SPD 15 Implementation Plan

OMB Control No. 0607-0810

Request for Non-substantive Change to the
American Community Survey
2024 Statistical Policy Directive No. 15 Implementation Plan
OMB Control No. 0607-0810
U.S. Department of Commerce
U.S. Census Bureau

Purpose
The purpose of this non-substantive change request (NSCR) is to provide a written plan and
timeline for the American Community Survey (ACS) and Puerto Rico Community Survey (PRCS)
to implement the 2024 Statistical Policy Directive No. 15 (SPD 15) Standards for Maintaining,
Collecting, and Presenting Federal Data on Race and Ethnicity. 1

Background
The ACS collects race and ethnicity data from respondents according to the standards outlined
by the U.S. Office of Management and Budget (OMB) in SPD 15. In March 2024, OMB issued
updates to SPD 15 that must be implemented into all Federal information collections that
collect data on race and ethnicity as soon as possible but no later than March 28, 2029.
As indicated in the Census Bureau’s information collection request (ICR) for the 2025 ACS, the
race and ethnicity standards will not be updated in data year 2025. As part of the terms of
clearance for the 2025 ACS, the OMB requested that the Census Bureau publish a Federal
Register Notice (FRN) seeking public input on the impact of different compliance timelines for
the ACS, summarize the comments, and provide a written report describing the steps needed
for the ACS to comply with SPD 15. As a culmination of the information gathered from these
steps, the Census Bureau is submitting this NSCR with a plan and timeline for the ACS to comply
with the updated standard.

Summary of Comments

In response to the terms of clearance, an FRN was posted on July 12, 2024, soliciting feedback
about the impact the SPD 15 update will have on data users, researchers, and community
organizations if it is implemented in either the 2026 ACS or the 2027 ACS.
Through the Interagency Committee on Statistical Policy (ICSP), comments from federal agencies
were also solicited given that the ACS serves as a data source for numerous federal statistical
agencies and other executive branch agencies.

1

For ease of discussion, the term ACS is used throughout this document to represent both the ACS and PRCS.

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The Census Bureau received 279 public comments and comments from 25 federal agencies. A
summary of the comments received, and the Census Bureau’s response are documented in
Attachment A.

Census Bureau Assessment

As a foundational item on the ACS, it is critical that race and ethnicity data produced to meet
the updated SPD 15 are accurate. Therefore, we must carefully assess our ability to implement
the updated SPD 15 in the ACS while maintaining the data quality standards the public expects.
Local, state, tribal, and federal programs use data on race and ethnicity for a myriad of
purposes. Race data are used in planning and funding government programs that provide funds
or services for specific groups. These data are also used to evaluate government programs and
policies to ensure that they fairly and equitably serve the needs of all racial groups and to
monitor compliance with antidiscrimination laws, regulations, and policies.
Staff and leadership from the Census Bureau’s ACS Program have assessed the impact of
implementing SPD 15 on ACS systems and operations. Nearly every step in the ACS survey life
cycle, from content development through data dissemination, is impacted by this change. While
prior content testing provides a solid basis for the questions and associated variables for data
collection instruments, the coding, editing, imputation, and data products require additional
time for development. That development time also includes outreach to the public and key
stakeholders about the SPD 15 changes.
This assessment, along with the proposed implementation timeline, is documented in
Attachment B.

Final Recommendation

Based on the Census Bureau’s assessment, feedback from the public, along with feedback from
other federal agencies that rely on ACS data, the Census Bureau proposes to begin collecting
race and ethnicity data under the new standard beginning with the 2027 ACS.

Attachments

Attachment A. Summary of Comments on ACS Implementation of SPD 15
Attachment B. Implementing Updated SPD 15 in the ACS

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Attachment A.
Summary of Comments on ACS Implementation of SPD 15
On July 12, 2024, the Census Bureau published a Federal Register Notice (FRN) seeking public
input on the impact of different timelines for the American Community Survey (ACS) to comply
with SPD 15. Through the Interagency Committee on Statistical Policy (ICSP), comments from
federal agencies were also solicited given that the ACS serves as a data source for numerous
federal statistical agencies and other executive branch agencies. This document provides a
summary of the comments received and the Census Bureau’s response to the comments.

1. Public Comments
Table 1 summarizes the comments received on the July 2024 FRN: ACS Timeline for
Implementing Updated 2024 Race and Ethnicity Data Standards.
Table 1. Public Implementation Timeline Feedback by Comment Topic
TOTAL PUBLIC COMMENTS
279
Comment on SPD 15 Policy

231

Discussed change to Black category

123

Discussed change to MENA category
and need for more research
Did not comment on timing
Recommended postponing or not
implementing

8
12

Support 2027

6

Support earliest year after research

5

Support 2026
•

108

17

Most of the comments received (over 80%) were comments on the SPD 15 policy itself.
o 123 comments related to requests to change the “Black or African American”
category to distinguish people descended from slaves vs. immigrants from Africa or
the Caribbean. Various requests were made about the language of the categories or
how to address this issue. A majority of these comments did not comment on the
timeline for implementing the current SPD 15. Five comments explicitly stated the
updated standard should not be implemented until this issue is addressed.
The U.S. Census Bureau collects race and ethnicity data following standards set by
the U.S. Office of Management and Budget (OMB). Per the guidance in OMB’s 2024
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Statistical Policy Directive No. 15, the Census Bureau will continue to use the
category name “Black or African American” for the ACS.
o 108 comments related to requests to include Armenian in the MENA classification.
Most of these commenters supported 2027 implementation in order to allow
sufficient time to adjust the classification and engage the community in discussions.
However, comments also stated that if the Census Bureau decides not to pursue
research prior to the 2027 ACS implementation, it should proceed as quickly as
possible with implementation in 2026 in order for this necessary research to be
conducted before implementation on the 2030 Census.
The Census Bureau plans to implement the updated 2024 standards in the ACS as
directed by OMB. The updates to SPD 15 were informed by robust empirical
research; extensive engagement with experts, scholars, organization leaders and
communities across the country; and the successful and meaningful collaboration
among federal agency leaders and experts on the Interagency Technical Working
Group on Race and Ethnicity Standards. In its decision, OMB noted that although
several commenters expressed interest in explicitly including Armenian as part of the
MENA category, the 2015 National Census Test found that most respondents who
identify as Armenian did not select MENA when it was offered. The OMB advised
that additional Federal agency research is needed on these groups to monitor their
preferred identification.
The Census Bureau is not pursuing empirical research to change the race and
ethnicity question design at this time. The OMB has established a Federal Committee
on SPD 15 that will manage a government-wide research agenda and undertake
regular reviews of the standards. Any plans for experimental testing will be
considered at a later time and in collaboration with OMB’s Federal Committee on
SPD 15. Once the Census Bureau has implemented the updated standards with a
combined race and ethnicity question, a dedicated MENA category, multiple detailed
checkboxes and examples, and dedicated write-in response areas, we will have the
ability to examine how respondents from all communities are self-identifying within
the framework of the updated race and ethnicity standards.
Additionally, the Census Bureau will be seeking public feedback through a FRN later
this year on how detailed race and ethnicity populations will be coded in the ACS.
The Census Bureau will consider all feedback provided in response to the FRN, but all
updates to how groups are coded must also be supported by strong research and
evidence and align with the definitions of the minimum reporting categories in the
updated SPD 15 before making any changes.

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•

Eight comments did not mention the timeline and are out of scope for this document.
They raised various issues:
o One supported implementation but did not comment on the timeline.
o Two indicated that race is a false identity.
o One raised concerns and questions about the crosswalk needed for the U.S.
Department of Veterans Affairs purposes.
o One suggested that the race question should be changed to ask about visual
identification but keep categories as is.
o One suggested race categories should be customized based on region of the
respondent to allow for easier self-identification; bridging factors should also be subnational.
o One provided their race without further comment.
o One indicated comments were in an attachment, but no attachment was provided.

•

Twelve comments suggested postponing implementation or that the Census Bureau
should not implement SPD 15. Reasons for postposing or not implementing included
requesting a change to the Black or African American category (5) as discussed above,
concerns about data breaches and safety (4), waiting to implement the updates in the
ACS until 2030, when they are also implemented into the decennial census (1), concerns
that the justification for collection and use of race data is not clear (1), and needing to
change the question wording and categories, and conduct testing before implementing
(1).
The Census Bureau uses confidential survey answers to create statistics, and no one is
able to identify individuals’ survey answers from the statistics we produce. The Census
Bureau is legally bound to strict confidentiality requirements. Individual records are not
shared with anyone, including federal agencies and law enforcement entities. Data on
race and ethnicity are used by local, state, tribal, and federal programs, and they are
critical factors in the basic research behind numerous policies, particularly for civil rights.
Race and ethnicity data are used in planning and funding government programs that
provide funds or services for specific groups.
The Census Bureau must implement the updated SPD 15 as expeditiously as possible,
and within OMB’s required 5-year implementation period (no later than March 28,
2029). The updates to SPD 15 were informed by robust empirical research; extensive
engagement with experts, scholars, organization leaders and communities across the
country; and the successful and meaningful collaboration among federal agency leaders
and experts on the Interagency Technical Working Group on Race and Ethnicity
Standards. Many of the SPD 15 updates are supported by Census Bureau research
findings over the past decade. Any plans for experimental testing will be considered at a
later time and in collaboration with OMB’s Federal Committee on SPD 15.
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•

Six comments supported 2027 implementation; they were primarily concerned with
accuracy of the data and expressed that if the Census Bureau needs another year to
ensure quality data, they were supportive of that. Commenters also expressed a desire
to be involved in discussions about coding, bridging, and data products.

•

Five comments supported either year for implementation, with most requesting
implementation as soon as feasible after completing research and stakeholder outreach.
The request for research varied from wording and category research to bridging and
data products. These commenters also indicated that if the Census Bureau was not
planning to do any additional research, then the updates should be implemented in
2026.

•

Of the seventeen comments that supported implementation in 2026, most referenced
the need for the low-level data sooner for specific sub-groups and to address inaccurate
reporting and burden for respondents. They also mentioned the need for data users to
have data ahead of 2030, both to prepare for 2030 data and to provide an opportunity
to correct issues prior to 2030 data products.
The Census Bureau is appreciative of the publics comments on the timeline to
implement SPD 15 in the ACS. In making a final recommendation about the timeline the
Census Bureau weighed the need for producing data under the new standard as quickly
as possible against the need for accurate data.

2. Federal Agency Comments
Through the Interagency Committee on Statistical Policy (ICSP), 25 federal agencies responded
to a request to identify impacts to their agency and programs if ACS implemented the updated
SPD 15 in 2027 as opposed to 2026. Table 2 summarizes the comments.
Table 2. Federal Agency Feedback
TOTAL FEDERAL AGENCY RESPONSES

25

Support for 2027 Implementation
Minimally impacted, not impacted, or have no
concerns about timing of a 2027 implementation
Support minimizing risks and ensure data quality

20

Aligns with agency and/or survey plans
No concern with timing of implementation
Expressed some concern

12
2
2
4*
5

Twenty of these agencies indicated there was no impact to their agency or programs of the
timing of ACS implementation. However, four agencies stressed the value of communication &
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coordination on data collection, coding, editing, bridging factors, imputation, tabulation, and
other methodological issues. (Note, in addition to these four agencies, three agencies that
expressed concern about the timeline also indicated the importance of communication and
coordination.)
Five agencies expressed some concerns about the timing of ACS implementation. Census
Bureau staff met with these five agencies (plus the Centers for Medicare & Medicaid Services)
to discuss the use of ACS for these surveys and programs in more detail. A summary of the
agency, their concern, and discussion is below.
Table 3. Concerns Raised by Agency and Status
Agency
Concern

Status

National Center for Health
Statistics (NCHS)

Expect Vital Statistics to take
long to transition. Primarily
concerned with comparability
of data.

This concern exists regardless of
whether ACS implements in 2026
or 2027. Census Bureau staff can
work with NCHS on the bridging
algorithm.

Centers for Disease Control
and Prevention (CDC)

Use ACS for weighting and
population denominators for
various programs.

Staff at CDC were open to using
Population Estimates Program
(PEP) or bridging factors, with
Census Bureau support. Census
Bureau staff will continue
discussions with CDC about
options.

Health Resources and Services
Administration (HRSA)

National Survey of Children’s
Health (NSCH) uses ACS for
raking: age, sex, race,
household poverty ratio,
household size, education.

NSCH uses prior year ACS data
which would mean use for NSCH
in 2027 or 2028. Theoretically
PEP could be used for race or
bridging factors could be used
but it would be a tradeoff of
effort vs implementation
timeline.

HRSA

National Sample Survey of
Registered Nurses (NSSRN) uses
ACS for weighting; cannot use
PEP because of the
subpopulation of interest.

NSSRN is conducted every four
years. The next iteration of the
survey is in 2026, which will use
2025 ACS data for weighting. The
2025 ACS will not have updated
race data. The 2030 iteration will
use 2029 ACS data, which will
have the updated standards

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Agency

National Center for Science
and Engineering Statistics
(NCSES)

Concern

Status

applied. NSSRN is also
considering conducting the
survey every two years. If the
survey is conducted in 2028, data
from the 2027 ACS with the
updated standard will be
available for use. Therefore,
there is no impact of the timing
of ACS implementation on
NSSRN.
The National Training,
If NTEWS stays on the current
Education, and Workforce
schedule it delays use of ACS
Survey (NTEWS) uses ACS as the updated race data for sampling
frame and the sample is
by two years. PEP cannot be
stratified on sex, race,
used. This impact may be
educational attainment, and
mitigated if NTEWS is combined
Science Technology Engineering with National Survey of College
and Math (STEM) occupations.
Graduates (NSCG) and
implemented on the NSCG
schedule.

NCSES

Analytical and congressionally
mandated STEM reports rely on
ACS public use microdata
sample (PUMS) data. Reports
use 3-year-old ACS data.

If ACS implements in 2026, the
reports released in 2029 would
use the new standard. If 2027,
then reports would be updated
in 2030.

Internal Revenue Service (IRS)

Use of ACS data for Bayesian
Improved First Name and
Surname Geocoding method of
imputing race and ethnicity
data when not collected
(reported).

The 5-year ACS data will be
available beginning in December
2028 and use 1 year of race and
ethnicity data collected under
the new standard and 4 years
worth of race and ethnicity data
cross-walked from the old
standard to the new standard.
IRS is evaluating a pilot of noise
injected race and ethnicity
microdata. Either approach (ACS
data or the microdata) will
require a crosswalk and bridging

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Agency

Concern

Status
of race and ethnicity data under
the current standard to the new
standard.

The Census Bureau expects to have continued conversations with these agencies. The Census
Bureau will also participate on interagency subgroups to discuss methodological best practices
related to implementation.

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Attachment B.
Implementing Updated SPD 15 in the ACS

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TABLE OF CONTENTS
1.

INTRODUCTION ............................................................................................................ 13

2.

ACS SURVEY LIFECYCLE OVERVIEW ................................................................................ 13

3.

FRAME & SAMPLE ......................................................................................................... 14

4.

DATA COLLECTION AND CAPTURE ................................................................................. 15

5.

6.

4.1

Respondent Contact Strategy and Materials ........................................................................... 16

4.2

Instrument Development ....................................................................................................... 16

4.3

Paper Data Capture ................................................................................................................ 17

4.4

Training .................................................................................................................................. 17

4.5

Case Management and Control System .................................................................................. 18

4.6

Language Support .................................................................................................................. 18

POST-DATA COLLECTION PROCESSING .......................................................................... 19
5.1

Data Integration ..................................................................................................................... 19

5.2

Write-in Response Coding ...................................................................................................... 20

5.3

Edit Input ............................................................................................................................... 21

5.4

Editing, Imputation, and Review ............................................................................................. 22

5.5

Disclosure Avoidance ............................................................................................................. 23

5.6

Weighting and Estimation....................................................................................................... 24

DATA PRODUCTS .......................................................................................................... 24
6.1

Data Products Development................................................................................................... 25

6.2

Data Products Review............................................................................................................. 27

6.3

Data Reasonableness Review.................................................................................................. 27

6.4

Data Products Dissemination.................................................................................................. 28

7.

COMMUNICATIONS ...................................................................................................... 28

8.

IMPLEMENTATION DEPENDENCIES AND CONSTRAINTS ................................................. 28
8.1

County-Level Bridging Factors................................................................................................. 28

8.2

Updated Population Estimates................................................................................................ 29

8.3

Race/Ethnicity Coding Improvement Project........................................................................... 29

8.4

Survey and Enterprise Innovations and Initiatives ................................................................... 30

8.5

2025 Content Changes ........................................................................................................... 30

8.6

Next ACS Content Test ............................................................................................................ 31

8.7

Disability Stakeholder Engagement Activities.......................................................................... 32

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8.8

9.

Sexual Orientation and Gender Identity Content..................................................................... 33

CONCLUSIONS .............................................................................................................. 33

10. REFERENCES ................................................................................................................. 35
Appendix A. Preliminary SPD 15 Implementation Schedule for ACS ...................................... 36

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1. INTRODUCTION
On March 28, 2024, the Office of Management and Budget (OMB) published a set of revisions
to Statistical Policy Directive No. 15 (SPD 15): Standards for Maintaining, Collecting, and
Presenting Federal Data on Race and Ethnicity (OMB, 2024). This is the first revision of SPD 15
since 1997. Once OMB updated SPD 15, the Census Bureau began exploring options for
implementing the new standards in the American Community Survey (ACS). 2 OMB requires an
implementation plan be submitted within 18 months and full implementation by March 29,
2029.
The Census Bureau is responsible for producing the best possible data to provide accurate
information about America’s people, places, and economy. This is particularly important for our
flagship survey, the ACS, which serves as the foundation for federal, state, and local
policymaking. Therefore, we must carefully assess our ability to implement the updated SPD 15
in the ACS while maintaining the data quality standards the public expects.
The race and ethnicity questions are foundational items on the ACS. As foundational items, the
data are used for edits for other topics as well as cross-tabulations in many data tables.
Therefore, it is a complex undertaking to implement changes to how race and ethnicity data are
collected and produced. Adding to this complexity, the post processing for this change will be
done as the Census Bureau is transitioning to a modern platform for data collection using cloudnative software and open-source technologies to process and analyze data.
ACS Program staff and leadership have fully assessed the impact on ACS systems and operations
of implementing SPD 15 in the ACS. The team evaluated the value and priority of the ACS
project portfolio, focusing on major program transformations and the implementation of SPD
15 while taking into consideration regular ongoing ACS production work. This holistic
assessment approach is essential for the ACS to continue achieving its mission while adapting to
change. This report documents the steps needed to comply with the updated SPD 15 for the
ACS survey lifecycle operations and systems. It also discusses competing priorities that impact
resources needed to implement the changes for the ACS.

2. ACS SURVEY LIFECYCLE OVERVIEW
The implementation timeline of SPD 15 was evaluated across the ACS survey lifecycle. The
Census Bureau categorizes survey work into functional areas that comprise the day-to-day

Note that references are made throughout this document to the ACS, but all changes also apply to the Puerto
Rico Community Survey (PRCS).
2

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production and operational work required for a survey like the ACS. Five major components of
the ACS survey lifecycle that are impacted by the revision to SPD 15 are as follows:
1. Frame &
Sample
Design

2. Data
Collection
& Capture

3. Post Data
Collection
Processing

4. Data Products
&
Dissemination

5. Communication

Each component of the survey lifecycle includes many operations and systems that make up the
ACS survey. This document assumes the reader has a basic knowledge of the ACS. For more
information about the design of the American Community Survey and details of the full set of
methods and procedures, see the ACS and PRCS Design & Methodology Report (U.S. Census
Bureau, 2022).
Implementing the updated SPD 15 requires significant changes to data collection, post-data
collection processing, and data product systems. To understand the impact of these changes,
Census Bureau staff held a series of meetings to assess what would need to be done, how it
would be conducted, and the resources needed for the implementation of SPD 15.
•

•

Several meetings were conducted to evaluate each component of the survey lifecycle,
what changes would be needed, the level of effort to make the changes, and when
information would be needed from subject matter experts to implement the change
under various scenarios.
Several all-day meetings were held to review major projects and initiatives to determine
how they align with the strategic vision of the ACS and Census Bureau. Staff assessed
the resource impact and associated risks of implementing SPD 15 concurrent with each
of the top priorities for the program.

This assessment assumes no additional content testing is needed before implementation of the
new combined race/ethnicity question on the survey.

3. FRAME & SAMPLE
The ACS and PRCS each consist of two separate samples: housing unit (HU) addresses and
residents of group quarters (GQ) facilities. We derive the sampling frames from which we draw
these samples from the Census Bureau’s Master Address File (MAF) Frame. The MAF contains
mailing and location address information, geocodes, and other attribute information about
each living quarter. A geocoded address is one for which state, county, census tract, and block
have been identified.
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The updated SPD 15 race and ethnicity standard has no impact on the frame or sample
selection, with one exception noted in the table below.
System/Operation
HU Frame Creation
GQ Frame Creation
Bureau of Prisons GQ Frame Creation
HU Sampling
GQ Sampling

Activities
• No changes needed
• No changes needed
• No changes needed
• No changes needed
• No changes are needed at this time.
Note: Bureau of Prisons sampling would be
impacted when the Bureau of Prisons makes
changes to their race and ethnicity data,
which serves as an input to the sampling.

4. DATA COLLECTION AND CAPTURE
Work in this area includes data capture methods and procedures for paper questionnaires,
training procedures for interviewers, workload management, and language assistance.
The work in Data Collection and Capture is focused on HU and GQ data collection operations.
This includes:
•
•

•
•
•
•

Respondent contact strategies and materials, such as notifications and reminder
approaches
Content development and instrument development and testing for paper
questionnaires, internet data collection, Computer-Assisted Personal Interviewing
(CAPI), Computer-Assisted Telephone Interviewing (CATI), Telephone Questionnaire
Assistance (TQA), Failed Edit Follow-up (FEFU), and Reinterview
Data capture methods and procedures for paper questionnaires
Training procedures for interviewers administering the survey over the phone or in
person, as well as answering questions and conducting follow-up interviews
Workload and response management (control system)
Language support

The implementation of SPD 15 impacts most, but not all, data collection and capture
components. Given prior experience with implementing similar content in the 2016 ACS
Content Test, the implementation of SPD 15 within the data collection and capture systems can
be done with current resources without major risk.

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4.1

Respondent Contact Strategy and Materials

The updated SPD 15 has no impact on the mail contact materials, such as letters and reminders,
or on the letters that interviewers have available to them.
4.2

Instrument Development

Census Bureau staff have decades of experience implementing question changes in the ACS
data collection instruments. Proposed content changes follow a change request process that
includes documentation and committee review along with specification updates, programming,
and testing. Updates to content include both English and Spanish for all modes of data
collection for the HU and GQ instruments.
System/Operation
HU and GQ Paper questionnaire

HU and GQ Internet Instruments

HU and GQ Personal Interview (CAPI
Operation)

Telephone Questionnaire Assistance

Failed-edit Follow-up (FEFU)

Activities
• Question wording changes
• Design new questionnaire
• Print new questionnaires
• Question wording, format, and help text
changes to align with the mode of
administration (i.e., the question is not the
same as paper)
• Specify output variable names and values
• Program instrument changes (HU internet
English, HU internet Spanish, GQ internet
English, GQ internet Spanish)
• Test instruments and verify output
• Question wording, format, and help text
changes to align with the mode of
administration
• Specify output variable names and values
• Program instrument changes (HU CAPI
English and Spanish, GQ CAPI, HU CATI
English and Spanish, and GQ CATI)
• Test instruments and verify output
• Question and help text changes
• Specify output variable names and values
• Test instrument and verify output
• Question and help text changes
• Specify output variable names and values
• Test instrument and verify output
• Develop a variable crosswalk
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System/Operation

4.3

Activities
Note: There is only one FEFU instrument
which is administered based on the date of
data collection. Therefore, for example, a
case in sample in 2026 but that responds in
January of 2027 would be asked the 2027
question version. Implementing this change
requires a crosswalk of variables.

Paper Data Capture

The USPS returns all completed ACS paper questionnaires to the Census Bureau’s National
Processing Center. The paper questionnaires are checked in and sorted by type of
questionnaire. They are then scanned, and the scanned images continue through the data
capture process. The scanning system uses optical mark recognition (OMR) and optical
character recognition (OCR) to capture data from the paper questionnaires. Keyers capture
data that the scanning system was unable to interpret with high confidence. When content of
the questionnaire changes, the scanning system and keying system need to be updated.
System/Operation
Paper Questionnaire Check-in
Scanning System

Keying System

4.4

Activities
• No changes needed
• Update requirements, such as question
placement, variable names, and values
• Program system changes
• Test system and verify output
• Update requirements, such as variable
names, valid values, and keying rules
• Program system changes
• Test system and verify output
• Update training materials and manuals for
keyers
• Train keyers

Training

While training materials will need to be updated, we anticipate those updates can be
completed with current resources without major risk.

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System/Operation

Activities

HU and GQ Personal Interview (CAPI
Operation)
Telephone Questionnaire Assistance

•
•
•
•
•
•

Failed-edit Follow-up
4.5

Update training materials and manuals
Train interviewers
Update training materials and manuals
Train interviewers
Update training materials and manuals
Train interviewers

Case Management and Control System

The ACS case management and control system includes detailed information documenting
operational outcomes for every ACS sample case. It is used to manage the operational flow of
cases through the various data collection phases daily. There are no changes to the control file
needed because of revisions to SPD 15.
Data from each mode of data collection are also processed in this step. Every day data are
received from the various systems used to collect and capture data from respondents in both
HUs and GQs. Changes are needed to the system that receives this data based on the revisions
to SPD 15. A new variable glossary for the race and ethnicity question is required to define new
variable names and ranges of values for each mode of data collection.
The resources and risk regarding system changes is discussed in more detail in sections 5 and 6.
System/Operation
ACS Case Management and Control
System
Daily Processing System

Activities
• No changes Needed
•

•
•
4.6

Requirements and specification updates to
the variable glossary (variable names, range
of values) by mode
Program system changes
Test system changes

Language Support

All revised content in the data collection instruments, help text, and other materials needs to
be translated into Spanish. We anticipate that translation can be completed with current
resources without major risk.
System/Operation
All data collection instruments

Activities
• Translate question text and help text

Training materials and manuals for field
representatives

•
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5. POST-DATA COLLECTION PROCESSING
The collected data undergo several processing steps before they are ready for use in data
products. Data preparation and processing are critical steps in the survey process, particularly
in terms of improving data quality. Developers of large ongoing surveys, such as the ACS,
develop and follow rigorous procedures and rules to guide these processes and ensure they are
done accurately and consistently.
The primary purpose of data preparation and processing is to take the response data gathered
from each survey collection mode to the point where they can be used to produce survey
estimates. Data returning from the field typically arrive in various stages of completion, from a
completed interview with no problems to one with most or all the data items left blank. There
can be inconsistencies within the interviews, such that one response contradicts another. There
may also be multiple interviews returned from the same household. These returns could
contain different answers to the same question.
The implementation of SPD 15 will have significant impacts on the post-processing activities of
the ACS. Many changes will require more time than usual to update requirements, program the
changes, and test the changes. For example, changes to the race and ethnicity questions in the
2020 ACS took over 6 months to program and test, which was only possible because technical
staff utilized work completed previously for the 2020 Census. Several staff will need to
reprioritize other projects to complete this work, putting the deferred work at risk and creating
both work and cost inefficiencies. Technical staff responsible for most of the systems discussed
in this section are also responsible for an ongoing massive transformation of the ACS systems to
implement cloud-based services and open-source software. That transformation is on a
conflicting timeline with the SPD 15 changes due to upcoming decommissioning of server-based
platforms and transition to new data collection systems. More information on these initiatives
can be found in section 8.4.
The risks to post processing by rushing the implementation of SPD 15 are significant. An error
identified after the release of products would involve large and unplanned costs, time delays,
and call in into question research and policies based on flawed data. It could also contribute to
the mistrust of, and reduced confidence in, the Census Bureau.
5.1

Data Integration

In Section 4.5, we discussed changes needed to process data from each mode of data
collection. In this step, daily responses from different modes are “normalized”, collated, and
accumulated, forming Data Collation Process files (DCP files). In this context, “normalized”
means that the data are aligned to form one set of variables and values.

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For race and ethnicity, this involves aligning data across the modes to account for different
administrations of the question. In the paper mode, the race and ethnicity question will be
presented as one question; in automated modes, the question will be “waterfalled” where an
initial question collects the major race and ethnicity categories, and based on selections,
subsequent questions are presented to collect further detail. Additionally, write-in responses
are initially evaluated as blank, do not know, refused, or requiring coding.
System/Operation
Data Collation Process

5.2

Activities
• Update requirements. The same inputs and
requirements from data processing are
needed for data integration.
• Develop a crosswalk to map the data from
the old content to the new content and from
the new content to the old content.
• Update software specifications
• Program system changes
• Test system changes

Write-in Response Coding

The write-in entries from the DCP files are then ready to be coded as part of monthly coding
operations.
The Census Bureau is in the process of conducting its Race/Ethnicity Coding Research Project. A
key component of this project is seeking feedback from the public through an FRN that will be
published in Fall 2024.
Any updates to the code list that result from the Race/Ethnicity Coding Research Project will
require updates to the code list, coding Masterfile, crosswalk, edit specifications, data product
specifications, etc.
System/Operation
Automated Coding System

Activities
• Update requirements (e.g., variable names)
• Update the code list and Masterfile with
results of the Race/Ethnicity Coding
Improvement Project
• Update software specifications
• Program system changes
• Deliver coding Masterfile for production
• Test system changes
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System/Operation
Clerical Coding System

5.3

Activities
• Update requirements and code list like the
automated coding system
• Program system changes
• Test system changes
• Update training materials
• Conduct coder training
• Update workload estimates
• Update staffing plans

Edit Input

Once all response data for the year have been processed, a series of steps are taken to produce
Edit Input Files. These are created by merging operational status information (such as whether
the unit is vacant, occupied, or nonexistent) for each HU and GQ persons within a facility with
the files that include the coded response data. These combined data then undergo several
processing steps before they are ready for use in data products. First, the response type and
number of people in the household unit are assessed to determine inconsistencies. Second, the
return is examined to establish if there are enough data to count the return as complete. Third,
if more than one response is received from a sample address, we assess and select which return
will be used. The third step is called the Primary Selection Algorithm (PSA). Steps one and two
are referred to in the table below as pre-PSA processing.
In general, the edit input processes are less impacted than other processing steps as it
essentially passes the data along, except what we use to determine a sufficient partial and to
assess which form to use if multiple returns are received. In these cases, variables and values
need to be updated.
System/Operation
Pre-PSA Processing

Primary Selection Algorithm (PSA)

Post-PSA File Creation

Activities
• Update requirements with new variable
names and values
• Program system changes
• Test system changes
• Update requirements with new variable
names and values
• Program system changes
• Test system changes
• Update requirements with new variable
names and values
• Program system changes
• Test system changes
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5.4

Editing, Imputation, and Review

The main steps in this process are editing and imputation, generating recoded variables,
reviewing edit results, and creating input files for the next steps.
Editing involves resolving inconsistent data. For example, a person reports a bachelor’s degree
as their highest level of educational attainment, but indicates they are currently enrolled in
High School.
When data are missing, it is standard practice to use a procedure called imputation to fill in
missing responses. Filling in missing data provides a complete dataset, making analysis of the
data both feasible and less complex for users. Imputation can be defined as the placement of
one or more estimated answers into a field of a data record that previously had no data or had
incorrect or implausible data (Groves et al., 2004).
New variables are created during data processing. These recoded variables, or recodes, are
calculated based on the response data. Recoding usually is done to make commonly used, yet
complex, variables user-friendly and to reduce errors that could occur when data users
incorrectly recode their own data. For example, creating a variable to represent people 60 and
over or creating a poverty-status indicator.
After editing and imputation are complete, Census Bureau subject matter analysts review the
resulting data files. Once the subject matter analysts have approved data within the edited files,
and their associated recodes, the files are ready to serve as inputs to the weighting operation
and disclosure review.
For 5-year data, several steps must be applied to the previous years’ final edited data to make
them consistent for multiyear processing. This includes applying updated geography for the
residence address, place of work, and migration data, inflating income data, aligning variables
and values that have had content changes, etc.
In addition to developing new edits for race and ethnicity, 16 other topics on the ACS use race
and ethnicity data in their edit or imputation logic, including Ancestry; Citizenship Status;
Computer and Internet; Employment Status; Fertility; Health Insurance Coverage; Income and
Earnings; Industry, Occupation, and Class of Worker; Journey to Work; Language Used at Home;
Marital Status; Migration; Period of Military Service; Place of Birth; Public Assistance; and
School Enrollment.
System/Operation
Edit and Imputation System for 1-year
Data

Activities
• Updated Requirements and Specifications:
o Variable names and variable recodes
o Develop race and ethnicity edit
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System/Operation

Edit Review Tools

Subject Matter Expert Review for 1-year
Data

Edit and Imputation System for 5-year
Data

Subject Matter Expert Review for 5-year
Data

5.5

Activities
o Update other question edits that utilize
race and ethnicity
o Change hot deck imputation methods
• Program system changes
• Test system changes
• Update variables and edit changes
• Review tool content for many other edits
that use race and ethnicity are impacted
• Update review programs with new variables
and values
• Test the race/ethnicity edit
o Develop a national-level file to use for
initial testing of the updated
race/ethnicity edit
o Conduct subsequent testing using statelevel files for topics other than race
o Additional time for testing the edit is
needed beyond the normal testing period
due to the complexity of the edit
o Testing and finalizing edit specifications
and programs for race and ethnicity must
be done before other subjects’ edits
because there are ripple effects on other
edits and products
• Develop variable crosswalk for race and
ethnicity data
• Program system changes
• Test system changes
• Verify crosswalk of race and ethnicity data

Disclosure Avoidance

The ACS disclosure avoidance methodology is based on the swapping, or interchanging, of a
small percentage of household records between pairs of households in different geographic
areas. The selection process for swapping is highly targeted to affect records with the most
disclosure risk. It is not expected that the changes due to SPD 15 will cause a major change in
the current methodology.

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System/Operation
Disclosure Protection System

5.6

Activities
• Assess disclosure risk using early versions of
the edits
• Update specifications
• Program system changes on both the 1-year
and 5-year data
• Test system changes

Weighting and Estimation

Changes to the weighting and estimation systems do not require a lot of effort but are
dependent on the development of county-level bridging factors (see section 8.1 for more
information) being applied to the population estimates produced by the Population Estimates
Program (see section 8.2 for more information) and to the 5-year microdata.
System/Operation
GQ Person Weighting System
HU Weighting System
Multiyear Estimation System

Activities
• Assess and develop revised methods to
create the population controls for use in the
weighting
• Update specifications to utilize new
population controls
• Program system changes
• Test system changes

6. DATA PRODUCTS
The activities for Data Products and Data Dissemination include the production, review, and
release of the 1-year and 5-year ACS data estimates. ACS data products include the tables,
reports, and files that contain estimates of social, economic, housing, and demographic
characteristics. These products cover geographic areas within the United States and Puerto
Rico.
The actual processing of the data products cannot begin until all response records for a given
year or years are edited and imputed in the data preparation and processing phases, disclosure
avoidance techniques are applied, and the final weights are determined. Using the weights, the
sample data are tabulated for a wide variety of characteristics according to the predetermined
content. These tabulations are done for the geographic areas that have a sample size sufficient
to support statistically reliable estimates, except for 5-year estimates, which are available for all
small geographic areas down to the census tract and block group levels. The Public Use
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Microdata Sample (PUMS) files are also created which provide a microdata file that is a subset
of the full sample data.
After the estimates are produced, Census Bureau subject matter analysts review them for
reasonableness. When the estimates have passed the final review, they are released to the
public. PUMS data files are reviewed in a separate process.
Like the impacts on post-data collection processing, many changes to data products will require
more time than usual to update requirements, program the changes, and test the changes.
Technical staff responsible for data products are also responsible for transforming data product
systems to implement cloud-based services and open-source software.
6.1

Data Products Development

The race and ethnicity changes will impact more than 600 tables, which is over one-third of
existing 1-year or 5-year ACS tables, for Race and Ethnicity and other topics that are crosstabulated by Race and Ethnicity, plus the creation of an unknown number of new tables. These
modifications will comply with OMB guidance on tabulation procedures for SPD 15. In addition
to standard annual ACS tables, multiple ACS special tabulations will be affected such as the
Citizen Voting Age Population (CVAP) by Race and Ethnicity and the Selected Population Tables
and American Indian and Alaska Native Tables (SPT-AIANT).
System/Operation
Detailed Tables

Activities
• Update Specifications
o Variable name and code changes have a
big impact on the specifications. We
need a good test plan to verify all
references are caught, and that there is
internal consistency.
o Detail specs and downstream impacts,
derived products, population groups,
iteration specs, table universes, etc.
o Redefine householder race and ethnicity
(this information feeds into several
products)
o Define new tables for Middle Eastern
and North African (MENA) populations
and update existing tables to combine
race and ethnicity
o Revise universes of existing tables
• Program system changes
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System/Operation

Data Profiles

Comparison Profiles

Geographic Comparison Tables

Narrative Profiles

Ranking Tables

Subject Tables

Selected Population Profiles

Selected Population Tables and American
Indian and Alaska Native Tables

Activities
o The table generator system should not
have to change much but is very
sensitive to what is in the specifications.
• Test system changes
• Specification Updates (see notes above)
• Program system changes
• Test system changes
• Specification Updates (see notes above)
• Program system changes
• Test system changes
• Specification Updates (see notes above)
• Program system changes
• Test system changes
• Specification Updates (see notes above)
• Program system changes
• Test system changes
• Specification Updates (see notes above)
• Program system changes
• Test system changes
• Specification Updates (see notes above)
• Program system changes
• Test system changes
• Specification Updates (see notes above)
• Program system changes
• Test system changes
• Specification Updates (see notes above).
Note that this product is not an annual
product. It is produced typically every 5
years. Based on the changes to content, we
need to determine when this product will be
produced and released next as the current
schedule may not be the best for data users.
• Program system changes
• Test system changes

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System/Operation
Public Use Microdata Sample (PUMS)

6.2

Activities
• Specification Updates (see notes above). We
need to redefine race and ethnicity
categories on the PUMS to include MENA
while still adhering to the disclosure
avoidance requirements.
• Program system changes
• Test system changes

Data Products Review

In data product review, data tables are rendered on a test platform for staff review. Subject
matter experts verify that estimates are produced according to the specifications and displayed
correctly.
System/Operation
Data Review System

6.3

Activities
• Update filtering options for race and
ethnicity tables
• Revise population groups hierarchy
• Program review system changes
• Test review system changes
• Update subject matter expert review
programs

Data Reasonableness Review

In data reasonableness review, subject matter experts review the weighted data to determine
whether estimates are consistent with our base of knowledge about the characteristics being
estimated, that is, are they reasonable over time and within a geographic area when compared
to changes in other estimates.
System/Operation
Reasonableness Review tools

Data Reasonableness Review

Activities
• Create rules for past year processing
• Update system specifications
• Program system changes
• Test system changes
• Update review programs with new variables
and values
• More time is needed for review because of
the complexity (real change due to change in
question vs. change due to processing or
other error)
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6.4

Data Products Dissemination

In this step, staff deliver the final data to the Center for Enterprise Dissemination Services and
Consumer Innovation, stage the data for release, and publish data tables to data.census.gov.
Additionally, updates are made to the ACS website with release notes, updated sample forms
with the new content, and other documentation.
System/Operation

Data Dissemination System

Activities
• Update user notes and links on tables
• Update documentation (sample forms,
subject definitions, comparison guidance,
summary of table changes, code lists, etc.)

7. COMMUNICATIONS
The ACS program depends heavily on engaging stakeholders in the development of the
program and seeking stakeholder input as much as possible in decisions affecting ACS data
products. Typically, consultations with stakeholders begins early in the ACS development
process to gain feedback on the overall approach and identify potential pitfalls and obstacles.
Implementation in 2027 allows the Census Bureau to properly engage with stakeholders to
continue building and maintaining trust.
Staff will conduct their usual outreach associated with the 1-year and 5-year data releases but
also expect that additional content may be developed for the website and additional
presentations may be held to explain the changes in the data products and data itself.

8. IMPLEMENTATION DEPENDENCIES AND CONSTRAINTS
In addition to the activities highlighted above that need to be done to implement SPD 15, other
Census Bureau priorities and projects must be considered in determining the timeline for
implementation.
8.1

County-Level Bridging Factors

When OMB publishes new race and ethnicity data standards, federal agencies require data
bridging guidance to compare race and ethnicity data collected under the new standards with
data collected under the old standards, and vice versa. “Bridging factors” are the proportion of
a race and ethnicity category from one classification scheme that can be assigned to a
corresponding race and ethnicity category in another classification scheme. Counts or estimates
of a race or ethnicity category in one classification can be multiplied by a bridging factor to
calculate a comparable count or estimate of that population in another classification. The
development of race and ethnicity data bridging methodology, enabling the comparison of data
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collected under 2024 SPD 15 with data collected under 1997 SPD 15, is critical for federal
agencies and the public.
An Interagency Technical Working Group (Working Group) of Federal Government career staff
who represent programs that collect or use race and ethnicity data was convened by the Chief
Statistician of the United States. 3 The Working Group’s Bridging Team developed national-level
bridging factors as part of the release of the updated SPD 15. Future iterations of the Working
Group’s bridging factors and programs are expected to be more expansive and flexible, allowing
data users to bridge race and ethnicity distributions separately by state and county, and to
incorporate other stratifying variables. This important work will help to the inform the ACS
implementation of SPD 15.
8.2

Updated Population Estimates

The ACS has historically used ratio estimation to take advantage of independent population
estimates by sex, age, race, and Hispanic origin, and estimates of total HUs produced by the
Population Estimates Program of the Census Bureau. This results in an increase in the precision
of the estimates and corrects for under- or over-coverage by geography and demographic
detail. This method also produces ACS estimates consistent with the population estimates by
these characteristics and the estimates of total HUs for each county in the United States. (For
more information about how population estimates are used see Chapter 11 of the ACS and
PRCS Design and Methodology report.)
Updated population estimates that align with SPD 15 and the combined race/ethnicity data
framework, along with county-level bridging factors, are needed as inputs into the ACS
weighting and estimation process to apply population controls.
8.3

Race/Ethnicity Coding Improvement Project

The Census Bureau is currently undertaking its Race/Ethnicity Coding Improvement Project,
which aims to enhance and improve the code list that was used in the 2020 Census to ensure
that detailed write-in responses to the race and ethnicity question are accurately coded and
tabulated. The ACS uses the same code list as the decennial census for coding and tabulating
data on race and ethnicity.
A critical component of this project is public feedback and stakeholder engagement. In Fall
2024, the Census Bureau plans to publish an FRN seeking public feedback on the proposed race
and ethnicity code list. It is anticipated that there will be a large volume of feedback, which
subject matter experts will need to review, and adjudicate before final decisions on the code list

U.S. Office of Management and Budget Interagency Technical Working Group on Race and Ethnicity Standards.
(2023). spd15revision.gov. Retrieved from: https://spd15revision.gov/content/spd15revision/en/about.html.
3

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are made. Once final decisions are made, updates will need to be made to the code list and
Masterfile used for the coding operation and to data product specifications.
8.4

Survey and Enterprise Innovations and Initiatives

The Census Bureau is transforming and modernizing our approach to creating statistical data
products. Four key innovation areas have been identified to allow us to respond more
effectively to the rapidly evolving needs of the nation. These innovation areas include
transitioning to a modern platform for data collection, using administrative data to replace
survey questions and to develop new data products, modernizing the platform for data
dissemination, and using cloud-native software and open-source technologies to process and
analyze data.
These critical innovations and initiatives require staff to switch all ACS data collection
instruments and associated functions to the Census Bureau’s new data collection system,
transition ACS systems to open-source software (i.e., refactor millions of lines of code), and
move from server-based platforms for data access and transfers to a cloud-based system, all
while continuing to maintain the current survey and innovate on other aspects of the survey
including administrative data use and content testing. These transitions are scheduled to occur
in the next few years and must be completed well before the 2030 Census production
operations.
8.5

2025 Content Changes

The approved content for the 2025 ACS and PRCS reflects the changes to content and
instructions that were recommended because of the 2022 ACS Content Test. The scope of a
content test is to determine question wording, instructions, response categories, and the
underlying constructs to improve the quality of data collected. The 2022 ACS Content Test
results led to recommendations to implement changes for the household roster, educational
attainment, health insurance coverage, and labor force questions. Additionally, three new
questions are being added: sewer, electric vehicle, and solar panels.
Overall, these 2025 content changes impact the ACS data collection instruments but do not
require extensive post-processing or data product changes like the change to the race and
ethnicity question:
• Household Roster: Requires changing instructions on the paper questionnaire but does
not change any downstream activities (variables are not changed); electronic
instruments require questions and pathing changes, but summary outcome variables
are the same and do not require downstream changes. There are no changes to data
products because of this question change.
• Educational Attainment: The revision changes formatting and wording to clarify the
response options. This requires updating instruments and collapsing categories in post30

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•

•

•

8.6

data collection processing. There is no coding for this question. Categories will be
collapsed for data products, which are relatively straightforward to define.
Health Insurance Coverage: Changes to the health insurance coverage question include
a change in formatting of the question that adds an explicit response category for those
who are uninsured, reordering some response options and rewording response options
for some categories. This requires updating instruments and post-data collection
variable updates that are easily mapped to existing categories. There are no changes to
coding procedures. We are still determining what changes are needed for edits and data
products.
Labor Force: Labor force questions related to when the person last worked, the number
of weeks, and the number of hours worked are being updated to clarify instructions to
only include work for pay, to include all jobs a person may hold, and to ensure that
military service is included. There are no changes to variables, post-processing steps, or
data products.
Sewer, Electric Vehicles, and Solar Panels: Requires implementation of new questions
and post-data collection processing that were tested and used in the 2022 ACS Content
Test. These questions have no coding. New edit and data products will be created, but
because there are a limited number of categories for each question (2-3), the data
products are relatively straightforward to define and are small in number.
Next ACS Content Test

Planning for the next ACS Content Test was scheduled to begin in the spring of 2024. However,
based on lessons learned from the 2022 Content Test revisions to the Content Test process
need to be considered before next steps are taken.
The process for altering ACS content is designed to help ensure that any proposed changes are
necessary and will produce quality, useful information for the nation. Adding a question or
making a change to the ACS involves extensive testing, review, and evaluation over a 5-year
period. Over 25 federal agencies participate in this process and make recommendations to the
Interagency Council on Statistical Policy’s Subcommittee on the ACS (ICSP-SACS). An important
step in the process is providing an opportunity for the public to provide feedback. We do this
through publishing a series of FRNs that invite public comments on proposed changes and
methods.
Based on the feedback from the FRN from our last content test related to the recommendation
to change the ACS questions on disability, the Census Bureau will recommend the ICSP-SACS
consider revisions to the protocols to enhance collaboration with data users and other
stakeholders at the beginning of, and during, the ACS content change process. Continued work
on this process change has been paused due to the focus on meeting requirements for SPD 15.
The next steps in ACS Content Test will be delayed until the ICSP-SACS has an opportunity to
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review and provide feedback on the proposed changes and the Census Bureau and OMB agree
on the modifications.
8.7

Disability Stakeholder Engagement Activities

From the FRN on the proposed changes to the 2025 ACS content, the majority of the 12,000
comments expressed concerns with the proposed changes to the disability questions. Based on
this feedback, the Census Bureau has retained the current ACS disability questions for the 2025
ACS. The Census Bureau has been leading a stakeholder engagement effort with the disability
community to address their concerns. The Census Bureau, National Center for Health Statistics
(NCHS), OMB, the Leadership Conference on Civil and Human Rights, the National Council on
Disability, the Consortium of Constituents with Disabilities, and the National Disability Rights
Network held a meeting on September 30, 2024, with federal agency disability stakeholders,
disability community representatives, data users, researchers, and disability advocates. The
purpose of the meeting was to discuss data needs and data uses surrounding the topic of
disability. 4
The OMB has established the Disability Data Interagency Working Group (DDIWG) to inform the
Federal Evidence Agenda to advance disability equity. The DDIWG’s work will inform federal
surveys and administrative collections on how to collect data on disability. The DDIWG is tasked
with identifying the needs for disability data in the Federal Government, identifying resources
that are currently available in the Federal Government on disability data, and identifying gaps in
the data. The DDIWG work will set up priorities for federal agencies. The DDIWG is exploring
what is in scope for the Evidence Agenda, it is reviewing inputs from community engagement,
the DDIWG will explore whether it will define disability and will it define how to measure
disability. The DDIWG will provide recommendations to federal surveys to advance disability
equity. A report is expected by fall of 2024.
A potential Committee on National Statistics (CNSTAT) panel would build on the Federal
Evidence Agenda produced by the Disability Data Interagency Working Group (DDIWG) to
advance disability equity. Using its expert knowledge, a CNSTAT panel would be useful to the
Census Bureau and the Federal Government in continuing the data work outlined by the
DDIWG. Given the data needs and gaps identified by the DDIWG, the panel would provide a
recommendation for the best approach for collecting disability data, whether that’s how to
collect it on existing surveys or proposing new approaches for collecting the data. The panel
would make recommendations for studies to be conducted and future work to continue
development of disability statistics.

See Livestream Meeting With Stakeholders on Disability Data Needs (census.gov) for more information about this
meeting.
4

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8.8

Sexual Orientation and Gender Identity Content

The Census Bureau is seeking approval to conduct the 2024 ACS Sexual Orientation and Gender
Identity (SOGI) Test. The Census Bureau proposes testing questions about sexual orientation
and gender identity to meet the needs of other federal agencies that have expressed interest in
or have identified legal uses for the information, such as enforcing civil rights and equal
employment measures. The information collected in the 2024 ACS SOGI test will be used to
evaluate the quality of data from questions on sexual orientation and gender identity and to
inform recommendations about whether and what questions to implement in production ACS.
Presentations about this test and the next steps have indicated the earliest possible year SOGI
questions could be implemented on the ACS is 2027. This timing accounts for when test results
will be available and when we could get OMB clearance to add the questions to the survey.
Additional assessments are still needed about the impacts to coding, editing, and data
products, especially for sex data which are used as cross-tabulations and as edit inputs for other
topics.
There are no final determinations of the SOGI implementation year. The SOGI implementation
timeline would have to consider other competing survey changes and program priorities, such
as SPD 15 and enterprise innovations (discussed in Section 8.4).
We anticipate that adding new questions on sexual orientation and gender identity will create
new edits and tables. While sex is a foundational item like race and ethnicity, with fewer
categories there are fewer and simpler impacts on edits and data products than the race
changes. It is not clear yet what, if any, impact there will be on the edits.
Additionally, these new question changes are limited to the ACS, while SPD 15 affects all Census
Bureau surveys that collect race and ethnicity data. Therefore, subject matter experts on race
and ethnicity have a more significant demand on resources to update specifications and be
involved in testing systems for a multitude of surveys.

9. CONCLUSIONS
Nearly every step in the ACS survey life cycle, from content development through data product
identification and testing, requires staff to update requirements, specifications, program
changes, and test the changes. The changes are complex, dependent on other projects and
activities, and in some cases need to waterfall from each other. The associated risks to data
quality and heightened errors are of sufficiently grave concern that a deliberate, thoughtful
approach must be followed.

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While prior content testing provides a solid basis for the questions and associated variables for
data collection instruments, additional time and resources are needed to develop the editing,
imputation, and data products for the new combined race/ethnicity question.
Based on our assessment, the Census Bureau plans to implement the updated race and
ethnicity standards into the 2027 American Community Survey data collection cycle.

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10. REFERENCES
Groves, R. M., F. J. Fowler, M. P. Couper, J. M. Lepkowski, E. Singer, and R. Tourangeau, (2004).
Survey Methodology. Hoboken, NJ: John Wiley & Sons, Inc.
Office of Management and Budget (2024). “Updated Statistical Policy Directive No. 15.”
Retrieved June 27, 2024 from https://www.federalregister.gov/documents/2024/03/29/202406469/revisions-to-ombs-statistical-policy-directive-no-15-standards-for-maintainingcollecting-and
U.S. Census Bureau (2022). “American Community Survey and Puerto Rico Community Survey
Design and Methodology (v3.0).” Retrieved June 27, 2024, from
https://www.census.gov/programs-surveys/acs/methodology/design-and-methodology.html

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Appendix A. Preliminary SPD 15 Implementation Schedule for ACS
ACS Process

ACS Operation

Activities

Timeline for
2027
Implementation

n/a

OMB Clearance

Question and Help Text Wording

Summer and
Fall 2025

Data Collection ACS Case
and Capture
Management and
Control System

Requirements

Spring 2026

Specifications, System changes,
Testing, and Production Release

Summer – Fall
2026

Data Collection Language Support
and Capture

Translation for all modes
(question, help text, guides)

Winter 2025 –
Spring 2026

Training materials and manuals
for all modes

Fall 2026

Data Collection HU Mailing
and Capture

Paper questionnaire changes &
printing

Fall 2025 –
Summer 2026

Data Collection HU Internet Data
and Capture
Collection

Instrument changes & testing

Fall 2025 –
Summer 2026

Data Collection Data Capture
and Capture

Requirements

Spring 2026

Paper data capture changes

Summer 2026

Data Collection Failed-edit Follow-up
and Capture

Instrument changes & testing

Fall 2025 –
Summer 2026

Training and manuals
Data Collection HU Personal
and Capture
Interview

Instrument changes & testing

Training and manuals

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Summer –
Winter 2026
Fall 2025 –
Summer 2026
Summer –
Winter 2026

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ACS Process

ACS Operation

Data Collection Telephone
and Capture
Questionnaire
Assistance

Activities

Timeline for
2027
Implementation

Instrument changes & testing

Fall 2025 –
Summer 2026

Training and manuals

Summer –
Winter 2026

Questionnaire and instrument
changes & testing

Fall 2025 –
Summer 2026

Training and manuals

Summer –
Winter 2026

Data Collection GQ Internet Data
and Capture
Collection

Instrument changes & testing

Fall 2025 –
Summer 2026

Post Data
Collection
Processing

Data Integration

Requirements, Specifications,
System changes, and Testing

Summer 2026 –
Spring 2027

Post Data
Collection
Processing

Write-In Response
Coding

Development and revision of the
code list and Masterfile updates,
including public comment

Spring 2024 –
Summer 2026

Post Data
Collection
Processing

Write-In Response
Coding (automated
coding and clerical
coding)

Requirements, Specifications,
System changes, and Testing

Fall 2026 –
Spring 2027

Post Data
Collection
Processing

Edits

Research and develop new race
and ethnicity edits

Spring 2024 –
Fall 2027

Post Data
Collection
Processing

Edit Input

Specifications, system changes &
testing

Fall 2027 –
Spring 2028

Post Data
Collection
Processing

Editing, Allocation,
and Review for 1year Data

Specifications, system changes,
testing, and production
deployment

Summer 2027 –
Summer 2028

Data Collection GQ Paper and CAPI
and Capture
Data Collection

Training and Materials
Development & Coder Training

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ACS Process

ACS Operation

Activities

Timeline for
2027
Implementation

Post Data
Collection
Processing

Disclosure Avoidance

Specifications, System changes,
Testing, and Production
deployment

Fall 2027 –
Spring 2028

Post Data
Collection
Processing

Weighting and
Estimation

Specifications, system changes,
Testing, and production
deployment

Fall 2027 –
Spring 2028

Data Products

Data Reasonableness
Review

Specifications, system changes,
Testing, and production
deployment

1-year: Winter
2027 – Summer
2027
5-year: Winter
2027 – Fall
2027

Data Products

Data Product
Development

Research and develop new data
products

Winter 2026 –
Winter 2027

Data Products

Data Products
Development
[Standard Data
Products & PUMS]

Specifications, System changes,
and Testing

Summer 2027 –
Spring 2028

Data Products

Data Products
Review [Standard
Data Products]

Production data products review

1-year: Spring
2028 – Summer
2028
5-year: Summer
2028 – Winter
2028

Data Products

Data Products
Dissemination
[Standard Data
Products & PUMS]

Dissemination of products and
update of website
documentation

38

1-year: Spring
2028 –Fall 2028
5-year: Fall
2028 – Winter
2029

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39