Comment Regarding Proposed Updates to OMB's Statistical Standards

April 11, 2023

NADOHE submitted the following comment to the Federal Register regarding proposed changes to the Office of Management and Budget's race and ethnicity statistical standards.

Dear Chair Sivinski,

As the National Association of Diversity Officers in Higher Education (NADOHE), we represent diversity officers across higher education who implement and manage the critical work of advancing inclusion and equity. We support the Office of Management and Budget’s work to modernize the race/ethnicity categories in federal records, which have not been updated since 1997, as higher education institutions need to be able to accurately understand, report on, and benchmark our rapidly changing populations.

Collecting accurate, actionable data is deeply important to our work to understand how campuses can better support students as they pursue their educational goals. We support the inclusivity of the new proposed standards, including the removal of outdated terminology and the addition of additional reporting categories such as “Middle Eastern or North African.” In particular, we support the removal of the Hispanic “trumping rule” that has suppressed data regarding the race of Hispanic/Latino/a/x people. We also encourage more regular examination of these reporting standards to ensure they accurately reflect evolving populations.

We applaud the Working Group’s governing principles, particularly the goal of respecting individuals and the ways in which they self-identify. People should be able to describe themselves intersectionally; how we self-identify strikes at the core of who we are as individuals. Any data collection on race and ethnicity requires great care and respect for individuals and their dignity.

Respectfully submitted,

Paulette Granberry Russell, J.D. 
President, NADOHE