Next100 Submits Public Comment Regarding How AmeriCorps Can Better Collect Data on Grantee and Service Recipient Diversity

Next100 executive director Emma Vadehra and associate director of strategy and operations Dan Edelman submitted a public comment regarding how AmeriCorps can better collect data to understand who works for its grantee organizations and whom those organizations serve in response to a request for comment. Their full comment is below.

Re: Next100 Comment on AmeriCorps Diversity Questionnaire (86 FR 47301)

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 and inclusive data collection to advance equity. We believe improving the data collected about AmeriCorps’ current and potential grantee organizations 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 corps 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. At the same time, collection must be undertaken in a way that minimizes burden on program providers and service recipients. 

Overall, we believe AmeriCorps’ new proposed data collection form will be helpful in understanding the programs and communities served by AmeriCorps. This data is necessary to ensure that AmeriCorps programs meet their mission by selecting and supporting organizations whose leaders and staffs reflect the United States as a whole and the specific communities AmeriCorps serves; and are actually serving communities in need of support. The information collected using this proposed form will have significant practical utility by collecting information on who organizations’ staff and leaders are, an effort only AmeriCorps (the agency) can take on. We also believe accurate data collection on communities served is important to gather, although we have some questions (detailed below) about whether all organizations will be able to collect all this data while remaining a welcoming environment.

The proposed form suggests that the data will be released to government entities upon request. We recommend that the data, aggregated as needed to protect program and individual privacy, also be released to the public on a regular basis. This will ensure the data is useful for program improvement purposes, to allow stakeholders and the public to understand AmeriCorps grantee organizations’ leaders and staffs, as well as who they serve, including about demographic characteristics at a state or local level. 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). This information will allow for a better understanding of the work of AmeriCorps grantees, and whether AmeriCorps is recruiting and retaining organizations with staffs and leaders who reflect the communities they serve.

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:

• We recommend that the data collected on the total number of people served and people in poverty be pulled out so it is collected independently, not totalled from racial/ethnic identification or other data. This will ensure that data on poverty status is collected consistently, even where organizations may be unable to collect complete racial and ethnic data.
• We recommend that you add “Middle Eastern or North African” or a similar category, as roughly three million people (https://lat.ms/3iOAhsW) in that group live in the United States. President Biden supported (https://bit.ly/3x8tDTc) adding such a category to the Census during his campaign.
• We recommend that you provide some more guidance for applicants on how to collect certain participant data. Overall, while this data collection is important, we believe you should give grantees flexibility where they determine they are not able to gather the data.
  • For “People in Poverty in the Communities Proposed to be Served (can be estimates)” in column F, we recommend that you direct applicants to reliable sources of information and provide guidance on how recent the data needs to be. For example, can they use the most recent Decennial Census data? If so, can you include a link to an easy-to-navigate webpage where they can find the information for their local geographic area?
  • For “LGBTQIA+, Disability Community, Veteran/Military/Family Member” identity, provide guidance on how (or if) estimates should be made if an organization does not primarily serve, say, LGBTQIA+ people or veterans. For organizations that lack experience working primarily with LGBTQIA+ people or people with disabilities, in particular, collection of this data may be difficult to execute while maintaining a welcoming environment.

Thank you for your consideration.