Comments by Richard Besser, MD, on Proposal to Improve Information-Sharing Between IRS and Census

The following comments were submitted by Richard Besser, MD, Robert Wood Johnson Foundation (RWJF) President and CEO, on the U.S. Department of the Treasury and the Internal Revenue Service’s proposed rule, “Disclosures of Return Information Reflected on Returns to Officers and Employees of the Department of Commerce, Including the Bureau of the Census, for Certain Statistical Purposes and Related Activities” (hereinafter “2024 Proposed Rule”).

RWJF is committed to improving health and health equity for all in the United States. In partnership with others, we are working to develop a Culture of Health rooted in equity that provides every individual with a fair and just opportunity to thrive, no matter who they are, where they live, or how much money they have. 

Health is more than an absence of disease. It is a state of physical, mental, and emotional wellbeing. It reflects what takes place in our communities, where we live and work, where our children learn and play, and where we gather to worship. That is why RWJF focuses on identifying, illuminating, and addressing the barriers to health caused by structural racism and other forms of discrimination, including sexism, ableism, and prejudice based on sexual orientation. 

We rely on evidence to advance health equity. We cultivate leaders who work individually and collectively across sectors to address health equity. We promote policies, practices, and systems change to dismantle the structural barriers to wellbeing created by racism. And we work to amplify voices to shift national conversations and attitudes about health and health equity.  

RWJF offers its strong support for the 2024 Proposed Rule, which authorizes the IRS to expand the disclosure of Federal Tax Returns and Return Information (FTI) to the Census Bureau (Bureau). The proposed changes would enable the Bureau to produce data that provides more detail about the economic conditions of various populations across the U.S., including populations that have been historically underserved, marginalized, and adversely affected by health inequity, for example, women, people of color, households with children, older adults, and immigrants. Our support for the proposed rule is grounded in the perspectives and expertise of our grantees, which include academic researchers, policy experts, advocates, and organizers with significant experience conducting independent research into racial disparities in tax administration.  

While the new rule will enable independent research to raise as many questions as it can answer, data that depicts a more accurate portrait of America is truly something to applaud. By way of illustration, in 2016, RWJF supported independent research to construct The Opportunity Atlas, a publicly available series of interactive maps that track economic opportunity by Census tract using anonymized longitudinal data covering nearly the entire United States population. Through this project, we learned that cooperation between the Bureau, IRS, and independent researchers is an incredibly strong tool to identify ways to improve opportunity for children across the United States. The Opportunity Atlas facilitates research to help policymakers and communities better understand the systemic impacts of policies and programs on places and people as well as to identify opportunities to promote healthier, more equitable communities. Similarly, the proposed rule holds the promise of providing key data to help us build toward an inclusive economy. 

Through our grantmaking, RWJF supports efforts to increase the fairness of the tax system, including work to address features of the tax system that have historically reinforced racial wealth disparities. Implementation of the proposed rule would support the work of our grantees who seek to use reliable analysis of tax data to understand who benefits from our tax system, who is systematically disadvantaged by our tax system, and how to address racial inequities and other inequities that new data may reveal.  

RWJF also supports efforts to ensure that the Treasury Department’s public-facing policies, programs, and practices benefit all Americans and that all people in the United States can fully participate in and benefit from the economy. The appropriate transfer of FTI data to the Bureau supports the work of the Treasury Department and other parties to advance racial equity in the economy and can support efforts to strengthen how policymakers determine the allocation of federal resources to advance racial and health equity. In turn, funding provided to federal agencies can better attend to families, child development, and the type of tax and care systems necessary to ensure that all families in the United States have a fair and just opportunity to be as healthy as possible.  

We look forward to continuing to work with the Treasury Department, IRS, and other partners to ensure that everyone has the opportunity to achieve optimal health and wellbeing. 

About the Robert Wood Johnson Foundation

The Robert Wood Johnson Foundation (RWJF) is committed to improving health and health equity in the United States. In partnership with others, we are working to develop a Culture of Health rooted in equity that provides every individual with a fair and just opportunity to thrive, no matter who they are, where they live, or how much money they have.