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Posted September 19, 2006


Anne Katahira-Sims, MAVIN Foundation Executive Director


(Seattle) MAVIN Foundation joined an impressive list of national civil rights and educational organizations in issuing a response to the U.S. Department of Education's (DOE) Proposed Guidance on Maintaining, Collecting and Reporting Data on Race and Ethnicity. Among the signers were the Asian American Justice Center, Mexican American Legal Defense and Education Fund, NAACP Legal Defense and Education Fund, Inc., and National Education Association. The DOE, which released its plans to adopt federal OMB standards on August 7, invited public comment until September 18, 2006. While MAVIN Foundation is encouraged by some of the DOE's proposals, the Foundation has significant concerns as well. The letter urges the DOE to postpone their proposals until the most egregious issues can be remedied.

Full text of the letter is below.

Read the Department of Education's Proposed Guidelines Here.

September 19, 2006

Patrick J. Sherrill
US Department of Education
400 Maryland Avenue, SW.
Room 6C103
Washington, DC 20202-0600

Dear Mr. Sherrill:

We are writing to express our deep concern about the Proposed Guidance on Maintaining, Collecting and Reporting Data on Race and Ethnicity to the U.S. Department of Education.

Upon review, we have determined that there are several aspects of the proposed regulations that would have a severely negative impact on the public's ability to access usable and accurate data on the racial and ethnic composition of students attending primary schools, secondary schools, colleges and universities in the U.S. Parents, researchers, civil rights advocates, and other groups who rely on disaggregated racial and ethnic student information are the most likely to be adversely affected. Among our concerns are the following:

    Creating a single "multiracial" category hides the specific racial and ethnic mix of students. The Department?s proposal not to require states to compile or report disaggregated racial and ethnic data for students who self-identify as more than one race would undermine the ability of researchers, civil rights groups, parents, and other interested parties to understand the scope of diversity in our schools. It would also complicate their ability to assess and determine the validity of information generated by No Child Left Behind, Individuals with Disabilities Education Act and other laws that rely on the racial and ethnic data of students.

    Implementing a two step process for identifying ethnicity and race may promote inaccurate data results. While it is important to understand racial differences within the Hispanic category, we do not have enough information to understand whether the proposed process allows for the accurate reporting of this data. As a result, we recommend an extended assessment of the impact of this two-step process before these changes are implemented.

    Encouraging young children to self-identify their racial/ethnic identity may distort the accuracy of the reported racial and ethnic data. While it is important that young people be able to self-identify, there is no check on the process to ensure the self-reported information is accurate. When you combine very young students with a complicated racial reporting form containing a multi-racial category and a complex two-step process for establishing ethnicity and race, it likely to generate more questions about the accuracy of the data.

    New reporting requirements would make it difficult for researchers, parents, civil rights advocates, and the public to access accurate information. If these parties wanted to gather disaggregated racial and ethnic data, the proposed regulations would have the effect of forcing them to request this information from entities in each state. This process would be burdensome and would likely hinder the collection of important data.
Given the increasing racial and ethnic diversity of our nation, it is more important than ever that we fully understand and document the range of diversity that exists among students and within individual students. It is for this reason that we are requesting that the Department give full consideration to alternative measures that include: 1) disaggregating racial and ethnic data from the proposed single mixed-race category; 2) requiring educational institutions and other recipients to compile and report disaggregated racial and ethnic data to the Department; 3) developing a process for verifying the racial/ethnic categories self-reported by younger students; and, 4) extending the period by which the Department examines the impact of the proposed regulations.

Since there is not enough information at this time about the impact of the proposed guidelines to justify moving forward with their implementation, we respectfully urge the Department to postpone the proposed changes until their more egregious aspects can be fixed and more information can be gathered.


Alliance for Excellent Education
Asian American Justice Center
Blacks in Government
Center for Children's Law and Policy
Internationals Network for Public Schools
Joint Center for Political and Economic Studies
League of United Latin American Citizens
MAVIN Foundation
Mexican American Legal Defense and Education Fund
NAACP Legal Defense and Educational Fund, Inc.
National Association for Multicultural Education
National Black Child Development Institute
National Education Association
Public Education Network
Sikh American Legal Defense and Education Fund
Southeast Asia Resource Action Center
The Schott Foundation for Public Education

MAVIN Foundation builds healthy communities that celebrate and empower mixed heritage people and families. Since 1998, MAVIN has invested millions of dollars into innovative and award-winning projects focused on mixed heritage people, transracial adoptees and multiracial families. For more information, visit


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Looking back at eight remarkable years!

Matt Kelley founded MAVIN magazine as a 19-year-old freshman at Wesleyan Univ.

MAVIN's premier issue hit newsstands on Jan. 29, 1999.

In 2000, MAVIN magazine became the nonprofit MAVIN Foundation.

Recently, Kelley focused his efforts on advocating on behalf of policy issues.

In 2005, MAVIN sent five 20-somethings on a 10,000-mile trek to raise awareness of multiracial issues.