Starting with the 2010-2011 school year, the U.S. Department of Education (DOE) and the Illinois State Board of Education (ISBE) require that school districts begin collecting racial and ethnicity data using the new federal data collection and reporting standards. The new standards require school districts to use a two-part question to re-identify race and ethnicity for all students and staff, focusing first on ethnicity and second on race. ISBE strongly recommends that parents/guardians identify the race/ethnicity of their children, as opposed to students making this identification. If parents/guardians do not complete the two-part question, school staff members must designate the race/ethnicity for the student, using “observer-identification.” To assist school districts as they prepare to collect this information next fall, we have addressed the following frequently asked questions regarding these new standards.

1. What does the new “two-part” question consist of?

School districts must first inquire about the ethnicity of the student. Specifically, districts must ask whether or not the student is Hispanic/Latino. Regardless of how they answered the ethnicity question, districts must next ask with which of the following five races the student identifies: American Indian or Alaska Native; Asian; Black or African American; Native Hawaiian or Other Pacific Islander; or White. More than one race may be selected for a student if applicable.

2. Rather than creating a separate form for parents to fill out during registration, can school districts collect this information using their current registration form?

Yes, a school district can collect this information using its current registration form, so long as a form is completed for every student. The registration form, however, will likely need to be revised to include the required two-part question for collecting race/ethnicity information on each student. The original individual responses to the two-part question must be retained by the school district for three years. Accordingly, if this information is collected on the student registration forms, the district must keep these registration forms (either by paper or electronic means) for three years.

3. How should a school district handle assigning race or ethnicity to a student?

The DOE has provided guidance with regard to how school district staff should assign a student’s race/ethnicity using observer-identification. First, the DOE advises that observer-identification should be used as a “last resort,” only after other efforts to increase the chance of having a parent/guardian identify the student have failed. Thus, if a parent has not completed the two-part question, school personnel should take steps to ensure that the parent intentionally refused to complete both parts of the question, rather than simply overlooking the question, before using observer-identification. For example, staff may review the form with the parent at registration, send a letter to the parent, or follow up with a phone call, explaining to the parent that the school district is required to select race and ethnicity categories for students on their behalf if their parents decline to answer the question. In communicating with parents, staff may assure the parent that the school district will maintain the confidentiality of the individual race and ethnicity records

If the parent/guardian still declines to answer the questions, school staff must select the student’s race/ethnicity for the student. Before relying on visual observation alone, school staff members may use existing information and records to help determine the student’s race/ethnicity. For example, staff should check the student’s prior records to determine whether a racial category was selected in the past. Staff may also check to see if a student’s siblings have identified a race/ethnicity (although staff should keep in mind that some siblings may have different races/ethnicities as a result of adoption or blended families). If sufficient existing information is lacking, staff may also look for clues from other sources. For example, the staff may consult with a teacher or counselor who has first hand knowledge about the student and his/her family. The staff may also look for clues from the student’s and parent’s country of birth or country of origin, the student’s home language or parent’s language of preference, and knowledge about the community in which the school belongs.

Because observer-identification is a difficult task, and race/ethnicity can be a sensitive subject, the DOE strongly encourages school districts to train its staff members who are acting as observers on the procedures for racial and ethnic identification.

4. Does ISBE or the DOE have further guidance on the new standards?

ISBE has prepared a sample data collection form that is separate and distinct from a school’s registration form for school districts’ use. ISBE has also prepared a sample letter to be sent home to parents to explain the reasons for the new questions on race/ethnicity, and additional guidance on implementing the new standards. The DOE has also published guidance on the new reporting and collection guidelines.