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Congressional Requesters:

United States Government Accountability Office:

GAO:

October 2004:

American Community Survey:

Key Unresolved Issues:

GAO-05-82:

GAO Highlights:

Highlights of GAO-05-82, a report to congressional requesters:

Why GAO Did This Study:

The Congress asked GAO to review operational and programmatic aspects 
of the Census Bureau’s ACS that will affect the reliability of small 
geographic area data. The ACS will be a mail survey of about
3 million households annually, whose results will be cumulated over 5 
years to produce estimates that will replace information previously 
provided by the Decennial Census long form. In addition, annual data 
will be published for geographic areas with 65,000+ populations and as 
3-year averages for areas with populations of 20,000 to 65,000. Annual 
data will be published beginning in 2006 with data for 2005. The 5-year 
averages for 2008–12 will provide data for small geographic areas.

What GAO Found:

The Census Bureau’s development of the American Community Survey goes 
back several decades and has included intensive research and field 
testing programs, as well as substantial outreach efforts, in 
particular through the reports and workshops at the National Academy of 
Sciences (NAS). However, if the ACS is to be an adequate replacement 
for the Decennial Census long form as the major source of data on small 
geographic areas and if it is to provide similar annual data for larger 
areas, the Census Bureau will need to

* incorporate in a timely manner the resolution of issues it has 
already identified in the ACS testing and 2000 Decennial Census 
evaluation programs, such as the residence concept, group quarters, and 
questions on disability;

* complete the ACS testing plan as originally planned, such as the 
comparison and evaluation of long form–ACS supplementary survey data at 
the state level, to identify other unresolved issues and to provide 
information for users of 2000 Decennial Census long-form data that will 
be necessary for the transition to the full ACS;

* evaluate and consult with stakeholders and users on the resolution of 
issues identified in this report, such as the methodology for deriving 
population and housing controls, guidance for users on the impact of 
the characteristics of multiyear averages for small geographic areas, 
and the presentation of dollar-denominated values;

* coordinate the results of the testing program for the 2010 Decennial 
Census short form with the ACS implementation schedule; and 

* resolve all issues so that the ACS estimates beginning with 2008 are 
consistent with the ACS estimates for 2009–12 and with the 2010 Census 
short form.

Although the Census Bureau has solicited advice from external 
stakeholders and users and has supported research by its own staff on 
most of the issues identified in this report, there is no indication 
that the Census Bureau has yet followed this advice or implemented 
plans for consultation on resolving these issues. In addition, it has 
been more than a year since the Census Bureau announced that it was 
looking into establishing an ACS partnership program that would involve 
advisory groups and expert panels to improve the program, but no such 
program has been established. 

Another issue related to the proposed ACS is how the Census Bureau 
might provide more timely and reliable small geographic area data. This 
goal could be accomplished, but it would require additional funding. 
The most direct approach would be to increase the sample size for 2009–
11. This increase would enable the Bureau to provide small geographic 
area data that would be the replacement for the 2010 Census long form 
1 year earlier.

What GAO Recommends:

The Secretary of Commerce should direct the Census Bureau to revise the 
ACS evaluation and testing plan, focusing on issues GAO identifies; 
give stakeholders meaningful input on related decisions; and make the 
underlying information public. The Secretary should direct the Bureau 
to set a schedule for incorporating operational and programmatic 
changes into the 5-year averages for 2008–12.

In commenting on a draft of this report, the Secretary stated that 
Commerce has already addressed most of the key issues we identified in 
this report. We believe, however, that the matters are not being fully 
addressed and need further attention by Commerce.

[End of section]

Contents:

Letter:

Results in Brief:

Background:

Outstanding Issues Jeopardize ACS's Replacement of the Long Form:

Improving Timeliness and Quality of Small Geographic Area Data Would 
Increase Costs:

Resolving Outstanding Issues Needs a Time Schedule:

Conclusions:

Recommendations for Executive Action:

Agency Comments and Our Evaluation:

Appendix I: Scope and Methodology:

Appendix II: Recent NAS Findings on Continuous Measurement and the ACS:

1998 NAS Workshop on the ACS:

2000 Interim Report:

2001 Letter Report:

2003 Interim Report:

The 2000 Census: Counting under Adversity:

Appendix III: The Decennial Census Long Form and the Evolution of the 
ACS Plan:

Decennial Census Long Form:

Evolution of ACS Plan:

Appendix IV: Continuous Measurement ACS Testing and Development 
Program:

Appendix V: Current Status of Unresolved Issues:

Independent Controls for Population and Housing Characteristics:

Operational Issues:

Valuation and Presentation of Dollar-Denominated Data Items:

Evaluations of ACS, Long-Form, and CPS Data Comparisons:

Information on Key Properties of Multiyear Averages:

External Consultation:

Appendix VI: Comments from the Department of Commerce:

Appendix VII: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Staff Acknowledgments:

Bibliography:

History of the Long Form and Mid-Decade Census:

Census Bureau ACS Reports:

Census Bureau Advisory Committee Presentations:

Census Bureau Continuous Measurement Series:

Census Bureau Internal Reports:

Census 2000 Evaluation Reports:

Census Bureau 2003 JSM Staff Papers:

Other Census Bureau Staff Research Papers:

Association of Public Data Users Papers:

Congressional Hearings and Testimony:

Other Reports and Papers:

Related GAO Products:

Tables:

Table 1: ACS Milestone Events and Unresolved Issues, 2004-13:

Table 2: Continuous Measurement and ACS Funding, Fiscal Years 1995-
2005:

Table 3: The 2000 Census Long Form and ACS Use of Independent Controls 
for Population and Housing Characteristics:

Table 4: Population Comparison for Counties in 2000 from ICPE and 2000 
Census by County Size:

Abbreviations:

ACS: American Community Survey: 
ASA: American Statistical Association: 
BEA: Bureau of Economic Analysis: 
BLS: Bureau of Labor Statistics:
C2SS: Census 2000 Supplementary Survey: 
CM: Continuous Measurement: 
CPI: Consumer Price Index: 
CPS: Current Population Survey: 
HUD: Department of Housing and Urban Development: 
ICPE: Intercensal Population Estimates: 
NAS: National Academy of Sciences: 
OMB: Office of Management and Budget:

United States Government Accountability Office:

Washington, DC 20548:

October 8, 2004:

The Honorable Tom Davis, Chairman: 
The Honorable Henry Waxman, Ranking Minority Member: 
Committee on Government Reform:
House of Representatives:

The Honorable William Lacy Clay, Ranking Minority Member: 
Subcommittee on Technology, Information Policy, Intergovernmental 
Relations, and the Census: 
Committee on Government Reform:
House of Representatives:

The Honorable Adam Putnam: 
House of Representatives:

The Census Bureau has designed the 2010 Decennial Census around three 
new operations. One will replace the Census long-form questionnaire 
with the American Community Survey (ACS).[Footnote 1] Testing the ACS 
began in 1996 and full implementation will begin in 2005 and continue 
as long as the program receives annual funding.

A separate long-form questionnaire has been mailed to a sample of 
households once a decade to collect detailed information on 
demographic, housing, social, and economic characteristics since the 
1960 Decennial Census. This information has been the main source of 
information for small geographic areas, including tracts and block 
groups; it has been used extensively by federal agencies for program 
implementation and by state and local governments for programmatic and 
planning purposes. In the 2000 Decennial Census, the long form was 
mailed to a sample of about 19 million housing units.

The ACS will contain the same questions as the long form but will be 
mailed monthly to an annual sample of 3 million housing units. With the 
smaller sample, the ACS is designed to provide the same information at 
the same level of geographic detail as the long form by means of a 
continuous measurement methodology in which survey responses will be 
accumulated over time. The Census Bureau has determined that in order 
to produce reliable estimates at the same geographic level of detail as 
the long form, ACS results will be cumulated over 5 years. It also has 
determined that the ACS will provide reliable estimates for geographic 
areas with populations of 20,000 to 65,000 by cumulating ACS responses 
over 3 years and for geographic areas with populations of more than 
65,000 by cumulating ACS results for 1 year but that these estimates 
will be less reliable than the corresponding long-form estimates.

According to the plan the Congress approved, the first annual ACS data 
for geographic areas with populations larger than 65,000 will be 
published beginning in 2006 with data for 2005; 3-year averages for 
geographic areas with populations between 20,000 and 65,000 will begin 
in 2008; and 5-year averages for geographic areas with populations 
smaller than 20,000, including tracts and block groups, will begin in 
2010. The 5-year averages for 2008-12 to be published in 2013 will 
replace the 2010 Decennial Census long form for small geographic areas, 
as they will be centered on 2010 and closely reflect the population and 
housing characteristics data from the 2010 Decennial Census short form. 
In replacing the long form, the ACS will provide the same long-form 
data items at the same level of geographic area detail but in a more 
timely way. Whereas the long form provided small geographic detail once 
a decade, the ACS will provide annual estimates for large geographic 
areas and estimates for smaller areas in terms of 3-year or 5-year 
averages.

You asked us to examine issues about replacing the long form with the 
ACS related to the reliability of data for small geographic areas. As 
agreed with your offices, our objectives for this report were to (1) 
review the Census Bureau's testing program on operational and 
programmatic aspects that will affect the reliability of small 
geographic area data and (2) determine whether alternatives to the 
proposed ACS would provide more frequent and more reliable data for 
small geographic areas.

To address these topics, we reviewed ACS-related Census Bureau 
documents, congressional testimony, National Academy of Sciences (NAS) 
reports, and consultants' reports prepared for the Census Bureau, 
Bureau of Labor Statistics (BLS), and Department of Housing and Urban 
Development (HUD). We also interviewed small-area data experts on the 
latest NAS report on the ACS and reviewed the Census Bureau's responses 
to recommendations on the ACS in our earlier reports.

We conducted our work between April 2003 and August 2004 in accordance 
with generally accepted government auditing standards. We describe our 
scope and methodology in more detail in appendix I.

Results in Brief:

If the ACS is to be an adequate replacement for the Decennial Census 
long form as the major source of data on small geographic areas and if 
it is to provide similar annual data for larger areas, we believe that 
the Census Bureau will need to (1) incorporate in a timely manner the 
resolution of issues it has already identified in testing the ACS, (2) 
complete the ACS evaluation and testing plan to identify other issues 
and provide information for users that will be necessary for the 
transition to the full ACS, (3) evaluate issues identified in this 
report and consult with stakeholders and users on their resolution, (4) 
coordinate the results of the testing program for the 2010 Decennial 
Census short form with the ACS implementation schedule, and (5) resolve 
all issues so that the ACS estimates beginning with 2008 are consistent 
with the ACS estimates for 2009-12 and with the 2010 Census short form.

Key Unresolved Issues:

Unresolved issues that might affect the reliability of ACS small 
geographic area data include (1) the introduction of a new concept of 
residence, (2) the uncertainty about the new methodology for deriving 
independent controls for population and housing characteristics, (3) 
the lack of guidance for users from the Census Bureau on the 
characteristics of multiyear averages for small geographic areas, and 
(4) operational procedures, such as questionnaire design and the 
adjustment to dollar-denominated values, and to the consistency between 
ACS and 2000 Census long-form data.

The Census Bureau has announced that it will adopt a concept of 
"current residence" for determining the geographic location of seasonal 
residents for the full ACS. The concept will differ from "usual 
residence," used for decennial censuses and the ACS testing programs. 
Under the usual residence concept, people who spend their winter in 
Florida and the rest of the year in New Hampshire, for example, are 
recorded as residents of New Hampshire; college students living away 
from home in dormitories are recorded as residents of the college. 
Under the current residence concept, people have only one residence at 
any point in time, but their place of residence does not have to be the 
same throughout the year. Although the Census Bureau plans to change 
this concept for the ACS, it has reported that sufficient research has 
not been conducted to make a final set of rules for determining current 
residence. In addition, it found problems with the residence questions 
used in 2000 but does not plan to incorporate improved questions until 
2010.

To determine independent controls for population and housing 
characteristics, which will be used to adjust ACS sample results, the 
ACS will use the characteristics derived from decennial censuses for 
the census year and for other years from the Census Bureau's 
Intercensal Population Estimates (ICPE) program. The Census Bureau has 
not developed a methodology for using ICPE for the full ACS to derive 
controls consistent with the ACS residence concept and ACS reference 
period or at the same level of geography used for the 2000 Census long 
form.

Before data for 2005 on places with populations of 65,000 or more can 
be released in 2006, a methodology is needed to provide controls that 
reflect changes in the residence concept and reference period. A 
methodology for controls for places with populations of more than 
20,000 that incorporates ICPE revisions is needed before the first 
multiyear averages are released in 2008. In addition, if the averages 
for 2008-12 are to replace the 2010 Census long form, the methodology 
for incorporating 2010 Census data and the related revisions to ICPE 
data will be needed in 2009.

User Guidance on Multiyear Averages:

ACS data for geographic areas with populations smaller than 65,000 will 
be presented only in terms of multiyear averages. Because of the 
statistical properties of these averages and users' unfamiliarity with 
them, we found that it is critical for the Census Bureau to provide 
users with guidance on topics such as the reliability of multiyear 
averages for areas with rapidly changing populations, the reliability 
of trends calculated from annual changes in multiyear averages, and the 
use of multiple estimates from the ACS data for geographic areas with 
populations larger than 20,000. Census Bureau officials told us that 
they agreed with the need for such guidance but had no plans for its 
contents.

ACS Implementation Schedule:

We found that the latest schedule for the 2010 Decennial Census does 
not provide adequate time for the Census Bureau to incorporate into the 
full ACS program changes necessary for the ACS data for 2008-12 to be 
reliable enough to replace the 2010 Census long form. We identified 
issues that need to be resolved before the 2006 release of the 2005 ACS 
and other issues that need to be resolved before the release of the 
first 3-year averages in 2008. The most important issues to be resolved 
are those that need to be in place by 2008, when the collection of data 
for calculating the 5-year averages (for 2008-12) that will replace the 
2010 Census long form will begin. Prompt resolution of the other issues 
would improve consistency between the 2005-07 ACS data and the ACS data 
beginning with 2008.

Alternatives to Improve Small Geographic Area Data:

Besides the key unresolved issues discussed above, we also identified 
an alternative to the proposed ACS that would provide more timely and 
reliable small geographic area data. This alternative would require 
additional funding to support a larger sample. Under an alternative, 
patterned after the Census Bureau's initial plan to replace the 2000 
Census long form, the sample size for 2009-11 would be increased to 4.8 
million housing units and then reduced to 3.0 million housing units for 
subsequent years. The larger sample would provide small geographic area 
data that would be the replacement for the 2010 Census long form from 
3-year averages (for 2009-11). These averages would be as reliable as 
the proposed 5-year averages (for 2008-12) and would provide the 
replacement for the long form data 1 year earlier. The larger sample 
could also be used permanently after 2011 and would provide continuous 
3-year averages for small geographic areas.

In written comments on a draft of this report, the Secretary of 
Commerce addressed three of the four recommendations we addressed to 
him. Regarding the first recommendation, the Secretary stated that the 
current ACS testing and evaluation plan already included the issues we 
have identified in the report. In following up to the Secretary's 
response, we learned that there is not yet a written plan, but only a 
rough outline of the types of work planned. Therefore, we believe our 
recommendation remains valid. Regarding the second recommendation, 
suggesting that the Census Bureau provide key stakeholders more direct 
and timely input into decisions on these issues, the Secretary stated 
that he believes that the present consultation process is adequate. We 
disagree, because as noted in appendix II of our report, the Census 
Bureau has not been responsive to recommendations from several National 
Academy of Sciences reports relating to the ACS. The Secretary agreed 
with our third recommendation that the Census Bureau provide public 
documentation for key decisions on issues we have identified in this 
report. The Secretary did not respond directly to our recommendation 
that he direct the Census Bureau to prepare a schedule for the 2010 
Census that ensures that all necessary changes are made in time for the 
2008 ACS so the 5-year ACS averages for 2008-2012 will be an adequate 
replacement for the 2010 long form for small geographic areas.

The comments from the Secretary also include a list of detailed 
technical comments from the Census Bureau. We reviewed each of these 
comments and revised the report where appropriate.

Background:

Now that the Census Bureau has congressional approval to begin the full 
ACS, data collection will begin in November 2004. The ACS test survey 
of a sample of 800,000 housing units, which has been conducted since 
2000, will end in December 2004. The Bureau has been using this survey, 
known as the ACS Supplementary Survey, to test procedures and to 
produce annual data for geographic areas with populations of 250,000 or 
more. As one part of the test program, the supplementary survey data 
for 2000 have been compared with corresponding data from the 2000 
Census long form to evaluate the quality of the ACS data and to provide 
users with information to make the transition from the long-form data 
to the full ACS data. According to the plan the Congress approved, the 
first annual ACS data for geographic areas with populations larger than 
65,000 will be published beginning in 2006 with data for 2005; 3-year 
averages for geographic areas with populations between 20,000 and 
65,000 will begin in 2008; and 5-year averages for geographic areas 
with populations smaller than 20,000, including Census tracts and block 
groups, will begin in 2010. The 5-year averages for 2008-12 will 
replace the 2010 Decennial Census long form for small geographic areas; 
they will be published in 2013 and will incorporate population and 
housing characteristics data from the 2010 Decennial Census short form.

In replacing the long form, the ACS will provide the same long-form 
data items at the same level of geographic area detail but in a more 
timely way. Whereas the long form provided small geographic detail once 
a decade, the ACS will provide annual estimates for large geographic 
areas and estimates for smaller areas in terms of 3-year or 5-year 
averages; the 5-year averages will provide data at the same geographic 
area level as the long form. According to the Census Bureau, these 5-
year averages will be about as accurate as the long-form data; the 
annual and 3-year averages will be significantly less reliable than the 
long-form data but more reliable than existing annual household surveys 
the Census Bureau conducts.[Footnote 2]

In the remainder of the Background section of this report, we briefly 
describe the major differences between the ACS and the Decennial Census 
long form. We also discuss the Census Bureau's outreach program, 
designed to involve stakeholders and users in shaping the ACS. Appendix 
III provides additional background information on the evolution of the 
ACS plan, appendix IV on the ACS testing and measurement program. 
Appendix II describes recent NAS findings on Continuous Measurement 
(CM) and the ACS.

Multiyear Averages:

The 2000 Census long form used a decennial sample of about 19 million 
housing units; the full ACS will use an annual sample of 3 million 
housing units. In order to provide reliable estimates for geographic 
areas with populations of 65,000 or less, monthly ACS responses will be 
cumulated over several years--3 years for places with populations of 
20,000 to 65,000 and 5 years for places with populations smaller than 
20,000. Because of the statistical properties of these averages and 
users' unfamiliarity with them, the Census Bureau has long recognized 
the need to provide guidance on such topics as the reliability of the 
averages for areas with rapidly changing population and the use of 
multiple estimates for states and other, larger geographic areas.

The Concept of Residence:

For the 2000 Decennial Census, the ACS test programs, and federal 
household surveys, including the Current Population Survey (CPS), 
seasonal residents are recorded in a geographic area according to a 
concept of usual residence. As we noted above, under this concept, 
people who spend their winter in Florida and the rest of the year in 
New Hampshire, for example, are recorded as residents of New Hampshire; 
college students living away from home in dormitories are recorded as 
residents of the college.

For the full ACS, the Census Bureau has announced its decision to 
change the concept to current residence. According to the Census 
Bureau, although each concept requires that a person have only one 
residence at any point in time, current residence recognizes that the 
place of residence does not have to be the same throughout a year, 
allowing ACS data to more closely reflect the actual characteristics of 
each area. The Census Bureau plans to use current residence because the 
ACS is conducted every month and produces annual averages rather than 
point-in-time estimates, unlike the Decennial Census. Current residence 
is uniquely suited to the ACS, because it continuously collects 
information from independent monthly samples throughout all months of 
all years. Because the ACS is designed to produce a continuous measure 
of the characteristics of states, counties, and other places every 
year, the new residence rules were needed for seasonal and migratory 
individuals.

Reference Period:

The underlying population and housing characteristics data for the 2000 
Census long form were for April 1, 2000. For the ACS test program, the 
underlying population and housing characteristics varied. For all years 
except 2000, they were for July 1; for 2000, they were for April 1. For 
the full ACS, because the data are collected monthly, the reference 
period will be the average for the year, and the Census Bureau will 
assume this average is equivalent to data for July 1.

Independent Controls for Population and Housing Characteristics:

The ACS will use population characteristics (age, sex, race, and 
ethnicity) and housing characteristics (occupied and vacant units) 
derived from an independent source and not from the results collected 
in the survey. Using independent controls for these characteristics is 
standard practice to correct sample survey results for the effects of 
nonresponse and undercoverage. Population and housing characteristics 
from the 2000 Census short form were used as independent controls for 
the 2000 Census long form, down to the tract level. For the ACS 
supplementary surveys, independent controls were from ICPE, which uses 
Decennial Census short-form data as benchmarks and administrative 
record data to interpolate between and extrapolate from the census 
benchmarks. ICPE develops and disseminates annual estimates of the 
total population and the distribution by age, sex, race, and Hispanic 
origin for the nation, state, counties, and functioning government 
units. ICPE provides annual estimates of population and housing 
characteristics at the county level, and for some subcounty levels, as 
of July 1, using the usual residence concept for seasonal residents.

Dollar-Denominated Data Items:

According to current Census Bureau plans, annual estimates of dollar-
denominated data items, such as income, rent, and housing-related 
expenses, will be presented after adjustment for inflation in order to 
facilitate comparisons over time. As in the ACS test programs, only 
annual estimates with this adjustment will be presented. The Census 
Bureau also has decided to continue to adjust annual data collected 
each month in the ACS to a calendar year basis. It will be using the 
Consumer Price Index (CPI) for the annual and monthly adjustments for 
all geographic areas.[Footnote 3]

Operational Differences:

The long form and ACS will also differ in how operations are conducted, 
such as nonresponse follow-up and data capture. For the 2000 Census 
long form, nonresponse follow-up was conducted for all nonrespondents. 
For the ACS supplementary surveys and for the full ACS, nonresponse 
follow-up will be conducted for a sample of one-third of all 
nonrespondents. For the 2000 Census long form, all data items were 
entered using automated optical character recognition procedure; data 
from the ACS will be manually keyed.

Group Quarters:

The ACS supplementary surveys excluded persons living in group 
quarters. Group quarters--which include nursing homes, prisons, college 
dormitories, military barracks, institutions for juveniles, and 
emergency and transitional shelters for the homeless--accounted for 
roughly 2.8 percent of the population in 2000. The Census Bureau 
decided not to cover these persons in the supplementary surveys, to 
avoid duplication with the 2000 Census, and because it lacked funding 
to cover them in subsequent years. Procedures for including in the ACS 
persons living in group quarters beginning with 2005 are discussed in 
the Census Bureau's ACS Operations Plan, issued in March 2003.[Footnote 
4] In addition, it has announced that it intends to continue testing 
procedures to improve the mailing list for group quarters to be used 
for the 2010 Decennial Census.

Outreach:

The Census Bureau has long recognized the need to seek input from 
stakeholders and users in making decisions for all its programs. The 
Census Bureau sponsors technical reports that NAS prepares. (In 
appendix II, we summarize recent NAS reports on the ACS and related 
decennial censuses.) The Census Bureau has also held conferences on the 
ACS and has contracted with Westat Inc. to organize two conferences of 
experts on specific aspects of the ACS. Additionally, the Census 
Advisory Committees, which are Census Bureau-appointed advisory 
committees whose members represent professional associations such as 
the American Statistical Association (ASA) and the American Marketing 
Association, meet twice a year. The Census Bureau and other federal 
statistical agencies also participate in the quarterly meetings of the 
Council of Professional Associations on Federal Statistics, whose 
members include professional associations, businesses, research 
institutes, and others interested in federal statistics.[Footnote 5]

To obtain input from other federal agencies, the Office of Management 
and Budget (OMB) established an interagency advisory committee for the 
ACS in 2000. The committee's major purpose was to coordinate the review 
of questions to be included in the ACS. Because of the committee's 
limited focus, the Census Bureau established the ACS Federal Agency 
Information Program in 2003, responding to a recommendation we 
made.[Footnote 6] This program is designed to assist each federal 
agency that has a current or potential use for ACS data to achieve a 
smooth transition to using the ACS.

Outstanding Issues Jeopardize ACS's Replacement of the Long Form:

From its beginnings in the mid-1990s, the Census Bureau's development 
plan for the ACS was designed to ensure that the ACS would 
satisfactorily replace the Decennial Census long form as the major 
source of small geographic area data. In our review of the plan, we 
found that the Census Bureau, as well as key ACS stakeholders, had for 
many years identified the key issues that needed to be resolved if the 
ACS were to reach this goal.

We have identified the following unresolved issues from our research 
(described in appendix I):

* the methodology to be used for deriving independent controls for 
population and housing characteristics with ACS definitions of place of 
residence and reference date,

* improvements needed to operational procedures,

* methods for valuation and presentation of dollar-denominated data 
items,

* comprehensive analysis of the comparability between new ACS data and 
corresponding data from the 2000 Census long-form and 2004 
supplementary survey, and:

* the provision of user guidance on multiyear averages.

Despite the Census Bureau's early identification of issues critical to 
the successful replacement of the 2010 Decennial Census long form as 
the new source of small geographic area data, we found that its plans 
to resolve these issues have been only partially completed. 
Furthermore, we found that despite recent changes to the ACS 
implementation schedule, it is not fully synchronized with the Census 
Bureau's time schedule for implementing the testing program for the 
2010 Decennial Census. Consequently, if these issues are not resolved 
in a timely manner, the Census Bureau's plan to replace the 2010 
Decennial Census long form with the 2008-12 ACS averages for detailed 
geographic areas will be jeopardized.

A Methodology for Independent Controls for Population and Housing 
Characteristics Is Lacking:

It is standard practice to use independent controls for population and 
housing characteristics to correct the results of sample surveys for 
the effects of nonresponse and undercoverage. For the 2000 Census long 
form, characteristics from the 2000 Census short form were used as 
independent controls down to the tract level. For the annual ACS 
supplementary surveys, characteristics from ICPE were used as the 
independent controls.[Footnote 7]

Independent controls for the full ACS will require a new methodology. 
Short-form data are available only once every 10 years, and the annual 
ICPE estimates do not provide data for the detailed geographic areas 
needed to prepare long-form detail and do not use the ACS residence 
concept or reference period. The new methodology is critical to the 
reliability of the ACS estimates of small geographic areas that ICPE 
does not provide and of areas that have large numbers of seasonal 
residents.

Census Bureau staff have long recognized the need for the new 
methodology. For example, a 1995 paper by Love, Dalzell, and Alexander 
expressed concern about population controls and residence rules as well 
as the need for consultation with users on these topics.[Footnote 8] 
They reported that the Census Bureau was planning to conduct research 
using data from the 1996 test sites to produce controls at the census 
tract and block group levels. They also noted that the Census Bureau 
would need to conduct research on the residence rule. A 2000 paper by 
Alexander and Wetrogan also discussed the issue of population 
controls.[Footnote 9] They reviewed possible methods for using ICPE to 
develop controls for the ACS and noted the need to consult with users 
on how to present information on the differences in ACS controls and 
ICPE in ACS publications.

Key stakeholders, including experts on the ACS we interviewed in August 
2003 (listed in appendix I), expressed similar concerns about the 
methodology.

It appears that no progress had been made on a new methodology until 
the Census Bureau reported in October 2003 to its advisory committees 
on the status of a new methodology to derive controls. It announced 
that when full ACS collection starts in November 2004, (1) interim 
procedures would be used and (2) a final methodology would not be 
determined until after the necessary research was completed. The Census 
Bureau did not provide a date when the methodology would be 
incorporated.

In our review of Census Bureau presentations about the new methodology 
(described in detail in appendix V), we found that it had no plans to 
maintain time-series consistency of the population and housing controls 
by routinely incorporating the regular revisions to ICPE estimates into 
the ACS. Without such revisions, there could be a significant lack of 
comparability in the ACS data being averaged, and the reliability of 
multiyear estimates would be reduced. For example, without such 
revisions, the 2008-12 averages that are to replace the 2010 Decennial 
Census long form would be based on controls extrapolated from the 2000 
Census for 2008-09 and controls from the 2010 Census for 2010-12. In 
addition, time-series consistency in the annual ACS data would be 
reduced, especially in the data for 2010 and previous years. Census 
Bureau officials told us that they were not planning any such 
revisions, unless the inconsistencies between 2010 ICPE and 2010 Census 
characteristics were significant, even though there were significant 
inconsistencies between the 2000 ICPE estimates and the 2000 Census 
data, especially for small geographic areas.

We found that regularly incorporating all revisions to ICPE into the 
ACS would improve ACS reliability and that planning would give users 
advance notice on the Census Bureau's revision practice. The need for 
such planning is critical, as evidenced by the failure that occurred in 
January 2004, when a revised set of ICPE data was incorporated into the 
calculation of monthly CPS data on employment. Initially, the revised 
employment estimates were released without a revision of the pre-2004 
data, resulting in a significant discontinuity between December 2003 
and January 2004. As a result of users' dissatisfaction about the 
discontinuity, a consistent set of employment estimates was 
released.[Footnote 10]

Finally, failure to adequately involve stakeholders in the decision 
process may contribute to significant misunderstanding about the use of 
the ACS estimates and corresponding estimates from the Decennial 
Census. In past decennial censuses, except for the very smallest 
geographic areas, the population and housing characteristics data 
published as part of the long-form detail were the same as the official 
data based on data collected on the short form. Because of differences 
in the residence and reference period concepts and the use of multiyear 
averages for small geographic areas, there will be less consistency 
between the ACS averages for 2008-12 and the 2010 Census data.

Operational Issues Have Not Been Addressed:

The Census Bureau has identified operational issues with the ACS test 
programs, primarily from its evaluation studies on the 2000 Decennial 
Census and Census Bureau staff research papers on comparisons between 
data collected in the ACS 2000 Supplementary Survey and the 2000 
Decennial Census long form. These issues (described in detail in 
appendix V) include problems with questionnaire design, nonresponse 
followup, and data capture, as well as coverage of persons living in 
group quarters.

For example, the Census Bureau conducted a study to evaluate the design 
of the ACS questions that are needed to implement the residence concept 
and reference period for the ACS.[Footnote 11] The study suggested that 
additional testing was needed for the questions about multiple 
residences and noted "that asking these questions on a person basis may 
produce different and probably better data than asking them on a 
household basis."[Footnote 12] Similarly, the authors found potential 
problems with the identification of seasonal residents. We were not 
able to identify in the Census Bureau's plans whether these issues 
would be addressed before implementation of the full ACS.

We also found, for the implementation of the full ACS for 2005, that 
the Census Bureau had addressed only the inclusion of group quarters 
and that it may not resolve the issue of questionnaire design until 
2010. In addition, even for group quarters, it is planning for 
improvements that may not be included until 2010. Furthermore, not all 
problems have been identified because of the delays in the Census 
Bureau's completing the evaluation studies of comparisons of long-form 
and ACS data items. Moreover, the Census Bureau's plans do not provide 
for external consultations on key decisions about resolving issues.

Although the Census Bureau has acknowledged the importance of the 
timing of incorporating changes to resolve the various issues, any 
delay in implementing solutions to 2010 would not meet the needs of the 
ACS collection and production schedule. For example, in its March 2003 
ACS operations plan, the Census Bureau recognized the need for 
maintaining questionnaire continuity to calculate consistent multiyear 
averages. It also has reported that it needs to incorporate changes in 
the ACS questionnaire no later than 2008 because changes introduced 
after 2008 and before 2013 would create inconsistencies in calculating 
the 5-year averages that are to replace the 2010 Decennial Census long 
form. Nevertheless, we found that the Census Bureau's current time 
schedule does not call for resolving issues such as questionnaire 
design before 2008.

Incorporating changes into the ACS beginning with 2008 will help 
maintain the reliability of the 5-year averages for small geographic 
areas; failing to incorporate them beginning with 2005 will reduce the 
reliability of the annual changes in the ACS data.

With regard to external consultation, we found that the Census Bureau's 
plans do not include time for consulting with stakeholders and users, 
despite NAS, BLS, and Census Advisory Committee suggestions and 
recommendations. For example, in a February 15, 2001, report to the 
Census Bureau, the NAS Panel on Research on Future Census Methods 
recommended that it conduct evaluation studies on "the effectiveness of 
operations used to designate special places and enumerate the group 
quarters and homeless populations."[Footnote 13] Members of the Census 
Advisory Committee had raised similar concerns. In a 2003 report 
prepared for BLS, their consultant had made a number of recommendations 
about the questions on employment.

We found that the Census Bureau needs to develop a time schedule so 
that changes can be introduced to minimize inconsistencies between the 
2005 and subsequent ACS data and to ensure that all necessary changes 
are made so that the ACS data for 2008-12 that will replace the 2010 
Decennial Census long form will be collected consistently. In addition, 
the prompt completion of the ACS--long-form comparison studies and 
related evaluations will provide sufficient time for the Census Bureau 
to consult with stakeholders and to provide users with the information 
they need to understand the effect of making changes to the ACS 
questionnaires or procedures between 2005 and 2008.

Plans for Valuation and Presentation of Dollar-Denominated Data Items 
Are Questionable:

When the Census Bureau began releasing data from the ACS test programs, 
all dollar-denominated items such as incomes, housing values, rents, 
and housing-related expenditures were adjusted for inflation. As in the 
ACS test programs, only annual estimates with this adjustment will be 
presented, and when the Census Bureau releases ACS data for each new 
year, it revises all dollar-denominated data for prior years. It makes 
a similar inflation adjustment for the annual income data collected in 
the CPS, but it releases the unadjusted estimates.[Footnote 14] The 
Census Bureau also has decided to continue to adjust annual data 
collected each month in the ACS to a calendar year basis. It will be 
using the CPI for the annual and monthly adjustments for all geographic 
areas.

The treatment of dollar-denominated data items is critical to all users 
of these data. It is particularly critical for federal agencies that 
will be using the ACS instead of the long form for many government 
programs to determine the allocation of funds or program eligibility. 
It is also critical to users of dollar-denominated items for small 
geographic areas because the inflation adjustments under the current 
procedure are based on a national average index.

In our review of the development and implementation of the ACS, we 
identified questions on the appropriateness of the methodology for the 
adjustment and the suppression of the unadjusted annual values. A 
report prepared for HUD found problems with the calculation of the 
adjustment and the use of the adjustment for income measures used for 
HUD programs. The report also noted that the lack of the unadjusted 
annual data would severely limit HUD's use of calculations appropriate 
to its program needs. Research by Census Bureau staff questioned the 
adjustment for incomes when they found that it was a probable source of 
difference between income data from the supplementary survey and 
corresponding data from the CPS and the 2000 Census long form.[Footnote 
15] (We discuss these findings in detail in appendix V.)

Our statisticians reviewed these findings and found a similar problem 
with the calculation of the adjustment because of the lack of trending 
adjustment. We found that the Census Bureau could estimate calendar 
year values using a combination of past trends in related series, 
information from other ACS respondents, or known information such as 
changes in cost-of-living adjustments for various transfer payment 
programs and changes in wage rates. We also found that converting ACS 
data from monthly to calendar year data is similar to conversion issues 
faced by other agencies that collect annual statistics compiled on a 
fiscal-year basis and that the procedures these agencies use could be 
adapted for the ACS.[Footnote 16] With regard to the use of a national 
cost-of-living adjustment, we have previously reported that for 
purposes such as allocating federal funds to states using income and 
poverty data, the CPI, a national measure of inflation, does not 
reflect variations in geographic areas.[Footnote 17] Census Bureau 
staff have reported similar findings.[Footnote 18]

The HUD and Census Bureau findings and our review raise serious 
questions about the inflation adjustments. We found no documentation 
explaining the rationale for the adjustment for either the ACS or the 
CPS, where its use is limited to income data. Bureau officials informed 
us that alternative procedures had not been examined and that 
stakeholders or users had not been consulted on the adjustment.

Evaluations of Comparisons Are Incomplete and Users Lack Information on 
ACS Time-Series Consistency:

We noted above that one of the Census Bureau's major justifications for 
the ACS test programs has been its comparing data collected in these 
programs, and corresponding data from the 2000 Decennial Census short 
and long forms, to identify operational problems. Another major 
justification for the ACS test programs has been the use of these 
comparisons, and comparisons with corresponding data from the CPS, to 
inform users in making the transition from the 2000 long form to the 
ACS. Census Bureau Director Kenneth Prewitt emphasized the importance 
of transition needs in testimony to the Congress in 2000 when he 
reported the following about the ACS test programs:

"These data will also contribute to a comparison with data from Census 
2000 that is necessary because there are differences in methods and 
definitions between the census and the ACS. Moreover, decision makers 
will want to compare an area's data to those from Census 2000. 
Comparisons using data from the operational test and from the 31 sites 
are essential to determine how much measured change between Census 2000 
and future years of the ACS is real and how much is due to operational 
differences between the ACS and the census."[Footnote 19]

Despite acknowledging the importance of these comparisons, the Census 
Bureau's publication of evaluations of the comparisons has been 
delayed, and their scope has been reduced in terms of levels, data 
items, and time period. The lack of information will create problems 
for ACS users who will be comparing the annual ACS data for 2005 (to be 
released in mid-2006) with 2000 Decennial Census data or comparing 
annual ACS supplementary survey data beginning with 2000.

In addition to delaying the release of the evaluation studies, the 
Census Bureau has reduced their scope. For the evaluations of ACS test 
site data, local experts did not participate in the evaluation of the 
comparisons for 27 of the 31 test sites. For the 4 test sites that were 
studied by local experts, they did not cover subcounty local government 
units. For evaluations of ACS supplementary survey data, the Census 
Bureau has eliminated the analyses of comparisons between (1) the 2000 
supplementary survey and the 2000 long form for geographic areas with 
populations of 250,000 or more and (2) the supplementary surveys for 
2000-02 to corresponding data from the CPS. It has reduced the scope of 
its evaluation studies by also eliminating comparisons of single-year 
estimates for most subnational areas and comparisons of data items such 
as financial characteristics of housing.[Footnote 20]

NAS found that the Census Bureau has not placed sufficient priority on 
completing the necessary evaluation studies.[Footnote 21] Furthermore, 
we found that the Census Bureau does not have a plan that includes the 
timely completion of all the studies. Once the studies are complete, it 
will need to incorporate the findings into ACS operations, consult with 
stakeholders, and provide users with the information they need to make 
the transition from the long form to the ACS. The plan will be needed 
to ensure that as many changes as possible can be introduced before the 
first annual ACS estimates are published in 2006 and that all necessary 
changes are implemented before 2008.

We found that the delays in completing the evaluations and their 
reduction in scope are likely to affect the use of the ACS in improving 
the small geographic area estimates of unemployment and poverty. For 
example, Labor uses the unemployment data extensively to administer a 
variety of federal programs. Several other departments use the poverty 
rates for similar purposes.[Footnote 22]

Users Are Not Informed on Key Properties of Multiyear Averages:

One of the major differences between the ACS and the long form is that 
the ACS will provide data for geographic areas with populations smaller 
than 65,000 in terms of multiyear averages. Experts outside and inside 
the Census Bureau have identified serious issues regarding the 
statistical properties of multiyear averages and have recommended that 
the Census Bureau provide guidance to federal agencies and others on 
their use. We found that stakeholders have urged the Census Bureau for 
many years to provide guidance on the strengths and weaknesses of these 
averages. The most recent request for guidance on using multiyear 
averages came in the July 2003 report by the NAS Panel on Research on 
Future Census Methods: "The Census Bureau should issue a user's guide 
that details the statistical implications of the difference between 
point-in-time and moving average estimates for various uses."[Footnote 
23] In the report's executive summary, the panel also stated that "The 
Census Bureau must do significant work in informing data users and 
stakeholders of the features and the problems of working with moving 
average-based estimates."[Footnote 24] It also expressed particular 
concern about the use of the multiyear (or moving) averages in fund 
allocation formulas.

Stakeholders have requested guidance on topics such as (1) the 
reliability of multiyear averages for areas with rapidly changing 
populations, (2) the reliability of trends calculated from annual 
changes in multiyear averages, and (3) the selection of ACS data for 
geographic areas with populations larger than 20,000 for which there 
will be multiple estimates. The Census Bureau has recognized the need 
for such guidance but has not announced any information about its 
contents or when it might be available, even though the guidance is 
needed well in advance of the release of the first multiyear averages 
in 2008.

We also found that plans for research to evaluate the statistical 
properties of multiyear averages are limited. The contracts to evaluate 
3-year averages for the ACS test sites cover only averages for 1999-
2001, with no comparisons with averages for 2000-02, 2001-03, or 1999-
2003. In addition, the evaluation studies discussed earlier lack any 
time-series dimension, such as comparisons of the supplementary surveys 
with annual data from the CPS. Thus, it appears that the Census Bureau 
has missed the opportunity to test (1) distortion and stability in 
multiyear averages, (2) differences between multiple estimates for the 
same geographic areas, and (3) the use of annual ACS data for small 
geographic areas.

Meaningful External Consultation on Key Issues Is Needed:

We found that in recent years, the Census Bureau has used its outreach 
efforts with stakeholders and users primarily to gain support for the 
ACS. Although it also has solicited advice from NAS panels, advisory 
committee members, and experts at workshops and conferences on some of 
the issues we have identified in this report, there is no indication 
that the Census Bureau will be following this advice. (For additional 
information, see appendix V.) Likewise, it has not yet followed similar 
advice from us, other government agencies, or even its own staff.

It has been more than a year since the Census Bureau announced, in 
March 2003, that it was looking into establishing an ACS partnership 
program that would involve advisory groups and expert panels to help it 
improve the program. We found that no such program has been established 
yet. Given that many key issues remain unresolved and that the Census 
Bureau has no plans to seek advice on resolving them, key aspects of 
the ACS will receive little or no input unless the Census Bureau 
revises its plans.

Improving Timeliness and Quality of Small Geographic Area Data Would 
Increase Costs:

In 1994, the Congress began to fund testing of the survey to replace 
the 2000 Decennial Census long form, beginning with the 2000 Census. In 
reviewing the development of the ACS, we found that the Census Bureau 
was planning to replace the 2000 long form by starting the ACS program 
with an annual sample of 4.8 million housing units for 1999, 2000, and 
2001 and reducing the sample for subsequent years to 3 
million.[Footnote 25] The larger sample would have provided 3-year 
averages for all small geographic areas for 2000 and would have 
provided data for the smallest geographic areas of the same quality as 
the traditional long form. In fiscal year 1998, plans to introduce the 
ACS to replace the census long form were delayed until after the 2000 
Census was completed.

When the Census Bureau submitted its plans in 1998 to replace the long 
form for the 2010 Decennial Census, a similar increase in sample size 
for 2009-11 was not proposed. Thus, compared with the plans for 2000, 
data for small geographic areas for 2010 would be delayed by a year and 
would be based on 5-year averages. When we reviewed the previous plan 
and other alternatives to the proposed ACS that would provide more 
timely and reliable data for small geographic areas, we determined that 
the only viable alternative to the current plans would be to expand the 
sample size for 2009-11, as proposed earlier.

This expansion would allow the Census Bureau to publish data for 
geographic areas with populations smaller than 20,000 a year earlier, 
and it would provide more reliable small-area data than under the 
currently planned 5-year averages. In addition, if the Congress were to 
provide the additional funds for this alternative, an additional year 
would be available for the Census Bureau to resolve issues we have 
identified in this report by giving it until the collection of data for 
2009 rather than for 2008. According to Census Bureau estimates, 
increasing the sample size for the 3 years would add about $250 million 
to the estimated $500 million cost for the 3 years, using the smaller 
sample.

Resolving Outstanding Issues Needs a Time Schedule:

The most recent Census Bureau schedule for implementing the ACS over 
the complete cycle of the 2010 Decennial Census was prepared in 
December 2003. Except for the completion of the questionnaire for the 
2008 ACS, the milestones do not cover the resolution of issues that it 
has already identified and issues we identify in this report. (See 
table 1.) Ideally, all these issues should be resolved before the first 
annual results of the full ACS sample are released. However, the Census 
Bureau has already announced that final plans for calculating 
independent population and housing controls with ACS residence and 
reference concepts will not be available for several years, the 2004 
test plans for the 2010 Decennial Census will cover group quarters and 
residence rules, reports from the 2004 tests will not be completed 
until 2005, and the 2006 test plans for 2010 also cover group quarters.

Table 1: ACS Milestone Events and Unresolved Issues, 2004-13:

2004; 
Fiscal quarter: Q4; 
ACS milestone event: Expand the ACS sample to 250,000 addresses per 
month; 
Unresolved issue: (1) Residence rule to be used; 
(2) Changes to operational procedures, questionnaire design, etc., 
based on analyses of differences between earlier ACS estimates and 
other sources such as 2000 Census or on evaluation of 2000 Census 
data.

2005; 
Fiscal quarter: Q1; 
ACS milestone event: Submit proposed topics for 2008 ACS to Congress; 
Unresolved issue: (1) Changes based on analyses of differences between 
earlier ACS estimates and other sources such as 2000 Census or on 
evaluation of 2000 Census data; 
(2) Consultation with stakeholders and users.

2005; 
Fiscal quarter: Q4; 
ACS milestone event: Publish 2004 ACS single-year results for all 
states and most areas with population 250,000+; 
Unresolved issue: (1) Information on degree of stability of year-to-
year changes in 2000-04 ACS based on comparisons with corresponding 
data from CPS and other surveys; 
(2) Release of dollar-denominated data items without adjustments for 
inflation and adjustment methodology.

2006; 
Fiscal quarter: Q1; 
ACS milestone event: Submit actual questions for 2008 ACS to Congress; 
Unresolved issue: Changes to questions to reflect results of analysis 
of differences between ACS test data and 2000 Census long-form data, 
evaluation of reporting in 2000 Census, and results of 2004 Census 
test.

2006; 
Fiscal quarter: Q4; 
ACS milestone event: Publish 2005 ACS single-year results for all 
geographic areas and population groups of 65,000+; 
Unresolved issue: (1) Methodology for calculating independent controls 
for population characteristics and housing units based on ACS 
definition of residence and reference period; 
(2) Source of independent controls for geographic areas not covered by 
ICPE; 
(3) Level of geographic detail to be released--for example, counties 
with population of less than 65,000 or incorporated places other than 
counties with population of 65,000 or more; 
(4) Information on consistency between 2004 and 2005 results.

2007; 
Fiscal quarter: Q1; 
ACS milestone event: Determine final content for the 2008 ACS; 
Unresolved issue: (1) Changes to questions to reflect results of 
analysis of differences between ACS test data and 2000 Census long-
form data, evaluation of reporting in 2000 Census, and results of 2004 
and 2006 Census tests; 
(2) Consultation with stakeholders and users.

2007; 
Fiscal quarter: Q4; 
ACS milestone event: Publish 2006 ACS single-year results for all 
geographic areas with population groups of 65,000+; 
Unresolved issue: (1) See 2006 Q4; 
(2) Guidance for users on statistical properties of multiyear averages 
to be released in 2008 and on use of single-year results and multiyear 
accumulations for same geographic area.

2008; 
Fiscal quarter: Q1; 
ACS milestone event: Implement content or methodology changes for 2008 
ACS data collection (first year of 5-year ACS accumulation to replace 
2010 long form); 
Unresolved issue: (1) Consultation with stakeholders and users; 
(2) Final decisions on 2010 Census short form.

2008; 
Fiscal quarter: Q4; 
ACS milestone event: Publish 2007 ACS single-year results for all 
geographic areas with population 65,000+, publish 3- year (2005-07) 
accumulation for all areas with population of 20,000+; 
Unresolved issue: (1) See 2006 Q4; 
(2) Plans and procedures for 3-year ACS accumulation--for example, 
revision to independent controls for previous years.

2009; 
Fiscal quarter: Q1; 
ACS milestone event: Complete 2008 ACS data collection; 
Unresolved issue: Changes to operational procedures, such as sampling 
rate for nonresponse followup.

2009; 
Fiscal quarter: Q4; 
ACS milestone event: Publish 2008 ACS single-year results for all 
geographic areas with population 65,000+, publish 3- year (2006-08) 
accumulation for areas with population 20,000+; 
Unresolved issue: Updated guidance for users on statistical properties 
of multiyear averages to be released in 2009 and on use of single-year 
results and multiyear accumulations for same geographic area.

2010; 
Fiscal quarter: Q4; 
ACS milestone event: Publish 2009 ACS single-year results for all 
geographic areas with population 65,000+, publish 3- year (2007-09) 
accumulation for areas with population 20,000+, publish 5-year (2005-
09) accumulation for all areas; 
Unresolved issue: (1) See 2008 Q4; 
(2) Incorporation of revisions to independent controls for 2005-08.

2011; 
Fiscal quarter: Q4; 
ACS milestone event: Publish 2010 ACS single-year results for all 
geographic areas with population 65,000+, publish 3- year (2008-10) 
accumulation for areas with population 20,000+, publish 5-year (2006-
10) accumulation for all areas; 
Unresolved issue: (1) Incorporate revisions to independent controls 
beginning with 2005 for benchmarking to 2010 Census; 
(2) Methodology for April 1 reference date for independent controls 
for 2010 Census.

2012; 
Fiscal quarter: Q4; 
ACS milestone event: Publish 2011 ACS single-year results for all 
geographic areas with population 65,000+, publish 3- year (2009-11) 
accumulation for areas with population 20,000+, publish 5-year (2007-
11) accumulation for all areas; 
Unresolved issue: (1) See 2011 Q4; 
(2) Reconcile differences between ACS and 2010 Census short form.

2013; 
Fiscal quarter: Q4; 
ACS milestone event: Publish 2012 ACS single-year results for all 
geographic areas with population 65,000+, publish 3- year (2010-12) 
accumulation for areas with population 20,000+, publish 5-year (2008-
12) accumulation for all areas; 
Unresolved issue: (1) See 2010 Q4; 
(2) Level of geographic detail from the 2010 Census to be used for 
independent controls similar to that used for the 2000 Decennial 
Census. 

Source: U.S. Census Bureau and GAO analysis.

[End of table]

In addition, the Census Bureau has announced that comparisons of 2000 
ACS and 2000 Census long-form data critical to the transition to the 
full ACS will be limited. Nevertheless, users who need the evaluation 
of these comparisons to compare data from the 2000 Decennial Census 
long form with data from the new ACS data or from the ACS supplementary 
surveys would benefit from the early resolution of other issues. For 
example, resolving issues before the release of the first 3-year 
averages (2005-07) would improve the consistency between these averages 
and the subsequent ACS data. Resolving all issues for the 2008 ACS is 
critical if these data are to be fully consistent with the ACS data for 
2009-12 and the 2008-12 averages are to be fully consistent with the 
2010 Decennial Census short-form data. As we noted above, the Census 
Bureau's schedule does call for timely completion of the 2008 
questionnaire. However, if questions to be included in the 2010 Census 
short form are changed during the congressional and OMB approval 
processes, currently scheduled for 2008 and 2009, data collected on the 
2010 Census short form will be inconsistent with the ACS data.

Conclusions:

The Census Bureau's development of the ACS goes back several decades 
and has included intensive research and field testing programs, as well 
as substantial outreach efforts, in particular through the reports and 
workshops at NAS. However, its current plan to begin full 
implementation of the ACS for 2005 has several critical deficiencies. 
The Census Bureau has not completed its testing program, and it has not 
acted to resolve key issues already identified by the ACS test program, 
by evaluation studies of the 2000 Decennial Census, by Census Bureau 
research studies, and by stakeholders and users, including us, NAS, and 
other federal agencies. Furthermore, the ACS implementation plan and 
the 2010 Decennial Census test programs are not synchronized, and there 
is no comprehensive program for external consultation on the resolution 
of these issues. Without prompt resolution of issues such as those 
relating to the calculation of independent controls for small 
geographic areas and the consistency of data used to calculate 
multiyear averages, the ACS will not be an adequate replacement for the 
long form in the 2010 Decennial Census. If the Census Bureau is not 
able to use the ACS to replace the long form, the Congress and other 
stakeholders need to be advised in 2005 in order to allow for the 
Census Bureau time to reinstate the long form for the 2010 
Census.[Footnote 26]

Recommendations for Executive Action:

To ensure that the ACS is an adequate replacement for the Decennial 
Census long form, we recommend that the Secretary of Commerce direct 
the Census Bureau to (1) revise the ACS evaluation and testing plan and 
focus on the issues we have identified in this report; (2) provide key 
stakeholders, such as the National Academy of Sciences, with meaningful 
and timely input on decisions relating to these issues; and (3) make 
public the information underlying the Census Bureau's decisions on 
these issues when it makes the decisions. We also recommend that the 
Secretary direct the Census Bureau to prepare a time schedule for the 
2010 Decennial Census that provides for resolving these issues by 
incorporating all operational and programmatic changes into the 2008 
ACS so that the 5-year averages for 2008-12 will adequately replace the 
2010 Decennial Census long-form data for small geographic areas. These 
revisions should be reflected in the single, comprehensive project plan 
for the 2010 Census, as we have previously recommended.

Agency Comments and Our Evaluation:

In written comments on a draft of this report, the Secretary of 
Commerce provided comments on our recommendations. (The Secretary's 
comments are reprinted in appendix VI.) He disagreed with our 
recommendation that the ACS evaluation and testing plan needed to be 
revised to focus on issues we have identified in this report, stating 
that the current ACS testing and evaluation plan already included these 
issues. In following up on the Secretary's response, we learned that 
there is not yet a written plan, but only a rough outline of the types 
of work planned. Therefore, we believe our recommendation remains 
valid. The Secretary did not accept our recommendation to provide key 
stakeholders more direct and timely input into decisions on these 
issues because he believes that the present consultation process is 
adequate. We disagree, because as noted in Appendix II of our report, 
the Census Bureau has not been responsive to recommendations from 
several National Academy of Sciences reports relating to the ACS. The 
Secretary agreed with the recommendation that the Census Bureau provide 
public documentation for key decisions on issues we have identified in 
this report. The Secretary did not respond directly to our 
recommendation that he direct the Census Bureau to prepare a schedule 
for the 2010 Census that ensures that all necessary changes are made in 
time for the 2008 ACS so the 5-year ACS averages for 2008-2012 will be 
an adequate replacement for the 2010 long form for small geographic 
areas.

The Secretary provided comments on the five major outstanding issues 
that, in our view, jeopardize the ACS as a replacement of the long 
form: lack of methodology for independent controls, operational issues 
not addressed, questionable plans for dollar-denominated items, 
incomplete evaluations and lack of information on ACS time-series 
consistency, and lack of information about multiyear averages.

The Secretary disagreed with our findings about the lack of a 
methodology for independent population and housing controls. He stated 
that a methodology for the ACS was already in place. On the issue that 
changes to that methodology are needed to account for the difference in 
the ACS residence concept, the Secretary agreed that a change was 
needed but stated that it could be delayed for several more years. On 
the issue of independent controls for subcounty areas, he stated that 
the Census Bureau had no plans to develop such controls, which we found 
were used for the 2000 Census long form, but that it might develop such 
controls using data from the ACS or administrative records. However, he 
did not respond to our findings about the use of existing subcounty 
area data from the ICPE or from the 2010 Census short form. The 
Secretary stated that the Census Bureau also had no plans to revise the 
ICPE. On the issue of the ACS reference period, the Secretary reported 
that the Census Bureau had recently decided to assume that July 1 would 
be used as the reference period. The Secretary did not comment on GAO's 
findings about the lack of plans to incorporate into the ACS 2010 
Census data and related revisions to the ICPE estimates for previous 
years.

We disagree with the Secretary's comments about the independent 
subcounty population and housing controls and believe that their use in 
the ACS is needed for the ACS to be an adequate replacement for the 
2010 Census long form for small geographical areas. We found that 
independent controls from the 2000 Census short form were used for 
detailed geographic areas for the 2000 Census long form and that 
differences in counts of population and housing (occupied and vacant) 
between the long form and the short form were limited to the smallest 
geographic areas. The similar use of 2010 Census short-form counts in 
the ACS also would minimize differences in these counts from the ACS 
and the 2010 Census. Consequently, we disagree with the Bureau's plan 
not to commit to the development of subcounty controls and its plans 
not to base these controls on ICPE total population and housing 
estimates, which are prepared annually for all general government 
units, and the more detailed and reliable data from the 2010 Census 
short form.

We also disagree with the Secretary that the implementation of a new 
methodology for independent controls with subcounty controls and the 
new residence concept can wait until 2008. As we noted in our report, 
we found that controls for subcounty areas with population of more than 
65,000 will be needed before the 2005 ACS estimates are released for 
these areas in 2006 and that controls for subcounty areas with 
populations of more than 20,000 will be needed before the first 
multiyear averages are released in 2008. (For the 2000 Census long 
form, controls for most areas of this size were from the 2000 Census 
short form.) With regard to the new residence concept, a decision to 
delay introducing a new methodology until 2008 would create time-series 
inconsistencies between 2000-2007 and 2008 and subsequent years. These 
inconsistencies could be very significant for geographic areas with a 
large population of seasonal residents.

The Secretary did not comment on our findings about the need for a 
methodology to revisions relating to the ICPE into the ACS. We found 
that this methodology, which is important to both the time-series 
consistency of the annual ACS estimates and to the multiyear averages, 
is not covered by the current ACS methodology, but that it will be 
needed when the 2010 Decennial Census short form data become available. 
We found that it has been the Census Bureau's practice for the ICPE, 
whose estimates are used as the independent controls for the ACS, to be 
benchmarked to the decennial census short-form data and that it uses 
similar practices for many other Census Bureau programs. For the ICPE, 
the Bureau will replace the 2010 ICPE estimates with the 2010 Census 
data, and use the differences in these estimates to revise the ICPE 
estimates back to the previous benchmark year, which for 2010 will be 
2001. (Table 4 of our report shows the impact of benchmarking on county 
population data for 2000.) It should be noted that we found that this 
practice is not followed in all Census Bureau programs. For example, 
for the Annual Economic and Social Supplement to the CPS, the Census 
Bureau introduced the benchmark information from the 2000 Decennial 
Census into the 2001 estimates and presented the data on both the old 
and the revised basis. This approach, to present estimates on an old 
and new basis for a single year, may be appropriate for an annual 
survey. However, GAO found that because of the use of multiyear 
averages in the ACS, it is imperative that the ACS estimates for all 
years beginning with 2001 be revised. Without such a revision program, 
ACS estimates for 2010, which we assume will not be released until the 
2010 Census short-form data have been incorporated, will be 
inconsistent with the 2009 estimates. In addition, the ACS estimates 
for 2008 and 2009 used to calculate the 5-year averages that will 
replace the 2010 Census long form will be based on controls that are 
inconsistent with those for 2010-12. Based on the revisions for 2000 
shown in our report, there could be many significant inconsistencies, 
especially for small geographic areas.

Although the Secretary did not comment on the issue of revision, in its 
technical comments on our draft report, the Census Bureau reported 
(comment 22) that with regard to incorporating 2010 Census data, it has 
decided "to make appropriate changes to the [ACS] population controls 
when necessary, including the possibility of reweighting the data 
around the 2010 time period and for all multiyear estimates." We 
disagree with the Census Bureau's approach primarily because it is not 
consistent with the practices used by the Census Bureau to incorporate 
census data into surveys and programs such as the ICPE and monthly 
retail sales that are controlled or benchmarked to a census or similar 
data set. For these surveys, it revises all previously published data 
on a predetermined schedule using a transparent statistical procedure. 
Most important, these procedures do not depend on the size of 
revisions, which can only be determined after a benchmark is completed. 
Regardless of the benchmarking procedures adopted for the ACS, we 
believe that the Census Bureau needs to have extensive consultation 
with external stakeholders to make its decision. In addition, because 
of the complexity of most benchmarking procedures, the Census Bureau 
needs to begin this consultation as soon as possible.

With regard to the recent Census Bureau decision about the reference 
period for the ACS, we are pleased that a decision has been made 
because any delay in this decision would have resulted in additional 
time-series inconsistencies in the ACS. We have changed our report to 
reflect this decision. Unfortunately, we have no documentation on the 
research underlying the decision and, as has been the case in other key 
decisions, we do not believe that there was any public discussion of 
this decision.

The second issue identified in our report related to the operational 
aspects of the ACS, including questionnaire design and the collection 
of data for persons living in group quarters. On these issues, the 
Secretary limited his comments to the questionnaires and addressed our 
findings that improvements identified as part of the 2000 Census 
cognitive testing research and research based on comparisons of ACS and 
2000 Census long-form data would not be completed until 2008. The 
Secretary noted that the Census Bureau has resolved the issue of 
finalizing the ACS questions, including the questions to be asked on 
the 2010 Census short form before 2008. Although this recent decision 
appears to have resolved the scheduling issue, we believe that 
uncertainties remain as to whether this schedule can be met. For 
example, the ACS milestones in the latest available schedule call for 
final approval of the questions by the Congress and by OMB in 2008 and 
2009, respectively, so that any changes made as a result of these steps 
would not be incorporated into the 2008 questions. As the Census Bureau 
has recognized, failure to maintain consistency in the questions for 
the 2008-2012 ACS will result in inconsistencies in the 5-year averages 
centered on 2010, which are the averages designed to provide the small 
geographic area data that would have been collected on the 2010 Census 
long form. In addition, the recently released ACS evaluation reports 
identify issues on which new research is necessary, including the 
issues with the questions on disability identified in our report, but 
the Census Bureau has not indicated its plan to complete this 
additional research or to consult with stakeholders about decisions 
related to the research. Although the Secretary did not comment on our 
findings with regard to group quarters, we remain concerned that the 
work on group quarters being conducted as part of the 2004, 2006, and 
2008 tests for the 2010 Census will not be reflected in the ACS 
beginning with 2008.

Our report also identified as unresolved issues the two inflation 
adjustments that the Census Bureau is applying on all dollar-
denominated ACS items. The first adjustment is used to convert annual 
data collected each month in the ACS to a calendar year basis. This 
adjustment recognizes that the annual data collected in the ACS are for 
different periods because the data are collected monthly and cover the 
previous 12 months. The second adjustment is used to present dollar-
denominated items in dollars of the most recent calendar year. This 
adjustment eliminates the impact of inflation when comparing data 
across years. The index used for both adjustments is the national-level 
CPI. The Secretary correctly observed that the CPI is a generally 
accepted measure of inflation and that most federal programs that 
allocate funds do not use regional measures of inflation. However, 
these observations did not directly address GAO's findings about the 
adjustments or the concerns raised by HUD in its report on future use 
of the ACS, which are discussed in appendix V of our report. For 
example, the Secretary did not address our finding about a lack of a 
rationale for adjusting items other than incomes for changes in overall 
inflation rather than adjusting with indexes, such as wage rates or 
rent, that are directly related to the item being adjusted. He did 
indicate that the Census Bureau would reconsider its present policy of 
showing only the inflation-adjusted annual estimates and multiyear 
averages. We believe our findings about the need for the Census Bureau 
to provide a comprehensive rationale for the two adjustments still 
apply.

The Secretary disagreed with the issue we identified on completeness of 
the Census Bureau's comparison and evaluation reports. He noted that 
after our draft report was completed, the Census Bureau released seven 
additional comparison reports and that it planned to prepare additional 
reports to evaluate issues we identified on the time-series consistency 
of the annual ACS estimates. However, despite earlier statements by the 
Census Bureau to compare and evaluate differences between state-level 
estimates from the Census 2000 Supplementary Survey (C2SS) and the 2000 
Census long form, these reports did not include any reference to the 
preparation of such comparisons, and the Secretary did not indicate 
they would be prepared. Because the focus of the long form and the ACS 
is on data from small geographic areas, we believe that reports on 
states and on other areas with population of 250,000 or more should be 
prepared.

The last issue we identified was the need to provide users with 
guidance on the interpretation of key properties of multiyear averages. 
The Secretary agreed about the need but noted that guidance is not 
needed in 2005. He reported on a newly created NAS panel that will be 
studying many of the key issues identified in our report. However, we 
believe that the Census Bureau should begin to release guidance on the 
averages before the first multiyear averages are released in 2008. One 
area in which such guidance will be needed is the interpretation and 
use of the multiple ACS estimates. When the 2005-07 averages are 
released in 2008, users will have annual estimates for some of these 
areas for 2006 as well as the 3-year averages, which will be centered 
on 2006. In 2010, when the first 5-year averages are released (2005-
09), users will have three sets of ACS estimates for places with 
populations larger than 20,000. For example, for each state, there will 
be an annual estimate for 2007 as well as 3-year and 5-year averages 
centered on 2007.

The comments from the Secretary also include a list of detailed 
technical comments from the Census Bureau. We reviewed each of these 
comments and revised the report where appropriate.

As agreed with your offices, unless you release the report's contents 
earlier, we plan no further distribution of it until 30 days from its 
issue date. We will then send copies to the Secretary of Commerce, the 
Director of the U.S. Census Bureau, and others who are interested. 
Copies will be made available to others on request. This report will 
also be available at no charge on GAO's Web site at http://www.gao.gov.

If you or your staff have any questions concerning this report, please 
contact me at (202) 512-9750. Other staff who made major contributions 
to this report are listed in appendix VII.

Signed by: 

Robert P. Parker: 
Chief Statistician:

[End of section]

Appendix I: Scope and Methodology:

We used a combination of approaches and methods to examine the Census 
Bureau's plans to develop, test, and implement the American Community 
Survey (ACS). We reviewed published and unpublished ACS-related Census 
Bureau reports, papers, presentations, budget documents, and 
congressional testimony; National Academy of Sciences (NAS) reports; 
congressional testimony delivered by outside experts; and consultants' 
reports prepared for the Census Bureau, the Bureau of Labor Statistics 
(BLS), and the Department of Housing and Urban Development (HUD).

We reviewed an extensive set of internal planning documents prepared 
between 1992 and 1995 that the Census Bureau provided, relevant papers 
Census Bureau staff presented at professional association meetings and 
similar symposiums from 1995 on, and evaluation reports based on the 
2000 Census. We also reviewed official Census Bureau presentations in 
special reports, congressional testimony, and recent advisory committee 
meetings. We reviewed similar materials NAS and consultants prepared 
for the Census Bureau and other federal agencies, as well as materials 
we prepared. The most important documents we reviewed are listed in the 
bibliography, organized by document type, at the end of this report.

In addition, we conducted independent research and analysis. To assess 
the evaluations the Census Bureau conducted to assist users in making 
the transition from the 2000 Census long form to the ACS, we obtained 
data from the 2000 Census and 2000 ACS (the Census 2000 Supplementary 
Survey) and prepared comparisons of key detailed data items at the 
state level. To determine the potential effect of replacing independent 
population and housing characteristics controls from the 2000 Census 
with corresponding data from the 2010 Census, we compared county-level 
intercensal estimates for April 1, 2000, based on the 1990 Census, with 
2000 Census counts. We also analyzed the Census Bureau's use of 
independent controls for estimates of population and housing 
characteristics for previous decennial censuses and its plans for the 
ACS.

To assess alternatives to the ACS, we spoke to current Census Bureau 
officials and individuals familiar with early efforts to provide more 
frequent long-form type data, including the Mid-Decade Census. We also 
reviewed congressional hearings on these developments and Census Bureau 
documents prepared in the 1990s on the Continuous Measurement program 
and on implementing the ACS to replace the 2000 Census long form. We 
did not independently verify the cost information the Census Bureau 
provided for the alternative we discuss. We also interviewed staff of 
the NAS Committee on National Statistics and outside small-area data 
experts. The outside experts we interviewed were:

Constance Citro, Committee on National Statistics Michael Cohen, 
Committee on National Statistics Linda Gage, California State 
Department of Finance Edwin Goldfield, Committee on National Statistics 
Ken Hodges, Claritas Inc. Graham Kalton, Westat Inc. Terri Ann 
Lowenthal, Consultant Joseph Salvo, New York City Planning Department 
Edward J. Spar, Council of Professional Associations for Federal 
Statistics Paul Voss, University of Wisconsin:

[End of section]

Appendix II: Recent NAS Findings on Continuous Measurement and the ACS:

In Modernizing the U.S. Census, a 1995 report, the NAS Panel on Census 
Requirements in the Year 2000 and Beyond stated that:

"Although we believe that the proposed continuous measurement system 
deserves serious evaluation, we conclude that much work remains to 
develop credible estimates of its net costs and to answer many other 
fundamental questions about data quality, the use of small-area 
estimates based on cumulated data, how continuous measurement could be 
integrated with existing household surveys, and its advantages compared 
with other means of providing more frequent small-area estimates. In 
our judgment, it will not be possible to complete this work in time to 
consider the use of continuous measurement in place of the long form 
for the 2000 census."[Footnote 27]

The panel concluded that:

"With regard to proposals to drop the long form in the next decennial 
census and substitute a continuous monthly survey to obtain relevant 
data, substantial further research and preparatory work are required to 
thoroughly evaluate the likely effect and costs of these proposals. 
Continuous measurement deserves serious consideration as a means of 
providing more frequent small-area data; however, the necessary 
research and evaluation cannot be completed in time for the 2000 
census." [Footnote 28]

Although 1994 saw the first proposals to implement the continuous 
measurement methodology as a replacement for the 2000 Census long form, 
the Census Bureau changed its plans in 1998, shifting to implementation 
to replace the long form in 2010.

Since 1995, NAS has produced several reports that relate totally or in 
part to the ACS, including a summary of a September 13, 1998, Committee 
on National Statistics workshop at NAS, two interim reports, a letter 
report, and a final report, by the Panel on Research on Future Census 
Methods, and a report released in early 2004 by the Panel to Review the 
2000 Census.[Footnote 29] (In this appendix, we do not discuss NAS 
reports after 1995 in which the ACS was discussed as a potential data 
source for federal programs.[Footnote 30]):

With few exceptions, the members of these two NAS panels and the 
workshop participants reported findings that cover most of what we have 
identified as unresolved issues and summarize in this 
appendix.[Footnote 31] The NAS reports and ours differ somewhat in 
emphasis. We have focused on the production and use of ACS data, 
whereas NAS focused more on data collection and processing 
methodologies. These differences may reflect the fact that NAS panel 
members are very sophisticated users who are more likely to use ACS 
microdata files and make their own adjustments for methodological 
issues; they make little use of the regular ACS publications.

1998 NAS Workshop on the ACS:

NAS sponsored a 1-day workshop in September 1998 to discuss 
methodological issues related to the ACS. Experts prepared "thought 
pieces" on issues NAS staff selected, with input from Census Bureau 
staff. The workshop's specific discussion topics were combinations of 
information across areas and across time, funding formula, weighting 
and imputation, sample and questionnaire design, and calibration of the 
output from this survey with that from the long form. The thought 
pieces and comments on them prepared Census Bureau staff for the 
discussions at the workshop.[Footnote 32]

NAS noted in the report on the conference that its six focus issues 
reflected only a partial list of key ACS topics; the report's 
conclusions identified other key issues.[Footnote 33] Stating that the 
workshop's purpose was "to assist the Census Bureau in developing a 
research agenda to address these and other methodological issues," the 
report pointed out that the Census Bureau's past focus on the ACS:

"has been on refining data collection, leaving the final answers to the 
difficult analysis questions for later. Thus, procedures for 
nonresponse and undercoverage adjustment were modeled, to the extent 
possible, after current procedures used for the census long form. Now 
that data collection has matured as the ACS demonstration phase is well 
under way, the Census Bureau is developing a research plan and 
initiating research to address all issues relating to ACS methodology. 
Fall 1998 therefore seemed an opportune moment for a workshop to assist 
the Census Bureau in developing a research agenda to deal with many of 
these challenging issues." [Footnote 34]

The report contained no specific recommendations but identified areas 
where additional research was needed, including issues we have 
expressed concern about, such as the availability of multiple ACS 
estimates for geographic areas with populations larger than 20,000 and 
the likelihood of differences between ACS estimates and estimates from 
a Decennial Census short form. From our perspective, the most relevant 
of the workshop's specific issues were (1) combining information across 
time, (2) weighting and imputation, and (3) calibrating the output from 
this survey with that from the long form.

Technical papers in the workshop's agenda book contained considerable 
discussion of time-series issues. The discussion in this section of the 
workshop focused on replacing moving averages with time-series modeling 
and using current household survey data to develop models. Speaking for 
the Census Bureau, Alexander stated that "Our current plan is to 
release annual data for even very small areas and let users perform 
their own time series analyses. We welcome ideas about what the 
Bureau's role should be . . ."[Footnote 35]

On the evaluation of comparisons between the ACS test data, the 
workshop report noted that the objective of the comparison using the 
national sample data was:

"to make comparisons between the long form and ACS for all states, 
large metropolitan areas, large substate areas, and population groups.

"The objective of the 1999-2001 comparison is to understand the factors 
associated with the differences between the 1999-2001 ACS and the 2000 
long form in the 31 areas, using the second comparison study to develop 
a calibration model to adjust the 2000 long-form estimates to roughly 
represent what the full ACS would have yielded in 2000."[Footnote 36]

Chapter 7 of the report was devoted to a discussion of calibration. The 
report stated that the model would "determine the effects that would be 
expected when switching from the long-form estimates to those from the 
ACS on various applications of long-form data." Once adjusted, the 
calibrated long-form data for 2000 can be compared with ACS data that 
are collected following full field implementation in 2003, "in order to 
understand the dynamics over time of such characteristics as poverty 
and employment."[Footnote 37]

The technical papers in the workshop's agenda book also noted other 
comparisons of ACS data. For example, Alexander discussed comparisons 
with CPS data, reporting that:

"We very much like the idea of viewing information from an ongoing 
comparison of ACS to CPS and other surveys as a way to help understand 
how the ACS 'error profile' might be changing over time and using this 
to help interpret ACS data in the context of the long-term time series 
of census estimates."[Footnote 38]

The use of independent controls for population and housing 
characteristics was also discussed at the workshop, but very generally, 
because the Census Bureau had not yet developed proposals for the 
controls. For example, the report's chapter 5 discussed improving the 
existing population controls. The Census Bureau reported discomfort 
with the quality of the existing county-level controls (from ICPE) and 
agreed that the ACS could be used to improve these estimates.[Footnote 
39] The Census Bureau also acknowledged that differences in residence 
rules and reference period would complicate the calculation of 
population weights. However, no discussion was reported of how the 
population counts from the 2010 Census would be used.

The report referred to moving averages in the conclusions chapter as 
one of the methodological problems noted at the workshop:

"the development of estimates that (a) sum to estimates at higher 
levels of geographic aggregation and (b) more closely approximate 
direct estimates at higher levels of aggregation . . . in the event 
that aggregate estimates are not constrained to (approximately) equal 
direct estimates (and also the release of direct estimates at lower 
levels of aggregation for analysis purposes) . . . ."[Footnote 40]

2000 Interim Report:

The Panel on Research on Future Census Methods, sponsored by the Census 
Bureau, was formed to examine alternative designs for the 2010 Census 
and to assist the Census Bureau in planning tests and analyses to help 
assess and compare their advantages and disadvantages. In addition to 
the first interim report, Designing the 2010 Census, released in 2000, 
a letter report was issued in 2001, and a second interim report was 
issued in 2003 (both discussed below). The panel issued a final report 
in 2004.

The panel's first interim report identified information from 2000 
Census data useful in assessing designs for the 2010 Census. In the 
executive summary, the panel made four specific recommendations and 
proposed other changes. One of the recommendations, relating to 
evaluation studies, is directly relevant to our report:

"The Census Bureau should develop a detailed plan for each evaluation 
study on how to analyze the data collected and how to use the results 
in decision making concerning 2010 census design. The Census Bureau 
should then use these plans to identify the benefits and resources 
required for each evaluation study, set priorities among them, and 
allocate sufficient resources for the careful completion of all or, at 
least, the highest priority evaluations."[Footnote 41]

In addition, the report proposed three changes for the 2010 Census and 
ACS. The first proposed change to the direction and nature of the 
evaluation program, was that the Census Bureau use the "ACS as a census 
testing platform"

"The American Community Survey is a proposed national, continuous, 
mailout-mailback survey of 250,000 households per month, with field 
follow-up that makes use of techniques closely related to those used in 
the census. Therefore, rather than rely exclusively on the two or three 
large-scale census tests, which are always at least slightly limited in 
their generalizability by the specific locations selected, the Census 
Bureau could use the ACS as a platform for testing possible changes in 
the census. This work could serve as preliminary testing to the larger 
mid-decade tests for the census design."[Footnote 42]

The second proposed change called for "a match study of the census 
short form and the ACS." This proposal, which could provide information 
on the effect of a change in the residence rule in the 2010 census, 
stated:

"The decennial census makes use of one residence rule definition, the 
ACS uses a second, and a third approach is being tested in the 
alternative questionnaire study. As the Census Bureau is well aware 
(based on the allocation of an experiment to this issue), confusion 
over residence rules is a source of possibly substantial error in the 
census. . . . The Census Bureau needs to find the residence rule 
(within the set of rules satisfying legal and other restrictions) that 
results in the most accurate estimates. To learn more about this issue, 
the panel proposes an ACS-short-form match study in 2000 to examine 
this and other short-form measurement error issues."[Footnote 43]

The third proposed change was the recommendation that the Census Bureau 
"form an ACS advisory group" to improve its efforts to consult with 
stakeholders. The panel stated:

"The development of the ACS raises a number of issues related to the 
quality of and planning for the 2010 census. There are also many other 
important technical issues raised by the introduction of the ACS into 
the federal statistical system. Formation of a technical working group 
could help to address many of these issues.î[Footnote 44]

2001 Letter Report:

The 2001 letter report--addressed from Benjamin King, Chair of the 
Panel on Research on Future Census Methods, to William Barron Jr., 
Acting Director of the Census Bureau--was prepared in response to a 
December 7, 2000, presentation by Census Bureau staff on the major 
elements of the Census Bureau's strategy for the 2010 Census. The panel 
recommended that the Census Bureau produce a "business plan" for the 
2010 Census that would provide an overall framework for development. It 
recommended that this plan include (1) a statement of objectives, (2) a 
timeline for completing tasks, (3) a cost-benefit analysis, and (4) 
more complete information on coordinating tasks within the Census 
Bureau.[Footnote 45] The panel also recommended the preparation of 
specific types of evaluation studies.

On the evaluation studies, the panel reported,

"The Bureau is currently conducting a wide array of evaluation studies 
and experiments designed to assess the quality of the 2000 census and 
inform approaches to the 2010 census. As noted above, the panel 
applauds the scope of these evaluation studies. However, the panel is 
concerned that the Bureau has not sufficiently focused its evaluation 
program and has instead labeled most of its evaluation categories as 
high priority."[Footnote 46]

In the letter report's conclusions, the panel recommended that the 
Census Bureau give the highest priority to studies and data analysis in 
seven specific areas, most of which related to the ACS. The panel's 
list of studies and analyses included the following recommendations, 
which we have also discussed:

"comparison of estimates from the ACS and 2000 census long-form data, 
in sites where both are available; coverage of the population, 
disaggregated by demographic and geographic subgroups; the 
effectiveness of major automated systems for data collection, capture, 
and processing; the quality and completeness of long-form data 
collection; and the effectiveness of operations used to designate 
special places and enumerate the group quarters and homeless 
populations."[Footnote 47]

In making these recommendations, the panel noted the need for the 
Census Bureau to maintain a strategy that would provide for "a smooth 
transition" from the long form to the ACS. The panel urged the Census 
Bureau:

"to broaden its justification for the ACS, detailing the need for and 
use of long-form data and how those data needs will be addressed 
through the ACS, perhaps in conjunction with the CPS and other 
demographic surveys. Accordingly, the Bureau should expedite ongoing 
evaluations that assess the quality of ACS data relative to the quality 
associated with the traditional census long form."[Footnote 48]

2003 Interim Report:

In the second interim report, Planning the 2010 Census, issued in 2003, 
the panel identified four areas of primary interest: reengineering the 
census, geographic coding, the ACS, and testing for the 2010 Census. 
With regard to the ACS, the panel reported in the executive summary 
that:

"The most basic question the panel faces regarding the ACS is whether 
it is a satisfactory replacement for the census long form. We recognize 
that significant estimation and weighting challenges must be addressed 
and that more research is needed on the relative quality of ACS and 
long-form estimates."[Footnote 49]

The panel found that the Census Bureau needed to complete evaluations 
of differences between 2000 Census long-form data and data from the ACS 
test sites and from the 2000-02 supplementary surveys. It also found 
that the Census Bureau needed to undertake a major effort to inform 
data users and stakeholders of the results of these evaluations and the 
features and problems of working with multiyear averages. One of the 
four main topics of this report was a separate chapter on the ACS, in 
which the panel discussed the following recommendations:

"The Census Bureau should carry out more research to understand the 
differences between and relative quality of ACS estimates and long-form 
estimates, with particular attention to measurement error and error 
from nonresponse and imputation. The Census Bureau must work on ways to 
effectively communicate and articulate those findings to interested 
stakeholders, particularly potential end users of the data.

The Census Bureau should make ACS data available (protecting 
confidentiality) to analysts in the 31 ACS test sites to facilitate the 
comparison of ACS and census long-form estimates as a means of 
assessing the quality of ACS data as a replacement for census long-form 
data. Again, with appropriate safeguards, the Census Bureau should 
release ACS data to the broader research community for evaluation 
purposes.

The Census Bureau should issue a user's guide that details the 
statistical implications of the difference between point-in-time and 
moving average estimates for various uses.

The Census Bureau should identify the costs and benefits of various 
approaches to collecting characteristics information should support for 
the full ACS not be forthcoming. These costs and benefits should be 
presented for review so that decisions on the ACS and its alternatives 
can be fully informed."[Footnote 50]

With regard to the first recommendation, the panel stated that:

"The fact that the Census Bureau has not done more in comparing the 
data collected from the 31 test sites, the C2SS, and the 2001 and 2002 
Supplementary Surveys with the data collected by the 2000 census long 
form is disappointing. Such analyses would help assess the quality of 
ACS data and would be helpful in making the argument for transition 
from the long form to the ACS. This deficiency is probably due to 
limited analytic resources at the Census Bureau and creates an argument 
for 'farming out' this analysis to outside researchers."[Footnote 51]

On the recommendation about the need for more information on multiyear 
or moving averages, the panel discussed several technical issues. The 
panel commented that:

"The ramifications of this basic concept emerge when moving average 
estimates are entered into sensitive allocation formulas or compared 
against strict eligibility cutoffs. A smoothed estimate may mask or 
smooth over an individual year drop in level of need, thus keeping the 
locality eligible for benefits; conversely, it may also mask 
individual-year spikes in activity and thus disqualify an area from 
benefits. It is clear that the use of smoothed estimates is neither 
uniformly advantageous nor disadvantageous to a locality; what is not 
clear is how often major discrepancies may occur in practice."[Footnote 
52]

On using moving-average data to measure year-to-year changes, the panel 
commented:

"It is incorrect to use annual estimates based on moving averages over 
several years when assessing change since some of the data are from 
overlapping time periods and hence identical. At the least, the results 
will yield incorrect estimates of the variance of the estimates of 
change. Therefore, users should be cautioned about this aspect of the 
use of moving averages."[Footnote 53]

In both recommendations on evaluations and moving averages, the panel 
called for the Census Bureau to engage in a greatly expanded effort to 
inform users and stakeholders. It also suggested that the Census Bureau 
farm out some of the research efforts.

In summarizing the results of its efforts, the panel noted the 1995 NAS 
report, as follows:

"Eight years later, faced with the task of offering advice on making 
the vision of continuous measurement a reality in the 2010 census, the 
similarity between the arguments then and now is uncanny. Similar, too, 
are the points of concern; the current panel is hard-pressed to improve 
upon the basic summary of concerns outlined by our predecessors. We 
are, however, much more sanguine that a compelling case can be made for 
the ACS and that it is a viable long-form replacement in the 2010 
census."[Footnote 54]

However, while the panel was identifying its concerns, it also 
supported full funding of the ACS, believing that existing "flaws" in 
the plan could be resolved.

The 2000 Census: Counting under Adversity:

In 2004, the Panel to Review the 2000 Census, sponsored by the Census 
Bureau, issued a report entitled The 2000 Census: Counting under 
Adversity. The findings were based primarily on the panel's review of 
information from the 2000 Census. The panel's charge had been to 
"review the statistical methods of the 2000 Census, particularly the 
use of the Accuracy and Coverage Evaluation Program and dual-systems 
estimation, and other census procedures that may affect the 
completeness and quality of the data."[Footnote 55] Thus, although the 
report focused on the 2000 Census, it made some recommendations for 
improving the 2010 Census. Its major recommendation was that:

"the Census Bureau, the administration, and Congress agree on the basic 
design for the 2010 census no later than 2006 in order to permit an 
appropriate, well-planned dress rehearsal in 2008. In particular, this 
agreement should specify the role of the new American Community Survey 
(ACS). Further delay will undercut the ability of the ACS to provide, 
by 2010, small-area data of the type traditionally collected on the 
census long-form sample and will jeopardize 2010 planning, which 
currently assumes a short-form-only census."[Footnote 56]

In its discussion of the 2010 Census, the report included several 
recommendations on ACS operations and evaluations. The panel 
recommended that the Census Bureau develop estimates of the effect on 
estimates from the 2000 long form resulting from imputation as well as 
sampling variability and nonresponse. More specifically,

"the Bureau should also study the effects of imputation on the 
distributions of characteristics and the relationships among them and 
conduct research on improved imputation methods for use in the American 
Community Survey (or the 2010 census if it includes a long-form 
sample)."[Footnote 57]

Finally, the panel recommended that the Census Bureau's plans for the 
2010 Census "include research on the trade-offs in costs and accuracy 
between imputation and additional fieldwork for missing data 
(Recommendation 4.2)."[Footnote 58] The panel also recommended that the 
Census Bureau:

"publish distributions of characteristics and item imputation rates, 
for the 2010 census and the American Community Survey (when it includes 
group quarters residents), that distinguish household residents from 
the group quarters population (at least the institutionalized 
component). Such separation would make it easier for data users to 
compare census and ACS estimates with household surveys and would 
facilitate comparative assessments of data quality for these two 
populations by the Census Bureau and others."[Footnote 59]

The panel's findings were similar to our findings, with one major 
difference. The panel's findings imply that some research on the ACS 
can be conducted after the results of the 2010 Census short form become 
available. In contrast, we see that such research is needed in order to 
improve the ACS by 2008, the first year in which ACS data will enter 
into the calculation of the 5-year average estimates (2008-12) that 
will replace the long form.

[End of section]

Appendix III: The Decennial Census Long Form and the Evolution of the 
ACS Plan:

Decennial Census Long Form:

In the decennial census for 1940 and for 1950, the Census Bureau used a 
single form to collect, from all households, population and key 
characteristics such as age and gender and, from a sample of 
households, detailed demographic, economic, and housing items. In the 
1940 Census, the Census Bureau used a sample of 5 percent of the 
population to collect data on questions on income, internal migration, 
and Social Security status, as well as on more refined questions on 
unemployment. In addition, the Congress authorized a new set of 
questions about the types of plumbing, heating, and appliances in 
dwellings.

Beginning with the 1960 Census, the first conducted by mail, it became 
necessary to use separate forms--a short form to collect population 
data from all households and a long form to collect the detailed items 
from a sample of households. In the 2000 Census, for example, the 
Census Bureau conducted a sample of 17 percent of the population and 
asked 45 questions on the long form. Since 1960, the long form has 
evolved into a cost-efficient way to collect data federal agencies need 
that minimizes respondent burden. For 2000, for example, the long form 
consisted of 45 questions that the Census Bureau developed working 
through OMB and with the consent of the Congress.[Footnote 60] Each 
question provided information required by statute. Thus, the 2000 long 
form provided all federal departments and agencies with critical data, 
and it was estimated that these data were used to allocate more than 
$200 billion in federal funds.[Footnote 61]

Evolution of ACS Plan:

In the 1950s, Census Bureau officials and users of Decennial Census 
data had begun to develop a program to provide intercensal data on 
population characteristics. The first major proposal to provide 
intercensal data called for a mid-decade census that would provide 
information every 5 years. In 1976, the Congress enacted legislation to 
require a mid-decade census beginning with 1985, but did not fully fund 
the program.

In the late 1980s, the Census Bureau shifted efforts to provide 
intercensal estimates to a program based on CM methodology, or 
Continuous Measurement. This approach would provide for more timely 
population data as well as the detailed demographic, economic, and 
housing data collected every 10 years by the Decennial Census long 
form.[Footnote 62] The program would integrate a new sample survey, 
existing surveys, administrative records, and statistical modeling. 
After a thorough analysis of alternatives based on this methodology, 
the Census Bureau developed a plan similar to the current ACS to 
replace the 2000 Census long form.

Initial $2.6 million funding for the CM program was included in the 
2000 Decennial Census budget for fiscal year 1995. These funds were to 
develop, test, and evaluate a CM program to replace the Decennial 
Census long form and to provide more timely long-form type data. In the 
program description in the budget documents, the Census Bureau reported 
that it planned to develop the new program that would integrate a new 
sample survey, existing surveys, administrative records, and 
statistical modeling. Table 2 shows that about $330 million has been 
provided to fund the CM program since 1995, with funding provided 
separately until 2003 and additional funding from both the 2000 and 
2010 Decennial Census programs. Beginning with 2003, all funding has 
been provided as part of the 2010 Census program. The Census Bureau 
requested $165 million for fiscal year 2005.

Table 2: Continuous Measurement and ACS Funding, Fiscal Years 1995-
2005:

Fiscal year: 1995; 
Budget[A]: $2.6; 
Activity: Develop and test a continuous measurement (CM) system to 
replace 2000 Census long form; 
study integration of administrative records, existing current surveys, 
and statistical modeling with a new survey for CM programs; 
Other information: None.

Fiscal year: 1996; 
Budget[A]: $10.0; 
Activity: Develop and test a CM system to replace 2000 Census long form 
and provide annual data; 
Other information: Continue evaluating and developing an integrated CM 
program.

Fiscal year: 1997; 
Budget[A]: $16.6; 
Activity: Rename test survey American Community Survey (ACS); complete 
data collection and processing for 1996 survey at 4 test sites; develop 
list to cover group quarters; 
Other information: Develop methods for integrating administrative 
records and information from household survey data into CM program.

Fiscal year: 1998; 
Budget[A]: $16.6; 
Activity: Continue testing and processing 1997 test site survey data; 
Other information: Make long-run plans for replacing 2010 long form 
with full implementation of ACS in 2003.

Fiscal year: 1999; 
Budget[A]: $20.0; 
Activity: Publish 1998 test site data and expand test site surveys to 
31 sites; prepare for supplementary surveys from national sample to 
begin with 2000 to compare with 2000 Census long-form data; 
Other information: Develop statistical models to evaluate comparisons 
of long form to supplementary surveys; continue testing to integrate 
information from administrative records.

Fiscal year: 2000; 
Budget[A]: $47.0; 
Activity: Provide for 2000 supplementary survey; continue comparison 
studies of differences for test site areas; develop plans for 
comparison studies with supplementary survey and using multiyear 
averages; 
Other information: None.

Fiscal year: 2001; 
Budget[A]: $45.2; 
Activity: Provide for continuation of supplementary surveys; continue 
testing and comparison studies with data from test sites and national 
survey; begin testing in Puerto Rico; 
Other information: Continue processing data from test sites for 
comparison studies.

Fiscal year: 2002; 
Budget[A]: $56.1; 
Activity: Prepare for full implementation in 2003; 
Other information: Continue evaluating comparison studies for test-site 
and supplementary survey data.

Fiscal year: 2003; 
Budget[A]: $57.1; 
Activity: Prepare to begin full implementation for 2005; 
Other information: Complete testing for group quarters and Puerto Rico.

Fiscal year: 2004; 
Budget[A]: $64.8; 
Activity: Prepare to begin full implementation for 2005; 
Other information: None.

Fiscal year: 2005; 
Budget[A]: $165.0; 
Activity: Full implementation; 
Other information: None. 

Sources: Budget of the United States, House of Representatives Report 
108-401, and Census Bureau budget documents.

[A] Dollars in millions. Fiscal year 1995 funding provided as part of 
the 2000 Decennial Census program. Fiscal year 1996-99 funding provided 
by CM program. Fiscal year 2000 and 2001 funding provided as both the 
CM program and part of the 2000 Census program. Fiscal year 2002 
funding provided as both the CM program and part of the 2010 Census 
program. Beginning with fiscal year 2003, funding provided as part of 
the 2010 Census program. Fiscal year 2005 figure is the budget request.

[End of table]

In 1996 and 1997, funding was provided to field-test what became the 
ACS, to replace the 2000 Census long form. The ACS was to begin in 1999 
with an annual sample of 4.8 million housing units for 1999, 2000, and 
2001 and 3 million housing units for subsequent years. Under this plan, 
a 3-year average of ACS data for 1999-2001 was to replace the 2000 
Census long form.[Footnote 63] It would provide the same detailed items 
and same level of geographic detail as the traditional long form with 
about the same quality. Annual ACS data would subsequently be provided 
for geographic areas with populations of 65,000 or more, 3-year 
averages would provide ACS data for geographic areas with populations 
larger than 20,000, and 5-year averages would provide ACS data for 
small geographic areas, such as census tracts, small towns, and rural 
areas. The 5-year average for 2010, 2020, and beyond would replace 
future Decennial Census long forms.

In the 1998 budget request, the Census Bureau shifted the timing for 
replacing the long form from the 2000 Census to the 2010 Census. As a 
result, it was funded to conduct annual supplementary surveys of 
750,000 households beginning with 2000, in addition to the ACS testing 
at four test sites (or counties). The Census 2000 Supplementary Survey, 
known as C2SS, and the surveys for subsequent years were to be used to 
test the feasibility of collecting long-form data at the same time as, 
but in a separate process from, the Decennial Census. Data from C2SS 
and the supplementary surveys were also to be used to test ACS data 
usability and reliability and to evaluate operational and programmatic 
issues associated with implementing the ACS. Also, the number of test 
sites was increased to 31 by 1999. Funding to compare and evaluate 
differences between data collected from the 2000 Census long form and 
the ACS testing programs began in 1999, to develop data to expand 
coverage to group quarters and Puerto Rico in 2001. Plans to integrate 
existing surveys, administrative records, and statistical modeling into 
the new program were dropped in 2001.

The 1998 budget request also reported that the Census Bureau would 
proceed with plans to replace the 2010 Census long form with an ACS 
based on an annual sample of 3 million housing units, as with the 
previous plan. Unlike that plan, the sample size for 2009-11 would not 
increase to provide 3-year averages for 2010. This revised plan called 
for full implementation of the ACS in 2003. Full ACS data for 2003 to 
2007 would have made 5-year averages available in 2008, 4 years before 
the long-form sample statistics from the 2010 Census would become 
available. However, budget decisions by the Congress delayed full 
implementation until the fourth quarter of fiscal year 2004.

[End of section]

Appendix IV: Continuous Measurement ACS Testing and Development 
Program:

The Congress initially provided funds for testing the CM methodology in 
1994. As we have noted, the Census Bureau had begun formal testing of 
the CM program in 1996 with an operational test of the ACS in four 
counties; this test was expanded to 31 test sites by 1999. A second 
testing program, the Supplementary Survey program, began in 2000 as a 
part of the 2000 Decennial Census. The Census Bureau designed C2SS to 
test the feasibility of collecting long-form data at the same time as, 
but in a separate process from, the 2000 Decennial Census. Data from 
C2SS and the same supplementary surveys, beginning with 2001, were also 
to be used to test ACS data usability and reliability. According to the 
Census Bureau, these surveys were to be used to examine technical, 
statistical, and operational issues associated with implementing the 
ACS and to document the key results in a series of reports.[Footnote 
64]

Before field testing began, the Census Bureau had conducted an 
extensive research program to identify the issues related to using the 
CM methodology and to replacing the long form. The research program 
resulted in a series of 20 reports, known as the Continuous Measurement 
Series, between 1992 and 1995.[Footnote 65] These reports, most of 
which were prepared by Charles Alexander, addressed a wide range of 
topics such as replacing the 2000 Census long form, collecting 
intercensal population data, and integrating the ACS with existing 
household surveys. The reports on replacing the long form identified 
the key issues that needed testing, and they served as the primary 
input to the Census Bureau's ACS test program. These issues included 
those subsequently tested by the Census Bureau as well as the 
unresolved issues we identify in this report.

Following the CM reports, Census Bureau staff presented papers from 
1995 through 2001 on ACS testing at various professional association 
and similar meetings, as well as at a 1998 symposium on the ACS 
sponsored by the Census Bureau.[Footnote 66] For example, the 1995 
paper by Love, Dalzell, and Alexander discussed issues related to the 
evaluation of the 1996 test site results, expressing concern about 
population controls and residence rules as well as the need for 
consultation with users.[Footnote 67] They reported that the Census 
Bureau was planning to conduct research using data from the 1996 test 
sites to produce controls at the census tract and block group level. 
They also noted that the Census Bureau would need to conduct research 
on the residence rule.

Alexander and Wetrogan also discussed the issue of population controls 
in their 2000 paper.[Footnote 68] They reviewed possible methods for 
using ICPE to develop controls for the ACS and discussed using ACS 
estimates on the foreign-born U.S. population to improve the Census 
Bureau's foreign-migration component of the intercensal estimates. 
(They reported that this effort would be part of what the Census Bureau 
had previously referred to as the Program of Integrated Estimates.) 
They also noted the need to consult with users on how to present 
information on the differences in ACS controls and ICPE in ACS 
publications.

Several papers have focused on the key role of evaluating differences 
among the ACS test data, census long-form data, and CPS data. 
Alexander, Dahl, and Weidman reported in 1997 that during the 
demonstration period, they would be working closely with experts 
familiar with specific test sites to learn about the quality of the ACS 
estimates.[Footnote 69] For example, they reported that the Census 
Bureau would be looking into sources of differences between the 1999-
2001 ACS test-site average estimates and the 2000 Census long-form 
results and using the results of differences between the 2000-02 
national sample and the 2000 long form to generate model-based 
estimates for small geographic areas. The authors noted that these 
model-based estimates, based largely on information from test sites, 
would be used to interpret changes between 2000 and future ACS 
estimates.

In another 1997 paper, Davis and Alexander reported the Census Bureau's 
action plan for evaluation studies.[Footnote 70] They called for 
evaluating the results of all test sites and releasing the expert 
review of the analyses of the differences between the 1999-2001 ACS and 
the 2000 Census long form. The schedule called for releasing this 
information before beginning the implementation of the full ACS. 
Alexander's 1998 paper on completed research, research in progress, and 
planned research included among the four items for planned research a 
"close study of differences between 1999-2001 ACS and 2000 long form in 
comparison areas."[Footnote 71]

The quality of the ACS measures of income was the subject of the paper 
Posey and Welniak presented at the Census Bureau's 1998 symposium on 
the ACS.[Footnote 72] They compared income reported in the 1996 ACS and 
1990 Decennial Census in an effort to evaluate the quality of the ACS 
income data. One of the adjustments they made to compare the two series 
was for the effect of inflation between 1990 and 1996. They noted that 
the results of the comparisons indicated a potential problem that may 
relate to the ACS inflation adjustment. (They described the calculation 
of the adjustment, which is based on the CPI, but did not provide a 
rationale for using the adjustment in the ongoing ACS data.)

Alexander and two BLS staff reported in 1999 on the potential for using 
the ACS to improve labor force data from the CPS for state and smaller 
geographic levels.[Footnote 73] They stressed that to develop 
procedures for making these improvements, much research would be needed 
to evaluate differences between the ACS and CPS.[Footnote 74]

The last research paper in this period was Alexander's 2001 paper 
focusing on the origins of the CM methodology and its 
developers.[Footnote 75] He discussed the ACS in the context of the 
methodology, noting several important differences related to the nature 
of the ACS. He included a review of the Census Bureau's testing and 
evaluation program, noting that the ACS test-site program had been 
expanded and that national sample supplementary surveys had been added. 
He said that these test data would be compared with the 2000 Census 
long-form data and that in 2001 and 2002, the Supplementary Survey 
would be used as part of the transition to the ACS. He also pointed to 
unresolved issues relating to the residence rule and the multiyear 
averages, because they would provide users with multiple estimates for 
geographic areas with populations larger than 20,000.

Between 2001 and 2003, the Census Bureau has issued three official 
reports and one internal report on the status of the ACS testing and 
development program. In Demonstrating Operational Feasibility, 
published in July 2001, the Census Bureau gave a brief history of the 
ACS development program, which by 2001 was focused on preparing for 
full implementation in 2003 (although the Census Bureau later revised 
this to 2004) but on its operational feasibility, using data from 
C2SS.[Footnote 76] On the basis of the Census Bureau's analysis of the 
results of its tests of operation feasibility, it reported the tests a 
success. However, it recognized that more evaluation on measures of 
data quality was necessary, as well as on differences between ACS and 
2000 Census long-form data. The Census Bureau announced that over the 
next 2 years it would issue reports comparing data from the 2000 Census 
long form at the national, state, and smaller geographic areas with 
data from the C2SS and the ACS development program.

Demonstrating Survey Quality, published in May 2002, focused on 
measures of C2SS survey quality, summarizing sampling and nonsampling 
error levels in both C2SS and the 31 ACS test sites.[Footnote 77] The 
Census Bureau used available, generally accepted measures of 
quality.[Footnote 78] On the basis of its analysis of the results of 
these quality tests, the Census Bureau reported the tests a success. 
This conclusion rested on test results that showed the C2SS program 
capable of providing reliable long-form data.

As in the July 2001 report, the Census Bureau recognized that more 
evaluation was necessary on measures of data quality as well as on 
differences between ACS and 2000 Census long-form data and the detailed 
estimates produced from C2SS. The Census Bureau repeated its commitment 
that over the next year and a half, it would release other reports to 
(1) analyze in detail basic demographic characteristics (relationship, 
race, tenure) produced from the C2SS at the national and state levels, 
including comparisons between C2SS and Census 2000; (2) describe the 
data release plan and products for the ACS and the usability and 
accessibility of estimates resulting from ACS methods; and (3) give 
several detailed analyses of selected social, economic, and housing 
characteristics (education, income, commuting patterns), including 
comparisons between C2SS and Census 2000 at the national and some 
subnational levels.

In June 2002, shortly after Demonstrating Survey Quality was released, 
a team of Census Bureau specialists who had been working on the ACS for 
several years prepared an internal report on testing. They presented a 
revised program development plan and identified key questions to be 
answered in testing the adequacy of the ACS in replacing the Decennial 
Census long form. Their plan included the preparation of a series of 
nine evaluation reports over 2 years.[Footnote 79] The reports that 
evaluated differences between the 2000 Census short-form data (100 
percent reported) and corresponding C2SS items were included in 
Demonstrating Survey Quality. Three reports to be completed between 
October 2002 and January 2003 would evaluate differences between the 
detailed housing, social, and economic characteristics between C2SS and 
the 2000 Census long form, as described in Demonstrating Survey 
Quality. (Although this schedule was later extended to the end of 2003, 
these three reports still had not been released when we prepared our 
final draft of this report.)

Finally, the team's plan included a report that would focus on the 
comparisons of 3-year averages for the basic demographic, housing, 
social, and economic characteristics from the C2SS and ACS test sites 
and comparable estimates in the 2000 Census long form. The last report 
in the plan would compare data for 2001 and 2002 with measures shown in 
Demonstrating Operational Feasibility. The plan did not provide 
completion dates for these reports.

American Community Survey Operations Plan, Release 1, published in 
March 2003, identified research projects to be completed in preparation 
for full implementation of the ACS.[Footnote 80] Two projects were on 
"weighting and estimation," which covered the methodology for using 
independent population and housing controls, and on "program of 
integrated estimates," which covered the calculation of these controls 
from the Census Bureau's intercensal population estimates program. The 
operations plan also reported on the schedule for completing several 
comparison and evaluation projects with ACS and 2000 Census long-form 
data discussed in Demonstrating Survey Quality. It discussed the need 
to evaluate multiyear estimates from the supplementary surveys to 
demonstrate the usability, reliability, and stability of ACS estimates 
over time, and it stated that a report comparing 3-year ACS data with 
data from the 2000 Census long form would be released in mid-
2003.[Footnote 81]

The Census Bureau reported that the results of these research projects 
would not be available in 2004. Instead, it said, it would use interim 
procedures, taking "extensive long-term investigation and 
experimentation" to develop final procedures.[Footnote 82] For the ACS 
weighting and estimation project, the Census Bureau reported that it 
would be using an interim adjustment to adjust the intercensal 
population and housing characteristics estimates to the ACS residence 
concept. The Census Bureau reported that ACS estimates of occupied 
housing units, households, and householders should agree at all 
geographic levels.

For the program of integrated estimates project, the operations plan 
discussed the need for more research to introduce improvements to the 
estimates from ICPE. (The ACS estimates are weighted to a population 
benchmark, either the most recent Decennial Census results or the most 
recent ICPE estimates.) The Census Bureau reported that because the 
accuracy of the intercensal estimates is important to overall ACS 
accuracy, it is important to use ACS data wherever appropriate to 
improve the intercensal estimates. The plan for the program on 
integrated estimates will use information from the 2000 Census, more 
current ACS distributions of population characteristics, and 
administrative records to produce improved population and housing unit 
estimates for all areas, including small areas. The plan also discussed 
improving housing characteristics by incorporating ACS distributions of 
local area vacancy rates and household characteristics into statistical 
models to better estimate subcounty populations. No time schedule for 
completing the research was provided.

Finally, the March 2003 American Community Survey Operations Plan, 
Release 1 discussed a plan in the ACS to cover group quarters. Persons 
living in group quarters live in places that the Census Bureau does not 
classify as housing units--for example, nursing homes, prisons, college 
dormitories, military barracks, institutions for juveniles, and 
emergency and transitional shelters for the homeless. Such residences 
accounted for roughly 2.8 percent of the population in 2000. Although 
data on group quarters were collected at the test sites beginning with 
1999, data were not collected in C2SS or subsequent supplementary 
surveys. The operations plan discussed the use of an updated Census 
2000 Special Places file for the sampling frame for the full ACS. In 
this case, the plan noted, training field representatives on collecting 
data from this population is to begin in October 2004, so that full 
data collection production can begin in January 2005.

Census Bureau staff made a presentation on comparison and evaluation 
reports at the April 2003 meetings of the Census Advisory Committee. 
The paper's author reported that work was under way on the comparison 
reports noted in the March 2003 operations plan, and she described the 
methodology to be used to evaluate differences between the 2000 long 
form and C2SS. She also reported that the results of the comparisons 
would be used to identify how the ACS should be improved but that 
additional research would be needed to address consistency over time 
between the 2000 Census and the full ACS. She stressed the importance 
of evaluating consistency "in educating users on the transition from 
the decennial census sample estimates to the ACS estimates."[Footnote 
83]

With regard to the comparison report of selected demographic, housing, 
social, and economic characteristics of 3-year estimates from the ACS 
test sites to the 2000 Census, the Census Bureau let four contracts 
with local experts to conduct comparisons of 3-year averages of ACS 
data for 1999-2001 for selected test sites with selected 2000 Census 
long-form data as well as 2000 Census population and housing unit 
characteristics. The comparisons, prepared at the county and census 
tract levels, would be made for measures of data quality (self-response 
rates, sample unit nonresponse rates, item nonresponse rates, and 
sample completeness ratios), as well as for data levels (counts, 
percentages, means, and medians) for demographic, social, economic, and 
housing characteristics.

In summer 2003, Census Bureau staff presented a number of research 
papers on the ACS at the annual Joint Statistical Meetings. Papers 
evaluated differences between long-form and C2SS data items, such as 
persons with disabilities, educational attainments, and income. Most of 
the papers that provided comparisons with long-form data indicated 
whether differences were statistically significant for every 
comparison. Comparisons were presented at a variety of geographic 
levels (national, state, and test site levels). Some papers cited 
operational differences as possible explanatory factors, but 
information was not presented using a standard set of factors.

The Census Bureau published ACS-2010 Census Consistency Review Plan, an 
internal document, at the beginning of October 2003. Its purpose was to 
identify methods for major operations used in the ACS and for the 2010 
Census that were likely to lead to inconsistent results and to 
recommend ways to address these inconsistencies.[Footnote 84] Papers 
prepared on these operations were to discuss how an issue might result 
in inconsistencies between the ACS and 2010 Census results and to set 
forth options for dealing with consistency issues, including a research 
process. The plan identified residence rules and group quarters as two 
topics. It did not discuss completing the work in time to incorporate 
it into the full ACS in the next several years.

Also in October 2003, the Census Bureau made two public announcements 
related to the ACS development plan at the Census Advisory Committee 
meetings. Two papers related directly to projects described in American 
Community Survey Operations Plan, Release 1. In "Enhancing the 
Intercensal Population Estimates Program with ACS Data: Summary of 
Research Projects," Weidman and Wetrogan reported on research to 
improve the intercensal estimates by using ACS data for two "high 
priority" areas--international migration and internal migration. This 
work was being conducted within the Program of Integrated 
Estimates.[Footnote 85] The second paper described options for 
determining population control weights for ACS implementation in fall 
2004 but did not indicate that research was under way to determine the 
effect of the options.[Footnote 86]

Another source of information related to ACS development was the 
various reports prepared as part of the Census 2000 Testing, 
Experimentation, and Evaluation Program. Schneider's January 2004 
report compared employment, income, and poverty estimates from the 2000 
Census long form and the CPS.[Footnote 87] From this comparison, the 
author concluded that this work should be continued in an effort to use 
the results of the comparisons to improve consistency between data 
collected in the CPS and data in the ACS; the ACS uses the same 
questions as the 2000 long form. The author also identified for 
additional research long-form questions that performed badly, based on 
a reinterview survey.

From May to July 2004, the Census Bureau released seven ACS evaluation 
reports. Four reports compared data from the 2000 Census long form and 
the C2SS at the national level. Two reports compared these long-form 
data with 1999-2001 data from the ACS test sites for selected counties 
and one of these compared these data at the tract level. The other 
report reviewed operational data from the 2001 and 2002 supplementary 
surveys. In most of the reports comparing long-form and ACS data, the 
Census Bureau identified additional work that was needed to improve the 
quality of the ACS estimates or to help explain differences between the 
two sets of data for 2000. As noted earlier, these comparisons were 
limited to the national level. (The seven new reports are listed in the 
bibliography.)

[End of section]

Appendix V: Current Status of Unresolved Issues:

Independent Controls for Population and Housing Characteristics:

According to the Census Bureau's plans, the calculation of independent 
controls for population characteristics (age, sex, race, and ethnicity) 
and housing characteristics for the full ACS will require a 
significantly different methodology from that used for the ACS 
supplementary surveys. Controls will be needed at the same level of 
geographic area detail as those that were used for the 2000 Census long 
form and will need to reflect the new concepts of residence and 
reference period underlying the ACS.

For the annual ACS supplementary surveys, these characteristics were 
used from ICPE as the independent controls. ICPE uses Decennial Census 
short-form data as benchmarks and administrative record data to 
interpolate between and extrapolate from the census 
benchmarks.[Footnote 88] The program provides "official" annual 
estimates of population and housing characteristics at the county 
level, and for some subcounty levels, as of July 1 of each year, using 
the usual residence concept for seasonal residents. The program also 
provides annual estimates of total population and housing units for all 
areas of general-purpose government, such as cities, villages, towns, 
and townships.[Footnote 89] Table 3 shows information on the 
calculation of the independent controls used for the 2000 Census long 
form, the ACS supplementary series, and the fully implemented ACS 
through 2012.

Table 3: The 2000 Census Long Form and ACS Use of Independent Controls 
for Population and Housing Characteristics:

Survey and date: 2000 Census long form; 
Source of controls[A]: 2000 Census; 
Weighting area: About 65,000 areas; 
Items weighed: Population: age group (13), sex, race (6), Hispanic 
origin (2). Housing: occupied or vacant, owner or renter; 
Residence concept: Usual; 
Reference period: Apr. 1, 2000.

Survey and date: ACS test site: 1999; 
Source of controls[A]: ICPE benchmarked to 1990 Census; 
Weighting area: County; 
Items weighed: Population: age group,[B] sex, race (3), Hispanic 
origin (2). Housing: no direct use of housing weights; 
Residence concept: Usual; 
Reference period: July 1, 1999.

Survey and date: ACS test site: 2000; 
Source of controls[A]: 2000 Census; 
Weighting area: County; 
Items weighed: Population: age group,[B] sex, race/ Hispanic origin 
(6), Housing: total number of units; 
Residence concept: Usual; 
Reference period: Apr. 1, 2000.

Survey and date: ACS test site: 2001-04[C]; 
Source of controls[A]: ICPE benchmarked to 2000 Census; 
Weighting area: County; 
Items weighed: Population: age group,[B] sex, race/ Hispanic origin 
(6). Housing: total units; 
Residence concept: Usual; 
Reference period: July 1, 2001-04.

Survey and date: ACS supplementary survey: 2000; 
Source of controls[A]: 2000 Census; 
Weighting area: County or county combinations; 
Items weighed: Population: age group,[B] sex, race/ Hispanic origin 
(6). Housing: total units; 
Residence concept: Usual; 
Reference period: Apr. 1, 2000.

Survey and date: ACS supplementary survey: 2001-04[C]; 
Source of controls[A]: ICPE benchmarked to 2000 Census; 
Weighting area: County or county combinations; 
Items weighed: Population: age group,[B] (14), sex, race/ Hispanic 
origin (6). Housing: total units; 
Residence concept: Usual; 
Reference period: July 1, 2001-04.

Survey and date: Full ACS: 2005-09,[D]; 
Source of controls[A]: ICPE benchmarked to 2000 Census adjusted to ACS 
residence concept; (adjustment methodology not announced); 
Weighting area: Three options:[E]; 
(1) Intercensal estimates (usual residence) for large areas and ACS 
estimates (current residence) for small areas; 
(2) Option 1 but model- based estimates to modify intercensal 
estimates for large areas to current residence; 
(3) Develop methods to generate current residence estimates for all 
small areas; 
Other: Same areas as 2000 Census long form using intercensal estimates 
and detail from 2000 census; 
Items weighed: Not announced; 
Residence concept: Current; 
Reference period: Not announced[F]; 
Comments: Residence concept changes; weighting area options part of 
research program to determine weighting areas for use with 3-and 5-
year averages for 2010.

Survey and date: Full ACS: 2010[E]; 
Source of controls[A]: 2010 Census adjusted to ACS residence concept; 
(adjustment methodology not announced); 
Weighting area: Not announced[G]; 
Items weighed: Not announced; 
Residence concept: Current; 
Reference period: Not announced; 
Comments: 2010 short-form data replace ICPE estimates.

Survey and date: Full ACS: 2011; 
Source of controls[A]: ICPE benchmarked to 2010 Census adjusted to ACS 
residence concept; (adjustment methodology not announced); 
Weighting area: Not announced[G]; 
Items weighed: Not announced; 
Residence concept: Current; 
Reference period: Not announced.

Survey and date: Full ACS: 2012; 
Source of controls[A]: ICPE benchmarked to 2010 Census adjusted to ACS 
residence concept (adjustment methodology not announced); 
Weighting area: Not announced[G]; 
Items weighed: Not announced; 
Residence concept: Current; 
Reference period: Not announced. 

Source: GAO analysis of Census Bureau documents.

[A] The Intercensal Population Estimates Program (ICPE) develops and 
disseminates annual estimates of the total population and the 
distribution by age, sex, race, and Hispanic origin for the nation, 
state, counties, and total population for subcounty functioning 
government units. ICPE is authorized by 13 U.S.C. §181, which requires 
the production of "current data on total population and population 
characteristics." ICPE estimates, benchmarked to the latest Decennial 
Census counts, are compiled using administrative record data on births, 
deaths, and migration. Because they are benchmarked to the census, they 
reflect the usual residence concept. They are adjusted to reflect the 
counts as of July each year.

[B] Not available.

[C] Assumes that test program and supplementary surveys end after 2004:

[D] When 2010 Census estimates become available, ICPE estimates 
beginning with 2001 will be revised to reflect the new benchmark. There 
is no announced use of revised ICPE estimates to revise previously 
published ACS estimates.

[E] The three options are from Alfredo Navarro, "American Community 
Survey: Use of Population Estimates as Controls in the ACS Weighting," 
presented at Census Bureau Advisory Committee of Professional 
Associations meeting, Washington, D.C., October 23, 2003.

[F] One of the Department of Commerce comments on our draft report 
stated that the Census Bureau would be using July 1 as the reference 
period for a given year's ACS annual average.

[G] There is no announced use of the tract or block group data from the 
2010 census.

[End of table]

Using ICPE for the ACS supplementary surveys, the Census Bureau 
prepared controls for counties, or combinations of counties. As shown 
in table 3, for the residence concept, controls from the 2000 Census 
and ICPE, which were based on the usual residence concept, were used. 
The reference period for the ACS test program for all years except 2000 
was for July 1; for 2000, it was for April 1. (Controls for the 2000 
Census long form also were for April 1.)

For the full ACS, the Census Bureau will use controls based on the 
current residence concept. According to the Census Bureau, the current 
residence concept recognizes that the place of residence does not have 
to be the same throughout a year, so that the current residence concept 
allows the ACS data to more closely reflect the actual characteristics 
of each area. The Census Bureau will use the current residence concept 
because the ACS is conducted every month and produces annual averages 
rather than point-in-time estimates, as the Decennial Census does. 
Also, because the ACS data are collected monthly, it will be necessary 
to use independent controls that define the reference period as the 
average for the year using a July 1 reference period.

To produce ACS estimates for the full sample, the Census Bureau will 
need new methodologies for calculating independent controls. For the 
first annual estimates, for 2005, a methodology will be needed to 
provide ACS-defined controls for all places with population of 65,000 
or more, including those for which intercensal population estimates are 
not available. For the 2005-07 estimates, which will be used to 
calculate the first multiyear averages, a methodology for controls for 
geographic areas with populations between 20,000 and 65,000 will be 
needed. For the 2008-12 estimates, a methodology for controls down to 
the geographic levels used for the 2000 Census long form will be 
needed. Finally, when the population and housing characteristics data 
from the 2010 Census short form become available and are incorporated 
into the ICPE estimates, another new methodology will be needed to 
revise the ACS controls for 2010.[Footnote 90]

The Census Bureau also has reported that it is not planning to revise 
earlier years' ACS data for consistency with revised 2010 estimates 
unless the inconsistencies between the 2010 ICPE and 2010 Census 
characteristics were significant. Table 4 shows the differences between 
population estimates at the county level for 2000 using ICPE based on 
the 1990 Census and the corresponding data from the 2000 Census. In 
2000, the population estimates for almost 20 percent of the counties 
differed by more than 5 percent. For counties whose population was 
smaller than 20,000, almost 25 percent had similar differences.

Table 4: Population Comparison for Counties in 2000 from ICPE and 2000 
Census by County Size:

County population[A]: All counties; 
Total: 3,141; 
Number of counties with ratio of less than 0.90: 118; 
Number of counties with ratio of 0.90-0.949: 384; 
Number of counties with ratio of 0.95- 0.999: 1,722; 
Number of counties with ratio of 1.00-1.049: 809; 
Number of counties with ratio of 1.05-1.099: 88; 
Number of counties with ratio of 1.10 or more: 20; 
Percentage of counties with ratio less than 0.95 or more than 1.05: 
19%. 

County population[A]: Less than 20,000; 
Total: 1,348; 
Number of counties with ratio of less than 0.90: 67; 
Number of counties with ratio of 0.90-0.949: 174; 
Number of counties with ratio of 0.95- 0.999: 672; 
Number of counties with ratio of 1.00-1.049: 355; 
Number of counties with ratio of 1.05-1.099: 63; 
Number of counties with ratio of 1.10 or more: 17; 
Percentage of counties with ratio less than 0.95 or more than 1.05: 
24%. 

County population[A]: 20,000 to less than 65,000; 
Total: 1,046; 
Number of counties with ratio of less than 0.90: 41; 
Number of counties with ratio of 0.90-0.949: 112; 
Number of counties with ratio of 0.95-0.999: 576; 
Number of counties with ratio of 1.00- 1.049: 294; 
Number of counties with ratio of 1.05-1.099: 20; 
Number of counties with ratio of 1.10 or more: 3; 
Percentage of counties with ratio less than 0.95 or more than 1.05: 
17%. 

County population[A]: 65,000 to less than 250,000; 
Total: 516; 
Number of counties with ratio of less than 0.90: 9; 
Number of counties with ratio of 0.90-0.949: 62; 
Number of counties with ratio of 0.95- 0.999: 315; 
Number of counties with ratio of 1.00-1.049: 125; 
Number of counties with ratio of 1.05-1.099: 5; 
Number of counties with ratio of 1.10 or more: 0; 
Percentage of counties with ratio less than 0.95 or more than 1.05: 
15%. 

County population[A]: 250,000 or more; 
Total: 231; 
Number of counties with ratio of less than 0.90: 1; 
Number of counties with ratio of 0.90-0.949: 36; 
Number of counties with ratio of 0.95-0.999: 159; 
Number of counties with ratio of 1.00-1.049: 35; 
Number of counties with ratio of 1.05-1.099: 0; 
Number of counties with ratio of 1.10 or more: 0; 
Percentage of counties with ratio less than 0.95 or more than 1.05: 
16%. 

Sources: Census Bureau reports and GAO analysis.

Note: Initial intercensal estimates for 2000 were benchmarked to the 
1990 Census; counties include county equivalents, such as parishes in 
Louisiana.

[A] Population classes reflect level of geographic area detail to be 
calculated from ACS. For example, geographic areas with populations 
smaller than 20,000 will be available using 5-year averages.

[End of table]

Census Bureau staff had long recognized the need for new methodologies 
to develop independent controls for the ACS. For example, a 1995 paper 
by Love, Dalzell, and Alexander, discussing issues related to 
evaluating the 1996 test site results, expressed concern about 
independent controls and residence rules, as well as the need for 
consultation with users.[Footnote 91] In 1998, the Census Bureau 
sponsored a conference on the quality of ACS data for rural data users. 
In the final report on this conference, the Westat authors concluded 
that the Census Bureau needed to continue and expand its contacts with 
stakeholders and to conduct additional research on several issues, 
including independent controls.[Footnote 92] Alexander and Wetrogan 
also discussed this issue at the 2000 Joint Statistical Meetings when 
they reviewed possible methods for using ICPE estimates.[Footnote 93] 
They also noted the need to consult with users on how to present 
information on the differences in ACS controls and ICPE in ACS 
publications.

Census Bureau staff also recognized that the new ACS would create 
differences between (1) ACS population and housing characteristics data 
and the corresponding "official" data from the Decennial Census and (2) 
ACS population and housing characteristics data and the "official" ICPE 
population estimates, which are benchmarked to Decennial Census data. 
They also recognized that the creation of new controls for the ACS 
would result in inconsistencies between ACS data and data from federal 
household surveys, such as the CPS, whose population and housing 
characteristics are also based on the Decennial Census and ICPE 
estimates. Such differences might hinder the use of ACS data to expand 
and improve small geographic area estimates based on the other surveys. 
(CPS provides official national estimates of labor force information, 
such as the unemployment rate and income estimates used to calculate 
the number of persons in poverty.)

In March 2003, the Census Bureau announced that it did not have a final 
methodology and that such methodologies would not be established for 
several years. In March 2003 in American Community Survey Operations 
Plan, Release 1, the Census Bureau identified research projects to be 
completed in preparation for full implementation of the ACS. One of 
these projects, "weighting and estimation," covered the methodology for 
calculating the independent controls for the ACS; a second, "program of 
integrated estimates," covers the calculation of these controls from 
the ICPE. This plan also reported that the results of these research 
projects would not be available in 2004 to begin implementing them with 
the start of the full ACS. Instead, the Census Bureau said it would use 
interim procedures and that it would take "extensive long-term 
investigation and experimentation" to develop final procedures.

For the weighting and estimation project, the Census Bureau reported 
that it would be using an interim adjustment to adjust the intercensal 
population and housing characteristics estimates to the ACS residence 
and reference period concepts. This project would include research to 
examine the need to achieve agreement between the estimates of occupied 
housing units, households, and householders at all geographic levels. 
The Census Bureau reported that work on the project to revise and 
simplify the weighting methodology began in early 2003, that 
preliminary papers documenting the revisions might be available by 
summer 2004, and that research would continue for several years.

For the program of integrated estimates project, the operations plan 
discussed the need for more research to introduce improvements to the 
ICPE estimates using information from the 2000 Census, more current ACS 
distributions of population characteristics, and administrative 
records to produce improved population and housing unit estimates for 
all areas, including small geographic areas. The plan also discussed 
improving the housing characteristics. ACS distributions of local area 
vacancy rates and household characteristics can be incorporated into 
statistical models that use distributions of housing unit 
characteristics to better estimate subcounty populations. No time 
schedule was provided for completing the research.[Footnote 94]

In October 2003, Census Bureau staff presented a paper at the Census 
Advisory Committee meetings that described the options being considered 
to convert the ICPE estimate to the current residence concept.[Footnote 
95] The paper described options for determining controls for ACS 
implementation in fall 2004 but did not indicate that research was 
under way to determine the options' effects. A second paper at the same 
meetings reported on research to improve the intercensal estimates by 
using ACS data for two "high priority" areas--international migration 
and internal migration. This work was being conducted as part of the 
Program of Integrated Estimates.[Footnote 96]

Although the latest NAS report on the ACS does not specifically note 
issues relating to independent controls, we asked experts who had 
participated in preparing NAS reports, as well as other experts in 
small area data, the following question about ACS weighting:

"Given the newly benchmarked intercensal estimates, the following 
question arises regarding the use of the 2010 Census data in the ACS: 
Should ACS estimates continue to be controlled to 2010 Census data at 
the county or county group level and differences between the ACS and 
census population counts and characteristics allocated proportionately 
to the tract or block group levels? Or should ACS estimates be 
controlled to 2010 Census data at the tract and block group level, as 
would have been the case with a long form?"

All the experts agreed that the ACS should be controlled to the 
decennial census, but several noted that they had not thought about the 
issue and had not heard anything from the Census Bureau on the issue. 
(The experts are listed in app. I.)

Operational Issues:

The Census Bureau has identified operational issues with the ACS test 
programs, primarily from information from evaluation studies on the 
2000 Decennial Census and Census Bureau staff research papers on 
comparisons between data collected in the ACS 2000 supplementary survey 
and the 2000 Decennial Census long form. These issues include problems 
with questionnaire design, nonresponse followup, and data capture, as 
well as coverage of persons living in group quarters.

In January 2004, the Census Bureau released the results of a key 
evaluation study of 2000 Decennial Census long-form data, using a 
reinterview survey.[Footnote 97] The study identified problems with 
long-form questions, which are the same as those used for the ACS, and 
proposed several research efforts based on a statistical evaluation of 
the quality of the responses to each question. For questions identified 
as having significant quality problems, the study recommended research 
on the design of the form and placement of the questions and suggested 
using cognitive experts in testing revised questions. The study also 
recommended that the Census Bureau and BLS work on the ACS employment 
and unemployment questions to ensure that they would complement the BLS 
local area unemployment statistics program.

The Census Bureau also conducted a study to evaluate the design of the 
ACS questions that are needed to implement the residence concept and 
reference period for the ACS.[Footnote 98] The study suggested that 
additional testing was needed for the questions about multiple 
residences (currently, the last set of questions in the housing 
section). It noted "that asking these questions on a person basis may 
produce different and probably better data than asking them on a 
household basis."[Footnote 99] The study was limited in scope and did 
not assess how accurately ACS respondents assign persons associated 
with the household to a current residence.

In the ACS, the Bureau uses "In the past 12 months . . ." whereas the 
Census Bureau used "In 1999 . . ." for the long form. Because the 
reference date is not fixed, it is important for a respondent to supply 
the date that the ACS questionnaire filled out. Otherwise, it cannot be 
determined whether there is an inconsistency in an ACS questionnaire 
received in late April 2004 that lists a resident aged 10 with a 
birthdate of April 15, 1993.[Footnote 100]

Census Bureau staff also discussed operational issues in research 
papers, based on evaluations of comparisons between 2000 Decennial 
Census long-form and ACS 2000 supplementary survey data for selected 
items presented at the 2003 Joint Statistical Meetings. A paper on 
income data identified the new question on the reference period as a 
potential source of problems, even though an additional instruction had 
been added to the ACS questionnaire in 1999.[Footnote 101] The authors 
expressed concern that some ACS respondents may misinterpret the 
question on "income in the past 12 months" as a request for monthly 
income instead of income during the previous year. The paper also 
included recommendations for additional research on the effect of the 
data capture methods. For the 2000 long form, all data items were 
entered with an automated optical character recognition procedure; data 
from the ACS will be manually keyed.

Another paper, presented at the same 2003 meetings, that evaluated 
differences in the data on disabled persons found large and significant 
differences at the national level and also recommended that new 
questions be tested.[Footnote 102] Additional areas were identified for 
further research, based on evaluations of questions such as educational 
enrollment, ancestry, and grandparents caring for grandchildren. These 
areas included specific facets of the mailout-mailback system and 
nonresponse followup. For example, nonresponse follow-up for the 2000 
long form was conducted for all nonrespondents, but for the ACS test 
program and for the full ACS, nonresponse follow-up will be conducted 
for a sample of one-third on all nonrespondents.

The Census Bureau also has discussed issues with the expansion of ACS 
coverage to include persons living in group quarters--for example, 
nursing homes, prisons, college dormitories, military barracks, 
institutions for juveniles, homeless shelters.[Footnote 103] In October 
2002, it informed its advisory committee members of the formation of a 
special planning team to address issues on the definition of group 
quarters and duplication in the address file. From the minutes of this 
meeting, it appears that this team will focus on group quarters in the 
context of the 2010 Census short form. In the ACS March 2003 operations 
plan, the Census Bureau reported on a new project to cover group 
quarters in the full ACS.[Footnote 104] The Census Bureau reported that 
the special project was needed because of the special challenges of 
developing an updated address list; in the past, such a list had been 
updated only once a decade. According to the Census Bureau, tests on 
the new list were to be completed in time for use in the full ACS in 
January 2005. In addition, an internal planning document issued in 
October 2003 identified group quarters (and residence rules) as special 
problems and instructed staff to provide recommendations on the 
collection of data on them in January 2004.[Footnote 105] Usually, the 
Census Bureau tests new questions. According to recent Census Bureau 
decisions, those tests would have to be completed so that new questions 
could be incorporated into the 2008 ACS questionnaire.[Footnote 106]

Valuation and Presentation of Dollar-Denominated Data Items:

The Census Bureau has adjusted all dollar-denominated items from the 
ACS testing programs, such as incomes, housing values, rents, and 
housing-related expenditures, for inflation. For example, ACS data for 
2001 and 2002 released in September 2003 for median household income 
are expressed in 2002 dollars. This practice means that when each added 
year of ACS data is released, all dollar-denominated items for prior 
years will be revised. The Census Bureau makes a similar adjustment for 
the annual income data collected in the CPS. Unlike the ACS, the Census 
Bureau releases annual CPS data without the adjustment. In addition, 
the annual values collected in the ACS were adjusted to the calendar 
year. It will be using the CPI for the annual and monthly adjustments 
for all geographic areas.

A report prepared for HUD found problems with the adjustment, including 
(1) the lack of a "trending" adjustment in the calculation of annual 
averages, (2) the use of the adjustment for multiyear averages, (3) the 
adjustment for cost of living for data items other than income, and (4) 
the lack of the unadjusted annual data that would enable HUD to use 
alternative methodologies. In addition, research by Census Bureau staff 
questioned the adjustment for incomes when they found that it was a 
probable source of difference between income data from the 
supplementary survey and corresponding data from the CPS and the 2000 
Census long form.[Footnote 107]

The report prepared for HUD provided a detailed review of HUD's use of 
the ACS for program applications. On the methodology for the inflation 
adjustment, the first step should be a trending adjustment that would 
convert the reported monthly data to a calendar year basis. Discussing 
this omission, the report stated,

"Making an inflation adjustment is not the same as trending. The cost 
of living adjustment assumes that the purchasing power measured at any 
point in the data collection period remains constant throughout the 
period. For example, assume that the cost of living rises by 3 percent 
a year. If a household reports an annual income of $50,000 in January, 
a cost of living adjustment to the end of the year would increase this 
income to $51,500, the amount needed in December to equal the 
purchasing power of $50,000 in January. A trending adjustment makes no 
assumption about purchasing power. It attempts to track movements in 
dollar income. Assume that dollar income is growing at 5 percent a 
year. Then a trending adjustment to the end of the year would increase 
the $50,000 reported in January to $52,500 in December."[Footnote 108]

HUD's second concern was that the methodology the Census Bureau used to 
calculate the adjustment was not appropriate for multiyear averages. 
The HUD report stated,

"The Census Bureau plans to report income in constant dollars. Income 
information collected in the various months will be adjusted for 
inflation so that all collected income will be expressed in dollars 
with the same purchasing power, presumably the purchasing power of 
dollars in December of the survey year. For moving average tabulations, 
all income information will be adjusted for changes in purchasing power 
over the period used to calculate the moving average. In other words, 
income reported by a respondent in the first month of a five-year 
moving average will be adjusted for almost five years of 
inflation."[Footnote 109]

To illustrate this problem, the HUD report gave the following example:

"The standard Census Bureau tables for areas over 65,000 will tabulate 
the rents reported by respondents over the twelve months during which 
data were collected. A unit reporting a contract rent of $800 in 
January might actually be paying $850 in December. The standard table 
would record this unit as having a rent of $800. The standard Census 
Bureau tables for areas under 20,000 will tabulate rents reported by 
respondents over a sixty-month period. A unit reporting a contract rent 
of $800 in the January of the first year might actually be paying 
$1,070 in December of the fifth year. The standard table would record 
this unit as having a rent of $800."[Footnote 110]

Such changes would not be captured with an adjustment based on the all-
items CPI.

The HUD report also noted that the inflation index the Census Bureau 
proposed related to income and not to the other dollar value data, such 
as rent, utility costs, or home value, where a purchasing power concept 
did not meet HUD's needs. The report concluded that to overcome this 
problem, before HUD could use dollar-denominated data from the ACS, it 
would first have to eliminate the inflation adjustment from the 
published data. The report stated: "For applications that involve 
trending income, HUD users will have to center the ACS information at 
an appropriate point in the collection period and remove the inflation 
adjustment before applying a trending factor."[Footnote 111] In 
addition, it noted that:

"The ACS will generate income distributions comparable to those from 
the decennial census, but the distributions will have a feature that 
will complicate the use of income data from the ACS in APP [HUD's 
Annual Performance Plan] measures. Whereas the decennial long form 
measures money income, the ACS reports average purchasing 
power."[Footnote 112]

The report thus recommended that HUD use the unadjusted data--data that 
the Census Bureau had not planned to publish--in order to make the 
changes needed for HUD.

The validity of the Census Bureau's inflation adjustment was also 
questioned in research Census Bureau staff conducted to evaluate 
differences between the data reported in the ACS supplementary surveys. 
In a paper presented at the 2003 Joint Statistical Meetings, staff 
evaluated differences between income data from C2SS and the 2000 Census 
long form, as well as the CPS.[Footnote 113] The paper summarized the 
major differences in the income data from these sources in terms of 
data collection, capture, and processing and provided preliminary 
assessments of their contributions to these differences. The authors 
noted the need for further research on the effect of the difference in 
reference period and the inflation adjustment, as well as operational 
aspects such as data capture. With regard to the inflation adjustment, 
they reported:

"If no CPI adjustment had been made to the dollars reported on either 
Census 2000 or C2SS/ACS, the difference between medians at the U.S. 
level would have been smaller than the 4.6 percent shown in Table 3 
[omitted]. Instead, the difference would have been 2.5 percent. Since 
adjustment clearly played a role in determining the size of the 
difference between Census 2000 and C2SS/ACS estimates, it would be 
worthwhile to examine the costs and benefits of adjusting C2SS/ACS 
incomes as well as the choice of factors used to adjust them."[Footnote 
114]

The authors summarized their findings by concluding that "it is clear 
that we are just at the beginning stages of understanding why Census 
2000 and C2SS income figures differ."[Footnote 115] They noted that the 
income comparisons are most critical because these Census Bureau data 
are used in the calculation of the number of people in poverty.

In a December 2003 research paper, Census Bureau staff examined 
concerns about the absence from the official poverty measures of 
adjustment for geographic differences in cost of living. Like the ACS, 
for which the Census Bureau is assuming that the cost of living is the 
same throughout all geographic areas, the poverty measures are based on 
the same assumption. The authors concluded that the use of a poverty 
measure that takes into account geographic differences in housing 
costs, would significantly change the poverty measures in many 
states.[Footnote 116]

Evaluations of ACS, Long-Form, and CPS Data Comparisons:

One of the Census Bureau's major justifications for the ACS test 
programs has been its comparing data collected in these programs, and 
corresponding data from the 2000 Decennial Census short and long forms, 
to identify operational problems. Another major justification for the 
ACS test programs has been the use of these comparisons, and 
comparisons with corresponding data from the CPS, to inform users in 
making the transition from the 2000 long form to the ACS.

The Census Bureau's 1999 request to OMB for approval of the forms for 
the ACS test programs stated that:

"to make a transition from the Census 2000 long form to collecting 
long-form data throughout the decade, we will begin ACS data collection 
in 1,203 counties. This data collection will allow for comparison of 
estimates from Census 2000 with estimates from the ACS for all states, 
large cities, and population subgroups, and will help data users and 
the Census Bureau understand the differences between estimates from the 
ACS and the Census 2000 long form."[Footnote 117]

In testimony to the Congress a year later, Kenneth Prewitt, the Census 
Bureau's Director, referred to the ongoing ACS test programs:

"These data will also contribute to a comparison with data from Census 
2000 that is necessary because there are differences in methods and 
definitions between the census and the ACS. Moreover, decision makers 
will want to compare an area's data to those from Census 2000. 
Comparisons using data from the operational test and from the 31 sites 
are essential to determine how much measured change between Census 2000 
and future years of the ACS is real and how much is due to operational 
differences between the ACS and the census."[Footnote 118]

When the Census Bureau began in 2001 to report on full implementation 
of the ACS, its first report focused on the operational feasibility of 
conducting the ACS.[Footnote 119] Its second report in 2002 focused on 
differences in operational characteristics of the ACS and the census 
long form, such as response rates and the extent of 
imputations.[Footnote 120]

The 2002 report stated that three reports evaluating differences 
between the ACS and census long form would be published at the end of 
2003.[Footnote 121] The Census Bureau repeated this schedule in March 
2003 when it released another official report on ACS plans.[Footnote 
122] In September, we were told by one of the ACS experts that 
consultants had been hired to conduct evaluations for 4 of the 31 test 
sites. The reports on comparisons with long-form items and for the test 
sites were published in May, June, and July 2004.

The results of these comparisons are similar to comparisons and 
evaluations of long-form data items previously prepared by Census 
Bureau staff, BLS, and GAO.

In September 2002, we prepared national and state comparisons between 
the 2000 ACS supplementary survey and the 2000 Decennial Census long 
form for about 10 items and between the 2000 ACS supplementary survey 
and the 2000 CPS for the poverty and unemployment rates. From the long-
form comparisons, we reported that:

"These comparisons showed large national differences for key items that 
did not appear to be accounted for by coverage differences between the 
two surveys. 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. . . . We also found a great degree of variation in the 
state differences between the long form and the supplementary 
survey."[Footnote 123]

From the CPS comparisons, we reported that:

"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."[Footnote 124]

Given these results, we recommended that the Census Bureau expand the 
scope of evaluation studies to develop supplementary survey estimates 
for states and large places consistent with the 2000 long form and that 
it include in its evaluations comparisons of year-to-year changes for 
2001 and 2002, using data from the supplementary surveys and the CPS at 
the national and state levels for key economic and housing items.

In September 2003, BLS received a report from a consultant who had been 
hired to evaluate differences between labor force data, such as the 
unemployment rate, reported in the ACS test programs and the 
CPS.[Footnote 125] The evaluation's purpose was to provide BLS with 
information on whether and how to incorporate ACS data into its 
measures of unemployment and the labor force. The consultant compared 
several labor market indicators from the CPS and ACS for 2000-02 at the 
national and state levels:

"Relative to the CPS, the ACS consistently generates lower estimates of 
the labor force and employment but higher estimates of unemployment. 
These patterns are present in each of the years 2000, 2001, and 2002. 
They are repeated in nearly all state-level data as well."[Footnote 
126]

He made a series of recommendations for additional research, some 
requiring additional information from the Census Bureau.

The need for such research was also reported in a January 2004 Census 
Bureau report that examined differences between labor force data from 
the CPS and the 2000 Decennial Census long form.[Footnote 127] Other 
findings and recommendations for further research similar to ours and 
those of BLS were also reported in research papers Census Bureau staff 
presented at the 2003 Joint Statistical Meetings. One paper on 
comparisons of income data for 2000 from the 2000 Decennial Census long 
form and the 2000 ACS Supplementary Survey reported that it:

"provided a summary of the major differences between the two income 
data sources, in terms of data collection, capture, and processing, and 
provided very preliminary assessments of the possible role these 
differences may have played."[Footnote 128]

The authors reported that additional work was needed to understand the 
differences and offered recommendations for further research.

Another paper presented at the same meetings examined differences 
between the national estimates for people aged 5 or older with a 
disability--48.9 million was the 2000 Census long-form estimate, 39.7 
million the C2SS estimate. The author did not determine which estimate 
was more reliable but did find that the wording of some questions might 
explain the overall difference. In addition, the author reported that 
more work, such as additional analysis of currently available data and 
testing of new questions, was needed to clearly identify the reasons 
for the difference.[Footnote 129] The differences in disability data 
were also the subject of a National Council on Disability position 
paper, which recommended changes to the questions on 
disability.[Footnote 130]

In addition to results from these comparison studies, the NAS Panel on 
Research on Future Census Methods found in July 2003 that the Census 
Bureau needed to complete evaluations of differences between 2000 
Census long-form data and data from the ACS test sites and the 2000-02 
Supplementary Surveys. Specifically, the panel stated that:

"The Census Bureau should carry out more research to understand the 
differences between and relative quality of ACS estimates and long-form 
estimates, with particular attention to measurement error and error 
from nonresponse and imputation. The Census Bureau must work on ways to 
effectively communicate and articulate those findings to interested 
stakeholders, particularly potential end users of the data."[Footnote 
131]

The panel also stated that, to facilitate this effort,

"The Census Bureau should make ACS data available (protecting 
confidentiality) to analysts in the 31 ACS test sites to facilitate the 
comparison of ACS and census long-form estimates as a means of 
assessing the quality of ACS data as a replacement for census long-form 
data. Again, with appropriate safeguards, the Census Bureau should 
release ACS data to the broader research community for evaluation 
purposes."[Footnote 132]

Information on Key Properties of Multiyear Averages:

One of the major differences between the ACS and the long form it will 
replace is that the ACS will provide data for geographic areas with 
populations smaller than 65,000 in terms of multiyear averages. Because 
of the statistical properties of these averages and users' 
unfamiliarity with them, we and many other stakeholders have identified 
these averages as a major challenge for users, including federal 
agencies. The Census Bureau has recognized the need for such guidance 
on the averages but has not made public plans for the topics to be 
discussed or when the guidance will be published.

From the 1998 conference that the Census Bureau had asked Westat to 
conduct on the quality of ACS data for rural data users, the report's 
authors concluded that "On the basis of the full exchange between the 
Bureau and the participants, they saw no evidence of an antirural bias 
in the design of the ACS."[Footnote 133] Nevertheless, they also 
concluded that the Census Bureau needed to conduct and expand its 
contacts with stakeholders and to conduct additional research on 
several issues we discussed in our report, including population 
controls, operational aspects of nonresponse followup, and multiyear 
averages. For these averages, the conference report noted that there 
would be issues with small geographic areas and the interpretation of 
changes in these averages:

"In discussing this issue, a number of the participants thought that 
averages were particularly problematic for those areas in which change 
is irregular. For example, the question was raised as to the meaning of 
'average poverty' over a 5-year period in which poverty rose and fell 
from one year to the next and, thus, the average would have no obvious 
meaning."[Footnote 134]

The report made similar comments with regard to such characteristics as 
unemployment and income. Although the conference participants had 
generally agreed with these concerns, the report pointed out that 
annually updating the 5-year averages "will provide some insight into 
trends, although turning points will be difficult to discern precisely, 
as will short-term trends."[Footnote 135]

About a year later, the Census Bureau had Westat convene another 
conference, this one focusing on the use of multiyear averages. The 
1999 report concluded:

"Although a 5-year moving average will generally provide reasonably 
reliable cross-section statistics for all areas, including very small 
communities, some care will have to be exercised in choosing time 
periods for which changes in population or their characteristics are 
measured. With 5-year averages, four-fifths of the data in a pair of 
neighboring years will be identical. The change being measured will 
then be one-fifth of the difference between the most recent year and 
the first year of the earlier time period. The sampling errors of the 
differences will thus be based on annual sample sizes, not 5-year 
averages, and will generally be too large to make useful inferences for 
small areas. The two 5-year averages that are being compared should 
generally be discrete and non-overlapping periods, e.g., 2003-2007 and 
2008-2012. These comparisons will have about the same reliability as 
changes between two censuses using data collected in the Census long 
form."[Footnote 136]

Census Bureau staff have been well aware of the difficulties of using 
the new multiyear averages. The Census Bureau's Charles Alexander 
presented a paper at a 2001 Statistics Canada conference on statistical 
methodology in which he recognized that the multiplicity of estimates 
for the same geographic area would be an issue for users (and for the 
Bureau). He said that the Census Bureau's presentation would:

"encourage analysts to use the same length of cumulation when comparing 
areas of different sizes . . . . For example, we would use one year for 
comparing states, but would recommend 5 years for all the counties in a 
table comparing large and small counties."[Footnote 137]

Alexander noted that this approach differed from that of Kish, the 
developer of the concept of a "rolling sample," who would "let us use 
tables of counties with one-year estimates for large counties, 3-year 
averages for medium-sized ones, and 5-year averages for small ones." He 
concluded this section of the paper by saying, "It will be interesting 
to see what practices data users will adopt in this regard."[Footnote 
138]

At the fall 2002 Census Advisory Committee Meetings, Navarro presented 
a paper that Alexander had written. Focusing primarily on the quality 
of the 5-year averages, the paper noted advantages and shortcomings, 
including that multiyear averages are not useful in all situations. For 
example,

"If there is little change in the population over the time covered by 
the average, the interpretation is about the same as that of a point-
in-time estimate with the advantage that the ACS estimate is more 
current than the historical decennial census long-form 
estimate."[Footnote 139]

The paper provided examples with "naive" assumptions about how users 
extrapolate between censuses to show that multiyear averages "work." By 
implication, under other conditions, users will need guidance on when 
multiyear averages can be used. The paper also did not discuss the 
interpretation of changes in the multiyear averages, as in the 1999 
Westat conference report or multiple estimates, which Alexander had 
discussed in his paper for the 2001 Statistics Canada conference.

In September 2002, two reports focused on issues related to the 
statistical properties of multiyear averages. We published a report on 
several aspects of the ACS, including the selection of questions and 
the feasibility of conducting the ACS as a voluntary survey, and HUD 
released a report prepared for its staff on the use of the ACS for HUD 
programs.[Footnote 140]

We stated in our report that the Census Bureau evaluation would not 
discuss "measures of stability of annual ACS data and ACS multiyear 
averages." We recommended that, as a first step, the Census Bureau:

"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."[Footnote 141]

We also discussed the need for additional information on the 
characteristics of the multiyear averages to help federal agencies make 
the transition to the ACS. We specifically noted the need for 
information on the selection of ACS data for geographic areas with 
populations larger than 20,000 for which there will be multiple 
estimates. On this issue, we stated that, "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."[Footnote 142]

For example, federal agencies that need state data can choose to use 
the annual data, multiyear averages of the annual data, or 3-year or 5-
year ACS averages. Federal agencies that also need county data 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. As many federal agencies, as well as state and local 
governments, will be using the ACS data for allocating funds, Census 
Bureau guidance would reduce the inconsistent use of the multiple 
estimates.

HUD is a major user of Decennial Census long-form data for various 
program applications. Its contract with ORC Macro to review how the ACS 
will affect HUD programs that previously relied on the Decennial Census 
long form for geographic area data resulted in a report that made two 
points about the multiyear averages, in addition to raising the 
previously discussed issues on the inflation adjustment to income. One 
of these issues related to interpretations of changes in the multiyear 
averages and their stability; the other related to the availability of 
multiple estimates for the same area.

The ORC Macro report noted that year-to-year stability is important and 
needs to be addressed. It warned that the "differences in the precision 
of estimates or year-to-year changes in estimates can create problems 
for HUD applications."[Footnote 143] The report used eligibility and 
level of benefits as an example of what could vary because of the 
effect of sampling variability on these changes. ORC Macro also stated: 
"The ACS will report data using different reporting periods for 
different sized areas. Inconsistent or multiple reporting periods can 
create problems for HUD applications."[Footnote 144] ACS data for many 
geographic areas will be available in terms of annual estimates and 3-
and 5-year averages, and the annual and 3-year averages (for larger 
areas) will be available before estimates for smaller areas. As a 
result, HUD will have to choose from multiple measures for some 
geographic areas. The study noted that HUD might decide to (1) continue 
to use 2000 long-form data until 2008, when the first 5-year average 
data will be available for all levels of geography, or (2) use the most 
recently available data in all cases.[Footnote 145]

ORC Macro's report also expressed concern about the amount of annual 
ACS data that the Census Bureau will release for areas with populations 
smaller than 65,000, whose accuracy the Census Bureau has found does 
not meet publication standards. According to the study, the Census 
Bureau informed HUD that beginning in 2008, it would provide 
researchers and planners a "research file" containing annual ACS data 
for areas of all sizes, including census tracts. ORC Macro recommended 
that if the Census Bureau does release these data, HUD consider using 
these "unofficial" research file results in some of its applications. 
The study noted, however, that if HUD decided to use these unofficial 
data but other agencies decided not to use them, there would be no 
standardization across government programs in funding allocation where 
the same ACS items were used.

The most recent request for the Census Bureau to provide users with 
guidance on using multiyear averages came in the July 2003 report by 
the NAS Panel on Research on Future Census Methods. The panel stated 
that "The Census Bureau should issue a user's guide that details the 
statistical implications of the difference between point-in-time and 
moving average estimates for various uses."[Footnote 146] In the 
report's executive summary, the panel stated that "The Census Bureau 
must do significant work in informing data users and stakeholders of 
the features and the problems of working with moving average-based 
estimates."[Footnote 147] It also expressed particular concern about 
the use of the multiyear (moving) averages in fund allocation formulas, 
noting that a multiyear average:

"is a smoothed estimate; by averaging a particular time period's data 
observation with those within a particular time window, the resulting 
estimate is meant to follow the general trend of the series but not be 
as extreme as any of the individual points. The ramifications of this 
basic concept emerge when moving average estimates are entered into 
sensitive allocation formulas or compared against strict eligibility 
cutoffs. A smoothed estimate may mask or smooth over an individual year 
drop in level of need, thus keeping the locality eligible for benefits; 
conversely, it may also mask individual-year spikes in activity and 
thus disqualify an area from benefits. It is clear that the use of 
smoothed estimates is neither uniformly advantageous nor 
disadvantageous to a locality; what is not clear is how often major 
discrepancies may occur in practice."[Footnote 148]

On another issue with multiyear averages, the panel noted, as the 
Westat report had done, the issue of interpreting year-to-year changes, 
stating,

"It is incorrect to use annual estimates based on moving averages over 
several years when assessing change since some of the data are from 
overlapping time periods and hence identical. At the least, the results 
will yield incorrect estimates of the variance of the estimates of 
change. Therefore, users should be cautioned about this aspect of the 
use of moving averages."[Footnote 149]

External Consultation:

During the past decade's development of the ACS, the Census Bureau has 
had many opportunities to consult with and take account of input from 
stakeholders and users in making key decision on the programs. It has 
(1) sponsored NAS panels, (2) held user conferences, (3) hired 
consultants to organize two conferences, (4) met regularly with its 
advisory committees and other user groups, and (5) encouraged its staff 
to present reports at ASA meetings and meetings of similar professional 
organizations. In the past several years, we and other federal agencies 
have reported on the ACS and provided recommendations to the Census 
Bureau. It established the ACS Federal Agency Information Program in 
2003, responding to a recommendation we had made.[Footnote 150] It also 
announced last year that it was looking into establishing a partnership 
with the Congress and its oversight entities.[Footnote 151]

Despite these opportunities, many stakeholders have observed that these 
consultations have not been successful. NAS noted the Census Bureau's 
lack of response to recommendations in last year's report on the 2010 
Census. The Panel on Research on Future Census methods offered the 
following comment by referring to a 1995 NAS report:

"Eight years later, faced with the task of offering advice on making 
the vision of continuous measurement a reality in the 2010 census, the 
similarity between the arguments then and now is uncanny. Similar, too, 
are the points of concern; the current panel is hard-pressed to improve 
upon the basic summary of concerns outlined by our predecessors. We 
are, however, much more sanguine that a compelling case can be made for 
the ACS and that it is a viable long-form replacement in the 2010 
census."[Footnote 152]

The Census Bureau has neither responded to the panel's first interim 
report in 2000 nor indicated that the recommendations were being 
adopted. The Census Bureau also has not responded to recommendations 
and issues raised by HUD and BLS. For example, it has not responded to 
HUD's recommendations on the ACS adjustments to dollar-denominated 
items or to BLS's recommendations on the ACS labor force questions. (On 
the issue of dollar-denominated items, we found no indication that the 
Census Bureau had ever consulted outside experts about either the 
methodology or the implementation.)

Census Bureau summaries of discussion about the ACS at its Advisory 
Committee meetings from October 2000 to April 2003 also indicate a lack 
of responsiveness.[Footnote 153] During this period, committee members 
raised concerns about the ACS. In particular, they made recommendations 
about many of the issues we have discussed in this report, including 
the evaluations of ACS and long-form comparisons, the new residence 
rules, independent controls, ICPE, group quarters, and Spanish-language 
questionnaires. At the April 2003 meeting, ASA committee members also 
requested a change in the structure of the Advisory Committee meetings, 
asking the Census Bureau to spend less time on update sessions and more 
time on sessions devoted to gathering more detailed input, commentary, 
and recommendations on topics the Census Bureau needs and wants advice 
on. Although the Census Bureau has addressed issues related to ICPE and 
Spanish-language questionnaires, the meeting summaries do not report 
that it followed recommendations in other areas.

[End of section]

Appendix VI: Comments from the Department of Commerce:

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

August 2, 2004:

Mr. Robert P. Parker: 
Chief Statistician: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548:

Dear Mr. Parker:

The U.S. Department of Commerce appreciates the opportunity to comment 
on the U.S. Government Accountability Office draft report entitled 
American Community Survey: Key Unresolved Issues (GAO-04-42). 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 (GAO) Draft Report Entitled American 
Community Survey: Key Unresolved Issues:

GAO's draft report identifies five outstanding issues that are believed 
to jeopardize the American Community Survey (ACS) replacement of the 
long form." Our comments are framed around these five issues.

Issue 1: A Methodology for Independent Controls for Population and 
Housing Characteristics is Lacking.

A methodology is in place to use independent housing unit and 
population estimates in the weighting process to produce ACS population 
and housing characteristics. These methods have been used during the 
extensive testing of the ACS. The Census Bureau agrees with the GAO 
recommendation that research should be conducted to assess whether 
there is a need for changes to these independent estimates or other 
aspects of the weighting process to deal with the issue of current 
residence. The GAO asserts that this must take place in the next year, 
with a decision made in time for producing 2005 estimates. The Census 
Bureau intends to conduct research over the next few years, with a 
decision in place for weighting and estimation of the 2008 estimates.

It is important to note that the Census Bureau has not concluded that 
methodological changes are needed nor that the changes that might be 
considered would require revisions in the Intercensal Population 
Estimates (ICPB). Research may determine that the ICPH which are 
currently used as population controls in the ACS should be revised or 
that additional information from other sources (e.g., seasonal housing 
questions from the ACS or administrative records) be used in 
combination with the existing ICPE to deal with this current residence 
issue. Research may also conclude that no general changes are warranted 
but that methods need to be developed for specific areas that exhibit 
effects of the difference between "current" and "usual" residence.

Research is not currently planned to develop population estimates (ICPE 
estimates) below the county level. As mentioned above, research may 
result in the development of alternative population controls below the 
county level, using the seasonal housing questions from the ACS or 
administrative records. The ICPE estimates, which refer to a July I 
point in time, are considered roughly equivalent to an "average 
population for the year." For this reason, the Census Bureau does not 
plan to conduct research on adjusting the July I centered population 
estimates for weighting of the ACS annual averages to address what the 
report refers to as the "reference date."

Issue 2. Operational Issues Have Not Been Addressed.

The report identifies a limited number of operational concerns. The 
major operational issue raised throughout the report deals with the 
process for revising the specific questions included in the ACS. The 
report states that questionnaire changes, identified in cognitive 
testing in 2001, have not been incorporated. The Census Bureau has 
developed a plan to delay all questionnaire changes until 2008. This 
will allow all changes to be consolidated and to minimize operational 
complexities in producing new materials, as well as technical 
complexities in the production of annual estimates.

Statements in this report about the 2010 decennial census schedules, 
and their lack of fit with the ACS, require clarification. In some 
parts of the report, the GAO correctly notes that schedules have been 
developed to facilitate having final content in place for the 2008 ACS. 
In other sections, the report states that the schedules are in 
conflict.

Issue 3: Plans for Valuation and Presentation of Dollar-Denominated 
Data Items Are Questionable:

The report raises concern about the inflation-adjustment methods used 
in the ACS. The ACS uses the Consumer Price Index (CPI), a generally 
accepted measure of inflation. The Census Bureau acknowledges that the 
inflation-adjustment issue deserves additional research and will 
investigate alternatives if funding permits. We note, however, that 
geographic differences in price levels are not accounted for by most 
federal programs and guidelines; for example, neither the official 
poverty thresholds nor the federal tax exemption for dependents uses 
such a distinction. Should the methodology for incorporating inflation 
be changed, the Census Bureau could recompute past data values if 
needed. In addition to standard data products, we expect to provide 
some additional information that could include unadjusted measures.

Issue 4; Evaluations of Comparisons Are Incomplete and Users Lack 
Information on ACS Time-Series Consistency.

The GAO states that the comparisons of Census 2000 and ACS results are 
limited and reflect major scaling back from original plans. The report 
states that we have, ". . . missed the opportunity to test (1) 
distortion and stability in multiyear averages, (2) differences between 
multiple estimates for the same geographic areas, and (3) the use of 
annual ACS data for small geographic areas." The Census Bureau has just 
completed a series of comparison reports and is planning additional 
research to assess the reliability and stability of ACS estimates over 
time. Evaluations of single-year versus multiyear estimates for the 
same areas are also planned.

Issue 5: Users Are Not Informed on Key Properties of Multiyear 
Averages.

The Census Bureau agrees with the need to develop such user guidance, 
and efforts have begun to educate users on the interpretation of 
multiyear averages. Although additional efforts are expected, the 
Census Bureau is currently working through the National Academy of 
Sciences (NAS) panel, the American Statistical Association Professional 
Advisory Committee, and the Federal Agency Information Program to more 
completely identify user needs and best practices. It is our intention 
to develop appropriate guidelines and tools. We do not see this as a 
process that needs to be in place in the next year; rather, it is 
required by the time the first set of multiyear averages will be 
available in 2008.

Conclusion/Recommendation:

-Many of the points raised in the report request additional information 
on the timing of ACS research and development, specifically related to 
independent housing unit and population estimates, weighting methods, 
comparison studies, and questionnaire changes. The Census Bureau agrees 
that more detailed documentation is needed about research and 
development plans, which includes schedules for when the ACS intends to 
introduce revised methodologies into production. Such clarification 
might allow the GAO and other users a clearer picture of our 
intentions.

The first recommendation is that the Census Bureau revise the ACS 
evaluation and testing plan to focus on the issues in this report. The 
current ACS testing and evaluation plan includes all of these issues, 
along with additional ones. The Census Bureau continues to review 
evaluation priorities and will share this information with the GAO.

The second recommendation is to provide key stakeholders, such as the 
NAS, with meaningful and timely input on decisions relating to these 
issues. The Census Bureau solicits input from many stakeholders, 
including the three panels that the Census Bureau has asked the NAS to 
convene, the Census Bureau's advisory committees, and federal agencies. 
We plan to continue to make use of these lines of communication.

The final recommendation in this report is a request that the Census 
Bureau make public the information underlying the Census Bureau's 
decisions on these issues when it makes the decisions. The Census 
Bureau will produce documentation for key operational and technical 
decisions and research papers that detail the reasons for decisions on 
issues such as these.

Additional Specific Comments:

The Census Bureau also has the following 62 specific comments about 
statements in the draft report.

p. 1, para. 2...mailed to a sample of 15 million households."

The Census 2000 sample data were compiled from a sample of 
approximately 19 million housing units that received the census long 
form questionnaire.

2. p. 2, para. 1 "...populations of 20,000 to 65,000 by cumulating ACS 
results for 1 year..."

Clarify this statement to be either "less than 20,000 by cumulating… 5 
years" or "greater than 65,000 by cumulating...1 year"

3. p. 2, para. 2 "3 year averages for geographic areas with populations 
between 20,000 and 65,000 will begin,..."

Throughout this report, the data product plan is misstated. In general, 
it should state that single-year estimates will be produced for areas 
with 65,000 or more population; 3-year estimates will be produced for 
areas with 20,000 or more population; and 5-year estimates will be 
produced for all areas down to the block group/tract level.

4. p. 2, para. 2 "The 5 -year averages for 2008-2012 to be published in 
2013 will replace...and closely reflect the population and housing 
characteristics data from the 2010 Decennial Census short form."

The degree to which the 2008-2012 estimates reflect the 2010 estimates 
is dependent on several issues, including the impact of residence rules 
differences, weighting research, and annexations between 2010 and 2012.

5. p. 2, para. 2...annual estimates for large geographic areas and 
estimates for smaller areas in terms of 3 year or 5 -year averages."

Replace "annual" with "single-year." Note that annual estimates will be 
produced for smaller areas too-not only for large areas.

6. p. 3, para. 3 and para. 4:

Several times on this page and later pages statements are made about 
the ACS residence concepts that apply only to the ACS population 
controls. The ACS is not introducing a new concept of residence, nor 
does it plan to adopt a concept of "current residence" that is new. The 
ACS has employed a current residence concept in data collection since 
its inception. This includes having a full set of rules to determine 
current residence. The work that has not, as yet, been done is the work 
to assess the need and methods, if required, to adjust the existing 
usual residence-based population estimates to current residence-based 
estimates. This is research that has been identified but has not been 
completed. In addition, other research is being planned on how the 
housing unit and population controls used in the ACS weighting process 
might be modified to address the issue of different residence rules 
between the ACS (current residence) and the intercensal population 
estimates program (usual residence).

7. p. 4, para. 1 "...does not plait to incorporate improved questions 
until 1010."

The cited research was undertaken to revise the "multiple residence 
questions" that are needed for the research on current residence-based 
controls. Based on this research, changes were made to the 2003 ACS 
questionnaire with the new questions added. In the course of that 
research, additional changes to other parts of the questionnaire were 
identified. To preserve content consistency, the ACS wants to minimize 
the frequency of questionnaire wording changes. The Census Bureau plans 
to incorporate all such changes in the 2008 questionnaire and to limit 
content changes for at least five years after that. The suggestions 
about the residence questions, along with other content changes (such 
as those needed for disability) will be integrated into the 2008 forms 
and procedures-The "2010" timing is therefore incorrect.

8. p. 4, para 2 "The Census Bureau has not developed a methodology for 
using ICPE...to derive controls consistent with the ACS residence 
concept and ACS reference period or at the same level of geography used 
for the 2000 Census long form, "

It is correct to say that methods have not, as yet, been developed for 
deriving controls consistent with the ACS residence concept. Census 
staff have identified this inconsistency as a weighting issue and plan 
to conduct required research to assess the extent of the issue and, if 
necessary, to develop approaches to address it. Multiple options could 
be considered to deal with this issue. The Census Bureau has not 
concluded that the existing population estimates must be changed to 
deal with seasonal populations in the ACS.

Related to the residence concept is the "reference period." The ICPE 
estimates refer to a July 1 point in time and are roughly equivalent to 
an "average population for the year," which is considered to be the ACS 
reference period-For this reason, the Census Bureau does not see the 
existing population controls as being inconsistent.

The third dimension noted, level of geography, is recognized by the 
Census Bureau as inconsistent with the long-form estimation methods. 
However, there is currently no methodology to develop estimates with 
age, sex, race, and Hispanic-origin characteristics for geographies 
lower than county level nor methodologies to develop estimates of total 
population for geographies lower than functioning governmental units. 
The Census Bureau plans to investigate alternative sources that might 
make it possible to provide some subcounty-level controls.

9. p. 4, para. 3 "Before data for 2005...a methodology is needed to 
provide controls..."

The Census Bureau does not agree that revisions to the controls are 
needed for 2005. The Census Bureau has concluded that a decision on the 
methodology and the associated research and development activities 
should be completed prior to production of 2008 data.

10. p. 4, para. 4 "Census Bureau Officials told us that they agreed 
with the need for such guidance but had no plans for its contents."

The Census Bureau has begun efforts to produce additional information 
for users on multiyear averages and to better understand bow they 
(federal agencies) currently apply census sample data. Planning efforts 
began over a year ago with the fast Federal Agency Information meeting. 
The report is correct that there is no formal plan or schedule, but 
incorrect that there are no plans for its content. A contract is in 
place with the NAS to convene a panel of experts to provide input and 
recommendations into the content of information that should be provided 
to ACS users transitioning from the long form to the ACS.

11. p. 4, para. 5 " ...latest schedule for the 2010 Decennial Census 
does not provide adequate time for the Census Bureau to incorporate 
into the full ACS program changes necessary for the ACS data far 2008-
2012 to be reliable enough..."

It isn't clear what 2010 activities the report is referring to and how 
they impact the ACS, Schedules have been defined to ensure that 2010 
content is defined no later than January 2007 to allow those content 
changes to be reflected in the 2008 ACS. If the report is referring to 
activities outside of the 2010 process, such as the development of 
revised population controls, it should state that. The report should 
also clarify what is meant by "reliable enough."

12, p. 5, para. 3 "...ACS Supplementary Survey..."

The Supplementary Surveys have always been called the Census 
Supplementary Surveys, not the ACS Supplementary Surveys.

13. p. 5, para. 3 "...will incorporate population and housing 
characteristics data from the 2010 Decennial Census short form."

Clarify that this statement refers only to using 2010 results in the 
form of population controls. As written, the statement suggests that 
actual data from the 2010 short form will be incorporated in the ACS. 
Also, see Item 4.

14. p. 6, para. 3 "...decennial sample of about 15 million households"

See Item 1.

15. p. 6, para. 4:

The report refers several times to the residence rules being used for 
"seasonal residents." The residence rules are applied to all people, 
and although many of the rules impact seasonal residents, they also 
impact people who might spend time in a Group Quarter and people with 
multiple residences that aren't seasonal.

16, p. 7, para. 2 "...change the concept to current residence."

Same comment as earlier about explanation of residence rules in place 
for the ACS. It is incorrect to say that the ACS is changing the 
concept to current residence. The ACS has been collecting the data 
using current residence rules since its inception in 1996. Using the 
example in this report, people who live in both Florida and New 
Hampshire for parts of the year (assuming more than two months in each 
place) could be interviewed in both states in the ACS, unlike the 
census that would have to pick one-New Hampshire.

17. p. 7, para. 3 Reference Period:

Again, clarify that this explanation applies only to the controls. The 
reference periods for data collection are driven by several factors, 
the controls are only one of them. Reference period includes period of 
data collection and the reference requested for reporting (e.g., last 
week, last three months).

18. p. 7, para. 4 "The ACS will use population characteristics-not from 
the results collected in the survey."

Clarify that the report is referring to controlling the final data. The 
ACS will certainly be using the population and housing characteristics 
collected in the ACS in the final data products.

19. p. 8, para. 3 "...nonresponse follow-up will he conducted far a 
sample of one-third of all nonrespondents."

The one-third subsample is not technically correct for full 
implementation. In full implementation, nonrespondents can be sampled 
at different rates, such as 1-in-2, 2-in-5 or 1-in-3 rates. Addresses 
that were unmailable are sampled at 2-in-3.

20. p. 10, para. 2 "...new ACS data and corresponding data from the 
2000 Census long-form and 2004 supplementary survey.,."

We would appreciate clarification of this recommendation. What is meant 
by "new ACS data?" What specific comparisons are being suggested?

21. p. 10, para. 3 "...ACS implementation schedule is not 
synchronized..."

Same as comment regarding page 4 of the draft report about the 
schedule. See comment 11 above.

22. p. 12, para. 2 ",.. no plans to maintain time-series 
consistency..." and "...not planning such revisions..."

The ACS has plans to make appropriate changes to the population 
controls when necessary, including the possibility of reweighting the 
data around the 2010 time period and for all multiyear estimates.

23. p. 14, para. 1 "...would be addressed before implementation of the 
full ACS."

Questionnaire design/wording changes will be implemented in 2008. Some 
specific testing is underway (e.g., disability) in conjunction with the 
ACS OMB Content Group.

24, p. 14, para. 2 "...no plans to provide for external 
consultations..."

This statement is incorrect. All question design changes are currently 
being worked through the ACS OMB Content Group to ensure that all 
federal agencies are aware of and, if they choose, can participate in 
the process for making revisions. The Census Bureau has no plans to 
make content changes to the questionnaire without such changes working 
through this group. Plans for testing race and Hispanic origin 
questions have been shared with multiple stakeholders, including 
advisory committees and federal agencies.

25. p, 14, para. 3 ".., current time schedule does not call for 
resolving issues such as questionnaire design before 2008."

The Census Bureau has a set of schedules for content changes that 
require that all changes be identified/finalized no later than January 
2007 in order that those changes be reflected in all questionnaires, 
translations, and related materials. A 2010 decision memorandum 
documents that requirement for all items common to 2010 and the ACS.

26. p, 14, para, 5 "do not include time for consulting with 
stakeholders and users..."

Consultation and updates are provided regularly at meetings of the 
census advisory committees, State Data Centers, Census Information 
Centers, and the ACS OMB Content Group. Additional communication occurs 
through the Federal Agency Information meetings. Also, see response to 
Item 10.

27. p. 15, para. 2 "…monthly values collected in the ACS were adjusted 
to their values for December of the data collection year, using the 
CPL"

The basis for dollar adjustments in the ACS would more accurately be 
described as the difference between the average CPI over a household's 
12-month reference period and the calendar year of the interview. 
Seethe "Adjusting Dollar Amounts" section at the URL below for a more 
detailed description of the method.



28. p. 17, para. 1 "...no documentation explaining the rationale for 
the adjustment..." and "…stakeholders and users had not been 
consulted..."

There is an OMB Directive to use the CPI to update the official poverty 
thresholds every year. While no formal rationale is documented, users 
recognize the need for such an adjustment when trends are being 
produced and compared, and the CPI is the generally accepted method. 
Census Bureau staff had talked extensively with economic data users 
about ACS income data since 1996, bringing up this issue, The Census 
Bureau also discussed the appropriate use of the CPT with the Census 
Advisory Committee of Professional Associations. They endorsed its use 
to inflate historical income data to improve year-to-year 
comparability,

29, p. 17, para. 1 "...this type of adjustment is not used for the 
SIPP..."

SIPP reports that look at economic trends, such as the recent income 
dynamics report from the SIPP (P70-95), use CPI adjustments in order to 
make consistent comparisons over time. Also, SIPP wealth reports, like 
P70-88, use CPI adjustments in discussing whether median wealth has 
increased or declined over time in real (after inflation) terms. These 
uses are consistent with the way that the CPS and: the ACS use the CPT 
when assessing if incomes have risen/fallen over time in real terms.

30, p.18, para. 1 "...scope has been reduced in terms of levels, data 
items, and time period "

It isn't clear what this statement is based on. The scope of these 
reports was defined over time based on consultation with advisory 
committees and users. The final choice of having the single-year 
reports focus on national and selected subnational (county) results was 
at the suggestion of the Census Advisory Committee of Professional 
Associations. The specific items in scope were defined to parallel the 
data in the four decennial census profile reports. Those were included 
in the final reports. The 3-year comparison reports included county and 
tract-level data for all test sites with the exception of Houston, TX. 
Means and medians were included in each of these reports. It is unclear 
what is meant by "time period."

31. p. 18, para. 2 "...no plans to evaluate the comparisons for 27 of 
the 31 test sites."

All 31 sites were included in the two 3-year averages reports issued by 
the Census Bureau in June 2004.

32. p. 18, para. 2 "...4 test sites to be studied will not cover 
subcounty local government units.

Although some proposed comparisons of subcounty data (i.e., MCD data in 
Vilas and Oneida, WI) could not be analyzed, the four test site reports 
that were issued in June 2004, studied a large amount of subcounty data 
including census tract data and neighborhood data in the case of the 
Bronx.

33. p. 18, footnote "...delay in completing the planned evaluation 
studies resulted from...2000 Census Accuracy, Coverage, and Evaluation 
program..."

Staff working on the A.C.E. evaluations were never scheduled to 
participate in any of the ACS comparison studies. The delays in these 
comparison studies were solely driven by the need to test the impact of 
using voluntary methods in the ACS.

34. p. 19, para. 2 "...delays in completing the evaluations...likely to 
affect the use of the ACS in improving the small geographic area 
estimates of unemployment and poverty."

The delays in the comparison studies have not affected [MISSING WORD] 
of work on using ACS data to improve small area poverty estimates 
program (SAIPE). Work has already begun on developing models that 
utilize ACS data.

35. p. 20, para. 2 "..,missed the opportunity to test..."

The Census Bureau plans to conduct research into some of these areas 
and does not see that the window of opportunity for such testing is now 
closed. Several of these types of evaluations warrant the use of data 
that are only recently available.

36, p. 20, para. 3 "..no indication that the Census Bureau will be 
following this advice..." "…not yet followed similar advice from us, 
other government agencies, or its own staff."

The various parts of this report are inconsistent with this statement. 
Appendix 11 and other similar records clearly show that advice given to 
the Census Bureau from NAS, Census Advisory Committees, and federal 
agencies has in many ways defined Census Bureau priorities and methods 
for testing. This includes the NAS request for information on quality 
comparisons, which were documented in 2002 in the report series, in 
several American Statistical Association papers in 2003, and in 
additional report series reports in 2004. The NAS also requested that 
data files be made available for users to conduct their own 
comparisons. This request required considerable resources but was given 
priority and data comparing Census 2000 and test site, 3-year averages 
were recently released on the ACS Web site. There are many additional 
examples that could be cited. The statement would be correct if it said 
that not all recommendations have been followed.

37. p. 20, para. 4 "...no plans to seek advice..." "…will receive 
little of no input..."

The ACS has plans in place to solicit input from' users and 
stakeholders, including the NAS through a variety of means including 
the recently initiated NAS panel, the ACS OMB Content Group, the 
Federal Agency Information meetings, and the regular Census Advisory 
Committee meetings.

38. p, 22, para. 1 "...2004 and 2006 test plans for the 2010 Decennial 
census...until 2005.

The point of this final phrase is unclear, The relationship between the 
ACS and these tests is limited to certain content testing, which is 
scheduled to coincide with ACS schedules for final content definition 
in January of 2007.

39. p. 22, Table 1:

Numerous references to unresolved residence rules should be clarified.

40, p, 22, Table 1 (Q4, 2006):

The level of geographic detail for the 2006 release or 2065 data is not 
an unresolved issue.

41, p. 23, Table l "...changes to operational procedures, such as 
sampling rate far nonresponse followup"

The proposed change to the personal visit followup subsampling rate 
will be implemented in 2005. The required research was complete 3 early 
this year and the results are currently being documented. There are no 
plans to revise this plan unless minor refinements are required based 
on observation in 2005.

42. p. 24, para, 1 "...Census Bureau has announced that 
comparisons...will he limited."

The Census Bureau does not characterize the comparison reports as 
limited. The Census Bureau released a complete series of comparison 
studies this spring-six detailed reports conducted by staff at the 
Census Bureau, another four reports conducted by experts outside of the 
Census Bureau.' As these reports are reviewed and discussed, additional 
research efforts maybe identified.

43, p. 25, para. 1 "...the ACS implementation plan and the 2010 
Decennial Census test programs are not synchronized..."

The plans are synchronized by design.

44. p. 25, para. 1 "Without prompt resolution of issues such as those 
relating to the calculation of independent controls...the ACS will not 
he an adequate replacement for the long farm..."

The Census Bureau does not agree that these issues must be immediately 
resolved, nor that they are critical to ensuring that the ACS can 
replace the long form.

The fourth report is scheduled for release the last week of July:

45, p. 43, para. 1 "They reported that the Census Bureau was planning 
to conduct research using data from the 1996 test sites to produce 
controls at the census tract and block group level"

The paper states that, "The Bureau's demographic estimates staff are 
researching ways to snake more detailed estimates for the 1996 CM test 
areas." This refers to intercensal population estimates for counties 
broken down by-sex, age, race and Hispanic origin. Up to that time only 
the total population for counties was produced. There was no suggestion 
of producing estimates for sub-county areas.

46. p. 52, para. 1 "...had not been released when we prepared our final 
plan of this report."

The release dates for the various comparison reports are as follows:

Comparing Basic Demographic and Housing Characteristics With Census 
2000 - May 2004:
Comparing Economic Characteristics With Census 2000 - May 2004:
Comparing Social Characteristics With Census 2000 - June 2004:
Comparing Housing Characteristics With Census 2000 - expected in July 
2004: Comparisons of the ACS 3-Year Average and the Census 2000 Sample 
for a Sample of Counties and Tracts - June 2004:
Comparing Quality Measures: The American Community Survey's 3-Year 
Averages and Census 2000's Long-Form Sample Estimates - June 2004:

47. p. 53, para. 1 "...to control the estimates to an independent 
source, it would be necessary to achieve agreement between the ACS 
estimates of occupied housing units, households, and householders at 
all geographic levels."

The desire to use a single weight to make these three estimates equal 
is not a prerequisite to controlling estimates to an independent 
source.

48. p. 53, para. 3 "...data on group quarters were collected at the 
test sites beginning with 1999..."

Group quarters data were collected in the test sites in 1999 and 2001 
only.

49. p. 57, para. 1 "...and housing characteristics (occupied and vacant 
units) for the full ACS..."

The ACS uses total housing units in the population controls, not 
information on occupied and vacant units.

50. p. 57, para, 1 "Controls will he needed at the same level of 
geographic area detail as those that were used far the 2000 Census long 
form and will need,."

The same level of geographic area controls are desirable but not 
necessary. The quality of controls is very important for their use in 
the ACS. If quality estimates at lower levels of geography are 
available, the ACS will consider their use. A similar set of statements 
also appear on page 60 (paragraph 2) and page 61 (paragraph 1).

51. p. 58, Table 3:

The table should be clarified to note that the residence concepts that 
are being discussed are not the residence rules for data collection but 
the residence basis for the population controls. The term, "reference 
period" should be clarified. In addition, the current plans do not 
envision having revised control methodologies in place for weighting of 
the 2005 data.

52. p. 59, Table 3 (2005 - 09d):

Weighting area options in this table should be revised. There are no 
plans to control to the same areas as the Census 2000 long form or to 
use detail from the Census 2000.

53. p. 60, para. 1 "Using ICPE for the ACS supplementary surveys, the 
Census Bureau prepared controls for places with a population of 250,000 
or more."

This statement is incorrect. The weighting area (as indicated in Table 
1) was county or county combinations.

54. p. 61, para. 1 "...to provide ACS-defined controls for all 
places..."

This statement misrepresents the weighting process. Controls are only 
used for counties or groups of counties, not for other places.

55. p. 61, para. 1 "For the 2008-2012 estimates, a methodology for 
controls down to the block level will he needed"

The Census Bureau does not agree with this statement and has not stated 
a requirement for block-level controls.

56. p. 67, para. 3 "…this team will focus on group quarters in the 
context of the 2010 census short form."

This group has a charter to support the group quarters needs of both 
the ACS and the 2010 decennial census.

57. p.68, para. 1 "...current time schedule does not allow for issues 
such as questionnaire design to he resolved unlit 2010"

Same comments as earlier. See Item 11.

58. p. 73, para. 1 "...first report focused on evaluations of 
differences in the A C5 and census short form data items."

The first report focused on the operational feasibility of conducting 
the ACS. It did not include evaluations of differences in any data 
items.

59. p. 73, para. 2 and para. 3 "...will not be issued until mid-2004." 
"...has yet to publish comparisons..."

See Item 46 above for release schedule for comparison study reports.

60. p. 75, para. 4 "The author was unable to determine which estimate 
was more reliable..."

The author did make such a determination, concluding that problems 
during Census 2000 nonresponse follow-up led to the higher than 
expected disability rates in Census 2000 relative to the ACS.

61 p. 83, para. 3 "...indicate a lack of responsiveness."

The Census Bureau has responded to all Census Advisory Committee 
recommendations and have provided all briefings that they have 
requested. It is true that not all recommendations have been followed 
and also true that within the committees, recommendations are not 
always consistent. When the Census Bureau decides not to pursue a 
recommended action, explanations are provided to the committees.

62 GAO highlights (cover page) characterize the ACS as a mail survey. 
It more accurately is a multimode survey using mail, telephone, and 
personal visit modes of data collection. Also, 3-year averages will be 
produced for areas of 20,000 or more, not areas of 20,000 to 65,000. 

[End of section]

Appendix VII: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Robert P. Parker (202) 512-9750, parkerr@gao.gov. 
Christopher Moriarity (202) 512-5420, moriarityc@gao.gov:

Staff Acknowledgments:

Additional staff who made major contributions to this report were 
Heather Von Behren, Penny Pickett, Mitchell Karpman, Michael Volpe, 
Andrea Levine, Patricia Dalton, and Robert Goldenkoff.

[End of section]

Bibliography:

The first section in this bibliography lists documents on the history 
of the long form and mid-decade census. The remaining works are divided 
between numerous types of Census Bureau reports and papers, Association 
of Public Data Users papers, congressional hearings and testimony, and 
other reports and papers. Recent reports from the National Academy of 
Sciences are discussed in appendix II. Related GAO Products are listed 
in a separate section at the end of this report.

History of the Long Form and Mid-Decade Census:

Alexander, Charles H. "Still Rolling: Leslie Kish's 'Rolling Samples' 
and the American Community Survey." In Proceedings of Statistics Canada 
Symposium 2001: October 16-19. Ottawa: Statistics Canada, 2002.

Anderson, Margo J., ed. Encyclopedia of the U.S. Census. Washington, 
D.C.: CQ Press, 2000.

House of Representatives, Committee on Post Office and Civil Service, 
Subcommittee on Census and Population. Review of Major Alternatives for 
the Census in the Year 2000. Serial 102-25. Washington, D.C.: August 1, 
1991.

House of Representatives, Committee on Post Office and Civil Service. 
Census Confidentiality/Mid-Decade Sample Survey Bill. Report 93-246. 
Washington, D.C.: June 4, 1973.

House of Representatives, Committee on Post Office and Civil Service. 
Mid-Decade Censuses of Population, Unemployment, and Housing. Report 
780. Washington, D.C.: August 12, 1965.

Salvo, Joseph, and Arun Peter Lobo. The American Community Survey: 
Quality of Response by Mode of Data Collection in the Bronx Test Site. 
Presented at 2002 Joint Statistical Meetings, New York City, August 14, 
2002.

Census Bureau ACS Reports:

American Community Survey Operations Plan, Release 1. Washington, D.C.: 
March 2003.

Meeting 21st Century Demographic Data Needs: Implementing the American 
Community Survey. Report 1. Demonstrating Operational Feasibility. 
Washington, D.C.: July 2001.

Meeting 21st Century Demographic Data Needs: Implementing the American 
Community Survey. Report 2. Demonstrating Survey Quality. Washington, 
D.C.: May 2002.

Meeting 21st Century Demographic Data Needs: Implementing the American 
Community Survey. Report 3. Testing the Use of Voluntary Methods. 
Washington, D.C.: December 2003.

Meeting 21st Century Demographic Data Needs: Implementing the American 
Community Survey. Report 4. Comparing General Demographic and Housing 
Characteristics With Census 2000. Washington, D.C.: May 2004.

Meeting 21st Century Demographic Data Needs: Implementing the American 
Community Survey. Report 5. Comparing Economic Characteristics With 
Census 2000. Washington, D.C.: May 2004.

Meeting 21st Century Demographic Data Needs: Implementing the American 
Community Survey. Report 6. The 2001-2002 Operational Feasibility 
Report of the American Community Survey. Washington, D.C.: May 2004.

Meeting 21st Century Demographic Data Needs: Implementing the American 
Community Survey. Report 7. Comparing Quality Measures: The American 
Community Survey's Three-Year Averages and Census 2000's Long Form 
Sample Estimates. Washington, D.C.: June 2004.

Meeting 21st Century Demographic Data Needs: Implementing the American 
Community Survey. Report 8. Comparison of the American Community Survey 
Three-Year Averages and the Census Sample for a Sample of Counties and 
Tracts. Washington, D.C.: June 2004.

Meeting 21st Century Demographic Data Needs: Implementing the American 
Community Survey. Report 9. Comparing Social Characteristics With 
Census 2000. Washington, D.C.: June 2004.

Meeting 21st Century Demographic Data Needs: Implementing the American 
Community Survey. Report 10. Comparing Housing Characteristics With 
Census 2000. Washington, D.C.: July 2004.

Census Bureau Advisory Committee Presentations:

The presentations in this section were made by the Census Bureau's 
Decennial Census Advisory Committee, Professional Association Advisory 
committees, and Race and Ethnic Advisory Committees.

The ACS: Data Products to Meet User Needs. Race and Ethnic Advisory 
Committee meeting, Washington, D.C., March 14, 2001.

Alexander, Charles, Alfredo Navarro, and Deborah Griffin. Update on ACS 
Evaluations. Decennial Census Advisory Committee meeting, Washington, 
D.C., November 5, 2001.

Gordon, Nancy. The American Community Survey. Joint Meeting of the 
Census Bureau Advisory Committees, Washington, D.C., July 28, 2000.

Gordon, Nancy. The American Community Survey. Decennial Census Advisory 
Committee meeting, Washington, D.C., September 21-22, 2000.

Gordon, Nancy. The American Community Survey. Race and Ethnic Advisory 
Committees meeting, Washington, D.C., November 2, 2000.

Gordon, Nancy. American Community Survey Update. Decennial Census 
Advisory Committee meeting, Washington, D.C., May 2, 2002.

Griffin, Deborah. An Overview of the Research and Evaluation Program 
for the American Community Survey. Decennial Census Advisory Committee 
meeting, Alexandria, Virginia, October 2-4, 2002.

Griffin, Deborah H. Comparing Characteristics from the American 
Community Survey and Census 2000: Methodology. Census Advisory 
Committee of Professional Associations meeting, Washington, D.C., April 
10-11, 2003.

Navarro, Alfredo. American Community Survey: Use of Population 
Estimates as Controls in the ACS Weighting. Census Advisory Committee 
of Professional Associations meeting, Washington, D.C., October 23, 
2003.

Navarro, Alfredo. A Discussion of the Quality of Estimates from the 
American Community Survey for Small Population Groups. Census Advisory 
Committee of Professional Associations meeting, Washington, D.C., 
October 2-3, 2002.

Weidman, Lynn, and Signe Wetrogan. Enhancing the Intercensal Population 
Estimates Program with ACS Data: Summary of Research Projects. Census 
Advisory Committee of Professional Associations meeting, Washington, 
D.C., October 23, 2003.

Census Bureau Continuous Measurement Series:

The memorandums listed here from the 20 in the Continuous Measurement 
series are those most directly related to topics we review in this 
report.

Alexander, Charles H. A Continuous Measurement Alternative for the U.S. 
Census. CM-10, October 28, 1993. CM-11 summarized this paper at the 
1993 annual meeting of the American Statistical Association, San 
Francisco, California, August 10, 1993.

Alexander, Charles H. Further Exploration of Issues Raised at the 
CNSTAT Requirements Panel Meeting. CM-13. Internal Census Bureau 
memorandum, Washington, D.C., January 31, 1994.

Alexander, Charles H. A Prototype Continuous Measurement System for the 
U.S. Census of Population and Housing. CM-17. Presented at the annual 
meeting of the Population Association of America, Miami, Florida, May 
5, 1994.

Alexander, Charles H. Some Ideas for Integrating the Continuous 
Measurement System into the Nation's System of Household Surveys. CM-
19A. Internal Census Bureau memorandum, Washington, D.C., January 6, 
1995.

Census Bureau Internal Reports:

2004 Census Test Operational Plan. Washington, D.C.: September 29, 
2003.

2010 Census Decision Memorandum Series No. 5, Finalizing Content for 
the 100 Percent Items in the 2010 Census and the American Community 
Survey. Washington, D.C.: June 3, 2004.

2010 Census Planning Memorandum Series No. 24, Action Plan: 2010 
Research and Development Planning Group on Race and Ethnic Data 
Collection, Tabulation, and Editing. Washington, D.C.: June 9, 2004.

2010 Census Planning Memorandum Series No. 26, Action Plan: 2010 
Research and Development Planning Group on Special Places/Group 
Quarters Development and Testing. Washington, D.C.: March 8, 2004.

ACS-2010 Consistency Review Plan. Washington, D.C.: October 1, 2003.

American Community Survey Development Report Series Program Plan. 
Washington, D.C.: rev. June 12, 2002.

Census 2000 Evaluation Reports:

Abramson, Florence. Special Place/Group Quarters Enumeration. Census 
2000 Testing, Experimentation, and Evaluation Program, Topic Report No. 
5. U.S. Census Bureau, Washington, D.C., February 2004.

Adlakha, Arjun, J. Gregory Robinson, Kirsten West, and Antonio Bruce. 
Assessment of Consistency of Census Data with Demographic Benchmarks at 
the Subnational Level. Census 2000 Evaluation O.20. U.S. Census Bureau, 
Washington, D.C., August 18, 2003.

Clarke, Sandra, John Iceland, Thomas Palumbo, Kirby Posey, and Mai 
Weismantle. Comparing Employment, Income, and Poverty: Census 2000 and 
the Current Population Survey. Census 2000 Auxiliary Evaluation. U.S. 
Census Bureau, Washington, D.C., September 2003.

Palumbo, Thomas and Paul Siegel. Accuracy of Data for Employment Status 
as Measured by the CPS-Census 2000 Match. Census 2000 Evaluation B.7. 
U.S. Census Bureau, Washington, D.C., May 4, 2004.

Schneider, Paula. Content and Data Quality in Census 2000. Census 2000 
Testing, Experimentation, and Evaluation Program, Topic Report No. 12. 
U.S. Census Bureau, Washington, D.C., January 22, 2004.

Census Bureau 2003 JSM Staff Papers:

Bureau staff presented many ACS-related papers at the August 2003 Joint 
Statistical Meetings in San Francisco, California. We reviewed the 
papers in this section in detail because they were related to 
comparisons between ACS estimates and 2000 Census results.

Boggess, Scott, and Nikki L. Graf. Measuring Education: A Comparison of 
the Decennial Census and the American Community Survey. Presented at 
Joint Statistical Meetings, San Francisco, California, August 7, 2003.

Dye, Jane Lawler. Grandparents Living with and Providing Care for 
Grandchildren: A Comparison of Data from Census 2000 and 2000 American 
Community Survey. Presented at Joint Statistical Meetings, San 
Francisco, California, August 7, 2003.

Love, Susan, and Deborah Griffin. A Closer Look at the Quality of Small 
Area Estimates from the American Community Survey. Presented at Joint 
Statistical Meetings, San Francisco, California, August 4, 2003.

Posey, Kirby G., Edward Welniak, and Charles Nelson. Income in the 
American Community Survey: Comparisons to Census 2000. Presented at 
Joint Statistical Meetings, San Francisco, California, August 7, 2003.

Raglin, David A., Theresa F. Leslie, and Deborah H. Griffin. Comparing 
Social Characteristics between Census 2000 and the American Community 
Survey. Presented at Joint Statistical Meetings, San Francisco, 
California, August 3, 2003.

Stern, Sharon M. Counting People with Disabilities: How Survey 
Methodology Influences Estimates in Census 2000 and the Census 2000 
Supplementary Survey. Presented at Joint Statistical Meetings, San 
Francisco, California, August 7, 2003.

Other Census Bureau Staff Research Papers:

Alexander, Charles H. American Community Survey Data for Economic 
Analysis (October 2001). Presented at the Census Advisory Committee of 
the American Economic Association meeting, Washington, D.C., October 
18-19, 2001.

Alexander, Charles H. Recent Developments in the American Community 
Survey. Presented at the 1998 Joint Statistical Meetings, Dallas, 
Texas, August 12, 1998.

Alexander, Charles H., Sharon Brown, and Hugh Knox. American Community 
Survey Data for Economic Analysis (December 2001). Presented at the 
Federal Economic Statistics Advisory Committee meeting, Washington, 
D.C., December 14, 2001.

Alexander, Charles H., Scot Dahl, and Lynn Weidman. Making Estimates 
from the American Community Survey. Presented at the 1997 Joint 
Statistical Meetings, Anaheim, California, August 13, 1997.

Alexander, Charles H., and Signe Wetrogan. Integrating the American 
Community Survey and the Intercensal Demographic Estimates Program. 
Presented at the 2000 Joint Statistical Meetings, Indianapolis, 
Indiana, August 14, 2000.

Butani, Shail, Charles Alexander, and James Esposito. Using the 
American Community Survey to Enhance the Current Population Survey: 
Opportunities and Issues. Presented at the 1999 Federal Committee on 
Statistical Methodology Research Conference, Arlington, Virginia, 
November 15-17, 1999.

Davis, Mary Ellen, and Charles H. Alexander, Jr. The American Community 
Survey: The Census Bureau's Plan to Provide Timely 21st Century Data. 
Missouri Library World, Spring 1997.

DeMaio, Theresa J., and Kristen A. Hughes. Report of Cognitive Research 
on the Residence Rules and Seasonality Questions on the American 
Community Survey. U.S. Bureau of the Census, Statistical Research 
Division, Washington, D.C., July 2003.

Love, Susan, Donald Dalzell, and Charles Alexander. Constructing a 
Major Survey: Operational Plans and Issues For Continuous Measurement. 
Presented at the 1995 Joint Statistical Meetings, Orlando, Florida, 
August 16, 1995.

Nelson, Charles, and Kathleen Short. The Distributional Implications of 
Geographic Adjustment of Poverty Thresholds. U.S. Bureau of the Census, 
Housing and Household Economics Statistics Division, Washington, D.C., 
December 2003.

Posey, Kirby G., and Edward Welniak. Income in the ACS: Comparisons to 
the 1990 Census. Presented at the American Community Survey Symposium, 
Suitland, Maryland, March 1998.

Salvo, Joseph, and Arun Peter Lobo. The American Community Survey: 
Quality of Response by Mode of Data Collection in the Bronx Test Site. 
Presented at the 2002 Joint Statistical Meetings, New York, August 14, 
2002.

Smith, Amy Symens. The American Community Survey and Intercensal 
Population Estimates: Where Are the Crossroads? Technical Working Paper 
31, U.S. Census Bureau, Population Division, Washington, D.C., December 
1998.

Association of Public Data Users Papers:

Davis, Mary Ellen. The American Community Survey Data Products, 
Alexandria, Virginia, October 20, 2003.

Gage, Linda, State of California, Department of Finance. American 
Community Survey: Research by the Data User Community. Alexandria, Va.: 
October 20, 2003.

Petroni, Rita. How Do 3-Year Averages from the ACS Compare to Census 
2000 Data? (Preliminary Results). Alexandria, Va.: October 20, 2003.

Salvo, Joseph, City of New York, Planning Department. American 
Community Survey: Research by the Data User Community. Alexandria, Va.: 
October 20, 2003.

Scarr, Harry A. Deputy Director, Census Bureau. Continuous Measurement. 
Association of Public Data Users, Washington, D.C; October 16, 1994.

Congressional Hearings and Testimony:

Barron, William Jr., Acting Director, U.S. Bureau of the Census, before 
the U.S. House of Representatives, Committee on Government Reform, 
Subcommittee on the Census. The Census Bureau's Proposed American 
Community Survey (ACS), Serial 107-9. Washington, D.C.: June 13, 2001.

Kincannon, Charles Louis, Director, U.S. Bureau of the Census, before 
the U.S. House of Representatives, Subcommittee on Technology, 
Information Policy, Intergovernmental Relations, and the Census. The 
American Community Survey: The Challenges of Eliminating the Long Form 
from the 2010 Census, Serial 108-97. Washington, D.C.: May 13, 2003.

Prewitt, Kenneth, Director, U.S. Bureau of the Census, before the U.S. 
House of Representatives, Committee on Government Reform, Subcommittee 
on the Census. House Hearing on ACS July 20, 2000. The American 
Community Survey: A Replacement for the Census Long Form? Serial 106-
246. Washington, D.C.: July 20, 2000.

Other Reports and Papers:

Kalton, Graham, and others. The American Community Survey: The Quality 
of Rural Data, Report of a Conference. Rockville, Md.: Westat, June 29, 
1998.

Nardone, Thomas, and others. Examining the Discrepancy in Employment 
Growth between the CPS and the CES. Washington, D.C.: FESAC, October 
17, 2003.

National Council on Disability. Improving Federal Disability Data. 
Washington, D.C.: January 9, 2004.

ORC Macro. The American Community Survey: Challenges and Opportunities 
for HUD. Calverton, Md.: September 27, 2002.

Vroman, Wayne. Comparing Labor Market Indicators from the CPS and ACS. 
Washington, D.C.: Urban Institute, September 2003.

Westat Inc. The American Community Survey: A Report on the Use of 
Multi-Year Averages. Rockville, Md.: April 30, 1999.

[End of section]

Related GAO Products:

2010 Census: Cost and Design Issues Need to Be Addressed Soon. GAO-04-
37. Washington, D.C.: January 15, 2004.

Medicaid Formula: Differences in Funding Ability among States Often Are 
Widened. GAO-03-620. Washington, D.C.: July 10, 2003.

Formula Grants: 2000 Census Redistributes Federal Funding Among States. 
GAO-03-178. Washington, D.C.: February 24, 2003.

Major Management Challenges and Program Risks: Department of Commerce. 
GAO-03-97. Washington, D.C.: January 1, 2003.

The American Community Survey: Accuracy and Timeliness Issues. GAO-02-
956R. Washington, D.C.: September 30, 2002.

Legal Authority for American Community Survey. B-289852. Washington, 
D.C.: April 4, 2002.

Medicaid Formula: Effects of Proposed Formula on Federal Shares of 
State Spending. GAO/HEHS-99-29R. Washington, D.C.: February 19, 1999.

Decennial Census: Overview of Historical Census Issues. GAO/GGD-98-103. 
Washington, D.C.: May 1, 1998.

Poverty Measurement: Adjusting for Geographic Cost-of-Living 
Difference. GAO/GGD-95-64. Washington, D.C.: March 9, 1995.

Status of the Statistical Community after Sustaining Budget Reductions. 
GAO/IMTEC-84-17. Washington, D.C.: July 18, 1984.

FOOTNOTES

[1] We discuss the other operations, which relate to the address list 
and the short-form census, in full in GAO, 2010 Census: Cost and Design 
Issues Need to Be Addressed Soon, GAO-04-37 (Washington, D.C.: Jan. 15, 
2004).

[2] We discuss the relative quality of the ACS and the long form in 
GAO, The American Community Survey: Accuracy and Timeliness Issues, 
GAO-02-956R (Washington, D.C.: Sept. 30, 2002), pp. 8-13.

[3] The CPI is a national-level price index that BLS compiles. It also 
compiles separate price indexes for selected geographic areas, but 
these indexes do not measure differences in the level of prices among 
areas.

[4] U.S. Census Bureau, American Community Survey Operations Plan, 
Release 1 (Washington, D.C.: March 2003), pp. 52-53. 

[5] This group's objective is to provide an open dialogue between its 
members and federal statistical agencies. See Council of Professional 
Associations on Federal Statistics, http://www.copafs.org (May 10, 
2004). 

[6] See our recommendations in GAO-02-956R, pp. 25-26. For information 
on the Federal Agency Information Program, see Census Bureau, American 
Community Survey, http://www.census.gov/acs/www (May 10, 2004).

[7] ICPE develops and disseminates annual "official" estimates of the 
total population and the distribution by age, sex, race, and Hispanic 
origin for the nation, state, counties, and functioning government 
units. The program is authorized by 13 U.S.C. §181, which requires the 
production of "current data on total population and population 
characteristics." The estimates of population and housing 
characteristics are as of July 1 of each year, using the usual resident 
concept for seasonal residents. For details on subcounty estimates, see 
U.S. Census Bureau, "Estimates and Projections Area Documentation: 
Subcounty Total Population Estimates," http://www.census.gov. 

[8] Susan Love, Donald Dalzell, and Charles Alexander, "Constructing a 
Major Survey: Operational Plans and Issues for Continuous Measurement," 
presented at the annual American Statistical Association meeting, 
Orlando, Florida, August 1995.

[9] Charles H. Alexander and Signe Wetrogan, "Integrating the American 
Community Survey and the Intercensal Demographic Estimates Program," 
presented at the Joint Statistical Meetings, Indianapolis, Indiana, 
August 14, 2000.

[10] See Bureau of Labor Statistics, "Labor Force and Employment 
Estimates Smoothed for Population Adjustments, 1990-2003," Washington, 
D.C., March 3, 2004. U.S. Department of Labor, Bureau of Labor 
Statistics, Demographics, Demographic Characteristics of the Labor 
Force (Current Population Survey), http://www.bls.gov/cps/cpspopsm.pdf 
(May 10, 2004).

[11] Theresa J. DeMaio and Kristen A. Hughes, "Report of Cognitive 
Research on the Residence Rules and Seasonality Questions on the 
American Community Survey," U.S. Census Bureau, Statistical Research 
Division, Washington, D.C., July 2003. 

[12] DeMaio and Hughes, pp. 9-10.

[13] Benjamin F. King, Chair, Panel on Research on Future Census 
Methods, National Academy of Sciences, letter to William Barron, Acting 
Director, U.S. Bureau of the Census, Washington, D.C., February 15, 
2001, pp. 3-4. The National Academies, National Academies Press, 2010 
Census Panel Letter Report (2001), http://books.nap.edu/html/
2010_census_panel/letterreport.pdf (May 10, 2004). 

[14] BLS makes a similar adjustment to the average weekly earnings data 
from the monthly establishment survey.

[15] For the HUD report, see ORC Macro, The American Community Survey: 
Challenges and Opportunities for HUD (Calverton, Md.: Sept. 27, 2002). 
For a complete discussion of the role of the inflation adjustment in 
differences between the ACS and CPS measures of income, see Kirby G. 
Posey, Edward Welniak, and Charles Nelson, "Income in the ACS: 
Comparisons to Census 2000," presented at the Joint Statistical 
Meetings, San Francisco, California, August 7, 2003. 

[16] For the procedures the Internal Revenue Service and the Department 
of Labor use, see SOI 2000: Corporation Income Tax Returns (Washington, 
D.C.: September 2003). Internal Revenue Service, Tax Statistics, 
Statistics of Income, SOI Products and Services, Corporation Tax 
Statistics--Complete Report Publications, http://www.irs.gov/taxstats/
article/0,,id=112834,00.html (May 10, 2004), and U.S. Department of 
Labor, Pension and Welfare Benefits Administration, Private Pension 
Plan Bulletin: Abstract of 1998 Form 5500 Annual Reports, no. 11 
(Washington, D.C.: winter 2001-02). http://www.dol.gov/ebsa/PDF/
1998pensionplanbulletin.pdf (May 10, 2004). 

[17] For example, in GAO, Poverty Measurement: Adjusting for Geographic 
Cost-of-Living Difference, GAO/GGD-95-64 (Washington, D.C.: Mar. 9, 
1995), we noted that experts generally agreed that it is appropriate to 
adjust state-level poverty counts for cost-of-living differences but 
that they differed on the most appropriate method of making such 
adjustments. In Medicaid Formula: Differences in Funding Ability among 
States Often Are Widened, GAO-03-620 (Washington, D.C.: July 10, 2003), 
we showed that using different cost-of-living adjustments at the state 
level significantly affected the amount of federal funding.

[18] Charles Nelson and Kathleen Short, "The Distributional 
Implications of Geographic Adjustment of Poverty Thresholds," U.S. 
Census Bureau, Housing and Household Economics and Statistics Division, 
Washington, D.C., December 2003.

[19] Kenneth Prewitt, Director, U.S. Bureau of the Census, before the 
U.S. House of Representatives, Committee on Government Reform, 
Subcommittee on the Census, Summary of House Hearing on ACS July 20, 
2000, The American Community Survey: A Replacement for the Census Long 
Form? Serial 106-246 (Washington, D.C.: July 20, 2000). 

[20] Census Bureau officials indicated that some of the delay in 
completing the planned evaluation studies may have resulted from the 
Census Bureau's need to devote additional resources to completing the 
evaluation of the 2000 Census Accuracy, Coverage, and Evaluation 
program and to a survey to test the effect of conducting the ACS as a 
voluntary survey.

[21] See Daniel L. Cork, Michael L. Cohen, and Benjamin F. King, eds., 
Planning the 2010 Census: Second Interim Report (Washington, D.C.: 
National Academies Press, 2003), p. 99.

[22] In Statistical Policy Directive 14, OMB designated the CPS as the 
official source of statistical measures of poverty. The U.S. Department 
of Health and Human Services also designated the CPS as the source of 
poverty measures for its programs in "Annual Update of the HHS Poverty 
Guidelines," 67 Fed. Reg. 6931 (Feb. 14, 2002).

[23] Cork, Cohen, and King, pp. 99-100.

[24] Cork, Cohen, and King, p. 6.

[25] See, for example, Charles Alexander, "A Prototype Continuous 
Measurement System for the U.S. Census of Population and Housing," CM-
17, presented at the annual meeting of the Population Association of 
America, Miami, Florida, May 5, 1994, and Harry A. Scarr, Deputy 
Director, Census Bureau, "Continuous Measurement," Association of 
Public Data Users, Fredericksburg, Virginia, October 16, 1994.

[26] GAO-04-37, pp. 11-12.

[27] See Barry Edmonston and Charles Schultze, eds., Modernizing the 
U.S. Census (Washington, D.C.: National Academies Press, 1995), p. 9. 
The panel was mandated by Public Law 102-125 and funded by the Census 
Bureau.

[28] Edmonston and Schultze, p. 3.

[29] See National Research Council, Committee on National Statistics, 
The American Community Survey: Summary of a Workshop (Washington, D.C.: 
National Academy Press, 2001); Michael L. Cohen and Benjamin F. King, 
eds., Designing the 2010 Census: First Interim Report (Washington, 
D.C.: National Academy Press, 2000); Benjamin F. King, National Academy 
of Sciences, to William Barron, U.S. Bureau of the Census, February 15, 
2001; Daniel L. Cork, Michael L. Cohen, and Benjamin F. King, eds., 
Planning the 2010 Census: Second Interim Report (Washington, D.C.: 
National Academies Press, 2003); Daniel L. Cork, Michael L. Cohen, and 
Benjamin F. King, eds., Reengineering the 2010 Census: Risks and 
Challenges (Washington, D.C.: National Academies Press, 2004); and 
Constance F. Citro, Daniel L. Cork, and Janet L. Norwood, eds., The 
2000 Census: Counting under Adversity (Washington, D.C.: National 
Academies Press, 2004).

[30] See, for example, Constance F. Citro and Graham Kalton, eds., 
Small-Area Income and Poverty Estimates: Priorities for 2000 and Beyond 
(Washington, D.C.: National Academy Press, 2000), and Thomas B. Jabine, 
Thomas A. Louis, and Allen L. Schirm, eds., Choosing the Right Formula: 
Initial Report (Washington, D.C.: National Academy Press, 2001).

[31] The exceptions are the Census Bureau's inflation adjustments for 
dollar-denominated data items and the specific use of 2010 Census 
population and housing controls.

[32] Charles Alexander, of the Census Bureau's Demographic Statistical 
Methods Division, who had directed most of its research on the ACS, 
prepared comments for the Census Bureau. See National Research Council, 
Committee on National Statistics, The American Community Survey: 
Summary of a Workshop, p. 5. 

[33] National Research Council, pp. 48-49.

[34] National Research Council, pp. 1 and 3.

[35] Charles Alexander, Technical Paper, prepared for Workshop on the 
American Community Survey, Committee on National Statistics, National 
Academy of Sciences, Washington, D.C., September 1998, p. 3-2. 

[36] National Research Council, p. 4.

[37] National Research Council, pp. 4 and 5. The Census Bureau provided 
funding for the development of this model in fiscal year 1999, but 
there is no report that the model was completed.

[38] Alexander, Technical Paper, pp. 3-7. 

[39] National Research Council, p. 26.

[40] National Research Council, p. 48.

[41] Michael L. Cohen and Benjamin F. King, eds., Designing the 2010 
Census: First Interim Report (Washington, D.C.: National Academy Press, 
2000), p. 2. The three other recommendations covered the master trace 
sample database, the 2000 Census administrative records research 
program, and the activities of local organizations that helped with the 
census count.

[42] Cohen and King, p. 34.

[43] Cohen and King, pp. 34-35.

[44] Cohen and King, eds., p. 38. The Census Bureau has established the 
Federal Agency Information Program on the ACS in response to a 
recommendation we made in GAO-02-956R, p. 25. Information is at the 
Census Bureau's Web site at http://www.census.gov/acs/www/.

[45] These recommendations were similar to recommendations we made in 
GAO-04-37, pp. 33-34.

[46] King, to Barron, p. 3.

[47] King, to Barron, p. 4. The other studies related to the 2000 
Census mailing list and the effect of local partnerships on the 2000 
Census collection process.

[48] King, to Barron, p. 2.

[49] Cork, Cohen, and King, p. 6.

[50] Cork, Cohen, and King, pp. 99-102. As we noted above, we discussed 
issues related to planning for the 2010 Census in GAO-04-37.

[51] Cork, Cohen, and King, p. 99. 

[52] Cork, Cohen, and King, p. 86. 

[53] Cork, Cohen, and King, p. 87.

[54] Cork, Cohen, and King, p. 98.

[55] Citro, Cork, and Norwood, eds., The 2000 Census: Counting under 
Adversity, p. 1.

[56] Citro, Cork, and Norwood, pp. 2-3.

[57] Citro, Cork, and Norwood, pp. 10-11.

[58] Citro, Cork, and Norwood, p. 11.

[59] Citro, Cork, and Norwood, p. 301. See recommendations 7.1 and 7.3.

[60] The long form is also discussed in Joseph Salvo and Arun Peter 
Lobo, "The American Community Survey: Quality of Response by Mode of 
Data Collection in the Bronx Test Site," presented at 2002 Joint 
Statistical Meetings, New York, August 14, 2002; Margo Anderson, ed., 
Encyclopedia of the U.S. Census (Washington, D.C.: CQ Press, 2000); and 
GAO, Decennial Census: Overview of Historical Census Issues, GAO/
GGD-98-103 (Washington, D.C.: May 1, 1998).

[61] See GAO-02-956R.

[62] Data items similar or identical to those collected on the long 
form are collected by the Annual Demographic Survey (CPS's March 
supplement), Annual Housing Survey, and other surveys. However, these 
surveys' samples limit the data they provide to the national level and 
selected states and metropolitan areas. Annual data for all small 
geographic areas are available from (1) administrative records on 
unemployment insurance and wages and federal income tax and Medicare 
records; (2) statistical series the Bureau of Economic Analysis (BEA) 
prepares, such as local area personal income data; and (3) model-based 
series such as the Census Bureau's Small Area Income and Poverty 
Estimates program.

[63] Harry A. Scarr presented this proposal as Deputy Director of the 
Census Bureau at an Association of Public Data Users conference in 
Fredericksburg, Virginia, on October 16, 1994. 

[64] The Census Bureau also prepared a number of internal papers that 
evaluated the results of the 2000 Census long form and recommended 
changes that applied to the ACS. We discuss some of these papers in 
this report. 

[65] Most of the papers in this series are not available to the public 
(a few are on the Census Bureau's ACS Web site at http://
www.census.gov/acs/www/), but the Census Bureau provided us with a 
complete set.

[66] Some of the papers from this March 25, 1998, symposium are 
available on the Census Bureau's ACS Web site; several presented 
information from the 1996 ACS testing. 

[67] Susan Love, Donald Dalzell, and Charles Alexander, "Constructing a 
Major Survey: Operational Plans and Issues for Continuous Measurement," 
presented at the annual American Statistical Association meeting, 
Orlando, Florida, August 16, 1995.

[68] Charles H. Alexander and Signe Wetrogan, "Integrating the American 
Community Survey and the Intercensal Demographic Estimates Program," 
presented at the Joint Statistical Meetings, Indianapolis, Indiana, 
August 14, 2000.

[69] Charles H. Alexander, Scot Dahl, and Lynn Weidman, "Making 
Estimates from the American Community Survey," presented at the Annual 
American Statistical Association Meeting, Anaheim, California, August 
13, 1997. 

[70] Mary Ellen Davis and Charles H. Alexander, "The American Community 
Survey: The Census Bureau's Plan to Provide Timely 21st Century Data," 
Delaware Dataline, Summer 1997. U.S. Census Bureau, American Community 
Survey, Advanced Methodology, Papers and Presentations, http://
www.census.gov/acs/www (June 3, 2004).

[71] Charles Alexander, "Recent Developments in the American Community 
Survey," presented at the American Statistical Association Meeting, 
Dallas, Texas, August 12, 1998. U.S. Census Bureau, American Community 
Survey, Advanced Methodology, Papers and Presentations, http://
www.census.gov/acs/www (June 3, 2004).

[72] Posey and Welniak, "Income in the ACS: Comparisons to the 1990 
Census."

[73] Shail Butani, Charles Alexander, and James Esposito, "Using the 
American Community Survey to Enhance the Current Population Survey: 
Opportunities and Issues," presented at the 1999 Federal Committee on 
Statistical Methodology Research Conference, Arlington, Virginia, 
November 15-17, 1999. 

[74] To assist in this research, BLS wrote a contract with Wayne Vroman 
of the Urban Institute for his 2003 report, "Comparing Labor Market 
Indicators from the CPS and ACS." 

[75] Charles H. Alexander, "Still Rolling: Leslie Kish's 'Rolling 
Samples' and the American Community Survey," in Proceedings of 
Statistics Canada Symposium 2001: October 16-19 (Ottawa, Canada: 
Statistics Canada, 2002). 

[76] U.S. Census Bureau, Meeting 21st Century Demographic Data Needs, 
Report 1, Demonstrating Operational Feasibility (Washington, D.C.: July 
2001). C2SS, conducted as part of the 2000 Census, was a national 
survey of about 700,000 households and designed to test the operational 
feasibility of collecting long-form data at the same time as, but 
separately from, the Decennial Census. Its questionnaire was 
essentially the same as the long form. The survey has been conducted 
annually since 2000.

[77] U.S. Census Bureau, Meeting 21st Century Demographic Data Needs, 
Report 2, Demonstrating Survey Quality (Washington, D.C.: May 2002). 

[78] U.S. Office of Management and Budget, Measuring and Reporting 
Sources of Errors in Surveys, Statistical Policy Working Paper 31 
(Washington D.C.: July 2001). 

[79] In 2000, the Census Bureau established an ACS Research and 
Evaluation Steering Committee to develop a series of reports on key 
results from the ACS development program. A team was to manage the 
program and identify key questions whose answers would demonstrate the 
adequacy of the ACS as a replacement for the Decennial Census long 
form. See U.S. Census Bureau, American Community Survey Development 
Report Series Program Plan (Washington, D.C.: rev. June 12, 2002), p. 
5.

[80] U.S. Census Bureau, American Community Survey Operations Plan, 
Release 1. 

[81] In April 2003, the Census Bureau let a contract with local experts 
to study and evaluate selected differences between 1999-2001 averages 
from four test sites and corresponding 2000 long-form data. 

[82] U.S. Census Bureau, American Community Survey Operations Plan, 
Release 1, p. 36.

[83] Deborah H. Griffin, "Comparing Characteristics from the American 
Community Survey and Census 2000: Methodology," presented at Census 
Advisory Committee of Professional Associations Meetings, Washington, 
D.C., April 10-11, 2003, p. 2. 

[84] U.S. Census Bureau, ACS-2010 Consistency Review Plan (Washington, 
D.C.: October 1, 2003).

[85] Lynn Weidman and Signe Wetrogan, "Enhancing the Intercensal 
Population Estimates Program with ACS Data: Summary of Research 
Projects," Census Advisory Committee of Professional Associations 
meeting, Washington, D.C., October 23, 2003.

[86] Navarro, "American Community Survey: Use of Population Estimates 
as Controls in the ACS Weighting," presented at Census Bureau Advisory 
Committee of Professional Associations meeting, Washington, D.C., 
October 23, 2003.

[87] Paula Schneider, Content and Data Quality in Census 2000, Census 
2000 Testing, Experimentation, and Evaluation Program Topic Report No. 
12 (Washington, D.C.: U.S. Census Bureau, January 22, 2004). 

[88] ICPE develops and disseminates annual estimates of the total 
population and the distribution by age, sex, race, and Hispanic origin 
for the nation, state, counties, and functioning government units. The 
program is authorized by 13 U.S.C. §181, which requires the production 
of "current data on total population and population characteristics."

[89] For additional details, see U.S. Census Bureau, "Estimates and 
Projections Area Documentation: Subcounty Total Population Estimates," 
http://www.census.gov.

[90] The initial ACS estimates for 2010 are to be released before the 
2010 Census-based ICPE estimates are available.

[91] Susan Love, Donald Dalzell, and Charles Alexander, "Constructing a 
Major Survey: Operational Plans and Issues for Continuous Measurement," 
presented at the annual American Statistical Association meeting, 
Orlando, Florida, August 16, 1995. 

[92] This May 14-15, 1998, conference was held in response to U.S. 
Senate Appropriations Committee Report 105-48, 105th Cong., 1st sess. 
(July 16, 1997), title II, p. 64, which had stated that "The outside 
evaluator should review the ACS to determine whether there is an 
antirural bias in its design." Graham Kalton and others prepared the 
conference report for the Census Bureau: The American Community Survey: 
The Quality of Rural Data (Rockville, Md.: Westat, June 29, 1998).

[93] Alexander and Wetrogan, "Integrating the American Community Survey 
and the Intercensal Demographic Estimates Program." 

[94] ACS data on foreign-born persons were used to estimate the 
national levels of international migration that were incorporated into 
the intercensal estimates for 2003, based on the 2000, 2001, and 2002 
ACS.

[95] Navarro, "American Community Survey." 

[96] Weidman and Wetrogan, "Enhancing the Intercensal Population 
Estimates Program with ACS Data." 

[97] Schneider, Content and Data Quality in Census 2000. 

[98] Theresa J. DeMaio and Kristen A. Hughes, "Report of Cognitive 
Research on the Residence Rules and Seasonality Questions on the 
American Community Survey," U.S. Census Bureau, Statistical Research 
Division, Washington, D.C., July 2003. 

[99] DeMaio and Hughes, "Report of Cognitive Research on the Residence 
Rules and Seasonality Questions," pp. 9-10.

[100] In contrast, a 2000 Census questionnaire received in late April 
2000 that listed a resident aged 11 with an April 15, 1989, birthdate 
would be considered inconsistent because the person was aged 10 on 
census day.

[101] Kirby G. Posey, Edward Welniak, and Charles Nelson, "Income in 
the American Community Survey: Comparisons to Census 2000," presented 
at the Joint Statistical Meetings, San Francisco, California, August 7, 
2003.

[102] Sharon M. Stern, "Counting People with Disabilities: How Survey 
Methodology Influences Estimates in Census 2000 and the Census 2000 
Supplementary Survey," presented at the Joint Statistical Meetings, San 
Francisco, California, August 7, 2003.

[103] Although data on group quarters were collected at the ACS test 
sites in 1999 and 2001, data on them were not collected in the ACS 
supplementary surveys, which began in 2000. The Census Bureau made this 
decision to avoid duplication with the 2000 Decennial Census and 
because it lacked funding to cover them in subsequent years.

[104] Census Bureau, American Community Survey Operations Plan, Release 
1. 

[105] U.S. Census Bureau, ACS-2010 Consistency Review Plan. 

[106] U.S. Census Bureau, 2010 Decision Memorandum Series No. 5. 
(Washington, D.C.: June 3, 2004) and 2010 Planning Memorandum Series 
No. 24 (Washington, D.C.: June 9, 2004).

[107] For a complete discussion, see ORC Macro, The American Community 
Survey: Challenges and Opportunities for HUD (Calverton, Md.: Sept. 27, 
2002). For a complete discussion of the role of the inflation 
adjustment in differences between the ACS and CPS measures of income, 
see Posey, Welniak, and Nelson, "Income in the American Community 
Survey." 

[108] ORC Macro, p. 16.

[109] ORC Macro, p. 44.

[110] ORC Macro, pp. 16-17.

[111] ORC Macro, p. 44.

[112] ORC Macro, p. 208.

[113] See Posey, Welniak, and Nelson. 

[114] Posey, Welniak, and Nelson, p. 14.

[115] Posey, Welniak, and Nelson, p. 15.

[116] Charles Nelson and Kathleen Short, "The Distributional 
Implications of Geographic Adjustment of Poverty Thresholds," U.S. 
Census Bureau, Housing and Household Economics and Statistics Division, 
Washington, D.C., December 2003.

[117] 64 Fed. Reg. 64 48759-48760 (Sept. 8, 1999). The Census Bureau 
made similar statements about the importance of comparisons in its 
request to OMB to extend approval of the supplementary survey forms in 
67 Fed. Reg. 67 21629 (May 1, 2002).

[118] Kenneth Prewitt, Director, U.S. Bureau of the Census, before the 
U.S. House of Representatives, Committee on Government Reform, 
Subcommittee on the Census, Summary of House Hearing on ACS July 20, 
2000, The American Community Survey: A Replacement for the Census Long 
Form? Serial 106-246 (Washington, D.C.: July 20, 2000). 

[119] U.S. Census Bureau, Meeting 21st Century Demographic Data Needs: 
Implementing the American Community Survey, Report 1, Demonstrating 
Operational Feasibility. 

[120] U.S. Census Bureau, Meeting 21st Century Demographic Data Needs: 
Implementing the American Community Survey, Report 2, Demonstrating 
Survey Quality. 

[121] U.S. Census Bureau, American Community Survey Development Report 
Series Program Plan, an internal report prepared a month later, had 
called for completing one of these reports by the end of 2002. 

[122] U.S. Census Bureau, American Community Survey Operations Plan, 
Release 1. 

[123] GAO-02-956R, p. 11.

[124] GAO-02-956R, p. 12. 

[125] Wayne Vroman, Comparing Labor Market Indicators from the CPS and 
ACS (Washington, D.C.: Urban Institute, September 2003).

[126] Vroman, p. 23.

[127] Schneider. 

[128] Posey, Welniak, and Nelson, "Income in the American Community 
Survey," p. 14.

[129] Stern, "Counting People with Disabilities." 

[130] Lex Frieden, Chair, National Council on Disability, "Improving 
Federal Disability Data," Washington, D.C., January 8, 2004. National 
Council on Disability, Newsroom, Publications, 2004, http://
www.ncd.gov/newsroom/publications/2004/publications.htm (May 11, 
2004).

[131] Cork, Cohen, and King, p. 99. 

[132] Cork, Cohen, and King, p. 99.

[133] Graham Kalton and others, The American Community Survey: The 
Quality of Rural Data, A Report of a Conference (Rockville, Md.: 
Westat, June 29, 1998), p. 3.

[134] Kalton and others, p. 12.

[135] Kalton and others, p. 13.

[136] Westat Inc., The American Community Survey: A Report on the Use 
of Multi-Year Averages (Rockville, Md.: April 30, 1999), p. 12.

[137] Alexander, p. 6.

[138] Alexander, p. 6.

[139] Charles Alexander, "A Discussion of the Quality of Estimates from 
the American Community Survey for Small Population Groups," written 
August 26, 2002, for the Census Advisory Committee of Professional 
Associations meeting, Washington, D.C., October 2-3, 2002, p. 3.

[140] GAO-02-956R and ORC Macro.

[141] GAO-02-956R, p. 25.

[142] GAO-02-956R, p. 15.

[143] ORC Macro, p. vi. 

[144] ORC Macro, p. vi.

[145] Since ORC Macro's study was issued, full implementation of the 
ACS has been delayed; the first 5-year averages will not be available 
until 2010. 

[146] Cork, Cohen, and King, pp. 99-100.

[147] Cork, Cohen, and King, p. 6.

[148] Cork, Cohen, and King, p. 86.

[149] Cork, Cohen, and King, p. 87.

[150] GAO-02-956R, pp. 25-26. Information on the Federal Agency 
Information Program is at Census Bureau, American Community Survey, 
http://www.census.gov/acs/www (May 11, 2004).

[151] Census Bureau, American Community Survey Operations Plan, Release 
1, p. 56.

[152] Cork, Cohen, and King, p. 98. 

[153] The record of committee recommendations for the October 2003 
meetings was not available.

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