The Council submitted comments to the U.S. Census Bureau opposing proposed significant changes to how the 2030 Decennial Census counts people and collects demographic data.
The proposed changes, however, would undermine the census’s ability to provide a fair and accurate count of the people living in America. If implemented, the proposal would exclude broad categories of people, including international students, H-1B visa holders, undocumented people and others, from the population count used to allocate congressional seats and federal funding. The proposed regulation would also eliminate questions on race and ethnicity from the census, an unprecedented departure from the census’s longstanding practice of collecting this critical information. These changes would undercount the number of people living in communities, reducing access to federal resources and political representation, and they would make it harder to understand and address racial disparities.
Read the full comments below. If you have any questions on the Council’s comments, please reach out to Caroline O’Neill at coneill@providers.org.
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November 2, 2026
Re: Docket No. USBC-2026-0628, Department of Commerce, Census Bureau, Decennial Census of the Population of Americans; Proposed Residence Criteria and Proposed Regulations for Demographic Questions
To the U.S. Census Bureau:
Thank you for the opportunity to comment on the U.S. Department of Commerce’s proposed changes to the Code of Federal Regulations governing the decennial census. My name is Bill Yelenak, and I am president and CEO of the Providers’ Council, the largest human services trade association in Massachusetts. We represent 220 community-based human services organizations across the Commonwealth, which together provide care to hundreds of thousands of residents, from housing stabilization and early intervention to behavioral health and disability supports. An accurate and complete census count is essential to helping our members understand where services are needed and secure the funding necessary to deliver them.
We object to the proposal to exclude lawfully present noncitizens, including international students and H-1B visa holders, along with undocumented residents, from the population count. The Fourteenth Amendment directs that House seats be apportioned by the “whole number of persons in each State,” and the Bureau has counted all residents for more than two centuries. Our sector also reflects the diversity of the communities it serves. According to a 2026 workforce study by the Providers’ Council and the UMass Donahue Institute, nearly one in four human services workers in Massachusetts are foreign-born. Excluding residents who live, work, and study in our communities from the count would leave an incomplete picture of the population and undermine efforts to plan and fund the services they and their neighbors rely on.
We also object to the proposed ban on questions about race, ethnicity, and sexual orientation. Our sector is 38 percent people of color, and our organizations intentionally design programs to reach communities that continue to experience documented disparities in housing, behavioral health, and other essential services. Without demographic data, providers will struggle to demonstrate community need, design culturally responsive programs, and show funders where disparities persist.
We are also deeply concerned about the proposal to count individuals at the location where they have spent the most days between January 3 and April 1. This is an arbitrary time period that may lead to people being counted incorrectly or missed entirely. In particular, this proposal will impact students, individuals visiting family, older residents who spend the winter months in warmer states, and those who are moving their residence. The proposed rule is also silent on how to count people experiencing homelessness and people living in group homes, residential treatment programs and other congregate settings – the very residents our members serve.
Lastly, we would like to raise concern over the proposal to permit census officials to use a person’s tax record to verify their residence, which may lead to people being counted incorrectly or missed entirely. In particular, this proposal will impact people who move mid-year, students, seasonal workers, people paid informally, and people without stable tax filings.
Our members depend on federal and state funding that is distributed using the data collected by the decennial census. When a community is undercounted, the consequences are concrete: programs that serve it receive less funding, and the staff who deliver those services are stretched further. According to a 2026 survey, providers across Massachusetts are already managing a 15 percent vacancy rate in client-facing full-time positions and a 16 percent vacancy rate in part-time positions, far above the statewide job-openings rate of 3.3 percent. Shrinking the funding base in the communities our members serve would make those vacancies harder to fill and services harder to sustain.
The Census Bureau should withdraw the proposed rule, and it should retain the demographic questions that communities, nonprofits, and public agencies rely on to understand and serve the people who live here. A fair and complete census is essential to public trust and to the funding that keeps care available for Massachusetts residents.
Thank you for considering this input.
Sincerely,
Bill Yelenak
President/CEO
Providers’ Council
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