Dear USET/USET SPF Family,
On March 29, 2024, the Office of Management and Budget (OMB) published a Notice of Decision in the Federal Register regarding revisions to its, “Statistical Policy Directive No. 15: Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity” (SPD No. 15). SPD No. 15 was last revised in 1997 and is a data standard for federal agencies to collect, maintain, and present data on “race and ethnicity” in areas such as the decennial Census, household surveys, and federal administrative forms. In 2022, OMB established a Federal Interagency Technical Working Group on Race and Ethnicity Standards (Working Group) to provide an initial set of proposed revisions to SPD No. 15. On February 14, 2023, OMB issued at Dear Tribal Leader Letter announcing a Tribal consultation on initial proposals from the Working Group to revise SPD No. 15, which included revising “race and ethnicity” questions regarding the American Indian/Alaska Native (AI/AN) category (interchangeably referred to as ‘category’ or ‘definition’).
Following the February 2023 Tribal consultation and comments received on revising SPD No. 15, the Working Group’s final recommendations to OMB included the following revisions to SPD No. 15’s terminology, definitions, and wording—
- Removal of language stating, “who maintain tribal affiliation or community attachment”, from the American Indian/Alaska Native’(AI/AN) category; and
- Changing the AI/AN definition be to, “the category `American Indian or Alaska Native' includes all individuals who identify with any of the original peoples of North, Central, and South America.”
- Under the 1997 SPD No. 15 definition, the AI/AN category is defined as a “person having origins in any of the original peoples of North and South America (including Central America), and who maintains Tribal affiliation or community attachment.”
OMB stated that comments received generally supported the proposal to remove the language, “who maintains tribal affiliation or community attachment”, from the AI/AN definition and, therefore, agreed to removing this language from the SPD No. 15 AI/AN definition. OMB’s Notice of Decision also adopted the change of, “(including Central America)” to having “Central America” listed co-equally with North and South America in the AI/AN definition.
On April 27, 2023, USET SPF submitted comments
to OMB following its February 2023 Tribal consultation and emphasized to OMB that Tribal Nations and our citizens have an inherent political status. Therefore, we should not be categorized and combined with various “racial” or “ethnic” initiatives that do not recognize or acknowledge this inherent political status and identity. We reminded OMB that the federal government has an obligation to ensure federal data collection efforts are accurately and meaningfully collecting AI/AN population data to measure who is eligible for federal programs and services delivered in fulfillment of trust and treaty obligations. USET SPF also voiced concerns with proposed revisions to SPD No. 15 regarding the definition of AI/AN and its potential to inform and affect funding formulas and allocations for Tribal-specific and other federal programs and services that Tribal Nations and Native people are eligible to access. USET SPF recommended further Tribal consultation on this issue and the establishment of a Tribal Advisory Group to provide direct input on revising the AI/AN definition. Although OMB’s Notice of Decision removed the language, “who maintains tribal affiliation or community attachment”, from the AI/AN definition—which we supported—it is still tied to SPD No. 15 questions related to “race and ethnicity”, which does not recognize the unique legal and political status of Tribal Nations and our citizens. OMB has stated its intention to consult further on this issue and USET SPF will continue to reiterate these concerns regarding federal data collection efforts.
For more information, please contact Brian Howard, USET SPF Senior Policy Analyst, at bhoward@usetinc.org.
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