Data Collection without Definitions

The Office of Management and Budget's Statistical Directive No. 15, first issued in 1977 and revised in 1997 and again in March 2024, sets minimum standards for federal government collection and reporting of data by race and ethnicity. We find that Directive 15 does accomplish its intended purpose of promoting data comparability and sharing across the government and beyond. Despite these benefits, the Directive is regularly the subject of criticism, particularly with regard to the definitions it provides for each of the seven racial and ethnic categories at its center. In this paper, we analyze a novel proposal: dispense with the definitions altogether. We describe problems with the definitions, including that they have internal flaws (e.g., they contain circular logic, are inconsistent, and lack comprehensiveness), they conflate race with related concepts such as ancestry and nationality, and they inappropriately constrain the identity choices of individuals and groups. We find the proposed change to be narrowly tailored and pragmatic; it would immediately resolve problems with the definitions, increase data comparability across time, and increase flexibility provided under Directive 15.