[dragonwriter]

No, those detailed individual non-race factors are being used as a better measure of actual disadvantage than race, just as the opponents of race-based affirmative action in admissions always argued they should be, because race-based admissions risked favoring the rare already-advantaged members of races whose members were on-average disadvantaged while doing nothing for the truly disadvantaged regardless of race.

(Of course, perhaps they did so dishonestly with the hope that raced-based affirmative action would get axed but that alternative race-blind alternative measures wouldn't materialize.)

Now, do they have racially disparate impact? Only insofar as actual adversity does.