Another Comment on the Proposed 2030 Census Rule: How Free and Charitable Clinics Could Be Affected
Updated: Oct 29
In a previous post, I explained my concerns about the US Census Bureau's proposal to stop collecting race and ethnicity data in 2030 and beyond. I provided a link to the comment I made objecting to this in the Federal Register. I submitted a second, separate Federal Register comment today about another aspect of the Census methodology that would likely undercount the populations Free and Charitable Clinics and Charitable Pharmacies serve. This methodology is so concerning for Free and Charitable Clinics that it needed its own argument.
What the rule proposes
The proposed Census rule would redefine a person’s “usual residence” as the place where they lawfully spent the greatest number of days from January 3 through April 1. It also states that a person’s usual residence should be consistent with, and evidenced by, their tax records, such as tax returns and W-2 forms. In practice, an address that does not match a tax record could mean a person is not counted where they live or not counted at all. This concerns me greatly, as would make it harder for our patients to be accurately counted and contribute to significant undercounting of our geographic populations.
Why the “usual residence” definition doesn’t work for Free & Charitable Clinic populations
The people our clinics serve are the people least likely to have a clean trail of government paperwork. While some patients may have a tax record from the previous year, housing instability is common in our population and maintaining a single residence for more than year is often difficult. Some patients reside in homes where they may not be officially on the lease. Patients who work in cash-based jobs, seasonal workers, and others who are not long-term residents of our communities may miss being counted in the Census due to their inability to provide corresponding documentation that meets the narrowed federal requirements. Tax records do not always reflect where someone currently lives, and records can be outdated or incomplete. Analysts also note that tax data do not cover everyone, and that addresses can be stale or nonresidential.
The concern is also measurable. In a Census Bureau simulation, about 8.4 percent of IRS 1040 records lacked a residential address and could not be linked to Bureau files. Even a small share of missed households, concentrated in low-income communities, becomes a large undercount where our patients live.
We need accurate Census data to serve our communities
As an epidemiologist, I think of the Census as the baseline data source for nearly everything we do. I use Census data in community assessments, grant applications, and other services for Free and Charitable Clinics, and it is irreplaceable. The count not only guides the distribution of federal and state funding for the next decade, it serves as a denominator for us to describe our communities to funders and explain the impact of our work. An undercount of the communities we serve means weaker data for planning, funding requests, and collaboration with partners.
What I asked the Census Bureau to do
My recommendations to the Census Bureau address these concerns well. If you have the opportunity to comment, you are free to use these.
Withdraw the proposed rule in its current form, including the requirement that usual residence be consistent with and evidenced by tax records.
Retain the established usual residence standard, where a person lives and sleeps most of the time, rather than a January 3 to April 1 day count.
Keep administrative records in their established role, which is to help count people who did not respond. Records should never serve as a test that a self-reported address must pass.
Limit any retained use of administrative records to use alongside multiple sources and field follow-up, consistent with the Bureau’s own research. The rule should include documented procedures for people who have no records, for conflicting addresses, for P.O. box and other nonresidential addresses, and for students, children, and seasonal residents.
Publicly document the record-linkage plan, validation rules, and results before any final rule, consistent with Census Bureau Statistical Quality Standard C4: Linking Data Records. That standard calls for a plan covering the objectives, the files to be linked, verification and testing, staff training, and evaluation of link rates and error rates, and for documentation sufficient to replicate and evaluate the linkage.
Publish, before any final rule, an analysis of the expected coverage effects by income, age, race and ethnicity, housing status, and geography, including for American Indians and Alaska Natives who live part of the year on and off reservation lands, and invite public review of that analysis.
Publish and respond to the feedback received from tribal governments in the October 2, 2026 consultation, and extend consultation to urban Indian organizations before any final rule.
Continue to set residence criteria through the established notice-and-comment process with full testing, so that stakeholders and the public can evaluate changes well ahead of 2030.
Add your voice
The comment period closes November 4, 2026. Free and Charitable Clinics and their partners are well positioned to describe, in concrete terms, who would be missed. Even a short comment about your patients carries weight. Comment here: https://www.regulations.gov/document/USBC-2026-0628-0001
Resources
Download my full length comment:
See my previous post about the proposed changes to race and ethnicity data collection in the 2030 census and corresponding federal comment.
Learn more about how I work with Free and Charitable Clinics.
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