The American Community Survey: Accuracy and Timeliness Issues	 
(30-SEP-02, GAO-02-956R).					 
                                                                 
GAO has reviewed several major issues associated with the	 
proposed full implementation of the American Community Survey	 
(ACS) by the Bureau of the Census for 2003. If the ACS is	 
approved, this mandatory mail survey would cost from $120 to $150
million a year, and would require responses from a sample of 3	 
million households to some 60 to 70 questions. The ACS would	 
replace the decennial census long form for 2010 and subsequent	 
decennial censuses. On the basis of sampling errors and related  
measures of reliability, the Census Bureau has decided that ACS  
data will be published annually for geographic areas with a	 
population of over 65,000; as 3-year averages for geographic	 
areas with a population of 20,000 to 65,000; and as 5-year	 
averages for geographic areas with a population of less than	 
20,000. According to the Bureau, the annual ACS data and 3-year  
averages would be significantly less accurate than data for 2010 
from the decennial census long form; 5-year averages, which would
be available at the detailed long-form level of geographic	 
detail, would be about as accurate as the long-form data. Federal
agencies that extensively use the 2000 Decennial Census long-form
data for program implementation would use ACS data in the future 
if the long form was eliminated. The questions to be asked in the
2003 ACS reflect justifications--specific statutes, regulations, 
and court cases--provided to the Bureau by federal agencies. To  
identify these justifications, the Bureau worked with the	 
agencies using a process similar to that used to prepare the	 
justifications for the questions on the 2000 Decennial Census	 
long form. The Bureau's plan to use responses to ACS questions to
develop samples for additional surveys is not prohibited by the  
disclosure provisions in 13 U.S.C. 9, as long as the Bureau	 
conducts the surveys. Some ACS questions duplicated or are	 
similar to questions on two existing federal surveys. Identical  
questions could be eliminated from the existing surveys because  
the ACS data would be more accurate, available at greater	 
geographic detail, and more timely. Similar questions could be	 
eliminated if the greater ACS accuracy, detail, and timelines	 
offset the advantage of asking additional and more relevant	 
questions on these surveys. The Bureau determined, and GAO has	 
agreed in a recently issued legal opinion, that it has the	 
statutory authority to conduct the ACS as a mandatory survey,	 
like the decennial census long form the ACS would replace. If the
ACS was conducted as a voluntary survey, the Bureau would need to
make up for the lower mail response with more interviews to	 
maintain the proposed level of accuracy of the ACS. Because	 
obtaining responses by interview is more costly than obtaining	 
responses by mail, conducting the ACS as a voluntary survey would
be more expensive. The Bureau used a number of strategies to	 
encourage participation in the ACS test program, which started in
1996. Two of the key strategies were (1) the training of	 
interviewers, whose job it was to collect data from households	 
that did not return the mail questionnaires, and (2) outreach and
promotion efforts. Telephone and in-person interviewers were	 
provided scripted replies, designed to overcome the objections of
nonrespondents, that highlighted themes such as the importance of
ACS data to the community and the legal requirement to		 
participate in the ACS. Since 1997, outreach and promotion	 
efforts have increased to include local workshops and town hall  
meetings, as well as contacts with representatives of print and  
broadcast media, professional journals, and umbrella		 
organizations.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-956R					        
    ACCNO:   A05218						        
  TITLE:     The American Community Survey: Accuracy and Timeliness   
Issues								 
     DATE:   09/30/2002 
  SUBJECT:   Census						 
	     Data collection					 
	     Data integrity					 
	     Federal agencies					 
	     Performance measures				 
	     Statistical data					 
	     Surveys						 
	     Census Bureau American Housing Survey		 
	     Census Bureau Current Population Survey		 
	     Census Bureau 2000 Supplemental Survey		 
	     2010 Decennial Census				 
	     Census Bureau American Community Survey		 
	     2000 Decennial Census				 

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GAO-02-956R

GAO- 02- 956R The American Community Survey

United States General Accounting Office Washington, DC 20548

September 30, 2002 The Honorable Dave Weldon, M. D. Chairman, Subcommittee
on Civil Service,

Census, and Agency Organization Committee on Government Reform House of
Representatives

The Honorable Dan Miller Vice- Chairman, Subcommittee on Civil Service,

Census, and Agency Organization Committee on Government Reform House of
Representatives

Subject: The American Community Survey: Accuracy and Timeliness Issues In
response to your March 11, 2002, request, we have reviewed several major
issues associated with the proposed full implementation of the American
Community Survey (ACS) by the Bureau of the Census for 2003. If the ACS is
approved, this mandatory mail survey would cost from $120 to $150 million
a year, and would require responses from a sample of about 3 million
households (250,000 each month) to some 60 to 70 questions. The ACS would
provide annual data for areas with a population of 65,000 or more and
multiyear averages for smaller geographic areas. In addition, the ACS
would replace the decennial census long form for 2010 and subsequent
decennial censuses.

Based on your request and subsequent discussions with your staffs, we
agreed to report on the following questions:

* How would the quality of the annual ACS data and multiyear averages,
which would be available beginning with annual data for 2003, compare with
that of the 2010 Decennial Census long- form data, and would these ACS
data adequately replace long- form data in meeting the needs of federal
agencies?

 Are the questions to be asked in the ACS beginning with 2003 justified
by statutory requirements of federal agencies, and is the planned use of
ACS data to select samples for additional surveys consistent with the
confidentiality provisions of Title 13 of the United States Code?

 Are ACS questions duplicative of or similar to those in other federal
surveys, and can the burden on the respondents be reduced?

 If the ACS was conducted as a voluntary survey, how would the costs be
affected?

 How did the Bureau encourage participation in the ACS test program
through (1) training for follow- up interviewers of nonrespondents and (2)
outreach and promotion efforts?

GAO- 02- 956R The American Community Survey Page 2 We conducted our audit
work at Bureau headquarters in Suitland, Maryland, and

Washington, D. C., from March through August 2002, in accordance with
generally accepted government auditing standards.

Results in Brief

On the basis of sampling errors and related measures of reliability, the
Census Bureau has decided that ACS data will be published annually for
geographic areas with a population of over 65,000; as 3- year averages for
geographic areas with a population of 20,000 to 65,000; and as 5- year
averages for geographic areas with a population of less than 20,000.
According to the Bureau, the annual ACS data and 3- year averages would be
significantly less accurate than data for 2010 from the decennial census
long form; 5- year averages, which would be available at the detailed
long- form level of geographic detail, would be about as accurate as the
long- form data. If the Bureau*s 2003 budget is approved, annual ACS data
for 2003 would be available beginning in 2004; the first 5- year average
data, for 2003- 07, would be available beginning in 2008. ACS data would
be significantly more timely than the once- every- 10- year data from the
long form. Accuracy and timeliness are both important components of survey
quality. Because there is no one formula to determine the relative
importance of the components, it is not possible to determine an overall
measure of survey quality to compare the ACS and long- form data.

Federal agencies that extensively use the 2000 Decennial Census long- form
data for program implementation would use ACS data in the future if the
long form was eliminated. To make the transition from the 2000 Decennial
Census long- form data to ACS data, which would begin with the release of
the annual ACS data for 2003, these agencies would need key information
from the Bureau*s evaluation of differences between the data collected
from the 2000 long form and that collected in the ACS tests. However, this
evaluation will not provide the agencies with the following key
information: data from the 2000- 02 ACS special supplements and the 2003
ACS with the same treatment of group quarters and seasonal residences as
the 2000 Census; techniques to improve consistency between the data items
from the 2000 long form and the 2003 and subsequent ACS estimates;
measures of stability of annual ACS data and ACS multiyear averages; a
framework for reconciling annual and multiyear data for the same
geographic level of detail; and procedures for revising previously
published ACS data to incorporate decennial census population counts.

The questions to be asked in the 2003 ACS reflect justifications* specific
statutes, regulations, and court cases* provided to the Bureau by federal
agencies. To identify these justifications, the Bureau worked with the
agencies using a process similar to that used to prepare the
justifications for the questions on the 2000 Decennial Census long form.
To support the request for approval of the ACS by the Office of Management
and Budget (OMB), the Bureau submitted a list of justifications it
selected from those provided by the agencies. These justifications were
selected from among those classified by the agencies as either mandatory*
decennial census data specified by statute* or required* decennial census
data used historically to support a statute or for court- imposed
requirements. Because agencies have not yet formally

GAO- 02- 956R The American Community Survey Page 3 approved the complete
list provided to the Bureau, we limited our review of the

justifications and their classifications to the list selected by the
Bureau. The justifications classified as mandatory met the Census Bureau*s
criteria. However, justifications classified as required could not be
verified because the agencies were not asked to provide sufficient
information about either their historical use of decennial census data or
planned use of the ACS.

The Bureau*s plan to use responses to ACS questions to develop samples for
additional surveys is not prohibited by the disclosure provisions in 13 U.
S. C. S: 9, as long as the Bureau conducts the surveys. Information from
the Census 2000 Supplementary Survey has already been used to develop the
sample for the National Epidemiological Survey on Alcohol and Related
Conditions, sponsored by the National Institutes of Health. The OMB, in
approving the ACS questionnaire, instructed the Bureau not to use the ACS
universe for additional surveys without agreement by OMB.

Some ACS questions duplicated or are similar to questions on two existing
federal surveys. In the request for OMB approval for the 2003 ACS
questionnaire, the Bureau said that there was some duplication, but that
there was no other single federal survey that collected all the ACS data.
OMB concurred with this position, and it appears to be a valid
interpretation. However, there is no indication that the agencies
sponsoring the existing surveys with questions that duplicate or are
similar to ACS questions have considered eliminating questions on their
surveys. Identical questions could be eliminated from the existing surveys
because the ACS data would be more accurate, available at greater
geographic detail, and more timely. Similar questions could be eliminated
if the greater ACS accuracy, detail, and timeliness offset the advantage
of asking additional and more relevant questions on these surveys.

The Bureau determined, and GAO has agreed in a recently issued legal
opinion, that it has the statutory authority to conduct the ACS as a
mandatory survey, like the decennial census long form the ACS would
replace. Based on this authority and on federal agency studies that a
mandatory mail survey would most likely result in a higher response rate
than a voluntary one, the Bureau plans to conduct the ACS as a mandatory
survey. If the ACS was conducted as a voluntary survey, the Bureau would
need to make up for the lower mail response with more interviews to
maintain the proposed level of accuracy of the ACS. Because obtaining
responses by interview is more costly than obtaining responses by mail,
conducting the ACS as a voluntary survey would be more expensive. The
Bureau has prepared a rough estimate of the added cost under the
assumption that the mail response rate to a voluntary ACS would be 6
percentage points less than the rate for a mandatory ACS. Using this
assumption, the Bureau estimates that a voluntary ACS would cost as much
as $20 to $35 million a year more.

The Bureau used a number of strategies to encourage participation in the
ACS test program, which started in 1996. Two of the key strategies were
(1) the training of interviewers, whose job it was to collect data from
households that did not return the mail questionnaires, and (2) outreach
and promotion efforts. According to the

GAO- 02- 956R The American Community Survey Page 4 Bureau, the tests have
consistently achieved high overall response rates and Bureau

officials have been pleased with the results. Telephone and in- person
interviewers were provided scripted replies, designed to overcome the
objections of nonrespondents, that highlighted themes such as the
importance of ACS data to the community and the legal requirement to
participate in the ACS. For the 1996 test, the refusal rates for telephone
interviews were about 14 percent and for in- person interviews about 4
percent. Moreover, for the tests conducted from 1996 to 2002, the Bureau
reported that it had received about 250 letters expressing concern about
the ACS. In a review of 82 of these letters, just 4 complained about the
conduct of an interviewer; in the other letters, the major concern
appeared to be privacy. For the outreach and promotion strategy, when the
ACS test began in 1996, the Bureau relied on press releases and free media
coverage for publicity. Since 1997, outreach and promotion efforts have
increased to include local workshops and town hall meetings, as well as
contacts with representatives of print and broadcast media, professional
journals, and umbrella organizations.

We are recommending that the Bureau provide federal agencies with key
additional information to better ensure the success of the transition from
the use of the 2000 Decennial Census long- form data to the use of ACS
data. We are also recommending that the Bureau and users of data from
existing surveys determine whether duplicative or similar questions on
these surveys can be eliminated because the same or similar data from the
ACS will be more accurate and timely.

Background

A decennial census usually consists of two major mandatory mail surveys.
To provide the basic population counts, which are required for
congressional apportionment and redistricting, a short form is mailed to
all housing units. 1 A long form is mailed to a sample of housing units to
provide detailed information for many federal programs, including such
topics as population and housing characteristics, incomes, education,
transportation, and disabilities at the Census tract level. 2

The President*s budget for fiscal year 2003 included a request for about
$120 million to fully fund the ACS, beginning with 2003, and to eliminate
the long form. According to the Bureau, the ACS, which would be an annual
survey of a sample of 3 million housing units, was developed primarily to
(1) provide long- form data items, at detailed geographic levels, that
would be more timely than the long form and more accurate than annual data
from existing surveys such as the Current Population and American Housing
Surveys and (2) improve the accuracy of the decennial census population
counts. 3 Bureau officials noted that the size of the ACS sample was

1 Article I of the United States Constitution requires an enumeration of
the population, every 10 years, for purposes of apportionment. See U. S.
Constitution art. I, sec. 2, cl. 3. To implement this constitutional
requirement, Congress enacted 13 U. S. C. S: 141, which requires a
decennial census of population. 2 For the 2000 Decennial Census, the long
form was mailed to 19 million housing units, or 1 out of every 6 units.
The Census tract

is the smallest level of geographic entity for which long- form data are
available. Census tracts are statistical entities within a county and are
defined by local data users. Generally, tracts have a population between
2,500 and 8,000 people. 3 For a discussion of the Census Bureau*s cost
estimates for the 2010 Decennial Census, see U. S. Bureau of the Census,

*Potential Life Cycle Savings for the 2010 Census* (Washington, D. C.:
June 2001).

GAO- 02- 956R The American Community Survey Page 5 determined in part by
the Bureau*s projected funding level for a conventional

decennial census in 2010. If approved, beginning with the 2010 Census, the
ACS would replace the long form, which, as GAO reported in 1998, ** is a
cost- effective method of providing baseline and trend data for use by
federal agencies and various other census stakeholders, compared to the
alternative of multiple data collections by other federal agencies for
their own purposes.* 4 Thus, because the ACS would replace the decennial
census long form, it would be important for the ACS to continue to serve
federal agencies in the same role as the long form.

Because of its sample size, the proposed ACS would eliminate the
availability of complete long- form detail* data items and geographic
levels* for any single year. The Bureau has determined that based on the
size of the ACS sample, it would be able to publish reliable annual ACS
data only for states and for cities, counties, and metropolitan areas with
a population of more than 65,000. 5 Compared with the size of the sample
used for the 2000 long form, which most likely would also be the size used
for 2010, the standard error for annual ACS data would be about three
times larger. 6 For smaller areas, the Bureau determined that it would
publish data only using 3- year or 5- year averages, depending on the
population size. The 3- year averages would be published for areas with a
population of between 20,000 and 65,000; 5- year averages would be
published for all geographic levels down to the tract level. For these 5-
year averages, the data would have standard errors about 1.33 times as
large as comparable long- form standard errors, but the Bureau expects
that this error will be offset by lower item nonresponse because of the
use of experienced interviewers for follow- up. 7

If the funding request is approved, annual ACS data, for 2003, would be
released beginning in 2004; data for areas with a population between
20,000 and 65,000 would first be released in 2006 as 3- year averages; and
data for areas with a population of less than 20,000 would first be
released in 2008 as 5- year averages.

Federal agencies using population counts to update fund allocations or for
other program purposes will not be affected by the ACS. Population counts
for 2000 and 2010 will come from the decennial census short form, and
annual population estimates will continue to come from the Bureau*s
intercensal population estimates program. 8 Some of these agencies have
already used these data to update fund allocations for programs requiring
population counts.

4 See U. S. General Accounting Office, Decennial Census: Overview of
Historical Census Issues, GAO/ GGD 98- 103 (Washington, D. C.: May 1998).
5 Population- size criteria reflect population in 2000.

6 The Bureau reported that standard errors of these annual data would
correspond to a 12 percent coefficient of variation for a 10 percent
estimate, which implies a 90 percent confidence interval of 10. 0+ 2.0.
For more details, see Charles Alexander, *American Community Survey Data
for Economic Analysis,* paper presented to the Census Advisory Committee
of the American Economic Association (Suitland, Md.: October 2001). 7
Alexander.

8 This program, also known as the Intercensal Demographics Estimates and
the Population Estimates Programs, is mandated by 13 U. S. C. S: 181. In
this program, administrative record data on births, deaths, immigration,
and emigration are used to produce annual population estimates* by state,
age, sex, race, and Hispanic origin* that are then used to implement
federal programs. For a description of this program, see *Population
Estimates: Concepts* at the Census Bureau*s Web site .

GAO- 02- 956R The American Community Survey Page 6 Federal agencies
dependent on detailed long- form data will incorporate the 2000

Decennial Census long- form data into their programs before they start to
use ACS data. These agencies will use the 2000 long- form data either to
replace the corresponding data from the 1990 Decennial Census or, for some
programs, to replace other source data for more recent years. Some
agencies have updated data from the 1990 Decennial Census using annual
data from household surveys. For example, the Current Population Survey
(CPS) and American Housing Survey (AHS) ask many of the same questions as
does the long form, but because of the sample size of these surveys, they
provide only national- level and some state- level data. The CPS data on
national and state levels of poverty and unemployment are also used
extensively for federal programs. For poverty and unemployment data for
smaller areas, the CPS data are supplemented by estimates from model-
based programs of the Census Bureau and the Bureau of Labor Statistics
(BLS). 9 In addition, data on income and employment at the state and
county level are prepared as part of the U. S. regional economic accounts
program of the Bureau of Economic Analysis. 10 Data from these accounts
are used to allocate over $125 billion in federal funds annually. 11

Regardless of how these agencies updated the 1990 Census data, if the ACS
proposal is approved, federal agencies would be required either to start
using 2000 Decennial Census data to using (1) annual ACS data beginning
with 2004, (2) 3- year averages beginning with 2006, or (3) 5- year ACS
averages beginning with 2008. 12 Thus, federal agencies using long- form
data would begin making decisions about the extent to which they would use
the new ACS data in 2004.

To test the quality of the ACS data and to assist ACS data users, the
Bureau conducted special national supplementary surveys that provided data
for the ACS questions for geographic areas with a population of 250,000 or
more. Using the annual data from the 2000 supplementary survey and 1999-
2001 averages for the test sites, the Bureau has started an ACS
development program that would evaluate and analyze differences between
ACS data and the corresponding data from the 2000 Decennial Census long
form. 13 Two of these reports have been released and the remaining

Some decennial census data users have recommended that the ACS estimates
should be used to improve the intercensal estimates. For example, see
Linda Gage, Department of Finance, California, statement prepared for the
Subcommittee on the Census, House Committee on Government Reform, 107 th
Cong. 1 st sess., 2001, 107- 9. Census Bureau plans for such improvements
are discussed in Charles Alexander and Signe Wetrogan, *Integrating the
American Community Survey and the Intercensal Demographic Estimates
Program* (paper presented at a meeting of the American Statistical
Association, Indianapolis, Ind.: August 14, 2000). 9 For the Census
Bureau*s income and poverty estimates program, see *Small Area Income and
Poverty Estimates* at the

Bureau*s Web site ; for the BLS labor force estimates
program, see *Local Area Unemployment Statistics* at the BLS Web site
. (Although the Census Bureau conducts the CPS, it is
largely funded by BLS, the agency responsible for preparing the official
estimates of unemployment and related labor force characteristics.) 10 For
a description of the program, see *Regional Economic Accounts* at the
Bureau of Economic Analysis Web site

. 11 See U. S. Office of Management and Budget, Budget of
the United States Government: Appendix (Washington, D. C.: 2002) 215.

12 The results of a special national survey conducted for 2000, officially
titled the *Census 2000 Supplementary Survey* and called the *C2SS* by the
Bureau, have been published. However, the Bureau has recommended that
these data should not be used when the 2000 long- form data become
available. The supplementary survey for 2000, as well as similar ones for
2001 and 2002, was conducted by the Bureau using the ACS questionnaire and
survey methodology to provide testing of the ACS. For purposes of this GAO
report, *ACS* refers to both the ACS surveys conducted at test sites
throughout the country and to these supplementary annual surveys. For
additional information, see *What Are Supplementary Surveys* and *What is
the American Community Survey* at the Census Bureau*s Web site. 13 The ACS
development program refers to testing, research, and development
activities the Bureau plans to conduct until the

ACS is implemented in 2003.

GAO- 02- 956R The American Community Survey Page 7 reports are scheduled
to be completed in 2003. In the second of these reports, the

Bureau evaluated the quality of the ACS data using measures of four types
of errors identified by OMB*s guidelines for survey error: accuracy,
timeliness, relevance, and accessibility. 14 However, this report only
provides limited information on the quality of the two surveys and does
not provide an overall measure of quality of either the long form or the
ACS. The Bureau also has announced that it plans to use the data from the
supplementary surveys for 2001 and 2002 to evaluate the stability of the
annual estimates, but there is no schedule for the scope or completion
dates for this evaluation.

The Bureau proposes to conduct the ACS as a mandatory mail survey because
it would cost less than conducting the ACS as a voluntary survey, based on
studies by federal agencies that showed response rates to mandatory mail
surveys are higher. The Bureau also wanted the ACS to be mandatory because
the Census long form was mandatory and both the long form and the ACS
collect data that have a use mandated by statute. In response to a
congressional request, GAO issued a legal opinion on April 4, 2002, that
concluded that the Bureau has the authority to conduct the ACS as a
mandatory survey. 15

The process for determining the questions to be asked in the 2003 ACS
started with the questions asked on the 2000 long form. To determine the
2000 questions, federal agencies, as they had for recent decennial
censuses, provided the Bureau with a list of statutory programs that
support specific questions; using criteria developed by the Bureau, these
agencies classified each program into one of three categories* mandatory,
required, or programmatic. A program was to be classified as mandatory if
the supporting statute explicitly calls for the use of decennial census
data. A program was to be classified as required either if the supporting
statute required the use of data and the decennial census was the
historical source of that data or if the data were needed for requirements
imposed by the U. S. federal courts. A program was classified as
programmatic if it did not meet the mandatory or required criteria, but
was needed for such purposes as program planning, implementation,
evaluation, or for the operation of another statistical program. The
Bureau included as questions on the 2000 long form those justified by
either a mandatory or required program and, in addition, included a few
questions that the Census Bureau needed for surveyoperation purposes. The
Bureau submitted the questions to Congress for review 2 years before the
forms were to be mailed, in accordance with 13 U. S. C. S: 141( f);
Congress did not disapprove them. The Bureau then submitted the questions
to OMB, in accordance with provisions of the Paperwork Reduction Act. OMB
reviewed and cleared the questions.

A similar process was used for the 2003 ACS questions with two exceptions:
(1) a final list from the federal agencies is not yet available and (2)
the questions were not submitted to Congress until July 11, 2002. For the
2003 ACS, the Bureau sent

14 See U. S. Bureau of the Census, Meeting 21 st Century Demographic Data
Needs* Implementing the American Community Survey: May 2002, Report 2:
Demonstrating Survey Quality (Washington, D. C.: May 2002). For a
discussion of the guidelines, see U. S. Office of Management and Budget,
Statistical Policy Working Paper 31, Measuring and Reporting Sources of
Errors in Surveys (Washington D. C.: July 2001). 15 See Legal Opinion B-
289852 (April 4, 2002) at GAO*s Web site .

GAO- 02- 956R The American Community Survey Page 8 federal agencies the
questions on the 2000 long form and asked them to do the

following: Provide a list of programs to support specific questions;
classify each program using criteria developed by the Bureau into one of
the three categories used for 2000* mandatory, required, or programmatic;
and describe the frequency and level of geographic detail needed for each
program. 16 Although no additional written information or guidance was
given to agencies to help them classify the programs into the correct
category for the ACS, Census officials spoke with agency officials about
this matter and reported that the categories were discussed at meetings of
the OMB- sponsored and -directed Interagency Committee on the American
Community Survey. In addition, agencies were not asked to provide any
information on how they were planning to use 2000 long- form data or on
planning to transition from the use of long- form data to the use of ACS
data.

Although the process of compiling the lists of programs for the 2003 ACS
started in early 2001, the agencies were not able to complete a final list
in time for the Bureau to submit the ACS questionnaire for OMB approval.
Therefore, in late 2001, the Bureau decided that for OMB approval, it
would select a short list of programs with mandatory or required
justifications already identified by the agencies. The Bureau selected
programs so that each of the proposed 2003 ACS questions was supported by
at least two statutes. In April 2002, as required by provisions of the
Paperwork Reduction Act, the Bureau submitted the 2003 ACS to OMB for
approval and justified the questions with the programs on the short list.
17 In order to ensure that the latest lists provided by the agencies were
complete, on June 13, the Department of Commerce formally requested that
each agency review their lists. These approved lists were not available at
the time of this review. On June 28, 2002, OMB cleared the ACS
questionnaire with the condition that the Bureau must submit to OMB, in
advance, any plans to use the ACS to select samples for other surveys. 18
This advance submittal would continue until OMB agreed on an approach for
the Bureau to evaluate such plans.

The Bureau has been conducting tests of the ACS at the county level,
starting with four test sites in 1996 and increasing to 31 sites by 1999.
Based on these tests, the Bureau has determined that it has successfully
demonstrated the feasibility of conducting the ACS. 19

Annual ACS Data Less Accurate but More Timely than Long Form; Federal
Agencies Need Additional Information for Transition to ACS

Our framework for evaluating quality of the data from the two surveys was
based on four OMB guidelines for measuring survey errors-- accuracy,
timeliness, relevance,

16 The definitions of the categories used for the 2003 ACS were
essentially the same as those used for the 2000 long form, except that the
definitions were modified to add the ACS when the 2000 Decennial Census
was referenced in the criteria. 17 The Paperwork Reduction Act (44 U. S.
C. S: 3507) also required that a notice of the request be published in the
Federal

Register; it appeared on May 1, 2002 (67 Federal Register 21629- 30). 18
See Office of Management and Budget, Notice of Action 0607- 0810 (June 28,
2002).

19 U. S. Bureau of the Census, Meeting 21 st Century Demographic Data
Needs* Implementing the American Community Survey: July 2001, Report 1:
Demonstrating Operational Feasibility (Washington, D. C.: July 2001).

GAO- 02- 956R The American Community Survey Page 9 and accessibility. 20
Because of the larger long- form sample, data for 2010 from a

decennial census long form would be significantly more accurate than the
data for 2010 from the proposed ACS. Based on the size of the 2000 long-
form sample, the 2010 census long form would be mailed to about 20 million
housing units; in contrast, the 2003 and later years* ACS questionnaires
would be mailed to 3 million units a year. On the one hand, ACS data for
2010 not only would be less accurate than the 2010 long- form data, but
would also be limited to areas with a population of more than 65,000. On
the other hand, ACS data would be timelier. Data for areas with a
population of more than 65,000 would be available annually, and the 5-
year averages would be available for the same geographic levels as the
long form. Because similar questions are used on both surveys, data from
the long form and the ACS would have the same level of relevance. Based on
past Bureau practices, there would be no significant differences in
accessibility to the data.

We did not attempt to combine our evaluations of the four guidelines into
an overall measure of quality for each survey. First, complete information
was not available to evaluate all of the components of each of these
guidelines. Second, as noted in the OMB guidelines, even with complete
information, it is difficult to combine the results of the evaluations of
these components into an overall measure of quality.

Currently, the Census Bureau*s plans to evaluate ACS data provide only a
limited amount of the information needed by federal agencies to transition
from their use of the 2000 long form to the ACS. For example, the plans do
not provide for (1) 2003 data conceptually consistent with the 2000 long-
form data, (2) information to adjust 2003 and 2004 data to account for
statistical differences with the 2000 long form, (3) information to
integrate annual data and multiyear averages, and (4) the Bureau*s
proposals to incorporate, first, the population counts from the 2010
Decennial Census into the 2010 ACS and, second, the resulting revisions to
the intercensal population estimates into previously published ACS data.
21

Evaluation of ACS and Long- Form Data Quality Currently Incomplete We
evaluated the data quality of the two surveys, using the four OMB
guidelines for measuring survey quality. According to the information
available to us, we found that the accuracy of ACS, based on sample size,
would be less than that of the decennial census long form. Sufficient
information on nonsampling errors is not yet available to compare the two
surveys for this measure of accuracy. Nonresponse errors, based on the
incomplete information, were somewhat smaller for the ACS. Measurement
errors, based on more complete information, appeared to be larger in the
ACS. However, the timeliness of the ACS data would be superior.

20 To evaluate the quality of the ACS program, we have primarily used
guidelines for measuring survey errors in U. S. Office of Management and
Budget, Statistical Policy Working Paper 31, Measuring and Reporting
Sources of Errors in Surveys

(Washington D. C.: July 2001). These guidelines are similar to guidelines
published by Statistics Canada, the International Monetary Fund, and in
OMB*s newly issued *Guidelines for Ensuring and Maximizing the Quality,
Objectivity, Utility, and Integrity of Information Disseminated by Federal
Agencies.* 21 For a discussion of the impact on federal programs resulting
from the replacement of the 2000 intercensal population

estimates with the 2000 Census population counts, see U. S. General
Accounting Office, Formula Grants: 2000 Census Will Redistribute Federal
Funding among States, GAO- 02- 1062 (Washington, D. C.: forthcoming).

GAO- 02- 956R The American Community Survey Page 10

Accuracy

Our findings on accuracy were based on information from the Bureau on both
sampling and nonsampling errors, which includes nonresponse, measurement,
and coverage errors. According to the Bureau, the ACS sampling error will
be larger than the error for the long form, but the impact of this larger
sampling error may be reduced through the use of more experienced
interviewers than those used for the decennial census. However, we found
no indication that the experience of the interviewer would make a
significant impact, especially if the ACS mail response rate was high and
the number of follow- up interviews low.

As reported in the OMB guidelines for survey errors, nonsampling error is
frequently the source of the most significant errors in surveys. But we
were not able to determine whether that was the case for either the long
form or the ACS. Nevertheless, for both surveys, we found indications
based on incomplete data of two types of nonsampling error, nonresponse
and measurement error. The impact of nonresponse error appears to have
been greater for the long form; the impact of measurement error appears to
be greater for the ACS.

Item nonresponse occurs when a respondent does not complete an item on the
survey form or provides an unusable response. 22 For both the Census 2000
Supplementary Survey and the 2000 Decennial Census long form, information
on item nonresponse was based on published information on imputations for
selected states and on national- level data on imputations for a small
group of items provided to GAO by the Bureau. For the 12 states for which
the Bureau has released item nonresponse data, imputation rates were
typically about the same for all the states. For individual items,
imputation rates were slightly higher for the long form. Of the 35 items
for which we had imputations at the national level for both surveys, we
found that for total income, the imputation exceeded 20 percent of the
total value for both. For items such as period of active- duty military
service, time of departure for work, weeks worked, the year housing was
built, and the value of owner- occupied housing units, we found that the
value imputed was between 10 and 20 percent for both surveys. For the rest
of the items for which we had data for both surveys, the imputations
accounted for slightly more of the long- form total than of the
corresponding items on the supplementary survey.

We found indications of measurement error, one of the major sources of
nonsampling error, based on our examination of long- form and ACS data.
Measurement error is usually calculated as the difference between the
survey value and the true value. As is usually the case, true values are
not available. For this review, we assumed that because of the much larger
sample size in the 2000 long form, the value from the 2000 long form is
closer to the true value than that in the Census 2000 Supplementary Survey
value. 23 To examine the differences between long- form and ACS data, we

22 The second major type of nonresponse error, unit nonresponse, which is
the complete failure to obtain data from a respondent, was very small for
both the 2000 long form and the supplementary survey. 23 Because the
sample size of the supplementary surveys is about one- fourth that of the
proposed 2003 ACS, these differences

may overstate the differences between the 2003 ACS data and comparable
long- form data.

GAO- 02- 956R The American Community Survey Page 11 compared published
national- level and state- level data for a set of items selected

from among the major topics on the form. 24 These comparisons showed large
national differences for key items that did not appear to be accounted for
by coverage differences between the two surveys. 25 For example, at the
national level, the largest differences were for these items: (1) for the
number of housing units lacking complete plumbing facilities, with the
long- form estimate 27 percent higher than the estimate from the
supplementary survey, and (2) for the number of unpaid family workers,
with the long- form estimate 59 percent lower. Other items with national-
level differences of at least 10 percent included selfemployed workers,
housing units lacking complete kitchen facilities, and housing units with
no telephone service. We also found a great degree of variation in the
state differences between the long form and the supplementary survey. For
the following items, a significant proportion of the states had long- form
estimates that were both 10 percent or more higher than and 10 percent or
more lower than the supplementary survey estimates: workers commuting by
public transportation; households with income of $200,000 or more; housing
units lacking complete plumbing facilities; number of renter- occupied
units with gross monthly rent of $1,000 to $1,499; and some of the
measures of the number of individuals and related children below the
poverty threshold.

To gauge the accuracy of the 2000 ACS data, we also looked at differences
between the 2000 ACS and the Census Bureau*s CPS. We reviewed these data
using a dimension of quality that is part accuracy as well as part
relevance and part timeliness. Based on sampling errors, we found that the
2003 ACS would be more accurate. However, based on technical reports, we
found that both the Census Bureau and the BLS view the existing surveys as
providing more accurate and more relevant information. 26 For example,
neither the Bureau nor BLS uses long- form data in the statistical
measures of income, poverty, and labor at the national and state levels.
27 The reason given by these agencies for not using the long- form data
for these items is that (1) the CPS has more detailed questions that more
closely relate to the underlying concepts and (2) the surveys are
conducted by experienced interviewers. OMB, in Statistical Policy
Directive No. 14, has designated the CPS as the official source of
statistical measures of poverty. The Department of Health and Human
Services (HHS) has designated the CPS as the source of poverty measures
for its programs. 28

24 Although the Bureau did compare 2000 Census and 2000 ACS results in one
of their evaluation reports, the comparisons were limited to short- form
items. See U. S. Census Bureau, Meeting 21 st Century Demographic Data
Needs* Implementing the American Community Survey: May 2002, Report 2:
Demonstrating Survey Quality (Washington, D. C.: May 2002). 25 These
differences, discussed later in the report, are the exclusion of people
living in group quarters and the different treatment

of people with seasonal residences. 26 For information on income and
poverty data, see *Guidance on Survey Differences in Income and Poverty
Estimates*

(March 19, 2002) at the Census Bureau*s Web site. For information on labor
force data, see Charles Alexander, Sharon Brown, and Hugh Knox, *American
Community Survey Data for Economic Analysis* (paper presented at a meeting
of the Federal Economics Statistics Advisory Committee, Washington, D. C.,
December 14, 2001). 27 The Census Bureau and BLS, however, use detailed
geographic information from the long form in constructing model- based

estimates of income, poverty, and unemployment for small geographic areas.
28 See *Annual Update of the HHS Poverty Guidelines,* 67 Federal Register,
6931- 33 (February 14, 2002).

GAO- 02- 956R The American Community Survey Page 12 To follow up this
information about poverty and unemployment rates, we compared

the total unemployment rate and two poverty rates-- for individuals and
for related children under 18-- in the long form, the Census 2000
Supplementary Survey, and the CPS. 29 We found that at the national and
state levels, there were small differences for the unemployment rate and
for the poverty rate for all individuals. In contrast, comparisons of
these rates for the CPS with these two surveys showed larger differences.
The national unemployment rate, according to the CPS, was 4.0 percent,
compared with 5.8 percent for the long form and 5.4 percent for the
supplementary survey. The national rate for individuals in poverty for the
CPS was 11.3 percent, compared with 12.4 percent for the long form and
12.5 percent for the supplementary survey. The pattern for the national
poverty rate for related children under 18 for the CPS was different
because there was a larger difference between the ACS and longform rates.
The CPS rate was 15.6 percent, as compared with 16.1 percent for the long
form and 17.0 percent for the supplementary survey. Small differences were
also shown in comparisons of the long- form and supplementary survey
distribution of state differences for the unemployment rate and for the
poverty rates for related children under 18 and for individuals. Comparing
the distribution of the state differences between the CPS and either of
the other two surveys only showed significant differences for the poverty
rate for related children under 18. Compared with the long form, the CPS
rate for 12 states is 2.5 or more percentage points lower and for 10
states is 2.5 or more percentage points higher. Compared with the
supplementary survey, the CPS rate for 16 states is 2.5 or more percentage
points lower and for 5 states, 2.5 or more percentage points higher.

We asked Census Bureau and BLS officials about future plans for the use of
the ACS. According to Census Bureau officials, they had been doing
research into the use of ACS data to improve their model- based estimates,
but did not have any definitive plans. 30 According to BLS officials, they
had recently let a research contract to help them determine whether ACS
data could be used to improve their small- area estimates. Because of the
widespread use of CPS poverty and unemployment data in federal programs,
assistance by these two statistical agencies would help the program
agencies in deciding whether to replace the CPS data with ACS data.

We anticipate that the Bureau*s evaluation studies, to be completed in
2003, will provide explanations for the measurement errors. For example,
we expect that the evaluations will separate out measurement errors by
quantifying the impact of excluding from the supplementary surveys people
living in group quarters and of treating differently people with seasonal
residences. In our review of differences between the long- form and
supplementary survey data, it did not appear that these errors would
explain the large differences noted above. Nevertheless, this exclusion
will contribute significantly to differences in certain states and for
certain data items.

29 Comparisons with the AHS were not possible because it is a biennial
survey and no data at the national level were available for 2000. 30 For a
discussion of potential ACS use in these models, see National Academy of
Sciences, Small Area Income and Poverty

Estimates: A Workshop (Washington, D. C., 2000) 123.

GAO- 02- 956R The American Community Survey Page 13

Timeliness

The timeliness of the ACS data for all geographic levels would be a major
improvement over the long form, especially for annually published data for
geographic areas with a population of 65,000 or more. However, use of
these annual data for geographic areas with populations at the lower end
of this range may be limited. The Bureau has reported that the accuracy of
the annual data for these areas would be roughly comparable with the
accuracy of the state estimates from the CPS. We found that in describing
the accuracy of the CPS income and poverty data, the Bureau has reported
that annual state data should not be used, but that 2- year averages
should be used to calculate changes at the individual state level and 3-
year averages should be used for calculating relative rankings for states.
31 Because the ACS has a larger sample than the CPS, these limitations
should not apply to annual ACS data for states and other large areas, but
they may apply to the annual ACS data for smaller areas. Thus, federal
agencies planning to use annual data for these areas will need information
on when to use multiyear averages instead of the annual data.

Relevance

Because of the similarity of the long- form and ACS questions, their
levels of relevance* the extent to which a survey provides conceptually
meaningful and useful measures* are similar. However, for federal program
use, two important measures from both surveys* poverty and unemployment
rates* the ACS and long- form data are not as relevant as the measures
from existing surveys according to the agencies that conduct them. Our
findings on these measures were discussed under *accuracy.*

Information to Meet Federal Agencies* Transition Needs Missing Federal
agencies would need assistance from the Bureau in the transition process,
as recognized in the 2001 National Academy of Sciences report choosing the
formula allocations, which concluded:

The American Community Survey (ACS), which is intended to replace the
decennial census long form, would be a major new data source that could be
used in estimating inputs if the survey were implemented as planned. With
data from census 2000 becoming available in stages and the ACS pending, an
immediate and high priority should be given to developing recommendations
on how to make a smooth transition to these and other data sources and how
to evaluate the impact on allocations of introducing new data sources. 32

The Census Bureau has recognized its responsibility to provide such
assistance through various outreach efforts and its ACS development
program. 33 The Bureau has stated: *Users need to understand the
differences in order to properly use the C2SS and ACS data in their own
applications and to be able to distinguish real changes over

31 See U. S. Census Bureau, Money Income in the United States: 2000
(Washington, D. C.: September 2001). 32 National Academy of Sciences,
Choosing the Right Formula: Initial Report (Washington D. C.: 2001). 33
This type of assistance is required by OMB*s data quality guidelines and
is recommended in National Academy of Sciences,

Principles and Practices for a Federal Statistical Agency (Washington, D.
C.: 2001).

GAO- 02- 956R The American Community Survey Page 14 time from changes in
estimates because of differences in methods.* 34 The current

plans for the testing program call for an analysis of differences between
the 2000 Census long- form data and the data from the Census 2000
Supplementary Survey, to be completed in 2003. 35

From the perspective of the federal agencies, however, we found the
content of the ACS development program is missing material, described
below. This material would address differences between the two surveys
related to sampling, measurement, and nonresponse errors, discussed
earlier in this section. The analysis of these differences will provide
information critical to the agency*s transition to the ACS because these
differences are likely to significantly change the allocation of funds and
program eligibility, and agencies will need to fully understand the
sources of such changes.

In an earlier report on the comparability of the 2000 Census long- form
data and the Census 2000 Supplementary Survey, the Bureau noted the
following about its evaluation program: *The purpose of those evaluations
is to help the user understand how the estimates will differ, but not to
adjust the C2SS in any way to mirror the long form.* 36 Thus, the Bureau
has excluded from the current testing program a plan to adjust the data
from supplementary surveys for 2000- 2002 and the 2003 ACS to account for
coverage differences* for group quarters and seasonal residences* between
the ACS and the 2000 Decennial Census long- form data at the national and
state levels. 37 In the supplementary surveys and the 2003 ACS, people
living in group quarters were excluded; in the 2000 Decennial Census,
people living in group quarters accounted for about 2.8 percent of the
population. 38 In addition, the Bureau decided to change the treatment of
people who had seasonal residences because the treatment in the decennial
census reflected where people lived on only 1 day of the year, even though
they might spend most of the time living somewhere else. This difference
does not affect the national- level data. The adjusted series for 2000
would help explain some of the large differences between the 2000 ACS and
long- form data; the adjusted series for 2003 would allow the agencies to
consider using the adjusted 2003 ACS data to update the 2000 estimates
instead of waiting until 2004, when ACS would begin to cover people living
in group quarters. Thus, it would only be necessary to adjust ACS data
beginning with 2004 for the difference in the treatment of seasonal
residences.

We also found that the ACS development program does not include plans to
provide information on two elements of accuracy of the annual ACS
estimates-- their use as

34 See *Preliminary Assessment of the Comparability of Census 2000 Long
Form Estimates with Census 2000 Supplementary Survey Estimates,* 6, at the
Census Bureau*s Web site. 35 The program was included in the Census
Bureau*s *American Community Survey Alert, June 2002,* which appears at
the

Bureau*s Web site. 36 *Preliminary Assessment of the Comparability of
Census 2000 Long Form Estimates with Census 2000 Supplementary Survey

Estimates,* 6. 37 For more information, see *Preliminary Assessment of the
Comparability of Census 2000 Long Form Estimates with Census

2000 Supplementary Survey Estimates,* 3. 38 People living in group
quarters* e. g., nursing homes, correctional institutions, college
dormitories, and military quarters-- were

excluded from the supplementary survey data for all years in an effort to
reduce reporting burden on the operators of these facilities in 2000. They
were also excluded from the 2001- 02 supplementary surveys and the
proposed 2003 ACS; they will be covered in the ACS, beginning with 2004.

GAO- 02- 956R The American Community Survey Page 15 measures of yearly
changes for state and county data and relative rankings between

states and counties. This information would assist federal agencies in
deciding (1) how frequently they should update their fund allocations or
eligibility criteria and (2) whether they should use averages or the
annual data. As previously noted, the accuracy of the ACS annual data
would be roughly comparable with state data from the CPS and the Bureau
has recommended using 3- year averages when calculating relative rankings
of state CPS income and poverty data.

In addition, we found that the ACS development program did not cover
information about different ways to integrate the annual data for states
and large counties and the 3- and 5- year averages for smaller counties.
For example, in 2008, the Bureau would publish annual data for 2007 for
states and counties with a population of more than 65,000; 3- year
averages for 2005- 07 for counties with populations of 20,000 or more; and
5- year averages for 2003- 07 for all counties. Federal agencies that need
state data can choose to use either the annual data, multiyear averages of
the annual data, or 3- year or 5- year ACS averages. Federal agencies that
also need county data will face several options: They can choose to use
the most recent annual data for large counties and adjust the averages of
the smaller counties to agree with annual data. Alternatively, they can
choose to use various combinations of multiyear averages. We also found
that some agencies use existing household survey data instead of decennial
census data. These agencies would now have the option of when or whether
to switch to the ACS. We found that the Bureau*s ACS development program
did not include a report analyzing differences for corresponding data
items in annual changes and in annual levels between the ACS and the
existing surveys.

Finally, we looked ahead to 2011, when the Bureau would need to
incorporate (1) the 2010 Decennial Census population counts into the 2010
annual ACS data and (2) the revised 2003- 09 population estimates into the
previous multiyear averages. We found no plans on benchmarking ACS data to
the 2010 Decennial Census, although these plans could affect agencies*
decisions on use of the ACS.

Federal Agencies Justify ACS Questions, but Uncertainty Remains on Extent
of ACS Data Use

Federal agencies provided the Bureau with a list of justifications to
support ACS questions and classified each program into one of three
categories* mandatory, required, or programmatic. This list was not
complete when the Bureau submitted the request to OMB for approval of the
ACS questionnaire. Consequently, from among those programs classified by
the agencies as mandatory* decennial census data specified by statute* or
required* decennial census data historically used to support a statute or
court- imposed requirements* the Bureau selected a short list of
justifications for submission to OMB. The Bureau provided OMB both the
short list and the latest draft of the complete list, and OMB cleared the
ACS questionnaire based on this information. Without a complete list
approved by the agencies and information on how the agencies planned to
use 2000 Decennial Census and ACS

GAO- 02- 956R The American Community Survey Page 16 data, we reviewed only
the justifications on the Census- approved short list sent to

OMB. 39 The 20 questions justified by mandatory programs reflect the
provisions of seven statutes: One statute justifies 13 questions for
providing information to the Equal Employment Opportunities Commission
(EEOC) to enforce the Federal Affirmative Action Plan. Another statute
justifies 6 questions for providing information to the Department of
Justice (DOJ) to enforce the Voting Rights Act. A Department of Commerce
(DOC) statute justifies 1 question for providing information for
legislative redistricting. The other statutes relate to programs of the
Department of Agriculture (USDA), DOC, and HHS. Based on our review of the
statutes underlying these programs, we found that the statutes require the
use of decennial census data.

As previously noted, we were unable to verify most of the 48 required
classifications because the agencies were not asked to report on how they
planned to use the newly available 2000 Decennial Census data. Information
on how these data were actually used was not available when the agencies
submitted their justification list because the 2000 Census long- form data
were not yet available. In addition, we were not able to review agency
plans for the ACS because the Bureau did not ask agencies to report their
planned use of ACS data in their programs. Information about when these
data would be introduced, whether annual data or multiyear averages would
be used, and whether 2000 Decennial Census and ACS data would be
integrated are likely to have also been useful to guide the Bureau in the
ACS development program. We were told by Bureau officials that this
information was not requested because the Bureau followed the
justification process used for the 2000 Decennial Census long form. We
were also told that the three questions included for survey- operation
purposes were necessary.

In addition to providing federal agencies with direct use of ACS data for
program needs, the Bureau has announced that it would conduct special
surveys for them, based on ACS responses. In the past, the Bureau has used
this practice for responses to other surveys, such as the decennial
censuses. We agree with the Bureau that this practice is not prohibited by
the disclosure provisions in 13 U. S. C. S: 9( a)( 1), which provide that
Census data may not be used *for any purpose other than the statistical
purposes for which it is supplied.* We agree with the Bureau*s opinion
that *statistical purposes* includes the use of information collected in
one Bureau survey to conduct another Title 13 statistical survey. The
Bureau itself would conduct all additional surveys; responses would not be
provided to any other federal agency. In the cover letters mailed with the
ACS questionnaires, the Bureau had notified respondents in the ACS testing
programs of this plan. We were unable to determine whether respondents
understood the possible impact of the plan; we also did not find any
mention of this notification in the information provided to the staff
conducting the ACS testing.

39 For the 2000 Decennial Census long form, the lists provided to the
Bureau by the federal agencies were not formally approved by the agencies.
On June 13, 2002, the General Counsel of the Department of Commerce sent a
letter to the General Counsels of the agencies that submitted information
for the lists, requesting formal approval. A final list, based on the
responses to the request, which were due July 13, 2002, was not available
at the time this report was prepared.

GAO- 02- 956R The American Community Survey Page 17 OMB, in approving the
ACS questionnaire for 2003, has required the Bureau to meet

certain conditions before using the ACS sample to select samples for other
surveys. OMB stated, *The Census Bureau is not permitted to use the ACS
for follow- up studies until an approach has been agreed to with OMB.* 40

Duplicate or Similar Questions in ACS and Other Federal Surveys

Duplicate or similar questions in federal surveys may cause an unnecessary
burden on respondents. The Paperwork Reduction Act requires agencies to
minimize the reporting burden for respondents and the cost to the
government by prohibiting unnecessary duplication of questions in
information collection. In its statement submitted to OMB for approval of
the ACS questionnaire under this act, the Bureau reported: *The content of
the American Community Survey reflects topics that the Census Bureau is
mandated or required to collect. A number of questions in the American
Community Survey appear in other demographic surveys, but the
comprehensive set of questions does not duplicate any other single
information collection.* 41 It should also be noted that although many ACS
questions are similar to or the same as questions on other federal
surveys, these other surveys do not provide data for small geographic
areas that the Bureau plans to provide from the ACS.

The Bureau*s statement on duplication does not address the possible
elimination of questions, on other surveys, that would become duplicative
because the data would be collected on the ACS. But we identified other
existing federal surveys that ask some of the same questions or similar
ones to those on the ACS. It appears, however, that continuation of the
inclusion of these questions on these surveys is justified because the
questions are primarily about population characteristics* such as age,
sex, race, and, sometimes, income. For example, these questions are needed
to provide context for the major focus of each of the following surveys:
the Survey of Consumer Expenditures (Department of Labor), the National
Health and Nutrition Examination and National Health Interview Surveys
(HHS), the Survey of Crime Victimization (DOJ), and the Survey on
Nutrition (USDA). The questions on these surveys focus on consumer
spending, smoking or eating habits, or crime, topics that would not be
covered by the ACS.

Other than the questions on population characteristics that are on many
surveys, questions on three voluntary household interview surveys appear
to have the most overlap with ACS questions. The surveys are the Bureau*s
annual supplement to the CPS, the Bureau*s Survey of Income and Program
Participation (SIPP), and the AHS, which the Bureau conducts for HUD. All
three of these surveys have questions that overlap with ACS questions on
the labor force, incomes, and other topics, such as country of birth. For
the AHS, there also is a substantial overlap for questions on housing
characteristics.

40 OMB, Notice of Action 0607- 0810 (June 28, 2002). 41 See Census Bureau,
supporting statement, para. A4, provided to OMB by the Bureau as part of
the *Paperwork Reduction Act

Submission for the 2003 ACS.*

GAO- 02- 956R The American Community Survey Page 18 It should be noted
that in some cases, overlap does not mean that the identical

questions were asked. In addition, even when virtually identical questions
were asked, one survey might include additional questions to obtain the
most relevant response. For example, to determine whether a person is
unemployed, the CPS asked more questions than does the ACS; to determine
whether a property is used as a business or medical office, the AHS asked
about the number of rooms used for business, number of rooms used for both
business and personal use, and if there is a medical or dental office on
the property. In the ACS, the respondent is only asked, *Is there a
business (such as a store or barber shop) or a medical office on this
property?*

According to the Census Bureau, income and labor force data should
continue to be collected in the CPS and SIPP because of the unique
characteristics of the data from these surveys. 42 The CPS income data
have been determined by OMB (Statistical Policy Directive No. 14) to be
the official statistical source to calculate the poverty threshold and
related estimates for the nation and for the states. SIPP collects more
detailed information on incomes and on characteristics related to poverty;
it is designed as a longitudinal survey, which allows users to study
household behavior over time. In addition, CPS and SIPP periodically
include supplements covering special topics. The CPS has covered topics
such as workers who hold multiple jobs, intermittent workers, and health
insurance. The SIPP has covered topics such as wealth, day care, and
disability. The ACS estimates of income and poverty would be more accurate
than the CPS or SIPP because they would have a smaller sampling error, but
the use of trained interviewers for the CPS and SIPP reduce nonresponse
error sufficiently to offset lower ACS sample error. Although trained
interviewers may reduce nonresponse error, there is also empirical
research that shows that both CPS and SIPP income data differ
significantly from independent benchmark estimates. 43 Now that 2000 long-
form income data are available, updating this research would enable the
agencies to reexamine the relative accuracy of the various estimates.

The AHS is a biennial household interview survey, sponsored by HUD and
conducted by the Bureau. The survey costs about $17 million a year and has
many questions on income and housing characteristics that are more
detailed, but similar to ACS questions. The ACS is based on a much larger
sample and provides far more geographic detail annually than the AHS. Our
review of ACS and AHS questions showed a substantial overlap for questions
on place of birth and citizenship, education, labor force characteristics,
transportation to work, income, and housing characteristics. Of the 66
questions on the 2003 ACS, 25 are in the section on housing
characteristics; all but one of these questions are the same as or similar
to questions on the AHS. In addition, when we reviewed the most recent
list of program justifications for the ACS, provided by HUD to the Bureau,
we noted an overlap between HUD*s current use of the AHS and the decennial
census and its planned use

42 For information on SIPP, including comparisons with other surveys, see
SIPP Users* Guide at the Census Bureau*s Web site. 43 See Marc I. Roemer,
*Assessing the Quality of the March Current Population Survey and the
Survey of Income and Program

Participation Income Estimates, 1990- 1996* (June 16, 2000) at the Census
Bureau*s Web site.

GAO- 02- 956R The American Community Survey Page 19 of the ACS. According
to information provided to OMB to support approval of the

AHS, HUD reported: The major program uses of the AHS are to develop and
evaluate the Fair Market Rents (FMR's) for the Section 8, Existing Housing
Program, the Housing Voucher Program, and the Annual Adjustment Factors
(AAFs) used to grant rent increases for units under contract for both
Section 8, New Construction and Existing Programs: New Construction
Housing and Existing Housing.

The preliminary list of ACS uses by HUD, provided to the Bureau, also
showed several of these same programs.

Conducting the ACS as a Voluntary Survey Would Most Likely Result in
Higher Costs

The Bureau*s decision to conduct the ACS as a mandatory survey is
supported by studies of two surveys* one of households and one of
businesses* that showed that response rates to mandatory mail surveys are
higher than those to voluntary mail surveys. The study on the household
survey, conducted by the Bureau as an experiment, using the 1990 Decennial
Census short form, showed the response to the mandatory survey was about 9
percentage points higher than the response to the voluntary survey. 44 The
study on the business survey, also conducted by the Bureau, showed the
response to the mandatory survey was more than 20 percentage points
higher. 45 We reviewed a study of another Bureau mail survey and a BLS
study of mail surveys of businesses and found the same pattern of
reporting. We also analyzed unpublished BLS data on the response rates to
a monthly business survey, where the reporting in some states was
mandatory. These data showed a higher response rate with mandatory
surveys, but the gap was smaller* 12 percentage points for March to May of
2001 and 6 percentage points for the same months in 2002. However, we also
found that interpreting differences in response rates between surveys is
difficult, as noted in the literature on response rates. 46 Some of the
factors that can distort the comparisons include differences in survey
methods, survey length, population surveyed, quality of nonresponse
follow- up interviewers, and extent and nature of follow- up methods.

We also found that response rates to private surveys tend to be lower than
for federal government surveys. Among the privately conducted national
household interview surveys, two are sponsored by HHS. For the Health and
Retirement Survey, conducted by the Institute for Social Research of the
University of Michigan, the response rate is about 82 percent. 47 For the
Medical Expenditures Panel Survey Household Component, conducted by
Westat, Inc., and the National Opinion

44 See D. A. Dillman and others, *Effects of Benefits Appeals, Mandatory
Appeals, and Variations in Statement of Confidentiality on Completion
Rates for Census Questionnaires,* Public Opinion Quarterly, 60, (1996)
376- 89. 45 D. R. Tulp Jr. and others, *Nonresponse Under Mandatory vs.
Voluntary Reporting in the 1989 Survey of Pollution Abatement

Costs and Expenditures (PACE)* (U. S. Census Bureau, Suitland, Md.,
photocopy). 46 See U. S. Office of Management and Budget, Statistical
Policy Working Paper 31, Measuring and Reporting Sources of

Errors in Surveys (Washington, D. C.: July 2001) and B. K. Atrostic and
others, *Nonresponse in U. S. Government Household Surveys: Consistent
Measures, Recent Trends, and New Insights,* Journal of Official
Statistics, 17: 2 (2001): 209- 26. 47 For a description of this survey,
see *Health and Retirement Study * at the Web site of the Institute for
Social Research at

.

GAO- 02- 956R The American Community Survey Page 20 Research Center of the
University of Chicago, the response rate for the 1996 survey

was 83 percent. 48 For telephone surveys, an industrywide survey of
private marketing and opinion research firms reported the highest average
response rate among different types of telephone surveys, 52.5 percent for
customer satisfaction surveys. 49 In contrast, the combined response for
the four ACS test sites in 1996 was 98.2 percent and for the Census 2000
Supplementary Survey, 95.4 percent.

Information provided by the Bureau indicated that costs of a voluntary ACS
would be greater because of the larger number of follow- up interviews
that would be needed due to the lower response rate. However, it is not
clear whether with sufficient funding, the Bureau would be able to achieve
the same overall response rate for a voluntary mail or interview survey as
for a comparable mandatory mail survey. Such a conclusion cannot be
determined from the existing evidence because there has been no testing of
response rates for a voluntary mail survey of households of the size and
scope of the ACS. For the ACS, such a study would be needed not only to
determine the overall response rate, but also the extent of item
nonresponse.

As to costs, we asked the Bureau to estimate the additional costs of
conducting the ACS as a voluntary survey, assuming a lower mail response
rate and comparable quality results. The Bureau provided an estimate of an
additional $20 to $35 million per year, assuming that the mail response
rate was 6 percent lower.

Interviewer Training, as Well as Outreach and Promotion Efforts,
Encouraged Participation in the ACS Test Program

As with all its surveys, one of the Bureau*s principal objectives in
conducting the ACS test program was to achieve a high response rate so as
to collect complete and accurate data. The training the Bureau provided to
interviewers who collected data from nonrespondents, in concert with other
strategies* such as a respondent- friendly questionnaire, multiple
mailings, as well as outreach and promotion* encouraged participation,
that is, a high response rate, in the ACS test program. 50

Follow- up Interviewers Trained to Encourage Participation in the ACS The
Bureau has consistently achieved high overall response rates in the ACS
tests. For example, the Bureau reported that the first ACS test in 1996
had a mail response rate of 60.9 percent at the four test sites (Rockland
County, N. Y.; Brevard County, Fla.; Fulton County, Pa.; and Multnomah
County and the city of Portland, Ore.). But the final response rate* once
the Bureau completed its follow- up efforts with people

48 For a description of this survey, see *Estimation Procedures in the
1996 Medical Expenditures Panel Survey Household Component * at the Web
site of the Agency for Health Care Policy and Research . 49 Jane M. Shepard and Steve Everett, *Cooperation Tracking Survey:
April 2002 Update* at the Council for Marketing and

Opinion Research Web site . 50 This discussion does not
cover interview, outreach, and promotion efforts associated with the 2000-
02 Census Supplementary

Survey program, conducted with the ACS questionnaire and survey
methodology and used to test the quality of these data

GAO- 02- 956R The American Community Survey Page 21 who did not respond to
the initial mail survey* was 98.2 percent. 51 The Bureau*s ACS

program staff was pleased with the results. As the ACS test program
expanded to 31 sites between 1997 and 1999, the Bureau continued to
achieve similar mail and final response rates. The Bureau*s staff of
follow- up interviewers helped achieve these high rates because they were
trained in a variety of techniques to encourage participation by
households that did not respond to an initial mail survey.

During the first month of the 3- month ACS data collection cycle, the
Bureau made a concerted effort to obtain responses by mail because this is
the least costly method of obtaining survey data. To encourage
participation, the Bureau used a respondentfriendly questionnaire and a
four- part mailing strategy: over the course of the month, the Bureau sent
each household (1) a pre- notification letter that described the ACS and
informed recipients they would soon receive the questionnaire; (2) an
initial ACS questionnaire and information about the survey; (3) a postcard
reminding recipients to complete the questionnaire and thanking them if
they had already done so; and (4) about 3 weeks after the initial ACS
questionnaire, a replacement questionnaire that was mailed to housing
units that had not yet returned their questionnaires. The Bureau reported
that in 1996, the replacement questionnaire added about 10 percentage
points to the initial response rate at each test site.

During the second month, Bureau staff attempted to collect data via the
telephone, using a procedure called Computer- Assisted Telephone
Interviewing, from households that did not mail back their questionnaires.
A month later, in a final procedure called Computer- Assisted Personal
Interviewing, Bureau field representatives were to visit a one- in- three
sample of the remaining nonrespondents. Overall, the telephone
interviewers and field representatives appeared to be effective in their
tasks. In 1996, refusal rates were about 14 percent for the telephone
interviews and 4 percent for the in- person interviews.

Because the telephone interviewers and field representatives play an
important data collection role and represent the Bureau to the general
public, proper training is critical. The Bureau provided both telephone
interviewers and field representatives with similar training, consisting
of lectures, scripted mock interviews, and discussions. Our review of the
materials used for the follow- up indicates that most of the training was
devoted to correct use of the computers and other mechanics of conducting
the interview. Dealing with reluctant respondents appeared to make up a
small portion of the training.

According to the training manual, telephone interviewers, after verifying
the household, were to begin the survey by telling respondents: *I am
required by law to

51 The 60. 9 percent response rate roughly reflects the percentage of mail
surveys returned before the start of follow- up interviewing. After the
processing was completed, 78. 5 percent of the responses were based on
mailed report forms, 11.5 percent on telephone interviews, and 10.5
percent on personal interviews. Information on item nonresponse rates is
not available. For additional information, see Susan Love and Greg
Diffendal, *The American Community Survey Monthly Response Rates, by Mode*
(paper presented at the American Community Survey Symposium, Bureau of the
Census, Washington, D. C.: March 1998).

GAO- 02- 956R The American Community Survey Page 22 tell you that this
survey is authorized by Title 13, section 182, of the United States

Code*. This survey is mandatory and your cooperation is very important.
All the information you provide is completely confidential.* 52

If respondents were reluctant to participate in the telephone interview,
the interviewers had available scripted answers to common questions about
the survey. These answers were aimed at addressing respondent concerns and
keeping them engaged. One or more of the following themes typically ran
through the suggested replies: federal law requires participation; data
from the ACS benefits the respondent*s community and the nation; federal
law protects the privacy of responses; and responding now can help save
taxpayers* money. For example, if a respondent said, *I think this is a
waste of taxes!* the interviewer was instructed to explain: *There are
many reasons why it*s definitely NOT a waste of tax dollars. Businesses,
government agencies, and the general public rely on up- to- date
statistics, like the information we are collecting in this survey, to make
informed decisions. Calling people by phone to collect this information is
the least expensive way to do it, if we can*t get a response by mail.* The
suggested replies appeared to be courteous, informative, firm, and
nonthreatening.

In addition, although the ACS was a mandatory survey, the training
materials cautioned interviewers: *It is rarely necessary to mention this
law because most people understand the importance of Census Bureau survey
data and are willing to cooperate. The Bureau places a high value on the
public*s cooperation and we are counting on you to maintain this cherished
relationship.*

Households that refused to participate in the telephone interview and
households for which the Bureau was unable to obtain a valid telephone
number were added to the universe of cases eligible for personal
interviews by the field representatives. Because personal visits are the
most expensive data collection method, the Bureau used a one- in- three
sample of the remaining nonresponding households. Such households are
sometimes the most difficult cases for the Bureau to resolve because a
number of them have already refused two mailed questionnaires and the
telephone follow- up.

The field representatives were trained in a variety of interviewing
skills, such as using probe questions to (1) obtain responses from
respondents who might not answer some of the questionnaire and (2)
eliminate bias from interview responses. In addition, to help improve
response rates, field representatives were told how to make a good
impression on respondents, demonstrate a strong knowledge of the survey,
introduce themselves with confidence and a smile, dress appropriately, and
be prepared to allay respondents* concerns. Further, the classroom
training included a video in which several experienced field
representatives provided tips on dealing with difficult refusals and
people who were hard to track down.

52 The Privacy Act of 1974, 5 U. S. C. S: 552a, requires all federal
agencies that collect information to advise respondents under what
authority the information is being collected, how the information will be
used, whether participation is required, and the consequences of not
responding.

GAO- 02- 956R The American Community Survey Page 23 This training was
followed with, among other topics, a discussion of how field

representatives could convert a potential refusal into a completed
interview. The training manual reminded field representatives that the ACS
is mandatory, and respondents who are living at addresses selected for the
survey are legally required to complete the questionnaire. The manual also
noted that (1) the introductory letter and the materials mailed
subsequently to the household indicate that the ACS is mandatory and (2)
the field representatives should have a copy of the letter available to
give to any reluctant respondents.

The training manual acknowledges that even though respondents have been
notified that participation is mandatory, some people may still be
reluctant to participate. The manual then instruct interviewers about the
importance of (1) making a proper introduction and good first impression
and (2) listening to and addressing any objections to participation, such
as the length of the survey or the personal nature of the questions.
Interviewers were provided with standard responses to frequently asked
questions that were similar to those responses provided to the telephone
interviewers.

If, after following these procedures, the respondent still refuses to
participate, interviewers were trained to *remain calm and professional,
and leave the site.* Interviewers were to report the refusal to their
supervisors who, in turn, were to attempt to contact the address either by
mail or telephone.

When the Bureau conducted personal interviews in 1996, the field
representatives were new to the endeavor. This initially resulted in
mistakes, such as interviewing neighbors and other nonhousehold members.
However, the Bureau retrained the interviewers and found that the number
of such mistakes declined. Moreover, the follow- up efforts elicited
little in the way of public complaint to the Bureau. Indeed, although the
Bureau invited the public to comment on the conduct of the ACS, none were
received from three of the test sites, according to the Bureau.

The exception was the Brevard County test site where, according to our
review of Bureau documents and interviews with Bureau officials, about 30
people, in 1996, wrote letters to Congress with concerns or complaints
about the ACS. The letters generally focused on the personal nature of the
questions or the legal requirement to participate in the survey, not about
the interviewers themselves. However, there was one reported incident in
which a field representative did not follow Bureau procedures and was
overly aggressive in collecting information from respondents. The Bureau
reportedly reprimanded that individual.

The Bureau reports that between 1996 and 2002, it received about 250
letters expressing concerns about the ACS. Our review of 82 letters, or
about one- half of those available to GAO, suggests that privacy was a
frequent concern; just 4 of the letters we reviewed mentioned that a
Bureau interviewer was rude or intimidating.

In 1996, the ACS nonresponse follow- up operation collected data from
about 13,800 households, with few problems. This record suggests that the
training the

GAO- 02- 956R The American Community Survey Page 24 Bureau provided its
telephone interviewers and field representatives was aligned

with the objective of securing a high response rate. For subsequent tests
of the ACS, the Bureau relied more heavily on a staff of permanent
interviewers. The Bureau believed that the training and experience of such
interviewers resulted in higher response rates and better quality data.
The Bureau*s future plans call for a similar approach.

Outreach and Promotion Efforts Have Gradually Expanded According to Bureau
officials, when it launched the ACS test in 1996, the Bureau had no
outreach staff onboard. Instead, the Bureau used a press release and free
media to publicize the survey to respondents. Following the initial test,
the Bureau developed outreach and promotion efforts that appeared to be
geared, in large part, toward government officials and data users. An
employee responsible for outreach first joined the ACS program in late
1996 and worked with local people in the Multnomah County, Oregon, test
site on how the data could best be used. The Bureau conducted additional
workshops at test sites in 1997, following the release of the 1996 data.
Those invited to attend included congressional staff, local elected
officials, planners, and other local government agencies.

As the ACS program expanded to 31 test sites, the Bureau increased the
number and type of outreach activities to include more data workshops;
town hall meetings; contacts with representatives of national and local
print and broadcast media; professional journals; and umbrella
organizations, such as the National League of Cities. For example, in late
June 2002, the Bureau held the third in a series of ACS meetings in
Seattle, Washington. According to the Bureau, among the 80 attendees were
representatives of congressional offices, public and private
organizations, academia, and the media. An outreach staff of six employees
continues to work with many of the organizations that are represented in
the Bureau*s racial, ethnic, and decennial census advisory committee.

If the Bureau*s plans for full implementation of the ACS are approved, it
expects to continue working with organizations that it partnered with for
the 2000 Decennial Census. As we noted in our earlier report, 53 the
Bureau relied on these partnerships to help improve participation in the
census and mobilize support for key census operations. The Bureau
recognized that local people and organizations know (1) what the
characteristics of their communities are better than the Bureau and (2)
how to best communicate with their communities.

By comparison, the promotion and outreach efforts for the decennial census
were far more ambitious, but that is to be expected, given the national
scope and universal coverage of the census. It included an advertising
campaign, developed by a private sector advertising agency, and a
nationwide effort to enlist support in taking the census through
partnering with corporations, community groups, and other

53 U. S. General Accounting Office, 2000 Census: Review of Partnership
Program Highlights Best Practices for Future Operations, GAO- 01- 579
(Washington, D. C.: August 2001).

GAO- 02- 956R The American Community Survey Page 25 organizations. In all,
for the 2000 Decennial Census, the Bureau spent about

$374 million on marketing, communication, and partnerships, or about $3.19
per household. According to the Bureau, the mail return rate was about 74
percent.

Conclusions

If the ACS is approved, federal agencies will be able to start using
annual ACS data as early as 2004. Primarily because the annual ACS data
will be less accurate than the 2000 decennial census long- form data,
these agencies will need to be provided with key information about ACS
data to ensure that the transition from the use of longform data to ACS
data is more likely to be successful. In addition, the availability of ACS
data will create opportunities to eliminate questions on existing surveys
and reduce the reporting burden of these surveys.

Recommendations for Executive Action

In order to facilitate the transition by federal agencies from the use of
2000 Decennial Census data to the ACS, we recommend that the Secretary of
Commerce direct the Director, Bureau of the Census, revise and expand the
quality- testing and evaluation component of the ACS development program.
In particular, the following actions should be taken:

 Establish a process to make sure that the ACS development program
produces key information needed by federal agencies that will have to use
ACS data when the long form is eliminated.

 Develop estimates, for states and large local government areas, of
social, economic, and housing characteristics from the 2000- 02 ACS
special surveys and the 2003 and 2004 ACS to provide agencies with ACS
estimates that are conceptually consistent with the 2000 Census.

 Expand the planned evaluation of differences between data from the
Census 2000 Supplementary Survey and the 2000 Decennial Census long form,
so as to identify techniques for agencies to use to improve consistency
between the 2000 Census data and the 2003 and subsequent ACS data.

 Analyze and report on differences between year- to- year changes for
2001 and 2002, using the data* from ACS special supplements and the CPS at
the national and state levels* for key economic and housing
characteristics, such as the unemployment and poverty rates, to determine
the stability of the annual ACS data.

 Extend the scope of the ACS development program to include plans to
benchmark ACS estimates, beginning with 2005, to the 2010 Census
population counts and the revised 2005- 09 population estimates to ensure
comparability between the ACS and 2010 Census data.

To more completely address the possibility of reducing the reporting
burden in existing surveys, we recommend that the Secretary of Commerce
direct the Director, Bureau of the Census, to review for possible
elimination, proposed ACS questions now asked on two surveys conducted by
the Bureau* the annual demographic supplement of the Current Population
Survey and the American Housing Survey.

GAO- 02- 956R The American Community Survey Page 26 Questions that are not
identical should be eliminated if, in the absence of other

reasons, the accuracy, timeliness, and geographic detail of the ACS data
outweigh the greater relevance of the data from the existing survey.

Scope and Methodology

We used a combination of approaches and methods to examine the Census
Bureau*s implementation of the ACS. These included statistical analyses;
meetings with key Bureau headquarters officials; and reviews of relevant
documentation, including congressional testimony and Federal Register
comments on the ACS. Information on all aspects of the ACS, the decennial
census, the supplementary surveys, and other Bureau surveys is available
at the Bureau*s Web site .

To obtain data on the ACS and the 2000 census and to examine how the
quality of the ACS data, beginning with 2003, would compare with that of
the 2010 Decennial Census long- form data, we spoke to Bureau officials
about the technical aspects of the ACS. We reviewed materials prepared by
the Bureau on the quality, coverage, and underlying definitions of the ACS
and the relationship of the ACS to other Bureau programs. We also
conducted an analysis of differences, for a representative set of data
items at both the national and state levels, between Census 2000
Supplementary Survey and 2000 long- form data

To assess the extent to which ACS data would meet the needs of federal
agencies, we spoke to officials at BLS and the Census Bureau concerning
the use of ACS data in their programs. We reviewed previous GAO reports on
formula allocation and eligibility determination. 54 We also reviewed
directives and guidelines prepared by OMB on the measurement of poverty,
and spoke to OMB staff on the potential impact of the ACS on those
guidelines. In addition, we reviewed recent studies, prepared by the
National Academy of Sciences, on federal fund allocation, small- area data
modeling, and statistical agency practices.

To determine whether the questions to be asked in the ACS are justified by
statutory requirements, we reviewed the statutes for mandatory programs
that agencies used to support the questions. To determine whether the
planned use of ACS data to select samples for additional surveys is
consistent with the confidentiality provisions of Title 13, we reviewed
the pertinent statutory provisions. We reviewed the cover letter for the
ACS that notified respondents of this use.

To determine if ACS questions are duplicative or similar to those in other
federal surveys and if the burden on the respondents could be reduced, we
reviewed the questions on other federal agency household surveys for
duplication with the ACS questions. For the CPS and AHS, we reviewed a
line- by- line comparison prepared for GAO by the Bureau.

54 See U. S. General Accounting Office, Formula Grants: Effects of
Adjusted Population Counts on Federal Funding to States,

GAO/ HEHS- 99- 69; Means- Tested Programs: Determining Financial
Eligibility is Cumbersome and Can be Simplified, * GAO- 02- 58, and Title
I Funding: Poor Children Benefit Though Funding Per Poor Child Differs,
GAO- 02- 242 (Washington D. C.: February 1999, November 2001, and January
2002).

GAO- 02- 956R The American Community Survey Page 27 To explore whether the
costs of conducting the ACS would be affected if it was

conducted as a voluntary survey, we reviewed published studies of
differences in response rates for the same surveys when conducted on a
mandatory versus a voluntary basis. 55 We also obtained similar
unpublished data from BLS for stateconducted surveys for which some states
had made responses mandatory. 56

To determine how the Bureau encouraged participation in the ACS test
program through training for follow- up interviewers of nonrespondents, as
well as outreach and promotion efforts, we interviewed Bureau officials
and reviewed documentation, including training manuals, videos, and
letters of complaint about the ACS test program.

We requested comments on a draft of this report from the Secretary of
Commerce. On September 25, 2002, the Secretary forwarded the Bureau *s
written comments on the draft (see enclosure).

Agency Comments and Our Evaluation

In written comments on a draft of this report, the Secretary of Commerce
provided the Bureau of the Census*s comments. Those comments are included
in the enclosure. Overall, the Bureau agreed with the thrust of our
recommendations. However, it expressed a number of concerns about some of
the detailed findings. The principal concerns raised by the Bureau and our
response are presented below. The Bureau also provided technical comments
that have been incorporated where appropriate.

First, the Bureau expressed concerns about our approach to comparing the
quality of data from the proposed ACS and the 2000 Decennial Census long
form, stating that (1) we did not adequately take into account the
tradeoffs between accuracy and timeliness and (2) we did not take into
account certain information on response rates. We followed OMB guidelines
on measuring survey quality in our analysis, and included in our analysis
information on the impact of nonsampling error, using measurement error
and item imputation rates for the detailed questions. We made standard
assumptions about the impact of sampling error on the two sets of data. In
addition, we recognized the limitations of these measures, including those
noted by the Bureau in its comments, and summarized our findings with the
following cautionary statement: *Because there is no one formula to
determine the relative importance of the components, it is not possible to
determine an overall measure of survey quality to compare the ACS and
long- form data.*

Second, the Bureau expressed concern about our focus on single- year ACS
data and our analysis of measurement errors in the ACS. Any analysis of
measurement errors in the ACS necessarily must focus on single- year data
since those are the only ACS data that exist. Moreover, our methodology
for determining relative measurement

55 In addition to the studies used by the Census Bureau, see John Gawalt,
*Research and Development in Industry: 1990, NSF 94- 304* (Washington, D.
C.: 1994). 56 See Bureau of Labor Statistics, *A Brief Study of Findings
from the CES Enrollment Research* (unpublished: November 1996).

GAO- 02- 956R The American Community Survey Page 28 error is fully
consistent with two previously stated Bureau positions. In the statement

to OMB justifying the need for the 2000 Census Supplementary Survey, the
Bureau reported that the primary need for the 2000 ACS data ** is to
determine how well ACS data compare with long- form data from Census
2000.* In addition, the Bureau provided users with the following statement
on their own Web site: *The Census 2000 Supplementary Survey [ACS] data
provided an early look at the detailed characteristics of the U. S.
population for 2000. However, as the official census sample data become
available, they should be used instead of the Census 2000 Supplementary
Survey to describe the population in 2000 and to look at changes from 1990
to 2000.* This statement clearly implies that the Bureau agrees that the
ACS data are less accurate.

Third, the Bureau stated that we should have addressed the use of income
and poverty data, in the official OMB measures, based on the Current
Population Survey (CPS) and not based on the corresponding long- form
data. This statement is incorrect. We addressed this issue in our
discussion, comparing the differences between the CPS, census long- form,
and ACS data. In the report, we compared two poverty measures and found
that at the national level, the long- form data were closer to the CPS
data than the ACS data.

Finally, the Bureau disagreed with our description of the list of federal
agency justifications, provided to OMB in April 2002, as incomplete,
stating that it was *complete* when it was submitted. This statement is
inconsistent with (1) the fact that the list provided to OMB was annotated
as a *draft* and (2) our later discussions with Bureau officials in which
they confirmed that all agencies have not yet submitted a final list of
justifications for ACS questions.

- - - - As agreed with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report until 30
days from its issue date. At that time, we will send copies to other
interested congressional committees, the Secretary of Commerce, the
Director of the Bureau of the Census, the Secretary of Housing and Urban
Development, and the Administrator of the Office of Information and
Regulatory Affairs of the Office of Management and Budget. Copies will be
made available to others on request. In addition, the report will be
available at no charge at the GAO Web site at http:// www. gao. gov. Tanya
Cruz, Robert Goldenkoff, Andrea Levine, Christopher Miller, Patrick
Mullen, and Theodore Saks made major contributions to this report. If you
have questions about this report, you may contact me on (202) 512- 9750.

Robert P. Parker Chief Statistician

Enclosure

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*** End of document. ***