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Managing an Identity Crisis: Forum Guide to Implementing New Federal Race and Ethnicity Categories
NFES 2008-802
October 2008

2.1 Policy and Procedure Development

The scope of policy and procedure development should at least include the following tasks:

  • Clearly identify applicable state laws that authorize the collection of race and ethnicity data.
  • Analyze current race and ethnicity categories collected in the state.
  • Develop a set of codes.
  • Identify the data systems that need to be included in the re-identification process.
  • Identify changes that need to be made in technology/software.
  • Estimate the cost.
  • Establish timelines and calendar.
  • Develop standards for re-identification of individual data.
  • Develop communication tools.

Within states, the SEAs will be the lead organizations in developing policy and procedures to guide the change to new race and ethnicity categories. The SEA must be knowledgeable about the required changes in racial and ethnic data collecting and reporting. However, while broad guidelines should be established at the state level, it is recommended that policies and procedures be developed collaboratively with input from districts and schools. This would mean involving such key players as district-level staff who are responsible for reporting the racial and ethnic data; representatives from the technology areas (in-house staff and vendors); representatives from schools who would be asked to determine and record the race and ethnicity of students; and school- or district-level staff who are responsible for entering the data.

Each state must anticipate possible issues facing the implementation process. These issues can include the size of the agency, the number and size of districts, the diversity of student and staff populations, the political environment, beliefs about the value and uses of data, current data collection schedules, and the ever-present question of state versus local control. This list is not exhaustive. Recognize that there will be questions, and possibly resistance, as changes are introduced.

The following paragraphs address each of these tasks and recommend broad guidelines for establishing applicable policies and procedures. There is additional information in subsequent parts of this guide.

  • Clearly identify applicable state laws that authorize the collection of racial and ethnic data. Determine what laws or State Board policies apply, and develop a succinct but authoritative statement. For example, the Massachusetts Department of Elementary and Secondary Education, which adopted the new race and ethnicity standards several years ago, answered this frequently asked question by stating, “Pursuant to Massachusetts General Laws, Chapter 69, Section 1I, the Department is authorized to collect race/ethnicity data but cannot make such information public. The Department will report these data only in the aggregate.” If more arguments for the change are needed, chapter 1 of this guide discusses federal reporting requirements and educational benefits of more precise data. (Documented later in this chapter are case studies of the collaborative efforts between the state education agency and a school district in Massachusetts in changing the race and ethnicity data collections.)
  • Analyze current race and ethnicity categories collected in the state. These may be more numerous than the federally required set; for example, some districts may further disaggregate the category of Asian into Chinese, Japanese, Korean, and others. The work required to implement the new federal standards may vary from state to state. States can evaluate the impact of changes only after they look at their current data sets. For individual student or staff data, many states collect more categories than the original race and ethnicity categories previously established by federal standards. These may come in the form of additional racial categories on the collection form or as an option to provide additional information (e.g., write-in) about an individual's ancestry.
  • Develop a set of codes. If the categories used by the state or its districts can be cross-walked into one of the more than 60 possible combinations for individual data, no changes may be needed. (See exhibit 5.1 for the possible combinations of the five race and Hispanic/Latino ethnicity categories). However, if there is a statewide student data system, the state may want to make sure all variations can be collapsed into a set of race and ethnicity categories to be used consistently within the state. Also, it must be possible to aggregate both state- and district-adopted categories into the seven categories required for reporting aggregated data to ED. Chapter 4 of this guide provides several coding scheme suggestions, as well as examples of some states' coding structures. In addition, states need to determine whether they would collect granular data from their districts or just the seven aggregate reporting categories as required for federal reporting.
  • Identify the data systems to be included in the re-identification process, and include the data stewards of all of these systems in the process. EEOC began collecting staff data using the new categories in September 2007 with its EEOC-1 report. Therefore, while ED does not collect race and ethnicity data about staff from SEAs, it makes sense that human resources and licensing/certification data should be considered as part of the overall implementation effort. In some states, staff data may not be maintained at the school district level, and there may be multiple state systems (licensure, employment, retirement, etc.) for personnel information. Many school districts do not have their own human resources department, or must draw from several sources where payroll and scheduling information are kept. Many districts may need to retrieve such information from state licensure/certification databases.

A state or local agency should identify all the subsystems that may contain an individual's racial and ethnic information, for example:

  • Student records
  • Central registration file
  • Special education data
  • Assessment data
  • Title I data
  • English Language Learners data
  • Transportation data
  • Career and Technical Education data
  • Charter schools registration and records
  • Free-and-reduced price lunch data
  • Migrant education data
  • Gifted and talented data
  • Discipline data
  • Distance education data
  • Human resources file
  • Retirement file
  • State certification and licensure information

Depending on a state's or local agency's size and the centralization of its data, it may make sense to prioritize certain data sets or collections. Agencies maintaining several subsystems that are not completely interoperable could consider prioritizing the implementation and adopt a “point-of-truth” system.

  • Identify required technical changes. Software systems for collecting, managing, and reporting data will need to be updated. This includes work to be conducted by in-house staff and by vendors. Involve these personnel early, preferably as key decisions are being made about categories and coding requirements. Normally it takes up to a year to implement the changes, test-run data, and check for quality and validity. The more time that is available to vendors who support states and districts, the better the control over the implementation cost.
  • Estimate cost of changes and secure agency support. The Federal Register notice about the new standards estimated that 25 million person-hours would be needed to complete implementation in all of the states. However, each state should estimate its own costs for changing to the new race and ethnicity standards because the starting point varies from state to state. These cost estimates should take into consideration the staff hours needed for policy development, training and professional development, system and program changes by in-house staff and vendors, and the re-inventory of data.
  • Establish timelines and calendars that realistically reflect the state's data collection and reporting processes. Timing is key to success. Work should proceed steadily once it is begun, building momentum while allowing ample time for all involved to implement the changes. Policy development typically takes about 6 months to 1 year, and vendors will need up to 1 year of lead time to create new products. The Implementation Timeline in Exhibit 1.2 sets out a probable series of events with time estimates that are keyed to the school year calendar. This is not a rigid schedule, but it does show how key components of the implementation process are related to one another.
  • ED's Final Guidance specifies that educational institutions must report data in the new categories by fall of 2010 for the 2010–11 school year. Now is the time to begin changing data systems! Some states, such as Massachusetts, began the process at the state level in 2004, anticipating the changes that would be required. Massachusetts began introducing the changes to the state's districts in 2005, when state staff included the topic at their annual staff trainings. (See Case Study later in this chapter.)

  • Develop data specifications and guidelines for re-identification of individuals' race and ethnicity. These guidelines and data specifications should enable district and school staff to understand how to implement their own policies and procedures about re-identification and data entry. Guidelines cover such things as establishing the timing and mechanism for communicating with parents about collecting new data, the follow-up procedures for missing data, and procedures for observing a student's race and ethnicity if parents refuse to provide that information. Chapter 4 of this guide includes recommendations for the data collection process.
  • Develop communication tools. These would include fact sheets, presentation slides, and/or hotlines to answer frequently asked questions and establish a mechanism that allows state staff to answer questions directly and consistently. Chapter 3 of this guide addresses the area in further detail.

As in any new initiative, building support from all levels of stakeholders is vital to the success of the process. Everyone in the education community from a teacher in a classroom, the front-line secretary at the principal's office, and district staff managing special programs, to state legislators debating the policies has a stake in getting and using quality data. (The Forum Guide to Building a Culture of Quality Data provides general guidelines for cultivating an environment of quality data.) All of the parties involved need to be convinced of the value of making changes towards developing and maintaining a successful culture of quality data.

question point What Do the New Standards Mean to School Districts?
  • Policy and procedure development begins at the state level, but it won't work without the close collaboration of districts and schools.
  • Identifying a key person (or office) in charge of the change is crucial at the district level. In addition to collaborating with the state, this person/office could be in charge of conducting an inventory of existing data to identify the data sets that need to be updated with the new racial and ethnicity data; and responsible for collaborating with state officials regarding policies and procedures development.
  • Vendors must understand that this change will affect all state and local data systems, not just one or two districts. Data systems will need to accurately capture the two-part race and ethnicity question from coding to recording and reporting. Local considerations, such as the capacity of the systems and reporting schedule, are taken into account in such changes.
  • Districts should emphasize to their vendors that this is a state-mandated reporting change and should, in most cases, be covered under their software support contract. Districts should insist that vendor changes to data entry screens will facilitate accurate data entry.
  • While the state can establish statewide policies, it is important for districts to set policies and procedures regarding the re-identification of individuals. See chapters 3 and 4 of this guide.