2020 Census: Actions Needed to Improve Census Bureau's Process for Working with Governments to Build Address List

A complete address list is a cornerstone of the Bureau's effort to conduct an accurate census. LUCA is one of several operations the Bureau uses to produce its address list. It gives tribal, state, and local governments the opportunity to review the address list for their areas and provide the Bureau with any updates before the census.

GAO was asked to review the status of LUCA, including its effect on other operations, as well as LUCA's overall effectiveness and necessity. This report examines (1) LUCA's status and its likely effects on 2020 field operations, and (2) what considerations the Bureau and other stakeholders could use to reexamine LUCA for 2030. GAO reviewed Bureau plans, analyzed data from LUCA participation and the Bureau's review of submissions, and held 9 discussions on a possible reexamination of LUCA with relevant Bureau officials, a council representing participating governments, and census data subject matter specialists.

The Census Bureau generally followed the operational design for its Local Update of Census Addresses (LUCA) program, which is intended to give tribal, state, and local governments the ability to review and offer modifications to the Bureau's Master Address File (MAF). The Bureau met milestones, apart from extending the participation window for natural disaster-stricken areas, and generally followed plans for outreach, training, and participation options.

However, some decisions created additional fieldwork. The Bureau received more updates from participants than it expected, so it only reviewed roughly 860,000 of the 5.1 million updates that did not match to the MAF (see figure below). The rest will be added to potential fieldwork. Had more addresses been reviewed in-office, many may have been rejected, based on the rejection rate for reviewed addresses. Avoiding this unnecessary fieldwork could have saved the Bureau millions of dollars when following up with non-responding households.

The Bureau has not reexamined LUCA with respect to the cost, quality, and public perception of the census since the program was authorized in 1994. Yet much has changed since then, from the tools the Bureau uses in building its address list to the provision of publicly accessible address data. As the Bureau turns to its strategic planning process for 2030, it will have several issues to address regarding the future of LUCA, including:

whether LUCA should continue to have a role in building the address list given the advent of other address-building initiatives;

how often to have governments review the MAF for the census, in light of the costs and benefits of administering such a program more frequently;

whether statutory nondisclosure protection of census address data is still needed given that address data sources and services are more prevalent.

GAO is making eight recommendations to the Department of Commerce, including that the Bureau ensure more LUCA submissions are reviewed and reexamine LUCA to address the related issues GAO identified as part of the Bureau's strategic planning process for the 2030 Census. The Department of Commerce agreed with our findings and recommendations and described several cost savings and efficiency gains—which we have not audited—from their related address list-building efforts. The Census Bureau, Office of Management and Budget, and U.S. Department of Transportation each also provided us with technical comments, which we incorporated as appropriate.

A complete and accurate address list is a cornerstone of the Census  Bureau’s (Bureau) constitutionally mandated effort to count everyone  once, only once, and in the right place. In 1994, Congress passed the  Census Address List Improvement Act, which instructs the Secretary of  Commerce to work with the Bureau to give tribal, state, and local  governments the ability to review and offer modifications to the Bureau’s  Master Address File (MAF) in order to assist the Bureau’s efforts to  ensure the accuracy of the census. The MAF is intended to be a  complete and current list of all addresses and locations where people live  or potentially live in the United States and Puerto Rico.

According to one of the sponsors of the legislation, the goals of the act  were to improve the quality of the MAF, decrease the cost of compiling  the MAF, and strengthen the relationship between local governments and  the Bureau. Additionally, there was a particular concern with the  undercount that occurred in the 1990 Census, including the differential  undercount of minorities.

First instituted for the 2000 Census, the Local Update of Census  Addresses (LUCA) program was designed to implement the requirements  of the Census Address List Improvement Act of 1994. LUCA involves a  multi-phase process: participating governments review and propose  modifications to the MAF; the Bureau reviews participant submissions  and provides feedback; and the Office of Management and Budget (OMB)  oversees a third-party review of appealed Bureau rulings. LUCA is one of  multiple opportunities that tribal, state, and local governments have to  provide input to the MAF. For the 2020 cycle, LUCA began in 2017 with  invitations to nearly 40,000 governments. Additions to the MAF via LUCA  will be finalized in January 2020.

You asked us to review the status of LUCA, its effect on other operations,  and its overall necessity and effectiveness given the complexities of  building the address list. This report examines (1) LUCA’s status and  likely effects on other 2020 Census operations, and (2) what  considerations the Bureau and stakeholders could use to reexamine  LUCA for 2030.

To address these objectives, we reviewed current and past  implementation plans for LUCA. We conducted a literature review to  identify any relevant third-party evaluations of past LUCA implementation,  as well as documentation on development of the Census Address List  Improvement Act of 1994 to better understand trends in LUCA  implementation and the extent to which the program has evolved in line  with its original purpose. Additionally, we interviewed former  congressional staff who assisted in writing the legislation. We also  interviewed senior Bureau officials, LUCA participant stakeholders, and  subject matter specialists to solicit informed views on a range of current  and future implementation issues.

To report on the current status of LUCA and the expected impact of any  resulting address list changes on 2020 Census field operations, we  obtained and analyzed multiple streams of data on LUCA participation  from governments and address validation by the Bureau. We reviewed  the Bureau’s implementation of LUCA 2020 thus far to assess the extent  to which it was in line with operational planning documentation. We found  the data to be reliable for the purposes of our reporting objectives. We  also reviewed current documentation and interviewed OMB officials on  plans for the ongoing LUCA appeals process, in addition to reviewing  prior evaluations related to the LUCA appeals process.

To identify considerations for a reexamination of the LUCA program, we  held a total of nine discussions: three with groups of Bureau officials  involved in managing LUCA; two with officials representing state  governments; and four with selected subject matter specialists as  identified by our internal stakeholders as well as by staff involved with a  former panel on reengineering the census. We structured these  discussions around relevant questions identified in GAO’s 21st Century  Challenges: Reexamining the Base of the Federal Government. We also  reviewed our prior reports and documentation on the LUCA program as  part of our summary of past implementation findings. Additionally, we  reviewed planning and cost documentation and interviewed cognizant  lead officials for geographic programs and initiatives related to LUCA to  identify any alternative program designs.

We conducted this performance audit from January 2019 to October 2019  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

A complete and accurate address list is the cornerstone of a successful  census because it identifies all living quarters that are to receive a census  questionnaire and serves as the control mechanism for following up with  households that do not respond. If the address list is inaccurate, the  Bureau may miss people, count them more than once, or include them in  the wrong locations. As figure 1 shows, the Bureau’s approach to building  complete and accurate address lists consists of a series of operations  and are conducted throughout the decade. These operations include  partnerships with the United States Postal Service (USPS) as well as  tribal, state, and local governments. Other federal agencies, local  planning organizations, the private sector, and nongovernmental entities  may also contribute to these operations by providing the Bureau with  updated address information as part of the Bureau’s continuous  maintenance of the MAF.

Like other information collected for the census, data collected through the  LUCA program are subject to protections under title 13 of the U.S. Code.  This means that data collected from the census cannot be used for non- statistical purposes or shared with unauthorized parties.

The fundamental structure of LUCA has not changed since the Bureau  first implemented it during the 2000 decennial cycle. The Bureau implements LUCA once every 10 years, near the end of the decennial  census cycle. The Bureau invites governments to review the MAF for their  respective areas. These governments must abide by Title 13 by  protecting the address data from disclosure. Participating governments  can then submit address updates for inclusion in the address list before  enumeration. The Bureau can accept or reject these address updates,  which participants then have the opportunity to appeal through an  appeals office that OMB administers and that the Bureau funds (see  figure 2).

While the structure of the program is largely the same as in previous  enumerations, the Bureau has made some changes to promote  participation and reduce perceived participation barriers. For example, in  2010, the Bureau extended review timelines from 90 to 120 calendar days  in response to LUCA participants’ feedback that they did not have enough  resources to complete a sufficient review within the Bureau’s original time  frame. Additionally, in the 2010 and 2020 cycles, the Bureau permitted  state governments to participate in LUCA. State participation can provide  coverage for local governments that may not have the resources to  participate in the operation. Moreover, following the 2010 Census and in  response to our prior recommendations, the Bureau assessed LUCA’s  contribution to the final census population counts. Doing so improved the  Bureau’s ability to determine how helpful LUCA was in gathering address  information from participants across the nation.

Procedures for Building the Address List and Counting Residents

In September 2014, the Bureau decided that it would only need to verify  addresses door to door in those areas it could not resolve with the aid of  computer imagery and third-party data sources—what the Bureau calls in- office address canvassing. The Bureau used this method of address  canvassing to reduce the costs of the labor-intensive “in-field address  canvassing”, which cost about $450 million during the 2010 Census. As  part of this effort, the Bureau planned to rely on in-office address  canvassing as the primary method for validating address updates  submitted during LUCA 2020.

After the Bureau builds its address list, it must enumerate residents and  follow up with them as necessary. Historically one of the most cost- intensive operations of the decennial census, the Bureau implements  Non-response Follow-up after the self-response period so that it can (1)  determine the occupancy status of individual nonresponsive housing units  and (2) enumerate them. The Bureau allows up to six enumeration  attempts for each nonresponsive housing unit or case. Any addresses  added from LUCA submissions become eligible to be enumerated.

Other sources of address data complement the Bureau’s data-collection  efforts. For instance, according to experts, systematic collection of  address data is now common at the state and local level, which allows  many governments to readily provide address information to the Bureau.  Since 2013, the Bureau has also received address updates throughout  the decade from the USPS as well as from tribal, state, and local  governments through its Geographic Support System (GSS) Program,  increasing the frequency of address updates.

Outside of the auspices of Title 13-protected census data, states and  federal agencies have worked toward making a national address  database publicly available. For example, the National Address  Database, managed by the U.S. Department of Transportation as part of  its work with the Bureau on federal address data issues, is an open  source database which enables governments to view and submit their  address information, including geospatial coordinates, for use across  governmental agencies. In 2015, we reported on the National Address  Database and Title 13, suggesting that Congress consider assessing  statutory limitations within Title 13 on address data to foster progress  toward such a national address database. However, there has been no  legislative action at the time of this report.

The Bureau Generally Implemented LUCA in Accordance with Its Plan, but Some Decisions Increased Fieldwork

The Bureau Met Nearly All Milestones, Conducted Outreach, and Obtained Participation According to Its Operational Plan

We found the Bureau’s implementation of LUCA 2020 largely followed its  operational plan, including key milestones, as well as outreach and  training objectives.

Milestones. Through July 2019, the Bureau had met its milestones  laid out in the LUCA 2020 Operational Plan as summarized in table 1,  with two minor changes that provided participating governments  additional time. First, in starting up the program, the Bureau was able  to mail out advance notice packages a month earlier than specified in  the 2020 Operational Plan to give potential participants additional time  to assess the resources they would need to participate before  receiving the formal invitation. Secondly, the Bureau extended the  deadline for participating governments to submit address updates  because natural disasters affected large regions of the country.

Outreach and training. The Bureau performed outreach and training  according to its LUCA 2020 Operational Plan. For example, the  Bureau provided technical training workshops for government  representatives, including training on address privacy laws.

The Bureau Implemented Its Planned Participation Options for LUCA, but the Bureau’s Participation Metric Excludes Useful Information

The Bureau implemented a streamlined participation process and  received address updates from participating governments covering 96  percent of the estimated population of the country. Based on the  Bureau’s post-2010 recommendations to improve LUCA for the 2020  Census, the Bureau did not ask participants to provide their full address  lists (an option in 2010), but invited governments to review only the  Bureau’s address list and offer updates. As shown in table 2, the Bureau  saw little change in the number of governments invited to participate,  registering to participate, and responding from the 2010 Census.

The changes in participation options prevent precise analysis of  participation beyond counting the number of governments that responded  in some fashion. Moreover, in 2000, the Bureau implemented LUCA with  two phases of data collection—one for rural addresses and one for urban,  with some governments eligible to provide address updates during both  phases. This differs from later decennials which condensed LUCA into a  single phase.

However, the Bureau’s measure for government participation excludes  important information about the degree of that participation. For instance,  only 8,389—or 21 percent of the nearly 40,000 tribal, state, and local  governments—participated in LUCA 2020. According to Bureau officials  and subject matter specialists we interviewed, address data are generally  improved when both a state and another level of government participate  in LUCA, even if the respective address updates cover some of the same  addresses. According to the Bureau, such redundancies can help  address the possibility of coverage gaps in any one government’s  address updates. Governments at the more local level can apply their  targeted, on-the-ground intelligence in cases where a state government  may lack the resources and data to cover the entire population as part of  its review of the MAF.

As figure 3 shows, the degree of local participation in LUCA varied greatly  across the country. For example, while state governments in New Mexico  and Oklahoma participated, many counties and local governments (e.g.,  towns and cities) within those states did not. Moreover, states like Texas  and South Dakota lacked any form of coverage in LUCA for many of their  counties. In contrast, large parts of the west coast and the southeast  benefitted from participation in LUCA by governments at multiple levels.

The Bureau maintains participation data on government type and shows  information similar to figure 3 on its external website. However, the  percentage of the population covered by at least one form of government  submission—identified by the Bureau as a primary performance  measure—does not identify participation in this way, nor does it  distinguish between governments representing a mix of urban and rural  geographic areas that have participated. Bureau officials told us that  state-centric participation was a focus for LUCA 2020 and that they  encouraged local governments to coordinate with state governments on  their address lists.

The purpose of the legislation that prompted LUCA was to help ensure  accuracy of the census by permitting various levels of government to  review the Bureau’s address data. We have previously reported that a  program’s measures should be consistent with the program’s initial (or  updated) statutory mission. The Census Address List Improvement Act  of 1994 called for the Bureau to solicit input on the address list from tribal  and local governments as well as state governments. The Bureau may  be able to find opportunities to obtain more complete coverage by  tracking metrics related to the types of governments participating in LUCA  and the degree to which tribal, state, and local governments are  complementing each other’s address updates. In doing so, the Bureau  could ensure that the LUCA program is contributing to accurate  enumeration. Tracking these metrics would also give the Bureau valuable  feedback on the success of its nationwide outreach and could increase  the accuracy of the MAF.

The Bureau’s Design and Implementation of LUCA Address Validation Led to Additional Fieldwork

Fieldwork in other 2020 Census operations increased as a result of (1)  LUCA’s original operational design, and (2) subsequent implementation  decisions the Bureau made in response to receiving a larger number of  address updates than it expected from participants. By design, the  Bureau had planned not to review suggested changes occurring in  geographic areas previously determined to be high growth, since the  Bureau had already planned to canvass such areas for addresses door- to-door later. When the Bureau received more than two million more  address updates than it had expected, it decided to review a sample of  updates in areas not slated automatically for in-field review, passing even more work directly on to Non-Response Follow-Up (NRFU) at a potential  cost of more than $25 million (in constant 2020 dollars).

The Bureau received 11 million address updates proposed by  participating governments, but about 5.1 million of these did not match  addresses in the MAF— approximately two million more than expected.  Bureau officials had not formalized any specific estimates but initially  expected that participants would propose about 5 million address updates  to the MAF, of which about 2.8 million would not match to the MAF and  would need to be reviewed. As figure 4 shows, 2.5 million of the 5.1  million new address updates that LUCA participants submitted were in  high-growth areas and passed directly on to in-field address canvassing.  While the Bureau’s reengineered approach to address canvassing for  2020 substantially reduced fieldwork, this pass-through of additional  workload represents a missed opportunity for the Bureau to further  reduce costs for in-field address canvassing. With a planned cost of $185  million (in fiscal year 2019 costs) for 2020, in-field address canvassing is  one of the most expensive census operations, according to the Bureau’s  July 2019 lifecycle cost estimate.

Another decision also led to increased workload. The Bureau streamlined  its address validation process in response to the higher-than-anticipated  number of address updates received. To manage this workload, the  Bureau reviewed only a sample of address updates suggested by  governments with 200 or more addresses otherwise eligible for review  (861,000 total updates out of 2.5 million) that were in areas not already  flagged for in-field address canvassing.

As a result, the Bureau added more than 1.6 million address updates to  the MAF without review as shown above, even though they were eligible  for in-office address canvassing. The Bureau will attempt to enumerate  households during the census through self-response methods, such as  online or paper questionnaires. If the Bureau does not initially receive  responses, these addresses will become part of the NRFU workload. Had  these addresses been canvassed in office, it is likely that many of them  would have been rejected, based on the rejection rate for other  addresses. Specifically, the Bureau rejected 39 percent (334,000 out of  861,000) of the address updates it reviewed in its sample.

If a similar rate of rejection were to have occurred in both groups, roughly  624,000 additional address updates would have been rejected instead of  being included in the enumeration universe with possible unnecessary  NRFU follow up. Assuming the same average cost of NRFU per case as  in 2010, these additional cases receiving census questionnaires could  result in an unnecessary $25 million in costs (in constant 2020 dollars).

Standards for Internal Control in the Federal Government indicates that  agencies should use quality information to achieve their objectives. The  Bureau’s decisions to limit the reviews conducted on submitted LUCA  updates mean that the Bureau will have some addresses in the MAF for  address canvassing and NRFU of unknown quality that will result in  potentially unnecessary fieldwork. Creating the conditions whereby the  Bureau can expand the scope of in-office review of tribal, state, and local  additions to the MAF will better position the Bureau to reduce its fieldwork  and related costs.

The Bureau and OMB Expect to Receive Fewer Appealed Addresses, but Opportunities May Exist to Assess Outcomes of the Appeals Process

The Census Address List Improvement Act of 1994 required that OMB  establish a process to adjudicate differences between the Bureau and  LUCA participants over proposed address updates to the MAF. The  Bureau and the LUCA appeals office that OMB established will conduct  the feedback and appeals phases of LUCA, respectively, from July 2019  through January 2020. Feedback to participants began in July 2019, and  the subsequent appeals process is expected to run through January  2020.

The Bureau and OMB expect fewer LUCA appeals for 2020 than in 2010  due in part to the Bureau’s decision to review only a portion of submitted  address updates and provisionally accept the rest. In 2010, participants  could appeal 13.3 million addresses, while according to the Bureau only  about 1.7 million addresses will be eligible in 2020. According to OMB, as  of mid-October 2019, the LUCA appeals office had begun processing files  containing appealed addresses from 1,122 participants. Officials indicated  the appeals office will not determine the total number and dispositions of  addresses processed until after the end of the operation. As in 2010,  OMB is giving participants 45 calendar days to appeal the Bureau’s  individual address reviews.

Since 2000, the LUCA appeals process has resulted in approval of more  than 90 percent of LUCA appeals that participating governments have  submitted, including more than 1.6 million appealed addresses (91  percent) in 2010. OMB officials noted that the practice for the appeals  process is to side with the participants if the weight of evidence on either  side of an appealed address is equal, which may account for the high  percentage of approved appeals. OMB is replicating this practice for  2020, according to the final regulation establishing the LUCA appeals  process in July 2019. Yet the Bureau’s post-2010 evaluation showed  that, among all forms of late additions to the MAF, addresses that were  reinstated to the MAF because of a LUCA appeal were the least likely to  be found valid as either residential or commercial addresses. Ultimately,  the Bureau enumerated individuals at 55 percent of such addresses for  the 2010 Census (compared to 83 percent of addresses added late to the  MAF through other operations). The 2010 LUCA appeals process  resulted in the Bureau contacting and enumerating over 700,000  households that otherwise would be less likely to be enumerated, yet the  high rate of erroneous addresses added to the MAF through appeals  reinstatement will be an additional source of NRFU workload, making that  operation more costly than necessary.

Given that LUCA is one of several operations used to build the MAF, it is  important for the Bureau to assess and determine how the high rate of  LUCA address updates that are reinstated through the appeals process  affect other operations and, thus, LUCA’s cost-effectiveness. Standards  for Internal Control in the Federal Government states that management  should use quality information to achieve the entity’s objectives. In its  post-2010 evaluation, the Bureau acknowledged that it needed to  research the reason for this seemingly low enumeration rate and to form  a plan to resolve the cause. However, it has yet to do so. Evaluating the  enumeration outcomes of appealed addresses and identifying factors that  led to these results could help to reduce the cost of unnecessary  enumeration attempts, as well as costs associated with the administration  of the appeals process.

The Bureau Lacks Data on Costs of Related Address List Development Efforts to Compare LUCA’s Cost- Effectiveness

The Bureau provided us with estimates for what LUCA would cost for the  2020 Census, but it was unable to provide sums for other address- building operations. The Bureau estimates that LUCA 2020 operations  will cost $29.6 million. Among other expenses, this includes certain  information technology costs, printed materials for outreach, and salaries  for Bureau staff and contractors throughout the decade.

Beyond the LUCA operation, the Bureau has several other initiatives that  provide information for the MAF, such as the USPS’s Delivery Sequence  File and the GSS Program. According to Bureau cost documentation,  these operations are funded through the Bureau’s Geographic Support Program at a level of $59 million annually since 2016. However, the  Bureau does not isolate the costs of operations within the Geographic  Support Program that may provide information on the relative cost- effectiveness of LUCA and related operations in updating the MAF.  Bureau officials and stakeholders that we spoke with have cited the GSS  initiative—which processes tribal, state, and local modifications to the  MAF throughout the decade—as an alternative design for LUCA. Officials  told us that costs for GSS are not tracked separately from other initiatives  that update the MAF and the Bureau’s geocoding database.

Standards for Internal Control in the Federal Government states that  agencies should establish and operate monitoring activities, such as  tracking program costs. Additionally, GAO’s 21st Century Challenges:  Reexamining the Base of the Federal Government indicates that, to meet  current and future challenges, it is important to evaluate whether  programs are using the most cost-effective or net-beneficial approaches  when compared to other tools and operation designs. Since the Bureau  does not isolate costs specific to various design components it uses to  build and update its address list, it is not possible to evaluate the relative  cost-effectiveness of LUCA’s current design in the context of other  address-list building the Bureau has undertaken for the 2020 Census.  Identifying and tracking these costs would help the Bureau to determine  the cost-effectiveness of its address-building activities and identify  improvements.

Opportunities Exist to Reexamine LUCA’s Role in the Decennial

Observations from LUCA 2020 Identify Challenges for Future Implementation to Address

While the Bureau largely implemented its approach for LUCA 2020 as  planned, the Bureau missed several opportunities to maximize the  benefits of LUCA toward improving the quality and reducing the cost of  the census. Specifically, increased fieldwork, time for participants to  review their address lists, and use of data on hard-to-count populations all  emerged as challenges for the Bureau to address in any future  implementation of LUCA or a similar program.

Data from LUCA reviews could have helped administrative records  modeling. In 2020, the Bureau is planning to use administrative records  to reduce the amount of follow-up it does seeking responses from vacant  or nonexistent addresses. Bureau officials noted that the Bureau learns  information from its review of the quality of LUCA updates that could  benefit its modeling with administrative records, perhaps resulting in more  cases where administrative records are deemed good enough to reduce  NRFU further.

Standards for Internal Control in the Federal Government states that  agencies should use quality information to achieve their objectives, in part  by obtaining relevant data from reliable sources. The Bureau did not,  however, plan to use information about addresses gathered during  LUCA—such as during its reviews of address updates during LUCA  validation—to help with its use of administrative records for the 2020  Census, nor determine how best, and when, to transfer data between the  respective Bureau teams to make this happen. However, having  information on the likelihood of addresses existing can help the Bureau  tailor its strategy for following up with addresses that do not produce  census responses. In addition, incorporating information learned about  addresses added through the appeals process may also improve the  results of the Bureau’s modeling with administrative records, which could  in turn reduce workload during NRFU.

Time constraints continue to limit participation. Officials of multiple  participating governments and other subject matter specialists told us that  the constrained timing of LUCA continues to be a barrier for governments  to fully participate. For 2020 and in prior iterations of LUCA, insufficient  time was one of the leading factors behind governments’ decisions not to  participate. Our prior work on re-examining the base of the federal  government highlights the importance of ensuring that a program is  meeting its original purpose. Since its inception, LUCA has been  intended to ensure that tribal, state, and local governments have the  opportunity to review the Bureau’s decennial address list. In the 2010  Census, the Bureau increased the length of time governments had for  reviewing the MAF from 90 days to 120 days, and kept this length for  2020. Yet, if governments lack the resources needed to review address  lists, and if governments run out of time, they either may not participate,  or their address updates may not reflect a comprehensive review of the  MAF for their jurisdictions.

Bureau officials agreed that more time for governments to participate  would be better. Facilitating increased participation, along with expanding  the scope of in-office reviews of LUCA submissions, however, may  require the Bureau to realign its schedule for other phases of tribal, state,  and local outreach. Figure 5 shows one potential opportunity for the  Bureau to do this. The Bureau scheduled a 5-month gap between the end  of its in-office address canvassing (and thus LUCA address validation)  and the beginning of in-field address canvassing. Bureau officials said  this period is needed to determine the right number of listers to hire and  train, as well as to prepare official address materials needed for later  operations. However, the 2020 schedule gave participants less time to  submit updates than they could have had if the Bureau’s address  validation phase had taken place later.

Moreover, as previously noted, participants had from July 2017 to  February 2018 to register for LUCA; officials noted that it could be  possible to provide the review materials on a rolling basis so that  participants who registered early could have more time to review their  address lists. Finding opportunities like this to give participants more time  for their review could improve the Bureau’s coverage.

The Bureau did not use its data on hard-to-count areas to help guide  LUCA. During LUCA 2020, the Bureau missed an opportunity to target  efforts in order to improve address listing in areas considered by the  Bureau to be hard-to-count. We have previously reported on the  importance of targeting a program’s benefits to those with the greatest  needs and the least capacity to meet those needs. The Bureau  maintains publicly available data at the census tract level on the extent to  which a geographic tract (roughly the population size of an urban  neighborhood) is considered hard-to-count. Bureau officials told us,  however, that they had not previously considered reviewing these data regularly when monitoring LUCA participation or prioritizing in-office  review workloads. When an address is missing, the people at that  address are more likely to be missed by the census.

Bureau officials managing LUCA told us that using the Bureau’s data on  hard-to-count areas could have given them insights into whether they  were receiving LUCA participation for areas most in need of  improvements in census coverage and whether they needed to better  target their LUCA outreach. Moreover, Bureau officials told us that they  would prefer to have more opportunity to provide feedback to participants  regarding their submitted updates and their address lists. Given the time  constraints discussed elsewhere in this report, data showing which  participants are in hard-to-count areas could help the Bureau prioritize  governments with which to invest time giving feedback. According to  Bureau officials, this information could also help the Bureau prioritize its  resources in other address list-building efforts, such as which areas the  Bureau should conduct additional rounds of in-office address canvassing  to ensure that recent address updates are not missed.

The Bureau Faces Additional Issues When Reexamining the Role of LUCA for the 2030 Census

Conditions surrounding LUCA have changed since LUCA was first  implemented in the 2000 Census. For example, the dissemination of  publicly available address data has increased, and the Bureau has  developed other mechanisms for governments to provide input to its  address list. However, LUCA’s designed role in the census has not  fundamentally changed or been reexamined since its authorizing  legislation. Moreover, the Bureau will soon begin its process for planning  geographic programs for 2030. This presents an opportunity to reexamine  LUCA’s contributions to building a complete and accurate address list.

In 2005, we identified criteria for reexamining federal programs in order to  address fiscal instability while updating federal programs and priorities to  meet current and future challenges. These criteria are based on a need  to inform Congress of our insights in order to help its budget and  programmatic deliberations and oversight activities. These criteria include  whether the program is using the most cost-effective approach when  compared to other tools and program designs; whether a program is  targeted to those with the greatest need; and what would be the likely  consequences of eliminating an operation.

Our review of Bureau documents and evaluations—along with interviews  of Bureau officials, subject matter specialists, and state-level LUCA  participant stakeholders—identified several issues for the Bureau to  resolve with stakeholders, Congress, and other federal agencies as part  of the planning process for the 2030 Census:

Assessing whether LUCA should continue to have a role in  building the address list. The first issue for the Bureau, Congress,  and other stakeholders to resolve is whether LUCA should continue to  be a vehicle for tribal, state, and local additions to the MAF. The  Bureau receives intergovernmental inputs into the MAF through  multiple sources, such as GSS and surveys of local governments to  determine jurisdictional boundaries. The Bureau’s decisions on the  scope of LUCA address validation for 2020 also mean that the effects  of LUCA on address list quality are unclear. Yet, a committee of state- level stakeholders and subject matter specialists emphasized the  value of having a forum for governments to review the Bureau’s  address list—a feature that is currently unique to LUCA. By registering  for LUCA under the authority of Title 13 nondisclosure requirements,  governments can also receive feedback from the Bureau on their  individual address updates, which the chair of a nationwide group of  state-level population data officials told us was valuable. Moreover,  stakeholders told us that having a program like LUCA late in the  decennial cycle may help promote awareness of the census at the  state and local level.

Determining how frequently to have governments review the  MAF. The method and frequency with which governments can review  the MAF is another issue for the Bureau to resolve. A committee of  state-level stakeholders and subject matter specialists told us that  having more opportunities for tribal, state, and local review of the MAF  during the decade would increase participation and thus quality of the  MAF by relaxing the time constraints that have historically deterred  participation in LUCA. Bureau officials also told us that a continuous  program would provide more opportunities for governments to refine  their address lists based on feedback from the Bureau. However,  increasing the frequency of address updates, reviews, and appeals  during the decade would increase program administration costs, and  such a program’s design would need to account for the fact that  smaller governments and LUCA nonparticipants already cite the lack  of human and financial resources as a barrier to participation.

Considering whether to make it easier for governments to access  and share address data. Given the prevalence of modern address  sources and services, the question of how closely to protect data on  census addresses is another issue for the Bureau to resolve in  conjunction with Congress and stakeholders. We have previously  recommended that Congress consider revising Title 13 nondisclosure  protections for address data.

Bureau officials and subject matter specialists we interviewed said if  federal agencies and tribal, state, and local governments could more  easily share address lists, there could be benefits to address list  quality. Bureau officials have also described scenarios in which it may  be possible to enact targeted modifications to Title 13 so that only  address data are affected. However, subject matter specialists we  interviewed also noted that Title 13 protections can give reassurances  to local residents and facilitate participation in building local address  lists. Allowing widespread disclosure and use of the Bureau’s address  list could also raise questions about which address lists are  considered authoritative.

Determining the role that a National Address Database should  play in contributing to the Bureau’s address list. Deciding whether  or how to leverage an existing publicly accessible address list as part  of the Bureau’s decennial efforts is another issue to resolve. We have  previously recommended that agencies responsible for interagency  address and geospatial policy take actions to facilitate collection of  national geospatial address data. First piloted in 2015 and now  managed by the U.S. Department of Transportation (DOT), the  National Address Database (NAD) provides publicly available address  and geographic coordinates to government and non-government  users. State-level stakeholders and DOT officials said a centralized,  open-source form of address data would benefit public services, such  as emergency response. Going forward, however, it will be important  to address resource constraints that limit the NAD’s reach. DOT’s lead  official for the NAD said that there are two permanent staff who  oversee nationwide outreach and data collection, and at the time of  this report, the NAD only has data from partners in 23 states.

These issues have been prompted by developments that have taken  place this decennial cycle, such as the development of the NAD and the  advent of additional inputs into the MAF such as GSS; therefore, the  Bureau has not yet had an opportunity to evaluate them in its decennial  planning. Standards for Internal Control in the Federal Government  underscores the need to identify, analyze, and respond to significant  changes, as well as use quality information and communicate externally  with stakeholders. With strategic planning for 2030 geographic  programs in mind, the Bureau has an opportunity to engage with  stakeholders, other federal agencies as appropriate, and Congress to  resolve these issues and evaluate how various alternatives could impact  the cost, quality, and public perception of the census.

The above issues do not exist in isolation, however, and need to be  resolved jointly. For instance, decisions to make address data more  accessible would increase inter-agency data sharing and thus incentives  for governments to participate in open-source address initiatives like the  NAD. Decisions on whether to continue LUCA in its current form will  affect the tools, such as GSS, available to tribal, state, and local  governments to provide updates to the MAF. As the Bureau engages with  affected partners on these issues, it will be important to consider various  scenarios that could flow from resolving these issues in concert with each  other.

The Bureau’s implementation of LUCA for 2020 is on track in terms of  milestones thus far, and the process for governments to appeal rejected  LUCA address updates is ongoing and will continue through January  2020. The Bureau also implemented planned changes to participation  options for governments and tracked participation by government.  However, the Bureau’s primary metric for representing the coverage of the nation by the LUCA operation does not leverage other information the  Bureau already has on the degree of useful overlap in coverage across  different levels of participating governments. Identifying and reporting  metrics on the extent to which governments participating in LUCA overlap  in their coverage of residents, as well as the characteristics of participants  such as type of government and the nature of their geographic area,  could provide more complete and useful feedback on the success of  LUCA and assurance of getting desired coverage while avoiding gaps.

We also found that opportunities exist for the Bureau to further reduce  fieldwork and make its address list-building efforts more cost effective. In  the future, the Bureau could more fully use its in-office address validation  process for LUCA to reduce costs and improve decennial accuracy.  Further, identifying the factors that lead to enumeration outcomes of the  LUCA appeals process may also produce lessons learned that could help  lower the amount of fieldwork and thus costs. Moreover, maintaining  more detailed cost data for the Bureau’s other related address list  development efforts will help position the Bureau to evaluate the relative  cost-effectiveness of LUCA in building the address list. Likewise, the  Bureau could also leverage the results of its in-office review of LUCA  updates, as well as its evaluation of the appeals process, to inform its  administrative records modeling and potentially reduce the number of  required in-field NRFU visits.

The Bureau can similarly take additional steps through programs like  LUCA to promote greater coverage in the census. By realigning the  schedule of LUCA where appropriate, the Bureau could give tribal, state,  and local governments more time to review the address list in their areas  and thus more time to provide quality updates to the Bureau. Moreover,  using data on participation in LUCA and related programs, in concert with  existing data on hard-to-count areas, would help the Bureau target its  resources for building the address list and conducting decennial outreach  to those areas most in need.

We have also identified fundamental issues related to the Bureau’s  address list activity that will require a forward-looking, stakeholder- inclusive approach for the Bureau to resolve. Re-examining LUCA and  the related issues will not be easy, and could take time. The Bureau is  uniquely positioned to lead the identification and assessment of what the  alternatives are, and particularly how they might affect the cost and  quality of the decennial census. Reporting out on the alternatives and  their justifications, and developing legislative proposals, as may be  appropriate, will help the Bureau, Congress, and the users of census data  benefit from cost and quality improvements in decennials to come.

We are making the following eight recommendations to the Department of  Commerce and the Census Bureau:  The Secretary of Commerce should ensure that the Director of the  Census Bureau identifies metrics on the extent to which governments  participating in LUCA overlap in their coverage of residents, as well as the  characteristics of participants such as type of government and geographic  area, and reports on such metrics. (Recommendation 1)

The Secretary of Commerce should ensure that the Director of the  Census Bureau takes steps to conduct in-office reviews of a greater  share of addresses submitted by governments before the addresses are  added to the Bureau’s address list for potential field work.  (Recommendation 2)

The Secretary of Commerce should ensure that the Director of the  Census Bureau, as part of the Bureau’s assessment of LUCA for 2020,  consults with OMB to report on the factors that led to enumeration  outcomes of addresses reinstated to the Bureau’s master address list by  the LUCA appeals process. (Recommendation 3)

The Secretary of Commerce should ensure that the Director of the  Census Bureau identifies and tracks specific costs for related address list  development efforts. (Recommendation 4)

The Secretary of Commerce should ensure that the Director of the  Census Bureau improves the use of LUCA results to inform procedures of  other decennial operations, such as sharing information on address  update quality to inform NRFU planning or administrative records  modeling. (Recommendation 5)

The Secretary of Commerce should ensure that the Director of the  Census Bureau realigns the schedule of LUCA-related programs to  provide participants with more time to review addresses.  (Recommendation 6)

The Secretary of Commerce should ensure that the Director of the  Census Bureau uses the Bureau’s data on hard-to-count areas to inform  geographic activities such as: targeting LUCA outreach to tribal, state,  and local governments; planning additional rounds of in-office address  canvassing; and providing feedback to tribal, state, and local  governments on gaps in their respective address data. (Recommendation  7)

The Secretary of Commerce should ensure that the Director of the  Census Bureau, as part of the Bureau’s strategic planning process for  geographic programs, reexamines LUCA in conjunction with  stakeholders, other federal agencies as appropriate, and Congress to  address the issues we have identified, including but not limited to:  Identifying and assessing alternatives and describing corresponding  effects on the decennial census.

Reporting out on the assessment of alternatives, including  justifications.

Developing legislative proposals, as appropriate, for any changes  needed to LUCA and address data in order to implement preferred  alternatives. (Recommendation 8)

We provided a draft of this report to the Secretary of Commerce, the  Acting Director of the Office of Management and Budget, and the  Secretary of Transportation. In its written comments, reproduced in  appendix I, the Department of Commerce agreed with our findings and  recommendations and said it would develop an action plan to address  them. The Department’s response also describes several claims of cost  savings and efficiency gains attributable to various address list-building  activities. While we have previously reported on the Census Bureau’s  2020 address list-building efforts, we have not audited claims made in the  Department’s response or elsewhere regarding potential cost savings  from innovations for the 2020 Census.

The Census Bureau, Office of Management and Budget, and U.S.  Department of Transportation each also provided us with technical  comments, which we incorporated as appropriate.

We are sending copies of this report to the Secretary of Commerce, the  Undersecretary of Economic Affairs, the Director of the U.S. Census  Bureau, the Acting Director of the Office of Management and Budget, the  Secretary of Transportation, and the appropriate congressional  committees. In addition, the report is available at no charge on the GAO  website at http://www.gao.gov.

If you or your staff have any questions about this report please contact  me at (202) 512-2757 or goldenkoffr@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix II.

Appendix I: Comments from the Department of Commerce

In addition to the contact named above, Ty Mitchell (Assistant Director),  Devin Braun, Charles Culverwell, Rob Gebhart, Allison Gunn, Lisa  Pearson, Kayla Robinson, Robert Robinson, Cynthia Saunders, and  Peter Verchinski made significant contributions to this report.

The Census Bureau needs an accurate address list to count everyone once, only once, and in the right place. To that end, the Bureau allows tribal, state, and local governments to review and offer updates to its master address list.

The Bureau received 5.1 million updates—more than it expected. As a result, it only reviewed a fraction of them in the office. This means that Census workers will have to visit more addresses in person—which could mean millions of dollars of additional fieldwork.

For the future 2030 Census, we recommended reviewing more of these updates in the office.