December 19, 2023
U.S. Census Bureau
Department of Commerce
4600 Silver Hill Road
Washington, DC 20233
[Submited electronically]
Re: Census Bureau Proposed Changes to the 2025 American Community Survey Questions, Docket Number USBC–2023–0009
To whom it may concern:
On behalf of the Alliance for Expanding America’s Workforce (AEAW), we wish to express concern about
the changes being proposed to the 2025 American Community Survey.
AEAW is an alliance of organizations dedicated to expanding employment opportunities for people with
disabilities by modernizing the federal government’s procurement processes, direct hiring practices, and
related policies. The federal government is the nation's largest employer and offers the greatest
opportunity to expand disability employment protections.
We are concerned with the proposed changes related to defining disability for the purposes of the
survey. We agree that it is vital to have accurate data to ensure that states and communities are getting
the necessary funding to provide support and services to individuals with disabilities. And we agree that
the current questions miss a substantial number of people with disabilities and need to be improved.
However, we are concerned that the proposed changes will not fix the problem of undercounting and
may exacerbate it.
Data from the American Community Survey is used by federal, state, and local governments to
determine funding levels for services and supports for individuals with disabilities. Making changes to
the survey that could significantly alter the number of individuals that are counted as disabled, and
therefore impact funding allocations, will impact the availability of services provided to support people
with disabilities to live and work in their communities. As employers and services provides to people
with disabilities in our communities, we are concerned that the changes proposed may dramatically
affect our employees with disabilities and the people who receive our services and supports.
We urge you to pause the proposed changes and engage our communities in a more inclusive public
process.
Regards,
AEAW