4.1 Issue # 1óRe-identification of an Individual's Race and Ethnicity
- Though not mandated, the Final Guidance encourages agencies to give all students (or their parents/guardians) and staff members the opportunity to re-identify their race and ethnicity according to the new categories. Such a process is beneficial for states and school districts, because:
- On the personal level, it provides students and staff of multiracial backgrounds the opportunity to express their races and ethnicity, and allows students or staff who previously identified themselves as “Asian or Pacific Islander” to select either “Asian” or “Native Hawaiian or Other Pacific Islander”; and
- On the institutional level, it promotes data consistency and comparability within schools, districts, and states.
- Resistance to change is to be expected when it involves a great number of respondents, staff time and resources are limited, or if there is distrust of the state or the federal government's reason for these changes. Resistance can come from small or large schools, or from traditional public schools or charter schools. It is important for district- and school-level personnel to understand and buy into the data changes. Making the case (see chapter 1) contributes to success at this introductory stage.
- Besides the mandated requirements, states should explain to districts and schools the benefits of these changes for the populations they serve, such as finally allowing multiracial individuals full recognition of their heritage, and identifying Hawaiian Natives and Other Pacific Islanders as a distinct group sharing a common heritage. Be sure that district- and school-level staff understand that the new categories are required for new enrollees, and that data systems must be using new categories by 2010. Changes are inevitable, and state staff members are there to help districts make the transition as smoothly as possible.
- There may be resistance from some parents (such as undocumented immigrants) who refuse to provide the information out of fear of authority, or of being stigmatized. Be ready to explain to respondents the difference between the new and old race and ethnicity categories. It is also vital to explain that although these categories are required by the federal government, only aggregate racial and ethnic data are reported.5 Race and ethnicity data are not considered “directory information” under FERPA. School districts should offer reassurance by referring to the protection of individually identifiable information under FERPA, and indicate that student and staff information is sent to the Federal government in ways that ensure no individual is identifiable. See Sample Letters to Parents and Staff Members included in chapter 3.
- The Final Guidance specifies how the race and ethnicity question should be presented, but does not mandate how an individual should answer the question. For example, some individuals may answer by the race and ethnicity with which they mostly comfortably identify, while others may answer based on their ancestry. The important issue is that the two-part question is being asked consistently across the state, district, and schools.
- States may establish guidance for school districts regarding the scheduling and process for implementing the re-identification. This is done most easily during the enrollment period for new students and at the beginning of the school year for returning students. Staggering data collection throughout the year would be more difficult to manage. Large and diversely populated school districts may choose to re-survey every year, while others might conduct a one-time survey, asking students or staff members to respond by a certain date to change their race and ethnicity on record. If the second approach is used, it is recommended that a notice be sent to parents or staff members to allow re-identification. (See sample letters in exhibit 3.1.) New forms could be designed to just ask the two questions on race and ethnicity, or forms preloaded with existing data could be sent to students or staff members for verification and change if applicable. Either way, a specific date should be included by which the students or staff members are asked to return the information. Indicate that current data will be used, or race and ethnicity will be assigned, if new information is not received. Allow students or staff members to check their record if they do not remember what race and ethnicity codes they had selected previously. Included later in this chapter is a case study of current difficulties in identifying the race and ethnicity of students and staff. State leadership in providing resources would contribute to the success of the process.
- The actual re-identification may be accomplished in different ways. Some districts have students fill out forms in their home rooms, while others mail out either a request for information or a verification of pre-loaded information requiring a parent's signature or entry on a web-based process. However, since the Final Guidance indicates that the selection of a student's race and ethnicity is primarily made by parents or guardians (see chapter 4.3), it is preferable to send the form to parents, asking them to identify the student's race and ethnicity, and then to sign and return the form. If a school district traditionally obtains data more quickly and accurately from high school students than from their parents, it would be preferable to ask students to provide this information themselves.
- To re-identify staff members' race and ethnicity, it is important to reiterate that this information is not a condition of employment. The federal rules and regulations on equal employment compliance have not changed.
5 ED research or statistical studies that collect information from individual students or staff members do not collect data in a way that permits the identification of individual respondents.