Note to Reviewer - Non-sub Change Request for 81 Comments in Regulations.gov

December 16, 2025

Memorandum for: Reviewer of 1220-0175

CC: Nicholas Johnson

From: Rose Woods

Stephanie Denton

Subject: Comments received in regulations.gov on the American Time Use Survey

The American Time Use Survey (ATUS) was approved for continued collection on September 29, 2025. Later, BLS was made aware of additional comments made on the 30-day Federal Register notice outside of the normal process, which requests that comments be submitted to “reginfo.gov.” The additional comments were submitted to “regulations.gov,” and thus BLS was not aware of them until after the approval process was complete. There were 81 comments received on “regulations.gov” in total, 79 unique comments and 2 duplicate comments. All of the comments were in overwhelming support of the continued collection of the ATUS.

Many commenters noted the many uses of ATUS data and the unique nature of the data. Below are just a few examples of the comments received.

“…[The ATUS] is the only data source available for studying how adults spend their time with children, spouses and partners, and their own parents and the tradeoffs people make in terms of their personal time, work time, and leisure in order to prioritize family time…When we discuss the idea that everyone has the same number of minutes in a day but different constraints on how they can use it, the data provides an eye-opening view into how circumstances like age, health status, educational attainment, and work schedule fundamentally shape the way we are able to care for ourselves and others.”

“The ATUS equips policymakers, researchers, journalists, community and business leaders, and the public with a critical and irreplaceable resource to understand and support uses of time that promote social and economic well-being for communities and individuals across the United States.”

“The ATUS is unique in offering nationally representative, detailed data on how people allocate their time, thereby enabling rigorous analysis of household activities that are often invisible in traditional labor market surveys. This facilitates research that is not abstract or purely theoretical but grounded in the empirical realities of people’s daily lives. Moreover, because of the ATUS, U.S. researchers can engage with global time-use research and conduct cross-national comparisons, as it serves as a critical baseline for similar surveys worldwide.”

In addition to expressing support for the ATUS, a few comments included suggestions for improvements to the ATUS. The comments are described individually below along with BLS responses.

Two commenters suggested expanding the sample size of the ATUS and adding new questions. One of the commenters suggested expanding subject areas to include information on adult and childcare received by household members from people outside the household; hours of childcare, adult care, and help with housework purchased and associated costs; and better information on earnings, transfers, and nonlabor income received by household members. The other commenter recommended adding a question on whether individuals typically work on the weekend.

Expanding the scope and sample size of the ATUS and adding new questions to the survey would expand the length and cost of the survey, as well as the burden on ATUS respondents. It is not feasible to expand the survey at this time due to budgetary constraints. An avenue for adding questions to the survey exists through sponsorship of an ATUS Module. An ATUS Module is a temporary set of questions added to the end of the regular time-use survey that is designed to elicit information about a special topic. While not a regular part of the survey, the Leave and Job Flexibilities Module did include a question about days of the week respondents typically worked in 2017-18 and 2024-25.

One of the above commenters also recommended that every person older than 15 years in the sample household should be queried rather than just one person, as they feel this is crucial to understanding the intrahousehold division of household work and care.

BLS recognizes the importance of measuring the intrahousehold allocation of time and did consider these measures when planning and developing the ATUS. However, due to budgetary constraints and data quality concerns, BLS found these measures too difficult to capture with the structure of the ATUS. For further information on considerations that went into designing and implementing the ATUS, including a discussion on the units of measurement considered, see “Planning, designing, and executing the BLS American Time-Use Survey” (Horrigan and Herz, 2004).

One commenter encouraged ATUS not to change the current methodology for data collection. They stated that automated collection techniques would produce worse results in data collection, would substantially increase nonresponse bias, would decrease coverage, and would substantially reduce survey completion rates. They stated that resorting to other forms of information technology to collect information would substantially harm the quality of the data collected, noting that the only way to get accurate and reliable data on time use is to ask sampled respondents directly and that using other forms of information technology would necessarily involve a great deal of data imputation, which would substantially diminish the quality and usefulness of the data.

BLS is currently exploring a mixed mode design for the ATUS which would introduce a web mode in which respondents can answer the survey. A move to a mixed-mode design could potentially help ATUS improve response and be prepared for the survey climate of the future. At this time, automated collection techniques are not under consideration for the ATUS. Before adopting any change in the ATUS methodology, extensive testing will be done to ensure the ATUS continues to produce high quality data.

One commenter encouraged regularly conducting the Leave and Job Flexibilities Module of the ATUS. They noted that although research makes clear that paid leave supports people’s employment and quality of life, comprehensive, intersectional paid leave data are rare, and researchers examining the need for paid leave, optimal program design, and innovative policy opportunities have found that existing data leave many important questions unanswered.

The cost of running the Leave and Job Flexibilities Module, like all ATUS modules, is borne by the module sponsor. Because of budgetary constraints, it is not possible for the ATUS to conduct the Leave and Job Flexibilities Module on a regular basis without sponsor support.

The same commenter also recommended publishing additional tables based on data already collected. Specifically, they recommended that BLS publish tables broken down by disability status for various categories of time use as well as publish data on the intersection of multiple demographic categories to increase the utility and clarity of the available information. They also recommended expanding data collection to provide full information for all Office of Management and Budget racial categories.

BLS produces hundreds of unpublished tables using ATUS data that show time use by various demographic categories, including age, employment status, sex, race, weekend day/weekday, presence and age of children in the household, marital status, disability status and more. These tables are available by request and are regularly sent out by ATUS staff. Please contact ATUSinfo@bls.gov to request unpublished tables.

One commenter noted that while ATUS data files and documentation are generally clear and well maintained, guidance on how best to incorporate survey weights (particularly regression analyses) could be improved.

BLS strives to provide helpful documentation for data users to more easily use ATUS data. ATUS staff regularly review materials for clarity and will take this suggestion into account when updating materials.

The same commenter also suggested continued exploration of user-friendly, automated, or online diary tools to further streamline participation.

BLS is currently exploring a mixed mode design for the ATUS which would introduce a web mode in which respondents can answer the survey. Implementation of a web mode has not yet been scheduled, since research and development is still ongoing.

All comments received have now been posted to regulations.gov and are available in the attached document loaded into reginfo.gov.