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entitled '2010 Census: Counting Americans Overseas as Part of the 
Decennial Census Would Not Be Cost-Effective' which was released on 
September 14, 2004.

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Report to the Subcommittee on Technology, Information Policy, 
Intergovernmental Relations and the Census, Committee on Government 
Reform, House of Representatives:

August 2004:

2010 CENSUS:

Counting Americans Overseas as Part of the Decennial Census Would Not 
Be Cost-Effective:

GAO-04-898:

GAO Highlights:

Highlights of GAO-04-898, a report to the Subcommittee on Technology, 
Information Policy, Intergovernmental Relations and the Census, 
Committee on Government Reform, House of Representatives: 

Why GAO Did This Study:

The U.S. Census Bureau (Bureau) has typically counted overseas members 
of the military, federal civilian employees, and their dependents. 
However, it usually excluded private citizens residing abroad. In July 
2004, the Bureau completed a test of the practicality of counting all 
overseas Americans. GAO was asked to assess (1) whether the Bureau 
implemented the test consistent with its design, and (2) the lessons 
learned from the test results. 

What GAO Found:

The Bureau generally implemented the overseas census test on schedule 
and consistent with its research design. Still, participation was poor, 
with just 5,390 questionnaires returned from the three test sites—
France, Kuwait, and Mexico. Moreover, because of the low response 
levels, obtaining those questionnaires proved to be quite expensive—
around $1,450 per response, which is far costlier on a unit basis than 
the 2000 Census. Although the two are not directly comparable because 
the 2000 Census included operations not used in the overseas test, the 
2000 Census cost around $56 per household. Further, boosting the 
response rate globally might not be practical. On the domestic front, 
during the 2000 Census, the Bureau spent $374 million on a months-long 
publicity campaign that consisted of television and other advertising 
that helped yield a 72-percent return rate. Replicating this level of 
effort on a worldwide basis would be difficult, and still would not 
produce a complete count. Ensuring a smooth overseas count could also 
stretch the Bureau’s resources. For example, at each test site the 
Bureau encountered various challenges that needed to be resolved such 
as French privacy laws. Moreover, managing a complex operation from 
thousands of miles away also proved difficult.

Enumerating Americans in Mexico and France: 

[See PDF for image]

[End of figure]

The approach used to count the overseas population in the 2004 test—a 
voluntary survey that largely relies on marketing to secure a complete 
count, lacks the basic building blocks of a successful census. The 
Bureau has done some initial research on alternatives, but all require 
more extensive review. Given that the Bureau already faces the 
difficult task of securing a successful stateside count in 2010, having 
to simultaneously count Americans abroad would only add to the 
challenges facing the Bureau.

What GAO Recommends:

Congress may wish to consider eliminating funding for additional 
research related to counting Americans abroad as part of the decennial 
census, including funding for tests planned in 2006 and 2008. However, 
funding for the evaluation of the 2004 test should continue as planned, 
particularly to inform congressional decision making on this issue. 
Should Congress desire better data on overseas Americans for certain 
policymaking and other nonapportionment purposes, Congress may wish to 
consider funding research on the feasibility of counting this group 
using alternatives to the decennial census. To facilitate this, we 
recommend that the Bureau, in consultation with Congress, research 
options such as a separate survey, administrative records, and data 
exchanges with other countries’ statistical agencies. The Bureau 
agreed with our conclusions and recommendations.

www.gao.gov/cgi-bin/getrpt?GAO-04-898.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Patricia A. Dalton at 
(202) 512-6806 or daltonp@gao.gov.

[End of section]

Contents:

Letter:

Results in Brief: 

Background: 

Scope and Methodology: 

2004 Overseas Test Was Generally Implemented as Designed: 

Overseas Census Test Results Were Disappointing and Costly: 

Conclusions: 

Matters for Congressional Consideration: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix:

Appendix I: Comments from the Department of Commerce: 

Tables: 

Table 1: Key Components of Overseas Enumeration Were Generally 
Implemented as Planned:

Table 2: Comparison of Responses Received for 2004 Overseas Census 
Test:

Figures: 

Figure 1: Key Decisions Facing Congress on Enumerating Americans 
Abroad:

Figure 2: Census Bureau Ads Placed in the International Herald Tribune: 

Figure 3: Census Materials Were Prominently Displayed in Various 
Locations in France and Mexico:

Figure 4: Key Building Blocks of a Successful Census:

Letter August 19, 2004:

The Honorable Adam H. Putnam: 
Chairman: 
The Honorable Wm. Lacy Clay: 
Ranking Minority Member: 
Subcommittee on Technology, Information Policy, Intergovernmental 
Relations and the Census: 
Committee on Government Reform: 
House of Representatives:

Although more than four million American citizens are believed to 
reside abroad, the precise number of overseas Americans is unknown. The 
U.S. Census Bureau (Bureau), the federal agency tasked with counting 
the nation's population every 10 years, has generally included in the 
census overseas members of the military, federal civilian employees, 
and their dependents (a group known collectively as "federally 
affiliated" individuals), but has typically excluded private citizens 
such as retirees, students, and business people.[Footnote 1]

Under the Constitution and federal statutes, the Bureau has discretion 
over whether to count Americans abroad. However, in recent years, the 
Bureau's policy of excluding private citizens from the decennial census 
has been called into question. For example, advocates of an overseas 
census claim that better demographic data on this population group 
would be useful for a variety of policy-making and business purposes, 
and would better represent their unique interests in Congress. 
Moreover, in January 2001, Utah sued the Bureau's parent agency, the 
U.S. Department of Commerce, claiming that it lost a congressional seat 
because the 2000 Census excluded the state's 11,000 Mormon missionaries 
and other private citizens living abroad.[Footnote 2] According to the 
Congressional Research Service, Utah would have gained a congressional 
seat had an additional 855 people been included in the state's 
apportionment totals.[Footnote 3] Utah's suit, however, was 
unsuccessful.

As we noted in our May 2004 report on this issue, counting Americans 
abroad as an integral part of the 2010 Census would be a monumental 
task that would introduce new resource demands, risks, and 
uncertainties to an endeavor that was already facing a variety of 
difficulties.[Footnote 4] Specific challenges include policy questions 
such as who should be counted and how should the data be used, as well 
as logistical difficulties such as ensuring a complete count and 
verifying U.S. citizenship.

To assess the practicality of counting overseas Americans, the Bureau 
held a test enumeration from February through July 2, 2004, in France, 
Kuwait, and Mexico. As agreed with your offices, we assessed (1) 
whether the Bureau implemented the test consistent with its design, and 
(2) the initial lessons learned from the test results and their 
implications for future overseas enumerations.

To address these objectives, we reviewed applicable planning and other 
documents, and interviewed knowledgeable Bureau officials and 
representatives of private organizations who helped the Bureau promote 
the census at the three test sites. Further, to review how the Bureau 
was implementing the census at the test locations, we made on-site 
inspections in Paris, France, and Guadalajara, Mexico. We conducted our 
work from March through July 2004, in accordance with generally 
accepted government auditing standards.

Results in Brief:

The Bureau generally implemented the 2004 overseas census test 
consistent with its research design. Key elements of the Bureau's plan, 
such as developing a questionnaire specifically for overseas Americans 
and launching a marketing campaign designed to publicize the test, were 
generally carried out as planned. Moreover, the test was conducted on 
schedule.

However, the response levels fell far short of what the Bureau planned 
for relative to the number of questionnaires it printed. For example, 
although the Bureau printed about 520,000 census forms for the three 
test sites--France, Kuwait, and Mexico--the actual number of paper 
responses it received only totaled 1,783, as of the end of the test in 
early July 2004. Another 3,607 responses were received via the 
Internet. Further, because of the low response levels, the data were 
expensive to obtain on a unit cost basis--around $1,450 per return. In 
contrast, the unit cost of the 2000 Census was about $56 per household. 
Although the 2000 Census costs are not directly comparable to the 2004 
overseas test because the 2000 test included operations not used in the 
overseas test, the 2000 Census was the most expensive census in our 
nation's history.

Further, substantially boosting overseas response levels might be 
infeasible. For example, during the 2000 Census, the Bureau spent $374 
million on a months-long publicity campaign that consisted of 
television, radio, and other forms of advertising that helped secure a 
72-percent return rate. Replicating this level of effort on a worldwide 
basis would be impractical at best, and would not produce a complete 
count. Indeed, even after the Bureau's aggressive publicity effort in 
2000, it still needed to follow-up with about 42 million households 
that did not complete their census forms.

Ensuring a smooth overseas count could also stretch the Bureau's 
resources, and thus detract from domestic efforts. For example, at each 
test site the Bureau encountered various difficulties that needed to be 
worked out. The difficulties included addressing French privacy laws 
and delivery problems in Kuwait. Moreover, managing a complex operation 
from thousands of miles away was also hard. This was particularly 
evident in the logistical challenges the Bureau had in overseeing the 
performance of the private firm hired to publicize the census at the 
three test sites.

The Bureau's longstanding experience in counting the nation's 
population has made it clear that a cost-effective census is assembled 
from key building blocks that include mandatory participation, a 
complete and accurate address list, and the ability to follow-up with 
nonrespondents. The approach the Bureau used to count the overseas 
population--a voluntary survey that relies heavily on marketing to 
secure a complete count--largely for reasons of practicality, lacks 
these building blocks, and it is unlikely that any refinements to this 
basic design would produce substantially better results. What's more, 
the Bureau already faces the difficult task of securing a successful 
stateside count in 2010. Having to count Americans abroad would only 
add to the challenges facing the Bureau.

Given the obstacles to a cost-effective count of overseas Americans as 
part of the decennial census, Congress may wish to consider eliminating 
funding for the research, planning, and development activities related 
to counting this population group using the Bureau's current approach, 
including funding for tests planned in 2006 and 2008. However, funding 
for the evaluation of the 2004 test should continue as planned because 
it could provide useful data to Congress. Moreover, should Congress 
determine that a count of overseas Americans might be useful for 
certain policy-making and other nonapportionment purposes, Congress may 
wish to consider authorizing and funding research on the feasibility of 
counting Americans abroad using alternatives to the decennial census.

To facilitate congressional decision making, we recommend that the 
Bureau, in consultation with Congress, research potential alternatives 
to the decennial census such as conducting a separate survey, examining 
how administrative records could be refined to produce a more accurate 
count of overseas Americans, and exchanging data with other countries' 
statistical agencies and censuses, subject to applicable 
confidentiality and other provisions. Once Congress knows the tradeoffs 
of these various options, it would be better positioned to provide the 
Bureau with the direction it needs so that the Bureau could then 
develop and test an approach that meets congressional requirements at 
reasonable resource levels.

The Secretary of Commerce forwarded written comments from the U.S. 
Census Bureau on a draft of this report. The comments are reprinted in 
the appendix.

The Bureau agreed with our conclusions and recommendations. 
Furthermore, the Bureau noted, "should Congress request and fund" 
further research on counting overseas Americans, it would be equipped 
to do that research itself.

Background:

According to the Bureau, no accurate estimate exists of the total 
number of Americans living abroad. The Constitution and federal law 
give the Bureau discretion to decide whether to count American citizens 
living abroad. In prior censuses, the Bureau has generally included 
"federally affiliated" groups--members of the military and federal 
employees and their dependents--but has excluded private citizens 
residing abroad from all but the 1960 and 1970 Censuses. The 2000 
Census, using administrative records, found 576,367 federally 
affiliated Americans residing overseas, including 226,363 military 
personnel, 30,576 civilian employees, and 319,428 dependents of both 
groups.

In response to congressional direction and the concerns of various 
private organizations, the Census Bureau launched a research and 
evaluation program to assess the practicality of counting both private 
and federally affiliated U.S. citizens residing abroad. The key part of 
this effort, the enumeration, took place from February 2004 through 
July 2, 2004, in France, Kuwait, and Mexico. To promote the overseas 
census test the Bureau relied on third parties--American organizations 
and businesses in the three countries--to communicate to their members 
and/or customers that an overseas enumeration of Americans was taking 
place and to make available to U.S. citizens either the paper 
questionnaire or Web site address.

Currently, the Bureau is processing and analyzing the overseas 
questionnaire data and plans to complete an evaluation of the test 
results in early 2005. The Bureau estimates that it will have spent 
approximately $7.8 million in fiscal years 2003 through 2005 to plan, 
conduct, and evaluate the 2004 test. The Bureau has requested 
additional funds for fiscal year 2005 to plan for further testing 
scheduled for 2006. The Bureau also plans to include overseas testing 
in the 2008 dress rehearsal if it were to receive the necessary 
funding.[Footnote 5]

In May 2004 we reported on the design of the overseas enumeration test 
and concluded that because of various methodological limitations, the 
test results will only partially answer the Bureau's key research 
objectives concerning feasibility (as measured by such indicators as 
participation and number of valid returns), data quality, and cost. 
Further, we noted that the Bureau should not decide on its own whether 
or not to enumerate Americans overseas, and in fact would need 
congressional guidance on how to proceed. As shown in figure 1, the key 
decisions facing Congress in this regard include, in addition to the 
threshold question of whether American residing overseas should be 
counted, how the data should be used and whether to enumerate this 
population group as part of the decennial census.

Figure 1: Key Decisions Facing Congress on Enumerating Americans 
Abroad:

[See PDF for image]

[End of figure]

We also recommended that if further testing were to occur, that the 
Bureau resolve the shortcomings of the design of the 2004 test and 
better address the objectives of an overseas enumeration.

Scope and Methodology:

As agreed with your offices, our objectives for this report were to 
assess (1) whether the Bureau implemented the test consistent with its 
design, and (2) the initial lessons learned from the test results and 
their implications for future overseas enumerations. To assess the 
first objective, we interviewed Bureau officials and compared the 
Bureau's test plans with what was actually done at the three test 
sites. We visited Paris, France, and Guadalajara, Mexico, to obtain the 
views of 12 private, civic, and other organizations on the 
implementation of the overseas census test, and/or to confirm at 36 
organizations the availability of census material. In addition, to a 
more limited extent, we interviewed officials from third party 
organizations in Kuwait via the telephone or e-mail. We judgmentally 
selected these organizations because they had agreed to display census 
promotional materials and, in some cases, had also agreed to do one or 
more of the following activities: make available paper copies of the 
census questionnaire, publish information in a newsletter, post a link 
to a Web site, send outreach e-mail to members, and/or create speaking 
opportunities to discuss the census. The results of these visits are 
not necessarily representative of the larger universe of third-party 
organizations.

To assess the implications of the test results on future overseas 
enumerations and the 2010 census, we obtained from Bureau officials 
preliminary results of the overseas census by test site and response 
mode as well as cost data. We also interviewed officials from the 
Bureau and third-party organizations to determine what lessons were 
learned from the test and the implications on future overseas 
enumeration efforts.

2004 Overseas Test Was Generally Implemented as Designed:

The Bureau's design for the 2004 overseas enumeration test was 
generally implemented as planned and completed on schedule. The 
Bureau's design had four key components: the mode of response, the 
questionnaire designed specifically for Americans living overseas, 
three test sites, and an outreach and promotion program designed to 
communicate and educate Americans abroad that a test census was being 
conducted. Table 1 describes each of these components in greater 
detail.

Table 1: Key Components of Overseas Enumeration Were Generally 
Implemented as Planned:

Key overseas test component: Census form response mode; 
What the Bureau planned: Census questionnaire will be available in 
paper format or via the Internet; 
Generally implemented as planned? Yes; 
GAO observations: Paper version of the census form was available at 
various locations at the test sites; Questionnaire was available for 
completion on the Internet; Paper version was also available in 
Spanish in Mexico.

Key overseas test component: Census test questions; 
What the Bureau planned: 2000 decennial short form questionnaire will 
be modified for the overseas enumeration; 
Generally implemented as planned? Yes; 
GAO observations: Asked respondents to provide their passport numbers 
and social security numbers to verify citizenship; Asked respondents 
about their employment status--military, federal, or other; Asked for 
information on everyone in the household even if the person was not a 
U.S. citizen.

Key overseas test component: Test sites; 
What the Bureau planned: Conduct test in three geographically diverse 
areas with large American populations, and where administrative records
may be available to help verify results; 
Generally implemented as planned? Yes; 
GAO observations: Overseas test was implemented in three countries: 
France, Kuwait, and Mexico.

Key overseas test component: Outreach/Promotion; 
What the Bureau planned: Contract with a public relations firm to 
develop a communications strategy to inform and motivate respondents 
living in the selected countries to answer the census; 
Generally implemented as planned? Yes; 
GAO observations: Public relations firm hired to develop a 
communication strategy; Strategy relied on public and private 
organizations in each of the test sites; Organizations displayed 
promotional materials about the test, communicated test census to 
members, and distributed the paper census forms to American residents. 

Source: GAO.

[End of table]

However, while the test was generally implemented as designed, our 
earlier report pointed out several methodological limitations with the 
design, such as not being able to calculate response rates because the 
universe of Americans is unknown or not being able to measure the 
quality of data because of the impracticality of developing an address 
list. As we discuss later in this report, it is these methodological 
limitations that impede the Bureau's ability to implement a successful 
overseas enumeration.

Overseas Census Test Results Were Disappointing and Costly:

Although the 2004 overseas enumeration test ended in early July 2004 
and the Bureau has just begun evaluating the results, the response 
levels were poor, and very expensive to obtain on a per unit basis. The 
response level to the overseas enumeration suggests that the current 
approach to counting overseas Americans--a voluntary survey that relies 
heavily on marketing to get people to participate--by itself cannot 
secure a successful head count. Further, obtaining the additional 
resources needed to produce substantially better results may not be 
feasible, and still not yield data that are comparable in quality to 
the stateside enumeration.

Response Levels Were Disappointing and Costly to Obtain:

The 5,390 responses the Bureau received for this test were far below 
what the Bureau planned for when printing up materials and census 
forms. While the Bureau ordered 520,000 paper forms for three test 
sites, only 1,783 census forms were completed and returned. Of these, 
35 were Spanish language forms that were made available in Mexico. The 
remaining 3,607 responses were completed via the Internet. Table 2 
below shows the number of census questionnaires that the Bureau printed 
for each country and the number of responses they actually received in 
both the paper format and via the Internet.

Table 2: Comparison of Responses Received for 2004 Overseas Census 
Test:

Test sites: Mexico; 
Number of forms printed for each test site: 430,000[A]; 
Number of responses by mode: Paper: 869[B]; 
Number of responses by mode: Internet: 1,130; 
Total number of responses received: 1,999.

Test sites: France; 
Number of forms printed for each test site: 75,000; 
Number of responses by mode: Paper: 886; 
Number of responses by mode: Internet: 2,219; 
Total number of responses received: 3,105.

Test sites: Kuwait; 
Number of forms printed for each test site: 15,000; 
Number of responses by mode: Paper: 28; 
Number of responses by mode: Internet: 258; 
Total number of responses received: 286.

Total; 
Number of forms printed for each test site: 520,000; 
Number of responses by mode: Paper: 1,783; 
Number of responses by mode: Internet: 3,607; 
Total number of responses received: 5,390. 

Source: U.S. Census Bureau.

[A] This includes 100,000 forms printed in Spanish.

[B] This includes 35 Spanish forms returned.

[End of table]

Because of the low response levels, in early April 2004, the Bureau 
reversed its decision to not use paid advertising and in May 2004 
initiated a paid advertising campaign in France and Mexico. This 
included print and Internet ads in France and print and radio ads in 
Mexico. See figure 2 for examples of the ads used in the paid 
advertising campaign.

Figure 2: Census Bureau Ads Placed in the International Herald Tribune:

[See PDF for image]

[End of figure]

A Bureau official told us the ad campaign for the 2004 overseas test 
cost about $206,000. This official said there were surplus funds 
available in the project budget to use for this purpose due to lower 
than expected processing and postage costs for the overseas test. While 
the Bureau saw some increase in the number of responses after the paid 
advertising campaign began, this official said the increase was slight.

Return on Investment for Overseas Enumeration is Low:

Not only were response levels low, they were extremely expensive to 
obtain on a unit basis--roughly $1,450 for each returned questionnaire, 
based on the $7.8 million the Bureau spent preparing for, implementing, 
and evaluating the 2004 overseas test. In contrast, the unit cost of 
the 2000 Census was about $56 per household. Although the two surveys 
are not directly comparable because the 2000 Census costs covered 
operations not used in the overseas test, the 2000 Census was still the 
most expensive census in our nation's history.

Securing a Higher Return Rate Would Be an Enormous Challenge:

The main reason for the high unit cost is the low return rate. However, 
significantly boosting participation levels may not be feasible. The 
Bureau's experience in the 2000 Census highlights the level of effort 
that was needed to raise public awareness about the census and get 
people to complete their forms. For the 2000 decennial, the Bureau 
spent $374 million on a comprehensive marketing, communications, and 
partnership effort. The campaign consisted of a five-part strategy 
conducted in three waves beginning in the fall of 1999 and continuing 
past Census Day (April 1, 2000). The effort helped secure a 72-percent 
return rate. Specific elements included television, radio, and other 
mass media advertising; promotions and special events; and a census-in-
schools program. Thus, over a period of several months, the American 
public was on the receiving end of a steady drumbeat of advertising 
aimed at publicizing the census and motivating them to respond.

The Bureau also filled 594 full-time partnership specialist positions. 
These individuals were responsible for mobilizing support for the 
census on a grassroots basis by working with governmental entities, 
private companies, and religious and social service groups, and other 
organizations.

Replicating this level of effort on a worldwide basis would be 
impractical, and still would not produce a complete count. Indeed, even 
after the Bureau's aggressive marketing effort in 2000, it still had to 
follow-up with about 42 million households that did not return their 
census forms. Moreover, because there are no reliable figures on the 
number of Americans residing overseas, the Bureau would not have a good 
measure of the number of people that did not participate, or the 
overall quality of the data.

Ensuring a Smooth Overseas Enumeration Could Stretch the Bureau's 
Resources:

The Bureau's experience in conducting the 2004 overseas test 
underscored the difficulties of administering a complex operation from 
thousands of miles away. Not surprisingly, as with any operation this 
complex, various challenges and unforeseen problems arose. While the 
Bureau was able to resolve them, its ability to do so should there be a 
full overseas enumeration as part of the 2010 Census, would be highly 
questionable as far more resources would be required. This was 
particularly evident in at least two areas: grappling with country-
specific issues and overseeing the contractor responsible for raising 
public awareness of the census at the three test sites.

Country-specific Issues Created Implementation Problems:

The Bureau encountered a variety of implementation problems at each of 
the test sites. In some cases the problems were known in advance, in 
others, glitches developed at the last minute. Although such 
difficulties are to be expected given the magnitude of the Bureau's 
task, a key lesson learned from the test is that there would be no 
economy of scale in ramping up to a full enumeration of Americans 
abroad. In fact, just the opposite would be true. Because of the 
inevitability of country-specific problems, rather than conducting a 
single overseas count based on a standard set of rules and procedures 
(as is the case with the stateside census), the Bureau might end up 
administering what amounts to dozens of separate censuses--one for each 
of the countries it enumerates--each with its own set of procedures 
adapted to each country's unique requirements. The time and resources 
required to do this would likely be overwhelming and detract from the 
Bureau's stateside efforts.

For example, during the overseas test, the Bureau found that French 
privacy laws restrict the collection of personal data such as race and 
ethnic information. However, these data are collected as part of the 
decennial census because they are key to implementing a number of civil 
rights laws such as the Voting Rights Act.

Addressing France's privacy laws took a considerable amount of 
negotiation between the two countries, and was ultimately resolved 
after a formal agreement was developed. The Bureau issued and posted on 
its Web site an advisory that informed Americans living in France that 
it was not mandatory to respond to the questionnaire, the only 
recipient of the collected data is the Census Bureau, the data will be 
kept for one year, and the respondent has a right to access and correct 
the data collected. The Bureau was able to collect race and ethnic 
data--generally a prohibited practice without the respondents' 
permission--only after it received special approval from a French 
government agency. Initially, however, it looked as if the Bureau might 
have to redesign the census form if it wanted to use it in France.

In Kuwait, delivery of the census materials was delayed by several 
weeks at the beginning of the test because they were accidentally 
addressed to the wrong contractor. Ultimately, the U.S. Embassy 
stepped-in to accept the boxes so that the enumeration could proceed. 
In Mexico, there was some initial confusion on the part of Mexican 
postal workers as to whether they could accept the postage-paid 
envelopes that the Bureau had provided to return the paper 
questionnaires for processing in the United States.

Because of the small number of countries involved in the test, the 
Bureau was able to address the various problems it encountered. Still, 
the Bureau's experience indicates that it will be exceedingly difficult 
to identify and resolve in advance all the various laws, rules, 
societal factors, and a host of other potential glitches that could 
affect a full overseas enumeration.

On-site Supervision of Contractor Was Problematic:

As noted previously, the Bureau hired a public relations firm to 
develop a communications strategy to inform and motivate respondents 
living in the test countries to complete the census. The firm's 
responsibilities included identifying private companies, religious 
institutions, service organizations, and other entities that have 
contact with Americans abroad and could thus help publicize the census 
test. Specific activities the organizations could perform included 
displaying promotional materials and paper versions of the census 
questionnaire, publishing information in a newsletter, and posting 
information on their Web sites. Although the public relations firm 
appeared to go to great lengths to enlist the participation of these 
various entities--soliciting the support of hundreds of organizations 
in the three countries--the test revealed the difficulties of 
adequately overseeing a contractor operating in multiple sites 
overseas.

For example, the public relations firm's tracking system indicated that 
around 440 entities had agreed to perform one or more types of 
promotional activities. However, our on-site inspections of several of 
these organizations in Paris, France, and Guadalajara, Mexico, that had 
agreed to display the census materials and/or distribute the 
questionnaires, uncovered several glitches. Of the 36 organizations we 
visited that were supposed to be displaying promotional literature, we 
found the information was only available at 15. In those cases, as 
shown in figure 3, the materials were generally displayed in prominent 
locations, typically on a table with posters on a nearby wall.

Figure 3: Census Materials Were Prominently Displayed in Various 
Locations in France and Mexico:

[See PDF for image]

[End of figure]

Five of these 15 organizations were also distributing the census 
questionnaire, but the forms were not readily accessible.

However, at 21 sites we visited, we found various discrepancies between 
what the public relations firm indicated had occurred, and what 
actually took place. For example, while the firm's tracking system 
indicated that questionnaires would be available at a restaurant and an 
English-language bookstore in Guadalajara, none were available. In 
fact, the owner of the bookstore told us that no one from the Census 
Bureau or the public relations firm had contacted her about displaying 
materials for the overseas test.

At the University of Guadalajara, although the tracking system 
indicated that an official had been contacted about, and agreed to help 
support the census test, that official told us no one had contacted 
him. As a result, when boxes of census materials were delivered to his 
school without any explanatory information, he did not know what to do 
with them, and had to telephone the U.S. Consulate in Guadalajara to 
figure out what they were for.

Likewise, in Paris, we went to several locations where the tracking 
system indicated that census information would be available. None was. 
In fact, at some of these sites, not only was there no information 
about the census, but there was no indication that the organization we 
were looking for was at the address we had from the database.

The results of the overseas test point to the difficulties of 
overseeing the contractor's performance. As census materials were made 
available at scores of locations across the three test countries, it 
would have been impractical for the Bureau to inspect each site. The 
difficulty of supervising contractors--and any field operation for that 
matter--would only be magnified in a global enumeration.

The Design of the Overseas Census Lacks the Building Blocks of a 
Successful Census:

The Bureau's experience in counting the nation's population for the 
2000 and earlier censuses sheds light on some of the specific 
operations and other elements that together form the building blocks of 
a successful head count (see fig. 4).

Figure 4: Key Building Blocks of a Successful Census:

[See PDF for image]

[End of figure]

While performing these activities does not necessarily guarantee a 
cost-effective headcount, not performing them makes a quality count far 
less promising and puts the entire enterprise at risk. The current 
approach to counting overseas Americans lacks these building blocks, as 
most are infeasible to perform on an overseas population. Each is 
discussed in greater detail below.

* Mandatory participation: Under federal law, all persons residing in 
the United States regardless of citizenship status are required to 
respond to the decennial census. By contrast, the overseas enumeration 
test was conducted as a voluntary survey where participation was 
optional. The Bureau has found that response rates to mandatory surveys 
are higher than the response rates to voluntary surveys. This in turn 
yields more complete data and helps hold down costs.

* Early agreement on design: Both Congress and the Bureau need to agree 
on the fundamental design of an overseas census. Concurrence on the 
design helps ensure adequate planning, testing and funding levels. 
Conversely, the lack of an agreed-upon design raises the risk that 
basic design elements might change in the years ahead, while the 
opportunities to test those changes and integrate them with other 
operations will diminish. Under the Bureau's current plans, after the 
2006 test, the Bureau would have just one more opportunity to test its 
prototype for an overseas enumeration--a dress rehearsal in 2008. Any 
design changes after 2008 would not be tested in a real-world 
environment. The design of the census is driven in large part by the 
purposes for which the data will be used. Currently, no decisions have 
been made on whether the overseas data will be used for purposes of 
congressional apportionment, redistricting, allocating federal funds, 
or other applications. Some applications, such as apportionment, would 
require precise population counts and a very rigorous design that 
parallels the stateside count. Other applications, however, could get 
by with less precision and thus, a less stringent approach. As we noted 
previously, Congress will need to decide whether or not to count 
overseas Americans, and how the results should be used. The basis for 
these determinations needs to be sound research on the cost, quality of 
data, and logistical feasibility of the range of options for counting 
this population group. Possibilities include counting Americans via a 
separate survey, administrative records such as passport and voter 
registration forms, and/or records maintained by other countries such 
as published census records and work permits. The Bureau's initial 
research has shown that each of these options has coverage, accuracy, 
and accessibility issues, and some might introduce systemic biases into 
the data. Far more extensive research would be needed to determine the 
feasibility of these or other potential approaches. Once Congress knows 
the tradeoffs of these various alternatives, it will be better 
positioned to provide the Bureau with the guidance it needs to go 
beyond research and conduct field tests of specific approaches. The 
Bureau can conduct the research, or it can contract it out. Indeed, the 
National Research Council of the National Academy of Sciences has 
conducted a number of studies on the decennial census, including a 
review of the 2000 Census and an examination of reengineering the 2010 
Census.

* A complete and accurate address list: The cornerstone of a successful 
census is a quality address list. For the stateside census, the Bureau 
goes to great lengths to develop what is essentially an inventory of 
all known living quarters in the United States, including sending 
census workers to canvass every street in the nation to verify 
addresses. The Bureau uses this information to deliver questionnaires, 
follow up with nonrespondents, determine vacancies, and identify 
households the Bureau may have missed or counted more than once. 
Because it would be impractical to develop an accurate parallel address 
list for overseas Americans, these operations would be impossible and 
the quality of the data would suffer as a result.

* Ability to detect invalid returns: Ensuring the integrity of the 
census data requires the Bureau to have a mechanism to screen out 
invalid responses. Stateside, the Bureau does this by associating an 
identification number on the questionnaire to a specific address in the 
Bureau's address list, as well as by field verification. However, the 
Bureau's current approach to counting overseas Americans is unable to 
determine whether or not a respondent does in fact reside abroad. So 
long as a respondent provides certain pieces of information on the 
census questionnaire, it will be eligible for further processing. The 
Bureau is unable to confirm the point of origin for questionnaires 
completed on the Internet, and postmarks on a paper questionnaire only 
tell the location from which a form was mailed, not the place of 
residence of the respondent. The Bureau has acknowledged that ensuring 
such validity might be all but impossible for any reasonable level of 
effort and funding.

* Ability to follow up with non-respondents: Because participation in 
the decennial census is mandatory, the Bureau sends enumerators to 
those households that do not return their questionnaires. In cases 
where household members cannot be contacted or refuse to answer all or 
part of a census questionnaire, enumerators are to obtain data from 
neighbors, a building manager, or other nonhousehold member presumed to 
know about its residents. The Bureau also employs statistical 
techniques to impute data when it lacks complete information on a 
household. Thus, by the end of each decennial census, the Bureau has a 
fairly exhaustive count of everyone in the nation. As noted above, 
because the Bureau lacks an address list of overseas Americans, it is 
unable to follow up with nonrespondents or impute information on 
missing households. As a result, the Bureau will never be able to 
obtain a complete count of overseas Americans.

* Cost model for estimating needed resources: The Bureau uses a cost 
model and other baseline data to help it estimate the resources it 
needs to conduct the stateside census. Key assumptions such as response 
levels and workload are developed based on the Bureau's experience in 
counting people decade after decade. However, the Bureau has only a 
handful of data points with which to gauge the resources necessary for 
an overseas census, and the tests it plans on conducting will only be 
of limited value in modeling the costs of conducting a worldwide 
enumeration in 2010. The lack of baseline data could cause the Bureau 
to over-or underestimate the staffing, budget and other requirements of 
an overseas count. For example, this was evident during the 2004 
overseas test when the Bureau estimated it would need around 100,000 
Spanish-language questionnaires for the Mexican test site. As only 35 
Spanish-language questionnaires were returned, it is now clear that the 
Bureau could have gotten by with printing far fewer questionnaires for 
Mexico. However, the dilemma for the Bureau is that its experience in 
the 2004 overseas test cannot be used to project the number of Spanish-
language questionnaires it would need for Mexico or other Spanish-
speaking countries in 2010. Similar problems would apply to efforts to 
enumerate other countries.[Footnote 6]

* Targeted and aggressive marketing campaign: The key to raising public 
awareness of the census is an intensive outreach and promotion 
campaign. As noted previously, the Bureau's marketing efforts for the 
2000 Census were far-reaching, and consisted of more than 250 ads in 17 
languages that were part of an effort to reach every household, 
including those in historically undercounted populations. Replicating 
this level of effort on a global scale would be both difficult and 
expensive, and the Bureau has no plans to do so.

* Field infrastructure to execute census and deal with problems: The 
Bureau had a vast network of 12 regional offices and 511 local census 
offices to implement various operations for the 2000 Census. This 
decentralized structure enabled the Bureau to carry out a number of 
activities to help ensure a more complete and accurate count, as well 
as deal with problems when they arose. Moreover, local census offices 
are an important source of intelligence on the various enumeration 
obstacles the Bureau faces on the ground. For example, during the 2000 
Census, the Bureau called on them to identify hard-to-count population 
groups and other challenges, and to develop action plans to address 
them. The absence of a field infrastructure for an overseas census 
means that the Bureau would have to rely heavily on contractors to 
conduct the enumeration, and manage the entire enterprise from its 
headquarters in Suitland, Maryland.

* Ability to measure coverage and accuracy: Since 1980, the Bureau has 
measured the quality of the decennial census using statistical methods 
to estimate the magnitude of any errors. The Bureau reports these 
estimates by specific ethnic, racial, and other groups. For 
methodological reasons, similar estimates cannot be generated for an 
overseas census. As a result, the quality of the overseas count, and 
thus whether the numbers should be used for specific purposes, could 
not be accurately determined.

Conclusions:

The 2004 test of the feasibility of an overseas enumeration was an 
extremely valuable exercise in that it highlighted the numerous 
obstacles to a cost-effective count of Americans abroad as an integral 
part of the decennial census. Although more comprehensive results will 
not be available until the Bureau completes its evaluation of the test 
early next year, a key lesson learned is already clear: The current 
approach to counting this population group--a voluntary survey that 
largely relies on marketing to ensure a complete count--would be costly 
and yield poor results. The tools and resources the Bureau has on hand 
to enumerate overseas Americans are insufficient for overcoming the 
inherent obstacles to a complete count, and it is unlikely that any 
refinements to this basic design would produce substantially better 
results, and certainly not on a par suitable for purposes of 
congressional apportionment.

What's more, the Bureau already faces the difficult task of carrying 
out a cost-effective stateside enumeration in 2010. Securing a 
successful count of Americans in Vienna, Virginia, is challenging 
enough; a complete count of Americans in Vienna, Austria--and in scores 
of other countries around the globe--would only add to the difficulties 
facing the Bureau as it looks toward the next national head count. As a 
result, we believe that any further tests or planning activities 
related to counting Americans overseas as part of the decennial census 
would be an imprudent use of the Bureau's limited resources.

That said, to the extent that Congress desires better data on the 
number and characteristics of Americans abroad for various policy-
making and other nonapportionment purposes that require less precision, 
such information does not necessarily need to be collected as part of 
the decennial census, and could, in fact, be acquired through a 
separate survey or other means. To help inform congressional decision 
making on this issue, including decisions on whether Americans should 
be counted and how the data should be used, it will be important for 
Congress to have the results of the Bureau's evaluation of the 2004 
overseas census test. Equally important would be information on the 
cost, quality of data, and logistical feasibility of counting Americans 
abroad using alternatives to the decennial census. Once Congress knows 
the tradeoffs of these various alternatives, it would be better 
positioned to provide the Bureau with the direction it needs so that 
the Bureau could then develop and test an approach that meets 
congressional requirements at reasonable resource levels.

Matters for Congressional Consideration:

Given the obstacles to a cost-effective count of overseas Americans as 
part of the decennial census and, more specifically, obtaining data 
that is of sufficient quality to be used for congressional 
apportionment, Congress may wish to consider eliminating funding for 
any additional research, planning, and development activities related 
to counting this population as part of the decennial headcount, 
including funding for tests planned in 2006 and 2008. However, funding 
for the evaluation of the 2004 test should continue as planned to help 
inform congressional decision making.

Should Congress still desire better data on the number of overseas 
Americans, in lieu of the method tested in 2004, Congress might wish to 
consider authorizing and funding research on the feasibility of 
counting Americans abroad using alternatives to the decennial census.

Recommendations for Executive Action:

To facilitate congressional decision making, we recommend that the 
Secretary of Commerce ensure that the Bureau completes its evaluation 
of the 2004 overseas census test as planned. Further, to the extent 
that additional research is authorized and funded, the Bureau, in 
consultation with Congress, should explore the feasibility of counting 
overseas Americans using alternatives to the decennial census. 
Potential options include:

* conducting a separate survey,

* examining how the design and archiving of various government agency 
administrative records might need to be refined to facilitate a more 
accurate count of overseas Americans, and:

* exchanging data with other countries' statistical agencies and 
censuses, subject to applicable confidentiality and other provisions.

Consideration should also be given to whether the Bureau should conduct 
this research on its own or whether it should be contracted out to the 
National Academy of Sciences.

Agency Comments and Our Evaluation:

The Secretary of Commerce forwarded written comments from the U.S. 
Census Bureau on a draft of this report on August 5, 2004, which are 
reprinted in the appendix. The Bureau agreed with our conclusions and 
recommendations. Furthermore, the Bureau noted, "should Congress 
request and fund" further research on counting overseas Americans, it 
would be equipped to do that research itself.

As agreed with your offices, unless you release 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, and the Director 
of the U.S. Census Bureau. Copies will be made available to others upon 
request. This report will also be available at no charge on GAO's Web 
site at [Hyperlink, http://www.gao.gov].

If you or your staff have any questions concerning this report, please 
contact me on (202) 512-6806 or by e-mail at 
[Hyperlink, daltonp@gao.gov] or Robert Goldenkoff, Assistant Director, 
at (202) 512-2757 or [Hyperlink, goldenkoffr@gao.gov]. Key 
contributors to this report were Ellen Grady, Lisa Pearson, and 
Timothy Wexler.

Signed by: 

Patricia A. Dalton: 
Director: 
Strategic Issues:

[End of section]

Appendixes: 

Appendix I: Comments from the Department of Commerce:

THE SECRETARY OF COMMERCE:
Washington, D.C. 20230:

Ms. Patricia A. Dalton: 
Director, Strategic Issues: 
U.S. Government Accountability Office: 
Washington, DC 20548:

Dear Ms. Dalton:

The U.S. Department of Commerce appreciates the opportunity to comment 
on the U.S. Government Accountability Office draft report entitled 2010 
Census: Counting Americans Overseas as Part of the Decennial Census 
Would Not Be Cost-Effective. The Department's comments on this report 
are enclosed.

Sincerely,

Signed by: 

Donald L. Evans: 

Enclosure:

Comments from the U.S. Department of Commerce Regarding the U.S. 
Government Accountability Office Draft Report Entitled 2010 Census: 
Counting Americans Overseas as Part of the Decennial Census Would Not 
Be Cost-Effective:

Thank you for providing us the opportunity to comment on your draft 
report, 2010 Census: Counting Americans Overseas as Part of the 
Decennial Census Would Not Be Cost-Effective.

Comments on Conclusions:

We agree with the draft report that the 2004 Overseas Census Test was 
an extremely valuable exercise that highlighted the numerous obstacles 
to a cost-effective count of Americans abroad as an integral part of 
the decennial census.

Comments on Recommendations for Executive Action:

"To facilitate congressional decision-making, we recommend that the 
Secretary of Commerce ensure that the Bureau completes its evaluation 
of the 2004 overseas census test as planned."

The Census Bureau concurs with this recommendation.

"Further, to the extent that further research is authorized and funded, 
the Bureau, in consultation with Congress, should research the 
feasibility of counting overseas Americans using alternatives to the 
decennial census. Potential options include ... a separate survey ... 
administrative records, and ... [data exchange with other countries]. 
Consideration should also be given as to whether the Bureau should 
conduct this research on its own or whether it should be contracted out 
to the National Academy of Sciences."

The Census Bureau is equipped to conduct this research, should Congress 
request and fund it. 

[End of section]

(450315):

FOOTNOTES

[1] Only the 1970, 1990, and 2000 Censuses used counts of federally 
affiliated personnel for purposes of apportioning Congress.

[2] Utah v. Evans, 143 F. Supp. 2d 1290 (D. Utah 2001), aff'd, Utah v. 
Evans, 534 U.S. 1038 (2001).

[3] Congressional Research Service, House Apportionment: Could Census 
Corrections Shift a House Seat?, RS21638 (Washington, D.C.: Oct. 8, 
2003).

[4] GAO, 2010 Census: Overseas Enumeration Test Raises Need for Clear 
Policy Direction, GAO-04-470 (Washington, D.C.: May 21, 2004).

[5] At this point, the Bureau does not have cost data beyond fiscal 
year 2005. Therefore, it is unknown what the costs will be for 
implementing and evaluating the 2006 overseas test or the 2008 overseas 
dress rehearsal.

[6] The Bureau plans to destroy all unused questionnaires for the 2004 
test.

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