Comment from Megan Hicks

I am submitting this comment as a social work researcher, educator, and faculty member who conducts community-engaged research focused on racial equity, health disparities, and improving outcomes for marginalized communities. My research depends on the ability to collect, analyze, and interpret high-quality demographic data in ways that accurately represent the lived experiences of the communities we serve. I am concerned that aspects of the revised Statistical Policy Directive No. 15 (SPD 15) may create unintended consequences for researchers, educators, and communities whose experiences are shaped by complex racial and ethnic identities and systems of inequity. I appreciate the goal of improving federal data collection and creating standards that better reflect the diversity of the United States. However, I have concerns about the implementation of several sections of the revised SPD 15, particularly the changes related to the collection and reporting of race and ethnicity data, including the requirement for a combined race and ethnicity question and changes to minimum reporting categories. As a social work researcher, I study populations where race and ethnicity are not simply demographic characteristics but critical factors connected to social conditions, structural inequities, access to resources, and health and behavioral outcomes. My current research includes federally funded projects examining racial equity and health-related outcomes among Black youth, including work supported by the National Institutes of Health and the Centers for Disease Control and Prevention. In this work, accurate and appropriately detailed demographic data are essential for understanding community experiences, identifying disparities, and developing interventions that address inequities. The way race and ethnicity data are collected directly influences our ability to identify disparities, evaluate interventions, and develop evidence-based programs. Changes to data collection systems must be carefully considered to ensure that historically marginalized groups are not unintentionally made less visible in research and evaluation. The revised SPD 15 sections related to collecting race and ethnicity information using a single combined question raise concerns for my research practice. While allowing individuals to select multiple identities may improve representation for some groups, the way data are aggregated and analyzed has important implications. In social work research, particularly research focused on racial inequities, broad aggregation can obscure meaningful differences between groups and may limit our ability to identify specific disparities or understand unique community experiences. For example, my research focuses on understanding the experiences and needs of Black youth and communities. Accurate racial and ethnic data are essential for examining how social environments, systemic inequities, and community-level factors influence outcomes. If data structures make it more difficult to identify specific populations experiencing disparities, researchers may lose the ability to document inequities and develop targeted solutions. I am also concerned about the implications for social work education. As faculty members, we prepare future social workers to use research evidence, evaluate programs, and advocate for communities. Students must learn how demographic data are collected and interpreted because these decisions influence policy, practice, and service delivery. Changes to federal standards should include clear guidance and resources to ensure researchers, educators, and practitioners understand how to maintain data quality while preserving the ability to analyze inequities. I recommend that OMB consider additional guidance addressing: 1. How researchers should analyze race and ethnicity data while preserving the ability to identify disparities affecting specific communities. 2. How federal agencies can prevent the unintended masking or aggregation of historically marginalized populations. 3. How community-engaged researchers and social scientists can be involved in ongoing evaluation of these standards. 4. How implementation guidance can support researchers working with populations experiencing structural inequities. Race and ethnicity data are foundational to social work research, practice, and policy advocacy. The quality of this data affects our ability to understand communities, evaluate interventions, and ensure resources reach those who need them most. I encourage OMB to continue refining these standards with attention to the needs of researchers, educators, and communities who rely on accurate demographic data to advance equity. Thank you for considering this comment.