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"The Limitations of Directive 15"

January/February 1995 issue of Poverty & Race

The development ofOM B Statistical Policy Directive 15, "Race and Ethnic Standards for Federal Agencies and Administrative Reporting," is grounded in the United States' historical and continuing differential treatment of selected populations. The directive represents the most current attempt to better classify racial and ethnic minority groups vis-a-vis a white majority group. It is not an absolute or final standard, and thus is subject to change.

Racial and ethnic categories have been used in the United States to distinguish groups in relation to a white majority. This differential treatment has been used both for exclusion and inclusion. Historically, these categories were used to denote a different civil status for persons who were not mem-hers of the initial settlers of this nation. Broad groups of people, including native tribes, slaves from Africa, residents of Spanish America, Southern Europeans and Asians were excluded from becoming full citizens. For example, a three-way racial classification was embedded in the first Census of 1790, which identified whites, American Indians and slaves. For apportionment purposes. a slave was counted as three-fifths of a white person. American Indians who were not taxed were not included in the count.

Since World War II, with the broad enactment of civil rights statutes, racial and ethnic data have been used to monitor discrimination against minorities and to support their inclusion and full citizenship participation. In general, civil rights laws do not specify individual racial and ethnic groups but rather forbid discrimination on the basis of race, color or national origin. In the enforcement of such laws, however, racial and ethnic grotips are classifled and minority groups designated.

Minority group status has been most associated with the black population. For over 200 years, the United States has been described as a black and white society, with a white majority and black minority. Minority group status is also identified with American Indians, particularly with tribes that maintain legal relationships with the federal government. With statehood, the minority group status of Aleuts and Eskimos in Alaska and Hawaiians in Hawaii has become prominent. These groups represent resident populations which predated American settlers. The minority group status of Asians is more recent due to their historically fewer numbers, concentration in the West, and a perception that they are new settlers. The latter view is reinforced with continuing immigration from Asian countries. Hispanics as a minority group are both distinct from and similar to the above racial groups. Hispanics are a multi-racial group, with European, African and Indian origins. In the Southwest, a Hispanic presence dates back to Spanish America, giving Hispanics a residential status similar to American Indians. Like Asians, they also include new settlers, with steady immigration from Mexico and Latin America. Finally, despite European origins, their historical treatment of being less-than-equal to whites is similar to the treatment of blacks.

Given this history, it was appropriate that in formulating Directive 15 in the 1970s, federal agencies directed special attention to the black. Latino, American Indian, Alaskan Native and Asian Pacific populations. Disparities between these groups and the white population were documented in the 1960 and 1970 Censuses and the 1976 Survey of Income and Education. These disparities were in large part due to earlier policies of limited or total exclusion in various areas such as citizenship, property rights and immigration. The civil rights compliance purposes of these categories have been paramount.

Both civil rights laws and Directive 15 have potentially wide and flexible coverage in their present forms. Protected groups are not necessarily limited to historically disadvantaged racial and ethnic minorities. Rather, they can include other groups that assume a national policy importance: for example, new refugees. Similarly, although Directive 15 does specify groups, the four racial categories and the Hispanic category are defined as minimum categories. Data on subgroups can be collected and reported as long as they can be aggregated for federal reporting purposes to the minimum categories. Additionally, exceptions to these categories can be obtained from 0MB. The Census Bureau has requested and been granted use of an "Other" category for the 1980 and 1990 Census. Finallt the directive does not preclude the use of other categories for non-federal reporting.

From a historical perspective, the current categories are relatively new and have been in use for less than two decades. Implementation of these categories has surfaced both the significance and limitations of this classification system. For the most part. these categories have been adhered to for a variety of data collection activities at the federal, state and local levels and in the public and private sectors. They have been useful in documenting the growth of minority populations. When Directive 15 was promulgated. racial and ethnic minorities were a stable but small proportion of the American population. Between 1970 and 1990, however, they increased from about one-eighth to one-fourth of the total population. They will continue to grow and diversify for the foreseeable future.

During this period, the limitations of Directive 15, on several levels, have become more visible. One entails the terminology of existing groups to reflect contemporary usage, such as "African American" for "black." While these terms are not conceptually synonymous and point out the ambiguity and fluidity of labels, such changes do not threaten the existine standards. A second limitation is the inclusion of particular groups in a category. The most prominent example is the reclassification of Pacific Islanders from an Asian and Pacific Islander catecory to one with American Indians and Alaskan Natives. On the one hand. Pacific Islanders, particularly Hawaiians, share an indigenous status with American Indians and Alaskan Natives and specific relationships with the federal government. On the other hand, an Asian and Pacific Islander category reflects a popular geographic usage referring to an Asia Pacific region. These types of limitations are not insurmountable.

A more challenging limitation of this policy is whether the current categories are exhaustive. Any new category undermines the extant classification, for it entails the addition of new groups that may not only not self-identify with the current categories but may not self-identify as a minority group. Critics contend that a new category would also diminish the number of existing groups. Nonetheless, the experience of the decennial Census with the "Other" race category is not encouraging of new groups. While the numbers of the American population reporting in this category increased between 1970 and 1990 (from less than one million to almost ten million), over 95% of per-sons reporting in the Other race category in 1990 were Hispanic. In addition, despite the general perception of a sizable multiracial population, about 253,000, or only 1/10 of 1% in the 1990 Census, provided multiple race responses. In the past, federal statistical systems (notably, those of the Census Bureau and the National Center for Health Statistics) have generally classified persons of mixed backgrounds as non-white and, more recently, in terms of a mother's race, rather than as a separate category. (When both parents were nonwhite, however, children were assigned the father's race; except if either parent was Hawaiian, the children were designated Hawaiian.)

Another limitation is whether the Hispanic origin category can continue to hold a preferential status. In distinguishing Hispanic origin as a separate ethnic category, Directive 15 set a precedent that selected ethnicity as primary over racial identity. Specifically, when a combination of race and ethnicity is used, Hispanics who are Black or White are excluded from the Black and White categories and counted under Hispanic. While Hispanics can be of any race, the white population in the last two decades has evolved to be defined as non-Hispanic.

Perhaps the most challenging limitation of this directive is whether such a policy has outlived its utility. In the current debate to revise Directive 15, the focus has shifted from measuring the disparities between majority and minority groups to highlighting benefits and entitlement of minority status. Such a shift may lead to the conclusion that disparities are minimal or no longer exist between the majority group and minority groups, despite evidence that both continuation and reduction of disparities exist. With emphasis on the latter, the monitoring of disparity and subsequent action to remedy disparities would no longer be primarv policy, objectives.

An equally popular reason for the utdatedness of this directive is that it does not reflect the groups with which individuals identify. New immigrants, for example, identify primarily with their nationality rather than race or ethnicity. For other individuals, race or ethnicity is not primary to their identification and thus assumes an optional status. Furthermore, in a heterogeneous society, persons can have a multiplicity of identities, shaped not only by official categories but by the individual's self-identification and definitions of a particular racial or ethnic community. the media and other groups.

In summary, race continues to be a major organizing principle in the United States. It is used as a basic demographic variable in defining the American population. Its origin, however, is as a legal status defining a majority and a minority. The intersection of demography and policy forces us to raise the question, "Do racial and ethnic categories matter?" An initial answer is, "It depends." For the racial and ethnic minority groups identified in 0MB Statistical Directive 15, it is clear that racial and ethnic categories continue to matter in tracking their political inclusion and access to resources. For other groups, however, it is less clear that racial and ethnic categories per se matter or that the official federal categories defined in Statistical Directive 15 are the only ones that matter.

It is clear that, for the whole nation, racial and ethnic categories will continue to matter as long as Directive 15's purpose is to provide racial and ethnic data to support policies of inclusion, including policies related to disadvantage and disenmination as stated in legislative and program requirements. To continue to be effective, Directive 15 must reconcile the historic need for differential attention to selected groups with the reality of greater interaction among existing categories and the probability of new' racial/ethnic categories.
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