Next100 Submits Public Comment Regarding AmeriCorps Data Collection and Transparency

Next100 executive director Emma Vadehra and associate director of strategy and operations Dan Edelman submitted a public comment regarding data collection and transparency to AmeriCorps in response to a request for comment. Their comment, which you can read below, explains how improving the data collected about AmeriCorps members and increasing transparency around that data will allow AmeriCorps (the agency), state commissions, and grantees to strengthen AmeriCorps and enhance the program’s focus on equitably serving communities and members.

Re: Next100 Comment on AmeriCorps Enrollment and Exit Form (86 FR 33689)

From: Emma Vadehra ([email protected]) and Dan Edelman ([email protected]), Next100

Thank you for your request for comments, and for your efforts to utilize efficient data collection to advance equity. We believe improving the data collected about AmeriCorps members and increasing transparency around that data will allow the agency, state commissions, and grantees to strengthen AmeriCorps and enhance the program’s focus on equitably serving communities and members. 

Robust and accurate data that is collected and shared regularly can help provide valuable insight into who a program serves and how well it serves them, although collection must be undertaken without imposing an unnecessary burden on program providers and service recipients. We believe AmeriCorps’ new proposed data collection form is not overly burdensome and is necessary to ensure that AmeriCorps programs meet their mission by selecting and supporting members who reflect the United States as a whole and the specific communities AmeriCorps serves. The information collected using this proposed form will have significant practical utility by collecting information on who members are and where they come from at the national level, an effort only AmeriCorps (the agency) can take on.

This collected data will be even more useful for program improvement purposes if it is regularly released to stakeholders and the public, who cannot currently find answers to major questions about AmeriCorps members, including about their demographic characteristics at a state or local level, and whether members typically serve their own communities. To maximize its utility, the data collected through this form should be released annually, broken down by state and county, as well as by issue area (e.g., food security, public health) and placement type (e.g., which AmeriCorps program, duration of service). This information—collected at enrollment and thus from members who complete their service terms as well as those who do not—can provide significant insight into member characteristics and outcomes. This will allow for a better understanding of the work of AmeriCorps grantees, and whether AmeriCorps is recruiting and retaining members from the communities it serves, as well as how outcomes—including program completion—differ for members from different backgrounds.

In addition to calling for increased transparency of this data, we also make the following recommendations, which will leverage this data to strengthen AmeriCorps’ focus on equity:

• In Part 1, please consider adding a question that gathers information about where a member grew up to allow for a better understanding of whether members are serving in their own communities. To allow for easy use of this data and to keep the burden low for members, the question could ask members to identify up to three zip codes where they lived the longest prior to membership, as long as they lived in each location for at least two years.
• For Part 3, Question 3, we recommend that you (1) list “Asian” instead of “Asian American,” which is not a racial origin; and (2) add “Middle Eastern or North African” or a similar category for the same question, as roughly three million people in that group live in the United States and President Biden supported adding such a category to the Census during his campaign.
• For Part 3, Question 7, we support the additional question about a parent’s education level, but are concerned that the proposed phrasing may feel confusing. We would propose instead that you ask members to identify the highest education level completed by any parent.
• For Part 3, Question 8, we strongly support the additional effort to gather information about members’ family socioeconomic status, as we believe this is critical to a better understanding of who joins AmeriCorps. However, we are concerned that young people may have a hard time getting this information accurately. While also imperfect, we suggest that the form could ask applicants about their Pell eligibility or eligibility for other benefits (e.g., free or reduced price lunch, SNAP, public housing) while growing up.
• We have three suggestions focused on clarification:
  • Clarify the explanatory text for Part 1, Question 4 such that the exact requirements for service eligibility are written in plain language.
  • For Part 1, Question 5, we suggest that you change “If you have some college” to “If you have some college but have not yet received a degree” or similar, to make it clearer how this response differs from the subsequent responses.
  • For the Member Enrollment Certification in Part 2, where the text says “provide documentation to verify the accuracy of the information,” it may be helpful to include some examples of documents (e.g., birth certificate, Social Security card).

Thank you for your consideration.