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Preparing for new ethnic/racial reporting rules

Lou McClelland, CU-Boulder Planning, Budget, and Analysis (PBA)
Revised 3/24/00

Special alert issued to institutional researchers nationwide on 3/21/00:

The Office of Management and Budget (OMB) has released OMB Bulletin No.00-02 which provides guidance to federal agencies on the aggregation and allocation of data on race.

Lou's comment: The above guidelines in brief
- keep Hispanic vs non-Hispanic as a categorization separate from race
- list several categories for reporting aggregate data by reporting, e.g., number checking African American only, number reporting African American and white, etc.
- make some of the aggregate categorizations dependent upon what's prevalent in a region or state

NCES (National Center for Education Statistics) has advised OMB that implementation of the new reporting for aggregate data systems, such as the IPEDS, will require several years and that the delay in issuing the guidelines on appropriate reporting will result in a delay in full implementation of the new reporting system to after the 2003 deadline.

All IPEDS reporting for the 2000-2001 cycle and the 2001-2002 cycle will use the existing categories.

NCES is currently reviewing the effects of the OMB guidelines on the implementation schedule and IPEDS reporting. However, because of uncertainty on how to deal with a limited number of multi-ethnic cateogies (largest four? All greater than one percent, in state region or nation? etc?) there is now a possibility that NCES will wait to establish its reporting categories after the release of the census collection, sometime in 2001. This makes it possible that the new system may not be required of institutions until three years after that, or 2004. In the meantime, everyone will have to report using the current categories (no multi-ethnic).

Update posted February 00

Negotiations between the US Dept of Education and US Dept of Labor on reporting requirements for the new racial/ethnic standards are ongoing. The agencies still advise institutions not to do anything.

We know that the new categories (e.g., Pacific Islander) will be required.

We know that if institutions ask each category as a yes/no question (e.g., list all categories and allow respondents to check any number) they will capture all information needed for reporting. However, we do not know if we will be allowed to report all the information captured. It's possible that a respondent checking categories A and B, for example, would be reported simply as A, where the choice of A or B was determined by a rule.

New information from AIR - 2/9/2000

*********************************************************************
*              Special Issue - AIR Alert #9 Update 9                *
*                     The Electronic Newsletter                     *
*        of the Association for Institutional Research (AIR)        *
*     February 9, 2000. . . . . . . . . . .Volume 20, Number 3      *
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RACIAL/ETHNIC DATA.  On November 5, 1999, NCES announced that the status
of changes in reporting racial/ethnic data and the date when these
changes will take effect are being revisited
(http://nces.ed.gov/ipeds/newracereport.asp).  Furthermore, it appears
that proposals for reporting data from the 1999 Policy Panel on
Racial/Ethnic Data (http://nces.ed.gov/ipeds/pdf/finalracerec.pdf) will
not be adopted.  Therefore, institutions are strongly urged not to make
any changes at this time with respect to collecting, storing, or
analyzing racial/ethnic data using multiple responses until a final
decision about forthcoming requirements for these data has been
announced. 

**********************************************************************
*       Status of Federal Race and Ethnicity Reporting Changes       *
*FROM                                                                *
*                     The Electronic Newsletter                      *
*        of the Association for Institutional Research (AIR)         *
*                                                                    *
*      10/29/99. . . . . . . . . . . . . .Volume 19, Number 20       *
**********************************************************************

SUBJECT: Status of Federal Race and Ethnicity Reporting Changes
Currently in Turmoil

PREPARED: October 29, 1999 by Terry Russell (AIR Executive Director)

The status of the changes in Federal race and ethnicity reporting that
were to be implemented with the 2000 Census and the 2002 IPEDS reporting
is currently undecided. AIR's recommendation is that institutions should
do nothing at this time to change their current race and ethnicity
reporting systems and formats, but should wait until the U.S. Office of
Management and Budget (OMB) decides what the changes should be.

OMB was to have issued a final recommendation in October, 1999.
Instead, the agency has begun reconsidering a variety of options in
addition to the 16-category multi-ethnic data collection and reporting
format developed in cooperation with the higher education community in
1998-99.

At this time, it is unclear what final format will be selected or when
that decision will be made.  Based on the variety of options under
discussion, the higher education associations are working together to
get a compromise format and revised timetable that is suitable to higher
education.  When these options, the probability for adoption of one or
another of them, and the time line for implementation becomes clearer,
the Higher Education Data Policy Committee will quickly issue an AIR
Alert with detailed discussions.  We will continue to keep you up to
date through AIR Alerts and other communications as events unfold.

Background

• OMB (federal office of Management and Budget) issued revised standards for racial/ethnic records and reporting July '97; revised further after comment October '97
• The new questions will be used in the 2000 census.
• Deadline for full implementation is Jan 1 2003 -- but this includes, e.g., grad rates reported in 2003 for students who entered in 1997, so we must start thinking now New IPEDS (federal reporting) forms and instructions will be effective by fall 2002. OMB states that the provisions are effective immediately for all new and revised record keeping or reporting. .
• Will affect faculty/staff reporting as well as student-- see discussion in last section
• For full background, see the federal register (October 30 1997), plus an extensive discussion of issues in an AIR (Association for Institutional Research) alert. Other resources are at census and US department of education sites. See also American Demographics, April 1998.
• This document was updated using AIR Alert #9, update 2, Feb 99 (http://www.fsu.edu/~air/Alert9u2.htm), a handout from AAU registrars meeting by Tony Broh, 2/99, and Bill Haid discussion

Issues

• Categories, definitions
• Collection: Asking the questions
• Entry and storage: Putting the information on the system
• Reporting: Using the information
• Other (timing, translations, faculty/staff)

DEFINITIONS of CATEGORIES (minimum differentiations)

Current, as used by UCB in the application for admission [more extensive definitions probably exist somewhere]

• African American or Black, not of Hispanic origin.
• American Indian or Alaskan Native.
• Asian or Pacific Islander.
• Hispanic, Chicano, Mexican American, Latino.
• White, not of Hispanic origin.

New, from the federal register 

• American Indian or Alaska Native. A person having origins in any of the original peoples of North and South America (including Central America), and who maintains tribal affiliation or community attachment.
• Note explicit inclusion of South and Central America. This was being contested by some US Native American groups.
• OMB recommends that respondents selecting this option be asked for documentation (but does not say what to do if none is given.)
• OMB says "do not change to 'Native American'"
• Native Hawaiian or Other Pacific Islander. A person having origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.
• Note -- new; formerly part of the next category
• Asian. A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and Vietnam.
• Black or African American. A person having origins in any of the black racial groups of Africa. Terms such as "Haitian" or "Negro" can be used in addition to "Black or African American."
• Hispanic or Latino. A person of Cuban, Mexican, Puerto Rican, Cuban, South or Central American, or other Spanish culture or origin, regardless of race. The term, "Spanish origin," can be used in addition to "Hispanic or Latino."
• White. A person having origins in any of the original peoples of Europe, the Middle East, or North Africa.
• OMB has recommended research on adding a category for Arab/Middle East at a later date
 

Current, from the UG application for admission 

• Select the one category that most accurately reflects your ethnic background (for compliance with the 1964 Civil Rights Act).
• African American or Black, not of Hispanic origin.
• American Indian or Alaskan Native.
• Name of Tribe or Nation: ___________________
• Enrolled member of tribe or nation VS. Non-enrolled member of tribe or nation.
• Asian or Pacific Islander.
• Hispanic, Chicano, Mexican American, Latino.
• White, not of Hispanic origin.
• Multiracial -- Indicate other ethnic or racial terms that further or better describe your ethnic background: _______________
• I do not wish to provide this information
• Citizenship collected separately

• Required: Respondents shall be offered the option of selecting one or more racial designations. Recommended forms for the instruction accompanying the multiple response question are "Mark one or more" and "Select one or more."
• The "separate format" (two questions) -- NOT now recommended by IPEDS
• Question 1: Hispanic/Latino, or not? (yes/no)
• Question 2: Mark one or more [or words to this effect] of
• American Indian or Alaska Native [can also use full definition on any/all items](and ask for documentation on this one)
• Asian
• Black or African American
• Native Hawaiian or Other Pacific Islander
• White
• The "combined format" - for situations when assessment is made by observation rather than by self-report.
• Now recommended by IPEDS Single question -- Mark one or more of
• Hispanic/Latino
• American Indian or Alaska Native
• Asian
• Black or African American
• Native Hawaiian or Other Pacific Islander
• White
• We can continue to make additional distinctions (e.g., documented/not) as we like as long as they can be collapsed to the above.
• Citizenship collected separately

We therefore assume that CU will use

• one question with "select one or more" for six groups
• a request for documentation for American Indian or Alaska Native
• additional differentiations if desired -- there has been some pressure for this. However, such differentiation would not be reported to CCHE or to the federal government. UCB current practice is typical of most institutions but there clearly is also precedent for far greater differentiation than we currently do.

Note-- For students we collect ethnicity on the application for admission. We have already printed sufficient applications for undergraduate admission to last through application for fall 2000.  These are applications which do not have the new questions. So applications for 2001 will be our first chance unless we reprint. To start with students entering summer 2001 we must have collection and storage issues resolved for students by April 2000 at the latest.
 

ENTRY and STORAGE -- Putting the data on the system 

Current 

• SIS (Student Information System) will accept only the following values
• I : AMERICAN INDIAN/ALASKAN NATIVE
• N : NON-DOC AMER INDIAN/ALASKAN NATIVE
• A : ASIAN OR PACIFIC ISLANDER
• B : BLACK, NON-HISPANIC
• H : HISPANIC/CHICANO/MEXICAN
• W : WHITE, NON-HISPANIC
• X : OTHER, FOREIGN, ETC
• Used by Admissions when individual is thought to be foreign.
• U : DID NOT PROVIDE
• blank : WILL NOT PROVIDE
• U is entered much more frequently than blank
• Roughly 4-5% of applications and enrolled students are U/blank
• Documented/undocumented American Indian are distinguished (I, N) but tribal affiliation is not stored on SIS
• Applicants to Boulder checking the "multiracial" entry only are entered in the first category they list in the open-text reply, or as U, did not provide, if they list nothing.
• Those checking multiple categories are few; no set rule for entry.
 

• Return whatever was in the old (pre 2003) ethnicity field.
• 6 independent yes/no fields, one for each new category. Any combination of those 6 fields is possible. E.g.,
• NNNNNN = left all blank
• YYYYYY = checked/answered yes to all (someone will surely do this)
• YNNNNN or NYNNNN or NNYNNN or NNNYNN ... = checked only one
• YNYYNN etc. = checked 2 or 3 or 4 or 5
• An additional field to indicate documented/not for American Indians
• A "reporting ethnicity" field derived from the 6 yes/no fields plus citizenship, and conforming to IPEDS reporting requirements (see below)
• Decision: If an individual is to be reported as "non-resident alien," should all six yes/no questions be set to zero? missing?

REPORTING -- Using the information

Current

• For official reporting, data to CCHE, data for federal government requests, etc., we
• Collapse documented/not into one American Indian/Native American category (federal and state reporting does not support the documented/not distinction)
• Use foreign-student info (a separate SIS field) to identify "non resident aliens," and call them this regardless of any ethnic/racial categorization for them
• Report U's, blanks, and any X's that aren't foreign as unknown
• For some internal purposes we sometimes distinguish documented/not
• There is one and only one dimension; all categories are mutually exclusive

ANTICIPATING THE RESULTS

• In fall '98 we surveyed CU-Boulder undergraduates in the five (old) racial/ethnic groups
• We knew what students had said on the old application for admission
• We asked the new "check all that apply" question (in September '98 two-question format). See question

• Minimum of 36 respondents per group

Implications

• Over 20% of every group of color also checked "white." How should such individuals be reported in longitudinal data on entering students, enrolled students, and degree recipients of color?
• 5% of old-code whites also checked another group. If 80% of students are old-code white, and 5% check another group, and we call these "students of color," the number of students of color will instantly increase by 25%
• The math: 80 whites, 20 students of color. 5% of the 80, or 4, check another group. This yields 24 students of color, a 25% increase.
• Possible "student of color" definitions
  • Checked any category except white and did not check white. Would reduce apparent N's by 20% or more
  • Checked any category except white, whether checked white or not. Would increase apparent N's by 20% or more.

• The University of Washington no longer collects ethnicity (or gender) on the application for admission, but later, at confirmation. The University of Washington does this to comply with a state prohibition on use of gender or ethnicity in University decisions.
• Translating from old to new
• We could ask all current students to answer the new questions, although it would be difficult logistically. VRR might be a possibility.
• We cannot ask students who aren't enrolled -- e.g., freshmen entering in '97 or '98 on whose (lack of) graduation we'll be reporting in 2003
• We could translate from old to new readily except for splitting current "Asian American" into two categories. We have discussed algorithms for doing so based on permanent address or state of origin but have decided these would be unwise.
• Even with great translation we cannot fill in multiple-category, multi-racial information. Tracking changes over time will be very messy.
• We can use a combination approach-- ask new and enrolled students, and faculty and staff, and use a translation for students who have left.

• Faculty & Staff
• All rules will apply to reporting for faculty and staff as well. 
• Currently staff indicate race/ethnicity by picking one of five choices on the state of Colorado application form.
• Faculty and unclassified staff usually provide information more informally (e.g., in a letter) or are classified by observation using the same five categories. This information is usually entered to the payroll system by a department secretary.
• The current payroll system defines codes for only the five usual groups. Individuals with other codes entered, or no code, who are at Boulder are asked by letter to place themselves in one of five groups. Practices differ somewhat at the other campuses.
• The reporting regulations will be addressed by ASP through Peoplesoft HR.

• CCHE affirmative action policy may well need to be changed
• Vocabulary:
  • The term "non-white" may not be used in presenting federal government data, per OMB rules. Various phrases involving the term "all other races" may be used. OMB is silent (at least in the handout) on use of the terms "minority" and "people of color."
  • OMB also says
    • American Indian not Native American
    • Spanish - Hispanic/Latino is OK
    • Black is OK
• Who does what -- we need to resolve
• What to ask students/applicants, and faculty, and staff
• When and how to ask current students, faculty, and staff the new questions
• How to enter and store the information in SIS, any new student system, ASP, etc.
• How we'll report individual-level student data to CCHE (CCHE + boards decision)
• How we, CCHE, and the federal government will report aggregate data (IPEDS will decide much of this)
• How we'll handle internal reporting
• How we'll handle translation of existing data, and longitudinal reporting
• 4 campus coordination
• Roles of Admissions, Pinnacle, Ofelia Miramontes (diversity AVC, Boulder) and similar positions, IR council, UMS, IIU, SIS key users and governing board

Last revision 03/28/06