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General Memorandum 12-122

General Memorandum 12-122
BIA Consultations on Indian Population and Labor Force Report

The Bureau of Indian Affairs (BIA) announced, via the attached October 11, 2012, FEDERAL REGISTER notice, a series of upcoming meetings with tribes regarding the preparation of a 2013 Indian Population and Labor Force Report (Report). The Reports, dating back to the late 1970s, provide tribal-specific data including size of BIA service population, size of available work force, and employment levels. Major changes are contemplated in how this data will be compiled and reported. Written comments are due November 12, 2012.

The Indian Employment, Training, and Related Services Demonstration Act PL 102-477) requires the BIA to publish, at least once every two years, an American Indian Population and Labor Force Report. The last such report was issued in 2005. The data reported is considered problematic due to its self-reported nature and lack of clear direction and standard methodologies for compiling the data. Virtually no funding or technical assistance is available to tribes to compile this data. The BIA conducted a web-based survey of tribes in order to collect population and labor force data for 2010, but then determined that the report would not be prepared because of "methodology inconsistencies." Instead, a new survey is to be designed that will meet the data quality standards set by the Office of Management and Budget.

Possible switch to use of Census Bureau data. Under consideration is the use of the Census Bureau's American Community Survey (ACS) data as the source for the Indian Population and Labor Force Report. The ACS replaced the Census Bureau's decennial "long form" questionnaire in 2010. By contrast, the ACS is an ongoing monthly survey, allowing for more frequent reporting, but collects data from fewer households. For a small population like American Indians and Alaska Natives the smaller survey increases the likelihood that the data will not be representative of the entire Indian or Alaska Native population. In response to concerns about this, the Census Bureau is increasing its sample size somewhat and has agreed to do follow-up interviews in rural areas of Alaska of those households that do not respond to the mail questionnaire. These improvements won't take full effect for another five years. Even then, the data will be reliant on a smaller number of Native household responses than under the previous "long form" questionnaire used in past decennial censuses.

Who is counted as unemployed? Of particular significance is that the ACS uses the Labor Department's definition of a person being "in the labor force" as one who is in the armed forces or is age 16 or older and who is employed or unemployed but if unemployed is actively seeking work and has taken steps to find a job within the last four weeks. The BIA report, on the other hand, counts anyone who is not employed but who is available for employment as being "in the labor force" and without a job. The BIA Report actually provides a "jobless" rate as opposed to what the Labor Department terms an "unemployment rate." The BIA's approach takes into account the labor market of many reservation areas where Indian people don't "actively seek work" because they know there simply are no jobs for which to apply. Tribes may well find that the jobless rate as presented in past BIA Reports was several times higher than the unemployment rate reported in the ACS. For instance, one tribe would have the following contrasts using the BIA versus the Labor Department definitions.

BIA Jobless Rate (2005 Report) 67.7 %
American Community Survey (5-year estimate) Unemployment Rate 21.2%

Neither the current BIA nor the ACS system will yield perfect results. However, if tribes find themselves suddenly having to utilize a totally different set of labor force figures, this will impact their planning and advocacy efforts. In addition, several federal programs take into account employment and poverty data in the distribution of funds, notably the Indian programs under the Workforce Investment Act. Also affected is the Indian Housing Block Grant program under the Native American Housing and Self-Determination Assistance Act which, in turn, affects the BIA Tribal Transportation Program.

The BIA, in the list of questions posed to tribes, notes that regardless of a long-term solution to developing a reliable source of Indian population and labor force data, that they are considering using the ACS for its 2013 report due to time constraints. This will likely be a key topic at the upcoming consultation sessions along with what adjustments might be made to the ACS data if that becomes the source for future Indian Population and Labor Force Reports.

See the attached notice about the upcoming sessions.

Informational sessions:

• October 20, 2012: 9 am – 12 Noon, AKST – Alaska Federation of Natives Conference, Anchorage, AK (teleconference access also available)
• October 24, 2012: 6 pm – 8 pm, PST – National Congress of American Indians Conference, Sacramento, CA

Leader-to-leader consultation sessions:

• October 29, 2012: 8:30 am –12:30 pm, CST – Oklahoma City, OK
• October 30, 2012: 1 pm – 4 pm, MST – Phoenix, AZ
• November 1, 2012: 8:30 am –12:30 pm, MST – Rapid City, SD
• November 9, 2012: 1 pm – 3 pm, EST– national teleconference

Please let us know if we may provide additional information or assistance with comments on the proposed changes to the American Indian Population and Labor Force Reports.

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Inquiries may be directed to:
Karen Funk (kfunk@hobbsstraus.com)

Available Documents for Download ( any referenced attachments are included in download )


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