by Amy Vertal and Meeta Anand

In March of 2024, OMB modernized its Statistical Policy Directive 15 (SPD 15), its standards for the collection of race and ethnicity data at the federal level: an important step towards capturing more thorough and actionable data. Many federal agencies collect information about the race and ethnicity of U.S. residents through surveys, program and benefits applications, and other mechanisms. Data on race and ethnicity serve several critical purposes, from informing federal services and program administration to protecting civil rights and ensuring equal opportunity. Complete, detailed, and high-quality race and ethnicity data are vital for federal agencies to function effectively and better serve the nation’s increasingly diverse population, allowing all U.S. residents to thrive.  

The 2024 SPD 15 standards went into immediate effect when released for all new data collections, and established a 5-year timeline for agencies to implement the updated standards on other data collections. This timeline initially required federal agencies to publish and submit to OMB their plans to implement 2024 SPD 15 by September 28, 2025, and to fully implement the updated standards by March 28, 2029. On September 26, 2025, OMB announced a 6-month delay to both deadlines. On March 27, 2026, the day before agencies were due to provide their implementation plans, OMB further pushed back the deadline for the submission of implementation plans: now they are due on March 28, 2027. However, the deadline for full implementation remains March 28, 2029.  In the meantime, in the past year alone we have seen 75 collections implementing the 2024 SPD 15, in whole or in part – and we look forward to continuing to see such implementation take place, even in the absence of published implementation plans.

Background: What is SPD 15?

To ensure the comparability of data collected across federal agencies, The U.S. Office of Management and Budget’s (OMB) Statistical Policy Directive No. 15: Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity establishes the minimum set of categories that agencies must use when collecting race and ethnicity data. On March 28, 2024, OMB issued its first updates to SPD 15 since 1997, enacting several changes long-since asked for by many stakeholders. The 2024 SPD 15 directs federal agencies to adopt a single, combined race and ethnicity question with a distinct Middle Eastern/North African (MENA) category, and require agencies to collect “disaggregated,” or more detailed, data for specific subgroups within each race and ethnicity category. This long-overdue modernization of the SPD 15 standards represents an important step toward improving the accuracy and quality of federal race and ethnicity data. The changes will allow more people to select race and/or ethnicity options on federal forms that accurately reflect their identities, leading to improved data quality and allowing more people to see themselves represented in federal statistics and in turn, better policy decisions.  

However, updating the SPD 15 standards is only the first step toward achieving these benefits for federal data. OMB must now hold federal agencies accountable to fully implement the standards in a timely manner.  

Federal agencies’ progress on 2024 SPD 15 implementation

In light of the extension, this blog examines federal agencies’ progress on implementing the 2024 SPD 15 standards from January, 2025, to January, 2026. This analysis draws on data from the Information Collection Requests (ICRs) that agencies must submit via reginfo.gov when making any changes to their data collections.  

During this period, federal agencies submitted 75 ICRs that sought changes to at least partially implement 2024 SPD 15 requirements.

Agency

ICRs

Department of Health and Human Services

23

Department of Commerce

14

Department of Defense

8

Department of Agriculture

7

Export–Import Bank of the United States

6

Department of Labor

4

Department of Justice

4

Department of Transportation

3

Department of Education

2

National Science Foundation

2

National Endowment for the Arts

1

Department of Veterans Affairs

1

The Department of Health and Human Services (HHS) submitted 23 ICRs requesting to implement 2024 SPD 15, more than any other agency. An additional 18 HHS submissions indicated future plans to implement the updated standards but requested additional time to do so. The Department of Commerce followed with 14 ICR submissions (7 by the Census Bureau and 7 by the National Oceanic and Atmospheric Administration).

The degree to which agencies implemented changes to fully comply with all 2024 SPD 15 requirements varied, however. A significant number requested to implement only the updated minimum categories (including MENA) and the combined question format, but not the detailed data collection requirement. While the 2024 SPD 15 requires agencies to collect data using the detailed categories in 2024 SPD 15’s Figure 1 (see below) “as a default,” agencies may request an exemption to this requirement from OMB “if the agency determines that the potential benefit of the detailed data would not justify the additional burden to the agency and the public or the additional risk to privacy or confidentiality.1”

A form asking 'What is your race and/or ethnicity?' with seven checkbox categories: American Indian or Alaska Native, Asian, Black or African American, Hispanic or Latino, Middle Eastern or North African, Native Hawaiian or Pacific Islander, and White. Each category includes sub-checkboxes for specific ethnicities and a text field for additional details.
Figure 1. Race and Ethnicity Question with Minimum Categories, Multiple Detailed Checkboxes, and Write-In Response Areas with Example Groups1

If granted an exemption, agencies may use a format that includes only the minimum categories with or without examples of the detailed categories, as shown in Figures 2 and 3 below.

A simplified version of the same race and ethnicity form shown in Figure 1, with the same seven checkbox categories, but with specific ethnicities listed only as examples in italic text beneath each category, without sub-checkboxes or text fields.
Figure 2. Race and Ethnicity Question with Minimum Categories Only and Examples1
A minimal version of the same race and ethnicity form in Figure 1, but listing only the seven category names as checkboxes with no examples, sub-options, or text fields.
Figure 3. Race and Ethnicity Question with Minimum Categories Only1

Of the 75 data collections for which agencies implemented 2024 SPD 15:

  • 20 fully implemented the updated minimum categories with detailed check boxes and examples (as in Figure 1);

  • 11 requested to implement only the minimum categories with examples (as in Figure 2); and,

  • 37 requested to implement only the minimum categories (as in Figure 3).

 

The remaining eight ICRs implemented combinations of the detailed and minimum versions depending on the mode of data collection or respondent type, to collect detailed data only for certain minimum categories, or indicated implementation of the 2024 SPD 15 standards but did not specify the exact question format. Many of the requests for exemption from using the detailed categories cited respondent burden, burden to state governments collecting and reporting data to the federal agency, or concerns about small sample size presenting confidentiality risks. At the same time, several appeared to lack the required justification for OMB’s consideration of such requests. Notably, only one of the requests to implement the less detailed versions of the 2024 SPD 15 minimum categories explicitly indicated that the agency would consider implementation of the detailed categories in the future.

At least 20 federal agency ICR submissions during this time period requested extensions for implementing any of the 2024 SPD 15 requirements on their data collection. Many of these requests cited the need for additional time and guidance for states or third-party vendors (such as electronic health records providers) to make the required updates to their data collection systems, or the cost and burden for the agency to update its own systems. Several also cited the agency’s ongoing development of its 2024 SPD 15 implementation plan as justification for delaying implementation on a specific data collection. Many of these requests also indicated the agency’s support for implementing 2024 SPD 15 in the future. 

Takeaways: Promising signs of progress, but federal agencies and OMB must commit to fully implementing SPD 15’s detailed data collection requirement

Federal agencies’ progress in proactively implementing 2024 SPD 15 on a significant number of data collections in advance of the deadline for agency-wide 2024  SPD 15 implementation plans is a promising indication of their commitment to improving the quality of their data collection. However, it is concerning that agencies requested exemptions from using the detailed race and ethnicity categories on over three-quarters of the data collections for which they sought to implement 2024 SPD 15. Failure to fully implement the detailed categories will produce less granular data that obscures important differences between specific groups, rendering the data less useful for agencies and the public. 

To achieve the full promise of 2024 SPD 15 for improving the quality of federal data, OMB must hold federal agencies accountable to fully implementing the updated standards, including the requirement to use the detailed categories by default. The March 28, 2027, deadline for agencies to submit their implementation plans will be a critical opportunity for OMB to provide this oversight. However, OMB must also support federal agencies in achieving full implementation by providing the necessary guidance (including bridging and messaging), technical assistance and resources to update their data collection systems, as well as to support states on implementation for data they report to federal agencies. This oversight and support can happen at any stage in the implementation process, regardless of the status of the submission of implementation plans.