When Multiple Races Become One: What Labor Department Records Reveal About Racial Collapsing
Prepared by the Freedmen Reparations Fund Trust
What happens after someone selects more than one race on a government or employment form? Does each selection remain visible, or does the person enter a different category when the information is analyzed?
Records released by the U.S. Department of Labor’s Office of Federal Contract Compliance Programs under FOIA request 2026-F-14263 document methods for combining racial responses, reallocating multiracial responses into single-race categories, and estimating allocations when detailed information was not retained.
The Freedmen Reparations Fund Trust has prepared a public-review report examining these methods and their implications for historically verified Freedmen Successors. Our concern is whether an analysis accurately communicates what people reported—and whether combining populations obscures differences that deserve examination.
Readers can examine both sources:
The comparison between White + American Indian and Black + American Indian shows why the specific reporting method matters. “American Indian” here refers to the federal category American Indian or Alaska Native.
Under the historical OMB aggregation guidance, both combinations were listed separately. At that stage, the categories could preserve the distinction between someone selecting White and American Indian and someone selecting Black and American Indian.
When the historical single-race allocation method was used, however, those combinations followed different rules.
White + American Indian: For the specified enforcement analysis, the response was allocated to American Indian under the rule assigning White plus one minority race to the minority category.
Black + American Indian: For a discrimination complaint, allocation followed the race alleged as the basis of discrimination. For discriminatory-pattern analysis, the guidance called for alternative allocations to each minority group. It did not prescribe an automatic Black-only result.
White + Black: Under the same historical rule, this combination was allocated to Black. Single-race responses were not reallocated. (obamawhitehouse.archives.gov)
This comparison identifies a concrete difference: White + American Indian received a predetermined American Indian allocation, while Black + American Indian followed the complaint’s alleged basis or alternative allocations for pattern analysis.
FRFT therefore asks: When someone selected Black and American Indian, which analysis was performed, which allocation was used, and were both original selections retained?
A separate method appears in the Labor Department’s EEO Tabulation FAQs. This method concerns the availability analysis described for the 2014–2018 EEO Tabulation.
PDF page 29, questions 5 and 6, explains that “Balance of not Hispanic or Latino” includes non-Hispanic people reporting multiple races or Some Other Race alone. Page 32, questions 16 and 17, explains that non-Hispanic respondents identifying as Two or More Races belong in that balance category for the described analysis.
Under this method, White + American Indian and Black + American Indian enter the same balance category, assuming the respondents are non-Hispanic. Their different combinations are no longer distinguishable from that category’s total.
The FAQ instructs contractors to include the balance category when determining overall minority availability, but not to use that column when determining availability for separate race or ethnicity groups.
Consequently, both combinations can contribute to the broad minority availability total without appearing as American Indian-alone responses. Black + American Indian also does not appear as a Black-alone response in that tabulation.
A person can be counted in the larger total while the particular combination they selected becomes invisible in that output.
FRFT describes the reduction of distinct responses into fewer categories as collapsing. The resulting total may be mathematically correct while providing too little detail to evaluate the populations within it.
Our report illustrates the problem with hypothetical employment figures. Suppose a combined population has 100 applicants and 40 hires. Within that total, a verified subgroup has 20 applicants and only two hires. The combined hiring rate is 40 percent, while the subgroup’s rate is 10 percent.
Reporting only the combined rate would leave the subgroup’s different outcome undisclosed. These figures illustrate the analytical problem; they are not findings about actual Freedmen applicants. A real investigation would also examine qualifications, positions, locations, time periods, and other relevant factors.
For Freedmen Successors, an additional question remains: Where is documented successor status measured?
The reviewed passages classify race and ethnicity. They do not establish a separately verified Freedmen Successor population. A broad racial label cannot independently identify which people meet documentary descent criteria or establish how that population fares within a combined category.
This is why FRFT emphasizes status, documented family connections, and verification. Without an appropriate status measure, these tables cannot answer questions specifically about the verified population.
An output that omits someone’s full combination does not establish that the original response was deleted. The original selections may remain elsewhere. In other cases, detailed combinations may never have been collected. An audit must distinguish those situations by examining intake forms, original fields, exports, retention practices, and subsequent uses.
The historical context also matters. OMB rescinded Bulletin 00-02 through its March 2024 revisions, with an exception for data collected or reported before March 28, 2024. The release of historical guidance does not establish which methods remain in use today. (spd15revision.gov)
FRFT calls for the Department to:
Identify original selections and whether they remain recoverable.
Explain each transformation, including its purpose, authority, and period of use.
Distinguish self-reported answers from observations and statistical estimates.
Identify decisions that relied on transformed information and available correction procedures.
Examine subgroup outcomes using appropriate evidence and consistent definitions.
The Fifth Amendment discussion in FRFT’s report explains the evidence needed for a constitutional claim. Combining categories alone does not establish a violation. The inquiry must connect the challenged federal action to unequal treatment or to deprivation of a protected liberty or property interest without adequate process. The released guidance establishes mechanisms warranting examination; implementation and resulting harm require further evidence.
People should be able to distinguish what they reported from what an institution combined, inferred, or reassigned. FRFT seeks preservation of original information, transparent explanations of classification decisions, and examination of their consequences for Freedmen Successors and other affected populations.
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Your donation helps the Freedmen Reparations Fund Trust and American Freedmen Legal Fund continue documentary research, historical preservation, and advocacy concerning verified Freedmen Successors.
This investigation shows why that work matters. The public deserves to understand how institutions collect, combine, and use information about our population—and what happens when those practices obscure distinctions that deserve examination.
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