Background in earlier DCSS news item, "Comment on revisions to the American Community Survey (ACS) and the Puerto Rico Community Survey (PRCS) by June 14"

The Census Quality Reinforcement Task Force (CQR) submitted comments on behalf of 29 organizations and 32 individual signers. [PDF]

"Conclusion:
"First, the research record supports implementation in the 2027 ACS, consistent with the Census Bureau's prior determination following formal analysis. That record, spanning more than two decades of Census Bureau testing and independent scientific advisory committee review, remains substantively unchanged. Each year of deferral beyond the Bureau's 2027 target reduces available time for implementation, testing, and evaluation before the current 2029 implementation benchmark, narrows the window for operational preparation before the 2030 Census, and extends the period during which known measurement limitations of the 1997 framework persist.

"Second, the program change described in the supporting statement is not reflected in the 30-day Federal Register Notice. The March 27, 2026 OMB bulletin extended the Action Plan submission timeline and stated that it otherwise made no additional changes to implementation timelines. The current September 2029 data collection implementation timeline referenced in OMB SPD 15 guidance therefore remains in effect, and the operational consequences of deferral identified above remain relevant regardless of the administrative latitude provided by the Action Plan extension.

"CQR respectfully submits that the technical record supports implementation of the updated standards in the 2027 ACS, consistent with the Census Bureau's prior determination, and that no new methodological findings in the public record justify further deferral."