60-day FRN Summary of Public Comments

NSFG

OMB Attachment B2

OMB No. 0920-0314

Public Comments on 0920-0314
Federal Register Notice from 6/10/21

Public Comment #1 (no spelling corrections made)
From: Jean Public
Sent: Monday, June 21, 2021 6:49 PM
To: OMB-Comments (CDC) ; [email protected]; [email protected]; [email protected];
[email protected]
Subject: Fw: public comment on federal register comment

this useless iformation should not be expensively collecgted every single year. once every 3 to 5 years is often
enough and gives the nation a feelign as to how secure marraige in. when you have so many politicians and
movie stars exhibiting such failures as marraige it in fact is very deleterious to this nation in terms of having
secure marraiges that last or turning in the wife for a younger newer model, which seems to be the rage these
days in both politics and in hollywood and entertainment.
marriage has been attacked by the rich people of america. none of the marriages seem to last without men
gadding about so that the future of marraige is not very secure.
spending tax dollars for this continuing collection is not necessary. this nation can see what is happening and
once every 3 to 5 years is often enough. the women pay the taxes for the kids and the family and whent he men
leave them they are destitute.

Public Comment #2 (7-page memo from American Atheists group has been added on next page to
preserve formatting) (brief response to this memo has been included as new Attachment B3)

August 9, 2021
Jeffrey M. Zirger
Lead, Information Collection Review Office
Office of Scientific Integrity, Office of Science
Centers for Disease Control and Prevention (CDC),
Department of Health and Human Services (HHS)
395 E St SW
Washington, DC 20024
Re:

Comments on “Proposed Data Collections Submitted for Public Comment and
Recommendations” (Dkt No. CDC-2021-0056; Doc. No. 2021-12210)

Dear Mr. Zirger:
American Atheists writes in response to the Notice and Comment submission by the Center for Disease
Control and Prevention (CDC) titled: “Proposed Data Collections Submitted for Public Comment and
Recommendations,” published June 10, 2021.1 CDC requested comments on the National Survey of
Family Growth (NSFG), specifically how the survey can be streamlined to collect more effective and
useful data and to minimize the burden on those who are responding to the survey. We submit
comments pertaining to the interests of nonreligious people and religious minorities, who are poorly
served by the Christian-oriented questions used to identify religious belief used in the survey. We ask
you to consider revising and updating these outdated religious questions in collaboration with
nonreligious and religious minority stakeholders.
American Atheists is a national civil rights organization that strives to achieve religious equality for
Americans by protecting what Thomas Jefferson called the “wall of separation” between the
government and religion created by the First Amendment. We work to create an environment where
atheism and atheists are accepted as members of our nation’s communities and where casual bigotry
against our community is seen as abhorrent and unacceptable. We promote understanding of atheists
through education, outreach, and community-building and work to end the stigma associated with being
an atheist in America. As advocates for religious equality, American Atheists believes that government
programs should be inclusive and accessible to people regardless of their religious beliefs or lack
thereof.

1

Center for Disease Control and Prevention (CDC), Department of Health and Human Services (HHS); Notice with
Comment Period; Proposed Data Collections Submitted for Public Comment and Recommendations 86 Fed. Reg.
30937, Dkt No. CDC-2021-0056, Doc. No. 2021-12210, Proposed Jun 10, 2021. Available at
https://www.federalregister.gov/documents/2021/06/10/2021-12210/proposed-data-collections-submitted-forpublic-comment-and-recommendations.
American Atheists
225 Cristiani St.
Cranford, NJ 07016

Phone 908.276.7300
fax 908.276.7402
www.atheists.org

Page 2 of 7
Improved Data Collection Regarding Religion is Essential for Nonreligious People and
Religious Minorities
Despite the stigma and inequities facing nonreligious people and religious minorities living in the US,
there is very little federal data collection pertaining to these populations. Questions about religious
belief are not asked on any major federal population survey, such as the YRBS, BRFSS, NSDUH, or NHIS.
This results in part from a 1976 law that prohibits the collection of mandatory religious data on the
Census, providing that “(c) Notwithstanding any other provision of this title, no person shall be
compelled to disclose information relative to his religious beliefs or to membership in a religious body."2
However, this limitation pertains only to mandatory data collection on the Census; the federal
government is fully capable of offering voluntary data collection on religion through population surveys
and cohort surveys such as the NSFG.
There has been substantial research showing that nonreligious people and religious minorities in the US
face stigmatization and minority stress that leads to significantly worse psychosocial outcomes.3 For
example, members of other faiths consistently rank atheists as the group they feel least positively
toward.4 And atheists and Muslims face clear bias in terms of government services.5 Despite comprising
of only 2.4% of the population,6 Jewish people were subject to about 63% of religious-based hate crimes
in the U.S. in 2019.7 Similarly, Muslims, despite making up only 1.1% of the population,8 were subject to
12% of religious-based hate crimes. Unfortunately, because there is insufficient data collection
concerning religion in US population surveys, the full extent of disparities faced by these populations is
unknown.
Nonreligious Americans
Because of this lack of data, American Atheists conducted the US Secular Survey, a 2019 survey of
nearly 34,000 nonreligious people living in the United States. Data from this survey shows
unequivocally that nonreligious people in the US encounter stigma and discrimination in various

2

13 U.S.C. § 221(c).
See, e.g., Brewster, M. E., Velez, B. L., Geiger, E. F., & Sawyer, J. S. (2020). It’s like herding cats: Atheist minority
stress, group involvement, and psychological outcomes. Journal of Counseling Psychology, 67(1), 1–13. Available at
https://doi.org/10.1037/cou0000392.
4
See, e.g., Burge, R.P. (2021). How Positive Do You Feel About These Groups. Data from General Social Survey,
2018.
5
See, e.g., Pfaff, S., Crabtree, C., Kern, H.L., & Holbein, J.B. (2020). Do Street-Level Bureaucrats Discriminate Based
on Religion? A Large-Scale Correspondence Experiment among American Public School Principals. Public
Administration Review, Aug. 30, 2020. Available at https://doi.org/10.1111/puar.13235.
6
Pew Research Center (2021, May 11). The Size of the U.S. Jewish Population. Available at
https://www.pewforum.org/2021/05/11/the-size-of-the-u-s-jewish-population/
7
FBI 2019 Hate Crime Statistics. Incidents, Offenses, Victims, and Known Offenders. (2019). Available at
https://ucr.fbi.gov/hate-crime/2019/topic-pages/tables/table-1.xls
8
Pew Research Center. (2018, Jan. 3). New estimates show U.S. Muslim population continues to grow. Available at
https://www.pewresearch.org/fact-tank/2018/01/03/new-estimates-show-u-s-muslim-population-continues-togrow/.
3

American Atheists
225 Cristiani St.
Cranford, NJ 07016

phone 908.276.7300
fax 908.276.7402
www.atheists.org

Page 3 of 7
aspects of their lives.9 Nearly one third (29.4%) of survey participants experienced discrimination in
education due to their nonreligious identity, and one in five (21.7%) experienced discrimination at
work.
Given this treatment, it is no surprise that nonreligious people frequently feel the need to conceal
their beliefs. Nearly one third (31.4%) of participants mostly or always concealed their nonreligious
identity from members of their immediate family. More than two in five participants mostly or
always concealed their nonreligious identity among people at work (44.3%) and people at school
(42.8%). Perhaps contributing to the frequent concealment of their nonreligious identities, nearly
half (47.5%) of survey participants were sometimes, frequently, or almost always asked or felt
pressure to pretend that they are religious.
Because of the discrimination and stigmatization nonreligious people face in our society, they
experience heightened rates of loneliness and depression. Our research shows that one in six
(17.2%) of survey participants are likely to be depressed and about one quarter (25.6%) of
participants often experience one or more indicators of loneliness and social isolation.
Notably, the level of discrimination and stigmatization was dramatically higher for participants
living in very religious areas. Nonreligious participants living in very religious communities were
nearly 2.5 times more likely to experience negative events in education than in not at all religious
communities, nearly 2.5 times more likely to experience negative events in public services (for
example, voting, jury duty, poll work), more than 3 times more likely in employment, and more
than 2 times more likely when dealing with private businesses. Moreover, participants living in very
religious communities experienced nearly 40% more stigma than those in not at all religious
communities.
Jewish Americans
ADL’s Audit of Antisemitic Incidents in the United States for 2020 showed a significant amount of
discrimination against Jewish Americans, the third-highest year on record since ADL began
recording in 1979.10 This report saw more than 2,000 acts of assault, vandalism, and harassment
incidents against the Jewish Community in 2020. While total number of incidents decreased 4%
from 2019, the highest year on record, incidents of harassment increased 10% from the previous
year. Furthermore, Jewish institutions such as synagogues, Jewish community centers, and Jewish
schools, recorded 327 incidents, a 40% increase from 2019. Of the 327 incidents, 264 were
harassment, and 114 of those were “Zoombombings,” a form of online harassment targeting the
Jewish community.”11 However, ADL’s Audit of Antisemitic Incidents cannot assess the full scope of
hate incidents and hate crimes against Jewish Americans, as such data is grossly underreported.
9

Frazer, S., El-Shafei, A., Gill, A.M. (2020). Reality Check: Being Nonreligious in America. Cranford, NJ: American
Atheists. Available at www.secularsurvey.org.
10
ADL. Audit of Antisemitic Incidents 2020. (2020). Available at https://www.adl.org/audit2020#executivesummary.
11
ADL. ”What is ’Zoombombing’ and Who is Behind It?” (2020, May 4). Available at
https://www.adl.org/blog/what-is-zoombombing-and-who-is-behind-it.

American Atheists
225 Cristiani St.
Cranford, NJ 07016

phone 908.276.7300
fax 908.276.7402
www.atheists.org

Page 4 of 7

Muslim Americans
Although Muslims in America comprise an underrepresented and underserved population that
faces significant disparities, there is limited data available about this population except for hate
crime data. In 2019 the FBI released their annual report on hate crime statistics and, even though
hate crimes are severely underreported for a variety of factors, 2019 saw more hate crimes than
any year other than 2008.12 However, due to lack of data and reporting it is unclear exactly how
many hate crimes take place in this country as law enforcement agencies do not have to report
hate crimes and many victims refrain from reporting hate crime incidents. Moreover, since the
2016 election, attacks on mosques are at an all-time high. Vandalism, threats, arson, and bombings
occur too often, with little to no media coverage and investigation into the perpetrators.13
Unfortunately, hate crime data alone cannot provide a full assessment of the needs and disparities
facing religious minority populations. With additional data from better federal data collection
concerning religion, both organizations and the federal government will be better able to assess
the challenges facing these populations and target programs to address the disparities resulting
from discrimination and stigmatization.
The National Survey of Family Growth Uses Antiquated Religious Questions that Fail to Collect
Appropriate Data on Nonreligious and Religious Minority Populations
The NSFG has included questions on religion as part of its longitudinal analysis for decades.14
Unfortunately these questions are quite outdated and Christian-oriented. Rather than reflecting
the wide diversity of religious belief and nonbelief in the US, they assume predominant Christianity
and focus on identifying members of particular Christian denominations. Despite the flaws in this
methodology, the Trump Administration sought to expand this approach to other data
collections.15 Moreover, there were other misguided attempts made to collect religious data, often
in ways that lack accuracy and confidentiality.16
12

Muslim Advocates ”2019 FBI Data Undercounts Hate Crimes” (2020, Nov. 17). Available at
https://muslimadvocates.org/2020/11/muslim-advocates-2019-fbi-data-undercounts-hate-crimes.
13
Muslim Advocates Threats and Violence Against Mosques. Available at
https://muslimadvocates.org/advocacy/threats-and-violence-against-mosques/.
14
CDC, National Center for Health Statistics. National Survey of Family Growth Questionnaires, Datasets, and
Related Documentation. Available at https://www.cdc.gov/nchs/nsfg/nsfg_questionnaires.htm.
15
See, e.g., Administration for Children and Families, Submission for OMB Review; Youth Empowerment
Information, Data Collection Exploration on Avoidance of Sex (IDEAS) (New Collection), 85 Fed. Reg. 49376, Doc.
No. 2020-17680, proposed Aug. 13, 2020. Available at:
https://www.federalregister.gov/documents/2020/08/13/2020-17680/submission-for-omb-review-youthempowerment-information-data-collection-and-exploration-on-avoidance.
16
See, e.g., Agency Information Collection Activities; Submission to the Office of Management and Budget for
Review and Approval; Comment Request; Mandatory Civil Rights Data Collection, 85 Fed. Reg. 40628, Docket No.
ED-2019-SCC-0119, Doc. No. 2020-14486, proposed July 7, 2020. Available at
https://www.federalregister.gov/documents/2020/07/07/2020-14486/agency-information-collection-activitiessubmission-to-the-office-of-management-and-budget-for.

American Atheists
225 Cristiani St.
Cranford, NJ 07016

phone 908.276.7300
fax 908.276.7402
www.atheists.org

Page 5 of 7

The NSFG’s approach to religious data collection is exclusionary, out of date, and in serious need of
revision. The religious questions focus on a large number of small Christian sects, which is
confusing, vague, and does not represent the full scope of American Christianity. Because of the
large number of these Christian sects,17 the questions are likely to fail to produce sufficient sample
sizes to provide reportable data. Further, there is no reason to collect data on the “type” of
Christianity (“born again,” charismatic, evangelical, fundamental, and none of the above), as these
descriptions are extremely subjective, and the data serves no governmental function. Finally, the
current NSFG religious questions fail to collect information on various religious beliefs or relegates
them to a dismissive “other” category.18
The manner in which these questions apply to nonreligious people reflects some of the flaws in the
NSFG’s approach to religious data collection. Surveys of religious belief conducted by the Pew
Research Center have shown that there has been a significant growth in religiously unaffiliated
people, often referred to as “Nones,” over the last several decades.19 However, research has shown
that this category is comprised of people of widely varying beliefs, from devoutly religious people
who have a belief system that is not easily characterized, to people who lack well-defined religious
beliefs but consider themselves “spiritual,” to agnostics, humanists, and atheists. And while Nones
are currently the fastest growing religious category (with 46.7% of youth ages 18-25 falling in this
category),20 only approximately 9% of the US population identifies as atheist or agnostic.
Despite significant differences between religiously unaffiliated and nonreligious (atheist, agnostic,
etc.) people and the significant size of these populations, they are grouped together for analysis on
the NSFG. This not only fails to take into account the important differences between these groups,
it obscures data about these widely varying populations.
The Trump Administration proposed rule changes involving mandatory civil rights data collection and
data collection in public schools requiring third party reporting of religious data would be highly
problematic nonreligious and religious minority communities.21 The rule essentially forced
administrators to routinely make assumptions and record what they believed the religion of the
students bullied to be and whether they thought there was a religious motivation for the bullying. This
reporting process would likely result in inaccurate data for nonreligious and religious minority students.
17

The relevant questions allow individuals to select one of 22 Christian denominations.
The relevant questions relegate Muslims, Buddhists, and Hindus to the “other” category and fail to collect data
on groups such as Sikhs.
19
See, e.g., Pew Research Center (2015). Religious Landscape Study: The Unaffiliated. Available at
https://www.pewforum.org/religious-landscape-study/religious-tradition/unaffiliated-religious-nones/.
20
Djupe, P. A. & Burge, R. P. (2020). “The Decline of Religion Continues – Nones Gain 3 Percent in One Year.”
Religion in Public Blog. Available at https://religioninpublic.blog/2020/10/07/the-decline-of-religion-continuesnones-gain-3-percent-in-one-year/.
21
See, e.g., Administration for Children and Families, Submission for OMB Review; Youth Empowerment
Information, Data Collection Exploration on Avoidance of Sex (IDEAS) (New Collection), 85 Fed. Reg. 49376, Doc.
No. 2020-17680, proposed Aug. 13, 2020. Available at:
https://www.federalregister.gov/documents/2020/08/13/2020-17680/submission-for-omb-review-youth
empowerment-information-data-collection-and-exploration-on-avoidance.
18

American Atheists
225 Cristiani St.
Cranford, NJ 07016

phone 908.276.7300
fax 908.276.7402
www.atheists.org

Page 6 of 7
Furthermore, it would negatively affect such students’ well-being, as they would be unable to report
their own religion and they would be disseminated into a religion based on what the administrators
believe their religion to be.
Religious Data Collection Must Be Inclusive, Voluntary, and Confidential
The NSFG is one of the few examples of federal data collection pertaining to religion, and as discussed,
the questions are outdated, exclusionary, and imprecise. We recommend that CDC and other relevant
agencies allocate resources to create updated survey questions regarding religion for use on appropriate
surveys.
A primary consideration for many religious minority populations is confidentiality of data. Concerns
about the confidentiality of data arose recently when the Trump Administration proposed to update the
Dept. of Education’s Civil Rights Data Collection (CRDC) to disaggregate bullying based on various
religions.22 The proposal essentially would force school administrators to routinely question students (or
make assumptions) about their religious beliefs and to create and maintain records about the religious
beliefs of students. Because of the lack of confidentiality inherent in this manner of data collection, it
likely would have contributed to increased stigmatization and discrimination against religious minority
and nonreligious students.
For example, even if students are not named in reports, faculty may know or easily determine the
identity of the student or students in a report. In schools with a small number of students, data collected
on religious harassment and bullying may not be anonymous because few students may fit the
demographic information reported about the victim or victims. As the statistics above demonstrate,
nonreligious and religious minority students already experience discrimination in school, and this rate of
discrimination is significantly higher in highly religious communities that are predominantly of one
religion.
This example helps illustrate why questions that collect religious data should only be self-report data on
voluntary surveys where data is not personally identifiable. Third-party reports of religious data tend to
be inaccurate and lack confidentiality, and so they should be avoided to the extent possible, outside of
necessary contexts such as hate crime reporting. Instead, broad, anonymous, population surveys, such
as YRBS and BRFSS, would be ideal for this type of data collection and provide essential data on
disparate risk factors facing religious minority and nonreligious populations.
The federal government has the resources and the technical expertise to develop suitable questions for
religious data collection on population surveys. By working with various organizations representing
nonreligious and religious minority communities, we believe that this data collection could be done
respectfully and in a way that takes into account the entirely valid concerns that religious minority and
nonreligious communities may have regarding confidentiality. We invite you to reach out to us so that
we can discuss this matter in greater detail.

22

Because of the delay and disruption caused by the pandemic and further revision to the CRDC, it is our
understanding that this proposed rule has not been implemented.

American Atheists
225 Cristiani St.
Cranford, NJ 07016

phone 908.276.7300
fax 908.276.7402
www.atheists.org

Page 7 of 7
Conclusion
The NSSFG is unique among federal surveys in that it captures data relating to religious beliefs.
Unfortunately, however, the relevant questions about religion are outdated and exclusionary. Because
of this inadequate data collection, the federal government is failing to identify and address significant
disparities faced by nonreligious people and religious minorities. We urge the CDC to update its NSFG
questions pertaining to religion and invite the agency to work with organizations that serve nonreligious
and religious minority communities as part of this process. If you have any questions regarding these
comments, please contact me at [email protected].
Sincerely,

Alison Gill, Esq.
Vice President, Legal & Policy
American Atheists

American Atheists
225 Cristiani St.
Cranford, NJ 07016

phone 908.276.7300
fax 908.276.7402
www.atheists.org