The Honorable Shalanda D. Young

Gaps in race and ethnicity data quality should not prevent their use or efforts to address disparities and inequities; however, without high-quality, self-reported data across all states, researchers and other stakeholders are limited in their ability to measure and monitor disparities, and address disparities in care, use of services, and health outcomes to evaluate the effectiveness in advancing. [...] Is the current “default” structure of the recommendation appropriate? Should SPD-15 pursue a more voluntary approach to the collection of disaggregated data, as opposed to having a default of collecting such data unless certain conditions are met? TFAH supports the current “default” structure of the recommendation as the appropriate method of collecting race and ethnicity data. [...] These estimates result from bridging the 31 race categories used in Census 2000 and Census 2010, as specified in the 1997 Office of Management and Budget (OMB) standards for the collection of data on race and 71 Ibid. [...] Specific guidance for the collection and reporting of race and ethnicity data in situations where self- identification is unavailable are: • Use clear and consistent criteria for identification: When collecting race and ethnicity data by proxy or observation, clear and consistent criteria should be used to identify the individual’s race and ethnicity. [...] • Ensure privacy and confidentiality: When collecting race and ethnicity data by proxy or observation, it is important to ensure that the individual's privacy and confidentiality are protected.82, 83, 84 The changes made to the National Survey on Drug Use and Health (NSDUH) by the National Institute on Drug Abuse (NIDA) can provide valuable insights and guidance for implementing revisions to SPD 1.