Early Futures Partnership submitted this comment on the Administration’s proposed changes to questions for the 2030 census, including residence criteria and regulations for demographic questions. We urge Nebraskans to learn more about the proposal and submit their own comment in opposition before the November 2 deadline. Learn more about the proposed changes
Thank you for the opportunity to submit public comment to Notice of Proposed Rule Making (NPRM): “Decennial Census of the Population of Americans; Proposed Residence Criteria and Proposed Regulations for Demographic Questions,” Docket No. 260903-0005 (RIN 0607-AA75).
Early Futures Partnership, a nonprofit in Nebraska supporting early childhood community practice and public policy, is writing to share concerns about the proposed changes to the 2030 decennial census. As advocates for Nebraska’s youngest children, it is critical that every child is included in an accurate count of the state’s population. Not only do decennial census counts ensure that Nebraskans are fairly represented in Congress, but accurate census counts are fundamental to strong economic policies, effective federal and state program outcomes and successful public health initiatives affecting thousands of children and families in Nebraska, as well as nationwide.
Opposition to Proposed Changes
Our primary concern is that the proposed residence criteria outlined in the current NPRM will lead to severe undercounts of children, limiting communities’ resources to address local needs, which affects all residents. According to the 2024 American Community Survey (ACS), there were an estimated 149,056 children under age 6, which accounts for 7.7% of 1.93 million total Nebraska residents.[i] Because Nebraska is one of the smaller states by population, it is especially important that all residents, including children, are counted accurately in each decennial census. The 2020 census was estimated to undercount children living in Nebraska age 0 to 4 by 3.1% with most undercounts coming from rural counties.[ii] This suggests that further undercounts would significantly underrepresent the number of young children living in rural communities in Nebraska.
Two specific proposed changes will result in undercounts of Nebraska children. First, the NPRM proposes asking parents about their citizenship on the short-form census questionnaire. The addition of a citizenship question will likely increase nonresponse rates among all immigrants, regardless of their current status. An estimated 19% of Nebraska children under age 6 have at least one immigrant parent,[iii] and implementing this change will impact the ability to count children under 6. Second, the NPRM proposes linking residence criteria to tax records. In Nebraska, an estimated 10,000 children under 6 currently live in households with incomes below the federal filing threshold,[iv] many of whom live in rural counties where undercounts would negatively harm these communities.
In addition to undercounts, we are also concerned about the NPRM proposal to remove demographic questions from the 2030 decennial census. The removal of demographic information will substantially undermine the accuracy of the ACS, among other federal datasets. The ACS is an important tool in our work at Early Futures Partnership, allowing us to measure local needs, as well as effective implementation of programs and policies.
Proposed Changes Impact Nebraska’s Early Childhood Ecosystem
We oppose the changes to the decennial census outlined in the NPRM because they will undercount Nebraska residents, particularly children, and impact the accuracy and usability of federal data sets. Because Early Futures Partnership prioritizes early childhood issues, the decennial census and the federal datasets that are born from the census are foundational to the work of informing and building policies that strengthen the supports for children, families and early childhood professionals across Nebraska. The list below highlights some, but not all, of the anticipated negative impacts should the NPRM be adopted.
Communities for Kids, an initiative of Early Futures Partnership, uses census data to estimate the number of children living in a community who need child care, but currently do not have access to a slot. This gap analysis is then used to measure the impact of each community’s plan for expanding local child care. Undercounting young children will negatively impact communities’ ability to plan and implement solutions.
First Five Nebraska, an initiative of Early Futures Partnership, uses census data across a wide variety of research projects, working with policymakers to make administrative and legislative changes that strengthen working parents’ access to child care. Policymakers rely on accurate data not only to create the policy, but to accurately estimate the fiscal impact of policy changes. Undercounting young children will negatively impact this process.
Nebraska’s Child Care Tax Credit Act includes a provision to provide a nonrefundable tax credit for individuals or organizations who expand child care options within census tracts identified by high poverty rates and low median family incomes (i.e., Opportunity Zones).[v] Because census data informs geographic boundaries, as well as population estimates, states need to know where population-level changes occur so they can develop strategies for supporting early childhood issues. This is particularly important in states with large rural areas, such as Nebraska, where distances between communities increase the cost and complexity of collecting reliable data.
Child care providers in low-income areas are eligible to receive a higher reimbursement rate for the federal Child and Adult Care Food Program, which uses census data to identify poverty rates within a child care provider’s area.[vi] Undercounting families within low-income areas may lead to additional operational costs for struggling child care businesses.
In addition to poverty income requirements, some Head Start and Early Head Start services in Nebraska offer services exclusively to children who come from migrant families, families who work in agriculture and families living on tribal lands. Undercounting these children may lead to reduced Head Start funding, which will lead to larger impacts on local economies.
Funding for Medicaid and the Children’s Health Insurance Program (CHIP) rely on accurate census data. In Nebraska, 38% of births are covered by Medicaid.[vii] Ensuring Nebraska receives sufficient funding for these programs is vital to child and maternal health, and undercounting children will negatively impact federal funding.
Conclusion
To address Nebraska’s most urgent early childhood challenges, Early Futures Partnership advocates for every Nebraskan to have a stake in policies that shape the practice of early care, education and healthy development of young children. Yet, the children who are most likely to be undercounted are the same children who will need support services the most.
These children come from households near or below the federal poverty level who lack access to high-quality child care or require services that promote maternal health and optimal child development. Undercounting children and their families who work to support them has a ripple effect across other parts of the early childhood ecosystem. It is for this reason that we oppose the NPRM for the decennial census and request that it be rescinded.
Thank you again for the opportunity to submit public comment.
Sincerely,
Marti Beard and Jason Prokop
Co-Presidents
Early Futures Partnership
[i] U.S. Census Bureau. (2026). Age by ratio of income to poverty level in the past 12 months (Subject Table B17024). 2025 American Community Survey 5-year Estimates. https://data.census.gov/table/ACSDT5Y2024.B17024?q=B17024&g=040XX00US31
[ii] U.S. Census Bureau. (2024, April). State and county net coverage error estimates for children aged 0 to 4 in the 2020 Census. U.S. Department of Commerce. https://www.census.gov/library/visualizations/interactive/net-coverage-error-young-children.html
[iii] Migration Policy Institute. (2026). Share of all children in immigrant vs. U.S.-born families, by state, 2000 and 2024. https://www.migrationpolicy.org/data-tool/children-immigrant-us-born-families
[iv] U.S. Census Bureau (2026). 2024 American Community Survey 1-year Estimates (Public-use microdata). Data were accessed from Steven Ruggles, Sarah Flood, Matthew Sobek, Daniel Backman, Grace Cooper, Julia A. Rivera Drew, Stephanie Richards, Renae Rodgers, Jonathan Schroeder, and Kari C.W. Williams. IPUMS USA: Version 16.0 [dataset]. Minneapolis, MN: IPUMS, 2025. https://doi.org/10.18128/D010.V16.0
[v] Nebraska Department of Economic Development. (2026, February). Opportunity zones. https://opportunity.nebraska.gov/programs/business/opportunity-zones/
[vi] Food and Nutrition Administration. (2007, June). Documentation of tier I eligibility determinations in the Child and Adult Care Food Program [Memo Code: CACFP 08-2007]. U.S. Department of Agriculture. https://www.fna.usda.gov/documentation-tier-i-eligibility-determinations-child-and-adult-care-food-program
[vii] Nebraska Department of Health and Human Services. (2025). Vital statistics: Birth dashboard (2024 finalized data). https://dhhs.ne.gov/Pages/Public-Data-Dashboards.aspx