On September 10, the U.S. Census Bureau of the Department of Commerce published a proposed rule related to the 2030 Decennial Census. Changes would include defining “usual residence” to exclude immigrants who are not U.S. citizens or lawful permanent residents, and prohibiting the inclusion of questions about race, ethnicity, and sexual orientation.
Here is our public comment, which we have submitted via the Federal Register:
To the Census Bureau of the US Department of Commerce
RE: 15 CFR Parts 60 and 70 [Docket No. 260903-0005] RIN 0607-AA75
At the Health Foundation for Western & Central New York, we are deeply troubled by the significant changes that the Census Bureau has proposed for the 2030 Census. We believe that these changes, if implemented, will jeopardize the ability to understand and potentially alleviate health disparities based on race, ethnicity, age, socioeconomics, and other demographic factors. Put simply, to solve a health-related problem, you must first identify where it exists.
At the Health Foundation, we work to improve the health and well-being of everyone who lives in the 16 NYS counties that we serve. Along with our community partners, we rely on the US Census to understand how many people live in a community, whether the population is growing or shrinking, and how the community might be changing. Census data help guide decisions about crucial public health infrastructure, including hospitals and clinics.
Tracking health disparities
Medical and public policy researchers use a variety of data to compare health outcomes across demographic groups and identify disparities in disease, disability, and premature death. They routinely link data from the US Census Bureau, including income, education, housing characteristics, and neighborhood-level information, with birth records, death records, hospital records, and other health datasets to study how social and economic conditions affect health. These linked datasets help illuminate how community conditions may contribute to health outcomes, such as infant mortality, chronic disease, and life expectancy. When certain populations consistently experience poor outcomes, the data can help researchers understand the factors that may be driving those trends.
Consider Black maternal and infant mortality, which remains a nationwide health crisis. Black women are about three times more likely than White women to die from pregnancy-related causes, even when factors such as income and education are taken into consideration. Erie County, one of the 16 counties we serve, has the largest population in western New York. It mirrors the national statistics for Black maternal and infant mortality. In fact, Black infants in Erie County die at an alarming rate: 13.2 deaths per 1,000 live births, compared with the national rate of 5.5. These statistics bolster the case for targeted interventions and continued investment in resources. (This webpage from the US Department of Health and Human Services highlights similar data from 2024: Infant Mortality and Black/African Americans | Office of Minority Health)
Addressing the needs of an entire community
Access to reliable demographic data enables foundations, government agencies, and community organizations to direct resources to areas with the greatest need. The 2020 Census revealed a high number of residents living below the poverty line in Erie County. When broken down according to racial or ethnic groups, the data revealed some clear disparities. Over the past several years, these data insights have enabled government agencies, community-based organizations, and funders to identify where the greatest needs may be and to direct resources appropriately.
A complete census is also essential for local governments to comply with federal legislation and regulations. For example, Area Agencies on Aging, authorized under the Older Americans Act, must meet service provision requirements based on population characteristics and regularly report data on who is receiving OAA-funded services. States and counties depend on accurate population data to allocate funding and plan services. Undercounting communities could result in fewer resources for older residents, a group with complex needs.
As another example, undercounting could lead to decreased federal funding for Medicaid. This is because the federal government’s share of Medicaid expenses factors in a state’s per capita income. Excluding noncitizens from the population count inflates the state’s per capita income, making the state seem richer than it really is.
Making sure everyone counts—and is counted
The Fourteenth Amendment of the US Constitution calls for counting the entire number of residents in the country. This means that if you’re a resident but not a citizen, you should still be counted for a complete profile of your community. Without accurate demographic information, policymakers, legislators, researchers, health care and other service providers, and philanthropic organizations will be less equipped to fully understand and address community needs.
If a community is undercounted in the census, it would lose not only its fair share of federal funding for key programs, but also its appropriate political representation over the next decade.
For all these reasons, we oppose the proposed changes. We respectfully urge the US Census Bureau to abandon them to help ensure that the 2030 Census is conducted fairly and accurately in accordance with Constitutional principles and established norms. Strong and healthy communities are built on an accurate understanding of every human being who lives there.
Thank you for the opportunity to share our perspective.
The Health Foundation for Western & Central New York
You can submit your own public comment at Regulations.gov. Deadline to submit: Monday, November 2, 2026.
