Data Collection without Definitions: Problems with OMB Directive 15 and a Proposal
The Office of Management and Budget’s Statistical Directive No. 15, first issued in 1977 and revised in 1997, sets out minimum standards for the federal government around collecting and reporting data by race and ethnicity. Directive 15 directly promotes comparability and sharing of data across the government and beyond as the standards are adopted voluntarily by other organizations. Despite these benefits, the Directive is regularly the subject of criticism, particularly regarding the definitions it provides for each of the five racial categories and the definition for Hispanic or Latino. In this paper, we propose a novel solution: dispense with the definitions altogether. We describe problems with the definitions, including their circular logic, inconsistency, and lack of comprehensiveness; we describe how they conflate race with related concepts such as ancestry and nationality and inappropriately constrain the identity choices of individuals and groups. Our narrowly tailored proposal, designed for practical implementation, would immediately resolve these problems, increase data comparability across time, and increase flexibility provided by Directive 15.