A month ago, I published an action alert due to the Census Bureau’s intent to change the definition of disability and the screening questions they use to compile disability data.
Today, I’m glad to report that the change has not been adopted, at least not at this point. This is largely due to the pushback received by the disability community. The National Advisory Committee, in their meeting on November 16 (starting at timestamp 7:44:05 in the recording) made the recommendation that the Bureau “not adopt” any changes to the new set of questions until “a representative cross-section of diverse members of the disability community can be consulted prior to any future changes to the disability data questions to safeguard against omitting many people with disabilities from the process.”
It’s important to note that these recommendations have not been finalized and that additional work on specific language is currently being completed. The Federal Register notice comment period is still open until December 19, and I still encourage submissions to that form, if you haven’t already. Sometime in the next few days, I intend to write and publish my own response to the Federal Register notice. Below is an overview, from my previous action alert, on how to submit to the Federal Register:
By law, anytime a federal agency wants to make a change, they have to put a notice in the Federal Register (big book) informing the public of the change they intend to make and allow comments from the public on it. This period is typically 60 days long (as of 12/1, there are 18 days left).
This is where you should submit more detailed comments. To submit a comment, click the green “Submit a Formal Comment” button on this page.
In your comment, consider including:
- Your relation to the issue (disabled person, non-disabled ally, academic, doctor, etc). Also include any relevant credentials in this area (MD, Disability Advocate, etc)
- An explanation of why you oppose the change of metrics.
- The impact this change may have on you/the community.
The Regulations.gov Commenter Checklist (republished and linked to from the Administrative Conference for the United States) here includes the above recommendations I’ve outlined to be particularly relevant, plus additional suggestions.
A brief note about form letters and decision-making by federal agencies, pulled from the Commenter Checklist, for emphasis: “Many in the public mistakenly believe that their submitted form letter constitutes a “vote” regarding the issues concerning them. Although public support or opposition may help guide important public policies, agencies make determinations for a proposed action based on sound reasoning and scientific evidence rather than a majority of votes. A single, well-supported comment may carry more weight than a thousand form letters.”
I implore you to use data in your comments. Make sure that your comment is:
- individualized to state your beliefs on the proposed changes,
- complete, and
- relevant to the regulation only
Do not include personal information or profanity, as this can result in your comment not being published publicly.
The in-progress recommendation by the National Advisory Committee is an exceptional step, which strongly discourages the proposed changes. It is a huge relief. But, there is still more we can do, so I encourage the continual submission of Federal Register comments until the close of the comment period to add even more pressure on the Census to continue consulting the disability community before making these decisions.
Hat tip to Sarah Blahovec on LinkedIn for her continued following of this issue and breaking the news to me through my feed.
Derek I. Schmitz 