The AAMC and the AAMC Center for Health Justice submitted a letter on April 17 to the White House Office of Management and Budget (OMB) in response to the request for comment on the Initial Proposals for Updating OMB’s Race and Ethnicity Statistical Standards (also known as SPD 15). The goal of SPD 15 is “to ensure the comparability of race and ethnicity across Federal datasets and to maximize the quality of that data by ensuring that the format, language, and procedures for collecting the data are consistent and based on rigorous evidence.”
SPD 15 was initially developed in 1977 and was revised once in 1997. In 2016, the AAMC submitted comments on the first proposed changes to SPD 15 since the revisions in 1997. Out of approximately 400 public comments, the AAMC and the American Anthropological Association were the only higher education organizations that submitted a response [refer to Washington Highlights, Oct. 28, 2016].
In its letter, the AAMC and the center recognized the critical need to revise SPD 15 “to ensure that [it is] keeping pace with changes in the population and evolving needs and uses for data” and commended the OMB for taking steps to uphold the credibility, integrity, impartiality, and utility of demographic information collected for federal statistical purposes. The AAMC also recommended additional opportunities for community feedback and intergovernmental collaboration, including continued input on key aspects of the proposed revisions to ensure the OMB does not adopt certain changes without robust public input and supporting research (e.g., collection and use of ancestry data, updates to terminology and definitions). Among other recommendations, the AAMC suggested the following:
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Information about race and ethnicity should be collected in a single question that asks individuals how they identify rather than asking about their race or ethnicity using those terms. For over a decade, the AAMC has asked the question in surveys and administrative data collections: “How do you self-identify? Please check all that apply.”
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“Middle Eastern or North African” (MENA) should be added as a new minimum reporting category. Changes to the definition of the current White category should remove the MENA classification.
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Detailed race and ethnicity categories should be used by federal agencies as a default. The OMB should provide additional criteria and guidance for making the decision that minimal categories may be used for a specific purpose.
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Terms and definitions from SPD 15 that reinforce racial and ethnic hierarchy should be removed. The OMB should provide an evidence-based rationale in support of the decision to adopt certain changes to terms and definitions and not others.
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Other demographic data for groups not currently represented in SPD 15 such as LGBTQ+ populations, along with data on other key areas that intersect with people’s identities (e.g., religion, country of origin, primary language, disability status, social determinants of health), should be collected.
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A multisector group should be convened to evaluate additional changes and potential research areas not implemented as part of the current revisions to SPD 15. For example, the White House is currently implementing Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through Federal Government, and through this effort has established a data working group to advance equitable data collection across federal agencies [refer to Washington Highlights, July 9, 2021].
The OMB is on track to complete the revisions to SPD 15 by summer 2024 and the AAMC and the center will continue to follow these efforts.