announce the contents 

of this report earlier, we plan no further distribution until 30 days after the 

date of this report. At that time, we will send copies of this report to the 

Acting Secretary of Commerce, the Under Secretary of Economic Affairs, 

the Acting Director of the U.S. Census Bureau, and interested 

congressional committees. The report also is available at no charge on 

GAO’s website at http://www.gao.gov. 

 

1120 U.S.C. § 1232g. 

Agency Comments 

and Our Evaluation
 

Page 15 GAO-13-269 Census Challenge Program

If you have any questions about this report please contact me at (202) 

512-2757 or goldenkoffr@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. The GAO staff that made major contributions to this report 

are listed in appendix III.

Sincerely yours,

Robert Goldenkoff

Director

Strategic Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 16 GAO-13-269 Census Challenge Program

To describe the U.S. Census Bureau’s (Bureau) changes to how local 

administrative records will be used in the challenge program, we reviewed 

the August 10, 2012, Federal Register outlining proposed changes; the 

final rule, which was issued in the January 3, 2013, Federal Register; 

Bureau reports and presentations, which served as the basis for the 

changes; and comments received from state and local data experts 

solicited by the Federal Register on the proposed changes prior to the 

Bureau’s issuance of the final rule. We also interviewed current and 

retired officials from the Bureau’s Population Division responsible for 

implementing the challenge program.

To describe the changes to how the Bureau will assure the quality of 

population estimates updated by the challenge program, we reviewed the 

Federal Register notice outlined earlier, and we interviewed Bureau 

officials to identify additional quality assurance steps the Bureau intends 

to implement. To better understand the current procedures and 

implications of these changes, we reviewed documentation the Bureau 

provided to local governments on submitting accurate documentation to 

challenge population estimates, including worksheets used to calculate 

revised population estimates. We conducted a case file review to identify 

specific quality assurance steps the Bureau has previously taken to 

review the quality of submissions from local governments. During our 

case file review, we observed a number of instances where case files and 

other documentation of challenges appeared to be incomplete or 

inconsistent. We reviewed each of the documentation weaknesses, and 

we shared our observations with ranking Bureau executive and program 

managers.

To examine the Bureau’s plans to use the types of local administrative 

records currently used by the challenge program to improve the cost or 

quality of the 2020 Decennial Census, we reviewed Bureau 

documentation on research and testing of administrative records for the 

2020 Census, as well as our prior reports on the Bureau’s research and 

testing efforts. Additionally, we interviewed the Bureau officials 

responsible for the research and testing efforts related to administrative 

records to understand which local records and processes from the 

challenge program the Bureau is considering for the 2020 Census.

Appendix I: Objectives, Scope, and 

Methodology 
Appendix II: Comments from the Department 

of Commerce

Page 17 GAO-13-269 Census Challenge Program

Appendix II: Comments from the Department 

of Commerce
Appendix II: Comments from the Department 

of Commerce

Page 18 GAO-13-269 Census Challenge Program
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 19 GAO-13-269 Census Challenge Program

Robert Goldenkoff, (202) 512-2757 or goldenkoffr@gao.gov

Other key contributors to this report include Ty Mitchell, Assistant 

Director; David Bobruff; Benjamin Crawford; Sara Daleski; Robert 

Gebhart; Will Holloway; Andrea Levine; Mark Ryan; and Timothy Wexler.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(451011)
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