Decennial Census: Methods for Collecting and Reporting Data on the Homeless and Others without Conventional Housing Need Refinement
Published: 2003-01-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Bureau of the Census partnered with local governments, advocacy groups, and other organizations to help it enumerate people without conventional housing. Counting this population--which includes shelter residents and the homeless--has been a longstanding challenge for the Bureau. A number of organizations put substantial resources into an operation the Bureau called Service-Based Enumeration. In return, some expected the Bureau to provide data that would help them plan and deliver employment, health, and other services. However, the Bureau did not release the data as planned, which raised questions about the Bureau's decision-making on data quality issues. In response to a congressional request, GAO examined the Bureau's decision-making process behind its change in plans.
section_title: What GAO Found
paragraphs: The Bureau's original plan for releasing Service-Based Enumeration data was outlined in an April 1999 internal memorandum that called for the separate release of data on people counted at "emergency and transitional shelters." The Bureau planned to combine other components of Service-Based Enumeration, including people counted at soup kitchens, regularly scheduled mobile food vans, and certain outdoor locations, into a single category. Driving the Bureau's decision was its experience during the 1990 Census when it released separate counts of people found at shelters, on the street, and similar locations that proved to be incomplete. The Bureau also tried to ensure that the Service-Based Enumeration figures could not be used as a "homeless" count, because it was not designed to provide a specific count of the homeless. Instead, the operation was part of a larger effort to count people without conventional housing. In January 2001, the Bureau changed its earlier decision because a statistical procedure used to refine the emergency and transitional shelter data proved to be unreliable, which lowered the quality of the data. In response, the Bureau combined the shelter data with a category called "other non-institutional group quarters," a category that also includes data on people enumerated in several other group locations such as facilities for victims of natural disasters. In the fall of 2001, the Bureau produced a heavily qualified special report on the shelter data. A key cause of the Bureau's shifting position on reporting these data appears to be its lack of well documented, transparent, clearly defined, and consistently applied guidelines on the minimum quality necessary for releasing data. Had these guidelines been in place at the time of the census, the Bureau could have been better positioned to make an objective decision on releasing these figures. Additionally, the Bureau could have used the guidance to explain to data users the reasons for the decision, eliminating any appearance of censorship and arbitrariness. Because the Bureau did not always adequately communicate its plans for releasing the data, expectation gaps developed between the Bureau and entities that helped with Service-Based Enumeration.

section_title: Letter
paragraphs: For the 2000 Census, the Bureau of the Census employed several initiatives  to help ensure a complete and accurate count of people without  conventional housing.  Enumerating this segment of the population, which  contains, among others, people referred to as “homeless,” has been an  ongoing problem for the Bureau.  In one initiative, known as Service-Based  Enumeration, census enumerators attempted to count these individuals at  emergency and transitional shelters, soup kitchens, regularly scheduled  mobile food vans, as well as at what the Bureau calls “targeted non- sheltered outdoor locations” (TNSOL) for people living on the street at  targeted locations who do not use services.  To help locate and count  people, the Bureau partnered with organizations providing services to the  homeless and local governments, some of which put substantial resources  into their efforts.  In return, some of these organizations expected the  Bureau to provide data that would help them plan and deliver health,  employment, and other services directed toward this population.
However, in its review of the emergency and transitional shelter data, the  Bureau identified serious concerns with the quality of the data and  concluded that the data should not be released without explanation of their  extensive limitations and caveats. As a result, the Bureau decided not to  separately report the emergency and transitional shelter data in the initial  release of summary files as originally planned.  Instead, the Bureau  combined the emergency and transitional shelter data with a category  called “other non-institutional group quarters.”  At the census tract level  (small statistical subdivisions of counties) this category included soup  kitchens, regularly scheduled mobile food vans, shelters for victims of  domestic violence, residential care facilities providing protective oversight,  staff quarters including those for nurses and interns at military and general  hospitals, and living quarters for victims of natural disasters.  At the block  level, in addition to the categories listed above, “other non-institutional  group quarters” included group homes, religious group quarters, other  nonhousehold living situations, and workers’ dormitories.  Aggregating the  shelter numbers with these other data raised concerns among some data  users that the Bureau was suppressing the results.
You asked us to examine the Bureau’s decision-making process behind its  change in plans.  As agreed with your offices, this report examines (1) the  Bureau’s plans for reporting the results of Service-Based Enumeration and  its reasons for changing those plans and (2) the Bureau’s protocols for  releasing data.
Members of the Congress also raised concerns about the quality of  Hispanic subgroup data and asked us to review the Bureau’s decision- making process for collecting and reporting ethnicity information.  The  results of that study are included in a companion report.  Both reports are  part of our ongoing series on the lessons learned from the 2000 Census that  can help inform the planning effort for 2010.  (See the Related GAO  Products section for a list of reports issued to date on census issues.)
subsections: section_title: Background
paragraphs: The procedures the Bureau used during the 1990 Census to count people  without conventional housing had limitations that resulted in incomplete  data.  To address these limitations and help improve the quality of the data,  the Bureau used a procedure for the 2000 Census called Service-Based  Enumeration that attempted to count people where they receive services  such as emergency shelters, soup kitchens, and regularly scheduled mobile  food vans.  Service-Based Enumeration also counted people in targeted  nonsheltered outdoor locations such as encampments beneath bridges.   The operation occurred from March 27 through March 29, 2000.
According to Bureau officials, Service-Based Enumeration was not  designed, and was never intended, to provide a specific count of homeless  persons.  Instead, the operation was part of a larger effort to count people  without conventional housing, including people in “institutional group  quarters” such as correctional facilities, nursing homes, and mental  hospitals, and “non-institutional group quarters” such as college  dormitories, military quarters, and group homes.  Service-Based  Enumeration counted people in specific categories of noninstitutional  group quarters.
To help ensure a complete count of people without conventional housing,  the Bureau partnered with local governments and community advocacy  groups to obtain lists of service locations and to assist with the  enumeration.  In some cases, the Bureau hired clients of the advocacy  groups and other people trusted by the homeless to conduct Service-Based  Enumeration.  For example in Atlanta, an advocacy group for homeless  veterans helped the Bureau employ homeless veterans to improve the  count of this population.  Local governments helped the Bureau as well,  often investing considerable resources.  For example, Los Angeles paid to  keep its city-run shelters open on the night they were enumerated so that  people using their services could be counted.
section_title: Scope and Methodology
paragraphs: To address your concerns about the Bureau’s dissemination of data on  persons without conventional housing, we agreed to examine (1) the  Bureau’s plans for reporting the results of Service-Based Enumeration and  its reasons for changing those plans and (2) the Bureau’s protocols for  releasing data.  To accomplish these objectives, we interviewed key Bureau  officials and reviewed relevant Bureau documents and data such as  operational plans, decision memorandums, and the Bureau’s partnership  program evaluation.
In order to obtain the perspective of data users, partners, and stakeholders,  we conducted in-person and telephone interviews with homeless  advocates, local government officials, and representatives of public service  agencies in New York City, Los Angeles, Cleveland, Atlanta, and  Washington, D.C.  These cities had large numbers of people without  conventional housing and they were actively involved with the Bureau  during the 2000 Census.  The organizations we contacted also provided  relevant documentation, such as comprehensive file documents relating to  partnership activities.
In addition to the above locations, we did our audit work at Bureau  headquarters in Suitland, Maryland.  Our audit work was conducted from  April 2002 through September 2002 in accordance with generally accepted  government auditing standards.
We requested comments on a draft of this report from the Secretary of  Commerce.  On November 21, 2002, the Secretary forwarded the Bureau’s  written comments on the draft (see app. I).  We address these comments at  the end of this report.
section_title: The Bureau of the Census Twice Changed Plans for Reporting Service-Based Enumeration Data
paragraphs: Under the Bureau’s original plan for releasing Service-Based Enumeration  data in Summary File-1 (SF-1), the emergency and transitional shelter  count was one of several categories of noninstitutional group quarters data  that were to be reported separately. Other people counted in the Service- Based Enumeration, including people counted at targeted nonsheltered  outdoor locations, soup kitchens, and regularly scheduled mobile food  vans, were to be combined and reported under the category “other non- institutional group quarters.”   This category also included residential care  facilities providing protective oversight, shelters against domestic violence,  staff dormitories for nurses and interns at military and general hospitals,  and living quarters for victims of natural disasters.
This decision was documented in an April 1999 internal memorandum from  the Bureau’s Assistant Division Chief for Special Population Statistics to  the Assistant Division Chief for Census Programs.  The Service-Based  Enumeration operation took place a year later, in March 2000.  The April  1999 plan was in large part a reaction to the challenges the Bureau faced  counting the emergency shelter and street population during the 1990  Census.  Although the Bureau disseminated separate counts of people  found at emergency shelters, preidentified street locations, and similar  sites, the counts proved to be incomplete.  Moreover, the Bureau stated in  its October 2001 report that despite its warnings to the contrary, the data  were sometimes misinterpreted as a “homeless” count.
The October report does not offer an example of this, but the  misinterpretation clearly played a role in a lawsuit against the Bureau.  As  a result, when designing the 2000 census, the Bureau attempted to both  improve the count and take precautions to ensure that the Service-Based  Enumeration count would not be misconstrued as a count of the homeless.
The Bureau’s data dissemination plans took into account the  recommendations of the Commerce Secretary’s 2000 Census Advisory  Committee, a panel that included representatives of advocacy and other  groups (including representatives from organizations that represent local  governments) that met periodically to review the Bureau’s plans.  The  homeless population was represented by the National Coalition for the  Homeless—an advocacy group that coordinates a network of 300 state and  local housing and homeless organizations.  In its January 1999 final report,  the Census 2000 Advisory Committee recommended that special attention  be paid to tabulating the results of Service-Based Enumeration and  targeted outdoor enumerations so that they could not be aggregated and  used as a homeless count.
subsections: section_title: The Bureau Changed Its Dissemination Plans Because of Data Quality Concerns
paragraphs: In January 2001, 5 months before the SF-1 release, the Bureau reversed its  April 1999 decision to release emergency and transitional shelter data  separately because of “data quality concerns.”  Instead, as shown in figure  1, the Bureau planned to combine the emergency and transitional shelter data with the “other non-institutional group quarters.”  This  category contained data on a variety of living arrangements including  facilities for natural disaster victims.  The Bureau’s decision was contained  in an internal Bureau memorandum from the Chief of the Population  Division to the Chief of the Decennial Systems and Contracts Management  Office.  Bureau officials told us that the decision to exclude a separate  emergency and transitional shelter count in SF-1 was made between  December 2000 and January 2001, by the Director of the Decennial Census  with input from the Associate Director Decennial Census, the Population  Division, the Associate Director for Demographic Programs, the Decennial  Management Division, and the Decennial Statistical Studies Division.
According to Bureau officials, their concerns focused on the accuracy of a  new statistical procedure called “multiplicity estimation” that adjusted the  number counted to better reflect the number of actual shelter users.   Because Service-Based Enumeration only counted people who were at  these facilities on the day of enumeration, the Bureau intended to use  multiplicity estimation to calculate the number of people who used these  facilities but were not present during Service-Based Enumeration.  The  multiplicity estimation procedure was based on information from those  who were counted and on the number of times they used the service  facilities in the prior week.  An estimate of people not counted on the day  of enumeration was added to the count of people who were.  According to  the Bureau, the multiplicity estimates tested well during the 1998 dress  rehearsal for the 2000 Census possibly because the three rehearsal sites did  not offer large enough sample sizes of the appropriate populations to  adequately test this procedure.  However, during the 2000 Census the  Bureau found that a census question pertaining to facility usage upon  which the multiplicity estimates were based had a low response rate.   Moreover, the Bureau found that respondents, particularly in shelters, did  not answer the question accurately.  Due to data quality concerns, the  Bureau decided not to use multiplicity estimation to adjust the data and  consequently decided not to report the data separately.
Bureau officials said they did not announce the change in plans because  they were still evaluating the problems with the data.  It was not until June  2000 that the Bureau began recalculating the data and making a final  decision on which categories to aggregate.  Ultimately, the Bureau did not  report any of the Service-Based Enumeration data separately in SF-1.   Emergency and transitional shelter data were the only data that were to be  released in SF-1 under separate reporting categories that the Bureau  decided to combine with another category.
section_title: The Bureau Produced a Special Report in October 2001 on the Emergency and Transitional Shelter Population
paragraphs: The release of the SF-1 data in June 2001 produced public discussion in the  press, among census partners, and in the Congress about the Bureau’s  decision to not separately release Service-Based Enumeration data.  In a  briefing for staff of the House Committee on Governmental Affairs, the  Associate Director of the Decennial Census announced that the Bureau  planned to produce a separate report on the emergency and transitional  shelter data.  In October 2001, the Bureau issued a special report, entitled  Emergency and Transitional Shelter Population: 2000.  This report  separately identified emergency and transitional shelter data for various  levels of geography down to the census tract level with 100 or more people  in emergency and transitional shelters.  The report did not include data for  the populations in targeted nonsheltered outdoor locations, soup kitchens,  regularly scheduled mobile food vans, and shelters for domestic violence.   The 17-page report contains an extensive discussion on the limitations of  the data.  For example, the Bureau noted that the data in the report should  not be construed as a count of people without conventional housing.   Moreover, the emergency and transitional shelter data at the census tract  level are not in the hard copy, but rather in the Internet version of the  report.  The Bureau stated that all Census 2000 data at the tract level are  available on the Internet and are not available in printed reports.
The October report contains most of the same data that were to be released  under the April 1999 dissemination plan for SF-1.  The Bureau asserted that  the data quality concerns with the emergency and transitional shelter data  (cited when it changed the plan to release these data in SF-1) required that  the data be presented in a manner that allowed the Bureau to clearly  outline the data’s limitations.  The October 2001 report contained an  extended discussion of these limitations.
The October 2001 report also identified reasons the Bureau did not (and  never planned to) separately release data on people counted at targeted  nonsheltered outdoor locations, soup kitchens, regularly scheduled mobile  food vans, and shelters for victims of domestic violence, including the  following.
People without conventional housing who were at outside locations  other than the targeted nonsheltered outdoor locations identified for the  census were not included in the TNSOL operation.
For the purposes of the TNSOL operation, the definition of “outdoor”  excluded both mobile and transient locations used by people  experiencing homelessness as well as abandoned buildings.
The option was given to the individuals found at soup kitchens and  regularly scheduled mobile food vans to select “usual home elsewhere.”   For example, if an individual enumerated at a soup kitchen listed a usual  home elsewhere, then that person was tabulated at their usual residence  and not at the service location.  Therefore, the data on this population  would not reflect a true count of the individuals using these services.
Prior to publicly releasing the October report, the Bureau asked two  representatives from the National Coalition for the Homeless to review a  draft of the portion of the report that described the limitations of the data.   The National Coalition for the Homeless commented extensively on the  section containing the caveats and limitations in order to strengthen the  report.  A member of the Board of Directors for the National Coalition for  the Homeless told us that he provided this feedback both as an  academician and a stakeholder.  Bureau officials stated that because of its  position on the Bureau’s Census Advisory Committee, the National  Coalition for the Homeless was the only advocacy group that reviewed any  portion of the October 2001 report prior to its publication.
section_title: Meeting Data Users’ Needs Proved Challenging
paragraphs: The controversy surrounding the release of the combined Service-Based  Enumeration data highlights the challenges the Bureau faced in 2000 trying  to meet the needs of various data users and the work the Bureau still needs  to do when planning for the 2010 Census to better reconcile those needs.   For example, several organizations we contacted favored the separate  release of the Service-Based Enumeration data categories.  Indeed, local  government officials we talked to in New York City believed that the data  would help with grant applications, projections about future service needs,  and determining their success in getting people off the streets and into  shelters.  The Executive Director of the Northeast Ohio Coalition for the  Homeless stated that the city of Cleveland does not do its own count of this  population and, therefore, the Bureau numbers are the only ones available  on this segment of the population.  Los Angeles city officials wanted the  Service-Based Enumeration data so they could better target their services  and, like Cleveland, Los Angeles did not have its own data.  Several of these  entities stated that the potential misuse of data was not a valid reason for  not separately releasing data.
In addition, the majority of the organizations we contacted partnered with  the Bureau anticipating that they would be able to use the Service-Based  Enumeration data to evaluate whether improvements were made in  enumerating local populations without conventional housing in 2000  compared to 1990.  The Assistant City Attorney of Los Angeles estimated  that Los Angeles spent about $300,000 on the effort to improve the count of  Los Angeles’s people without conventional housing.  For example, as part  of an extensive effort to help the Bureau develop a list of targeted  nonsheltered outdoor locations, the city provided senior Bureau staff with  a helicopter tour over some outdoor locations where people without  conventional housing lived.   The Assistant City Attorney of Los Angeles  stated that she believed the city would get the targeted nonsheltered  outdoor locations data that they helped collect and wanted to review.  In  addition, because of the Bureau’s focus on counting people at shelters, the  city kept shelters open on the night of the enumeration at its own expense  even though shelters in Los Angeles typically do not have many people  during warm weather.  Los Angeles expected to have detailed data to use to  evaluate the effectiveness of its resource allocation.
However, the National Coalition for the Homeless and other advocates of  the homeless opposed the separate release of any of the Service-Based  Enumeration data.  They were concerned that these data could be misused  as a count of the homeless population and lead to flawed decision-making  by policymakers.
Ultimately, the Bureau left a number of data users unsatisfied.  Those who  wanted the Service-Based Enumeration categories released separately did  not feel the Bureau met their expectations with the data released in SF-1 or  with the release of the October report.  Users who opposed the separate  release of the data and were pleased that SF-1 combined the Service-Based  Enumeration components with other data were displeased that the October  2001 report was released.
The difficulties the Bureau experienced trying to reconcile the competing  needs and interests of data users illustrates the importance of effective  communication between the Bureau and its key data users and partners to  ensure no expectation gaps develop.  More than just a good business  practice, federal internal control standards require agencies to have  effective external communications with groups that can have a serious  impact on programs, projects, operations, and other activities.
However, our conversations with several Bureau partners and our review  of Bureau documents suggest that communications were sometimes vague  and insufficient.  For example, although the April 1999 memorandum that  outlined the Bureau’s initial data dissemination plans was written a year  before the 2000 Census, this information may not have been effectively  communicated to the Bureau’s partners.  Indeed, at a Capitol Hill briefing  on this topic in June 2001, Bureau officials themselves acknowledged that  they did not do a good job of communicating on this issue.  Some of the  partners we spoke to indicated that had they known earlier about the  Bureau’s plans to limit the release of Service-Based Enumeration data they  might have focused their resources on different census operations.   Further, our review of Bureau documents indicated that the information on  the “official plan” for the release of the different Service-Based  Enumeration categories of data was limited and inconsistent.  Some  partners stated that they did not know that the Bureau never intended to  report the targeted nonsheltered outdoor location data.
Although the Bureau made numerous presentations on Service-Based  Enumeration that emphasized there would be no count of the homeless,  the Bureau provided little detail on how components of Service-Based  Enumeration would actually be presented.  In the absence of clear  communication from the Bureau, partners developed their own  expectations of what would be released.  Several of the local officials and  advocates that we spoke to expected that the data would be released in the  same detail as it was in 1990, because they were not told otherwise.  For  example, a Los Angeles government official said that the Bureau stated it  would not provide a homeless count in 1990, but it still released the street  count data separately.  By focusing resources on counting specific  categories of the population, the Bureau may have created expectations  that there would be a count of that population.
section_title: Census Bureau Had Few Documented Guidelines Governing the Release of Census Data
paragraphs: A cause of the Bureau’s shifting position on reporting the components of  Service-Based Enumeration appears to be its lack of documented, clear,  transparent, and consistently applied guidelines governing the release of  data from the 2000 Census.  Except for some guidance aimed at protecting  the confidentiality of census records, the Bureau had few written  guidelines on the level of quality needed to release data to the public.  Had  these guidelines been in place during the decennial census, they could have  informed the Bureau’s decision on whether to release the Service-Based  Enumeration data, how to characterize these data, and help defend the  decision after it was made.   Such guidelines could also provide a basis  ahead of time for expectations about the conditions under which data will  or will not be released.
Although Bureau officials emphasized that the Bureau has a long tradition  of high standards and procedures that yield quality data (to its credit, the  Bureau’s quality assurance practices identified the problem with the  multiplicity estimator), the officials acknowledged that these standards  were primarily part of the agency’s institutional knowledge.  The written  guidance that did exist appeared to be vague and insufficient for making  consistent decisions on the quality thresholds needed for releasing data to  the public, and the circumstances under which it might be appropriate to  suppress certain data.
According to the Bureau’s Associate Director for Methodology and  Standards, a technical paper issued in 1974 and revised in 1987 contained  the Bureau’s only written guidelines for discussion and presentation of  errors in data.  This paper noted that, “stimates for individual cells of a  published table should not be suppressed solely because they are subject to  large sampling errors or large nonsampling variances, provided users are  given adequate caution of the lack of reliability of the data.  On the other  hand, data known to have very serious bias may be suppressed.”
subsections: section_title: A Newly Created Bureau Program Could Provide Guidelines for Releasing Data
paragraphs: In 2000, the Bureau initiated a new quality assurance program to document  Bureau-wide protocols designed to ensure the quality of data collected and  disseminated by the Bureau.  The Bureau’s Methodology and Standards  Council is charged with setting statistical and survey quality standards and  guidelines for Bureau surveys and censuses.  In support of this role, the  council has established a quality framework in which the demographic,  economic, and decennial areas can share and support common principles,  standards, and guidelines.  The quality framework covers eight unique  areas, one of which is dissemination.
Because this Bureau program is in its initial stages, we could not evaluate  it.  However, Bureau officials believe that the program is a significant first  step in addressing the lack of agencywide written guidelines for releasing  data.  The initiative appears to be consistent with Office of Management  and Budget guidelines issued in February 2002 requiring federal agencies to  issue their own guidance for ensuring and maximizing the quality,  objectivity, utility, and integrity of information disseminated by the  agency.  As the Bureau develops its guidelines, it will be important that  they be well documented, transparent, clearly defined, and consistently  applied.
section_title: Conclusions
paragraphs: Although Service-Based Enumeration was designed to address the  challenges the Bureau encountered during the 1990 Census in obtaining a  complete count of people without conventional housing, the Bureau’s  experience during the 2000 Census suggests that tallying this population  group remains problematic.  Moreover, the Bureau’s difficulties were  compounded by its shifting position on how to report the data once they  were collected.  A number of government, community, and advocacy  organizations helped the Bureau enumerate this population group.   However, the Bureau, by first planning to release the data one way, then  changing the decision, and ultimately releasing the data anyway—all for  reasons that were not clearly articulated to the Bureau’s stakeholders— raised questions about the Bureau’s decision-making on data quality issues.   As noted at the beginning of this report, related questions have also been  raised about how the Bureau collected and reported data on Hispanic  subgroups.  To the extent similar incidents occur in the future, they could  undermine public confidence in the accuracy and credibility of Bureau  data.
Thus, as the Bureau plans for the 2010 Census, it will be important for it to  refine its methods for enumerating people living in unconventional housing  and reporting the resulting data, in part by properly testing and evaluating  those methods.  As noted earlier, the Bureau could not properly test a key  statistical technique during the census dress rehearsal because the sample  size was too small.
Moreover, while addressing the competing needs and desires of data users  will likely remain a considerable challenge, it will be important for the  Bureau to more effectively articulate its plans to avoid the expectation gaps  that occurred during 2000.  The Bureau’s plans for collecting data on  persons without conventional housing need to specify how the Bureau  plans to separately report these data.
Bureau-wide guidelines on the level of quality needed to release data to the  public, on how and when to document data limitations, and on the  circumstances under which it is acceptable to suppress data, could help the  Bureau be more accountable and consistent in its dealings with data users  and stakeholders, and help ensure that the Bureau’s decisions both are, and  appear to be, totally objective.
section_title: Recommendations for Executive Action
paragraphs: To ensure that the 2010 Census will provide public data users with more  complete, accurate, and useful information on the segment of the  population without conventional housing, we recommend that the  Secretary of Commerce direct the Director of the Bureau of the Census to  do the following. 1. Ensure that all procedures for enumerating and estimating segments of  the population without conventional housing are properly tested and  evaluated under conditions as similar to the census as possible. 2. Develop agencywide guidelines for Bureau decisions on the level of  quality needed to release data to the public, how to characterize any  limitations in the data, and when it is acceptable to suppress the data  for reasons other than protecting the confidentiality of respondents.   Ensure that these guidelines are documented, transparent, clearly  defined, and consistently applied. 3. Ensure that the Bureau’s plans for releasing data are clearly and  consistently communicated with the public.
section_title: Agency Comments and Our Evaluation
paragraphs: The Secretary of Commerce forwarded written comments from the Bureau  of the Census on a draft of this report (see app. I).  The Bureau agreed with  each of our recommendations and, as indicated in the letter, is taking steps  to implement them.  However, it expressed several general concerns about  our findings.  The Bureau’s principal concerns and our response are  presented below.  The Bureau also suggested minor wording changes to  provide additional context and clarification.  We accepted the Bureau’s  suggestions and made changes to the text as appropriate.
The Bureau took exception to our findings concerning the adequacy of its  data quality guidelines, noting that the Bureau’s decisions regarding the  release and characterization of emergency and transitional shelter data  were based on established guidelines for data quality. However, the Bureau  did not cite any written guidelines to support its position.  As noted in our  report, Bureau officials, including the Associate Director for Methodology  and Standards, told us that the Bureau had few written guidelines,  standards, or procedures related to the quality of data released to the  public.  In this report we acknowledge the Bureau’s tradition of high  standards and procedures that yield quality data.  However, according to  the Bureau, these standards are generally undocumented and part of the  agency’s institutional knowledge.  To provide a basis for consistent  decision-making and clear communication within the Bureau and to the  public, guidelines on the quality of data released to the public must be fully  documented, transparent, clearly defined, and consistently applied.
Additionally, the Bureau said that when data do not meet an acceptable  level of quality, it considers various options for modifying its dissemination  plans.  The Bureau’s decision to delay the release of the emergency and  transitional shelter data may have been entirely appropriate.  Our concern  is not that the Bureau changed its plans, but that it could not provide us its  guidelines for determining an acceptable level of quality or clearly indicate  how it determined that the data did not meet minimal quality standards for  release in SF-1.
The Bureau also commented that its decisions regarding the distribution of  data from SF-1 were well publicized and that the only change in Bureau  plans for the release of Service-Based Enumeration data was the decision  to delay release of the emergency and transitional shelter data.  This report  focused on the changing plans for the release of the emergency and  transitional shelter data and noted that the Bureau never intended to  release any other data from the Service-Based Enumeration.  However, we  found that the Bureau did not effectively communicate its decisions with  its partners or the public.  Decisions on the release of the emergency and  transitional shelter data were contained in internal decision memoranda.   We found that these decisions were not always reflected in new releases of  the SF-1 documentation.  Although Bureau officials told us that they always  intended to produce a separate report on emergency and transitional  shelter data, they did not make this intention public when the SF-1 data  were released.  Some stakeholders did not realize that the Bureau was not  releasing emergency and transitional shelter data with SF-1 until they  examined the SF-1 data.  As we stated in our report, these communication  problems can undermine stakeholder and public confidence in the Bureau  and its products.
As agreed with your office, unless you publicly announce 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 of this report to the Chairman  of the House Committee on Government Reform, the Chairman of the  Subcommittee on Civil Service, Census and Agency Organization, the  Secretary of Commerce, and the Director of the Bureau of the Census.   Copies will be made available to others on request.  This report will also be  available at no charge on GAO’s home page at http://www.gao.gov.
Please contact me on (202) 512-6806 or by e-mail at daltonp@gao.gov if you  have any questions.  Other key contributors to this report were Robert  Goldenkoff, Timothy Wexler, Elizabeth Powell, Chris Miller, James  Whitcomb, Ty Mitchell, Robert Parker, and Michael Volpe.
section_title: Related GAO Products on the Results of the 2000 Census and Lessons Learned for a More Effective Census in 2010
paragraphs: 2000 Census:  Refinements to Full Count Review Program Could Improve  Future Data Quality.  GAO-02-562.  Washington, D.C.: July 3, 2002.  2000 Census: Coverage Evaluation Matching Implemented As Planned,  but Census Bureau Should Evaluate Lessons Learned.  GAO-02-297.  Washington, D.C.: March 14, 2002. 2000 Census: Best Practices and Lessons Learned for a More Cost- Effective Nonresponse Follow-Up. GAO-02-196. Washington, D.C.:  February 11, 2002. 2000 Census: Coverage Evaluation Interviewing Overcame Challenges,  but Further Research Needed. GAO-02-26. Washington, D.C.:  December 31,  2001. 2000 Census: Analysis of Fiscal Year 2000 Budget and Internal Control  Weaknesses at the U.S. Census Bureau. GAO-02-30. Washington, D.C.:  December 28, 2001. 2000 Census: Significant Increase in Cost Per Housing Unit Compared  to 1990 Census. GAO-02-31. Washington, D.C.: December 11, 2001. 2000 Census: Better Productivity Data Needed for Future Planning and  Budgeting. GAO-02-4. Washington, D.C.: October 4, 2001. 2000 Census: Review of Partnership Program Highlights Best Practices  for Future Operations. GAO-01-579. Washington, D.C.: August 20, 2001.
Decennial Censuses: Historical Data on Enumerator Productivity Are  Limited. GAO-01-208R. Washington, D.C.: January 5, 2001. 2000 Census: Information on Short- and Long-Form Response Rates.  GAO/GGD-00-127R. Washington, D.C.: June 7, 2000.
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