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Amputee Coalition’s Public Comment on the ACS and Puerto Rico Community Survey Questionnaire Change

Dec 21, 2023 |

In response to the proposed changes assessing disability status, the Amputee Coalition submitted a comment letter to the U.S. Census Bureau requesting the agency reconsider transitioning from the American Community Survey (ACS) to the Washington Group Short Set (WGSS) of questions. The Coalition disagrees with the proposed switch because of the anticipated negative impacts that the limb loss and limb difference community will experience.  

 In the letter, the Coalition outlines their concerns beginning with the WGSS measurement gauge which does not consider fluctuating mobility levels. Currently on the ACS, people are asked to respond with “yes” or “no”, but the WGSS will require participants to select their difficulty level from four options. Only those indicating “a lot of difficulty” or “cannot do at all” for one or more questions are categorized as disabled. The Coalition states that the ongoing variations in functionalities for individuals with limb loss and limb difference pose genuine challenges for accurate assessment. This categorization will exclude individuals and has the potential to undercount an already marginalized and underserved population. 

 Another concern is the oversight of distinguishing between durable medical equipment (DME) usage and non-usage, forcing individuals to answer questions without clarification. Because of this, the Amputee Coalition recommends that the ACS explicitly inquire about both the usage and non-usage of DME to include those who rely on these devices. 

 Finally, the letter makes the point that vital disability stakeholders were excluded from the process of modifying ACS questions. The Amputee Coalition strongly recommends that the Census Bureau temporarily suspend its ongoing efforts to reform ACS questions and take a proactive approach that involves actively seeking input from a diverse range of researchers and individuals with disabilities. 

 The letter concludes by advocating for collaborative and transparent dialogue to ensure the voices of the disability community are heard. In this way the resulting changes will be both accurate and considerate of the unique needs and perspectives of the community. 

 View the full letter here. Visit our Advocacy Letters to Policymakers webpage to view other letters the Amputee Coalition has endorsed. If you haven’t already, we invite you to join our active Advocacy community on AC Connect!