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. 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. 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. 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. 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.