|DATE:||April 7, 2004|
|SUBJECT:||Final WIC Policy Memorandum Fiscal Year 2002-6, Revision 1 WIC Racial/Ethnic Data Collection|
Supplemental Food Programs
This policy memorandum provides guidance to state and local agencies on the WIC Racial/Ethnic Data Collection. It includes 1) the revised WIC program racial and ethnic data categories, and 2) the reporting requirements for the data categories set forth by the Office of Management and Budget (OMB).
On Oct. 30, 1997, OMB issued a Notice in the Federal Register advising of revisions to the Statistical Policy Directive No. 15, Race and Ethnic Standards for Federal Statistics and Administrative Reporting. The new standards were developed by OMB in order to monitor enforcement of civil rights laws for populations that historically experienced discrimination and differential treatment in housing, education, employment and other areas because of their race or ethnicity. These new standards were developed to ensure uniformity and comparability in the collection and use of data on race and ethnicity by federal agencies. Federal agencies are required to issue new racial/ethnic data system and collection procedures by Jan. 31, 2003.
Under the new standards, OMB requires data collection on ethnicity as well as racial categories. The two ethnic categories required by OMB are “Hispanic or Latino” and “Not Hispanic or Latino”. Only one category can be selected. The five racial categories required by OMB are: 1) American Indian or Alaska Native, 2) Asian, 3) Black or African American, 4) Native Hawaiian or Other Pacific Islander and 5) White. One or more racial categories may be selected. The OMB definitions for racial and ethnic categories are listed in Attachment I.
Federal agencies, not state agencies, are required to compile information on any multiple race combinations that represent one percent or more of the population served by the jurisdiction (state agency).
Impact on State Agencies
The new OMB standards will change the racial and ethnic data collected at the time of application for individuals determined eligible to participate in the WIC Program. Therefore, these changes will result in modifications to state agencies’ data collection instruments and/or management information systems. State agencies have flexibility to determine the format for collection of this data. Attachment II illustrates the minimum information that must be collected to capture the racial and ethnic data.
Self-identification by the participant at the time of certification is the preferred method of obtaining data. Participants must be asked to self-identify their racial and ethnic categories, but only after it has been explained and they understand that the collection of this information is to produce data on characteristics of populations served, and to monitor compliance with Federal civil rights laws. Participants should also be informed that this data collection has no effect on the determination of their eligibility to participate in the WIC Program.
OMB requires that when the participant does not provide racial and ethnic information, the staff shall obtain the information through observation and record it as observed. If a participant chooses not to self-identify her/his racial and/or ethnic group, visual identification by a program staff member must be used to determine the participant’s racial and ethnic categories. Selection of one race is acceptable when local agency staff performs visual identification.
The new standards will also change the compilation of data for transmittal to the Food and Nutrition Service (FNS) contractor for the WIC Participant and Program Characteristics (PC) report. FNS will work with its contractor to produce the information for multiple race categories for individuals who mark more than one race. Soon after the issuance of this policy memorandum, FNS will issue the Minimum Data Set Specifications, including data codes for racial and ethnic data, to provide guidance on the compilation of data for transmittal to FNS contractors for the PC report.
No later than April 1, 2005, state agencies must begin collecting racial and ethnic data from participants at certification using the new OMB racial and ethnic categories. This allows state agencies to report data for the PC 2004 report under the previous racial/ethnic data categories before system changes are implemented to reflect the new categories for race and ethnicity.
By April 1, 2006, the PC report will reflect the new racial and ethnic data categories collected by FNS for all state agencies.
However, if state agencies implement the new racial/ethnic categories before April 1, 2005, they are encouraged to report the data as part of the PC 2004 report and notify FNS of this fact in advance of submitting the PC 2004 data.
We hope this information will facilitate the process of collecting and reporting racial and ethnic data in accordance with the revised OMB standards and deadlines for reporting to FNS.
PATRICIA N. DANIELS
Supplemental Food Programs Division